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Second, the Draft EIR's claim that additional retrofits would be cost- prohibitive is unsupported. The Draft EIR fails to include any kind of cost-benefit analysis. Considering the huge emissions from the Project and its resulting enormous adverse impacts on the already severely compromised air quality in the San Joaquin Valley air basin, the Project should be required to implement all feasible mitigation. B46 cont. Third, the use of PuriNOx and the use of selective catalytic reduction ("SCR") (urea injection) systems are, contrary to the Draft EIR's claim, feasible and have been — successfully demonstrated on off-road equipment. These mitigation measures alone or in combination have been routinely required as CEQA mitigation for other construction projects or projects operating mobile off-road equipment and should be required for this Project as well. V.C.I PuriNOx PuriNOx is an alternative water/diesel formulation that was recommended by the California Air Resources Board ("CARB") as a viable control strategy to improve air quality in California for use in heavy-duty diesel engines including off- road engines. (CARB 03/0444.) PuriNOx was verified by CARB on January 31, 200145 as achieving a 14% reduction in NOx and a 63% reduction in PMto compared to CARB diesel. It can be used in any direct-injection, heavy-duty compression ignition BA7 ^ engine and is compatible with existing engines and existing storage, distribution, and vehicle fueling facilities. Operational experience indicates little or no difference in performance and startup time, no discernable operational differences, no increased engine noise, and significantly reduced visible smoke. (Hagstrand 06/0446.) This fuel has been successfully used in heavy-duty off-road and on-road equipment, including by the Tri-Delta Transit Authority fleet in Contra Costa County, by the County of Sacramento at the Keifer Landfill and North Transfer station, in off-road construction equipment at very large residential construction projects in Sacramento, in truck fleets operated by Pacific Cement in San Francisco ' State of California,California Air Resources Board, Assessment of Emissions of Lubrizol's PuriNOx Water/Diesel Emulsion on Exhaust Emissions from Heavy-Duty Diesel Engines, March 2004. 45 Letter from Dean C.Simeroth,Chief,Criteria Pollutants Branch,to Thomas J.Sheahan,Lubrizol, Verification of Lubrizol Corp.PuriNOx Fuel,January 31,2001, http://www.arb.ca.gov/fuels/diesel/altdiesel/altdiesel.htm,accessed June 18,2004. 'M Personal communication,Petra Pless/Phyllis Fox with Hep Hepner,Ramos Oil Co., Dixon,CA, (916371-3289,ext.242)and Bill Hagstrand, Lubrizol(440-347-6592),March and June 2004. 36