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Incorrect Application of Construction -Related Mitigation Measures <br />Review of the Project's CalEEMod output files demonstrates the model includes the following five (5) <br />construction -related mitigation measures: "Replace Ground Cover," "Water Exposed Area," "Water <br />Unpaved Roads," "Reduce Vehicle Speed on Unpaved Roads," and "Clean Paved Roads" (see excerpt <br />below) (Appendix B, pp. 86, 118, 239). <br />3.1 Mitigation Measures Construction <br />Replace Ground Cover <br />Water Exposed Area <br />Water Unpaved Roads <br />Reduce Vehicle Speed on Unpaved Roads <br />Clean Paved Roads <br />As a result, the model includes a 6% clean paved road reduction, 12% unpaved road moisture content, <br />and 15 miles per hour ("MPH") vehicle speed (see excerpt below) (Appendix B, pp. 80, 112, 232). <br />Table Nave I fd. Nave I DeiaWt Va.- I N,n VALe <br />t--------------- W-------------Mus------ -- h -- <br />a___________ <br />As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be <br />justified.13 According to the "User Entered Comments & Non -Default Data" table, the justification <br />provided for these changes is: "Per SCAQMD Rules and Regulations" (Appendix B, pp. 79, 111, 231). <br />Furthermore, in regard to the Project's construction emissions, the Addendum states: <br />"Emission data is pulled from 'mitigated' results, which include SCAQMD regulatory <br />requirements including Rule 403 and Rule 1113. SCAQMD Rule 403 Fugitive Dust applied. The <br />Rule 403 reduction/credits include the following: properly maintain mobile and other <br />construction equipment; replace ground cover in disturbed areas quickly; water exposed <br />surfaces three times daily; cover stockpiles with tarps; water all haul roads twice daily; and limit <br />speeds on unpaved roads to 15 miles per hour" (p. 3.2-4). <br />However, as the excerpt above demonstrates, while the Addendum indicates which mitigation measures <br />were included in the model, the Addendum does not explicitly require the Project to include onv of the <br />above -mentioned construction -related mitigation measures. Thus, the Addendum fails to demonstrate a <br />commitment to the implementation, monitoring, and enforcement of any construction -related <br />mitigation measures, and we cannot verify their inclusion in the model. <br />13 CalEEMod User Guide, available at: htto://www.caleemod.com/, p. 2, 9 <br />e <br />75C-83 <br />