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• • Draft Supplemental Environmental Impact Report Page IV.D-20 Forward Inc. Landfill 2018 Revised Project • . CO, SO, and VOCs compared to the LFG engine scenario. The LFG engine scenario would • result in lower emissions increases of NOx, PM10 and PM2.5• • Rule 2201 requires new and modified stationary sources of emissions to mitigate emissions • using best available control technology (BACT) and to offset emissions when above emissions • offset threshold levels. All VOCs, NOx, CO, SOx, PM10 and PM2.5 emissions from stationary • sources in excess of the applicable SJVAPCD emissions offset threshold levels shall be offset by acquisition of emission offsets, as required by SJVAPCD Rule 2201 regulations. For example, • under the Project (flare)—Current Actual scenario, a total of 19.0 tpy of NOx emissions would • be offset(29.0 tpy—10 tpy);while under the Project(LFG Engines) —Current Actual scenario, a • total of 11.1 tpy of NOx emissions would be offset(20.1 tpy—10 tpy). Thus, the stationary source NOx emissions would be mitigated with emission offsets and would be less than • significant. • • To determine whether Project emissions would exceed the NAAQS or CAAQS, emissions were • modeled, added to background concentrations and compared to the standards. Project(future potential)—Current Actual emissions of CO, NO2 and SO2 would not exceed the NAAQS or CAAQS when added to background concentrations. Project (future potential)—Current Actual • emissions of PM10 and PM2.5were found to contribute to background concentrations that exceed the NAAQS and CAAQS (the SJVAPCD is designated nonattainment for PM10 and PM2.5). Additional information regarding the assumptions and methodologies used in the ambient air • quality analysis is available in the AQIA by SCS Engineers (See Appendix D). • • With implementation of Mitigation Measures D.2a. and D.2b.,stationary sources would be mitigated (by D.2a.)and fugitive emissions and mobile emissions would be mitigated (by • D.2b.). The future emission offsets to be purchased as required by Mitigation Measures D.2a. and D.2b. would reduce emissions in the SJVAB and the Project's contribution to existing • violations of the NAAQS and CAAQS would not be considered substantial after mitigation. • Thus, with mitigation, this impact would be less than significant. • Mitigation Measure D.2a. (Revises 2013 EIR Mitigation Measure D.2a.): The applicant shall comply with SJVAPCD Rule 2201 regulations to offset stationary source emissions of VOCs, • CO, NO, SO, PM10 and PM2.5 in excess of the applicable SJVAPCD emissions offset threshold levels. The applicant shall also comply with Regulation VIII and implement Mitigation • Measure D.1. for operational activities such as earthmoving. • • Mitigation Measure D.2b. (Same as 2013 EIR Mitigation Measure D.2b.): The applicant shall • enter into a Voluntary Emissions Reduction Agreement(VERA) with the SJVAPCD (to offset unmitigated mobile and fugitive dust emission impacts). The VERA shall cover mobile • emissions and fugitive emissions (above the SJVAPCD CEQA thresholds for NOx, PM10 and • PM2.5) associated with the 8.1 mcy of new capacity. • • • • • • • •