Attachment 3.3 - Appendix C Air Quality and Greenhouse Gas Technical Report.pdf — Chula Vista City Council, November 18, 2025 (part 1 of 12)

Appendix C
Air Quality and Greenhouse Gas Emissions
Technical Report

Air Quality and Greenhouse Gas Emissions
Technical Report
Rohr Wohl Specific
Plan Project,
City of Chula Vista, California
JULY 2025
Prepared for:

CITY OF CHULA VISTA
276 Fourth Avenue
Chula Vista, California
Contact: Arturo Ortuno
Prepared by:

605 Third Street
Encinitas, California 92024
Contact: Elena Nuño, Air Quality Specialist

Printed on 30% post-consumer recycled material.

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Table of Contents
SECTION PAGE NO.

Acronyms and Abbreviations ............................................................................................................................................. v Executive Summary ......................................................................................................................................................... vii 1 Introduction .......................................................................................................................................................... 1

1.1 Report Purpose and Scope .................................................................................................................... 1

1.2 Regional and Local Setting .................................................................................................................... 1

1.3 Project Description ................................................................................................................................. 2

1.4 Project Design Features ......................................................................................................................... 2 2 Air Quality .............................................................................................................................................................. 9

2.1 Environmental Setting ............................................................................................................................ 9

2.1.1 Meteorological and Topographical Conditions ........................................................................ 9

2.1.2 Pollutants and Effects ........................................................................................................... 10

2.1.3 Sensitive Receptors ............................................................................................................... 16

2.2 Regulatory Setting ............................................................................................................................... 16

2.2.1 Federal.................................................................................................................................... 16

2.2.2 State ....................................................................................................................................... 17

2.2.3 Local ....................................................................................................................................... 24

2.3 Significance Criteria and Methodology .............................................................................................. 29

2.3.1 Thresholds of Significance .................................................................................................... 29

2.3.2 South Coast Air Quality Management District ...................................................................... 30

2.3.3 Approach and Methodology .................................................................................................. 30

2.4 Impact Analysis .................................................................................................................................... 41

2.4.1 Would the Project conflict with or obstruct implementation of the applicable air quality plan? ........................................................................................................................... 41

2.4.3 Would the Project expose sensitive receptors to substantial pollutant concentrations? ..................................................................................................... 52

2.4.4 Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? ......................................................... 59 3 Greenhouse Gas Emissions ............................................................................................................................. 61

3.1 Environmental Setting ......................................................................................................................... 61

3.1.1 Climate Change Overview ...................................................................................................... 61

3.1.2 Greenhouse Gases and other Climate Forcing Substances ............................................... 61

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3.1.3 Global Warming Potential ...................................................................................................... 63

3.1.4 Sources of Greenhouse Gas Emissions ............................................................................... 64

3.1.5 Potential Effects of Climate Change ..................................................................................... 66

3.2 Regulatory Setting ............................................................................................................................... 67

3.2.1 Federal.................................................................................................................................... 67

3.2.2 State ....................................................................................................................................... 69

3.2.3 Local ....................................................................................................................................... 82

3.3 Significance Criteria and Methodology .............................................................................................. 85

3.3.1 Thresholds of Significance .................................................................................................... 85

3.3.2 Approach and Methodology .................................................................................................. 89

3.4 Impact Analysis .................................................................................................................................... 91

3.4.1 Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment, or would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases? ............................................................................................................. 91 4 Energy .............................................................................................................................................................. 115

4.1 Environmental Setting ....................................................................................................................... 115

4.1.1 Electricity .............................................................................................................................. 115

4.1.2 Natural Gas .......................................................................................................................... 115

4.1.3 Petroleum ............................................................................................................................. 116

4.2 Regulatory Setting ............................................................................................................................. 116

4.2.1 Federal.................................................................................................................................. 116

4.2.2 State ..................................................................................................................................... 118

4.2.3 Local ..................................................................................................................................... 122

4.3 Significance Criteria and Methodology ............................................................................................ 124

4.3.1 Thresholds of Significance .................................................................................................. 124

4.3.2 Approach and Methodology ................................................................................................ 125

4.4 Impact Analysis .................................................................................................................................. 125

4.4.1 Would the project result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during Project construction or operation? ..................................................................................... 125

4.4.2 Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency? ............................................................................................................ 129

4.4.3 Would the Project result in a cumulatively considerable energy impact? ........................ 130 5 References ...................................................................................................................................................... 131 6 Preparers ......................................................................................................................................................... 139

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TABLES
ES-1 Summary of Impact Determinations ................................................................................................................ xiii 2-1 Ambient Air Quality Standards ......................................................................................................................... 17 2-2 Local Ambient Air Quality Data ......................................................................................................................... 19 2-3 SDAB Attainment Designation .......................................................................................................................... 21 2-4 SCAQMD Air Quality Significance Thresholds .................................................................................................. 30 2-5 CalEEMod Land Use Development Summary for the Proposed Project ........................................................ 31 2-6 CalEEMod Land Use Development Summary for the Existing Site ................................................................ 31 2-7 Project Construction Schedule ......................................................................................................................... 32 2-8 Construction Scenario Assumptions ................................................................................................................ 33 2-9 Project Trip Generation ..................................................................................................................................... 36 2-10 Existing Project Site Trip Generation................................................................................................................ 37 2-11 American Meteorological Society/Environmental Protection Agency Regulatory Model Principal Parameters .......................................................................................................................................... 38 2-12 Operational Health Risk Assessment American Meteorological Society/ U.S. Environmental Protection Agency Regulatory Model Operational Principal Parameters ....................................................... 40 2-13 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions - Unmitigated ............................. 47 2-14 Estimated Maximum Daily Construction Criteria Air Pollutant Emissions - Mitigated ................................. 48 2-15 Estimated Maximum Daily Operational Criteria Air Pollutant Emissions ....................................................... 49 2-16 Ambient Carbon Monoxide Concentrations for SCAQMD’s Most Congested Intersection ........................... 53 2-17 Carbon Monoxide Emission Factors Predicted by the EMFAC Model ............................................................ 53 2-18 Construction Health Risk Assessment Results – Unmitigated....................................................................... 54 2-19 Construction Health Risk Assessment Results - Mitigated ............................................................................ 54 2-20 Operational Health Risk Assessment Results – Unmitigated ........................................................................ 55 2-21 Operational Health Risk Assessment Results - Mitigated .............................................................................. 55 3-1 Six Top GHG Producer Countries ...................................................................................................................... 64 3-2 GHG Emissions Sources in California .............................................................................................................. 65 3-3 Project Potential to Conflict with City of Chula Vista Climate Action Plan ..................................................... 91 3-4 Project Potential to Conflict with 2022 Scoping Plan ..................................................................................... 96 3-5 Project Potential to Conflict with 2017 Scoping Plan GHG Emission Reduction Strategies .............. 98 3-6 Consistency with Assembly Bill 32 Regulatory Programs ............................................................................. 101 3-7 Estimated Annual Construction Greenhouse Gas Emissions ....................................................................... 112 3-8 Estimated Annual Operational Greenhouse Gas Emissions ........................................................................ 113 4-1 Construction Petroleum Demand ................................................................................................................... 126 4-2 Project Annual Operational Electricity Demand Summary ........................................................................... 126 4-3 Total Project-generated Transportation Annual Fuel Demand ..................................................................... 128

