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San Joaquin Valley Air Pollution Control District Page 2 District Reference No.20220181 March 16,2022 District significance thresholds for annual emissions of criteria pollutants are the following: 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 District recommends that a more detailed preliminary review of the Project be conducted for the Project's construction and operational emissions. Ia) Construction Emissions Project construction air emissions are short-term emissions generated from construction activities and may exceed the District's significance thresholds. Therefore, the District recommends, to lessen air quality impacts from construction-related diesel exhaust emissions, the County consider incorporating the below measure into the Project. Recommended Measure: To reduce impacts from construction-related diesel exhaust emissions, the Project should utilize clean off-road construction equipment, including the latest tier equipment as feasible. 1 b) Project Related Operational Emissions —Cleanest Available Truck The San Joaquin Valley will not be able to attain stringent health-based federal air quality standards without significant reductions in emissions from heavy heavy- duty (HHD) Trucks, the single largest source of NOx emissions in the San Joaquin Valley. The District recently adopted the 2018 PM2.5 Plan which includes significant new reductions from HHD Trucks, including emissions reductions by 2023 through the implementation of the California Air Resources Board (CARB) Statewide Truck and Bus Regulation, which requires truck fleets operating in California to meet the 2010 0.2 g/bhp-hr NOx standard by 2023. Additionally, to meet the federal air quality standards by the 2020 to 2024 attainment deadlines, the District's Plan relies on a significant and immediate transition of heavy-duty truck fleets to zero or near-zero emissions technologies, including the near-zero truck standard of 0.02 g/bhp-hr NOx established by the California Air Resources Board. The Project is expected to generate an increased amount of operational mobile source emissions form HHD truck trips. To reduce impacts from operational mobile source emissions, the District recommends that the following clean air measures be considered for inclusion in the environmental review: • Advise fleets associated with Project operational activities to utilize the cleanest available HHD truck technologies, including zero and near-zero (0.02 g/bhp-hr NOx) technologies as feasible.