CORRESPONDENCE - 60A - Laserfiche WebLink

Home Browse Search

not properly accounted for. Therefore, an updated air quality analysis should be prepared in an updated DEIR to adequately evaluate the Project's construction and operational air quality impacts. Underestimated Land Use Size Review of the Project's CaIEEMod output files demonstrates that the size of the proposed retail land use was underestimated within the model, and as a result, emissions may be underestimated by the model. According to the Air Quality and Greenhouse Gas Impact Analysis, provided as Appendix C to the Addendum, "The proposed project would develop up to 220 apartment units and 13,350 square -feet (sf) of retail/commercial floor area" (Appendix C, p. 1). However, review of the CalEEMod output files reveals that an area value of 12,350 square feet was modeled for the retail land use (see excerpt below) (Appendix C, pp. 135, 163, 188). ..........................Stnp Mall ...................... .................1i.3 ......................... ................... i66Es ft ...................... - .........0.28......... 12,350.00 ............0. �. As you can see in the excerpt above, the model underestimated the retail land use by 1,000 square feet. As previously stated, the land use type and size features are used throughout CaIEEMod to determine default variable and emission factors that go into the model's calculations.5 As previously stated, the square footage of a land use is 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). By underestimating the size of the proposed retail land use, the model underestimates the Project's construction and operational emissions and should not be relied upon to determine Project significance. Underestimated Saturday and Sunday Trip Rates Review of the Project's CaIEEMod output files demonstrates that the Saturday and Sunday trip rates for the proposed Project are underestimated. As a result, the Project's mobile -source operational emissions are underestimated. According to the Traffic Impact Analysis Report, provided as Appendix E-1 to the Addendum, the Project is expected to generate approximately 1,420 net daily vehicle trips (see excerpt below) (Appendix E-1, p. 19). 5 "CaIEEMod 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. 3