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FIGURES
1 Project Location ................................................................................................................................................... 5 2 Site Plan ................................................................................................................................................................ 7

APPENDICES
A Air Quality Emissions CalEEMod Output Files
B HRA Output Files
C Energy Estimates

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Acronyms and Abbreviations
Acronym/Abbreviation Definition
µg/m3 micrograms per cubic meter
ac acre
AQMP Air Quality Management Plan
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CalEEMod California Emissions Estimator Model
CAP Climate Action Plan
CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board
CCR California Code of Regulations
CEQA California Environmental Quality Act
City City of Chula Vista
CO carbon monoxide
DPM diesel particulate matter
EMFAC EMissions FACtor model
EPA U.S. Environmental Protection Agency
g/L grams per liter
H2S hydrogen sulfide
HAP hazardous air pollutant
HRA Health Risk Assessment
ksf thousand square feet
LOS level of service
MM Mitigation Measure
NAAQS National Ambient Air Quality Standards
NO nitric oxide
NO2 nitrogen dioxide
NOx oxides of nitrogen
O3 ozone
PDF Project Design Feature
PM2.5 fine particulate matter
PM10 coarse particulate matter
ppb parts per billion
ppm parts per million
project Rohr Wohl Specific Plan Project
RAQS Regional Air Quality Strategy
RTP Regional Transportation Plan
ROG reactive organic gases
SANDAG San Diego Association of Governments
SCAQMD South Coast Air Quality Management District

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Acronym/Abbreviation Definition
SCS Sustainable Communities Strategy
SDAB San Diego Air Basin
SDAPCD San Diego Air Pollution Control District
SDG&E San Diego Gas & Electric Company
SIP state implementation plan
SO2 sulfur dioxide
SOx sulfur oxides
sp parking space
TAC toxic air contaminant
VMT vehicle miles traveled
VOC volatile organic compound

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Executive Summary
The purpose of this technical report is to assess the potential air quality and greenhouse gas emissions impacts associated with implementation of the Rohr Wohl Specific Plan Project (project/proposed project). This assessment uses the significance thresholds in Appendix G of the California Environmental Quality Act (CEQA) Guidelines (14 CCR 15000 et seq.) and the emissions-based significance thresholds recommended by the City of Chula Vista (City) and other applicable thresholds.

Project Overview
The proposed project involves the preparation of a Specific Plan that would govern future development within the three Planning Areas (A, B-1, and B-2) at the project site. Specific plans are a mechanism to ensure that projects develop in an organized and a cohesive manner. Specific plans incorporate a development framework for detailed land use, circulation, infrastructure including drainage, sewer, and water facilities, and urban design and landscape plans. A comprehensive set of design guidelines and dev elopment regulations are included to guide and regulate site planning, landscape, and architectural character within the Specific Plan area ensuring that excellence in design is achieved during project development. The Rohr Wohl Specific Plan establishes the procedures and requirements to approve new development within the Specific Plan area.

Project Design Features
The proposed project would implement the following construction-related project design features (PDFs) intended to reduce emissions from project construction. The project would implement PDF-AQ-1, as follows:

PDF-AQ-1: Standard construction practices would be employed to reduce fugitive dust emissions and include watering of the active sites and exposed surfaces up two times per day, depending on weather conditions; watering unpaved roads, and limiting vehicle speeds on unpaved roads. Construction of the Project would be subject to SDAPCD Rule 55 – Fugitive Dust Control. Compliance with Rule 55 would limit fugitive dust that may be generated during grading and construction activities.

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▪ Leasing preference shall be given to prospective tenants with a facility -owned and operated fleet that is alternative/zero-emissions.
▪ Prior to tenant occupancy, the developer or successor(s) in interest shall provide documentation to the City of Chula Vista demonstrating that occupants/tenants of the Project site have been provided documentation on funding opportunities, such as the Carl Moyer Program, that provide incentives for using cleaner-than-required engines and equipment. ▪ The minimum number of automobile electric vehicle (EV) charging stations required by the California Code of Regulations Title 24 shall be provided prior to issuance of a Certificate of Occupancy. In addition, the buildings shall include electrical infrastructure sufficiently sized to accommodate the potential installation of additional automobile EV charging stations in the future. Electrical infrastructure shall be provided such that EV charging stations can be installed on 20% of the Project’s total autom obile parking spaces. Buildings shall include an electrical system and other infrastructure sufficiently -sized to accommodate the potential expanded installation of EV charging stations in the future. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage which informs future occupants/owners of the existence of this infrastructure. ▪ Tenants shall be in, and monitor compliance with, all current air quality regulations for on-road trucks including CARB’s Heavy -Duty (Tractor -Trailer) Greenhouse Gas Regulation, Periodic Smoke Inspection Program, and the Statewide Truck and Bus Regulation.

PDF-GHG-2 Operational Energy Source Emissions Reductions Measures. The Project shall implement the following measures.
▪ The project shall be designed such that each building features skylights that cover a minimum of 3% of the total roof area of the Project.
▪ Photovoltaic infrastructure shall be provided on the rooftops of project buildings such that a minimum of 25% of the total roof area of the project includes photovoltaic arrays at Project buildout. Project buildings shall include an electrical system and o ther infrastructure sufficiently sized to accommodate the potential installation photovoltaic arrays in the future up to 50% of the total roof area of the project. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage which informs future occupants/owners of the existence of this infrastructure.
▪ Project building plans shall specify that all fixtures installed in restrooms and employee break areas shall be U.S. Environmental Protection Agency (EPA) Certified WaterSense or equivalent. ▪ Project building plans shall specify that all heating, cooling, lighting, and appliance fixtures installed be Energy Star -rated. Information on energy efficiency, energy -efficient lighting and lighting control systems, energy management, and existing energy incentive programs shall be provided to future tenants of the project.
▪ Prior to the issuance of permits that would allow the installation of landscaping, the City of Chula Vista shall review and approve landscaping plans for the site that require: (1) a plant palette emphasizing drought -tolerant plants; (2) use of water -efficient irrigation techniques; and (3) sufficient shade trees are provided so that at least 30% of the automobile parking areas will be shaded within 15 years after project construction is complete (excluding the truck courts

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where trees cannot be planted due to interference with truck maneuvering). The City of Chula Vista shall inspect for adherence to these requirements after landscaping installation. ▪ Structures shall be equipped with outdoor electric outlets in the front and rear of the structures to facilitate use of electrical lawn and garden equipment.

Air Quality
The air quality impact analysis evaluated the potential for adverse impacts to air quality due to construction and operational emissions resulting from the project. The State CEQA Guidelines allow lead agencies to use the significance criteria established by the applicable air quality management district or air pollution control district to evaluate a project’s impacts to air quality. The City of Chula Vista has elected to apply the South Coast Air Quality Management District’s (SCAQMD) quantitative emissions significance thresholds to determine a project’s air quality impacts.

Criteria air pollutants are defined as pollutants for which the federal and state governments have established ambient air quality standards (criteria) for outdoor concentrations to protect public health. Criteria air pollutants include ozone (O3), nitrogen dioxide (NO 2), carbon monoxide (CO), sulfur dioxide (SO 2), particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM 10), particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM 2.5), and lead. Pollutants that are evaluated include volatile organic compounds (VOCs), oxides of nitrogen (NOx), CO, sulfur oxides (SOx), PM10, and PM2.5. VOCs and NOx are important because they are precursors to O3.

