3 - The Bowery_PUBLIC COMMENT_RAMSEY

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2 meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project- specific values, but the California Environmental Quality Act (CEQA) requires that such changes be justified by substantial evidence.2 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.3 Review of the Project’s air modeling demonstrates that the DEIR underestimates emissions associated with Project activities. As previously stated, the DEIR’s air quality analysis relies on air pollutant emissions calculated using CalEEMod. When we reviewed the Project’s CalEEMod output files, provided in Appendix B to the DEIR, we found that several of the values inputted into the model were not consistent with information disclosed in the DEIR. As a result, the Project’s construction and operational emissions are underestimated. An updated EIR 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. Unsubstantiated Changes to Vehicle Emission Factors The vehicle emission factors used to estimate the proposed Project’s operational emissions were changed from the CalEEMod default values without proper justification. As a result, the model should not be relied upon to determine Project significance. According to the Project’s CalEEMod output files, 1,185 of the vehicle emission factors were manually changed from their default values (Appendix B, pp. 114-158, 196-240, 277-321, 338-382). As previously stated, the CalEEMod User Guide requires that any non-default values inputted must be justified.4 According to the “User Entered Comments & Non-Default Data” table, the justification provided for these changes is: “EMFAC2017” (Appendix B, pp. 110, 193, 277, 338). However, EMFAC2017 refers to an entire database, not a specific set of vehicle emission factors or calculations. The “User Entered Comments & Non-Default Data” table or the DEIR should have specified which input parameters were used to obtain the vehicle emission factors inputted in the model. As a result, we cannot verify these values, and the model should not be relied upon to determine Project significance. Use of Incorrect Trip Purpose Percentages in Proposed Land Use Model Review of the Project’s CalEEMod output files demonstrates that the pass-by trip percentages utilized in the model are inconsistent with the pass-by trip percentages indicated by the Traffic Impact Analysis (TIA), provided as Appendix K to the DEIR. As a result, the model underestimates the Project’s operational emissions. 2 Ibid, p. 1, 9. 3 Supra, 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 Supra, fn 1, p. 7, 13.