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City of Sams Ana -The Bowery May 11, 2020 P.P to of 2s The DEIR concludes that would not have a significant aesthetic impact as to emitting substantial light or glare based upon stated future compliance with the Santa Ana Municipal Code that provides for building lighting specifications. However, the Project fails to analyze how compliance with the Code will adequately mitigate the substantial new source of light: the Project will create. The DEIR states that Santa Ana Municipal Code sections 41-611.1 and 41-1304 "provides specifications for shielding lighting away from Adjacent uses and intensily of security lighting " But how will this mitigate the significant impact on aesthetics for the Project? And just because the Project will comply with the City's lighting regulations does not mean that the amount of light. created for a project of this magnitude, in a currently non-residential area, will be adequately mitigated. California law requires a project -specific application and analysis, and the Project fails to provide a project -specific analysis of how code compliance translates to sufficient mitigation 4. The DEIR's At'r Qsrak'tyAna#sit isNot SA9 ppwed by Substantial Eridevee According to iVlr_ Hagcanann and I)r. Rosenfeld, the DEIR's air quality analysis is fundamentally flawed because the input parameters used with Call FM. od provided in Appendix B to the DHJR "were not consistent with information disclosed in the DEIR." (Hagemana at 2.) As a result, "the project's construction and operational emissions are underestimated" and a new FIR should be prepared. (Id) Unsubstantiated changes were made to vehicle emissions factors The first flaw in the input parameters, according to Mr. Hagemarm and Dr. Rosenfeld, is that "vehicle emissions factors used to estimate the pmposed Ptol cfs operational emissions were changed from the CaIEEMod default values without proper justification." (Id) Unverified and manually inputted values were used in the model which cannot be relied upon. (Id..) ii. Pass -by tap percentages utilized in the model are inconsistent with the Tial&c Impact.Analy-sis Second, "the Project's CalEEMod output files j... ] are inconsistent with the pass -by trip percentages indicaled by theTraffic Impact Aredysis..." (Id) According to the information provided by Mr. Hagemaun and Dr. Rosenfeld, and because the infonnaliou provided is inconsistent, "the model may undereslimate the Projcct's 16 17 18 75C-138