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4.1 – Air Quality Draft Environmental Impact Report February 2021 14800 W. Schulte Road Logistics Center 4.1-34 4.1.4 Impacts Analysis Threshold A: Would the Project conflict with or obstruct implementation of the applicable air quality plan? Significant and Unavoidable Impact. A project is non-conforming with an air quality plan if it conflicts with or delays implementation of any applicable attainment or maintenance plan. The SJVAPCD has prepared plans to attain federal and state O3 and PM ambient air quality standards as required under the federal and California Clean Air Act, as detailed in Section 4.1.2. The SJVAPCD has established thresholds of significance for criteria pollutant emissions, which are based on SJVAPCD New Source Review offset requirements for stationary sources. Stationary sources in the SJVAPCD jurisdiction are subject to some of the toughest regulatory requirements in the nation. Emissions reductions achieved through implementation of the SJVAPCD offset requirements are a major component of SJVAPCD’s air quality plans. Thus, projects with emissions below the thresholds of significance for criteria pollutants would not conflict or obstruct implementation of the SJVAPCD’s air quality plan (SJVAPCD 2015a). As discussed for Threshold B, below, the Project would exceed the SJVAPCD threshold for NOx during operations. Therefore, the Project would potentially conflict with or delay implementation of the SJVAPCD attainment plans and would result in a potentially significant impact. Implementation of Mitigation Measure (MM-)AQ-1 through MM-AQ- 3 would reduce the Project’s impacts; however, impacts would remain significant and unavoidable. Threshold B: Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the Project region is non-attainment under an applicable federal or state ambient air quality standard? Significant and Unavoidable Impact. Past, present, and future development projects may contribute to adverse air quality impacts in the SJVAB on a cumulative basis. By its nature, air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and present development, and the SJVAPCD develops and implements plans for future attainment of ambient air quality standards. Based on these considerations, project-level thresholds of significance for criteria pollutants are used in the determination of whether a project’s individual emissions would have a cumulatively considerable contribution on air quality. If a project’s emissions would exceed the applied significance thresholds, it would have a cumulatively considerable contribution. Conversely, projects that do not exceed the project-specific thresholds are generally not considered to be cumulatively significant. Construction and operation of the Project would result in emissions of criteria air pollutants that may result in a cumulatively considerable net increase in emissions of criteria air pollutants for which the SJVAB is designated as nonattainment under the NAAQS or CAAQS. As discussed in Section 4.1.2, the SJVAB has been designated as a nonattainment area for O3, PM10, and PM2.5 under national and/or California standards. The following discussion quantitatively evaluates potential short-term construction and long-term operational impacts that would result from implementation of the Project. Construction Emissions Construction of the Project would result in the temporary addition of pollutants to the local airshed caused by on - site sources (i.e., off-road construction equipment, soil disturbance, and ROG off-gassing) and off-site sources (i.e., vendor trucks and worker vehicle trips). Construction emissions can vary substantially from day to day depending on the level of activity, the specific type of operation, and for dust, the prevailing weather conditions. Therefore, such emissions levels can only be approximately estimated with a corresponding uncertainty in precise ambient air quality impacts.