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11. THE AIR QUALITY ANALYSIS IS FUNDAMENTALLY FLAWED <br /> The Draft EIR states that the Project would have a significant air quality _ <br /> impact if it would: <br /> — Conflict with or obstruct implementation of the applicable air quality <br /> plan(s); <br /> — Violate any air quality standard or contribute substantially to an existing <br /> or Project air quality violation; <br /> — Result in a cumulatively considerable net increase of any criteria pollutant <br /> for which the Project region is nonattainment under an applicable federal — <br /> or state ambient air quality standard (including releasing emissions which <br /> exceed quantitative thresholds for ozone precursors — i.e., 10 tons per B-e _ <br /> year of ROG or NOx); <br /> — Expose sensitive receptors to substantial pollutant concentrations, <br /> resulting in a cancer risk greater than 10 in one million or a hazard index <br /> greater than 1; <br /> — Create objectionable odors affecting a substantial number of people; <br /> — Cause a net increase in pollutant emissions of ROG or NOx exceeding <br /> 10 tons per year; <br /> — Cause a violation of state CO concentration standards; or <br /> — Cause visible dust emissions due to onsite operations in violation of San _ <br /> Joaquin Valley Air Pollution Control District's Regulation VUL (Draft EIR, <br /> pp. 4.6-17/18.) <br /> There are two major problems with this set of significance criteria. First, the <br /> Draft EIR did not conduct any analyses to determine if some of the criteria were met. <br /> Second, the list of significance criteria is incomplete. These two problems are <br /> discussed below. <br /> IIA The Draft EIR Did not Conduct Any Analyses to Determine Compliance <br /> with some Significance Criteria <br /> The Draft EIR stated that the Project would be considered to have a <br /> significant air quality impact if it conflicts with or obstructs implementation of an air B-9 <br /> quality plan. (Draft EIR, p. 4.6-17.) The Draft EIR indicates that the Project would _ <br /> emit large amounts of pollutants, including those that have caused the San Joaquin <br /> Valley Air Basin to be classified as being in nonattainment — ROG, NOx, and PM10. <br /> (Draft EIR, Table 4.6-5A.) A number of plans have been developed to bring the San — <br /> 4 <br />