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` The Fresno Airport data used by the Applicant, rather than being measured in 0.1 meter per second increments, is based on wind speed observations that are ` reported in whole knots. This is evidenced by examining the meteorological data files used in the modeling files provided by FSA. Every modeled hourly wind speed is a factor of 0.51 or 0.52 meter per second (the units required for input to the air dispersion model), which exists because one knot equals 0.51479 meter per second. The once-per-hour observations at Fresno Airport (in whole knots, no fractions or decimals)were converted to meters per second and can therefore be back-converted to the whole knot measurements originally reported by the airport. B-58 cont. ` Sensitive and accurate measurements of wind speeds are necessary for measuring winds down to 0.5 meter per second (about one knot),which can then be used as 1.0 meter per second in the air dispersion modeling analyses. There would be no need to label such low wind speed hours as calm, which will greatly increase the number of hours included in the modeling analyses. Again, it is these low wind speed hours which must be included in the modeling data set to verify compliance with the NAAQS (which was not done her but should have been) and to identify the peak concentrations to use in risk calculations. The Applicant should be required to collect one year of pre-construction meteorological data, the risk assessments and other analyses that rely on dispersion modeling should be revised, and the Draft EIR recirculated for review. IX. CUMULATIVE IMPACTS ARE SIGNIFICANT As discussed in the following comments, the Draft EIR's cumulative impact V analysis is flawed because it did not consider all other projects in the Project vicinity, namely a large mine expansion. Further the Draft EIR failed to identify and adequately mitigate all cumulative impacts. r IKA The Valley Rock Mine Was Omitted 6 The cumulative impacts are large due to four other very large gravel mines within 5 miles of the Project site. (Draft EIR, p. 6-4.) This list fails to include the B-59 proposed Valley Rock Mine, which is just west of the Granite (formerly Brown) Quarry,just across Interstate 580. This mine is an existing facility that has a pending proposal to expand to 315 acre to mine 35 million cubic yards (approximately L 50 million tons) over 40 years, according to their initial study?$The Draft EIR's L98 Valley Rock Quarry Expansion,San Joaquin County Community Development Department File No.PA0400690. Applicant Richard Deatley/West Coast Aggregates.Modification of existing quarry L 49 L