Air Quality Plan Consistency
If a project proposes development that is greater than that anticipated in the local plan and the growth projections set by the San Diego Association of Governments (SANDAG), the project might conflict with the State Implementation Plan and SDAPCD Regional Air Quality Strategy, and therefore may contribute to a potentially significant cumulative impact on air quality. The proposed project would amend the General Plan to change the land use designation on the project site from Industrial (I) to Rohr Wohl Specific Plan; allowed uses on site would be governed by the Specific Plan. The project area is currently designated as General Industrial (I -G) in the City of Chula Vista General Plan. The zoning of the area would be amended to allow for a flexible combination of light industrial, office, commercial and visitor -oriented uses. Th e proposed uses would rejuvenate an underutilized property creating a diverse spectrum of new employment opportunities and restoring the approximate 1,000 jobs that existed on site during Rohr Industries operations. While the proposed project would contribute to population growth it would be in an area that is comparable to existing conditions , as such it would not lead to substantial employment and population growth that would exceed that projected by SANDAG. Based on this consideration, impacts related to the project’s potential to conflict with or obstruct implementation of the applicable air quality plan would be less than significant.

Cumulatively Considerable Net Increase in Nonattainment Criteria Air Pollutant Emissions Construction of the project would result in the temporary addition of pollutants to the local airshed caused by on - site sources (i.e., off -road construction equipment, soil disturbance, and VOC off -gassing) and off -site sources (i.e., on-road haul trucks, vendor trucks, and worker vehicle trips). The maximum daily construction emissions would not exceed the SCAQMD’s significance thresholds for NO x, CO, SO x, PM10, or PM 2.5 during construction. However,

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the project’s construction emissions would exceed the SCAQMD’s thresholds of significance for VOCs. Therefore, the project would have a potentially significant impact.

The analysis herein assumed an operational year of 20 30. Operation of the project would generate operational criteria air pollutants from mobile sources (vehicles), area sources (consumer product use, architectural coatings, and landscape maintenance equipment), and energy (natural gas). The net operational emissions would not exceed the SCAQMD’s operational significance thresholds for VOCs, NOx, CO, SOx, PM10, or PM2.5.

The potential for a project to result in a cumulatively considerable impact is based on the project’s potential to exceed the project -specific daily thresholds. Implementation of Mitigation Measure AQ -1 would reduce VOC emissions below the SCAQMD’s thresholds of significance, resulting in a less than significant impact after mitigation. Because the mitigated construction and net operational emissions would not exceed the SCAQMD’s significance thresholds for VOCs, NO x, CO, SO x, PM 10, or PM 2.5, the project wo uld not result in a cumulatively considerable increase in criteria air pollutants. The impact would be less than significant after mitigation.

Exposure of Sensitive Receptors
Regarding potential carbon monoxide (CO) violations or hotspots, the project determined that there no intersections within the project area or within the City that are more congested than SCAQMD ’s most congested intersections evaluated for CO hotspots in its 2003 CO attainment redesignation request to the United States Environmental Protection Agency (EPA). Given that traffic volumes would be substantially less than those evaluated by SCAQMD and CO concentrations in the project area are well below ambient air quality standards. The project would not result in a CO hotspot given the above information and continued improvements in vehicle emissions. The impact would be less than significant.

Construction of the project would result in exposure of nearby sensitive receptors (residences) to diesel particulate matter (DPM), which is a toxic air contaminant (TAC). The construction health risk assessment (HRA) determined that the maximum individual cancer risk would exceed the SCAQMD’s threshold of significance resulting in a potentially significant impact. Mitigation Measure AQ-2 and Mitigation Measure AQ-3, which require the provision of electric infrastructure and select electric equipment during construction and the use of Tier 4 Final construction equipment, respectively, would be incorporated into the project to reduce DPM emissions. The mitigated construction health risk was determined to be less than the SCAQMD’s threshold of significance.

Operation of the project would also result in exposure of nearby sensitive receptors to DPM from potential diesel - fueled cargo handling equipment, trucks, and emergency generators. The operational HRA prepared for the project determined that the unmitigate d operational emissions would exceed the SCAQMD’s threshold s of significance resulting in a potentially significant impact. Mitigation Measure AQ-4 would require the use of electric cargo handling equipment, while Mitigation Measure AQ-4 would require the use of Tier 4 emergency generators, and Mitigation Measure AQ-5 would place truck requirements and restrictions to encourage the use of cleaner vehicles. Together these measures would result in a mitigated health risk that is below the SCAQMD’s thresholds of significance.

With the implementation of mitigation, the construction and operational health impacts would be less than significant after mitigation.

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Other Emissions
Potential odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment, architectural coatings, and asphalt pavement application, which would disperse rapidly from the Project site and generally occur at magnitudes that would not affect substantial numbers of people. Impacts associated with odors during construction would be less than significant. The project would be a mixture of industrial/business park with commercial, hotel, and restaurant land uses that would not include land uses with sources that have the potential to generate substantial odors . Impacts associated with odors during operation would be less than significant.

Greenhouse Gas Emissions
Global climate change is primarily considered a cumulative impact but must also be evaluated on a project -level under CEQA. A project contributes to this potential impact through its incremental emissions combined with the cumulative increase of all other sources of greenhouse gas (GHG) emissions. GHGs are gases that absorb infrared radiation in the atmosphere. Principal GHGs regulated under state and federal law and regulations include carbon dioxide (CO 2), methane (CH 4), and nitrous oxide (N 2O). GHG emiss ions are measured in metric tons of CO 2 equivalent (MT CO2e), which account for weighted global warming potential (GWP) factors for CH4 and N2O.

Greenhouse Gas Emissions / Conflicts with Applicable GHG Reduction Plans The project’s potential to conflict with applicable GHG reduction plans and regulations was the sole criteria used to evaluate the project’s significance under CEQA. Applicable GHG reduction plans include: the City’s Climate Action Plan (CAP), the 2022 Scoping Plan, the 2017 Scoping Plan, AB 32 Regulations, and the 2008 Scoping Plan, SANDAG’s RTP/SCS, and the City’s General Plan. The project was determined to not conflict with applicable GHG reduction plans and regulations. Furthermore, the project is locat ed within an area identified for growth and development and it would restore employment to comparable historic numbers for the project site ; the project would not result in unanticipated growth. Based on the preceding, the project would result in a less than significant GHG impact.

Energy
Wasteful, Inefficient, or Unnecessary Consumption of Energy Resources The project’s construction energy demand would represent a “single-event” energy demand and would not require ongoing or permanent commitment of resources, impacts would be less than significant. Project operations would comply with applicable regulatory measures adopted to reduce energy demand as well as incorporated PDF-GHG-1, which would further reduce energy demand. Based on the preceding, the project’s operational demand would be less than significant.

Conflict with Renewable Energy or Energy Efficiency Plans The project would comply with applicable energy plans. In addition, PDF-GHG-1 would go above and beyond current energy code standards to further enhance energy efficiencies and provide renewable energy to the project site.

Accordingly, impacts would be less than significant.

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Cumulative Energy Impact
The project itself would not result in wasteful, inefficient, or unnecessary use of energy as a result it would not contribute to a cumulative energy impact. The impact would be less than significant.

Mitigation Measures
Mitigation Measure AQ-1 Low VOC Paints. The project shall use super-compliant VOC paint (defined as less than 10 g/L of VOC) during project construction for architectural coatings.

