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6. namely high ambient concentrations of ozone and PM10, thus making it appropriate B-16 to use their CEQA significance thresholds. cont. L Inset Table 1 compares the Draft EIR's construction exhaust emissions of L PM10, NOx, and ROG for five-year old equipment with the daily and annual significance thresholds for construction emissions from other air districts. Table 1: `, Comparison of the Draft EIRs daily and annual construction diesel exhaust emission estimates for five-year old equipment with SJVAPCD's annual and other air districts' short-term CEQA significance thresholds NOx PMI 0 ROG Source (ton/year) (lb/day) (ton/year) (Ib/day) (ton/year) (Ib/day) r Emissions* 6.99 189.16 0.22 5.95 0.46 12.36 Significance thresholds** SJVAPCD operation 10 10 YSAQMD construction 82 ISO 82 ` EDCAPCD construction 82 82 SMAQMD construction 85 B-17 SCAQMD construction 1 10 100 1 27 150 1 10 75 Total annual emissions in ton/year from Excel spreadsheet"Construction Engine Emissions Table,"see Exhibit 1;daily emissions in lb/day calculated as(ton/year)x(2000lb/ton)/(74 days) L "YSAQMD,YoloSolano Air Quality Management District,Air Quality Handbook,Guidelines for Determining Air Quality Thresholds of Significance and Mitigation Measures for Proposed Development Projects that Generate Emissions from Motor Vehicles,revised 2002; EDCAPCD=D Dorado County Air Pollution Control District,CEQA Guide,February 2002; SMAQMD Sacramento Metropolitan Au Quality Management District,Guide to Au Quality Assessment,July 2004; L SCAQMD=South Coast Au Quality Management District,CEQA Air Quality Handbook,April 1993. Table 1 demonstrates that daily Project NOx emissions from 5-year-old construction equipment would substantially exceed any of the cited air district's daily significance thresholds for construction and would be considered a significant adverse impact on air quality in the corresponding air basins. The same is true for 6, NOx emissions from new construction equipment(91.6 lb/day), except the SCAQMD threshold would not be exceeded. Project NOx and ROG emissions, both L ozone precursors, would contribute to the already extreme ozone problems in the San Joaquin Valley air basin,yet the Draft EIR fails to identify this significant impact and requires no mitigation for diesel exhaust from construction equipment. Feasible Lmitigation for diesel exhaust emissions for construction equipment exists and should be required. (See Comment V.C.) LPM10 emissions from construction are also significant. PM10 emissions arise from two sources — fugitive dust, discussed above in Comment IILB, and engine B-18 L exhaust, discussed in this comment. The Draft EIR piecemeals these emissions by evaluating the fugitive component and the engine components separately. However, L 9 L