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RECIEVED San Joaquin Valley JUN 21 Air Pollution Control District (aornmunity Development Dept, June 16, 2006 Reference No. C200601368 Kathy Allen San Joaquin County Community Development Dept. 1810 East Hazelton Avenue Stockton, CA 95205 Subject: PA-0600320 (SA); Real Development, LLC; 3401 S.Whiskey Slough Road; (APN 131-080-13) Dear Kathy Allen: The San Joaquin Valley Unified Air Pollution Control District (District) has reviewed the project referenced above and offers the following comments: The entire San Joaquin Valley Air Basin is designated non-attainment for ozone and particulate matter (PM10 and PM2.5). This project would contribute to the overall decline in air quality due to construction activities in preparation of the site, and ongoing traffic and other operational emissions. Based on the size of the project, the District expects that the project would not exceed the District's thresholds of significance for ozone precursors of 10 tons per year of reactive organic gases (ROG)and oxides of nitrogen (NOx). It appears that this project will be subject to the District's Indirect Source Review Rule (Rule 9510). This rule was adopted to reduce the impacts of growth in emissions from all new development in the San Joaquin Valley. Rule 9510 requires applicants subject to the rule to provide information that enables the District to quantify construction, area and operational PM10 and NOx emissions, and potentially mitigate a portion of those emissions. Preliminary analysis, based on the trip generation information included with the application and the size of the construction site, indicates that this project may generate emissions in excess of the Rule's 2.0 tons per year baseline for ROG and NOx that would require emissions to be reduced. An application must be filed with the District no later than concurrent with application with a local agency for the final discretionary approval. For more information and instruction, please contact the District's ISR staff by phone at (559) 230-5800 or by email at ISRng-vallevair.org. Based on the information provided, the proposed project will be subject to the following District rules. The following items are rules that have been adopted by the District to reduce emissions throughout the San Joaquin Valley, and are required. This project may be subject to additional District Rules not enumerated below. To identify additional rules or regulations that apply to this project, or for further information, the applicant is strongly encouraged to contact the District's Small Business Assistance Office at (209) 557- 6446. Current District rules can be found at http://www.vallevair.org/ruies/lruleslist.htm. Regulation VIII (Fugitive PM10 Prohibitions) Rules 8011-8081 are designed to reduce PM10 emissions (predominantly dust/dirt) generated by human activity, including construction and demolition activities, road construction, bulk materials storage, paved and unpaved roads, carryout and trackout, landfill operations, etc. The District's compliance assistance bulletin for construction sites can be found at http//www.vallevair.org/busind/comply/PM10/Reg%20VIII%20CAB.pdf. If a non-residential project is 5.0 or more acres in area or will include moving, depositing, or relocating more than 2,500 cubic yards per day of bulk materials on at least three days, a Dust Control Plan must be submitted as specified in Section 6.3.1 of Rule 8021. Construction activities shall not commence until the Northern Region Office Central Region O(fire Southern Region Office 4600 Enterprise Way 19911 East Gettysburg Avenue 2700 M Street,Suite 275 Modesto,CA 95356-8716 Fresno,CA 93726-1244 Bakersfield,CA 93301-2373 (209).557-6400 • FAX(209)557-6475 (559)230-6000 • FAX(559) 2:30-6061 (661):126-6900 • FAX(661) 326-6985 www.valleyaicorg