Mitigation Measure AQ-2 Provision of Electrical Infrastructure for Construction and Use of Electric Construction Equipment. After the grading phase of Project construction, the Project Applicant or successor in interest shall provide temporary electrical hook ups to the power grid, rather than diesel -fueled generators, for contractors’ electric construction tools, such as saws, drills and compressors. The use of diesel-fueled generators for on-site construction activities shall be prohibited unless electric al infrastructure is not yet available on the Project site. Diesel-fueled generators may be used for off -site construction work. All off-road equipment with a power rating below 19 kilowatts (e.g., plate compactors, pressure washers) used during Project construction must be electric-powered. The Project Applicant or successor in interest shall include these requirements in applicable bid documents, purchase orders, and contracts with successful contractors.

Documentation using industry-standard emission estimation methodologies shal be furnished to the City Community Development Department demonstrating that estimated project -generated construction emissions would not exceed the applicable SCAQMD cancer risk threshold with the alternate construction method(s). If the documentation demonstrat es project -generated construction emissions will remain below the applicable SDAPCD cancer risk threshold, then the City may approve the alternate construction method(s) at the Development Director's discretion. Required construction equipment fleet and me thodologies approved by the City shall be included in the in the contract specifications for the applicant’s contractor.

Mitigation Measure AQ-4 Cargo Handling Equipment. All cargo handling equipment (including yard trucks, hostlers, yard goats, pallet jacks, and forklifts) shall be zero-emission vehicles. Each

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building shall include the necessary charging stations or other necessary infrastructure for cargo handling equipment. The building manager or their designee shall be responsible for enforcing these requirements.

Mitigation Measure AQ-5 Tier 4 Emergency Generators. The project operations shall be conditioned to operate with Tier 4 Final certified emergency generators.

Summary of Findings
Table ES-1. Summary of Impact Determinations
Analysis
Report
Section
CEQA
Checklist
Question
Significance Determinations
Unmitigated Mitigated
Air Quality
Air Quality Management
Plan

2.4.1 AQ-1 Less than Significant No Mitigation Required Cumulatively
Considerable Net
Increase of Any Criteria
Pollutant

2.4.2 AQ-2 Potential Significant Less than Significant
Sensitive Receptors 2.4.3 AQ-3 Potentially Significant Less than Significant Other Emissions and
Odors

2.4.4 AQ-4 Less than Significant No Mitigation Required Greenhouse Gas Emissions
Would the project
generate greenhouse
gas emissions, either
directly or indirectly, that
may have a significant
impact on the
environment, or would
the project conflict with
an applicable plan,
policy, or regulation
adopted for the purpose
of reducing the

3.4.1 GHG-1 and
GHG-2
Less than Significant No Mitigation Required

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Table ES-1. Summary of Impact Determinations
Analysis
Report
Section
CEQA
Checklist
Question
Significance Determinations
Unmitigated Mitigated
emissions of greenhouse
gases?
Energy
Wasteful, Inefficient, or
Unnecessary
Consumption of Energy
Resources

4.4.1 EN-1 Less than Significant No Mitigation Required Conflict with Renewable
Energy or Energy
Efficiency Plans

4.4.2 EN-2 Less than Significant No Mitigation Required Result in a cumulatively
considerable energy
impact?

4.4.3 EN-3 Less than Significant No Mitigation Required

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1 Introduction

1.1 Report Purpose and Scope
The purpose of this technical report (report) is to evaluate the potential air quality and greenhouse gas (GHG) impacts associated with construction and operation of the proposed Rohr Wohl Specific Plan Project (project/proposed project ) located in the City of Chula Vista (City), California, within San Diego County. This assessment uses the significance thresholds in Appendix G of the California Environmental Quality Act (CEQA) Guidelines (14 CCR 15000 et seq. ) and is based on the SCAQMD emissions-based significance thresholds as recommended by the City.

This introductory section provides a description of the proposed project. Section 2, Air Quality, describes the air quality–related environmental setting, regulatory setting, existing air quality conditions, and thresholds of significance and analysis methodology, and presents an air quality impact analysis per Appendix G of the CEQA Guidelines. Section 3, Greenhouse Gas Emissions, describes the GHG emissions –related environmental setting, regulatory setting, existing climate changes conditions, and thresho lds of significance and analysis methodology, and presents a GHG emissions impact analysis per Appendix G of the CEQA Guidelines. Section 4, Energy presents an energy impact analysis per Appendix G of the CEQA Guidelines. Section 5, References, includes a list of the references cited, and Section 6, List of Preparers, includes a list of those who prepared this technical report.

1.2 Regional and Local Setting
The project site is 44.78 acres located in the City of Chula Vista, California (City). The site is in the northwest portion of the City, directly adjacent to the City of San Diego. More specifically, the project site is located west of Interstate (I) 5, north of H Street, south of G Street, and east of Marina Parkway (Figure 1, Project Location). The site Assessor’s Parcel Numbers are 571-330-35, 36, 37, 38, 39, 40, 41, 42, 43, 44, and 45.

The project site is located within the San Diego Air Basin (SDAB) and is within the jurisdictional boundaries of the San Diego Air Pollution Control District (SDAPCD).

Project Setting and Surrounding Environment
The project site consists of developed land occupied by the former Rohr Aircraft Facility. The site was developed with several industrial buildings historically used for manufacturing, warehousing, research and development, and related office uses totaling approximately 1,048,841 square feet. One of the industrial buildings in Planning Area A, known as Building 29 (795 H Street), was used for research and development, tooling, and warehousing and distribution of aftermarket products until February 2021 . Ren ovations of that building commenced in 2021, including removal of approximately 50,000 square feet of interior mezzanine office space. Planning Areas B-1 and B-2 were used for manufacturing operations, which ceased in approximately 2020. Demolition of the buildings in Planning Areas B-1 and B-2 (totaling approximately 766,837 square feet) commenced in May 2023 in connection with environmental remediation of the site.

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Land uses in the vicinity of the project site include vacant properties, Collins Aerospace, and Seven Mile Casino to the north; Marina, Chula Vista Harbor, and future development as part of the Chula Vista Bayfront Master Plan to the south; Bay Boulevard and I-5 to the east; and Chula Vista RV Resort and future development site for the Gaylord Pacific Resort Hotel and Convention Center to the west.

1.3 Project Description
The proposed project involves the preparation of a Specific Plan that would govern future development within the three Planning Areas (A, B-1, and B-2) at the project site (see Figure 2). Specific plans are a mechanism to ensure that projects develop in an organized and a cohesive manner. Specific plans incorporate a development framework for detailed land use, circulation, infrastructure including drainage, sewer, and water facilities, a nd urban design and landscape plans. A comprehensive set of design guidelines and development regulations are included to guide and regulate site planning, landscape, and architectural character within the Specific Plan area ensuring that excellence in design is achieved during project development. The Rohr Wohl Specific Pla n establishes the procedures and requirements to approve new development within the Specific Plan area.

