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Draft Supplemental Environmental Impact Report Page VIII-12 Forward Inc.Landfill 2018 Expansion Project B. Responses to San Joaquin Valley Air Pollution Control District Letter B-1. Comment Noted. The DSEIR Air Quality Impact Assessment(AQIA) (DSEIR t Appendix G)characterizes sources separately, so the information can be presented as stationary and non-stationary sources as needed. B-2. Comment Noted. Mitigation Measure D.2b. on Page IV.D-21 of the DSEIR has been revised. See Response B-5. B-3. The SJVAPCD Emissions Offset Threshold Levels in District Rule 2201 are the same or less than the SJVAPCD CEQA thresholds for criteria pollutants emissions from stationary sources.In the event that the net increases of criteria pollutant emitted from stationary sources due to the project do not require offsets per the requirements of District Rule 2201,project emissions would be below the SJVAPCD Emissions Offset Threshold Levels in District Rule 2201 and thus below the SJVAPCD CEQA thresholds for stationary sources, and therefore less-than-significant according to the SJVAPCD's Guidance for Assessing and Mitigating Air Quality Impacts (GAMQAI).ERGs already obtained by the facility would be considered as mitigation for permitted emissions from stationary sources. If project emissions are above the Emissions Offset Threshold, emissions offsets would be obtained from emission reduction sources approved by the ' SJVAPCD to mitigate to less than a significant level. B-4. Comment Noted.The applicant and applicant engineer(SCS)acknowledge that they will need to acquire and Authority to Construct(ATC)and Permit to Operate (PT)) for the increased landfill capacity under Rule 2010. They also acknowledge that any new permits may incorporate requirements related to other District Rules and prohibitions for odor, dust, and other emissions. The applicant will be required to obtain and comply with the applicable permits from the SJVAPCD for the Project,which is the regulatory agency with subject matter jurisdiction to regulate air emission impacts from the project and that the applicant will obtain and adhere to any required permits,including source specific permits to operate the site-wide Title V permit. B-5. In addition to the analysis of the project to the Air District's CEQA emissions thresholds (DSEIR, Table IV.D-4 on page IV.D-22),the DSEIR did analyze ambient air quality concentrations surrounding the project site and determined the increased on-site emissions from the project would cause or contribute to a violation of the National and California Ambient Air Quality Standards (AAQS). As stated in the first full paragraph on page IV.D-21 of the DSEIR: "To determine whether Project emissions would exceed the NAAQS or CAAQS, emissions were modeled, added to background concentrations and compared to the standards. Project(future potential)-Current Actual emissions of CO,NO2 and SO2 would not exceed the NAAQS or CAAQS when added to background concentrations. Project(future potential)-Current Actual emissions of PMlo and PM2.5 were found to contribute to background concentrations that exceed the NAAQS and CAAQS(the SJVAPCD is designated nonattainment for PM,o and PM2.5). Additional information regarding the assumptions and methodologies