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r ` The SJVAPCD recommended implementation of a number of potential mitigation measures, including: — Use alternative fueled construction equipment, — Minimize idling time (e.g., 10 minutes); — Limit the hours of operation of heavy duty equipment and/or the amount of equipment in use; �. — Replace fossil-fueled equipment with electrically driven equivalents (provided they are not run via a portable generator set; and — Curtail construction periods during periods of high ambient pollutant concentrations; this may include ceasing construction activity during the peak-hour of vehicular traffic on adjacent roadways (days declared as r, Spare the Air Days by the District). (SJVAPCD 01/03, pp. 2-3.) None of these mitigation measures are required in the Draft EIR for either site preparation or Project operation. The Draft merely mentions that they"may be applied to construction sources of combustion" and makes no mention of these mitigation measures for mobile off-road equipment used during the operational ea6 phase of the Project. (Draft EIR, p. 4.6-20.)The above mitigation measures should be cont. explicitly required. As mitigation for Project operational emissions from mobile equipment, the Draft EIR claims that the Project would operate new equipment, both on-site off- road equipment and haul trucks, which"would provide the best available operating efficiency for the equipment" The Draft EIR claims that additional retrofits to Lreduce NOx emissions to less than significance would be"cost-prohibitive' and "not technically feasible' and that there are "no current control technologies that when applied together would reduce the total NOx emissions from the Project to less than significant, that is, a 90 percent reduction." (Draft EIR, pp. 4.6-24-4.6-25.) The Draft EIR further claims that the use of the"fuel additive PuriNOx, and/or the use of urea injection system in combination with a reducing catalyst" are not feasible because "these technologies have not been widely tested in the types of engines for the project" and that"they have been known to affect engine operation efficiencies and i may create secondary impacts." (Draft EIR, pp. 4.6-24 -4.6-25.) The Draft EIR's L assumptions and conclusions are erroneous for a number of reasons. First, the goal of mitigation is to reduce emissions to the maximum extent feasible even if it is not possible to reduce the emissions to below significance. The Draft EIR's all-or-nothing approach to mitigation is not acceptable under CEQA. v 35