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3.Response to Comrnerds V As described in Section 4.6.1 of the DEIR, SJVAPCD has responsibility for preparing air quality plans for its jurisdiction that will demonstrate how the region will attain the relevant air quality standard or demonstrate reasonable improvements in air quality conditions. The regulations and CEQA guidance prepared by SJVAPCD implement these air quality plans. San Joaquin County _ has considered the SJVAPCD's regulations and guidance and determined that it is appropriate for the DEIR to rely upon them,including adopted significance thresholds,in evaluating the impacts ►� of the project on regional air quality. The DEIR acknowledges that operation of the project would have a significant impact on air quality. The revised air quality analysis,while demonstrating overall lower levels of emissions, still identifies a significant impact for NOx (an ozone 6a precursor),and identifies a cumulative impact for NOx,ROG, and PM(see Impact 6.4) Response to Comment B-10 Commenter states that,far most pollutants, the Draft EIR does not contain any analysis using dispersion models to estimate the increase in ambient concentrations in order, to determine if emissions from Project construction and operation would cause or contribute to a violation ofan ambient air quality standard. Commenter states that the Draft EIR should be revised to include an ambient air quality analysis for ozone, PMI 0, PM2.5, and NO2. The DEIR uses appropriate methodologies to allow both the lead agency and responsible agencies ` to identify potentially significant mitigation measures and identify potentially feasible mitigation measures to avoid or reduce those effects. Annual emission limits are an appropriate means of - determining the air quality impacts of a quarry operation for the following reasons: I. Production levels of a quarry may vary considerably over the course of a year. Thus, short-term emissions would vary considerably. The air quality analysis was based on the maximum permitted annual rate of production, 4 million tons per year. 2. SJVAPCD, a responsible agency, evaluates potential air quality impacts using an annual jr threshold. It is logical that the lead agency would use a threshold of significance that would serve the needs of itself and responsible agencies. 3. Consistency with the SJVACPCD attainment plan,a potentially significant impact, is assessed in terms of annual emission inventories. Therefore, a potentially significant contributor to these air emissions should be evaluated on an annual basis. It should also be noted that ambient air quality analysis (short-term analysis)was prepared for the following emissions: L • CO (carbon monoxide): see Impact 4.6.5, which uses 8-hour and 24-hour ambient levels 4 • DPM (diesel particulate matter)and other toxic air contaminants: see Impact 4.6.4 and the revised air quality analysis. • Crystalline silica(a portion of PMI 0 emissions): see revised air quality analysis. LCemex Vernalis Quarry Mining and Reclamation Project 3-5 ESA/203075 Final Environmental Impact Report June 2008 L