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The impacts to air quality due to total particulate matter emissions from the operation of the project are considered significant and unavoidable. All feasible and reasonable changes or alterations have been required in, or incorporated into, the project that substantially lessen the potentially significant effect as identified in the Final EIR. Brief Explanation of the Rationale for the Finding CEQA requires that all feasible and reasonable mitigation measures be applied to the project to reduce the impacts from construction and operation on air quality. Implementation of Mitigation Measures 4.1-1, 4.1-2 and 4.1-6, described in detail above, would reduce total particulate matter emissions. No other reasonable or feasible mitigation has been identified that will reduce impacts to air quality for the project. Potential Significant Effect Without appropriate mitigation,the project has the potential to significantly impact air quality due to total emissions from the operation of the project. Description of Specific Impact All of the Project components that contribute to potential emissions of NOx, VOC and PMIo from operation of the Project are presented below. This includes each Project component along with its mitigated emissions, and compares the net increase in emissions to the established thresholds of significance. Other total Project emissions of pollutants such as SOx, CO, and odors, or impacts to Toxics,Visibility for Military Flight Corridors, or Valley Fever Exposure were determined to be at a level of less than significant impact. Total project operational emissions, after mitigation and full compliance with all rules and regulations, continues to exceed the thresholds. The totals are NOx—41.93 tpy (10 tpy significance threshold), VOC - 12.74 tpy (10 tpy significance threshold), and PMIo - 64.4073 tpy (15 tpy significance threshold). These exceedances along with the related health effects are significant, particularly when viewed against the background of the serious nature of existing problems and projections in the San Joaquin Air Basin. The San Joaquin Valley Basin is in nonattainment, although plans and projections have been formulated to achieve the required gains by the deadlines imposed by EPA. This project will produce additional emissions that have to be mitigated to implement the attainment plans and meet the EPA deadlines. Given the serious situation in the air basin and as required under CEQA, all reasonable and feasible mitigation must be imposed on this project. Mitigation Measure 4.1-7 requires the applicant to execute a Development Mitigation Contract with the District to fund emission reduction projects. This fully enforceable contract will address the remaining emissions of NOx, VOC and PMIo after all design features and other mitigation has been implemented. While the goal will be to reduce all emissions so that there is no net increase from project implementation, the final reductions will be based on available projects which could involve trading ROG reductions for PMIo reductions. As such the actual reduction in emissions may not actually be the equivalent of"zero'. As such although all feasible and reasonable mitigation has been imposed, given the science of air quality quantification, there may be remaining contributions of pollutants and related health impacts from the project. Given the serious nature of the existing problems and projections in the Basin, air quality impacts remain significant. A socioeconomic evaluation for mitigation was performed on this project to calculate reduction of emissions feasible based on economic benefit of the project. A calculation of 9.4 million dollars for 100% mitigation of all left over air pollutants after mitigation was determined to economically infeasible. _.. _ _ ...__ _...... _..._. _ ... . - ._..,.. . ..__...... .._.,..... - --. ___.. _.. ..- ----._.--._ Findings of Fact—Section 15091 March 15,2016 H.M. Holloway Landfill Modification Project Final Board of Supervisors 13