SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix F: Environmental Analysis October 16,2008 

APPENDIX F 

ENVIRONMENTAL ANALYSIS FOR PROPOSED AMENDMENTS TO 

RULE 4306 AND PROPOSED NEW RULE 4320 

October 16, 2008 

F- 1 Final Draft Staff Report with Appendices 

For Proposed Amendments to Rule 4306 

and Rule 4307 and Proposed New Rule 4320 
SAN JOAQLllN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix F: Environmental Analysis October 16,2008 

This page intentionally blank 

F - 2 Final Draft Staff Report with Appendices 

For Proposed Amendments to Rule 4306 

and Rule 4307 and Proposed New Rule 4320 
San Joaquin Valley 

AIR POLLUTION CONTROL DISTRICT 

San Joaquin Valley Unified Air Pollution Control District 

Califorr~ia Environniental Quality Act (CEQA) Recommendation 

Rule 4306 Amendments and Proposed Rule 4320 

CEQA requires public agencies to evaluate and disclose the potential environ~iiental 

inipacts of discretionary actions that they undertake, including the issuance of air 

pollution permits. 

The San Joaquin Valley Unified Air Pollution Control District (District) is proposing to 

adopt Rule 4306 Amendments and Proposed Rule 4320. In accordance with Sections 

15070 to 15075 of the California Environmental Quality Act Guidelines, the District 

prepared an Initial Study and Proposed Negative Declaration for the project. These 

documents were available for public comment from July 24, 2008 to August 13, 2008. 

No comment letters were received. The District's evaluatio~i of the project concludes 

that the project's potential environmental impacts will be less than significant. 

Per the District's Environmental Review Guidelines (adopted August 2000), the District 

Governing Board is the decision-making body for the adoption of District rules, 

regulations and plans. The Air Pollution Control Officer (APCO) of the District, or his 

appointed designee, has duly considered said Initial Study and Negative Declaration. 

Accordingly, the APCO (a) certifies that .the Initial Study and Proposed Negative 

Declaration reflect the independent judgment of the District; (b) finds that, the 

environmental impact of the above-described project will be less than significant; and (c) 

recommends the Governing Board approve and adopt the Negative Declaration for said 

rule(s). 

In accordance with the provisions of Sections 15075 of the California Environmental 

Quality Act Guidelines, and upon approval by the Governing Board, District staff is 

hereby directed to cause to be filed a Notice of Determination with .the Fresno, Kern, 

Kings, Madera, Merced, San Joaquin, Stanislaus, and Tulare County Clerks and the 

State Clearinghouse (if required). 

SAN JOAQUIN VALLEY UNIFIED 

AIR POLLLI1-ION CONTROL DISTRICT 

Executive DirectorIAPCO V 

Northern Region Central Region (Main Office) Southern Region 

4800 Enterprise Way 1990 E. Gettysburg Avenue 2700 M Street, Suite 275 

Modesto, CA 95356-8718 Fresno, CA 93726-0244 Bakersfield, CA 93301-2373 

Tel: (209) 557-6400 FAX: (209) 557-6475 Tel: (559) 230-6000 FAX: (559) 230-6061 -[el: (6611 326-6900 FAX: (661) 326-6985 

www.valleyair.org 

Printed on recycled papera 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

A~~endix F: Environmental Analvsis October 16. 2008 

This page intentionally blank 

Final Draft Staff Report with Appendices 

For Proposed Amendments to Rule 4306 

and Rule 4307 and Proposed New Rule 4320 
PUBLIC NOTICE OF AVAILABILITY 

INITIAL STLIDY AND PROPOSED NEGATIVE DECLARATION 

July 21, 2008 

Notice is hereby given that the San Joaquin Valley Unified Air Pollution Control District (District) proposes to 

issue an lnitial Study and Proposed Negative Declaration for the following project: 

PRO.IECT TITLE, LOCATION, AND DESCRIPTION 

Project Title: Rule 4306 Amendments and Proposed Rule 4320 

Project Location: All counties within the San Joaquin Valley Air Basin (SJVAB), including: Fresno, Kern, Kings, 

Madera, Merced, San Joaquin, Stanislaus, and Tulare. 

Description of Project: The project is to adopt amendments to Rule 4306 (Boilers, Steam Generators, and 

Process Heaters - Phase 3) and adopt proposed Rule 4320 (Advanced Emission Reduction Options For 

Boilers, Steam Generators, and Process Heaters Greater Than 5.0 MMBtuIhr). The project will seek to reduce 

oxides of nitrogen (NOx), oxides of sulfur (SOX) and particulate matter (PM) emissions from this source 

category. This project is part of the District's 2007 8-hour ozone and 2008 PM2.5 attainment strategies. To 

satisfy the attainment goals of the ozone and PM plans, this project will seek to obtain as much NOx, SOX, and 

PM emission reductions as is expeditiously practicable, technologically feasible, and economically reasonable, 

as determined by the District's Governing Board. The control technologies that would likely be installed to 

achieve the draft NOx limits is an Ultra Low NOx burner (LILNB) system with or without flue gas recirculation, or 

selective catalytic reduction (SCR), or nonselective catalytic reduction (SNCR). The draft SOX limit can be met 

through the exclusive use of PUC-quality natural gas, commercial propane, butane, or liquefied petroleum gas, 

or a combination of such gases, limiting fuel sulfur content, or add-on pollution control equipment. Add-on 

control could be a wet or dry scrubber. The draft PM limit can be met through compliance with the SOX limit 

requirements or add-on controls. For add-on PM emission controls, filters or electrostatic precipitators are used. 

