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<br /> <br /> <br />Memorandum <br />March 25, 2025 <br />Page 10 <br />21202-23 North County Landfill_AQ_0307 <br />in speculative results.5,6 The methodology used in this analysis is consistent with the California <br />Supreme Court’s ruling regarding Sierra Club v. County of Fresno.7 <br />ANALYSIS AND FINDINGS <br />Consistency with Air Quality Plan <br />As discussed above, the Valley Air District has adopted several air quality attainment plans for <br />particulate matter and ozone over the years that identify measures needed in the SJVAB to <br />attain NAAQS. Emission reductions achieved through implementation of the Valley Air District <br />New Source Review offset requirements are a major component of the Vally Air District’s air <br />quality plans. Since the Valley Air District’s thresholds of significance were developed based on <br />New Source Review offset requirements, projects with emissions below the thresholds of <br />significance for criteria air pollutants would be determined to not conflict or obstruct <br />implementation of the Valley Air District’s air quality plans. As discussed below, the project’s <br />emissions of criteria air pollutants of concern from permitted equipment and activities, as well <br />as from non-permitted equipment and activities, would be below the thresholds of significance. <br />In addition, the project would be required to comply with applicable rules and regulations, such <br />a Regulation VIII (Fugitive PM10 Prohibitions). Therefore, the project would not conflict with or <br />obstruct implementation of applicable air quality plans. <br />Criteria Air Pollutant Emissions <br />The project would not change the North County Landfill’s design capacity of 41.2 million cubic <br />yards of disposal and would not involve construction of new facilities. The project would <br />increase the maximum amount of allowed daily refuse disposal and the number of daily <br />incoming refuse trucks from 1,200 tons per day and 850 trucks per day to 4,000 tons and 1,200 <br />trucks per day. This increase would involve a change in refuse truck routing; approximately 51 <br />transfer trucks that currently go to the Foothill Landfill would be re-routed to the North County <br />Landfill. The increase in daily refuse disposal would also increase the use of off-road equipment <br />associated with landfill operations. Up to six new employees would be needed for the increase <br />in waste disposal and truck trip-related activity. <br /> <br />5 Brief for South Coast Air Quality Management District as Amicus Curiae Supporting Respondents, Sierra Club, Revive <br />the San Joaquin, and League of Women Voters Fresno v. County of Fresno and Friant Ranch (SCAQMD Amicus <br />Curiae), 2018, 6 Cal.5th 502, Case No. S219783. <br />6 Brief for San Joaquin Valley Unified Air Pollution Control District as Amicus Curiae Supporting Respondents, Sierra <br />Club, Revive the San Joaquin, and League of Women Voters Fresno v. County of Fresno and Friant Ranch (SJVUAP <br />Amicus Curiae), 2018, 6 Cal.5th 502, Case No. S219783. <br />7 California Supreme Court, 2018. Sierra Club, Revive the San Joaquin, and League of Women Voters Fresno v. County <br />of Fresno and Friant Ranch, 6 Cal.5th 502, Case No. S219783.