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Project would add another 0.7 ton/year or 5.3 lb/day41 to the already significant <br /> NOx emissions from Project operations. In other words, indirect emissions Bit <br /> cont. <br /> ` associated with electricity generation for Project uses alone would amount to about <br /> 7% of the SJVAPCD s annual significance threshold for NOx. <br /> .. IV.E.2 Other Omitted Emission Sources <br /> L There are two classes of sources that were omitted from the Draft EIR's <br /> analysis. <br /> First, the summary tables in the text of the Draft EIR (Tables 4.6-5A, B, & C) <br /> omit some of the emission sources that are included in the Excel spreadsheets in <br /> Exhibit 1. The omitted sources include recycling, pickup trucks, and the oil heater. <br /> B-az <br /> Second, several other emission sources were not included in either the Draft <br /> EER or the supporting Excel spreadsheets. These include fugitive dust emissions <br /> t• from paved areas within the facility (roads, parking lots); fugitive dust emissions <br /> from haul trucks outside of the facility; fugitive VOC emissions from loading asphalt <br /> into trucks (a key source of community odor complaints); fugitive dust emissions <br /> from trackout onto public roads; combustion and fugitive dust emissions from <br /> maintaining landscaped areas; and emissions from reclamation of the site. <br /> bw The Draft EER should be revised to explicitly include these additional sources <br /> of emissions. <br /> V. ADDITIONAL FEASIBLE MEASURES EXIST AND SHOULD BE <br /> REQUIRED TO MITIGATE OPERATIONAL IMPACTS <br /> v <br /> The CEQA Guidelines, Section 15021(a)(2), state that"[a] public agency <br /> should not approve a project as proposed if there are feasible alternatives or <br /> L mitigation measures available that would substantially lessen any significant effects B-43 <br /> that the project would have on the environment." CEQA requires a lead agency to <br /> Ladopt all feasible mitigation measures or feasible project alternatives that can <br /> substantially lessen or avoid any significant effects on the environment associated <br /> with a project. (Pub. Res. Code, §21002.) The lead agency may only adopt a <br /> statement of overriding considerations if, after implementation of all feasible <br /> mitigation measures, project emissions are still significant. The Draft EIR fails this <br /> L fundamental test by failing to identify and require feasible mitigation for the <br /> significant operational impacts of the Project. <br /> L41 (1980 MWh/year) x (0.7lb/MWh NOx)/ (2,000 lb/ton)=0.69 ton/year NOx; <br /> (0.69 ton/year)/ (261 work days/year) x (2,000 lb/ton)=5.31b/day. <br /> L <br /> 31 <br /> L <br />