SU0004094 - Laserfiche WebLink

Home Browse Search

3.Response to Comments Ien ` CO is primarily related to gasoline combustion,the major source of which is on-road traffic. Thus, CO is assessed primarily in terms of potential"hot spots"along the proposed haul routes. The asphalt plant drum is typically powered by natural gas or electricity, neither of which is a r substantial on-site source of CO. Response to Comment B-32 Commenter restates that compliance with SCVAPCD Rule 1711 and air permitting requirements in the Authority-to-Construct(`ATC)permit do not adequately mitigate PM10 emission r impacts. Commenter also states that the DEIR does not disclose what additional controls might be imposed in the ATC permit, and that the emissions in the Draft FIR are in excess of controls in the ATC permit. Regulation VIII consists of a series of emission reduction rules designed to mitigate the impacts of fugitive dust. Compliance with Regulation VIII is included in Mitigation Measure 4.6.1. As the commenter points out,the proposed project would be required to implement BACT(best available control technology). Implementation of BACT is included in Mitigation Measure 4.6.2. Compliance with regulation does in fact constitute mitigation,where those regulations would reduce a significant impact. See Sundstrom v. Mendocino County(1988) 202 Cal.App.#3 296). Response to Comment B-33 Commenter states that DEIR's calculations of estimated fugitive PM10 emissions from unpaved roads underestimate their own calculations, and that the DEIR should be revised to explain and ` support the basis for the assumed 75 percent control offugitive dust, and should further require that this level of control be achieved by listing it as mitigation. .. The 75%control efficiency(CE)is based on SCAQMD CEQA Handbook and WRAP Fugitive Dust Handbook (Sept 2006). As in Table XI-D (SCAQMD),twice daily watering provides 55% CE,and limiting to 25 mph provides 44%CE,the composite is 75%.Note,the SJVAPCD Regulation VIII includes mitigation measure of limiting traffic to 15 mph which would provide even greater CE. t+. Response to Comment B-34 Commenter states that there are several problems with the evaluation of the emission factor for wind erosion: • the commenter was unable to reproduce the stated emission factors; V • no support is provided for the velocities used to the make the wind erosion calculations; • the 50 square meter stockpile area seems small for the size of the proposed quarry; L ` Cernex Vernalis Quarry Mining and Reclamation Project 3-13 ESA/203015 Final Emironmental Impact Report June 2008 L