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Specifically,the number and length of vehicle trips is utilized to estimate the vehicle miles travelled ("VMT") associated with construction. Then, utilizing vehicle-class specific EMFAC 2014 emission factors, CaIEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction-related VMT, including personal vehicles for worker commuting.4 Specifically, in order to calculate VMT, CaIEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below): "VMTd =F(Average Daily Trip Rate; * Average Overall Trip Length ;) n Where: n = Number of land uses being modeled."' Furthermore, to calculate the on-road emissions associated with worker trips, CaIEEMod utilizes the following equation (see excerpt below): "Emisslonspollutant=VMT * EFrunning,pollutant Where: Emissionspollutant=emissions from vehicle running for each pollutant VMT=vehicle miles traveled EFrunning,pollutant=emission factor for running emissions."' Thus,there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall trip length, by way of a local hire requirement or otherwise. Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed,the number, length, and vehicle class of worker trips are utilized by CaIEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction! In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CaIEEMod default worker trip parameters. CaIEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project- specific values, but the California Environmental Quality Act ("CEQA") requires that such changes be justified by substantial evidence.'The default number of construction-related worker trips is calculated by multiplying the 4"Appendix A Calculation Details for CaIEEMod."CAPCOA,October 2017,available at:http://www.agmd.gov/docs/default- source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5"Appendix A Calculation Details for CaIEEMod."CAPCOA,October 2017, available at:http://www.agmd.gov/docs/default- source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p.23. 6"Appendix A Calculation Details for CaIEEMod."CAPCOA,October 2017, available at:http://www.agmd.gov/docs/default- source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. "CaIEEMod User's Guide."CAPCOA, November 2017, available at:http://www.agmd.gov/docs/default- source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4, p.34. $CaIEEMod User Guide,available at:http://www.caleemod.com/, p. 1,9. 2