4.12 Air Quality
required for the portions of the action that would be permitted by the San Diego APCD under the New
Source Review program. As seen in the table, the estimated emissions of CO, ROC and NOx would be
less than the threshold values. The emissions are also compared to the area's annual emissions forecast,
and it is seen that the project-related emissions of these three pollutants would be much less than ten
percent of the area emissions. Therefore, the proposed action is presumed to conform to the SIP, and a
formal conformity determination is not required.
A Record of Non-Applicability (RONA) is a memorandum required by Department of Navy policy that
reflects the determination of an authorized official that a formal conformity analysis is not required. A draft
RONA is included in Appendix F.
NEPA and CEQA Significance
The NEPA and CEQA impact analysis differ from the General Conformity analysis in that emissions of SO2
and PM10, attainment pollutants, are considered, as well as the nonattainment pollutant emissions5.
Therefore, SO and PM10 are included in estimated emissions calculations of Table 4.12-1, as well as
threshold values.
As stated in Section 4.12-1, the emissions of the project would not be significant if they would conform to
the SIP, and theywould not expose sensitive receptors to pollutant concentrations. The issuance of permits
for major emissions sources, and the comparison of estimated project emissions with threshold values for
other sources, as shown in Table 4.12-1, demonstrate conformance with the SIP. The project would not
cause a violation of the 1-hour or 8-hour CO standard, because the project would not produce severe
traffic congestion, toxic pollutants or extraordinary quantities of fugitive dust. Thus, no sensitive receptors
would be exposed to pollutant concentrations. The California Air Resources Board (ARB) has identified
particulate emissions from diesel engine exhaust as toxic air contaminants. The ARB is now conducting
studies to determine if further controls will be required. At this time, no methods have been promulgated
for evaluating the impact of diesel engine exhaust. The intensity of operations, one or two pieces of
equipment moving back and forth on the beach, would be small compared with uses such as heavy traffic
or industrial warehouse operations, and it may be assumed that the impact of diesel emissions on local
residents would be less than significant. As noted above, there would be no extraordinary quantities of
5
This evaluation does not address lead, hydrogen sulfide or vinyl chloride. Although these pollutants are
regulated by the state or federal government, through ambient air quality standards, little to no emission of these
substances would result from implementation of the proposed action.
Regional Beach Sand Project EIR/EA
Page 4.12-5
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