A General Plan and Land Use Plan Amendment is proposed to be processed concurrently with Specific Plan adoption, which would change the existing I -G (General Industrial) zoning designation to three new zoning designations: PA-1 (for Planning Area A), PA-2 (for Planning Area B-1), and PA-3 (for Planning Area B-2). These new designations would provide for permitted, conditionally permitted, and prohibited uses within six land use categories: Commercial Retail (CR), Commercial Visitor (CV), Commercial Office (CO), Light Industrial (LI), Regional Technology Park (RTP), and Business Park Flex (BPF). The existing zoning designation of I-G would be amended to complement the Collins Aerospace Campus to allow a flexible combination of light industrial, office, commercial and visitor-oriented uses to complement both the overall Chula Vista Bayfront area and the western part of Chula Vista. California Government Code (Title 7, Division 1, Chapter 3, Article 8, Section s 65450–65457) permits adoption and administration of specific plans as an implementation tool for the local general plan. Specific plans must demonstrate consistency in regulations, guidelines, and programs with the goals and policies set forth in the general plan. The Rohr Wohl Specific Plan would be prepared in conformance with the goals and policies of the City of Chula Vista General Plan as amended, in providing a commercial/light Industrial use on an underutilized property, creating new employment opportunities, and providing regulations that support the success of an employment area of the City.

1.4 Project Design Features
The Project would implement construction -related and operational project design features (PDFs) intended to reduce emissions of criteria air pollutants and toxic air contaminants (TACs) as follows:

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PDF-GHG-1 Operational Mobile Source Emissions Reductions Measures. The project shall implement the following measures.
▪ Legible, durable, weather-proof signs shall be placed at truck access gates, loading docks, and truck parking areas that identify applicable California Air Resources Board (CARB) anti -idling regulations. At a minimum, each sign shall include: (1) instructions for truck drivers to shut off engines when not in use; (2) instructions for drivers of diesel trucks to restrict idling to no more than 5 minutes once the vehicle is stopped, the transmission is set to “neutral” or “park,” and the parking brake is enga ged; and (3) telephone numbers of the building facilities manager and CARB to report violations. Prior to the issuance of an occupancy permit, the City of Chula Vista shall conduct a site inspection to ensure that the signs are in place. ▪ Tenants shall train managers and employees on efficient scheduling and load management to eliminate unnecessary queuing and idling of trucks. Staff in charge of keeping vehicle records shall be trained in diesel technologies and compliance with CARB regulations by attending CARB- approved courses as well as maintaining on-site records demonstrating compliance. ▪ Leasing preference shall be given to prospective tenants with a facility -owned and operated fleet that is alternative/zero-emissions.
▪ Prior to tenant occupancy, the developer or successor(s) in interest shall provide documentation to the City of Chula Vista demonstrating that occupants/tenants of the Project site have been provided documentation on funding opportunities, such as the Carl Moyer Program, that provide incentives for using cleaner-than-required engines and equipment. ▪ The minimum number of automobile electric vehicle (EV) charging stations required by the California Code of Regulations Title 24 shall be provided prior to issuance of a Certificate of Occupancy. In addition, the buildings shall include electrical infrastructure sufficiently sized to accommodate the potential installation of additional automobile EV charging stations in the future. Electrical infrastructure shall be provided such that EV charging s tations can be installed on 20% of the Project’s total automobile parking spaces. Buildings with over 200 parking spaces shall include an electrical system and other infrastructure sufficiently -sized oversize electrical rooms by 25 percent or by providing a secondary electrical room to accommodate future expansion of electric vehicle charging capability to accommodate the potential expanded installation of EV charging stations in the future. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage which informs future occupants/owners of the existence of this infrastructure. ▪ Tenants shall be in, and monitor compliance with, all current air quality regulations for on-road trucks including CARB’s Heavy -Duty (Tractor -Trailer) Greenhouse Gas Regulation, Periodic Smoke Inspection Program, and the Statewide Truck and Bus Regulation.

PDF-GHG-2 Operational Energy Source Emissions Reductions Measures. The Project shall implement the following measures.
▪ The project shall be designed such that all buildings with occupied rooms shall have some form of daylighting (e.g. skylights or windows) each building features skylights that cover a minimum of 3% of the total roof area of the Project.

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▪ Photovoltaic infrastructure shall be provided on the rooftops of project buildings in accordance with the proposed land use. Industrial/warehouse buildings shall provide a minimum 3% of the total roof area for photovoltaic arrays at building construction . All other proposed land uses shall provide a minimum 1 0% of the total roof area for photovoltaic arrays at building construction. such that a minimum of 25% of the total roof area of the project includes photovoltaic arrays at Project buildout. Project buildings shall include an electrical system and other infrastructure sufficiently sized to accommodate the potential installation photovoltaic arrays in the future up to 50% of the total roof area of the project. The electrical system and infrastructure must be clearly labeled with noticeable and permanent signage which informs future occupants/owners of the existence of this infrastructure. ▪ Project building plans shall specify that all fixtures installed in restrooms and employee break areas shall be U.S. Environmental Protection Agency (EPA) Certified WaterSense or equivalent. ▪ Project building plans shall specify that all heating, cooling, lighting, and appliance fixtures installed be Energy Star-rated. Information on energy efficiency, energy -efficient lighting and lighting control systems, energy management, and existing energy incentive programs shall be provided to future tenants of the project.
▪ Prior to the issuance of permits that would allow the installation of landscaping, the City of Chula Vista shall review and approve landscaping plans for the site that require: (1) a plant palette emphasizing drought -tolerant plants; (2) use of water -efficient irrigation techniques; and (3) sufficient shade trees are provided so that at least 30% of the automobile parking areas will be shaded within 15 years after project construction is complete (excluding the truck courts where trees cannot be planted due to interference with truck maneuvering). The City of Chula Vista shall inspect for adherence to these requirements after landscaping installation. ▪ Structures shall be equipped with outdoor electric outlets in the front and rear of the structures to facilitate use of electrical lawn and garden equipment.

54 75
5 W 32ND ST
04TH AVE

GRAND CARIBE CSWY
02ND AVE

GU NPOWDER POINT DR
05TH AVE

FLOWER ST
I ST

BEECHAVE

DAVIDSON ST
E ST
SMITH
AVE

PARK WAY

GLOVERAVE

JAMES ST

MARDIGRASRD
C ST

MCINTOSH ST

MARINA PKY

SHASTA ST
J ST

HALSEY ST

SIERRA WAY
03RD AVE
01ST
AVE

MOSS ST

KEARNEY ST
G ST
05TH AVE
F ST

CORONADO

CAY S BLVD
DELMAR
AVE

GUAVA AVE
ALLEY

MADRONA ST
W
OODLAW
N

AVE CEDAR AVE

CORONADO BAYRD

SANDPIPE

R WAY ELDER AVE

SEA VALE ST
FIG
AVE
D ST

BAYSIDE WAY

FIG AVE

BRIGHTWOOD AVE

MADISON AVE

BROADWAY

CHURCH AVE

WOODLAWN AVE
G ST

GARRETT AVE

LANDIS AVE

EAST PARK LN

SEA VALE ST

TWIN OAKS AVE

GARRETTAVE
ALLEY

CASSELMAN ST

COLORADO AVE

LAGOON DR
H ST
L ST

ALVARADO ST

ARIZONA ST

GREEN TURTLE RD

RIVERLAWNAVE

DATE AVE

ASH AVE

GUAVA AVE

THE POINT
W 35TH ST
K ST

MINOTAVE

MAR INA WAY

ROOSEVELT ST

WESTBY ST

OAKLAWN AVE

BAY BLVD

BAYBLVD
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SOURCE: SANGIS 2023
Date: 6/29/2023 - Last saved by: agreis - Path: Z:\Projects\j1454101\MAPDOC\DOCUMENT\EIR\Figure4-1_ProjectLocatoin.mxd 02 ,0001,000
Feet
Project Boundary
Chula Vista
Solana Beach
Encinitas
San Diego
Carlsbad
Oceanside
La Mesa
El Cajon
Santee
Poway
San Marcos
Escondido
Vista
Imperial
Beach
Del Mar
Coronado
Riverside
County
Mexico
905
209
75 52
54 94
241
98 73
125
274
195
56 78
86 111
67 74
74 76 79
805
215
15 5
8 Project Site
FIGURE 1
Project Location
R
ohr Wohl Specific Plan

