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3 <br /> <br />not properly accounted for. Therefore, an updated air quality analysis should be prepared in an updated <br />DEIR to adequately evaluate the Project’s construction and operational air quality impacts. <br />Underestimated Land Use Size <br />Review of the Project’s CalEEMod output files demonstrates that the size of the proposed retail land use <br />was underestimated within the model, and as a result, emissions may be underestimated by the model. <br />According to the Air Quality and Greenhouse Gas Impact Analysis, provided as Appendix C to the <br />Addendum, “The proposed project would develop up to 220 apartment units and 13,350 square-feet (sf) <br />of retail/commercial floor area” (Appendix C, p. 1). However, review of the CalEEMod output files <br />reveals that an area value of 12,350 square feet was modeled for the retail land use (see excerpt below) <br />(Appendix C, pp. 135, 163, 188). <br /> <br />As you can see in the excerpt above, the model underestimated the retail land use by 1,000 square feet. <br />As previously stated, the land use type and size features are used throughout CalEEMod to determine <br />default variable and emission factors that go into the model’s calculations.5 As previously stated, the <br />square footage of a land use is used for certain calculations such as determining the wall space to be <br />painted (i.e., VOC emissions from architectural coatings) and volume that is heated or cooled (i.e., <br />energy impacts). By underestimating the size of the proposed retail land use, the model underestimates <br />the Project’s construction and operational emissions and should not be relied upon to determine Project <br />significance. <br />Underestimated Saturday and Sunday Trip Rates <br />Review of the Project’s CalEEMod output files demonstrates that the Saturday and Sunday trip rates for <br />the proposed Project are underestimated. As a result, the Project’s mobile-source operational emissions <br />are underestimated. <br />According to the Traffic Impact Analysis Report, provided as Appendix E-1 to the Addendum, the Project <br />is expected to generate approximately 1,420 net daily vehicle trips (see excerpt below) (Appendix E-1, p. <br />19). <br /> <br />5 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- <br />source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 18.