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II.6.2 Short-Term Impacts Were not Evaluated The CEQA Guidelines, Section 15126.2(a), require that"[djirect and indirect significant effects of the project on the environment shall be clearly identified and described, giving due consideration to both the short-term and long-term effects." (Emphasis added). The Draft EIR solely relied on the SJVAPCIYs annual — significance thresholds of 10 tons per year for NOx and ROG to determine the significance of all air quality impacts and completely ignored short-term impacts. (Draft EIR,Tables 4.6-4,4.6-5.) Ambient air quality standards, which must be protected,exist for shorter time periods — 1 hour, 8 hours and 24 hours. (Draft EIR, Table 4.6-1.) Intermittent activities, such as construction and mining, have very high short-term emissions that are averaged out when presented on an annual basis. These short-term peaks are _ missed entirely when only annual thresholds are used, as here. The SJVAPCD has not developed short-term, i.e. daily or hourly significance thresholds, like most other B-13 air districts. (GAMAQI,3 pp. 24-25.) — The use of the SJVAPCUs annual significance thresholds for short-term emissions is inequitable and not protective of the air quality in the air basin and does not constitute adequate review under CEQA. Recognizing this problem, the SJVAPCD is aiming to revise its quantitative significance thresholds and intends to add new significance thresholds for construction and cumulative impacts in the near future. (Meyer 01/064.) Given the lack of short-term quantitative significance thresholds in the SJVAPCIYs guidance, the County could have conducted ambient air quality dispersion modeling to evaluate whether ambient air quality standards would be — violated. (See Comment II.A.) In the alternative, the County could have used short- term significance thresholds developed by other air districts to screen for significance of criteria pollutant emissions. (See discussion in Comment II.B.2.) The Draft EIR should be revised to evaluate the significance of both short-term and annual emissions and the Draft EIR should be recirculated for review. 3 San Joaquin Valley Air Pollution Control District,Guide for Assessing and Mitigating Air Quality Impacts("GAMAQP'). 4 Petra Pless,phone conversation with Chrystal Meyer,San Joaquin Valley Air Pollution Control — District, (559)230-5835, on January 27,2006. 6