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INTENTIONALLY LEFT BLANK

EVEV EVEVEVEVEVEV EVEVEVEVEV EVEV EVEV EV
H ST

PRIVATE

LAGOON DR

MARINA PKWY
G ST

BAY BLVD
RIDA
INTERSTATE 5
SDG&E
NOT A
PART
MARINA
PKWY
G ST
SHEET OF 1

COLLINS WOHL BAYFRONT SPECIFIC PLAN

PLANNING AREAS
JULY 29, 2022
1 PLANNING AREA B-1
PLANNING AREA B-2
PLANNING AREA A-2
COLLINS - "PARCEL C"

NOT A PART
SPECIFIC PLAN BOUNDARY ~

44.78 ACRES
PA A-2 9.29 AC.

PA B-1 26.13 AC.

PA B-2 9.36 AC.
* * * CLOSING ESCROW FROM
COLLINS TO PW WOHL 10/31/22

NOT A PART
Z:\Projects\j1453001\MAPDOC\DOCUMENT\Visual
SOURCE: COLLINS WOHL BAYFRONT SPECIFIC PLAN, 2022
FIGURE 2
Site Plan
Rohr Wohl Specific Plan

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INTENTIONALLY LEFT BLANK

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2 Air Quality

2.1 Environmental Setting
The Project site is located within the boundaries of the San Diego Air Basin (SDAB). The SDAB is one of 15 air basins that geographically divide the State of California. The SDAB lies in the southwest corner of California and covers 4,260 square miles with the San Diego region.

Air pollutants are emitted by a variety of sources, including mobile sources (vehicles), area sources (hearths, consumer product use, architectural coatings, and landscape maintenance equipment), energy sources (natural gas), and stationary sources (generators or other stationary equipment). Some air pollutants need to be examined at the local level, and others are predominately an issue at the regional level. For instance, ozone (O3) is formed in the atmosphere in the presence of sunlight by a series of chemical reactions involving oxides of nitrogen (NOx) and reactive organic gas (ROG) (also termed volatile organic compounds (VOCs)). Because these reactions are broad scale in effects, O 3 is typically analyzed at the regional level (i.e., in the SDAB) rather than the local level. On the other hand, air pollutants such as coarse particulate matter (PM10), fine particulate matter (PM2.5), carbon monoxide (CO), and toxic air contaminants (TACs) are a potential concern in the immediate vicinity of the pollutant source because the pollutants are emitted directly by or are formed close to the source. Therefore, the study area for emissions of PM10, PM2.5, CO, and TACs is the local area near the source, such as in the vicinity of the Project Site, and the study area for regional pollutants such as NOx and ROGs is the entire SDAB.

2.1.1 Meteorological and Topographical Conditions
Air quality is a function of the rate and location of pollutant emissions under the influence of meteorological conditions and topographic features that influence pollutant movement and dispersal. Atmospheric conditions such as wind speed, wind direction, atmospheric stability, and air temperature gradients interact with the physical features of the landscape to determine the movement and dispersal of air pollutants, and consequently affect air quality.

The weather of the San Diego region, as in most of Southern California, is influenced by the Pacific Ocean and its semi-permanent high-pressure systems that result in dry, warm summers and mild, occasionally wet winters. The average temperature ranges (in degrees Fahrenheit) from the mid -40s to the high 90s. Most of the region’s precipitation falls from November to April, with infrequent (approximately 10%) precipitation during the summer.

The average seasonal precipitation along the coast is approximately 10 inches; the amount increases with elevation as moist air is lifted over the mountains (WRCC 2016).

The topography in the San Diego region varies greatly, from beaches on the west to mountains and desert on the east; along with local meteorology, it influences the dispersal and movement of pollutants in the basin. The mountains to the east prohibit dispersal of pollutants in that direction and help trap them in inversion layers.

The interaction of ocean, land, and the Pacific High-Pressure Zone maintains clear skies for much of the year and influences the direction of prevailing winds (westerly to northwesterly). Local terrain is often the dominant factor inland, and winds in inland mountainous areas tend to blow through the valleys during the day and down the hills and valleys at night.

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The SDAB experiences frequent temperature inversions. Subsidence inversions occur during the warmer months as descending air associated with the Pacific High-Pressure Zone meets cool marine air. The boundary between the two layers of air creates a temperature inversion that traps pollutants. The other type of inversion, a radiation inversion, develops on winter nights when air near the ground cools by heat radiation and air aloft remains warm.

The shallow inversion layer formed between these two air masses also can trap pollutants. As the pollutants become more concentrated in the atmosphere, photochemical reactions occur that produce O 3, which contributes to the formation of smog. Smog is a combination of smoke and other particulates, O 3, hydrocarbons, oxides of nitrogen (NOx) and other chemically reactive compounds which, under certain conditions of weather and sunlight, may result in a murky brown haze that causes adverse health effects (CARB 2023a).

Light daytime winds, predominantly from the west, further aggravate the condition by driving air pollutants inland, toward the mountains. During the fall and winter, air quality problems are created due to carbon monoxide (CO) and NOx emissions. CO concentrations are generally higher in the morning and late evening. In the morning, CO levels are elevated due to cold temperatures and the large number of motor vehicles traveling. Higher CO levels during the late evenings are a result of stagnant atmospheric c onditions trapping CO in the area. Since CO is produced almost entirely from automobiles, the highest CO concentrations in the SDAB are associated with heavy traffic. Nitrogen dioxide (NO2) levels are also generally higher during fall and winter days.

Under certain conditions, atmospheric oscillation results in the offshore transport of air from the Los Angeles region to San Diego County. This often produces high O3 concentrations, as measured at air pollutant monitoring stations within San Diego County. The transport of air pollutants from Los Angeles to San Diego has also occurred within the stable layer of the elevated subsidence inversion, where high levels of O3 are transported.

2.1.2 Pollutants and Effects

2.1.2.1 Criteria Air Pollutants
Criteria air pollutants are defined as pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state standards have been set, with an adequate margin of safety, at levels above which concentrations could be harmful to human health and welfare. These standards are designed to protect the most sensitive persons from illness or discomfort. Pollutants of concern include O3, NO2, CO, sulfur dioxide (SO2), PM10, PM2.5, and lead. These pollutants are discussed in the following paragraphs. 1 In California, sulfates, vinyl chloride, hydrogen sulfide, and visibility - reducing particles are also regulated as criteria air pollutants.

Ozone (O3). O3 is a strong-smelling, pale blue, reactive, toxic chemical gas consisting of three oxygen atoms. It is a secondary pollutant formed in the atmosphere by a photochemical process involving the sun’s energy and O 3 precursors. These precursors are mainly NO x and VOCs. The maximum effects of precursor emissions on O 3 concentrations usually occur several hours after they are emitted and many miles from the source. Meteorology and terrain play major roles in O3 formation, and ideal conditions occur during summer and early autumn on days with low wind speeds or stagnant air, warm temperatures, and cloudless skies. O3 exists in the upper atmosphere

1 The following descriptions of health effects for each of the criteria air pollutants associated with project construction and operations are based on the U.S. Environmental Protection Agency’s “Six Common Air Pollutants” (EPA 2022) and the California Air Resources Board’s “Glossary of Air Pollutant Terms” (CARB 2023a) published information.

