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San Joaquin Valley JUN 2 3 2004 Air Pollution Control District Community Development De Pt July 21, 2004 168DEV2004 Leanne Mueller Development Service Division 1810 E. Hazelton Ave Stockton, CA 95205 Subject: PA-0400351 (APN #213-270-13 and 14) Dear Ms. Mueller: I ' Please note the correction made to the APN number to included APN #213-270-14. iThe San Joaquin Valley Unified Air Pollution Control District (District) has reviewed the project referenced above and offers the following comments: The entire San Joaquin Valley is classified non-attainment for ozone and fine particulate matter (PM10). This project would contribute to the overall decline in air quality due to increased traffic and ongoing operational emissions. Although this project alone would not generate significant air emissions, the increase in emissions from this project, and others like it, cumulatively reduce the air quality in the San Joaquin Valley. A concerted effort should be made to reduce project-related emissions as outlined below: The following items are rules that have been adopted by the District to reduce emissions throughout the San Joaquin Valley, . and are required. Current District rules . can be found at http://www.valleyair.org/rules/1 ruleslist.htm. 1. District Regulation VIII - f=ugitive Dust Rules is a series of rules designed to reduce PM10 emissions generated by human activity, including construction, road construction, bulk materials k storage, landfill operations, etc. An assistance bulletin has been enclosed for the applicant. 2. Paving operations of this project will be subject to Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations). This rule applies to the manufacture and use of cutback asphalt, slow cure asphalt and emulsified asphalt for paving and maintenance operations. I 3. District Rule 4103 (Open Burning) regulates the burning of agricultural material. Agricultural material shall not be burned when the land use is converting from agriculture to nonagricultural purposes. In the event that the project burned or burns agricultural material, it would be in violation of Rule 4103 and be subject to District enforcement action. r The District encourages innovation in measures to reduce air quality impacts. There are a number of measures that could be incorporated into the design/operation of this project to provide additional reductions of the overall.level of emissions..., (Note: Some of the measures may already exist as City/County development stand ards. .Any. measure selected should be implemented to the fullest extent possible.) The measures listed below should not be considered all-inclusive and,remain options that the project proponent should consider: • "Trees should be carefully selected and located to protect the building(s) from energy consuming environmental conditions,,and to shade paved areas, Trees should be selected to shade paved areas that will shade.50%of,the i area within 15,years. Structural soil should be used under paved areas to improve tree growth. A brochure has F been included for the applicant.