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Contrary to the Draft EIR's conclusion, fugitive dust PM10 emissions are not adequately mitigated to less than significant levels by implementation of the _ SJVAPCD's Regulation VIII. (See Comment III.B.) Numerous additional feasible B-15 cont mitigation measures exist and should be required to further mitigate the considerable emissions from the Project. (See Comment III.C.) III.A Project Construction NOx And PM 10 Emissions Are Significant And Unmitigated The Draft EER estimated construction engine emissions of ROG, NOx, CO, and PM10 in tons per year. The NOx and ROG emissions were compared to the SJVAPCD's annual operational significance thresholds to determine significance. Based on this comparison, the Draft EIR concluded that the increase in emissions of _ NOx and ROG would be less than significant. (Draft EIR, p. 4.6-20.) This is incorrect as it fails to consider short-term impacts. The Draft EIR's conclusion rests on the erroneous assumption that annual significance thresholds are applicable to short-term emissions and are protective of the San Joaquin Valley air basin's air quality. This is not the case. (See Comment II.B.2.) Project construction is expected to last only 74 days, not an entire year. All B-16 construction emissions are generated and impact the air basin s air quality during this time period and may result in violations or contribute significantly to existing violations of ambient air quality standards. Therefore, the use of the SJVAPCD s annual significance thresholds for short-term emissions is inequitable and not protective of the air quality in the air basin and does not constitute adequate review under CEQA. Given the lack of short-term quantitative significance thresholds in the SJVAPCD's guidance, the County could have conducted ambient air quality dispersion modeling to evaluate whether ambient air quality standards would be violated. In the alternative, the County could have used short-term significance thresholds developed by other air districts to screen for significance of criteria pollutant emissions. For example, the CEQA Guidelines published by the Sacramento Metropolitan Air Quality Management District("SMAQMD") contain quantitative significance thresholds for Project construction. (SMAQMD 07/045, p. 2-10.)The southern portion of the Sacramento air basin and the South Coast Air Basin suffer from similar air quality problems as the San Joaquin Valley air basin, 5 Sacramento Metropolitan Air Quality Management District,Guide to Air Quality Assessment, _ July 2004. 8