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San Joaquin Valley NO V 8 ?005 Air Pollution Control District CommU17it DSelo .pment ov. . -November 7, 2005 ;Reference No. C2005{11494 Rick_Griffin:. Sah�Joagdin County Coitirimunity Dei.pept 1810 East`Hazelton Avenue Stockton, CA95205 Subject, PA=0500728:,(SA) (P.r, -applicatiari) A'N:'1J1 2E(32 Valley Ciydics; Dear Mr. Griffin: The San Joaquin Valley Unified Air Pollution Control District(District) has reviewed the project referenced above and offers the following comments. J The entire San Joaquin Valley Air Basin is classified non-attainment for ozone and fine particulate matter (PM10). This project will contribute to the overall decline in air quality due to increased traffic and ongoing operational emissions. This project may generate significant air emissions and it will reduce the air.quaGty,in•the.San Joaquin Valley.,,;The.project•will_.make it%more.difficult.to meet_mandated,emission reductions.and air_quaUy standards. ; Based on the`informi tion provided in the application for site approval PA-0500726 (SA) (Pre-application) by Valley Organics.for a.".composting.green waste facility", the project will most likely be subject to the permitting requirements of the District and.require a Permit to Operate (PTO)_..Any equipment subject to i the .District's PTO requirements must obtain -an Authority to. Construct (ATC) from the District. Construction of equipment, which requires an ATC, and intimately related appurtenances such as foundations and utility hookups for the equipment, cannot begin until an ATC is obtained. Construction of equipment not requiring a District permit is not subject to this ATC requirement. Depending upon the nature and complexity of the application and staff workload, ATC approval can take several months. For further information, the applicant should contact the District's Small Business Assistance Office at (209) 557-6446 or our Permit Services Section at (209) 557-6400. To avoid unnecessary delays in the project, f applications should be submitted to the District as soon as the project developer has determined the scope of the orojert_ The District considers a composting facility to be a processing facility, not a farming operation, as it does not involve the growing of crops or raising of fowl or animals; therefore, the composting facility is subject to Rule 4102 (Nuisance). The provisions of Rule 4102.3.1 do not apply to odors emanating from agricultural operations in the growing of crops or raising of fowl or animals as defined in Rule 4103 (Open Burning). Per Rule 4102.4.1 a person shall not discharge from any source whatsoever such quantities of air contaminants. or other materials which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public or which endanger the comfort, repose, health or safety of any person. In the event the composting facility creates a public nuisance, it could be in violation and be subject to District enforcement action. Hazardous Air Pollutants (HAPs) The proposed project should be analyzed to see if it is considered near a location of sensitive receptors and if HAPs are a concern. Potential HAPs sources include project equipment, operations, and vehicles (the Air Resources Board (ARB) has designated diesel particulate