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November 8, 2024 Page 18 7357-013acp printed on recycled paper Following their review of the Project’s CalEEMod output files, SWAPE finds that the DEIR failed to account for emissions generated by material import and export from the Project site, and relied on input values that were inconsistent with information disclosed in the DEIR. As a result, the Project’s reactive organic gases, nitrogen oxide (“NOx”), exhaust PM10 and exhaust PM2.5 emissions associated with Project construction were underestimated.84 As SWAPE shows, the DEIR’s conclusions are not supported by the evidence because they rely on a CalEEMod model that underestimates emissions and on mitigation measures that are unverified and unenforceable. SWAPE concludes that the DEIR fails to accurately characterize the Project’s construction length resulting in a significant underestimation of the Project’s air pollutant emissions.85 The DEIR includes unsubstantiated construction phase length in the modeling.86 The DEIR’s construction air quality modeling therefore underestimates the peak daily emissions associated with construction and is not supported by substantial evidence.87 Further, the DEIR provides that “[a]ccording to the applicant-provided information, the grading would not lead to significant import or export material. Material movement would be limited to an off-site location, which is within 1 mile of the residential project site.”88 The DEIR states that import and export of grading material would be limited to an off-site location.89 But the DEIR’s air quality modeling relies on CalEEMod inputs that provide that there will be zero cubic yards of material imported and exported from the Project site associated with Site Preparation, Grading, or Paving.90 The air quality modeling associated with “Construction Earthmoving Activities” is therefore unsupported by substantial evidence.91 SWAPE concludes that “[t]he inclusion of material import and export within the model is essential for accurately calculating emissions generated from material movement, which encompasses truck loading and unloading, as well as additional hauling truck trips.”92 By failing to include the amount of material import required for Project construction, the model has underestimated the Project’s construction-related emissions.93 84 SWAPE Comments, p. 4. 85 Id. at 3. 86 Id. 87 Id. 88 DEIR, p. 3.2-46. 89 Id. 90 DEIR, Appendix B: Air Quality, Greenhouse Gas, and Energy Supporting Information, p. 78. 91 Id. at 117. 92 SWAPE Comments, p. 5. 93 SWAPE Comments, p. 5.