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While portions of some of these measures are included as part of the Draft EIR's mitigation measures, the above measures are generally far more protective than those recommended for this Project. All of these measures are feasible and B-25 various combinations of them are routinely required elsewhere to reduce fugitive cont. PM10 emissions. See, for example, the fugitive dust control program for the Big Dig26, for the El Toro Reuse Draft EIR27, and for the Padres Ballpark Final EIR28. IV. PROJECT OPERATIONAL IMPACTS ARE UNDERESTIMATED 6. The Draft EIR finds significant unavoidable impacts on air quality from operation of the Project after implementation of its sole mitigation measure, the use of new on-site off-road equipment and haul trucks. (Draft EIR, pp. 4.6-21 -4.6-24.) 1„ As discussed in the following comments, the Draft EIR substantially underestimated potential operational emissions from the Project, and thus failed to disclose the magnitude of impacts on air quality resulting from operation of the Project. V B-26 The Draft EIR summarizes emissions from the Project in three brief tables for Ldifferent production levels ranging from 1.7 to 4.0 million tons per year. (Draft EIR, Tables 4.6-5A, 4.6-5B and 4.6-5C.) As discussed in Comment I, the Draft EIR does not explain how these emissions were calculated, preventing meaningful public review. 1 6 We thus requested support for the operational emissions from ESA and were provided the Excel spreadsheets attached to these comments as Exhibit 1 two weeks before these comments were due. These spreadsheets were extraordinarily difficult 6„ to review because they contain numerous calculation errors; labeling and unit errors; and erroneous assumptions. Further, the emission factors that are used are not annotated as to source, and the large collection of spreadsheets contains no roadmap to lead the reviewer from dozens of unlabeled spreadsheets and columns to the L 26 A.Kasprak and P.A.Stakutis, A Comprehensive Air Quality Control Program for a Large Roadway Tunnel Project,Proceedings of the Air&Waste Management Associations 93rd Annual Conference 7 Exhibition,June 18-22,2000. L 27 County of Orange,Draft Environmental Impact Report No.573 for the Civilian Reuse of Marine Corps Air Station El Toro and the Airport System Master Plan for John Wayne Airport and Proposed Orange County International Airport,Draft Supplemental Analysis,Volume 1,April 2001,pp.2-121 to 2-123. L 28 City of San Diego, Final Subsequent Environmental Impact Report to the Final Master Environmental Impact Report for the Centre City Redevelopment Project and Addressing the Centre L City Community Plan and Related Documents for the Proposed Ballpark and Ancillary Development Projects,and Associated Plan Amendments,V.IV.Responses to Comments,September 13,1999, pp.IV-254 to IV-256. I� 19 L