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4 Environmental Analysis 4.3 Air Quality During the longer-term operational phase, the Project would have routine inspection and maintenance activities that would result in a net increase in emissions. However, as discussed in Section 2.5.2, the increase in emissions would not exceed any significance thresholds or violate any SJVAPCD rules or regulations. Based on emissions from construction and operation, the Project would not conflict with or obstruct implementation of the SJVAPCD's air quality plans, and the associated impact would be less than significant. Compliance with Rule 9510 would reduce NOX emissions by 43 percent in 2024 and 69 percent in 2025 through the use of Tier 4 engines for equipment greater than 85 horsepower. In addition, the use of Tier 4 engines will also decrease diesel PM10 by 45 percent in 2024 and 70 percent in 2025. These reductions are well above the Rule 9510 reduction requirements and the impact would be less than significant. Fugitive particulate matter will be reduced by preparing a Dust Control Plan. Mitigation: None required; however, the Applicant-proposed compliance with Rule 9510 and preparation of a Dust Control Plan have been included as Mitigation Measures AQ-1 and AQ- 2, respectively, to ensure their implementation. IMPACT 4.3-2: Would the project result in a cumulatively considerable net increase of any criteria pollutants for which the project region is non-attainment under an applicable federal or state ambient air quality standard? (Less than Significant Impact) The Project would result in an increase in short-term emissions related to construction and an increase in long-term operational emissions for those pollutants and precursors (ROG and NOX) for which the SJVAPCD is in nonattainment (03, PM1o, and PM2.5). Although the Project site is located in a region that is in nonattainment for 03, PM1o, and PM2.5, the cumulative emissions associated with the Project would not be considerable as the emissions would fall below SJVAPCD significance thresholds. Under this condition, the Project would not make a cumulatively considerable contribution during construction or operations. Therefore, impacts would be less than significant. Additionally, the Project would not conflict with the SJVAPCD 03, PM1o, or PM2.5 attainment plans, which address cumulative emissions in the SJVAB and account for emissions associated with construction activity. Therefore, impacts would be less than significant. Construction Emissions Project construction emissions were calculated using CaIEEMod. Table 4.3-8 presents the estimated maximum annual emissions generated during construction of the Project.As previously stated, the BAAQMD annual significance threshold for PM2.5 was used instead of the SJVAPCD threshold, as the BAAQD annual PM2.5 threshold is more conservative. Table 4.3-9 presents the estimated onsite maximum daily emissions generated during construction of the Project. Emissions with and without Rule 9510 and dust control reductions , along with both onsite and offsite contributions. Detailed emission calculations are provided in Appendix D. The SJVAPCD has determined that projects with emissions below the thresholds of significance for criteria pollutants would not conflict with or obstruct implementation of the SJVAPCD's air quality plan (SJVAPCD 2015a). Griffith Energy Storage Project 4.3-25 Tetra Tech/SCH 2022120675 Draft Environmental Impact Report August 2023