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failure to include this mine in its cumulative impacts means that the Draft EIR a-59 underestimated the cumulative impacts on air quality, traffic, water, and biological cont. resources. IX.B All Significant Cumulative Impacts Were Not Identified The Draft EER briefly discussed the cumulative Project air quality impacts of NOx, ROG, PM10, PM2.5, and DPM. (Draft EIR, pp. 6-10, 6-11, 648.) The statements are conclusory and unsupported. For example, the Draft EER for the first time in the cumulative analysis states that Project impacts of PM10, PM2.5 and DPM are not significant. This is surprising, as Section 4 did not analyze PM2.5 at all,was B-60 ambiguous as to the significance of PM10 (Draft FIR, p. 4.6-22) due to the absence of significance criteria, and concluded that public health impacts of DPM are significant and required mitigation (Impact 4.6.4). _ There are several impacts that were found to be not significant for the Project, but which were not evaluated for cumulative impacts. These include construction — impacts, odor impacts, and public health impacts from the asphalt plant operation and other facilities. The Draft EIR should be revised to evaluate the cumulative impacts of these activities. IX.0 No New Mitigation Is Proposed for Cumulative Impacts The Draft FIR concludes that emissions of ROG, NOx, PM10, PM2.5, and DPM are cumulatively significant. However, the Draft FIR does not propose any additional mitigation beyond that required for the Project in Section 4. In fact, the cumulative analysis concludes that while Project PM10 impacts are not significant, they are cumulatively considerable. However, in spite of this finding, the Draft FIR B-61 makes no effort to mitigate this new impact, instead defaulting to Project Mitigation Measure 4.6.2, which was designed to mitigate significant NOx and ROG impacts, not PM10 impacts. Different mitigation is required for PM10 as most PM10 originates from different sources than ROG and NOx. As discussed in Comments V.B and V.D, there are many feasible mitigation measures that could be used to _ mitigate the cumulatively significant PM10 impacts. This failure to mitigate is not acceptable, given the wide range of mitigation _ measures that are available. (See Comments II.C.2 and V.) An EIR must demonstrate permit QX-86-2.SCH number 2005122133.Proposed approval to expand an existing quarry from 4,790,000 cubic yards of sand and gravel to 35,517,854 cubic yards in five phases over a 40 year period. Assessor Parcels 265-070-09,13,affecting 315.1 acres. 50