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Furthermore, according to SCAQMD Rule 403, Projects can either water unpaved roads 3 times per day, water unpaved roads 1 time per day and limit vehicle speeds to 15 mph, or apply a chemical stabilizer (see excerpt below) (p. 403-21, Table 2). 14 Table 2 Woutintted) FUGITIVE DUST SOURCECATEGORY CONTROL ACTIONS Unpaved Roads (48) Water all roads used for any vehicular tret£c at least once per every two hours of active operations [3 times per normal 8 hour work day]; OR (4b) Water all roads used for any vehicular traffic once daily and restrict vehicle speeds to 15 nules per hour OR. (4c) Apply a chemical stabilizer to all unpaved road surfaces in sufficient quaoti[y and frequency to maintain a stabilized surface. As you can see in the above excerpt, to simply comply with SCAQM D Rule 403, the Project may either water unpaved roads 3 times per day, water unpaved roads 1 time per day and limit vehicle speeds to 15 mph, or apply a chemical stabilizer. Thus, none of the measures included in the CaIEEMod model are explicitly required by SCAQMD Rule 403, and we cannot verify their inclusion in the model. By including construction -related mitigation measures without properly committing to their implementation, the model may underestimate the Project's construction -related emissions and should not be relied upon to determine Project significance. IncorrectApplication of Operational Mitigation Measures Review of the Project's CaIEEMod output files demonstrates that the model incorrectly includes several mobile-, area-, and water -related operational mitigation measures. As a result, the Project's operational emissions may be underestimated, and the model should not be relied upon to determine Project significance. First, the Project's CaIEEMod output files reveal that the model included the following two (2) mobile - related operational mitigation measures: "Increase Density' and "Increase Diversity' (see excerpt below) (Appendix B, pp. 102, 134, 255). 4.1 Mitigation Measures Mobile Increase Density Increase Diversity Second, the Project's CaIEEMod output files reveal that the model included the "Use only Natural Gas Hearths" area -related operational mitigation measure (see excerpt below) (Appendix B, pp. 106, 138 261). 14 "RULE 403. FUGITIVE DUST." SCAQMD, June 2005, available at: htto://www.agmd.gov/docs/default-source/rule- b oo k/ r u l e-i v/ r u l e-403. o d f. 75C-84