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3 <br /> <br />The CalEEMod User’s Guide requires any changes to model defaults be justified.3 As shown above in the <br />“User Changes to Default Data” table above, the justification provided for these changes is: <br />“The schedule is based on applicant-provided information. The construction would occur 7 days <br />a week for conservative estimates” (Appendix B, pp. 95). <br />Regarding the Project’s anticipated construction duration, the DEIR states: <br />“At the time of this analysis, the construction of the proposed project was anticipated to begin <br />in March 2025 and end in August 2027” (p. 3.7-22). <br />The DEIR also provides the following construction schedule (see excerpt below) (p. 3.2-24, Table 3.2-4). <br /> <br />The changes to the individual construction phase lengths, however, remain unsubstantiated. While the <br />DEIR substantiates a total length of Project construction of 30 months, the DEIR fails to provide a <br />sufficient source for the individual construction phase lengths, as demonstrated above by Table 3.2-4. <br />The DEIR cites its own CalEEMod outputs as the source of these changes, which does not qualify as <br />“substantial evidence” required under CEQA.4 Until a proper source is provided, such as information <br /> <br />3 “CalEEMod User’s Guide.” CAPCOA, May 2021, available at: https://www.aqmd.gov/caleemod/user's-guide, p. <br />13, 14. <br />4 “CalEEMod User’s Guide.” CAPCOA, May 2021, available at: https://www.aqmd.gov/caleemod/user's-guide, p. <br />14.