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San Joaquin County January 23, 2003 NOP for RMC Pacific Materials Page 2 Section 2: projected pollutant emissions generated during the construction and operational phases of the project. The growth-inducing and cumulative impacts analyses should take into consideration the existing and planned development both within the project area and in the surrounding areas. The District recommends the use of the URBEMIS 7G modeling program to calculate the pollutant emissions resulting from motor vehicle trips generated by this development project. Additional guidance is provided in the GAMAQI. Additionally, the EIR should quantify emissions that are individually small but cumulatively significant sources of pollution. This includes, but is not limited to, emissions from natural gas combustion for space and water heating and emissions from _ gas-powered lawn and garden maintenance equipment. URBEMIS 7G may also be used to quantify these emissions. _ As the projects are considered for approval the applicant and the City of Lathrop should consider the toxic risk associated with diesel-fueled engines and vehicles. The California Air Resources Board has issued a report entitled Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles (October 2000). Appendix VII of the report provides several risk characterization scenarios, which may serve as a starting point for estimating risks from diesel engine emissions. The District will work with applicants to review appropriate methodology for estimating toxic risk. Section 3: mitigation measures. Mitigation measures must be included in the EIR that reduce the emissions of reactive organic gases (ROG), nitrogen oxides, carbon monoxide, and PM-10 to the maximum extent feasible. Site design and building construction measures that would reduce air . quality impacts should be included. In addition, measures to reduce vehicle trips, miles traveled, and cold starts should be included in the project. As a result of the Valley's nonattainment status, the District strongly recommends that the project applicant and the City of Lathrop implement all feasible mitigation measures to reduce the amount of ozone precursors that will result from the buildout of this project. The following is a list of potential mitigation measures, the list is not meant to be all inclusive, and the District encourages new innovative ideas. • Use alternative fuel construction equipment. • Minimize idling time (e.g. 10 minute maximum)