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t s� San Joaquin Valley RECEIVED is Air Pollution Control District DEC - 6 2005 Community Development Dept. December 5, 2005 Reference No. C200501696 Kathy Allen San Joaquin County Community Development Dept. 1810 East Hazelton Avenue Stockton, CA 95205 Subject: PA-0500725 (UP)—APN 249-110-39 Dear Ms. Allen: The San Joaquin Valley Unified Air Pollution Control District (District) has reviewed the project referenced above and we suggest that a Negative Declaration would be appropriate in addressing only air quality related issues. We believe this project's emissions can be mitigated to a less than significant level by acquiring District permits where necessary, complying with applicable District rules and regulation, and implementation of certain mitigation measures. However, we have not analyzed the cumulative impacts to water, cultural, biological, or other resources, as the air quality resource is our area of expertise. We also offer the following comments: The entire San Joaquin Valley Air Basin is designated non-attainment for ozone and particulate matter (PM10 and PM2.5). This project would contribute to the overall decline in air quality due to increased traffic and ongoing operational emissions. Preliminary analysis indicates that this project alone would not generate significant air emissions. However, the increase in emissions from this project, and others like it, cumulatively reduce the air quality in the San Joaquin Valley. A concerted effort should be made to reduce project-related emissions as outlined below: Based on the information provided, the proposed project will be subject to the following District rules. The following items are rules that have been adopted by the District to reduce emissions throughout the San Joaquin Valley, and are required. This project may be subject to additional District Rules not enumerated below. To identify additional rules or regulations that apply to this project, or for further information, the applicant is strongly encouraged to contact the District's Small Business Assistance Office at (209) 557-6446. Current District rules can be found at http://www.valleyair.org/rules/1 ruleslist.htm. Regulation VIII (Fugitive PM10 Prohibitions) Rules 8011-8081 are designed to reduce PM10 emissions (predominantly dust/dirt) generated by human activity, including construction and demolition activities, road construction, earthmoving activities, bulk materials storage, paved and unpaved roads, carryout and trackout, landfill operations, etc. The District's compliance assistance bulletin for construction sites can be found at: http://www.valleyair.org/busind/comply/PM10/Req%20V111%20CAB.pdf. If a non-residential site is 1.0 to less than 5.0 acres, an owner/operator must provide written notification to the District at least 48 hours prior to his/her intent to begin any earthmoving activities as specified in Section 6.4.2 of Rule 8021. A template of the District's Construction Notification Form is available at: http://www vallevair orq/busind/comply/PM10/forms/Req%20V111%2ONotification%20-%2011-17-2004 pdf. David I.Crow 1111111a/ Executive Director/Air Pollution Control Officer Northern Region Office Central Region Office Southern Region Office 4800 Enterprise Way 1990 East Gettysburg Avenue 2700 M Street,Suite 275 Modesto,CA 95356-8718 Fresno,CA 93726-0244 Bakersfield,CA 93301-2373 (209)557-6400 • FAX (209)557-6475 (559)230-6000 • FAX(559) 230-6061 (661)326-6900 • FAX (661)326-6985 www.valleyair.org