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i0. Draft Supplemental Environmental Impact Report Page IV.D-26 Forward Inc.Landfill 2014 Expansion Project Lsequestration of materials in the landfill were considered as a credit against emissions, none of the scenarios would exceed the 25,000 metric ton annual limit. Also, none of the Project scenarios would exceed 25,000 metric ton annual limit when compared to the Current Permitted emissions. However, this analysis does not consider sequestration of !.. carbon in the landfill as a credit against emissions, and therefore under both the project scenarios (Flare-Current Actual and LFG-Current Actual scenarios) the project would exceed the 25,000 metric ton increase annual limit compared with existing emissions. ` Considering all three items in total and given the compliance with CARB's Landfill Methane Rule and the energy efficient location of the landfill, the project would generally be in compliance with the state's goals for reducing GHG emissions. Regardless, the t project would result in an increase above the 25,000 metric ton annual limit(at the y" maximum acceptance rate—when compared to the current actual baseline) resulting in additional impacts in California (the project GHG emissions would be similar to emission levels from major sources). Thus,because of the emissions that would be generated from maximum operations, this impact is considered potentially significant. Mitigation Measure D.4. (Same as 2013 EIR Mitigation Measure D.5.): Both the Flare ip. and LFG engine options would require feasible mitigation measures to further reduce GHG emissions. The landfill operators shall annually report GHG emissions from the project(actual operations)to the County and SJVAPCD. If project operations exceed 25,000 metric tons of CO2e per year by 2020, then the landfill shall purchase verifiable GHG credits to offset the remaining project emissions above 25,000 metric tons of CO2e per year. Additional GHG credits shall be purchased every five years if the annual reports indicate that the credits have not offset excess GHG emissions (those above 25,000 metric tons of CO2e per year)in the prior five years. The purchase of the verifiable GHG credits would reduce the impact to a level that is less than significant. Impact D.5.The project would contribute to a cumulative air quality impact in the project area (Revises 2013 EIR Impact D.6.). According to the SJVAPCD GAMAQI, cumulative impacts should be assessed for ozone, PMIo, CO and TAC. Ozone impacts are the result of the cumulative emissions from numerous sources in the region and transport from outside the region. Ozone impacts are assessed based on the emissions of NO,,and VOC (ozone precursors). The proposed project would have a less than significant impact on ozone impacts (after mitigation). However, cumulative projects within the project vicinity would potentially result in a significant impact for ozone. The residual emissions from the project(emissions after mitigation and emissions from the extended years of landfill operations, and increased daily acceptance rate [above existing actual emissions], as a result of the project) would contribute to the overall ozone impact in the region. PMIo impacts are assessed by determining exposure to sensitive receptors near the project site from earth disturbing activities from the current project and any nearby projects that may occur at the same time. According to SJVAPCD GAMAQI,if the level of earth disturbing activity may cause an adverse impact, enhanced dust control measures should be included to reduce the impact to less than significant levels. Thus, with Mitigation Measure D.2a and D.2b,the impacts of PMIo from the project would be less than L significant.However, the project would add to the cumulatively significant impact for particulate matter within the project vicinity. Because the project would result in PMIo emissions from traffic and operations every day(due to the extended years of landfill L, l