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threshold, not whether the new equipment optimizes operating efficiency. The Draft EIR is silent as to the amount of NOx and ROG that would be reduced by the new equipment. Our review of the emission calculations suggests the Draft EIR's emissions are already based on the assumption of new equipment. Thus, this so-called mitigation does not reduce emissions as reported in the Draft EIR. The �- Draft EIR, in fact, does not include any mitigation for the significant NOx and ROG impacts that it admits. ` Third, the mitigation measure claims that"[w]hile several emission-reducing measures are currently available, current proven technology limits the maximum ` reductions." (Draft EIR, Measure 4.6.2, p.4.6-24.) The Draft EIR does not identify the referenced emission-reducing measures or explain why proven technology limits maximum reductions. The Draft EIR must be expanded to support these conclusory L statements. B-43 cont Fourth, the mitigation measure claims that"additional retrofits to reduce NOx emissions below acceptable emission standards would be cost prohibitive." (Draft EIR, Measure 4.6.2, p. 4.6-24.)The Draft EIR does not explain what it means by"additional retrofits" and"cost prohibitive" nor does it contain any analyses to ` support this claim. The Draft EIR should be revised to identify all potential mitigation measures,establish cost significance thresholds if cost is used to reject any measure, and estimate costs of each such measure to demonstrate that any rejected mitigation measure indeed is cost prohibitive. L Numerous feasible mitigation measures exist that would reduce the Project's significant NOx, ROG, CO, and PM10 emissions from construction and operation. These measures are routinely required for other Projects as CEQA mitigation and should be required for this Project in a revised Draft EIR. This comment focuses on mitigation for operational impacts except for off-road mobile equipment. The ` equipment used to construct the Project is similar to some of the equipment used to operate the Project,e.g., dozers. Thus, both construction and operational mitigation for off-road equipment is discussed in this comment. We note that some of the L measures discussed below are identified in Appendix D to the Draft EIR, but they are not required as mitigation. L V.A Maximum Potential Production Rate As discussed in Comment IV.A, the Draft EIR should be revised based on the maximum potential of its proposed equipment or, alternatively, the Applicant's B-44 operations must be limited to the maximum throughput used for emission estimates ` from Project operations. For the latter case, the Draft EIR should include a mitigation measure to explicitly require that the SJVAPCD's Permit to Operate limit the 33 L