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2 <br /> <br />Quality Act (“CEQA”) requires that such changes be justified by substantial evidence.2 After entering all <br />relevant data into the model, CalEEMod calculates the emissions from both construction and <br />operational phases, producing “output files.” These files outline the parameters used in the emissions <br />calculations and highlight any modifications made to the default values, along with justifications for <br />each change. <br />Upon review of the Project’s CalEEMod output files, provided in the Air Quality, Greenhouse Gas, and <br />Energy Supporting Information (“AQ & GHG Analysis”) as Appendix B to the DEIR, we identified several <br />model inputs that are inconsistent with the information presented in the DEIR. These discrepancies, <br />outlined below, suggest the Project’s construction emissions may be underestimated. A revised EIR <br />should be prepared to include an updated air quality analysis that adequately evaluates the impacts that <br />construction of the Project will have on local and regional air quality. <br />Unsubstantiated Changes to Individual Construction Phase Lengths <br />Review of the CalEEMod output files demonstrates that the “Alameda County Arroyo Lago Residential <br />Main Site” model includes changes to the default construction schedule (see excerpt below) (Appendix <br />B, pp. 95, 96). <br /> <br />As a result of these changes, the model includes the following construction schedule (see excerpt below) <br />(Appendix B, pp. 77): <br /> <br /> <br />2 “CalEEMod User’s Guide.” CAPCOA, May 2021, available at: https://www.aqmd.gov/caleemod/user's-guide, p. <br />13, 14.