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6 <br /> <br />CalEEMod separates the operational trip purposes into three categories: primary, diverted, and pass-by <br />trips. According to Appendix A of the CalEEMod User’s Guide, the primary trips utilize the complete trip <br />lengths associated with each trip type category. Diverted trips are assumed to take a slightly different <br />path than a primary trip and are assumed to be 25% of the primary trip lengths. Pass-by trips are <br />assumed to be 0.1 miles in length and are a result of no diversion from the primary route.7 Review of the <br />Project’s CalEEMod output files demonstrates that all of the trips were assumed to be primary, with <br />pass-by and diverted trips artificially reduced to zero (see excerpt below) (Appendix B, pp. 446, 504, 562, <br />620). <br /> <br /> <br />As you can see in the excerpt above, the diverted and pass-by trips were manually reduced to zero, <br />while the primary trips were increased to 100 percent in the model. As previously stated, the CalEEMod <br />User’s Guide requires that any non-default values inputted into the model must be justified.8 According <br />to the “User Entered Comments & Non-Default Data” table, the justification provided for these changes <br />is: “Trip Rates based on information provided in the Trip Generation” (Appendix B, pp. 401, 459, 517, <br />575). However, the trip generation indicated in the DEIR fails to substantiate the reduction of pass-by or <br />diverted trips in the existing model. Thus, the model overestimates the existing land use’s mobile- <br />related operational emissions and should not be relied upon to determine Project significance. Failure to Implement All Feasible Mitigation to Reduce Emissions <br />The DEIR determines that the Project’s operational VOC emissions would exceed the applicable <br />SCAQMD threshold (see excerpt below) (p. 5.2-17, Table 5.2-8). <br /> <br />7 “CalEEMod User’s Guide, Appendix A: Calculation Details for CalEEMod.” SCAQMD, available at: <br />http://www.aqmd.gov/docs/default-source/caleemod/caleemod-appendixa.pdf?sfvrsn=2, p. 20 <br />8 Supra, fn 1, p. 7, 13.