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Air Permitting Specialists 12247 Welch Road,Wilton,California 95693 Tel:(916)687-8352 •Fax:(916)687-7863 E-Mail:ray(a%kapahi.cbm Web Site:www.kapahi.com December 20, 2012 Katherine J. Hart Attorney-at-Law Abbott&Kindermann, LLP 2100 21 a Street Sacramento, CA 95818 Subject: Comments of Final Environmental Impact Report Love's Travel Stops,Flag City (Lodi),CA Dear Kate: We have reviewed the Final Environmental Impact Report (FEIR)for the proposed Love's Travel Stops project in Lodi,California. The focus of our review was the air quality section and responses to our comments as noted in your November 13,2012 letter to Mr. Rick Griffin(San Joaquin County,Planning Division). Our main comment is related to the significance of the air quality impacts and the proposed mitigation to reduce these impacts to less than significant. These are addressed in Responses 3D to 3H in the FEIR. The FEIR confirms our assertion that the project would have a significant air quality impact since the annual NOx emissions would exceed 10 tons per year,the threshold of significance set by the San Joaquin Valley Air Pollution Control District(SJVAPCD). We take issue, however,with the applicant's assertion that payment of off-site mitigation fees would reduce the significance of the impacts to less than significant. The mitigation fees under SJVAPC District Rule 9510 are aimed at broad efforts by the District to improve air quality in the Central Valley. These are off-site mitigation fees that would not lessen the impact of air emissions in the project area or even San Joaquin County since there are no fee programs in place which identify how the fees will reduce the NOx emissions. In other words,the EIR does not establish any linkage between payment of off-site mitigation fees and improvement in the air quality in the vicinity(or San Joaquin County) of the project where the impacts would occur.