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District CEQA Reference No: 20200052 <br />Page 2 of 8 <br />i) Construction Emissions: Construction emissions are short-term emissions and <br />should be evaluated separately from operational emissions. For reference, the <br />District's annual criteria thresholds of significance for construction are: 100 tons <br />per year of carbon monoxide (CO), 10 tons per year of oxides of nitrogen (NOx), <br />10 tons per year of reactive organic gases (ROG), 27 tons per year of oxides <br />of sulfur (SOx), 15 tons per year of particulate matter of 10 microns or less in <br />size (PM10), or 15 tons per year of particulate matter of 2.5 microns or less in <br />size (PM2.5). <br />Recommended Measure: To reduce impacts from construction related <br />exhaust emissions, the District recommends the cleanest reasonably <br />available off-road construction fleets, as set forth in §2423 of Title 13 of the <br />California Code of Regulations, and Part 89 of Title 40 Code of Federal <br />Regulations. <br />ii) Operational Emissions: Permitted (stationary sources) and non -permitted <br />(mobile sources) sources should be analyzed separately. For reference, the <br />annual criteria thresholds of significance for operation of permitted and non - <br />permitted sources each are: 100 tons per year of carbon monoxide (CO), 10 <br />tons per year of oxides of nitrogen (NOx), 10 tons per year of reactive organic <br />gases (ROG), 27 tons per year of oxides of sulfur (SOx), 15 tons per year of <br />particulate matter of 10 microns or less in size (PM10), or 15 tons per year of <br />particulate matter of 2.5 microns or less in size (PM2.5). <br />Recommended Measure: Project related impacts on air quality can be <br />reduced through incorporation of design elements, for example, that <br />increase energy efficiency, reduce vehicle miles traveled, and reduce <br />operational related emissions. <br />iii) Recommended Model: Project related criteria pollutant emissions from <br />construction and operation non -permitted (limited to equipment not subject to <br />District permits) should be identified and quantified. Emissions analysis should <br />be performed using CalEEMod (California Emission Estimator Model), which <br />uses the most recent approved version of relevant Air Resources Board (ARB) <br />emissions models and emission factors. CalEEMod is available to the public <br />and can be downloaded from the CalEEMod website at: www.caleemod.com. <br />iv) The proposed Project could have a significant impact on regional air quality. <br />As such, the District recommends the EIR also include a discussion on the <br />feasibility of implementing a Voluntary Emission Reduction Agreement (VERA) <br />for this project. A VERA is a mitigation measure by which the project proponent <br />provides pound -for -pound mitigation of emissions increases through a process <br />that develops, funds, and implements emission reduction projects, with the <br />Planning Commission Staff Report 51 <br />PA -1900240 (SA), PA -2000014 (ER), PA -2000019 (DA) <br />Response Letters <br />