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9 <br /> <br />therefore has the lowest emissions compared to other tiers, including Tier 4 Interim equipment (see <br />excerpt below):12 <br /> <br />Tier 4 Interim equipment has higher emission levels than Tier 4 Final equipment. Therefore, by modeling <br />construction emissions assuming a full Tier 4 Final equipment fleet, the AQ & GHG Analysis fails to <br />account for higher emissions that may occur because of the use of Tier 4 Interim equipment. <br />Additionally, while MM AIR-3 specifies that it applies to “off-road equipment with engines greater than <br />50 horsepower,” a review of the CalEEMod output files reveals that Tier 4 Final emissions standards are <br />applied to equipment with lower horsepower. Specifically, as shown in the excerpt above, the AQ & <br />GHG Analysis applies these standards to excavators, welders, and rollers, all of which all have <br />horsepower ratings below 50. Until a revised EIR is prepared that substantiates the use of Tier 4 Final <br />emissions standards, including for equipment with less than 50 horsepower, the model should not be <br />relied upon to determine Project significance. <br />Greenhouse Gas Failure to Adequately Evaluate Greenhouse Gas Impacts <br />The DEIR estimates that the Project would result in net annual greenhouse gas (“GHG”) emissions of <br />2,872-metric tons of carbon dioxide equivalents per year (“MT CO2e/year”) (see excerpt below) (p. 4.6- <br />27 – 4.6-28, Table 4.6-4). <br /> <br />12 “San Francisco Clean Construction Ordinance Implementation Guide for San Francisco Public Projects.” August <br />2015, available at: https://www.sf.gov/sites/default/files/2024- <br />03/San_Francisco_Clean_Construction_Ordinance_2015.pdf , p. 6.