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A loaded truck trip is considered a round trip (loaded truck leaves facility, travels to job site, and returns empty), and is comprised of two one-way trips. Project-generated trips during subsequent hours (from 10:00 PM to 5:00 AM) would have less of an effect on traffic flow conditions than during the above-described peak nighttime hour, as Project trips would be lower, and background traffic volumes during those later hours are lower. Thus, the proposed Project would neither conflict with an applicable plan, ordinance or policy establishing measures of effectiveness for the performance of the circulation system, nor conflict with an applicable congestion management program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways. Mitigation: None required. Air Quality and Climate Change The EIR determined that the operation of the asphalt batch plant during the proposed nighttime operations is considered a potentially significant impact even after mitigation. The San Joaquin Valley Air Pollution Control District has determined that a minimum buffer for an asphalt batch plant from residences is one mile. However, the asphalt batch plant at the project site is located less than one mile from many residences, the closest being 0.3 miles (1,600 feet) north of the plant. In a letter dated November 16, 2011 from the San Joaquin Valley Air Pollution Control District it stated, "under the current request for nighttime operations an increase in odor complaints would be expected". In 2008 the District received a total of 3 (three) complaints regarding operations at the site alleging that odors from the facility are posing a nuisance. In 2009 seven (7) and 2011 eleven (11). The District's threshold of significance for odor impacts is more than one confirmed compliant per year averaged over a three year period, or three unconfirmed complaints per year averaged over a three-year period. As a result odors from the facility should be considered to have a significant impact on nearby residential areas and other sensitive receptors. Thus, a qualitative analysis was done based on previous odor complaints attributed to the facility from the operation of the asphalt batch plant. Dispersion modeling was conducted to evaluate concentrations of Hydrogen Sulfide and potential odor impacts at the nearest sensitive residential receptors. Dispersion modeling analysis shows a potential maximum 1-Hour Hydrogen Sulfide concentration of 20 pg/m'. The California ambient air quality standard for Hydrogen Sulfide is 42 pg/m'. Thus, the project is not expected to result in ground-level concentration known to produce odor impacts; however, the number of complaints from the operation of the asphalt batch plant is considered potentially significant. While dispersion modeling does not show a potentially significant impact based on Hydrogen Sulfide concentration, the record of previous odor complaints and the potential for increased sensitivity at night, would result in a potentially significant impact. Impact 3.3.1: The project could create objectionable odors affecting a substantial number of people. This impact would be potentially significant. Mitigation Measures: Measure 3.3.1. The operator shall incorporate additives to the rubberized asphalt mix in accordance with accepted industry standards. The objective of the additives shall be to reduce offensive odors associated with the production of rubberized asphalt. The operator shall consider technological improvements to reduce odors, as they become available, and incorporate if feasible. The operator shall ensure that loading, unloading, and material handling activities are carried out efficiently and without delays to avoid excessive odors. The operator shall use water trucks and/or sprinkler systems to reduce the potential dust associated with the operation. San Joaquin County QX-89-0002/Aggregates Inc. Community Development Page 6