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specific values, but the California Environmental Quality Act (CEQA) requires that such changes be justified by substantial evidence.' Once all of the values are inputted into the model, the Project's construction and operational emissions are calculated, and "output files" are generated. These output files disclose to the reader what parameters were utilized in calculating the Project's air pollutant emissions and make known which default values were changed as well as provide justification for the values selected.' Review of the Project's air modeling demonstrates that the Addendum underestimates emissions associated with Project activities. As previously stated, the Addendum's air quality analysis relies on air pollutant emissions calculated using CalEEMod. When reviewing the Project's CalEEMod output files, provided in Appendix C to the Addendum, we found that several of the values inputted into the model were not consistent with information disclosed in the Addendum. As a result, the Project's construction and operational emissions are underestimated. A DEIR should be prepared to include an updated air quality analysis that adequately evaluates the impacts that construction and operation of the Project will have on local and regional air quality. Failure to Include All Proposed Land Uses Review of the Project's CalEEMod output files demonstrates that not all of the land uses proposed by the Addendum were included in the air model. As a result, the Project's construction and operational emissions are underestimated. According to the Addendum, the proposed Project would include 332 parking spaces (p. 1-1). However, review of the Project's CalEEMod output files demonstrates that the model failed to include any amount of parking (see excerpt below) (Appendix C, pp. 135, 163, 188). Stw Mall .,...., ..,.. .,....,.... 1235 .... ........ 1000Fgft .....,.. ..,0.28, 12.350.00 ...... 0 As you can see in the excerpt above, the model failed to include any amount of parking. The land usage parameters, including land use types and sizes, are used throughout CalEEMod to determine default variables and emission factors that go into the model's calculations.' For example, land use areas are used for certain calculations such as determining the wall space to be painted (i.e., VOC emissions from architectural coatings) and volume that is heated or cooled (i.e., energy impacts). Therefore, by failing to include the proposed parking land use in the air model, the construction and operational emissions are ' CAPCOA (November 2017) CalEEMod User's Guide, http://www.agmd.gov/docs/default- source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=41 p. 1, 9. 3 CAPCOA (November 2017) CalEEMod User's Guide, http://www.agmd.gov/docs/default- source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4, fn 1, p. 11, 12 — 13. A key feature of the CalEEMod program is the "remarks" feature, where the user explains why a default setting was replaced by a "user defined" value. These remarks are included in the report. 4 "CalEEMod User's Guide." CAPCOA, November 2017, available at: http://www.agmd.gov/docs/default- source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=41 p. 18. 2