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Draft Supplemental Environmental Impact Report Page IV.D-30 ' Forward Inc. Landfill 2018 Revised Project materials in the landfill were considered as a credit against emissions,none of the scenarios would exceed the 25,000 metric ton annual limit. Also,none of the Project scenarios would ' exceed 25,000 metric ton annual limit when compared to the Current Permitted emissions. However, this analysis does not consider sequestration of carbon in the landfill as a credit against emissions, and therefore under both the project scenarios(Flare-Current Actual and ' LFG Engines-Current Actual scenarios)the project would exceed the 25,000 metric ton increase annual limit compared with actual existing emissions. Considering all three items in total and given the compliance with CARB's Landfill Methane Rule and the energy efficient location of the landfill,the project would generally be in compliance with the State's goals for reducing GHG emissions. Regardless,the project would result in an increase above the 25,000 metric ton annual limit(at the maximum acceptance rate—when compared to the current actual baseline) ' resulting in additional impacts in California (the project GHG emissions would be similar to emission levels from major sources). Thus,because of the emissions that would be generated from maximum operations,this impact is considered potentially significant. Mitigation Measure DA. (Same as 2013 EIR Mitigation Measure D.5.): Both the Flare and LFG engine options would require feasible mitigation measures to further reduce GHG emissions. ' The landfill operators shall annually report GHG emissions from the project(actual operations) to the County and SJVAPCD. If the increase in operational emissions pr-ejeet-epe-�ations exceeds 25,000 metric tons of CO2e per year by 2020,then the landfill shall purchase verifiable GHG credits to offset the remaining project emissions above 25,000 metric tons of CO2e per year. Additional GHG credits shall be purchased every five years if the annual reports indicate that the credits have not offset excess GHG emissions(those above 25,000 metric tons of CO2e per year) in the prior five years. The purchase of the verifiable GHG credits'would reduce the impact to a level that is less than significant. Impact D.5.The project would contribute to a cumulative air quality impact in the project ' area (Revises 2013 EIR Impact 13.6.). According to the SJVAPCD GAMAQI, cumulative impacts should be assessed for ozone, PMlo, CO, and TAC. The SJVAB is nonattainment for both the NAAQS and CAAQS for ozone.The SJVAB is nonattainment for the CAAQS for PM,O.The nonattainment status of ozone and PM10 in the SJVAB is a result of past and present development within the SJVAB.Thus,the existing emissions of ozone and PMlo in the SJVAB have resulted in an existing significant cumulative impact. Ozone impacts are the result of the cumulative emissions from numerous sources in the region ' and transport from outside the region. Ozone impacts are assessed based on the emissions of NO,and VOC (ozone precursors).The project would have a less than significant impact on project-level ozone impacts (after mitigation). However,the residual emissions from the project ' (emissions after mitigation and emissions from the extended years of landfill operations, and 72 A carbon credit or carbon offset is a credit for GHG emissions reduced or removed from the atmosphere from an emissions reduction project,which can be used,by governments,industry or private individuals to compensate for the emissions they are generating.California's long-term GHG reductions goals in existing laws/regulations such as E.O.S-3-05,E.O.B-30-15,and S.B.32 ensure carbon credits will be available in 2020 and beyond. '