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5 <br /> <br /> <br />The model does not account for the possibility of Project-related earthwork, and therefore fails to <br />conduct a “‘conservative analysis’ to afford the ‘fullest possible protection of the environment’” as is <br />required under CEQA.7 As the DEIR leaves doubt as to whether there would be material import or <br />export, the model should include a conservative estimate. <br />Additionally, the DEIR’s inclusion of the adjacent site into the AQ & GHG Analysis’s AERMOD modeling <br />fails to substantiate the model’s omission of material import and export. As discussed by the Bay Area <br />Air Quality Management District (“BAAQMD”), Project Applicants are required to model construction- <br />related emissions using CalEEMod which can include “soil disturbance, grading, and material hauling.”8 <br />As such, the above-mentioned soil import and export should have been included in the CalEEMod as <br />well. <br />The inclusion of material import and export within the model is essential for accurately calculating <br />emissions generated from material movement, which encompasses truck loading and unloading, as well <br />as additional hauling truck trips.9 By failing to include the amount of material import required for Project <br />construction, the model has underestimated the Project’s construction-related emissions and should not <br />be relied upon to determine the significance of the Project’s construction emissions. A revised EIR <br />should be prepared to include required amounts of material import and export, and include revised <br />models, as required by CEQA and the BAAQMD. <br />Unsubstantiated Changes to Off-Road Construction Equipment Values <br />Review of the CalEEMod output files demonstrates that the “Alameda County Arroyo Lago Residential <br />Main Site” model includes changes to the off-road construction equipment input parameters (see <br />excerpt below) (Appendix B, pp. 95, 96). <br /> <br />7 “Warehouse Truck Trip Study Data Results and Usage” Presentation. SCAQMD Inland Empire Logistics Council, <br />June 2014, available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/high-cube-warehouse-trip- <br />rate-study-for-air-quality-analysis/final-ielc_6-19-2014.pdf?sfvrsn=2 <br />8 “BAAQMD CEQA Air Quality Guidelines.” BAAQMD, 2022, available at: <br />https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-guidelines-2022/ceqa-guidelines- <br />chapter-5-project-air-quality-impacts_final-pdf.pdf?la=en, p. 5-4. <br />9 “CalEEMod User’s Guide.” CAPCOA, May 2021, available at: https://www.aqmd.gov/caleemod/user's-guide, p. <br />34.