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San Joaquin Valley Air Pollution Control District Page 2 District Reference No.20210676 July 14,2021 found in the District's Guidance for Assessing and Mitigating Air Quality Impacts at: https://www.valleyair.org/transportation/GAMAQI.pdf The District recommends that a more detailed preliminary review of the Project be conducted for the Project's construction and operational emissions. The additional environmental review of the Project's potential impact on air quality should consider the following items: 1) Project Related Criteria Pollutant Emissions 1a) Construction Emissions: Construction emissions are short-term emissions and should be evaluated separately from operational emissions. Equipment exhaust, as well as fugitive dust emissions should be quantified. For reference, the District's annual criteria thresholds of significance for construction are listed above. The District recommends that the County consider the use of the cleanest reasonably available off-road construction practices (i.e. eliminating unnecessary idling) and fleets, as set forth in §2423 of Title 13 of the California Code of Regulations, and Part 89 of Title 40 Code of Federal Regulations as a mitigation measure to reduce Project related impacts from construction related exhaust emissions. 1 b) Operational Emissions: Emissions from stationary sources and mobile sources should be analyzed separately. For reference, the District's annual criteria thresholds of significance for operational emissions are listed above. 1 c) Recommended Model: Project related criteria pollutant emissions from construction and operational sources should be identified and quantified. Emissions analysis should be performed using CaIEEMod (California Emission Estimator Model), which uses the most recent approved version of relevant Air Resources Board (ARB) emissions models and emission factors. CaIEEMod is available to the public and can be downloaded from the CalEEMod website at: www.caleemod.com. 1d) 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