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Cemex Vamalis Quarry Mining and Reclamation Project the facility;fugitive VOC emissions from loading asphalt into trucks (a key source of community odor complaints); and fugitive dust emissions from trackout onto public roads. Commenter states that the DEIR should be revised to include these additional sources. These sources were considered in the revised air quality analysis,which do not add significant new information not already discussed in the Draft EIR as defined in CEQA Guidelines Section 15088.5. Please see FEIR Appendices B and C. — Response to Comment B-43 Commenter states that the lead agency cannot adopt a statement ofoverriding considerations as it fails to identify and require feasible mitigation for the significant operational impacts of the Project Commenter restates comment B-23. — Commenter states that Mitigation Measure 4.6.2, which relies only on the use ofnew equipment, is insufficient to mitigate both Project operation and cumulative impacts for emissions ofROG and NOx from Project operation for several reasons: • the use of new equipment must be explicitly required as mitigation rather than just being _ "proposed"by the Applicant. Commenter also states that Mitigation Measure 4.6.4(p. 4.6-28)substantially conflicts with Mitigation Measure 4.6.2(p. 4.6-24) because it allows the option ofeither using new equipment or retrofitting its fleet, so the commenter argues that the measure should be revised to require both new equipment and catalyzed DPM filters. • the claim that the use ofnew equipment will provide the "best available operating efficiency"(Draft EIR,p. 4.6-24.) is not relevant to the amount of emission reductions that can be achieved, and the Draft EIR is silent as to the amount ofNOx and ROG that would be reduced by the new equipment. • the Draft EIR does not identify the referenced emission-reducing measures or explain why proven technology limits maximum reductions (Draft EIR,Measure 4.6.2,p. 4.6- 24). The Draft EIR must be expanded to support these conclusory statements. • the Draft EIR does not explain what it means by "additional retrofits"and "cost prohibitive"nor does it contain any analyses to support its claim that "[wfhile several emission-reducing measures are currently available, current proven technology limits the maximum reductions. "(Draft EIR,Measure 4.6.2,p. 4.6-24). The Draft EIR should be revised to identify all potential mitigation measures, establish cost significance thresholds ifcost is used to reject any measure, and estimate costs ofeach such measure to demonstrate that any rejected mitigation measure indeed is cast prohibitive. Use of catalyzed DPM filters is required,unless new equipment would have controls of equal or — better efficiency(Mitigation Measure 4.6.4). Information on the age of the fleet is the best available. Cemex Vernalis Quany Mining and RmWmWn Project 3-16 ESA/208015 Final Environmental Impact Report June 2008