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` III.C.2 All Feasible Fugitive PM10 Mitigation Measures Were Not Required 1. The Draft EIR erroneously concluded that mitigated construction PM10 emissions would not be significant. (Draft EIR, Impact 4.6.1, p. 4.6-18.) However, as .. discussed above, mitigated construction PM10 impacts remain significant, requiring additional mitigation. Further, the Draft EIR concluded that PM10 impacts from Project operation were not significant and did not require any mitigation. (Draft EIR, pp. 4.6-22 and 6-11.) Comment IV.B explains why this is not correct. Thus, this comment discusses mitigation measures for fugitive dust from both Project construction and operation, because the activities involved and, thus, control ` methods are similar. B-25 r, There are numerous additional relevant and reasonable measures contained in the CEQA Guidelines and rules of air districts and other agencies that should be required to mitigate the significant construction PM10 emissions from this Project. Further, several agencies have conducted comprehensive studies of fugitive dust control measures to bring their region into compliance with national ambient air quality standards on PM10. The SCAQMD has sponsored research, passed regulations (e.g., Rule 403),16 ` and published guidelines that identify best management practices for controlling fugitive dusts at construction sites. The Rule 403 lurplementation Handbookl7 contains a comprehensive list of such measures. Clark County, Nevada, has also sponsored research, passed regulations L (Rule 94), and published best management practices for controlling fugitive dust from construction activities.18 Clark County's Construction Activities Notebook contains a comprehensive list of best management practices. Similarly, Arizona has f. developed guidance to control fugitive PM10 emissions. (ADEQ 6/5/01?9) L 1e South Coast Air Quality Management District,Revised Final Staff Report for Proposed Amended Rule 403,Fugitive Dust and Proposed Rule 1186,PM10 Emissions from Paved and Unpaved Roads, and livestock Operations,February 14,1997. 17 South Coast Air Quality Management District,Rule 403 bnplementation Handbook,January 1999. 18 P.M.Fransioli,PM10 Emissions Control Research Sponsored by Clark County,Nevada, Proceedings of the Air&Waste Management Association's 94th Annual Conference&Exhibition, L Orlando,FL,June 24-28,2001, 19 Arizona Department of Environmental Quality("ADEQ"), Air Quality Exceptional and Natural Events Policy PM10 Best Available Control Measures,June 5,2M. k 15 1.