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summary tables in the Draft EIR. This does not meet a draft EIR's burden to explain and disclose the basis for its conclusions. We set out some of the problems we discovered from reviewing these spreadsheets below. These problems resulted in substantial underestimates of emissions from Project operation. We believe there are likely more errors than we discovered due to the shortness of time for this review, truncated by the late receipt B-26 of the supporting calculations. The emission calculations should be comprehensively Dont. reviewed by an experienced professional and described and annotated in an appendix to the Draft EIR. The problems identified below should be corrected. The Excel spreadsheets in Exhibit 1 indicate that operational emissions arise from: (1)quarry processing operations; (2) concrete production; (3) asphalt production; (4) recycling construction materials; (5) haul trucks; and (6) various fugitive sources. The emissions from these sources were substantially underestimated. IV.A Emission Estimates Must Be Based on Maximum Potential Production Rate The courts have required that an EIR must analyze all aspects of a project that are reasonably foreseeable consequences of the project. (See Laurel Heights Improvement Assn v Regents of Univ. of Cal. (1988)47 C3d 376, 396, 253 CR 426, 433 in which a general standard was set out for determining when a future activity must be analyzed.) When information is scarce or where there are possible variations in B-27 project operation, EIRs typically employ a reasonable worst-case analysis in order to capture the largest expected potential change from existing baseline conditions. This approach is not mandated by CEQA but is a common practice to address — uncertainty, particularly for large projects such as this one. See, for example, the discussion in the SCAQMD CEQA Guidelines which explains: "[t]he daily emissions estimate should be based on the highest daily emissions (including weekdays and weekends)." (SCAQMD 4/93, pp. 6-3, 9-5.)The emission estimates in the Draft EIR are not based on reasonably foreseeable operating modes of the proposed facility and thus substantially underestimate potential emissions. W.A.I Operating Hours The Draft EIR states the Project will operate up to 24 hours per day, 6 days a week, Monday through Saturday with maintenance occurring on Sundays. (Draft B-28 - EIR, p. 3-8.) The Draft EIR also states that overnight operation would only occur as needed for special contract jobs requiring nighttime delivery but does not restrict the number of such days. (Draft EIR, p. 3-22.) Thus, the reasonably foreseeable 20