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San Joaquin Valley Air Pollution Control District Page 2 District Reference No . 20220098 February 28, 2022 1a ) Construction Emissions Project construction air emissions are short -term emissions generated from construction activities such as mobile heavy - heavy duty ( HHD ) diesel off- road equipment and are expected to exceed the District significance thresholds . Therefore , the District recommends , to lessen air quality impacts from construction - related diesel exhaust emissions , the County consider incorporating the below measure into the Project . Recommended Measure : To reduce impacts from construction - related diesel exhaust emissions , the Project should utilize clean off- road construction equipment , including the latest tier equipment as feasible . 1 b ) Operational Emissions Emissions from stationary sources and mobile sources should be analyzed separately . For reference , the District ' s annual criteria thresholds of significance for operational emissions are listed above . 1 c ) Recommended Model Project related criteria pollutant emissions from construction and operational sources should be identified and quantified . Emissions analysis should be performed using CalEEMod ( California Emission Estimator Model ) , which uses the most recent approved version of relevant Air Resources Board ( ARB ) emissions models and emission factors . CalEEMod is available to the public and can be downloaded from the CalEEMod website at : www . caleemod . com . 1d ) Project Related Operational Emissions — Truck Routing Truck routing involves the path / roads HHD trucks take to and from their destination . The air emissions from HHD trucks can impact residential communities and sensitive receptors . Since the Project has the potential to generate HHD truck trips , the District recommends the environmental review evaluate HHD truck routing patterns to help limit emission exposure to residential communities and sensitive receptors . More specifically , this measure would assess current truck routes , in consideration of the number and type of each vehicle , destination /origin of each vehicular trip , time of day/week analysis , vehicle miles traveled ( VMT ) and emissions . The truck routing evaluation would also identify alternative truck routes and their impacts on VMT , and air quality .