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4 <br /> <br />from the Project Applicant, the model should have included proportionately altered individual phase <br />lengths to match the proposed construction duration of 30 months.5 <br />The construction emissions are inexplicably spread out over a longer period of time for some phases, <br />but not for others. According to the CalEEMod User’s Guide, each construction phase is associated with <br />different emissions activities (see excerpt below).6 <br /> <br />By altering and extending the construction phase lengths without proper justification, the model <br />assumes there are a greater number of days to complete the construction activities required by the <br />prolonged phases. As a result, there will be less construction activities required per day and fewer <br />pollutants emitted per day. The model may therefore underestimate the peak daily emissions associated <br />with construction and should not be relied upon to determine the significance of the Project’s <br />construction emissions. <br />Failure to Include Required Material Export and Import <br />The DEIR reveals that Project construction could include soil import and export, stating: <br />“Based on applicant provided information, any import and export of soil would be accomplished <br />by using soil from a soil harvest site east of the residential project site. As such, import and <br />export of material would not generate long haul trips but would expand the area to be disturbed <br />to include the vacant lot located directly east of the residential project site. Potential impacts <br />from this additional area to be disturbed was accounted for in the localized air quality impact <br />analysis completed for the project by including the adjacent site as part of the AERMOD <br />modeling conducted for the construction HRA” (p. 3.2-26). <br />Review of the CalEEMod output files, however, demonstrates that the “Alameda County Arroyo Lago <br />Residential Main Site” model does not include any amount of material import or export (see excerpt <br />below) (Appendix B, pp. 81, 82): <br /> <br />5 See Attachment A for proportionately altered construction schedule. <br />6 “CalEEMod User’s Guide.” CAPCOA, May 2021, available at: https://www.aqmd.gov/caleemod/user's-guide, p. <br />32.