San Joaquin Valley Air Pollution Control District

The San Joaquin Valley Air Pollution Control District covers eight counties, from San Joaquin south to the valley portion of Kern. Its Guidance for Assessing and Mitigating Air Quality Impacts, known as GAMAQI and dated March 19, 2015, is the governing document, with two one-page threshold sheets posted alongside it: criteria pollutants dated March 19, 2015 and toxic air contaminants dated July 13, 2015. The GAMAQI is unusually explicit about what a technical report must contain, down to the electronic model input and output files.

Criteria pollutant thresholds, Table 2

Pollutant	Construction (tons/yr)	Operational, permitted equipment (tons/yr)	Operational, non-permitted equipment (tons/yr)
CO	100	100	100
NOx	10	10	10
ROG	10	10	10
SOx	27	27	27
PM10	15	15	15
PM2.5	15	15	15

The numbers are the district's Rule 2201 New Source Review offset thresholds carried into CEQA, and a Board revision to the offset thresholds revises these automatically.

How the comparison is made

• Annual only. There are no pounds per day thresholds. Thresholds apply on a calendar year basis; construction is evaluated over a rolling twelve month period.
• Three separate comparisons. Construction, operational permitted equipment (stationary sources with district permits), and operational non-permitted equipment and activities (mobile, area, energy) are each compared to the threshold separately. Two tons from permitted equipment and nine from everything else is two comparisons, not eleven tons.
• PM. Construction exhaust and fugitive dust are summed against one PM number.
• Ambient analysis. When on-site emissions of any criteria pollutant exceed 100 pounds per day after enforceable mitigation, the district recommends an ambient air quality analysis by dispersion modeling against the state and national standards. Table 4 gives development sizes below which that analysis is not expected: 50 dwelling units, 2,000 square feet commercial, 25,000 square feet light industrial, 100,000 square feet heavy industrial, 20,000 square feet medical office, 39,000 square feet general office, 9,000 square feet educational, 10,000 square feet governmental, 20,000 square feet recreational, and transportation projects whose construction exhaust reaches 2.0 tons of NOx or PM10.
• Small Project Analysis Level. The district pre-quantified emissions by land use type and size. Projects at or below the SPAL sizes, and below the listed daily trip counts including heavy heavy-duty truck trips, are deemed less than significant without quantification. The November 2020 SPAL sheet was run in CalEEMod 2016.3.2.
• Rule 9510, Indirect Source Review. Development at or above the Table 4 sizes (50 dwelling units, 2,000 square feet commercial, 25,000 square feet light industrial, 100,000 square feet heavy industrial, 20,000 medical office, 39,000 general office, 9,000 educational, 10,000 government, 20,000 recreational, or 9,000 square feet of any other space) must reduce construction NOx and PM10 by 20 and 45 percent and operational NOx and PM10 by 33.3 and 50 percent, through design or fees. Compliance reduces emissions but may not bring a project below the thresholds.

Greenhouse gases

The district adopted its GHG policy on December 17, 2009 and the GAMAQI carries it unchanged. There is no tonnage threshold.

• A project complying with an approved GHG reduction plan or mitigation program, specified in law or adopted by the lead agency with a CEQA document, is less than significant and need not apply Best Performance Standards.
• A project implementing Best Performance Standards, the district's list of design elements and technologies, is less than significant without quantifying its emissions.
• Otherwise the project quantifies emissions and shows a reduction of at least 29 percent against business as usual, counting reductions since the 2002 to 2004 baseline, the AB 32 target of the time.

The 29 percent figure is tied to the 2020 target of the original AB 32 Scoping Plan. State targets have since moved to 40 percent below 1990 by 2030 and carbon neutrality by 2045. Lead agencies in the Valley increasingly supplement the district method with their own climate action plans, and a report should state which authority the finding rests on.

Health risk, odor, and CO

Impact	Threshold
Excess cancer risk, maximally exposed individual	20 in a million or greater on the later July 13, 2015 sheet; the March 2015 GAMAQI text prints 10
Acute hazard index	1 or greater
Chronic hazard index	1 or greater
Odor, existing source	More than one confirmed complaint per year, or three unconfirmed, averaged over three years, from the district's compliance database
CO hotspot	Analysis required if a traffic study shows any street or intersection dropping to level of service E or F, or an existing F substantially worsened

Table 6 screening distances trigger a detailed odor analysis when receptors would be closer than: two miles for a wastewater treatment plant or petroleum refinery; one mile for a landfill, transfer station, composting facility, asphalt batch plant, chemical or fiberglass manufacturing, painting and coating, food processing, feed lot or dairy, or rendering plant.

Construction measures

Regulation VIII, the district's fugitive dust rules, applies to every construction site as a matter of law, and the GAMAQI says compliance with it does not constitute mitigation for that reason. The district recommends its enhanced and additional control measures, or a voluntary emission reduction agreement, where sensitive receptors or site size warrant. There is no fixed count of measures that a less than significant finding depends on.

Model

CalEEMod, the latest version approved by the district, downloaded from the model site or the district's own page.

Where the thresholds are published

San Joaquin Valley Air Pollution Control District, Guidance for Assessing and Mitigating Air Quality Impacts, March 19, 2015: Table 2 (criteria pollutants), Section 8.3 (separate permitted and non-permitted evaluation, SPAL), Section 8.4 and Table 4 (ambient analysis screening), Section 8.5 and Table 5 (toxics), Table 6 (odor), the greenhouse gas section of Chapter 8; Air Quality Thresholds of Significance, Criteria Pollutants, March 19, 2015; Air Quality Thresholds of Significance, Toxic Air Contaminants, July 13, 2015; Guidance to Conduct Detailed Analysis for Assessing Odor Impacts, August 1, 2016; Small Project Analysis Levels, November 13, 2020; Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA, December 17, 2009.