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O3 layer (stratospheric O 3) and at the Earth’s surface in the troposphere. 2 The O 3 that the U.S. Environmental Protection Agency (EPA) and the CARB regulate as a criteria air pollutant is produced close to the ground level, where people live, exercise, and breathe. Ground-level O3 is a harmful air pollutant that causes numerous adverse health effects and is thus considered “bad” O 3. Stratospheric, or “good,” O 3 occurs naturally in the upper atmosphere, where it reduces the amount of ultraviolet light (i.e., solar radiation) entering the Earth’s atmosphere.

Without the protection of the beneficial stratospheric O3 layer, plant and animal life would be seriously harmed.

O3 in the troposphere causes numerous adverse health effects; short-term exposures (lasting for a few hours) to O3 at levels typically observed in Southern California can result in breathing pattern changes, reduction of breathing capacity, increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes (EPA 2013).

Inhalation of O3 causes inflammation and irritation of the tissues lining human airways, causing and worsening a variety of symptoms. Exposure to O3 can reduce the volume of air that the lungs breathe in, thereby causing shortness of breath.

O3 in sufficient doses increases the permeability of lung cells, rendering them more susceptible to toxins and microorganisms. The occurrence and severity of health effects from O3 exposure vary widely among individuals, even when the dose and the duration of exposure are the same. Research shows adults and children who spend more time outdoors participating in vigorous physical activities are at greater risk from the harmful health effects of O3 exposure.

While there are relatively few studies on the effects of O3 on children, the available studies show that children are no more or less likely to suffer harmful effects than adults. However, there are a number of reasons why children may be more susceptible to O3 and other pollutants. Children and teens spend nearly twice as much time outdoors and engaged in vigorous activities as adults. Children breathe more rapidly than adults and inhale more pollution per pound of their body weight than adults. Also, children are less likely than adults to notice their own symptoms and avoid harmful exposures. Further research may be able to better distinguish between health effects in children and adults. Children, adolescents and adults who exercise or work outdoors, where O3 concentrations are the highest, are at the greatest risk of harm from this pollutant (CARB 2023a).

Nitrogen Dioxide (NO2). NO2 is a brownish, highly reactive gas that is present in all urban atmospheres. The major mechanism for the formation of NO2 in the atmosphere is the oxidation of the primary air pollutant nitric oxide (NO), which is a colorless, odorless gas. NO x plays a major role, together with VOCs, in the atmospheric reactions that produce O 3. NO x is formed from fuel combustion under high temperature or pressure. In addition, NO x is an important precursor to acid rain and may affect both terrestrial and aquatic ecosystems. The two major emissions sources are transportation and stationary fuel combustion sources such as electric utility and industrial boilers.

NO2 can irritate the lungs, cause bronchitis and pneumonia, and lower resistance to respiratory infections (EPA 2022). A large body of health science literature indicates that exposure to NO2 can induce adverse health effects.

The strongest health evidence, and the health basis for the ambient air quality standards for NO 2, results from controlled human exposure studies that show that NO 2 exposure can intensify responses to allergens in allergic asthmatics. In addition, a number of epidemiological studies h ave demonstrated associations between NO 2 exposure and premature death, cardiopulmonary effects, decreased lung function growth in children, respiratory symptoms, emergency room visits for asthma, and intensified allergic responses. Infants and children are particularly at risk because they have disproportionately higher exposure to NO 2 than adults due to their greater breathing rate for their body weight and their typically greater outdoor exposure duration. Several studies have shown that long-term NO2 exposure during childhood, the period of rapid lung growth, can lead to smaller lungs at

2 The troposphere is the layer of the Earth’s atmosphere nearest to the surface of the Earth. The troposphere extends outward about 5 miles at the poles and about 10 miles at the equator.

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maturity in children with higher levels of exposure compared to children with lower exposure levels. In addition, children with asthma have a greater degree of airway responsiveness compared with adult asthmatics. In adults, the greatest risk is to people who have chronic respiratory diseases, such as asthma and chronic obstructive pulmonary disease (CARB 2023b).

Carbon Monoxide (CO). CO is a colorless, odorless gas formed by the incomplete combustion of hydrocarbon, or fossil fuels. CO is emitted almost exclusively from motor vehicles, power plants, refineries, industrial boilers, ships, aircraft, and trains. In urban areas, such as the Project location, automobile exhaust accounts for the majority of CO emissions.

CO is a non -reactive air pollutant that dissipates relatively quickly; therefore, ambient CO concentrations generally follow the spatial and temporal di stributions of vehicular traffic. CO concentrations are influenced by local meteorological conditions—primarily wind speed, topography, and atmospheric stability. CO from motor vehicle exhaust can become locally concentrated when surface -based temperature inversions are combined with calm atmospheric conditions, which is a typical situation at dusk in urban areas from November to February. The highest levels of CO typically occur during the colder months of the year, when inversion conditions are more frequent.

CO is harmful because it binds to hemoglobin in the blood, reducing the ability of blood to carry oxygen. This interferes with oxygen delivery to the body’s organs. The most common effects of CO exposure are fatigue, headaches, confusion and reduced mental alertness, light-headedness, and dizziness due to inadequate oxygen delivery to the brain. For people with cardiovascular disease, short-term CO exposure can further reduce their body’s already compromised ability to respond to the increased oxygen demand s of exercise, exertion, or stress.

Inadequate oxygen delivery to the heart muscle leads to chest pain and decreased exercise tolerance. Unborn babies whose mothers experience high levels of CO exposure during pregnancy are at risk of adverse developmental effects. Unborn babies, infants, elderly people, and people with anemia or with a history of heart or respiratory disease are most likely to experience health effects with exposure to elevated levels of CO (CARB 2023c).

Sulfur Dioxide (SO 2). SO2 is a colorless, pungent gas formed primarily from incomplete combustion of sulfur - containing fossil fuels. The main sources of SO2 are coal and oil used in power plants and industries; as such, the highest levels of SO2 are generally found near large industrial complexes. In recent years, SO2 concentrations have been reduced by the increasingly stringent controls placed on stationary source emissions of SO2 and limits on the sulfur content of fuels.

Controlled human exposure and epidemiological studies show that children and adults with asthma are more likely to experience adverse responses with SO2 exposure, compared with the non-asthmatic population. Effects at levels near the 1 -hour standard are those of asthma exacerbation, including bronchoconstriction accompanied by symptoms of respiratory irritation such as wheezing, shortness of breath, and c hest tightness, especially during exercise or physical activity. Also, exposure at elevated levels of SO 2 (above 1 parts per million [ppm]) results in increased incidence of pulmonary symptoms and disease, decreased pulmonary function, and increased risk of mortality. Older people and people with cardiovascular disease or chronic lung disease (such as bronchitis or emphysema) are most likely to experience these adverse effects (CARB 2023d).

SO2 is of concern both because it is a direct respiratory irritant and because it contributes to the formation of sulfate and sulfuric acid in particulate matter (NRC 2005). People with asthma are of particular concern, both because they have increased baseli ne airflow resistance and because their SO 2-induced increase in airflow resistance is greater than in healthy people, and it increases with the severity of their asthma (NRC 2005). SO 2 is thought to induce airway constriction via neural reflexes involving irritant receptors in the airways (NRC 2005).

