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Air Quality and Greenhouse Gas Technical Report Griffith Energy Storage Project 2.5.1 Would the Project conflict with or obstruct implementation of the applicable air quality plan? Less than significant impact. The Project would not conflict with existing land uses or result in population growth. The Project would comply with applicable SJVAPCD rules and regulations, such as Regulation VIII (Fugitive PM,o Prohibitions) and IX (Mobile and Indirect Sources)which are discussed in detail in Section 2.2.3.1. Rule 9510 requires reductions in NOx and diesel particulate matter(as PM10). In addition, the Project would not result in a long-term increase in the number of trips or increase the overall vehicle miles traveled in the area. Worker vehicle trips, vendor trucks, and haul trucks would be generated during the proposed construction activities but would cease after construction is completed. NOx emissions during construction would not exceed the SJVAPCD significance threshold. Additionally, as discussed in Section 2.2.3.1, compliance with SJVAPCD Regulation VIII and Rule 9510 would further reduce the Project's less than significant NOx emissions. During the longer-term operational phase, the Project would have routine inspection and maintenance activities that would result in a net increase in emissions although, as discussed in Section 2.5.2, the increase in emissions would not exceed any significance threshold or violate any SJVAPCD rule or regulation. The purposes of Rule 9510 are to reduce emissions from nitrogen oxide (NOx)and particulate matter of 10 microns or less (PM 10) associated with construction and operation of new development projects in the San Joaquin Valley. Specifically, Rule 9510 was promulgated to reduce the growth in NOx and PM10 emissions associated with new development projects, including transportation and transit development projects in the San Joaquin Valley. The Rule 9510 NOx and PM10 reduction requires at least 20 percent reduction of NOx construction emissions and 45 percent of construction diesel exhaust particulate matter(expressed as PM,o). The rule assures that the Project will not interfere with SJVAPCD attainment plans. Table 7 provides NOx and PM,o construction exhaust emissions with and without Rule 9510 NOx and PM,o emissions reductions, and the percent reduction from the use of Tier 4 engines for equipment greater than 85 horsepower. Table 7. Rule 9510 NOx and PM,o Reductions NOx Diesel Exhaust PMio Exhaust Emissions (tons per year) (tons per year) 0 - 2 2025 025 2024 No Reductions 9.06 0.29 0.38 0.01 Rule 9510 Reductions 5.13 0.09 0.21 0.003 Percent Reduction 43% 69% 45% 70% 2.5.2 Would the project violate any air quality standard or contribute substantially to an existing or projected air quality violation? Construction Emissions Less Than Significant Impact. The SJVAPCD has established annual significance thresholds to address pollution sources associated with general construction activities, such as the operation of on-site construction equipment, fugitive dust from site grading activities, and travel by construction workers. In addition to the SJVAPCD annual significance thresholds, the SJVAPCD also recommends the use of daily emissions thresholds for the evaluation of project impacts on localized ambient air quality. Based on these recommended thresholds, the proposed Project would result in a significant contribution to localized ambient air quality if on-site emissions would exceed a daily average of 100 lbs/day for any of the pollutants evaluated. OTETRA TECH 24 July 2023