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III.C.I Project Construction PM 10 and NOx Emissions Remain Significant <br /> after Mitigation <br /> As discussed in Comment III, exhaust emissions of NOx and PM10 from <br /> Project construction are significant and thus must be mitigated. The Draft EIR did <br /> not disclose this significant impact and thus does not contain any responsive <br /> mitigation. <br /> The Draft EER includes six mitigation measures that"may be applied to — <br /> construction source of combustion' and lists use of alternative-fueled equipment, <br /> minimizing idling time, limiting hours of operation, use of electric equipment, <br /> curtailing construction during periods of high pollutant concentrations, and — <br /> rescheduling activities to reduce short-term impacts. (Draft EER, p. 4.6-20.) These <br /> measures do not mitigate the significant combustion emission impacts for two <br /> principal reasons. <br /> First, these measures are not required, but only optional, at the discretion of <br /> the applicant as they "may be applied." The language in the Draft EIR should be e-24 <br /> changed to require that these measures be used, by stating: "the following <br /> additional control measures shall be applied to reduce combustion emissions." — <br /> Second, these measures by themselves would not reduce the significant PM10 <br /> and NOx emissions from construction equipment to a less than significant level. — <br /> Idling emissions, for example, are not included in the Draft EIR's emission <br /> calculations, so reducing them does not reduce the Draft EIR's emission estimates. <br /> Electrical-driven or alternative-fueled versions of the equipment generating the <br /> emissions are not available. Curtailing construction and rescheduling would reduce <br /> peak hourly emissions, but not average daily or annual and may actually increase <br /> fugitive dust emissions. There are many additional mitigation measures that could <br /> be used to reduce significant PM10 and NOx emissions from equipment exhaust. <br /> These are discussed below in Comment V. These should be evaluated for the <br /> construction phase of the Project, the Draft EIR revised to identify construction <br /> exhaust mitigation and recirculated. <br /> Third, note 4 to the Draft EIR's Table 4.6-4 claims that PM10 emissions from <br /> engine exhaust are mitigated in Mitigation Measure 4.6.1. (Draft EIR, Table 4.64, <br /> note 4.) However, Mitigation Measure 4.6.1 only addresses fugitive PM10 from site <br /> preparation. It does not contain any mitigation for engine exhaust. Thus, this <br /> footnote must be corrected. — <br /> 14 <br />