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5A Public Hearings 2021 0706
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5A Public Hearings 2021 0706
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CM City Clerk-City Council - Document Type
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7/6/2021
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Reso 2021-105 Callan & East 14th Project CUP, Parking and Site Plan
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6 <br /> <br />be used on site for a portion of the total building construction duration” and “MM: limit crane use” <br />(Appendix A, pp. 83, 105). Furthermore, the AQ & GHG Report provides the following off‐road <br />construction equipment assumptions (see excerpt below) (Appendix A, pp. 63): <br /> <br />However, these changes remain unsupported for two reasons. First, the Checklist fails to mention or <br />justify the revised off‐road construction equipment usage hours whatsoever. Second, the AQ & GHG <br />Analysis cannot simply assume that cranes would be used for fewer than 354 hours or that welders <br />would be predominately used during the initial framing phase. According to the CalEEMod User’s Guide: <br />“CalEEMod was also designed to allow the user to change the defaults to reflect site‐ or project‐ <br />specific information, when available, provided that the information is supported by substantial <br />evidence as required by CEQA” (emphasis added).9 <br />Here, as the Checklist fails to mention the changes and the AQ & GHG Report fails to provide substantial <br />evidence to support the revised off‐road construction equipment usage hours, we cannot verify the <br />changes. By including unsubstantiated changes to the default off‐road construction equipment usage <br />hours, the models may underestimate the Project’s construction‐related emissions and may constitute <br />an impact that more severe than was analyzed in the General Plan EIR or the Checklist. <br />Unsubstantiated Changes to Fleet Mix Percentages <br />Review of the CalEEMod output files demonstrates that the “Callan and E 14th Street Infill Checklist <br />Project Operations” model includes several changes to the default operational vehicle fleet mix <br />percentages (see excerpt below) (Appendix A, pp. 130‐131). <br /> <br />9 CalEEMod Model 2013.2.2 User’s Guide, available at: http://www.aqmd.gov/docs/default‐ <br />source/caleemod/usersguideSept2016.pdf?sfvrsn=6, p. 12. <br />121
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