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5 <br /> <br /> <br />As you can see in the excerpt above, the total number of vehicle trips for Saturday and Sunday are lower <br />than those indicated by the DEIR for the apartments, fast food restaurant with and without drive <br />through, high turnover (sit down) restaurant, quality restaurant, and regional shopping center. Thus, the <br />trip rates inputted into the model for these land uses are underestimated and as a result, the model <br />incorrectly estimates the Project’s operational mobile-source emissions. <br />Unsubstantiated Reduction in Commercial-Work Trip Length in Existing Model <br />Review of the Project’s CalEEMod output files demonstrates that the commercial-work (C-W) trip length <br />was manually increased in the model without adequate justification. As a result, the model may <br />underestimate the Project’s operational emissions. <br />Review of the Project’s CalEEMod output files demonstrates that the Project’s C-W trip length was <br />manually increased from the default value of 16.60 miles to 40 miles (see excerpt below) (Appendix B, <br />pp. 562, 620). <br /> <br /> <br />As previously stated, the CalEEMod User Guide requires that any non-default values inputted must be <br />justified.6 However, review of the “User Entered Comments & Non-Default Data” table demonstrates <br />that this change was not justified or even addressed. The DEIR and associated appendices also fail to <br />address this reduction. As a result, we cannot verify that this trip length is accurate and, as a result, the <br />model should not be relied upon to determine Project significance. <br />Use of Incorrect Trip Purpose Percentages in Existing Model <br />Review of the Project’s CalEEMod output files demonstrates that the pass-by and diverted trip <br />percentages used in the model were manually altered without sufficient justification. As a result, the <br />model underestimates the Project’s operational emissions. <br /> <br />6 Supra, fn 1, p. 7, 13.