AVAILABILITY OF INITIAL STUDY AND PROPOSED NEGATIVE DECLARATION: 

The Proposed Negative Declaration is based upon a finding that the project will not have significant impacts on 

the environment or human health. The reasons to support such a finding are documented in the lnitial Study 

and Proposed Negative Declaration prepared by the District. Copies of the Initial Study and Proposed Negative 

Declaration and all documents referenced therein may be reviewed at the following location: 

San Joaquin Valley Unified Air Pollution Control District: 

San Joaquin Valley APCD 

Central Region Office 

1990 E. Gettysburg Ave. 

Fresno, CA 93726 

On the web at: http://www.vallevair.orq/notices/~ublic notices idx.htm 

COMMENTS ON INITIAL STUDY AND PROPOSED NEGATIVE DECLARATION: 

Public Review Period: Begins: July 24, 2008 Ends: August 13,2008 

Any interested person may submit written comments on the lnitial Study and Proposed Negative Declaration. 

Written comments will be reviewed by the District in considering the adoption of a Final Negative Declaration for 

the project. To be considered, comments must be received by 5:00 pm on August 13, 2008. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

A~~endix F: Environmental Analvsis October 16. 2008 

This page intentionally blank 

Final Draft Staff Report with Appendices 

For Proposed Amendments to Rule 4306 

and Rule 4307 and Proposed New Rule 4320 
San Joaquin Valley Unified 

Air Pollution Control District 

Rule 4306 Amendments 

and Proposed Rule 4320 

(District Project # CEQA 20080320) 

Initial Study and 

Negative Declaration 

August 2008 
SAN JOAQUIN VALLEY AIR POLLU'TION CONTROL DIS'TRICT GOVERNING BOARD 

2008 

CHAIR: LEROY ORNELLAS 

Sl~pervisor, San Joaquin Co~~nty 

VICE CHAIR: CHRIS VIERRA 

Councilmember, City of Ceres 

' MEMBERS: 

TONY' BARBA 

Supervisor, Kings County 

JUDITH G. CASE 

Supervisor, Fresno County 

RONN DOMlNlCl 

Supervisor, Madera County 

MICHAEL G. NELSON 

Sl.~pervisor, Merced COI-~nty 

WILLIAM O'BRIEN 

Supervisor, Stanislaus County 

HENRY T. PEREA 

. Council Member, City of Fresno 

JOHN G. TELLES, M.D. 

Appointed by ,the Governor 

RAYMOND A. WATSON 

Supervisor, Kern County 

J. STEVEN WORTHLEY 

Supervisor, Tulare County 

AIR POLLUTION CONTROL OFFICER 

SEYED SADREDIN 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18, 2008 

A. PRO.IECT BACKGROUND INFORMATION 

1. Project Title: 

Proposed Amendments to Rule 4306 (Bo~lers, Steam Generators, and Process 

Heaters - Phase 3) and Proposed Rule 4320 (Advanced Err~ission Reduction 

Options for Boilers, Steam Generators, and Process Heaters Greater Than 5.0 

MMBtulhr) 

2. Lead Agency Name and Address: 

San Joaquin Valley Unified Air Poll~~tion Control District 

1990 E. Gettysburg Avenue 

Fresno CA 93726-0244 

3. Contact Person: 

CEQA: Jessica Willis 

(559) 230-5800 

Planning: Manuel Salinas 

(559) 230-5800 

4. Project Location: 

The rule applies to new and modified stationary sources located within the 

boundaries of the San Joaquin Valley Unified Air Pollution Control District (see 

Exhibit 1, Map of District boundaries). 

5. Project Sponsor's Name and Address: 

San Joaquin Valley Unified Air Pollu.tion Control District 

1990 E. Gettysburg Avenue 

Fresno CA 93726-0244 

6. Assessor's Parcel Number: 

Not applicable to this project. 

7. General Plan DesignationlZoning: 

Not applicable to this project. 

Page 1 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

Exhibit 1 

San Joaquin Valley Unified Air Pollution Control District Boundaries 

San D~ego 

Page 2 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

8. Project Description: 

This rulemaking project is to adopt amendments to Rule 4306 (Boilers, Steam 

Generators, and Process Heaters - Phase 3) and adopt proposed Rule 4320 

(Advanced Emission Reduction Options for Boilers, Steam Generators, and Process 

Heaters Greater Than 5.0 NIMBtuIhr). This rulemaking project will seek to reduce 

oxides of nitrogen (NOx), oxides of sulfur (SOX) and particulate matter (PM) 

emissions from this source category. This project is part of the District's 2007 8-hour 

ozone and 2008 PM2.5 attainment strategies. To satisfy the attainment goals of the 

ozone and PM plans, this project will seek to obtain as much NOx, SOX, and PM 

emission reductions as is expeditiously practicable, technologically feasible, and 

economically reasonable, as determined by the District's Governing Board. The 

rl~lemaking project is also intended to satisfy state and federal Clean Air Act 

requirements. 

District staff will submit proposed amendments to Rule 4306 and proposed Rule 

4320 to the District Governing Board for consideration of adoption during a public 

hearing scheduled for September 18, 2008. 

NOx Control Technoloqv 

The control technologies that wol-~ld likely be installed to achieve the draft lVOx limits 

is an Ultra Low NOx burner (ULNB) system with or without flue gas recirculation, or 

selective catalytic reduction (SCR), or nonselective catalytic reduction (SNCR). 

SOX Control Technology 

The draft SOX limit can be met through the exclusive use of PUC-quality natural gas, 

commercial propane, butane, or liquefied petroleum gas, or a combination of such 

gases, lirrliting fuel sulfur content, or add-on pollution control equipment. Add-on 

control could be a wet or dry scrubber. 

PM Control Technoloqv 

The draft PM limit can be met through compliance with the SOX limit requirements or 

add-on controls. For add-on PM emission controls, filters or electrostatic precipitators 

are used. 

Page 3 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

9. Other Agencies Whose Approvals Are Required and Permits Needed: 

This project is a n~le development project and does not require permits from any 

dgency. The United States Environmental Protection Agency must approve the rule 

for inclusion into California's State Implementa.tion Plan. 

