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San Joaquin Valley Air Pollution Control District August 4, 2003 AUG `e5 20030369 John Funderburg Community Dev. Dept. Dev. Services Division 1840 E. Hazelton Ave Stockton CA 95205 Subject: PA-0300337 (SA) DeBrouwer Enterprises LLC. Dear Mr. Funderburng: The Central office will be commenting for Mr. John Cadrett(of the North office) during his vacation. Mr. Cadrett will return from vacation on July 29, 2003, Stanislaus County should continue to send notices and requests for comments to the District's North Office. Please address CEQA related requests to Mr. John Cadrett at San Joaquin Valley Air Pollution Control District, Northern Region Office, 4230 Kiernan Avenue, Suite 130, Modesto, CA 95356-9322. The San Joaquin Valley Unified Air Pollution Control District (District) has reviewed the project referenced above and offers the following comments: The entire San Joaquin Valley is non-attainment for ozone and fine particulate matter (PM10). This project would contribute to the overall decline in air quality due to increased traffic and ongoing operational emissions. Although this project alone would not generate significant air emissions, the increase in emissions from this project, and others like it, cumulatively reduce the air quality in the San Joaquin Valley. The project would make it more difficult to meet mandated emission reductions and air duality standards. A concerted effort should be made to reduce project-related emissions as outlined below: The construction and operation phases of this project will be subject to certain aspects of District Regulation VIII- District Regulation VI11 - Fugitive Dust Rules is a series of rules designed to reduce PM10 emissions generated by human activity, including construction, road building, bulk materials storage, landfill operations, etc. If the proposed parking/work area(s) is(are) unpaved and either generate 75 trips Per day or is(are) .5 acres or larger, then the applicant will have to mitigate dust from the project site. A Dust Control Plan must be submitted for the District's approval at least 30 days before construction activities begin if the project encompasses 40 acres or more or will move more than 2,500 cubic yards per day of material on at least three days of the project. An assistance bulletin has been enclosed for the applicant. Current District rules can be found at: http://www.valleyair.org/rules/1 ruleslist.htm. There are a number of mitigation measures that should be incorporated into the design of this project to reduce the overall level of emissions. (Note: Some of the mitigation measures may already exist as County development standards. All other measures should be implemented to the fullest extent possible.)