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District CEQA Reference No:20200083 Page 2 of 3 Construction -and operational emissions are to be evaluated separately. For reference, the District's annual criteria thresholds of significance for construction and for operational emissions are: 100 tons per year of carbon monoxide (CO), 10 tons per year of oxides of nitrogen (NOx), 10 tons per year of reactive organic gases (ROG), 27 tons per year of oxides of sulfur (SOx), 15 tons per year of particulate matter of 10 microns or less in size (PM10), or 15 tons per year of particulate matter of 2.5 microns or less in size (PM2.5). The purpose of Rule 9510 Indirect Source Review (ISR) is to reduce emissions from nitrogen oxide (NOx) and particulate matter of 10 microns or less (PM10). The analysis for Rule 9510 is limited to NOx and PM10. Therefore, using District Rule 9510 ISR is not appropriate for determining a project's significance impact and the District recommends that construction and operational emissions associated with the Project be evaluated. 3. Per the County's submittal, there are on-site residential receptors. In addition, there are off-site residential and work place receptors. The District recommends the Project be evaluated for potential health impacts to surrounding receptors (on-site and off- site) resulting from operational toxic air contaminant (TAC) emissions due to diesel exhaust emitted from mobile sources. i) The District recommends conducting a screening analysis that includes all sources of emissions. A screening analysis is used to identify projects which may have a significant health impact. A prioritization, using CAPCOA's updated methodology, is the recommended screening method. A prioritization score of 10 or greater is considered to be significant and a refined Health Risk Assessment (HRA) should be performed. For your convenience, the District's prioritization calculator can be found at: http:www.Valleyair.org/busind/pto/emission—facto rs/C rite ria/Toxics/Utilities/PR IORITIZATION%20RMR%202016.XLS. ii) The District recommends a refined HRA for projects that result in a prioritization score of 10 or greater. Prior to performing an HRA, it is recommended that the Project proponent contact the District to review the proposed modeling protocol. The Project would be considered to have a significant health risk if the HRA demonstrates that the Project related health impacts would exceed the Districts significance threshold of 20 in a million for carcinogenic risk and 1.0 for the Acute and Chronic Hazard Indices, and would trigger all feasible mitigation measures. The District recommends that Projects that result in a significant health risk not be approved.