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tons/year. The Draft EIR should be revised to evaluate air quality and other impacts for the maximum production rate or the production rate should be restricted to the level evaluated in the Draft EIR. Under CEQA, reasonable worst-case production is always used to estimate B-29 environmental impacts because a facility could lawfully operate at its permitted cont production rate limits with no further environmental or agency review or oversight. Air district permits typically limit a facility's production rate on a daily or hourly basis based on the actual capacity of the facilities' equipment, not based on the — annual production rate discussed in a CEQA document. Therefore, the Draft EIR must be revised to restrict operation of the facility to the levels used to estimate emissions, or the Draft EIR must revise the emissions based on the maximum capacity of the facility's equipment and recirculate the Draft EIR. IV.A.3 Emission Controls The Draft EIR's operational emissions assume that certain controls are in — place. For example, the PM10 emissions from the sand dryer are assumed to be controlled with a fabric filter and the PM10 emissions from sand handling are assumed to be controlled with a wet scrubber. A fabric filter is also assumed to be used on the asphalt plant. (See Exhibit 1.)The unpaved road and other fugitive PM10 emissions assume that 75 percent of the emissions will be controlled, but the B-30 _ Draft EIR does not explain how this will be achieved. (Draft EIR, Appx. D, p. 11.) The Draft EIR does not require the installation of these controls. The CEQA Guidelines, Section 15126.4(a)(1)(A), requires that"[t]he discussion of mitigation measures shall distinguish between the measures which are proposed by project proponents to be included in the project and other measures proposed by the lead, responsible or trustee agency or other persons which are not included but the lead agency determines could reasonably be expected to reduce adverse impacts if required as conditions of approving the project." The Draft EIR is silent as to mitigation measures proposed by the applicant that are embedded in the emission spreadsheets. Thus, the Draft EIR does not establish any obligation to actually use _ the controls assumed in the emission calculations. IV.B CO Emissions Are Significant The Draft EIR evaluated the impact of CO emissions based solely on the increase in traffic generated by the Project. (Draft EIR, Impact 4.6.5, pp. 4.6-28- B31 _ 4.6-30.) However, the Excel spreadsheets reveal that there are other sources of CO emissions that were not disclosed in the Draft EIR, as show in inset Table 2. 99