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RECEIVED San Joaquin Valley "'V - 3 2005 Air Pollution Control District Community Development Dept, October 31, 2005 Reference No.C200501460 Kathy Allen San Joaquin County Community Development Department 1810 East Hazelton Avenue Stockton, CA 95205 Subject: PA—0500699 (GA)(Pre-application) APN: 255-250-09, 255-180-04 & 15; 255-260-13, 14, & 16 (Arcadia Homes) Dear Ms. Allen: The San Joaquin Valley Unified Air Pollution Control District (District) has reviewed the project referenced above and offers the following comments: Preliminary analysis indicated that the potential emissions from this project exceed the District's operational thresholds of significance for ozone precursors. These thresholds are 10 tons per year for either of the following two ozone precursor emissions: reactive organic gasses (ROG) or oxides of Nitrogen (NOx). The proposed project should be analyzed to see if Hazardous Air Pollutants (HAPs) are a concern. The District's thresholds of significance for HAPs are the probability of contracting cancer for the Maximally exposed Individual (MEI) exceeds 10 in one million or ground level concentrations of non- carcinogenic toxic air contaminants would result in a Hazard Index greater than 1 for the MEI. The District recommends using the URBEMIS 2002 Version 8.7 program to calculate project area and operational emissions and to identify mitigation measures that reduce impacts. URBEMIS can be downloaded from www.urbemis.com or the South Coast Air Quality Management District's website at hfp://www.aqmd.gov/cega/urbemis.html. If the analysis reveals that the emissions generated by this project will exceed the District's thresholds, this project may significantly impact the ambient air quality if not sufficiently mitigated. The project applicant or consultant is encouraged to consult with District staff for assistance in determining appropriate methodology and model inputs. Questions regarding URBEMIS should be directed to Hector Guerra at(559)230-5800. The District recommends the preparation of an Air Quality Impact Assessment (AQIA) and a Traffic Impact Study to determine impacts when projects are of this size, unless an analysis has been accomplished for a recent previous approval such as a general plan amendment or zone change. Please indicate to the District if the project has.been analyzed and what the results were frpm any previous study. The District does not typically recommend quantifying PM10 emissions from construction activities. The District considers that PM10 emissions are reduced to levels considered less-than-significant through compliance with the District's Regulation VIII (Fugitive PM10 Prohibitions) rules. If construction activity is especially intense, or sensitive receptors are nearby, the District recommends applying the enhanced PM10 control measures listed in the Guide for Assessing and Mitigating Air Quality Impacts(GAMAQI). Based on the information provided, the proposed project will be subject to the following District rules. The following items are rules that have been adopted by the District to reduce emissions throughout the San