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E Peoples Organization for Land Preservation Comments to SU-91-9 Air Quality con't. Further, since a majority of the homes being built in Linden and the County may be for people who will be working in the inter Bay Area and Sacramento, the EIR should concern itself with the effects of the Flor project, both sigularly and ` cumulatively, on the inter Bay Area amd Sacramento's air quality. i Specifically, and at a minimum, the EIR should study the oxides of nitrogen, reactive organic gasses, carbon monoxide, ambient levels for ozone (98% of all damage to agricultural crops is due to ozone), ozone precursors (hydrocarbons) , ' sulphur dioxide, lead, hydrogen sulfide, vinyl chloride, and fine particulate matter, and the effect of the aforementioned on the health of present residents i of the area. The Flor project EIR should contain emission assessments for that project and an emission assessment for all of the presently approved and proposed projects. ! Current models being used by this County's Air Polution Control District are not valid for all project emission assessments, especially the Flor project in Linden. The model used on the Flor project was a standardized data base which more aptly fits a large urban setting and not a rural community with no jobs and little services. Further, the EIR should notice the present measures that the San Joaquin Valley ! Unified Air Pollution Control District is proposing to implement, as they relate to these indirect sources of air pollution. The EIR should study how the project will reduce air pollution, since San Joaquin County is required by the State Clean Air Act to reduce air pollution by 5% per year beginning in 1987. There must be within the EIR a clear method of mitigating all of the air quality impacts discovered. Also, receptors for mitigations could be researched such as the Valley Air Trust Incorporated. A model must be developed to assess the incremental damage which surrounding and vally-wide agricultural crops will incur due to the Flor project. The development should indemnify growers or successfully mitigate to alleviate legal recourse from crops damaged by deteriorating air quality. 5. Water The EIR should focus on the availability, withdrawal, capacity, demand, quality, recharge and subsidence of water. The EIR study should also compare water use, based on the economic benefit of land remaining dedicated to agricultural use as compared to becoming a municipal use (Floc Subdivision) . i It is not enough to suggest, as past EIRs have suggested, that one acre of ' agricultural land uses the same amount of water as one acre of municipal land, especially if the one acre of municipal land will be used for housing, and not for providing jobs for the present San Joaquin County residents, which the I agricultural land may have been providing. G r r (4)