SU0004094 - Laserfiche WebLink

Home Browse Search

1. Joaquin Valley air basin into compliance with air quality standards. (Draft EIR, pp. 4.6-8/9.) However, the Draft EIR does not contain any analysis of whether the B_9 increase in emissions from the Project individually and cumulatively would conflict cont with or obstruct implementation of these air quality plans. The Draft EER should be revised to contain a responsive analysis and should be recirculated for review. The Draft EIR also states that the Project would be considered to have a significant air quality impact if it violates any air quality standard or contributes substantially to an existing or projected violation of air quality standards. (Draft EIR, p.4.6-17.) This is normally done by using dispersion models to estimate the increase in ambient concentrations resulting from Project emissions. For most pollutants, the Draft EIR does not contain any such analysis to determine if emissions from Project construction and operation would cause or contribute to a violation of an ambient B t L air quality standard. The discussion in Comment VI indicates that Project construction and operation would contribute to existing violations of the state and federal ambient air quality standards for ozone, PM10, and PM2.5. Further, analyses 6' for other similar projects indicate that the Project would likely cause violations of th California 1-hour NO2 standard. Thus, the Draft EIR should be revised to include an ambient air quality analysis for ozone, PM10, PM2.5, and NO2 and should be ` recirculated for review. LII.B The Significance Criteria Are Incomplete The Draft EIR reports Project emissions in tons per year. The NOx and ROG emissions were compared to annual operational significance thresholds adopted by B the San Joaquin Valley Air Pollution Control District("SJVAPCU') to determine significance. (Draft EIR, Table 4.6-4,4.6-5.)There are three problems with this L approach, each separately discussed below. LII.B.I The Significance of CO, PM 10, PM2.5, and SO2 Emissions Was not Evaluated LThe construction and operation of the Project will emit ROG, NOx, CO, PM10, PM2.5, and sulfur dioxide ("SO2"). The Draft EIR did not report PM2.5, CO and SO2 emissions from most sources and did not evaluate the significance of the B-12 L PM10, PM2.5, CO, and SO2 emissions from any source because the SJVAPCD does not have a significance threshold for these pollutants. (Draft EIR, Tables 4.64 and 4.6-5.)The absence of local significance thresholds does not excuse the County from 6- analyzing the significance of an impact. The Draft EIR should be revised to include emissions of all criteria pollutants and the significance of these emissions should be Levaluated using significance thresholds from other air districts or by conduction dispersion modeling. L 5 L