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by the Project, in a currently non-residential area. The comment further states that California law requires a project -specific application and analysis, and the Project fails to provide a project -specific analysis of how code compliance translates to sufficient mitigation. Response 16: The Draft EIR describes on page 5.1-19 that nighttime lighting associated with the existing urban development is present both onsite and within the surrounding area, and includes streetlights along Red Hill Avenue and Warner Avenue, parking lot and building fagade lighting, interior illumination passing through windows, and illumination from vehicle headlights. Also, page 5.1-33 describes that all of the Project's outdoor lighting would be hooded, appropriately angled away from adjacent land uses. It also describes that the Project would be required to comply with the City's lighting regulations that would be verified by the City's Planning and Building Agency during the permitting process. Because lighting exists on the Project site area, the increase in light that would be generated by the Project would not be substantial. As the lighting standards are part of the City's development standards and would be imposed in the same manner as the rest of the development standards related to the Project, pursuant to the municipal code. The City's standard development review and permitting process involves verification that all of the development standards applicable to the Project, including lighting, are implemented, which would ensure that impacts related to lighting would be less than significant. Comment 17: The comment asserts that the air quality analysis is flawed because the input parameters used with CaIEEMod were not consistent with information disclosed in the Draft EIR and that vehicle emissions factors used to estimate the proposed Project's operational emissions were changed from the CaIEEMod default values without proper justification. The comment further contends that as a result, the Project's construction and operational emissions are underestimated and a new EIR should be prepared. Response 17: The comment asserts that unsubstantiated changes were made to the CaIEEMod default values for operational emissions. The California Air Resources Board (CARE) released EMFAC2017 as its latest emissions inventory model. It should be noted that the air districts recommended California Emissions Estimator Model (CaIEEMod) v 2016.3.2 does not yet incorporate EMFAC2017 when calculating emissions. As such, post -processing of EMFAC2017 emissions data for import into CaIEEMod was completed in the modeling, as noted in the model output data sheets that are included in the Draft EIR for review. Comment 18: The comment asserts that the pass -by trip percentages utilized in the air quality model are inconsistent with the Traffic Impact Analysis and as a result the model may underestimate the Project's mobile -related operational emissions. Response 18: The default pass -by and vehicle percentages were adjusted to reflect the internal capture identified in the trip generation data provided to Urban Crossroads, Inc. at the time the AQIA was prepared. It should be noted that CaIEEMod does not include an option to account for internal capture — and in fact, use of the pass -by model option is likely a conservative representation since the pass -by category assigns a trip length of 0.1 miles to every trip, per CaIEEMod guidance. Notwithstanding, as noted in the Draft EIR and as summarized by the commenter in subsequent comments, the total trips identified in the final traffic study include 12,872 daily vehicle trips after accounting for pass -by and internal capture. As the commenter summarizes in their comments and as presented in the Draft EIR, the AQIA and underlying associated technical analysis is based on 16,400 daily trips which is higher than the final trip generation in the traffic study. As such, the AQIA likely overstates rather than understates any potential impacts from vehicular activity. Comment 19: The comment asserts that the Saturday and Sunday trip rates are incorrect and that the number of vehicle trips is higher than the input parameter figures used in CaIEEMod and thus the trip estimates are incorrect and cannot be relied upon. 75C-200