10. Name of Person Who Prepared Initial Study: 

Manuel Salinas, Air Quality Engineer 

San Joaquin Valley Unified Air Pollution Control District 

1990 E. Gettysburg Ave. 

Fresno, CA 93726 

(559) 230-5800 

Page 4 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

B. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED 

The environmental factors checked below WOI-~ld be potentially affected by the proposed 

project, involving at least one irr~pact that is a "Potentially Significant Impact" or "Potentially 

Significant Unless Mitigated", as indicated by the checklist on the following pages. 

Aesthetics 

Biological Resources 

Hazards & Hazardous 

Materials 

Mineral Resources 

Public Services 

UtilitiesIService 

Systems 

Agriculture Resources Air Quality 

Cultural Resources GeologyISoils 

HydrologyNVater Land Uselplanning 

Quality 

Noise Population/Housing 

Recreation Transportationrrraffic 

Mandatory Findings of 

Significance 

C. DETERMINATION 

I certify that this project was independently reviewed and analyzed and that this document 

reflects the independent judgment of the District. 

[XI I find that the proposed project COULD NOT have a signi.ficant effect on the 

environment, and a NEGATIVE DECLARATION has been prepared. 

I find that although the proposed project could have a significant effect on the 

environment, there will not be a significant effect in this case because the 

mitigation measures described on an attached sheet have been added to the 

project. A NII-I-IGATED NEGATIVE DECLARA-I-ION will be prepared. 

I find that the proposed project MAY have a significant effect on the environment, 

and an ENVIRObIMENTAL IMPACT REPORT is required. 

I find that the proposed project MAY have a significant effect(s) on the 

environment, but at least one effect 1) has been adequately analyzed in an earlier 

document pursuant to applicable legal standards, and 2) has been addressed by 

mitigation measures based on the earlier analysis as described on attached 

sheets, if the effect is a "potentially significant impact" or "potentially significant 

unless mitigated." An ENVIRONMENTAL IMPACT REPORT is required, but it 

must analyze only the effects that remain to be addressed. 

Signature: Date: 

Printed Name: Leroy Ornellas Title: Board Chair 

Page 5 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

D. ENVIRONMENTAL IMPACT CHECKLIST 

I Potentially 1 

I. AESTHETICS 

Would the proposal: 

a) Affect a scenic vista or scenic highway? 

II. AGRICULTURE RESOURCES 

b) Have a demonstrable negative aesthetic effect? 

c) Create light or glare? 

In determining whether impacts to agricultural 

resources are significant environmental effects, lead 

agencies may refer to the California Agricultural Land 

Evaluation and Site Assessment Model (1997) 

prepared by the California Dept. of Conservation as an 

Potentially 

Significant 

Impact 

J 

J 

optional model to use in assessing impacts on 

agriculture and farmland. 

Would the project: 

a) Convert Prime Farmland, Unique Farmland, or 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. The 

rules do not impose requirements that would affect any changes in the physical environment that would 

obstruct any scenic vistas or views of interest to the public. The project would not create aesthetically offensive 

sites visible to the public. No significant adverse aesthetic impacts are expected from the adoption and 1 implementation of the rules. 

Mitigation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

Farmland of Statewide Importance (Farmland), as 

shown on the maps prepared pursuant to the 

Farmland Mapping and Monitoring Program of the 

California Resources Agency, to non-agricultural 

use? 

b) Conflict with existing zoning for agricultural use, or 

a Williamson Act contract? 

c) Involve other changes in the existing environment, 

significant 

lmpact 

Unless 

Mitigated 

which, due to their location or nature, could result 

in conversion of Farmland, to non-agricultural 

Less Than 

Significant 

Impact 

Less Than 

Significant 

Impact 

Impact ~ 

J 

Potentially 

Significant I lmpact 

Potentially 

Significant 

lmpact 

Unless 

use? 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. The 

project does not impose requirements affecting agricultural resources, as identified above. 

Mitigation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

Page 6 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

Ill. AIR QUALITY 

Where available, the significance criteria established by 

the applicable air quality management or air pollution 

control district may be relied upon to make the following 

determinations. 1 Would the project: I Impact Mitigated Impact 1 Impact 

increase of any ~riterii~ollutant forwhich the 

project region is non-attainment under an 

applicable federal or state ambient air quality 

standard (including releasing emissions which 

exceed auantitative thresholds for ozone 

Potentially 

Significant 

a) Conflict with or obstruct implementation of the 

applicable air quality plan? 

b) Violate any air quality standard or contribute 

substantially to an existing or projected air 

quality violation? 

c) Result in a cumulativelv considerable net 

I v 

J 

Potentially 

Significant 

Impact 

Unless 

precurs&s)? 

I (d) Selective Catalytic Reduction (SCR) technology would likely be used to comply with the proposed 

amendments. SCR uses ammonia in the presence of a catalyst to convert NOx to harmless nitrogen and water 

vapor. The California Office of Environmental Health and Hazard Assessment (OEHHA) has not classified 

ammonia as a carcinogen. However, ammonia does have acute and chronic health effects. The District's 

thresholds for significance for toxic impacts are a cancer risk greater than 10 in a million and/or a hazard index 

(HI) of 1.0 or greater for chronic non-carcinogenic or acute risks. The District's permitting process is such that a 

project cannot be permitted if the health risks exceed the District's Thresholds. 

d) Expose sensitive receptors to substantial 

pollutant concentrations? 

e) Create objectionable odors affecting a 

substantial number of people? 

(e) District Rule 4102 (Nuisance) applies to any source operation that emits or may emit air contaminants or 

other materials. In the event that a project creates a public nuisance, it could be in violation and be subject to 

District enforcement action. Also, since the olfactory organs can detect ammonia at very low concentrations, 

there is little chance that any long-term exposure at unhealthy concentrations could mistakenly occur. 

