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1 Pages ' Oes.rk:t"Orarenoe Nn 20180953 The District appreciates your efforts to mitigate thc� air quality impacts of your Project by entering into a VERA with the District. The District looks forward to working with the Project proponent on the implementation of a VERA for this Project ' The District recommends that the following details of the proposed VERA be clarified in MM D.2b: ' • This measure does not specify to what level the VERA will reduce Project non-stationary source emissions ' There are two emission reduction options available to VERA participants There is the "pollutant-by-pollutant" option, under which each pollutant will be ' mitigated individually to their respective significance threshold level, and the "net-zero" option. For the purposes of fulfilling the terms of a VERA with the District, the terns ' "net-zero" means that the sum of NOx, VOC, and PM10 combined Project emissions will be fully mitigated by the sum of NOx, VOC, and PM10 ' combined emission reductions achieved under the VERA. The "net zero" concept is limited to the three pollutants NOx, VOC and PM i0, due to their strong interrelatedness. NOx is the driving pollutant for both the wintertime ' 0 PM problem and the summertime ozone problem (in combination with VOCs (cont.) The District considers "net zero" mitigation to result in a less-than-significant air quality impact for these three pollutants, even if VOC or PM 10 emissions remain above their individual significance thresholds after mitigation, because ' this means that the mitigation has achieved excess reductions of NOx the critical component to the Valley's air quality issues. The District recommends the "net-zero" approach, method This method results in a significantly larger amount of NOx reduction, which is the primary driver to the formation of ozone and PM in the Valley. ' Additionally, the District recommends starting the VERA process as early as possible. Information concerning the execution of a VERA contract can be ' obtained by calling (559) 230-6000 and asking to speak to a District CEQA staff member. The District recommends that this measure include details as to when the I VERA shall be executed. The District requires that the VERA be approved prior to the start of generating ei-nissions (i.e. start of Project operations) To ' avoid unnecessary delays in Project development., the District recommends clarifying that the Project proponent need only obtain an af)proti-ed VERA prior to the start of Project operations, and not require documentation confirming I full compliance with said VERA, as this process takes place over time. I