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San Joaquin valley Air Pollution Control District October 4, 1999 N990609 Chandler Martin San Joaquin County OCT - 51999 Development Services Division 1810 East Hazelton Avenue ;;,^j`y oP,V210j1filEllt Circ Stockton, CA 95205 SUBJECT: PATTERSON PASS BUSINESS PARK SPECIAL PURPOSE PLAN AUTOMOBILE AUCTION FACILITY 200 ACRE (PP-99-02) Dear Mr. Martin: The San Joaquin Valley Unified Air Pollution Control District has reviewed the proposed project and offers the following comments: The San Joaquin Valley's air quality has been designated nonattainment by the EPA and by the Air Resources Board (ARB) for ozone and PM-10 (fine particulate matter, dust). The Federal Clean Air Act (CAA) and the California Clean Air Act require areas that are designated nonattainment to reduce emissions until standards are met. Based on the information provided, it appears that this project will generate an increase in vehicle trips and therefore, an increase in motor vehicle emissions. Given the magnitude of this project (6,000 vehicles), the emissions may exceed the District's thresholds of significance for the ozone precursors ROG, reactive organic gases, and NOx, oxides of nitrogen. The application provides no indication of how many of these vehicles are operated each day, which could greatly affect project emissions. The District's thresholds for ROG and NOx are 10 tons/year for each pollutant. As a result, the District recommends that further air quality analysis be performed to more accurately analyze this project's impacts. This analysis should include emissions quantification utilizing the URBEMIS 7G program. This program is available from the District upon request. The construction phase of this project can generate emission from the movement of soil, use of heavy equipment, bulk materials handling, asphalt paving and other related David L. Crow Executive Director/Air Pollution Control Officer Northern Region Office Central Region Office Southern Region Office 4230 Kiernan Avenue, Suite 130 1990 East Gettysburg Avenue 2700 M Street.Suite 275 Modesto, CA 95356-9321 Fresno,CA 93726-0244 Bakersfield,CA 9.3301-2370 (209)557-6400•FAX(209)557-6475 (559)230-6000•FAX(559)230-6061 (661)326-6900•FAX 1661 1326-6985