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1 <br /> Page <br /> DisJrrcr Fa7erer+cw No 20780953 <br /> Per page 1-2 of the DSEIR, the Project area being proposed has a smaller increase <br /> in permitted landfilling capacity than the proposed 2013 project and does not inciude <br /> the expansion of landfilling operations onto the 164-acre Broeehini parcel. The <br /> Project site is located on the west side of Austin Road, Yx mile north of Lynch road, <br /> ' north of Manteca. CA. (APN/Address 181-150-07, -08, -09, & -10 and 201-06O-01, - <br /> 02, 03. -05, -06, & -07 / 9999 South Austin Road, Manteca, CA.) <br /> In 2018, the Project proponent, Forward Inc , requested that a previously proposed <br /> project request from 2014 be reinitiated and is proposing the current infill <br /> development Project. Per the County of San Joaquin (County), the current DSEiR <br /> (1) is to replace the 2014 project that was initially proposed and evaluated under a <br /> ' Draft Supplemental EIR, and (2) is being developed for this current proposed landfill <br /> Project. <br /> ' The District makes the following comments: <br /> A Operational Emissions <br /> The District would like to clarify that stationary and non-stationary source <br /> emissions may be addressed separately as operational emissions when <br /> compared to thresholds of significance. <br /> Table W.13-4 of the DSEIR compares the combined total of stationary and non- <br /> 0 stationary source emissions to CEQA significance thresholds. Although <br /> stationary and non-stationary source emissions would still exceed the CEQA <br /> thresholds of signif,cance when compared individually, the District's Guidance for <br /> Assessing and Mitigating Air Quality impacts (GAMAQI) allows for stationary and <br /> non-stationary sources to be compared separately to the CEQA thresholds of <br /> significance. Therefore, future project-related air quality impact determination for <br /> stationary and non-stationary source emissions may be assessed separately. <br /> ' B Voluntary Emissions Reduction Agreement <br /> The District recommends that MiticJ-ation Measure D.2b. be revised to clarify <br /> ' the parameters of the prol.)osed VERA. <br /> O The DSEIR proposes to mitigate operational emissions from non-stationary <br /> ' sources with implementation of Mitigation Measure (MM) O.2b. As stated in MM <br /> D.2b, "The applicant shaft enter into a Voluntary Emissions Reduction Agreement <br /> (VERA) with the SJVAPCD (to offset unmitigated mobile and fugitive dust <br /> ' emission impacts). The VERA shall cover ntubile emissions and fugitive <br /> ernissions (above the SJVAPCD CEQA thresholds for NOx, PMIO and PM2.5) <br /> associated with the 8.1 mcy of new capacity." <br /> 1 <br />