3 - The Bowery_PUBLIC COMMENT_RAMSEY

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3 CalEEMod separates the operational trip purposes into three categories: primary, diverted, and pass-by trips. According to Appendix A of the CalEEMod User’s Guide, the primary trips utilize the complete trip lengths associated with each trip type category. Diverted trips are assumed to take a slightly different path than a primary trip and are assumed to be 25% of the primary trip lengths. Pass-by trips are assumed to be 0.1 miles in length and are a result of no diversion from the primary route.5 Review of the Project’s CalEEMod output files demonstrates that the trip purpose percentages are inconsistent with the trip purpose percentages indicated by the DEIR (see excerpt below) (Appendix B, pp. 330, 391). As you can see in the excerpt above, the model assumes a 3% pass-by percentage for the apartment land use, 17% for the fast food restaurant without drive-through, 69% for the fast food with drive- through, 79% for the high turnover (sit down restaurant), 76% for quality restaurant, and 76% for regional shopping center. However, these values are inconsistent with the pass-by trips indicated by the DEIR. Based on the DEIR’s Proposed Project Trip Generation table, the apartment and parking land uses are not expected to generate any pass-by trips, the fast food restaurant without drive through is expected to generate 17%, the fast food restaurant with drive-through is expected to generate 31%, the high turnover (sit down) restaurant is expected to generate 21%, the quality restaurant is expected to generate 22%, and the regional shopping center/retail land use is expected to generate 24% (5.14-11, Table 5.14-5). By including primary trip percentages that are inconsistent with information provided in the DEIR, the model may underestimate the Project’s mobile-related operational emissions and should not be relied upon to determine Project significance. Use of Incorrect Saturday and Sunday Trip Rates Review of the Project’s CalEEMod output files demonstrates that the Saturday and Sunday trip rates inputted into the model are incorrect. The number of daily trips, including pass-by trips, are indicated in the DEIR (see excerpt below) (p. 5.14-11, Table 5.14-5). • the apartment land use is estimated to generate 6,092 daily trips; • the high-turnover sit down restaurant is expected to generate 2,740 daily trips; • the retail land use is expected to generate 636 daily trips; • the quality restaurant is expected to generate 2,067 daily trips; • the fast casual restaurant is expected to generate 1,564 daily trips; 5 “CalEEMod User’s Guide, Appendix A: Calculation Details for CalEEMod.” SCAQMD, available at: http://www.aqmd.gov/docs/default-source/caleemod/caleemod-appendixa.pdf?sfvrsn=2, p. 20