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they should been evaluated together as construction emissions, not separately evaluated, thus diluting the impact of the total emissions. The PM10 emissions from 8-18 grading, 729 lb/day, plus those from equipment exhaust, 5.9 lb/day, exceed all of cont. the PM10 significance thresholds. Thus, PM10 emissions from Project construction are significant, a new impact that was not disclosed in the Draft EIR. Likely, the emissions calculated by the Draft EIR for construction emissions would be even higher because the Draft EIR assumed the use of only 5-year old construction equipment. This assumption does not reflect the average age of the — typical construction equipment fleet. Older engines, up to 20 years are frequently found in the construction fleet. The typical useful life of many types of heavy-duty off-road equipment, e.g.,crawler tractors, rubber-tired dozers, graders, off-highway tractors and trucks, skid steer loaders, and graders, is on the order of 10 to 16 years. B-1s (See, e.g., Exhibit 1, spreadsheet"Construction Equipment Information.")These older engines have considerably higher emissions than the 5-year-old equipment assumed in the Draft EIR. Thus, depending on the actual age of the equipment that will be used for site preparation, the Draft EIR may have considerably — underestimated emissions. The Draft EIR should be revised to either require the use of 5-year old equipment at the time site preparation is performed or demonstrate a reasonable worst-case emissions scenario based on older equipment. — Further, the construction emissions in the Draft EIR, Table 4.64, are based on only four types of equipment- scrapers, dozers, motor graders, and water trucks. Construction of the Project will require many additional pieces of fuel-burning equipment to construct the various components of the Project. These include cranes, B-2 — forklifts, delivery trucks, pavers, trenchers, dredgers, compressors, drill rigs, welding machines, and construction worker commuting, among many others. See Exhibit 1, which is the applicant's list of construction equipment that was provided in response to our inquiries. The emissions from all of this equipment were not included in the Draft EIR's emissions estimates. The Draft EIR should be revised _ to present a construction schedule and equipment deployment schedule for the entire construction project and total construction emissions estimated for the peak day and year. This is likely to demonstrate that total annual emissions of CO, NOx, _ and PM10 from Project construction would be significant. Finally, because the Project will be constructed in phases6' some phases will be graded when the quarry will be fully operational. Thus, site preparation B-21 emissions would coincide with emissions resulting from the operational phase and b Footnote 3 to Draft EIR Table 4.6-4 states that the most grading that could be expected in any one _ year would be two phases. 10