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specific values, but the California Environmental Quality Act ("CEQA") requires that such changes be justified by substantial evidence.' 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.' When reviewing the Project's CaIEEMod output files, provided in the Air Quality Assessment as Appendix B to the Addendum, we found that several model inputs were not consistent with information disclosed in the Addendum. As a result, the Project's construction and operational emissions are underestimated. A Project -specific 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. Use of an Underestimated CO2 Intensity Factor Review of the Project's CaIEEMod output files demonstrates that the default CO2 intensity factor was manually reduced from 702.44 pounds per megawatt hour ("Ibs/MWh") to 510.44 Ibs/MWh (see excerpt below) (Appendix B, pp. 80, 112, 232). I Table Name I Column Name I Default Value I New Value I 1671 ro. dbh , °leri ;t 66ilierellyFechtlr ............................. a.............................. 702.44 1 510.44 As you can see in the excerpt above, the default CO2 intensity factor was artificially reduced by approximately 27%. As previously mentioned, the CaIEEMod User's Guide requires any changes to model defaults be justified.' According to the "User Entered Comments & Non -Default Data" table, the justification provided for these changes is: "CO2 Intensity Factor adjusted per the SCE 2018 CRSR. The report provides intensity factor of CO2e, The CO2 intensity factor is calculated as 513-25*0.029-298*0.00617=510.4363 to avoid double counting" (Appendix B, pp. 79, 111, 231). However, review of the Edison International 2018 Sustainability Report demonstrates that the CO2 intensity factor is 513 Ibs/MWh.' As the Project fails to provide an adequate source for the values and calculations utilized in the "User Entered Comments & Non -Default Data" table justification, we cannot verify the revised value of 510.44 Ibs/MWh. As such, the Project should have used the 513 Ibs/MWh carbon intensity value. This underestimation presents an issue, as CaIEEMod uses the CO2 intensity 'Ca I EEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9. 'Ca I EEMod User Guide, available at: http://www.caleemod.com/, p. 11, 12-13. A key feature oft he CaIEEMod 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. 'CaIEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9 ' Edison International 2018 Sustainability Report, available at: http://www.aamd.gov/docs/default- source/caleemod/01 user-39-s-euide2016-3-2 15november2017.pdf?sfvrsn=4%20, p. 10 75C-77