Less Than 

Significant 

I 

Y 

4 

I Global Warming Impacts I 

N o 

Discussion: (a-c) Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development 

project. The San Joaquin Valley Air Basin is a non-attainment area for the state and federal ambient ozone and 

PMlo standards. NOx is a precursor to both ozone and PMlo. It is expected that the use of NOx emission 

control devices will have positive effects on the air quality of the Valley. It is anticipated that some increased 

emissions of ammonia will result from the use of SCR control systems. The amount of ammonia emissions is 

assumed to be a small fraction of the amount of NOx that is controlled and that the large, net, positive air 

quality benefit outweighs the small increase in fugitive ammonia emissions. 

Combustion processes generate greenhouse gas (GHG) emissions in addition to criteria pollutants. The effects 

of GHG gas emissions on global climatic change occur over long periods of time and are typically considered to 

be cumulative impacts. Implementation of Rule 4306 and Rule 4320 has the potential to increase fuel use, 

which will increase C02 emissions. Emitted C02 is the primary GHG pollutant emitted during the combustion 

process. For the purpose of addressing GHG impacts of implementing the proposed rule changes, the overall 

increase in C02 emissions was calculated. As presented in Table1 (Attachment I), implementation of the 

proposed rule changes could increase C02 emissions by a total of 583,000 metric tons per year. District 

records show 369 facilities could be affected by the proposed rule revisions, resulting in an average increase in 

C02 emissions of 1,581 tons per year per facility. 

1 At this time there are no generally accepted thresholds of significance for determining the impact of GHG I 

Page 7 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

emissions from an individual project on global climatic change. In the absence of a specific significance 

threshold, District staff evaluates the significance on a case-by case basis. One approach in determining 

significance is to estimate what percentage of the total inventory of GHG emissions are represented by 

emissions from a project. If emissions are a relatively small percentage of the total inventory, it is possible that 

the project w~ll have little or no effect on global climatic change. As presented in Table 1, the increase in C02 

emissions resulting from implementation of the proposed rule amendments would be 0.1 1 % of the State's GHG 

emissions inventory. 

In its CEQA & Climatic Change, document (January, 2008) CAPCOA identifies several potential GHG 

significance thresholds. A potential threshold identified by CAPCOA is 25,000 metric tons per year per project, 

which is also equivalent to CARB's proposed mandatory reporting threshold under AB 32 for a single facility. In 

addition, the District in assessing the significance GHG emissions from individual projects has previously 

applied a threshold of 38,000 metric tons per year, on a case-by-case basis. 

In conclusion, the maximum cumulative GHG emissions increase that could result from the implementation of 

these rules would be an extremely small percentage of the State's GHG emissions inventory and total project 

emissions would be significantly below the 38,000 metric tons per year threshold previously applied by the 

District for individual facilities on a case-by-case basis. Furthermore, on a per facility basis, increased C02 

emissions from an individual facility would be significantly below CARB's proposed 25,000 metric tons per year 

mandatory reporting threshold for a single facility. Any increase in emissions of GHG from a single facility, as a 

result of complying with the rules, would be substantially below the thresholds discussed above. District staff 

concludes that adverse impact from implementing Rule 4306 and Rule 4320 are less than significant. 

Mitigation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320 and supporting staff report; CEQA & 

Climatic Chanae. CAPCOA. 2008 

IV. BIOLOGICAL RESOURCES 

Would the project: 

a) Have a substantial adverse effect, either directly 

or through habitat modifications, on any species 

identified as a candidate, sensitive, or special 

status species in local or regional plans, policies, 

or regulations, or by the California Department of 

Fish and Game or U.S. Fish and Wildlife Service? 

b) Have a substantial adverse effect on any riparian 

habitat or other sensitive natural community 

identified in local or regional plans, policies, 

regulations or by the California Department of 

Fish and Game or US Fish and Wildlife Service? 

c) Have a substantial adverse effect on federally 

protected wetlands as defined by Section 404 of 

the Clean Water Act (including, but not limited to, 

marsh, vernal pool, coastal, etc.) through direct 

removal, filling, hydrological interruption, or other 

means? 

d) Interfere substantially with the movement of any 

native resident or migratory fish or wildlife species 

or with established native resident or migratory 

wildlife corridors, or impede the use of native 

wildlife nursery sites? 

Potentially 

Significant 

lmpact 

Potentially 

Significant 

lmpact 

Unless 

Mitigated 

Less Than 

Significant 

lmpact lmpact 

Page 8 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

I I I Potentially l I 1 

I ' protecting biological resources, such as a tree I I I I J 1 

IV. BIOLOGICAL RESOURCES (continued) 

Would the project: 

e) Conflict with anv local policies or ordinances 

preservation policy or ordinance? 

1 f) Conflict with the provisions of an adopted Habitat I 1 l Conservation Plan, Natural Community 

Conservation Plan, or other approved local, I 

Potentially 

Significant 

Impact 

regional, or state habitat conservation plan? 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. 

Adoption of the rules and subsequent implementation are not expected to adversely affect existing plant or 

animal species or communities and unique or endangered plant or animal species. The adoption of the rules is 

not expected to conflict with plans, ordinances, or policies to protect biological resources, as described above. 

Mitigation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

V. CULTURAL RESOURCES 

Would the project: 

significant 

Unless 

Mitigated 

Potentially 

Significant 

a) Cause a substantial adverse change in the 

significance of a historical resource as defined in 

significance of an archaeological resource 

pursuant to '1 5064.5? 

Less Than 

Significant 

Impact 

Potentially 

Significant 

N o 

Impact 

adoption and implementation of the rules do not impose requirements affecting cultural resources and will not 

result in a significant adverse impact. 

