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` further increase the already significant and unavoidable impacts from the B-21 operational phase of the Project. (See Draft FIR, pp. 4.6-24 -4.6-25.) cont 111.6 Project Construction Fugitive Dust PM 10 Emissions Remain Significant after Implementation of SJVAPCD's Regulation VIII and other Measures The Draft EIR considers construction-related fugitive dust emissions potentially significant but states that emission estimates were not prepared because 6' they are not required by the SJVAPCD for purposes of CEQA documentation. (Draft EIR, p. 4.6-18.)The Draft EIR concludes that implementation of the SJVAPCD's Regulation VIII and certain additional measures would reduce the emissions to less 6. than significance. (Draft EIR, pp. 4.6-18/20.) The SJVAPCD's CEQA Guide for Assessing and Mitigating Air Quality Impacts ("GAMAQI"), in fact, emphasizes ` implementation of effective and comprehensive control measures rather than detailed quantification of construction emissions. However, the SJVAPCD also points out that a lead agency may elect to quantify construction emissions and provides recommendations in Section 5 of the GAMAQL (GAMAQI, p. 24 and PP• 44145.) s-22 The CEQA Guidelines, §15064(b), emphasize that the determination of significant impacts "calls for careful judgment on the part of the public agency involved." Thus, the deciding factor for the lead agency of whether to prepare emission estimates should be consideration of the extent of the anticipated construction emissions and potentially resulting impacts and effectiveness of the b, proposed mitigation rather than blind reliance on agency guidance,which has been rejected by the courts. As demonstrated below, implementation of Regulation VIII alone plus certain additional measures as required in the Draft FIR, are not sufficient to reduce the significant fugitive dust emissions from Project construction. LConstruction fugitive dust emissions can be estimated based on emission factors developed by the Midwest Research Institute ("MRI") for the South Coast Air Quality Management District. (MRI 03/067.) Use of these emission factors is also L recommended by the Fugitive Dust Handbook published by the Western Regional Air Partnership ("WRAP"). (WRAP 11/058, p. 3-3.) Based on these emission factors and information provided in the Draft EIR about the total duration of site L preparation, 74 days, and the total Project site acreage, 659 acres, Project construction would result in unmitigated fugitive dust emissions of 294 pounds per f L 7 Midwest Research Institute,Improvement of Specific Emission factors(BACM Project No.1),Final LReport,March 29,1996. B Western Regional Air Partnership,WRAP Fugitive Dust Handbook, November 15,2004. L 11 L