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City of Santa Ana – The Bowery <br />May 11, 2020 <br />Page 18 of 28 <br />The DEIR concludes that would not have a significant aesthetic impact as to emitting <br />substantial light or glare based upon stated future compliance with the Santa Ana <br />Municipal Code that provides for building lighting specifications. However, the Project <br />fails to analyze how compliance with the Code will adequately mitigate the substantial <br />new source of light the Project will create. The DEIR states that Santa Ana Municipal <br />Code sections 41-611.1 and 41-1304 “provides specifications for shielding lighting <br />away from adjacent uses and intensity of security lighting.” But how will this mitigate <br />the significant impact on aesthetics for the Project? And just because the Project will <br />comply with the City’s lighting regulations does not mean that the amount of light <br />created for a project of this magnitude, in a currently non-residential area, will be <br />adequately mitigated. California law requires a project-specific application and analysis; <br />and the Project fails to provide a project-specific analysis of how code compliance <br />translates to sufficient mitigation <br />4. The DEIR’s Air Quality Analysis is Not Supported by Substantial <br />Evidence <br />According to Mr. Hagemann and Dr. Rosenfeld, the DEIR’s air quality analysis <br />is fundamentally flawed because the input parameters used with CalEEMod <br />provided in Appendix B to the DEIR “were not consistent with information <br />disclosed in the DEIR.” (Hagemann at 2.) As a result, “the Project’s construction <br />and operational emissions are underestimated” and a new EIR should be <br />prepared. (Id.) <br />i. Unsubstantiated changes were made to vehicle <br />emissions factors <br />The first flaw in the input parameters, according to Mr. Hagemann and Dr. Rosenfeld, <br />is that “vehicle emissions factors used to estimate the proposed Project’s operational <br />emissions were changed from the CalEEMod default values without proper <br />justification.” (Id.) Unverified and manually inputted values were used in the model <br />which cannot be relied upon. (Id.) <br />ii. Pass-by trip percentages utilized in the model are <br />inconsistent with the Traffic Impact Analysis <br />Second, “the Project’s CalEEMod output files […] are inconsistent with the pass-by <br />trip percentages indicated by the Traffic Impact Analysis…” (Id.) According to the <br />information provided by Mr. Hagemann and Dr. Rosenfeld, and because the <br />information provided is inconsistent, “the model may underestimate the Project’s