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Cernex Vernalis Quant'Mining and Redannation Project Response to Comment B-11 Commenter states that there are three problems with the significance criteria of comparing emissions to annual operational significance thresholds adopted by the San Joaquin Valley Air Pollution Control District("SIVAPCD'). — This comment is addressed specifically in subsequent responses. Response to Comment B-12 Commenter states that the significance criteria are incomplete because the significance afCO, — PM10, PM2.5, and SO2 emissions were not evaluated as the SIVAPCD does not have a significance threshold for these pollutants. Comment is incorrect. CO was specifically examined in Impact 4.6.5. The major source of CO is traffic generated by the project. CO concentrations were estimated using the CALINE model and assessed for violation of the 1-hour and 8-hour standard at all study intersections.No potential violations were found. Particulate matter was evaluated in the air quality section, and potentially significant impacts are identified Impacts 4.6.1 and 4.6.2. Operational emission levels of PM 10 are estimated in Impact 4.6.2 (and the revised air quality analysis). As the SJVAPCD does not have a quantitative significance threshold level for PM 10 or PM2.5 emissions, significance was assessed in terms of conflict with the applicable air quality plan,contributing to a cumulative increase in criteria pollutants for which the area is in non attainment,and exposing sensitive receptors to substantial — pollutant concentrations. For PM,potential conflict with the air quality plan was identified in Impacts 4.6.1 and 4.6.2,which would be mitigated by compliance with Regulation VIII of the SJVAPCD. Cumulative increase of criteria pollutants(in this instance PMI0 and PM2.5) for — which the area is in non-attainment was found to be a significant and unavoidable cumulative impact(Impact 6.4). Exposing of sensitive receptors to substantial pollutant concentrations, which include particulates in the form of DPM and crystalline silica were analyzed in Impact 4.6.4 and the revised air quality analysis. SO2,sulfur dioxide,was not assessed, as no evidence has been presented that this is a potentially — significant impact. The San Joaquin Valley and adjacent air districts, including the Bay Area,are in attainment for SO2. California's low-sulfur diesel fuel standards have substantially eliminated this as a pollutant of concern. Significant SO2 impacts are primarily associated with areas reliant upon coal-burning power plants. Response to Comment B-13 Commenter states that the significance criteria are incomplete because short-term impacts were not evaluated since the SIVAPCD has not developed short-term, i.e. daily or hourly significance thresholds. Commenter notes that intermittent activities, such as construction and mining, have very high short-term emissions that are averaged out when presented on an annual basis, and that these short-term peaks are missed entirely when only annual thresholds are used. Cemex Vermlis Quarry Mining and Reclamaapn ProjW 3-6 ES"203015 Final Emironmental Impact Report June 2009