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CgVnaX Vemalie QUany Mining and Reclamation Pmjed Operations are defined as the removal and processing of aggregate (sand and gravel)and the production of ready mix concrete and asphalt. The two components, construction and operation, are separated due to the different nature of the equipment used,hours of operation, time of operation,and emission factors. — Assumptions regarding construction are presented in Impact 4.6.1 (page 4.6-18 et seq.). An analysis was prepared based on site preparation of the entire 659 acre area.As discussed above, the project was phased,and it is unlikely that construction would occur on more than one phase in any given year. However,even this "worst case"analysis results in a less than significant impact related to diesel-powered equipment NOx emissions (see Table 4.6-4). Fugitive dust emissions were not quantified(per the GAMAQI), but were considered to be potentially significant unless District-recommended dust control measures were implemented. Twenty-one different mitigation measures are identified in Impact 4.6.1. Response to Comment B-16 Commenter states that it is inappropriate to compare the emissions from the 74 day construction period to the WAPCD's annual operational significance thresholds to determine significance. Similar to Comment B-13, commenter suggests that the County could have conducted ambient air quality dispersion modeling to evaluate whether ambient air quality standards would be violated, or the County could have used short-term significance thresholds developed by other air districts to screen for significance of criteria pollutant emissions. _ Please see Response to Comment B-10 for a discussion of short-term versus long-term (annual) emission impacts. It should be noted that the 74-day construction period reflects the theoretical grading of the entire site. This is done for purposes of a"worst case"annual emission,which _ indicated that the SJVAPCD standards for criteria pollutants would not be exceeded. As discussed in Response to Comment B-15, the construction activity on an annual basis is likely to be much less. The use of standards from other air districts is not supported. As the commenter has stated previously,the use of regulatory standards as thresholds of significance should be done selectively. The lead agency has determined that SJVAPCD,as the air district of jurisdiction,and the agency responsible for the development and implementation of air quality plans in the region, is the appropriate source for threshold guidance. Response to Comment B-17 Commenter states that, referring to inset Table 1, construction equipment would exceed the daily _ Project NOx emissions for nearby air quality districts and that the Draft EIR fails to identify this significant impact and requires no mitigation for diesel exhaust from construction equipment. As stated above, in Response to Comment B-16,the use of standards from other air districts is not supported.As the commenter has stated previously,the use of regulatory standards as thresholds of significance should be done selectively. The lead agency has determined that SJVAPCD, as the air district of jurisdiction,and the agency responsible for the development and implementation of air quality plans in the region, is the appropriate source for threshold guidance. Cemex Vernalis Quarry Mining aM Reclamation Projed 3-8 ES"203015 Final Emirmmental Impact Report June 2008