Mitigation: None 

c) Directly or indirectly destroy a unique 

paleontological resource or site or unique 

geologic feature? 

d) Disturb any human remains, including those 

interred outside of formal cemeteries? 

- / Reference: Pro~osed Amendments to Rule 4306. Pro~osed Rule 4320. and su~~ortina staff report. 

J 

J 

Page 9 of 21 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. The 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

Page 10 of 21 

VI. GEOLOGYISOILS 

Would the project: Potentially 

Significant 

Impact 

a) Expose people or structures to potential 

substantial adverse effects, including the risk of 

loss, injury, or death involving: 

i) Rupture of a known earthquake fault, as 

delineated on the most recent Alquist-Priolo 

Earthquake Fault Zoning Map issued by the 

State Geologist for the area or based on other 

substantial evidence of a known fault? Refer to 

Division of Mines and Geology Special 

Publication 42. 

ii) Strong seismic ground shaking? 

iii) Seismic-related ground failure, including 

liquefaction? 

iv) Landslides? 

b) Result in substantial soil erosion or the loss of 

top so^^? 

c) Be located on a geologic unit or soil that is 

unstable, or that would become unstable as a 

result of the project, and potentially result in on- or 

off-site landslide, lateral spreading, subsidence, 

liquefaction or collapse? 

d) Be located on expansive soil, as defined in Table 

18-1-B of the Uniform Building Code (1994), 

creating substantial risks to life or property? 

e) Have soils incapable of adequately supporting the 

use of septic tanks or alternative wastewater 

Potentially 

Significant 

lmpact 

Unless 

pp 

Mitigated 

Less Than 

Significant 

Impact 

--- 4 

J 

J 

J 

J 

J 

disposal systems where sewers are not available 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. The 

adoption and implementation of the rules does not impose requirements affecting geology/soils, as identified 

above. 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

VII. HAZARDS 8 HAZARDOUS MATERIALS 

Would the project: Potentially 

Significant 

Impact 

a) Create a significant hazard to the public or the 

environment through the routine transport, use, or 

disposal of hazardous materials? 

Potentially 

Significant 

Unless 

Mitigated 

b) Create a significant hazard to the public or the 

environment through reasonably foreseeable 

upset and accident conditions involving the 

release of hazardous materials into the 

environment? 

c) Emit hazardous emissions or handle hazardous or 

acutely hazardous materials, substances, or 

waste within one-quarter mile of an existing or 

proposed school? 

J 

J 

Less Than 

Significant 

Impact 

No 

Impact 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

I Impact 

d) Be located on a site which is included on a list of I 

VII. HAZARDS & HAZARDOUS MATERIALS 

(continued) 

Would the project: 

hazardous materials sites compiled pursuant to 

Government Code Section 65962.5 and, as a 

result. would it create a sianificant hazard to the 

Potentially 

Significant 

public or the environment? 

e) For a project located within an airport land use 

plan or, where such a plan has not been adopted, 

within two miles of a public airport or public use 

airport, would the project result in a safety hazard 

for people residing or working in the project area? 

f) For a project within the vicinity of a private airstrip, 

would the project result in a safety hazard for 

people residing or working in the project area? 

g) Impair implementation of or physically interfere 

with an adopted emergency response plan or 

emergency evacuation plan? 

h) Expose people or structures to a significant risk of 

loss, injury or death involving wildland fires, 

including where wildlands are adjacent to 

urbanized areas or where residences are 

Potentially 

Significant 

Impact 

Unless 

Mitigated 

Less Than 

Significant 

Impact 

J 

intermixed with wildlands? 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development proiect. 

Proposed amendments to Rule 4306 and proposed Rule 4'320 is a rule development project. he facilities'that 

would be affected include industrial and commercial facilities located in industrial/commerciaI zones. Selective 

Catalytic Reduction (SCR) technology would likely be used to comply with the proposed amendments. SCR 

uses ammonia in the presence of a catalyst to convert NOx to harmless nitrogen and water vapor. California 

Office of Environmental Health and Hazard Assessment has not classified ammonia as a carcinogen. 

However, ammonia does have acute and chronic health effects. Acute exposure to ammonia at a 

concentration of 3,200 micrograms per cubic meter has been found to cause irritation of the eyes and 

respiratory tract. Higher concentrations cause conjunctivitis, laryngitis, and pulmonary edema. Long-term 

exposure to ammonia at concentrations of 200 micrograms per cubic meter or greater has been found to affect 

the respiratory tract. Since the olfactory organs can detect ammonia at very low concentrations, there is little 

chance that any long-term exposure at unhealthy concentrations could mistakenly occur. Also, since state and 

local safety regulations govern the handling, storage, and transport of ammonia, the potential for accidental 

release and acute exposure is minimized. Adherence to these regulations is anticipated to minimize significant 

impacts associated with the use of ammonia. 

Some SCR systems can also use non-hazardous urea or aqueous ammonia ipjection to achieve the proposed 

emission limits without anhydrous ammonia. The use of anhydrous ammonia involves greater risk than 

aqueous ammonia because it is stored and transported under pressure. In the event of a leak or rupture of a 

tank, anhydrous ammonia is released and vaporizes. Aqueous ammonia is a liquid at ambient temperatures 

and gas is only produced when a liquid pool from a spill evaporates. Under current Office of Emergency 

Services regulations implementing the California Accidental Release Prevention program, aqueous ammonia is 

regulated under California Health and Safety Code Section 2770.1. The use of aqueous ammonia would 

further minimize any potential hazard impacts associated with anhydrous ammonia use. A limit on ammonia slip 

is normally included in permits to operate of stationary sources, which should minimize potential air quality 

impacts associated with ammonia slip from sources operating SCR. Furthermore, properly operating and wellmaintained equipment could reduce the level of ammonia emissions. Therefore, the levels of ammonia 

emissions from potential ammonia slip are not expected to reach hazardous levels. 

