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As you can see in the excerpt above, the model calculates 267 hauling truck trips for demolition. <br />According to the "User Entered Comments & Non -Default Data" table, the justification provided for <br />these changes is: "Estimated tons of demolished material based on AQconstruction questionnaire" <br />(Appendix B, pp. 79, 111, 231). However, this justification is incorrect for two (2) reasons. First, the <br />Addendum and associated documents fail to provide an AQ construction questionnaire, as referenced. <br />As such, we are unable to verify the inputted amount of demolition material as claimed. Second, the <br />Addendum fails to disclose the specific square footage of facilities to be demolished or the tons of debris <br />resulting from this demolition. Thus, we cannot verify that the hauling trip number calculated in the <br />model is the result of the input of the correct amount of demolition. As such, demolition may be <br />underestimated. <br />This potential underestimation presents an issue, as the total amount of demolition material is used by <br />CaIEEMod to determine emissions associated with this phase of construction. The three primary <br />operations that generate dust emissions during the demolition phase are mechanical or explosive <br />dismemberment, site removal of debris, and on -site truck traffic on paved and unpaved road.12 Thus, by <br />failing to substantiate the demolition of existing structures and hardscape, emissions associated with <br />fugitive dust, site removal, and exhaust from hauling trucks traveling to and from the site may be <br />underestimated. As a result, the model may underestimate the Project's construction -related emissions <br />and should not be relied upon to determine the significance of the Project's air quality impacts. <br />Use of Underestimated Operational Vehicle Trips <br />According to the Traffic Impact Analysis ("TIA"), provided by Appendix K to the Addendum, the proposed <br />Project is expected to generate 1,171 daily vehicle trips throughout operation (Appendix K, pp. 314, <br />Table 5-1). However, review of the "Project Traffic Generation Forecast Table" demonstrates that a 5% <br />non -auto trip reduction was applied to the Project's daily vehicle trip estimate, resulting in a reduction <br />of 59 vehicle trips (see excerpt below) (Appendix K, pp. 314, Table 5-1). <br />"CalEEMod User Guide, Appendix A, p. 11, available at: http://www.caleemod.com/ <br />75C-81 <br />