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Table 3: Comparison of annual process rates and PM 10 emission estimates depending on unit weight of concrete New Concrete concrete recycling Annual process rate B-38 (yd'/year) 350,000 100,000 cont. Based on light-weight concrete* (ton/year) 526,400 150,400 I I I ton/ft'= 1.504 Ib/yd' Based on normal-weight concrete (tonlyear) 708,750 202,500 150 ton/ft'= 20251 Ib/yd' PM 10 emissions Based on light-weight concrete* (Ib/day) 175.5 50.1 1 1 1 ton/ft'= 1.504 Ib/yd' Based on normal-weight concrete (Ib/day) 236.9 67.6 150 ton/ft'= 20251 Ib/yd' *as calculated in Draft EIR's air quality analysis IV.E Emission Sources Were Omitted The Draft EIR failed to consider a number of emissions sources, as discussed in the comments below. IV.E.I Indirect Impacts Were not Evaluated B-39 6. The CEQA Guidelines, Section 15126.2(a) require that"[djirect and indirect L significant effects of the project on the environment shall be clearly identified and described, giving due consideration to both the short-term and long-term effects." The Draft EIR did not consider the indirect air quality and other impacts of the Project. IV.E.I .a Growth Inducing Impacts The Project is a new mine and associated processing facilities that would produce building materials — aggregate, cement, asphalt — to fuel growth �. elsewhere. The Draft EIR argues that the development of new sources of aggregate B-40 is a response to growth, not something that induces growth. (Draft EIR, p. 6-2.) This is inconsistent with the CEQA Guidelines, Section 15126.2(d), which holds that growth inducing impacts include "projects which would remove obstacles to population growth (a major expansion of a waste water treatment plant might, for ` example, allow for more construction in service areas)." We maintain that providing L 29 1