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8 <br /> <br />CalEEMod uses the off-road equipment unit amounts, horsepower, and hours of use per day values to <br />calculate the emissions associated with off-road construction equipment.11 The model may therefore <br />underestimate the peak daily emissions associated with construction and should not be relied upon to <br />determine Project significance. <br />Incorrect Application of Tier 4 Final Engine Emissions Standards <br />Review of the DEIR demonstrates that the “Alameda County Arroyo Lago Residential Main Site” model <br />assumes that the Project’s off-road construction equipment fleet would meet Tier 4 Final emissions <br />standards (see excerpt below) (Appendix B, pp. 78, 79). <br /> <br /> Furthermore, the DEIR includes mitigation measure (“MM”) AIR-3 that states: <br />“Prior to the issuance of any demolition, grading, or building permits (whichever occurs earliest), <br />the project applicant and/or construction contractor shall prepare a construction operations <br />plan that, during construction activities, requires all off-road equipment with engines greater <br />than 50 horsepower to meet particulate matter emissions standards for Tier 4 interim engines” <br />(p. 3.2-55). <br />The inclusion of Tier 4 Final emissions standards remains unsupported, as the DEIR fails to discuss or <br />required the use of Tier 4 Final emission standards. The United States Environmental Protection Agency <br />(“U.S. EPA”) has slowly adopted more stringent standards to lower the emissions from off-road <br />construction equipment. Since 1994, Tier 1, Tier 2, Tier 3, Tier 4 Interim, and Tier 4 Final construction <br />equipment have been phased in over time. Tier 4 Final represents the cleanest burning equipment and <br /> <br />11 “CalEEMod User’s Guide.” CAPCOA, April 2022, available at: https://www.caleemod.com/documents/user- <br />guide/01_User%20Guide.pdf, p. 36.