SU0004094 - Laserfiche WebLink

Home Browse Search

Ceirrex Vernalis Quany Mining and Reclamation Projed Response to Comment B-22 Commenter states that even though emission estimates are not required by the WAPCD for purposes of CEQA documentation, the Draft EIR cannot rely solely on the lead agency's guidance. Commenter states that implementation ofS1VAPCD's Regulation VIII alone plus — certain additional measures as required in the Draft EIR, are not sufficient to reduce the significant fugitive dust emissions from Project construction. Commenter lists four air districts'currently recommend significance thresholds that apply specifically to short-term construction emissions: SMAQMD, South Coast Air Quality Management District, San Luis Obispo County Air Pollution Control District, and the Monterey — Bay Unified Air Pollution Control District, and states that the fugitive dust emission estimates far the proposed project exceed the construction emission significance thresholds of each of the _ listed districts. Commenter states that this indicates that mitigated fugitive dust emissions from Project site preparation would result in significant adverse impacts on air quality, resulting in a new significant impact that was not disclosed in the Draft EIR. Commenter goes on to state that fugitive dust emissions associated with Project construction would therefore significantly contribute to the already severe PM10 problem in the San Joaquin Valley air basin, and that the Draft EIR fails to disclose this significant impact. — Despite implementation of Regulation VIII,the impact of fugitive dust emissions was found to be cumulatively considerable (see Impact 6.4). — 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-23 _ Commenter states that the DEIR ignored the districts request for "i'mjitigation measures must be included in the EIR that reduce the emissions of reactive organic gases (ROG), nitrogen oxides, carbon monoxide, and PM--10 to the maximum extent feasible,"as well as the District's — recommendation that"the project applicant... implement all feasible mitigation measures to reduce the amount of ozone precursors that will result from the buildout of this project. In this letter, the District provided a list ofpotential mitigation measures and emphasized that "the list is not meant to be all inclusive, and the District encourages new innovative ideas." While only the decision making body (the Planning Commission or Board of Supervisors)can decide whether or not a given mitigation measure is feasible,the Final EIR includes all recommended mitigation measures that would substantially reduce or avoid a significant _ environmental impact. See also Response to Comment B-25. — Cemex Vnnalis Quarry Mining and Reclamation Project 3-10 ESA/203015 — Final Emin nmei tal Impact Repm June 2008