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San Joaquin Valley Air Pollution Control District MAY 2 3 2001 Jim Van Buren May 21, 2001 communay Ljdvrfup11fc,fL San Joaquin County Community Development Department Development Services Division 1810 East Hazelton Avenue Stockton, CA 95205 SUBJECT: L.00KEFORD OAKS (SU-00-1) Dear Mr. Van Buren: The San Joaquin Valley Air Pollution Control District (District) has reviewed the proposed project and offers the following comments: The San Joaquin Valley's air quality has been designated nonattainment by the EPA and by the Air Resources Board (ARB)for 03 (ozone) and PM-10(fine particulate matter, dust). The Federal Clean Air Act (CAA) and the California Clean Air Act require areas that are designated nonattainment to reduce emissions until standards are met. Based on the limited information provided, it appears that the construction and buildout of this project will contribute to the overall decline in air quality. Both short and long-term impacts related to the construction and operational phases of this project will deteriorate the ambient air quality thereby making it more difficult to meet mandated emission reductions and air quality standards. As a result, the District has developed both regulatory and advisory measures designed to reduce PM-10 and ozone precursor emissions. Therefore the District recommends that the project be subject to an EIR._The air quality section of the EIR should have three main components. Section one should provide a description of the regulatory environment and existing air quality conditions impacting the San Joaquin Valley. Section two should provide estimates of existing emissions o ulation vehicle use, missions related to an population,and projected pollutant e Y in increases p and construction activities along with an analysis of the effects of these increases. Section three should identify and discuss all feasible mitigation measures which, after r implementation, will reduce the air quality impacts generated by this project. i Section 1: Regulatory Environment and Existing Air Quality The District has several sources of information available to assist with the existing air quality and regulatory environment section of the DEIR. The District's Guide for Assessing and Mitigating Air Quality Impacts contains discussions regarding the existing air quality conditions and trends of the San Joaquin Valley Air Basin, including thosep ollutants of particular concern: ozone, PM-10, and carbon monoxide. It includes David L. Crow Executive Director/Air Pollution Control Officer Northern Region Office Central Region,Office Southern Region Office' 4230 Kiernan Avenue, Suite 130 " 1990 E. Gettyshurg Avenue 2700 M Street, Suite 275 Modesto, CA 95356-9322 Fresno, CA 93726-0244 Bakersfield, CA 93301-2370 (209) 557-6400 ♦ FAX (209) 557-6475 (559) 230-6000 ♦ FAX (559) 230-6061 (661) 326-6900 ♦ FAX (661) 326-6985