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San Joaquin Valley Air Pollution Control District May 1, 2006 Reference No. C20060983 Chandler Martin San Joaquin County Community Development Dept. Development Services Div. 1810 E. Hazelton Ave Stockton, CA 95205 Subject: PA-0500838(Major Subdivision-small lot), PA-0600161 (Major Subdivision-large lot), PA- 0600127(Development Agreement)—College Park at Mountain House Specific Plan III— Global Investment 8 Development, LLC Dear Mr. Martin: The San Joaquin Valley Unified Air Pollution Control District(District) has reviewed the project referenced above and offers the following comments: The comment deadline for the project was April 21, 2006. However, the District did not receive the request for comment until April 26, 2006. Per our discussion last week, although these comments are being submitted after the due date, the District requests that they be considered in the San Joaquin County staff analysis. Please make every effort to provide a reasonable review period. If your agency is working in an expedited time frame, the District will accept emails or faxes with a hardcopy following shortly thereafter. The entire San Joaquin Valley Air Basin is designated non-attainment for ozone and particulate matter (PM10 and PM2.5). This project will contribute to the overall decline in air quality due to construction activities in preparation of the site, and ongoing traffic and other operational emissions. Preliminary analysis, based on the information provided, indicates that this project may potentially generate significant air emissions and will be subject to the District's Indirect Source Review(Rule 9510). Rule 9510 was adopted to reduce the impacts of growth in emissions from all new development in the San Joaquin and requires applicants subject to the rule to provide information that enables the District to quantify construction, area and operational PM10 and NOx emissions, and potentially mitigate a portion of those emissions. More information on Rule 9510 is listed below in the Applicable District Rules section. The District recommends the preparation of an Air Quality Impact Assessment(AQIA) and Traffic Impact Study (TIS) to determine impacts when projects are of this size. 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 htto:i/www.agmd.gov/cega/urbemis.html. If the preliminary analysis indicates that the project exceeds the District's Thresholds of Significance for ozone precursors (10 tons/year of either Reactive Organic Gases or Oxides of Nitrogen), then the District recommends the preparation of a full AQIA that describes the air quality setting and identifies measures that reduce air quality impacts. The project applicant or consultant is encouraged to consult with District staff for assistance in determining appropriate methodology and model inputs. Northern Region Office Central Region Office Southern Region Office 4800 Enterprise Way 1990 East Gettysburg Avenue 2700 M Street,Suite 275 Modesto,CA 95356-8718 Fresno,CA 93726-0244 Bakersfield,CA 93301-2373 (209)557-6400 • FAX(209)557-6475 (559) 230-6000 • FAX(559)230-6061 (661)326-6900 • FAX(661)326-6985 wsvw.vallevairare