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<br /> <br /> <br />Memorandum <br />March 25, 2025 <br />Page 12 <br />21202-23 North County Landfill_AQ_0307 <br />distances for each trip category. The input parameters and assumptions used to estimate <br />criteria air pollutant emissions from off-road heavy construction equipment and mobile sources <br />are provided in Attachment A. <br />The estimated annual emissions during operation of the project are presented in Table 2. As <br />shown in Table 2, the project’s estimated net change in ROG, NOx, PM10, PM2.5, CO, and SOx <br />emissions during operation are below the Valley Air District’s threshold of significance and <br />would not result in a cumulatively considerable net increase in criteria air pollutants for which <br />the region is in nonattainment; therefore, the project’s impact on regional air quality would be <br />less than significant. <br />Table 2. Estimated Annual Criteria Air Pollutant and Precursor Emissions from Non- <br />Permitted Equipment and Activities (tons per year) <br />Emission Scenarios ROG NOx PM10 PM2.5 CO SOx <br />Off-Road Equipment <br />Baseline Condition 0.24 6.79 1.06 0.63 7.60 0.01 <br />Project Condition 0.35 7.82 1.87 1.07 12.73 0.02 <br />Net Difference 0.11 1.04 0.81 0.44 5.13 0.01 <br />On-Road Mobile Sources Baseline Condition 0.13 3.70 1.40 0.31 0.18 0.03 <br />Project Condition 0.13 3.54 1.48 0.31 0.18 0.04 <br />Net Difference 0.01 -0.16 0.08 0.00 0.002 0.004 <br />Total Net Difference 0.11 0.88 0.90 0.45 5.13 0.01 <br />Valley Air District Thresholds 10 10 15 15 100 27 <br />Threshold Exceeded? No No No No No No <br />Source: Attachment A. <br />Landfill Gas <br />As discussed above, the project would increase criteria air pollutant emissions attributable to <br />the potential increases in exhaust emissions from the flare. The reported emission inventory for <br />the North County Landfill in 2023 was provided by the applicant (Attachment B) and is <br />summarized in Table 3 as a representation of the baseline condition. As shown in Table 3, <br />under the baseline condition, emissions of ROG, NOx, PM10, CO, and SOx from the flare are <br />relatively low – approximately two orders of magnitudes lower than the applicable Valley Air <br />District operation thresholds for permitted sources. For the project condition, the maximum <br />criteria air pollutant emissions from the flare were conservatively estimated using emission <br />limits obtained from the project’s current Title V permit and the heat input to flare obtained <br />from the 2023 inventory. Detailed calculations are provided in Attachment A. For the project