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Draft Supplemental Environmental Impact Report Page IV.D-21 Forward Inc. Landfill 2018 Revised Project (Emission Reduction Credit Banking), or other Actual Emissions Reductions that may be used to mitigate an emission increase as part of the same Stationary Source Project in accordance with the provisions of SJVAPCD Rule 2201. Emission offsetting works by using emission reductions from existing sources to offset emission increases from new or expanding sources. Emission offsets are considered adequate mitigation because they are enforceable by permit conditions, legally binding agreements, or other measures, and they are capable of being monitored and enforced." 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 PMIo and PM2.5 were found to contribute to background concentrations that exceed the NAAQS and CAAQS(the SJVAPCD is designated nonattainment for PMIo and PM2.5). Additional information regarding the assumptions and methodologies used in the ambient air quality analysis is available in the AQIA by SCS Engineers (See Appendix D). With implementation of Mitigation Measures D.2a. and D.2b., stationary sources would be mitigated (by D.2a.)and fugitive emissions and mobile emissions would be mitigated (by D.2b.). The future emission offsets to be purchased as required by Mitigation Measures D.2a. and D.2b. would reduce emissions in the SJVAB and the Project's contribution to existing violations of the NAAQS and CAAQS would not be considered substantial after mitigation. Thus, with mitigation, this impact would be less than significant. Mitigation Measure D.2a. (Revises 2013 EIR Mitigation Measure D.2a.): The applicant shall comply with SJVAPCD Rule 2201 regulations to offset stationary source emissions of VOCs, CO,NO, SOX,PMIo and PM2.5 in excess of the applicable SJVAPCD emissions offset threshold levels. The applicant shall also comply with Regulation VIII and implement Mitigation Measure D.1. for operational activities such as earthmoving. Mitigation Measure D.2b. (Same as 2013 EIR Mitigation Measure D.2b.): The applicant shall enter into a Voluntary Emissions Reduction Agreement(VERA)with the SJVAPCD (to offset unmitigated mobile and fugitive dust emission impacts). The VERA shall cover mobile emissions and fugitive emissions (above the SJVAPCD CEQA thresholds for NOx,PMIo and PM2.5)associated with the 8.1 mcy of new capacity. II San Joaquin Valley Air Pollution Control District(SJVAPCD),Guidance for Assessing and Mitigating Air Quality Impacts(GAMAQI),March 19,2015.