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2656 29th Street, Suite 201 Santa Monica, CA 90405 Matt Hagemann, P.G, C.Hg. (949) 887-9013 mhagemann@swape.com Paul E. Rosenfeld, PhD (310) 795-2335 prosenfeld@swape.com November 7, 2024 Kelilah Federman Adams Broadwell Joseph & Cardozo 601 Gateway Blvd #1000 South San Francisco, CA 94080 Subject: Comments on the Arroyo Lago Residential Project (SCH No. 2023050339) Dear Ms. Federman, We have reviewed the September 2024 Draft Environmental Impact Report (“DEIR”) for the Arroyo Lago Residential Project (“Project”) located in the City of Alameda (“City”). The Project proposes constructing 194 dwelling units with associated parking areas and a 0.7-acre park on the 26.6-acre site, as well as 1,000 feet of off-site road improvements to Busch Road. Our review concludes that the DEIR fails to adequately evaluate the Project’s air quality and greenhouse gas impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project may be underestimated and inadequately addressed. A revised Environmental Impact Report (“EIR”) should be prepared to adequately assess and mitigate the potential air quality and greenhouse gas impacts that the project may have on the environment. Air Quality Unsubstantiated Input Parameters Used to Estimate Project Emissions The DEIR’s air quality analysis relies on emissions calculated with the California Emissions Estimator Model (“CalEEMod”) Version 2022.1 (p. 3.2-1). 1 CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project-specific values, but the California Environmental 1 “CalEEMod User’s Guide.” California Air Pollution Control Officers Association, May 2021, available at: https://www.aqmd.gov/caleemod/user's-guide.