Certain catalvsts used in SCRs mav contain hazardous materials that must be pro~erlv disposed of at the end 

Page 1 1 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

or their useful life. Existing waste disposal regulations are considered to be adequate to prevent any significant 

impact from occurring. 

In conclusion, the transportation, storage, and use of anhydrous ammonia, aqueous ammonia, or urea in 

conjunction with the operation of SCR as well as disposal of spent catalyst are not expected to have any 

adverse impacts on the environment as well as living things. 

Mitiaation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

I I Potentially l I 1 

VIII. HYDROLOGYIWATER QUALITY significant 

Potentially Impact Less Than Would the project: I Significant 1 Unless 1 Significant 1 NO 

Page 12 of 21 

discharge requirements? 

b) Substantially deplete groundwater supplies or 

interfere substantially with groundwater recharge 

such that there would be a net deficit in aquifer 

volume or a lowering of the local groundwater 

table level (e.g., the production rate of pre-existing 

nearby wells would drop to a level which would 

not support existing land uses or planned uses for 

which permits have been granted)? 

c) Substantially alter the existing drainage pattern of 

the site or area, including through the alteration of 

the course of a stream or river, in a manner, 

which would result in substantial erosion or 

the site or area, including through the alteration of 

the course of a stream or river, or substantially 

increase the rate or amount of surface runoff in a 

manner which would result in flooding on- or offsite? 

e) Create or contribute runoff water which would 

exceed the capacity of existing or planned storm 

water drainage systems or provide substantial 

f) Otherwise substantially degrade water quality? 

g) Place housing within a 100-year flood hazard area 

as mapped on a federal Flood Hazard Boundary 

or Flood Insurance Rate Map or other flood 

hazard delineation map? 

h) Place within a 100-year flood hazard area 

structures which would impede or redirect flood 

flows? 

i) Expose people or structures to a significant risk of 

loss, injury or death involving flooding, including 

flooding as a result of the failure of a levee or 

dam? 

j) lnundation by seiche, tsunami, or mudflow 

4 

J 

J 

~ 

J 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. The 

project does not impose requirements affecting hydrologylwater quality, as identified above. 

Mitigation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

IX. LAND USEIPLANNING 

Would the project: 

a) Phvsicallv divide an established communitv? 

b) Conflict with any applicable land use plan, policy, 

or regulation of an agency with jurisdiction over 

the project (including, but not limited to the 

general plan, specific plan, local coastal program, 

or zoning ordinance) adopted for the purpose of 

avoiding or mitigating an environmental effect? 

c) Conflict with any applicable habitat conservation 

plan or natural community conservation plan? 

Potentially 

Significant 

lmpact 

Potentially 

Significant 

lmpact 

Unless 

Mitigated 

Less Than 

Significant 

Impact 

I I I I 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. The 

District does not have land use authority and is generally prohibited from encouraging or prohibiting specific 

land uses. As such, the rules and their provisions have no characteristics that would directly change land use, 

zoning or land use plans or directly affect the land use classification, or location criteria of any public or private 

residential, commercial, industrial, or public land use facility. Any facilities affected by the proposed rules would 

still be anticipated to comply with, and not interfere with, any applicable land use plans, zoning ordinances, 

habitat conservation or natural community conservation plans. Thus, no significant adverse land use impact is 

antici~ated. 

I Mitigation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

I I I Potentially l 1 

X. MINERAL RESOURCES 

Would the project: 

significan-t 1 Potentially 1 lmpact 1 Less Than 

Significant Unless Significant 

region and the residents of the state? 

b) Result in the loss of availability of a locally 

a) Result in the loss of availability of a known 

mineral resource that would be of value to the 

important mineral resource recovery site 

delineated on a local general plan, specific plan or 

other land use plan? 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development proiect. The 

in pact 

adoption and implementation of the proposed rules would nit result in the loss of availability'of a kn'owi mineral 

resource of value to the region and the residents of the state or of a locally-important mineral resource recovery 

site delineated on a local general plan, specific plan, or other land use plan. Therefore, significant adverse 

impacts to mineral resources are not anticipated. 

IVlitiaation: - None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

Mitigated 

Page 1 3 of 21 

impact Impact 

,I 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

Page 14 of 2 1 

Potentially 

XI. NOISE Significant 

Potentially Impact Less Than Would the project result in: Significant Unless Significant 

Impact Mitigated 

a) Exposure of persons to or generation of noise 

levels in excess of standards established in the 

local general plan or noise ordinance, or 

applicable standards of other agencies? 

b) Exposure of persons to or generation of excessive 

groundborne vibration or groundborne noise 

levels? 

c) A substantial permanent increase in ambient 

noise levels in the project vicinity above levels 

existing without the project? 

d) A substantial temporary or periodic increase in 

ambient noise levels in the project vicinity above 

levels existing without the project? 

e) For a project located within an airport land use 

plan or, where such a plan has not been adopted, 

within two miles of a public airport or public use 

airport, would the project expose people residing 

or working in the project area to excessive noise 

levels? 

f) For a project within the vicinity of a private airstrip, 

would the project expose people residing or 

working in the project area to excessive noise 

levels? 

4 

4 

4 

4 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. The 

project does not impose requirements affecting noise, as identified above. 

Mitigation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

XII. POPLILATION/HOUSING 

Would the project: Potentially 

Significant 

Impact 

a) Induce substantial population growth in an area, 

either directly (for example, by proposing new 

homes and businesses) or indirectly (for example, 

through extension of roads or other 

infrastructure)? 

b) Displace substantial numbers of existing housing, 

necessitating the construction of replacement 

housing elsewhere? 

c) Displace substantial numbers of people, 

necessitating the construction of replacement 

housing elsewhere? 

4 

4 

4 

Potentially 

Significant 

lmpact 

Unless 

--- 

Mitigated 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. The 

project does not impose requirements affecting population/housing, as identified above. 

