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Administrative Draft Environmental Impact Report Gill Medical Center Project 1 N was chosen to represent a "worst-case" scenario per it's similarity to the Airbus H145 which is the largest aircraft anticipated for transport to the Project site. In order to estimate the highest daily emission rate of helicopter pollutants, three flights daily are assumed. Emissions are calculated using standardized landing and take-off cycle factors generated by the USEPA as presented in the Air Force Mobile Emissions Guidance Documents (Air Force Civil Engineer Center 2020). Emissions are calculated that occur in the "mixing zone" which is from 0—3,000 feet above ground level.This approach is consistent with CEQA guidance found in the Aviation Environment Design Tool referenced in CEQA guidance. See Appendix D for emissions modeling details. 4.5.3.3 Project Impacts and Mitigation Measures Impact 4.5-1 Air pollutant emissions associated with the proposed project could conflict with applicable air quality plans. Impact Determination: less than significant Threshold: Conflict with or obstruct implementation of the applicable air quality plan. As part of its enforcement responsibilities, the USEPA requires each state with nonattainment areas to prepare and submit a SIP that demonstrates the means to attain the federal standards.The SIP must integrate federal, state, and local plan components and regulations to identify specific measures to reduce pollution in nonattainment areas, using a combination of performance standards and market-based programs. Similarly, under state law,the CCAA requires an air quality attainment plan to be prepared for areas designated as nonattainment with regard to the NAAQS and CAAQS.Air quality attainment plans outline emissions limits and control measures to achieve and maintain these standards by the earliest practical date. The SJVAPCD prepared the 2007 Ozone Plan, 2013 Plan for the Revoked 1-Hour Ozone Standard, 2016 Plan for the 2008 8-Hour Ozone Standard, 2016 Moderate Area Plan for the 2012 PM2.5 Standard, 2020 RACT Demonstration for the 2015 8-Hour Ozone Standard, 2007 PMio Maintenance Plan and Request for Re-designation, and 2018 Moderate Area Plan for the 2012 PM2.5 Standard.These plans collectively address the air basin's nonattainment status with the national and state 03 standards as well as particulate matter by establishing a program of rules and regulations directed at reducing air pollutant emissions and achieving state (California) and national air quality standards. Pollutant control strategies are based on the latest scientific and technical information and planning assumptions. According to the SJVAPCD (2015), the established thresholds of significance for criteria pollutant emissions are based on SJVAPCD New Source Review (NSR) offset requirements for stationary sources. Stationary sources in the SJVAB are subject to some of the most stringent regulatory requirements in the nation. Emission reductions achieved through implementation of SJVAPCD offset requirements are a major component of the District's air quality planning efforts.Thus, projects with emissions below the thresholds of significance for criteria pollutants are determined to "Not conflict or obstruct implementation of the District's air quality plan" (SJVAPCD 2015). As shown in Table 4.5-4 and Table 4.5-6 below, both Project construction and Project operations would not generate emissions that would exceed SJVAPCD significance thresholds. Furthermore, the Project Air Quality 4.5-13 October 2021