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City of Santa Ana – The Bowery <br />May 11, 2020 <br />Page 19 of 28 <br />mobile-related operational emissions and should not be relied upon to determine <br />Project significance.” (Id. at 3.) <br />iii. Saturday and Sunday trip rates are incorrect. <br />Third, Mr. Hagemann and Dr. Rosenfeld’s review of the Project’s DEIR also revealed <br />that “the total daily trips calculated for Saturday and Sunday were underestimated for <br />each of the proposed land uses.” (Id. at 3-4.) The DEIR actually indicates that the <br />number of vehicle trips is higher than the input parameter figures used in CalEEMod <br />and thus the trip estimates are incorrect and cannot be relied upon. (Id. at 5.) <br />iv. Commercial-work trip length inputs are unjustified <br />Fourth, “the commercial-work (C-W) trip length was manually increased in <br />[CalEEMod]…” and the DEIR fails to provide any justification for this increase. (Id. at <br />5.) Because no rationale or justification was provided—the model cannot be relied <br />upon. <br />v. Pass-by and diverted trip percentages are unjustified <br />Lastly, the DEIR’s “pass-by and diverted trip percentages used in [CalEEMod] <br />were manually altered” and so the DEIR “underestimates the Project’s <br />operational emissions.” (Id. at 5; additional detail on p. 6.) According to Mr. <br />Hagemann and Dr. Rosenfeld, it is clear that “the model overestimates the <br />existing land use’s mobile-related operational emissions and should not be relied <br />upon to determine Project significance.” (Id.) The new values provided in the <br />DEIR were not adequately justified either because the reduction in pass-by and <br />diverted trips is not substantiated. (Id. at 6.) <br />For all of the above reasons, the DEIR’s air quality analysis is flawed because it is not <br />supported by substantial evidence. The EIR should be amended to adequately reflect <br />the true input parameters so that a reasonably accurate estimate of air quality impacts <br />can be analyzed and mitigated. <br />H. The City Failed to Include All Relevant Projects in its Cumulative <br />Impacts Transportation/Traffic Analysis <br />An EIR’s discussion of cumulative impacts is required by CEQA Guidelines <br />§15130(a). The determination of whether there are cumulative impacts in any issue <br />area should be determined based on an assessment of the project's incremental effects <br />“viewed in connection with the effects of past projects, the effects of other current