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November 8, 2024 <br />Page 19 <br /> <br />7357-013acp <br /> printed on recycled paper <br />By failing to account for the total amount of material import and export that <br />will be needed during Project construction, the Project’s fugitive PM10 and PM2.5 <br />emissions and mobile-source emissions are also greatly underestimated.94 These <br />errors and omissions of basic input data from the DEIR’s air quality model render <br />the results of the DEIR’s air quality analysis artificially low and inaccurate. The <br />DEIR must be revised and recirculated to accurately calculate and mitigate the <br />Project’s significant air quality impacts. <br /> <br />ii. The DEIR’s Air Quality and GHG Modeling Relies on Nonbinding <br />Measures to Artificially Reduce Air Emissions <br /> <br />The DEIR includes mitigation measure (“MM”) AIR-3 which requires: <br /> <br />“Prior to the issuance of any demolition, grading, or building permits <br />(whichever occurs earliest), the project applicant and/or construction <br />contractor shall prepare a construction operations plan that, during <br />construction activities, requires all off-road equipment with engines greater <br />than 50 horsepower to meet particulate matter emissions standards for Tier 4 <br />interim engines.”95 <br /> <br />The DEIR’s air quality modeling, though, relies on Tier 4 final engines to <br />purportedly reduce air quality impacts to less than significant levels. Tier 4 <br />Interim equipment has higher emission levels than Tier 4 Final equipment.96 <br />Therefore, by modeling construction emissions assuming a full Tier 4 Final <br />equipment fleet, the air quality and greenhouse gas emissions impacts analyses fail <br />to account for higher emissions that may occur because of the use of Tier 4 Interim <br />equipment.97 <br /> <br />Additionally, while MM AIR-3 specifies that the measure applies to “off-road <br />equipment with engines greater than 50 horsepower,” a review of the CalEEMod <br />output files by SWAPE reveals that Tier 4 Final emissions standards are applied to <br />equipment with lower horsepower.98 Specifically, the DEIR’s air quality and GHG <br />analysis applies these standards to excavators, welders, and rollers, all of which all <br />have horsepower ratings below 50.99 The air quality and GHG analysis in the DEIR <br />is therefore not supported by substantial evidence and emissions associated with <br /> <br />94 Id. <br />95 DEIR, p. 3.2-55. <br />96 SWAPE Comments, p. 9. <br />97 SWAPE Comments, p. 9. <br />98 SWAPE Comments, p. 9. <br />99 SWAPE Comments, p. 9.