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San Joaquin Valley Air Pollution Control District Page 2 District Reference No.20220037 February 10,2022 The District offers the following comments: 1) Project Related Criteria Pollutant Emissions 1a) Construction Emissions Although the construction-related emissions are expected to have a less than significant impact,the District suggests that the County advise project proponents with construction-related exhaust emissions and activities resulting in less than significant impact on air quality to utilize the cleanest reasonably available off-road construction fleets and practices (i.e. eliminating unnecessary idling) to further reduce impacts from construction-related exhaust emissions and activities. 1b) Project Related Operational Emissions—Cleanest Available Truck The San Joaquin Valley will not be able to attain stringent health-based federal air quality standards without significant reductions in emissions from heavy-heavy duty(HHD)Trucks,the single largest source of NOx emissions in the San Joaquin Valley. The District recently adopted the 2018 PM2.5 Plan which includes significant new reductions from HHD Trucks, including emissions reductions by 2023 through the implementation of the California Air Resources Board (CARB) Statewide Truck and Bus Regulation, which requires truck fleets operating in California to meet the 2010 0.2 g/bhp-hr NOx standard by 2023. Additionally, to meet the federal air quality standards by the 2020 to 2024 attainment deadlines, the District's Plan relies on a significant and immediate transition of heavy duty truck fleets to zero or near-zero emissions technologies, including the near-zero truck standard of 0.02 g/bhp-hr NOx established by the California Air Resources Board. Based on the information provided, this Project consists of an agricultural processing, packing, storage, and distribution building that is anticipated to generate HHD truck trips. To reduce impacts from operational mobile source emissions, the District recommends that the following clean air measures be considered for inclusion in the environmental assessment. • Advise fleets associated with Project operational activities to utilize the cleanest available HHD truck technologies, including zero and near-zero (0.02 g/bhp-hr NOx)technologies as feasible. • Advise all on-site service equipment (cargo handling, yard hostlers, forklifts, pallet jacks, etc.)to utilize zero-emissions technologies as feasible. Planning Commission Staff Report, PA-2200090, PA-2100295 (GP, SA) 28 Response Letters