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Draft Environmental Impact Report Page IV.D-14 Forward Landfill Expansion I.. If a project cannot meet the above requirements,it should be presumed to have significant impacts related to climate change and all feasible GHG mitigation measures (i.e., carbon offsets) should be implemented. ' SJVAPCD Final Draft Climate Change Action Plan On June 30, 2009,the SJVAPCD released a proposal that would instruct lead agencies within the District on how to determine whether GHG emissions from a proposed project would be significant for CEQA purposes. The SJVAPCD plan would rely on a set of performance measures to mitigate a projects GHG impact without necessarily quantifying its emissions. With potential applicability to this proposed project, Best Performance Standards are provided for 1)non-emergency flares with rated heat release greater than five million BTU per hour13 and 2) landfill 'Operations.34 Under the Plan, landfills would comply with CARB Regulation to Reduce Methane Emissions from Municipal Solid Waste Landfills.15 Existing Air Quality + i The SJVAPCD's regional air quality monitoring network provides information on existing ambient concentrations of criteria air pollutants. Monitored ambient air pollutant concentrations reflect the number and strength of emissions sources and the influence of topographical and meteorological factors.Table IV.D-2 presents a five-year summary of air pollutant (concentration) data collected at the monitoring station in the vicinity of the project area on Hazelton Street in Stockton; located seven miles to the northwest of the Forward Landfill Pollutant concentrations measured at this station should be representative of background air pollutant concentrations at the project site. However,background concentrations can vary among different locations within an area. Within Table IV.D-2, these measured air pollutant concentrations are compared with CAAQS and NAAQS. The monitoring data show that ozone, PM,,,, and PM2.5 periodically exceeded the AAQS. I i 1a Combustion shall be performed in an alternate device in lieu of a flare which produces useful energy which r would have otherwise been required(utilized as fuel in an engine,boiler,turbine or delivered to a natural gas pipeline,etc.)where the proposed operation is non-emergency.Emergency flares shall utilize a flow-sensing ignition device rather than a continuous pilot and non-GHG purge gas 14 SJVAPCD Climate Change Action Plan,http://www.valleyair.org/Programs/CCAP 06-30- { 091 DRAFT%20CCAP%20GHG o20staff%20report lune`7.2030,%202009.pdf,June 30,2009. 15 CARB,Proposed Regulation to Reduce Methane Emissions from Municipal Solid Waste Landfills, http://www.arb.ca.sov/regact/20091landfills091isor.pdf,2009. The regulation includes CH4 reduction " strategies such as installation of collection and control systems for landfills that would otherwise be exempt by current regulations,design of collection and control systems to capture maximum amounts of CH4 produced,continuous operation of CH4 control equipment,Improved leak standards(200 ppmv)for CH4 collection and control system components as well as landfill surface emissions,99%CH4 destruction ' efficiency for flares and methane-fire energy recovery devices,and other enhanced source testing,inspection, monitoring and operating standards. f ,