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City of Santa Ana— First American Mixed -Use Project [114 and 117 East Fifth Street] — Comments to City Council <br />November 18, 2019 <br />Page 8 of 13 <br />1. The Addendum Underestimated the Pr yect's Emissions <br />Mr. Hagemann and Mr. Rosenfeld state that the Addendum used unsubstantiated <br />input parameters to estimate project emissions. Exhibit C, p. 1-2. They explain that <br />the parameters inputted onto CalEEMod.2016.3.2. to calculate the Project's emissions <br />were incorrect and otherwise inadequate, which results in inaccurate emissions <br />information. <br />First, the Addendum fails to include all proposed land uses and as a result, <br />underestimated the Project's construction and operational emissions. Exhibit C, p. 2. <br />Specifically, the Addendum failed to include the Project's inclusion of 332 parking <br />spaces into the CalEEMod emissions calculation, which resulted in the failure to <br />account for the construction and operational emissions associated with such parking <br />spaces. <br />Next, the Addendum underestimated land use sizes by 1,000 feet of the Project's floor <br />surface area of the strip mall component of the Project. Exhibit C, p. 2. Moreover, the <br />Addendum underestimated Saturday and Sunday trip rates by approximately 59 and <br />320 trips, which also underestimated the emissions resulting from such trip rates <br />unaccounted for. <br />2. The Addendum Failed to Adequately Evaluate the Health Ricks Associated <br />with the Pr ject's Diesel Particulate Matter Emissions <br />According to Mr. Hagemann and Mr. Rosenfeld, diesel particulate matter (DPM) <br />health risk emissions was not adequately evaluated in the Addendum. The Addendum <br />incorrectly relied upon a Localized Significance Threshold (LST) analysis, rather than <br />conducting a quantified health risk assessment (HRA). Exhibit C, p. 4. Without a <br />quantified HRA, the Addendum's conclusion that the Project's health risk impacts will <br />be less than significant is unsupported. Id. <br />Moreover, the Addendum relies on a flawed CalEEMod model which underestimated <br />the excess cancer risk posed to nearby residents as a result of Project emissions. <br />Exhibit C, p. 4. <br />Finally, according to Mr. Hagemann and Mr. Rosenfeld, the omission of a quantified <br />HRA is inconsistent with the most recent guidance published by the Office of <br />Environmental Health Hazard Assessment (OEHHA), which is the organization <br />responsible for providing guidance on conducting HRAs in California. Exhibit C, p. 6. <br />OEHHA recommends all projects with construction lasting at least 2 months be <br />