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S� PE Technical Consultation, Data Analysis and Litigation Support for the Environment 2656 29`" Street, Suite 201 Santa Monica, CA 90405 Matt Hagemann, P.G, C.Hg. (949) 887-9013 mhagemann@swape.com Paul E. Rosenfeld, PhD (310) 795-2335 prosenfeld@swape.com November 18, 2019 Mitchell M. Tsai 155 South El Molino Avenue Suite 104 Pasadena, CA 91101 Subject: Comments on the First American Mixed -Use Project (SCH No. 20006071100) Dear Mr. Tsai, We have reviewed the August 2019 Environmental Impact Report Addendum ("Addendum") for the First American Mixed -Use Project ("Project") located in the City of Santa Ana ("City"). The Project proposes to construct 220 residential units, 13,350 square feet of retail space, and 332 parking stalls on the approximately 1.7-acre site. Our review concludes that the Addendum fails to adequately evaluate the Project's Air Quality, Health Risk, and Greenhouse Gas impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project are underestimated and inadequately addressed. An updated Addendum should be prepared to adequately assess and mitigate the potential air quality and health risk impacts that the project may have on the surrounding environment. Air Quality Unsubstantiated Input Parameters Used to Estimate Project Emissions The Addendum's air quality analysis relies on emissions calculated with CalEEMod.2016.3.2.1 CalEEMod provides recommended default values based on site -specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project- 1 CAPCOA (November 2017) CaIEEMod User's Guide, http://www.agmd.gov/docs/default- source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4.