Mitigation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

Less Than 

Significant 

Impact 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

XIII. PUBLIC SERVICES 

Would the project Potentially 

Significant 

Impact Mitigated Impact Impact 

a) Result in substantial adverse physical impacts 

associated with the provision of new or physically 

altered governmental facilities, need for new or 

physically altered governmental facilities, the 

construction of which could cause significant 

environmental impacts, in order to maintain 

acceptable service ratios, response times or other 

performance objectives for any of the public 

Fire protection? 

Police protection? 

Mitigation: None 

Reference: Pro~osed Amendments to Rule 4306. P~ODOS~~ Rule 4320. and su~~ortina staff re~ort. 

Potentially 

Significant 

Impact 

Unless 

Schools? 

Parks? 

Other public facilities? 

b) Cumulatively exceed official regional or local 

population projections? 

c) Induce substantial growth in an area either 

directly or indirectly (e.g., through projects in an 

undeveloped area or extension of major 

infrastructure)? 

d) Displace existing housing, especially affordable 

housing? 

XIV. RECREATION 

a) Would the project increase the use of existing 

neighborhood and regional parks or other 

recreational facilities such that substantial 

physical deterioration of the facility would occur or 

be accelerated? 

b) Does the project include recreational facilities or 

require the construction or expansion of 

recreational facilities which might have an 

adverse physical effect on the environment? 

Page 1 5 of 21 

J 

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4 

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Less Than 

Significant 

fi 

implementation of the proposed rules is not anticipated to generate significant adverse impacts to public 

services (i.e., fire departments, police departments, and local governments). The proposed rules would not 

result in the need for new or physically altered government facilities in order to maintain acceptable service 

Mitigation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. The 

project does not impose requirements affecting recreation, as identified above 

Potentially 

Significant 

Impact 

No 

Potentially 

Significant 

Impact 

Unless 

Mitigated 

Less Than 

Significant 

Impact 

N o 

Impact 

J 

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San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

Page 16 of 21 

Potentially 

XV. TRANSPORTATIONITRAFFIC Significant 

Potentially Impact Less Than Would the project: Significant Unless Significant 

a) Cause an increase in traffic which is substantial in 

relation to the existing traffic load and capacity of 

the street system (i.e., result in a substantial 

increase in either the number of vehicle trips, the 

volume to capacity ratio on roads, or congestion 

at intersections)? 

b) Exceed, either individually or cumulatively, a level 

of service standard established by the county 

congestion management agency for designated 

J 

J 

c) Result in a change in air traffic patterns, including 

either an increase in traffic levels or a change in 

location that results in substantial safety risks? 

d) Substantially increase hazards due to a design 

feature (e.g., sharp curves or dangerous 

intersections) or incompatible uses (e.g., farm 

equipment)? 

e) Result in inadequate emergency access? 

f) Result in inadequate parking capacity? 

g) Conflict with adopted policies, plans, or programs 

supporting alternative transportation (e.g., bus 

turnouts, bicycle racks)? 

J 

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Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. The 

project does not impose requirements affecting transportation and traffic, as identified above. 

Mitigation: None 

XVI. UTILITIESISERVICE SYSTEMS 

Would the project: 

a) Exceed wastewater treatment requirements of the 

applicable Regional Water Quality Control Board? 

b) Require or result in the construction of new water 

or wastewater treatment facilities or expansion of 

existing facilities, the construction of which could 

cause significant environmental effects? 

c) Require or result in the construction of new storm 

water drainage facilities or expansion of existing 

facilities, the construction of which could cause 

significant environmental effects? 

d) Have sufficient water supplies available to serve 

the project from existing entitlements and 

resources, or are new or expanded entitlements 

needed? 

e) Result in a determination by the wastewater 

treatment provider which serves or may serve the 

project that it has adequate capacity to serve the 

project's projected demand in addition to the 

provider's existing commitments? 

Potentially 

Significant 

Impact 

. 

Potentially 

Significant 

lmpact 

Unless 

Mitigated 

Less Than 

Significant 

Impact 

N o 

Impact 

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San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18,2008 

Page I7 of 21 

XVI. UTILITIESISERVICE SYSTEMS 

(continued) 

Would the project: 

f) Be served by a landfill with sufficient permitted 

capacity to accommodate the project's solid waste 

disposal needs? 

Potentially 

Significant 

Impact 

g) Comply with federal, state, and local statutes and 

regulations related to solid waste? J 

Potentially 

Significant 

Impact 

Unless 

Mitigated 

--- 

Less Than 

Significant 

Impact 

Discussion: Proposed amendments to Rule 4306 and proposed Rule 4320 is a rule development project. 

Installation of SCR and other control systems will require electrical power for fans, electronics and control 

motors. The project is not expected to have any adverse impacts on utilities/service systems, as identified 

above 

Mitigation: None 

Reference: Proposed Amendments to Rule 4306, Proposed Rule 4320, and supporting staff report. 

XVII. MANDATORY FINDINGS OF 

SIGNIFICANCE 

a) Does the project have the potential to degrade the 

quality of the environment, substantially reduce 

the habitat of a fish or wildlife species, cause a 

fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or 

animal community, reduce the number or restrict 

the range of a rare or endangered plant or animal 

or eliminate important examples of the major 

periods of California history or prehistory? 

b) Does the project have impacts that are individually 

limited, but cumulatively considerable? 

("Cumulatively Considerable" means that the 

incremental effects of a project are considerable 

when viewed in connection with the effects of past 

projects, the effects of other current projects, and 

the effects of probable future projects)? 

c) Does the project have environmental effects, 

which will cause substantial adverse effects on 

human beings, either directly or indirectly? 

Discussion: (a-b) Proposed amendments to Rule 

project. No significant adverse impacts on the categories outlined above are anticipated as a result of this 

project. 

