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Draft Supplemental Environmental Impact Report Page IV.D-20 Forward Inc. Landfill 2018 Revised Project • Curtail construction during periods of high ambient pollutant concentrations;this may include ceasing of construction activity during the peak-hour of vehicular traffic on adjacent roadways. • Require that all diesel engines be shut off when not in use on the premises for more than five minutes to reduce the emissions from idling. Significance after Mitigation Construction impacts would be less than significant with the implementation of Mitigation Measure D.1. Impact D.2.The project would result in an increase in operational emissions of criteria air P p l P pollutants from onsite emission sources and increase emissions associated with traffic- related trips(Revises 2013 FEIR Impact D.2.and adds CO discussion to replace 2013 FEIR Impact 13.3.). The AQIA10 evaluated how the project would increase criteria pollutant emissions from LFG- derived sources under two scenarios: additional LFG is controlled either by additional flare capacity (flare scenario)or LFG engines at existing and future LFG to energy facilities (LFG engine scenario). Two b4aseline scenarios were evaluated:Current Actual emissions, determined using 2016 and 2017 operational data; and Current Permitted emissions,based on emissions of landfill sources at maximum permitted levels. Table IV.D-4 presents net project emissions derived from the AQIA. Project unmitigated impacts for VOC, NO, PM10,PM2.5 and CO would be considered potentially significant under almost all of the Project scenarios presented. Additional information regarding the assumptions ' and methodologies used in the air emission calculations is available in the AQIA by SCS Engineers (See Appendix F). The flare scenario would result in lower emissions increases of CO,SOX, 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 10.1 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. Emission offsets are emission reductions recognized by the SJVAPCD in the form of Emission Reduction Credits that are issued in accordance with the provisions of SJVAPCD Rule 2301 "SCS Engineers,Air Quality Impact Analysis and Air Toxics Risk Assessment for Proposed Landfill Project Forward Landfill Manteca,California,May 2018.