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Draft Supplemental Environmental Impact Report Page IV.D-14 Forward Inc. Landfill 2018 Revised Project methodology relies on the use of performance-based standards that would be applicable to projects that result in increased GHG emissions. Use of performance-based standards is a method of determining significance of project specific GHG emission impacts using established specifications or project design elements,BPS,and is not mitigation of project related impacts. Establishing BPS would help project proponents, lead agencies, and the public by proactively identifying effective, feasible GHG emission reduction measures.Emission reductions achieved through implementation of BPS would be pre-quantified thus,negating the need for project specific quantification of GHG emissions. However, at this time the District has not approved BPS for landfills. For illustrative purposes only,the guidance document does identify the following BPS for landfills9: Illustrative BPS: Landfills shall comply with CARB Regulation to Reduce Methane Emissions from Municipal Solid Waste Landfills. The SJVAPCD signed a Memorandum of Understanding to implement CARB's Landfill Methane Rule on October 20, 2011. BPS would be established through a process approved by the District's Governing Board.The proposed process would provide ample opportunity for stakeholders and other interested parties to participate and provide valuable input into the establishment of baseline GHG emissions and BPS. Existing Air Quality The SJVAPCD's regional air quality monitoring network provides information on existing ambient concentrations of criteria air pollutants. Monitored ambient air pollutant concentrations reflect the number and strength of emissions sources and the influence of topographical and meteorological factors. Table IV.D-2 presents a five-year summary of air pollutant(concentration) data collected at the monitoring station in the vicinity of the project area on Hazelton Street in Stockton;located seven miles to the northwest of the Forward Landfill. Pollutant concentrations measured at this station should be representative of background air pollutant concentrations at the project site. However,background concentrations can vary among different locations within an area. Table IV.D-2 compares these measured air pollutant concentrations with CAAQS and NAAQS. The monitoring data show that ozone, PMlo, and PM2.5 periodically exceeded the AAQS. 9 CARB,Landfill Methane Rule,h :/ www.arb.ca.gov/ 2009. The regulation includes uP g g CH4 reduction strategies such as installation of collection and control systems for landfills that would otherwise be exempt by current regulations,design of collection and control systems to capture maximum amounts of CH4 produced,continuous operation of CH4 control equipment,improved leak standards(25 ppmv,integrated)for CH4 collection and control system components as well as landfill surface emissions,99%CH4 destruction efficiency for flares and methane-fire energy recovery devices,and other enhanced source testing,inspection,monitoring and operating standards.