(c) Compliance with proposed Rule 4320 has the potential to cause adverse effects on humans. However, as 

discussed in Section Ill. Air Quality (d, e) and Section VII. Hazards & Hazardous Materials (a-h), the impacts to 

human health risks are less than significant. 

Potentially 

Significant 

Impact 

4306 and 

Potentially 

Significant 

lmpact 

Unless 

Mitigated 

proposed Rule 

Less Than 

Significant 

Impact 

J 

4320 is a rule 

N o 

Impact 

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development 
San Joaquin Valley Unified Air Pollution Control District August 18,2008 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proioosed Rule 4320 

E. INI'I'IAL STUDY DIS'TRIBU'I'ION LIST 

Fresno County County of Kern 

2221 Kern Street 1 1 15 Truxton Ave. 

Fresno, CA 93721 .Bakersfield, CA 93301 

County of Kings 

1400 W. Lacy Blvd. 

Hanford, CA 93230 

County of Madera 

209 W. Yosemite Ave. 

Madera, CA 93637 

County of Merced County of San Joaquin 

2222 "M" Street, Room 14 6 S. El Dorado St., 2nd Floor 

Merced, CA 9534 Stockton, CA 95202 

County of Stanislaus 

1021 "I" Street, Suite 101 

Modesto, CA 95354 

County of Tulare 

221 S. Mooney Blvd., Rm. 105 

Visalia, CA 93291 

California Dept. Fisli & Ganie Califorr~ia Dept. Fish & Game 

Region 2 (North Central) Region 4 (Central) 

1701 Nimbus Road, Suite A 1234 E. Shaw Ave. 

Rancho Cordova, CA 95670 Fresno, CA 9371 0 

California Dept. Fish & Game California Dept. Transportation, District 6 

141 6 gth Street, 1 2th lo or 201 5 E. Shields Ave., Suite 100 

Sacramento, CA 95814 Fresno, CA 93726 

California Dept. Transportation, District 10 California Dept. Water Resources 

1976 E. Charter Way 14.1 6 gth Street, P.O. Box 942836 

Stockton, CA 95205 Sacramento, CA 94236 

Regional Water Quality Control Board Regional Water Quality Control Board 

Central Valley - Region 5F Central Valley - Region 5s 

1685 "El1 Street 1 1020 Sun Center Drive, Suite 200 

Fresno, CA 93706 Rancho Cordova, CA 95670 

Page 18 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Proposed Rule 4320 

August 18, 2008 

Attachment 1 

COP, emission increase due to Rule 4320 as Percent of Statewide GHG (C02,) = 0.1 1 % 

District's GHG (C02e) Significance Threshold per project (facility), case by case basis = 38,000 metric tonslyr 

Number of facilities subject to Rule 4320 = 369 

Average annual C02e increase per facility = 1,581 metric tonslyr 

Table 1 - GREENHOUSE GAS (C02e) EMISSIONS FROM UNITS SUBJECT TO RULE 4320 USING SCR 

Page 1 9 of 21 

Category 

Category A 

(>5 to 20 

MMBtu) 

Category B 

(>20 

MMBtuIhr) 

Category C 

(Oilfield 

steam 

generators) 

Category D 

(Refinery 

Units) 

TOTAL 

Statewide 1990 GHG(C02e) emissions inventory = 499,000,000 metric tonslyr 

Statewide 2020 GHG Emissions lnventory C0,e = 600,000,000 

Interpolated Statewide 201 2 GHG Emissions Inventory C02e = 544,000,000 

# Units 

370 

237 

238 

70 

91 5 

Total 

MMBtuIhr 

6,081.72 

15,637.1 1 

16,304.36 

2488.05 

40,511.24 

Operating 

Capacity 

0.5 

0.5 

0.75 

0.75 

Operating 

Hourslyr 

4380.0 

4380.0 

6570.0 

6570.0 

Fuel Used 

without 

penalty 

MMBtuIyr 

2.7E+07 

6.8E+07 

1 .I E+08 

1.6E+07 

2.2E+08 

5% fuel 

penalty 

MMB~UI~~~ 

1331897 

3424527 

5355982 

81 7324 

10929730 

C02 EF 

I~IMMB~U~ 

11 7.65 

11 7.65 

1 17.65 

1 17.65 

co2 

Emissions 

lblyr 

1.57E+08 

4.03E+08 

6.30E+08 

9.62E+07 

1.29E+09 

co2 

Emissions 

short 

tonslyr 

7.83E+04 

2.01 E+05 

3.1 5E+05 

4.81 E+04 

6.43E+05 

co2 

Emissions 

metric 

tonslyr 

7.1 1 E+04 

1.83E+05 

2.86E+05 

4.36E+04 

5.83E+05 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Pro~osed Rule 4320 

August 18,2008 

APPENDIX A 

Response to Comments 

Page 20 of 21 
San Joaquin Valley Unified Air Pollution Control District 

Initial Study and Negative Declaration 

Rule 4306 Amendments and Pro~osed Rule 4320 

August 18, 2008 

District Response to Comments 

Pursuant to CEQA Guidelines §I5072 the District provided a Notice of Availability 

(NOA) to each of the Responsible and Trustee Agencies and County Clerks identified 

above in Section E. lnitial Study Distribution List. The NOA was published in the 

newspaper of major circulation in each county. The NOA and Negative Declaration 

were also posted on the District's website. 

Pursuant to CEQA Guideline §I 5105, the District provided a 20-day commenting period, 

beginning July 24, 2008, and ending on August 13, 2008. The District did not receive 

any comments on the Negative Declaration. Therefore, no response to comments is 

required. 

Page 21 of 21 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix F: Environmental Analysis October 16,2008 

This page intentionally blank 

F - 30 Final Draft Staff Report with Appendices 

For Proposed Amendments to Rule 4306 

and Rule 4307 and Proposed New Rule 4320