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Cemex Vema6s Cluarry Mining and Reclamation Project v Cystalline silica is analyzed in the revised air quality analysis utilizing the HARP model (see Appendix A).The health risk from crystalline silica exposure,with standard dust control measures,is found to be less than significant. Response to Comment B-58 Commenter states that the air dispersion modeling used to analyze impacts to public health through the estimate of ambient concentrations of toxic air contaminants in inadequate, as it relied on five years of meteorological data from the Fresno Airport. These airport data are neither site-specific nor is the quality of this data set acceptable for air dispersion modeling. Commenter speculates that the public health risk assessment which relies on these data for air modeling is flawed and likely underestimates modeled concentrations and thus health risk. Commenter states that the Applicant should be required to collect one year ofpre-construction — meteorological data, the risk assessments and other analyses that rely on dispersion modeling should be revised, and the Draft EIR recirculated far review. The Fresno Airport data represents the best available information. The Fresno data set,was determined to have the most similar air-land characteristics,per CARB's California Surface Wind Climatology. The suggestion that one year of pre-construction data should be collected prior to preparation of a Draft EIR does not meet the "reasonableness"test for a CEQA analysis for a project of this type. Response to Comment B-59 Commenter states that the cumulative impacts needs to include the proposed Valley Rock Mine. A cumulative CEQA analysis can be done in one of two ways per CEQA Guidelines Section 15130(6).The first is a list of past,present, and probable future projects. The second is to use projections in an adopted planning document. The air quality cumulative analysis is based on the air quality plans described on page 4.6-8. The SJVAPCD considers any criteria pollutant that would have a direct impact to also have a cumulative impact. In addition, PM emissions were found to be cumulatively significant in the DEIR(see DEIR Chapter 6). Response to Comment B-60 Commenter states the statements regarding the cumulative Project air quality impacts ofNOx, ROG, PM10, PM2.5, and DPM are conclusory and unsupported. Commenter also states that the Draft EIR should be revised to evaluate the cumulative impacts of construction impacts, odor impacts, and public health impacts from the asphalt plant operation and other facilities. See Response to Comment B-59 regarding cumulative impacts. Odor impacts were analyzed in Impact 4.6.3. Public health impacts from the asphalt plant were analyzed in Impact 4.6.7 and were reassessed using the HARP model in the revised air quality analysis,attached to this FEIR as Appendix A. Also see the response to comment B-12 regarding PM2.5 and Draft EIR pages 4.6-4 and 4.15 for more information. Cem Vernslm Quarry Mming aM Reclamation Prmea 3-22 ESA 1203015 Final Environmental Impact Report June 2008