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Particulate Matter (PM). Particulate matter pollution consists of very small liquid and solid particles floating in the air, which can include smoke, soot, dust, salts, acids, and metals. Particulate matter can form when gases emitted from industries and motor vehicles undergo ch emical reactions in the atmosphere. PM 2.5 and PM 10 represent fractions of particulate matter. Coarse particulate matter (PM 10) consists of particulate matter that is 10 microns or less in diameter and is about 1/7 the thickness of a human hair. Major sources of PM 10 include crushing or grinding operations; dust stirred up by vehicles traveling on roads; wood -burning stoves and fireplaces; dust from construction, landfills, and agriculture; wildfires and brush/waste burning; industrial sources; windblown dust from open lands; and atmospheric chemical and photochemical reactions. Fine particulate matter (PM 2.5) consists of particulate matter that is 2.5 microns or less in diameter and is roughly 1/28 the diameter of a human hair. PM2.5 results from fuel combustion (e.g., from motor vehicles and power generation and industrial facilities), residential fireplaces, and woodstoves. In addition, PM2.5 can be formed in the atmosphere from gases such as sulfur oxides (SOx), NOx, and VOCs.

PM2.5 and PM10 pose a greater health risk than larger-size particles. When inhaled, these tiny particles can penetrate the human respiratory system’s natural defenses and damage the respiratory tract. PM 2.5 and PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections. Very small particles of substances such as lead, sulfates, and nitrates can cause lung damage directly or be absorbed into the blood s tream, causing damage elsewhere in the body. Additionally, these substances can transport adsorbed gases such as chlorides or ammonium into the lungs, also causing injury.

Whereas PM10 tends to collect in the upper portion of the respiratory system, PM2.5 is so tiny that it can penetrate deeper into the lungs and damage lung tissue. Suspended particulates also damage and discolor surfaces on which they settle and produce haze and reduce regional visibility.

A number of adverse health effects have been associated with exposure to both PM2.5 and PM10. For PM2.5, short-term exposures (up to 24-hour duration) have been associated with premature mortality, increased hospital admissions for heart or lung causes, acute and chronic bronchitis, asthma attacks, emergency room visits, respiratory symptoms, and restricted activity days. These adverse health effects have been reported primarily in infants, children, and older adults with preexisting heart or lung diseases. In addition, of all of the common air pollutants, PM2.5 is associated with the greatest proportion of adverse health effects related to air pollution, both in the United States and worldwide based on the World Health Organization’s Global Burden of Disease Project. Short-term exposures to PM10 have been associated primarily with worsening of respiratory diseases, including asthma and chronic obstructive pulmonary disease, leading to hospitalization and emergency department visits (CARB 2023e).

Long-term exposure (months to years) to PM2.5 has been linked to premature death, particularly in people who have chronic heart or lung diseases, and reduced lung function growth in children. The effects of long-term exposure to PM10 are less clear, although several studies suggest a link between long -term PM 10 exposure and respiratory mortality. The International Agency for Research on Cancer published a review in 2015 that concluded that particulate matter in outdoor air pollution causes lung cancer (CARB 2023e).

Lead. Lead in the atmosphere occurs as particulate matter. Sources of lead include leaded gasoline; the manufacturing of batteries, paints, ink, ceramics, and ammunition; and secondary lead smelters. Prior to 1978, mobile emissions were the primary source of atmospheric lead. Between 1978 and 1987, the phaseout of leaded gasoline reduced the overall inventory of airborne lead by nearly 95%. With the phaseout of leaded gasoline, secondary lead smelters, battery recycling, and manufacturing facilities are becoming lead-emissions sources of greater concern.

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Prolonged exposure to atmospheric lead poses a serious threat to human health. Health effects associated with exposure to lead include gastrointestinal disturbances, anemia, kidney disease, and in severe cases, neuromuscular and neurological dysfunction. Of particular concern are low-level lead exposures during infancy and childhood. Such exposures are associated with decrements in neurobehavioral performance, including IQ performance, psychomotor performance, reaction time, and growth. Children are highly susceptible to the effects of lead.

Volatile Organic Compounds (VOCs). Hydrocarbons are organic gases that are formed from hydrogen and carbon and sometimes other elements. Hydrocarbons that contribute to formation of O 3 are referred to and regulated as VOCs (also referred to as reactive organic gases). Combustion engine exhaust, oil refineries, and fossil-fueled power plants are the sources of hydrocarbons. Other sources of hydrocarbons include evaporation from petroleum fuels, solvents, dry-cleaning solutions, and paint.

The primary health effects of VOCs result from the formation of O3 and its related health effects. High levels of VOCs in the atmosphere can interfere with oxygen intake by reducing the amount of available oxygen through displacement. Carcinogenic forms of hydrocarbons, such as benzene, are considered TACs.

Sulfates. Sulfates are the fully oxidized form of sulfur, which typically occur in combination with metals or hydrogen ions. Sulfates are produced from reactions of SO 2 in the atmosphere and can result in respiratory impairment, as well as reduced visibility.

Vinyl Chloride. Vinyl chloride is a colorless gas with a mild, sweet odor, which has been detected near landfills, sewage plants, and hazardous waste sites, due to the microbial breakdown of chlorinated solvents. Short -term exposure to high levels of vinyl chloride in air can cause nervous system effects, such as dizziness, drowsiness, and headaches. Long-term exposure through inhalation can cause liver damage, including liver cancer.

Hydrogen Sulfide. Hydrogen sulfide is a colorless and flammable gas that has a characteristic odor of rotten eggs.

Sources of hydrogen sulfide include geothermal power plants, petroleum refineries, sewers, and sewage treatment plants. Exposure to hydrogen sulfide can result in nuisance odors, as well as headaches and breathing difficulties at higher concentrations.

Visibility-Reducing Particles. Visibility-reducing particles are any particles in the air that obstruct the range of visibility. Effects of reduced visibility can include obscuring the viewshed of natural scenery, reducing airport safety, and discouraging tourism. Sources of visibility-reducing particles are the same as for PM2.5.

2.1.2.2 Non-Criteria Pollutants
Toxic Air Contaminants (TACs). A substance is considered toxic if it has the potential to cause adverse health effects in humans, including increasing the risk of cancer upon exposure, or acute and/or chronic noncancer health effects.

A toxic substance released into the air is considered a TAC. TACs are identified by federal and state agencies based on a review of available scientific evidence. In the State of California, TACs are identified through a two-step process that was established in 1983 under the Toxic Air Contaminant Identification and Control Act. This two-step process of risk identification and risk management and reduction was designed to protect residents from the health effects of toxic substances in the air. In addition, the California Air T oxics “Hot Spots” Information and Assessment Act, Assembly Bill (AB) 2588, was enacted by the legislature in 1987 to address public concern over the release of TACs into the atmosphere. The law requires stationary sources to report the types and quantities of certain substances

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routinely released into the air. The goals of the Air Toxics "Hot Spots" Act are to collect emission data, to identify facilities having localized impacts, to ascertain health risks, to notify nearby residents of significant risks, and to reduce those significant risks to acceptable levels.

Examples include certain aromatic and chlorinated hydrocarbons, certain metals, and asbestos. TACs are generated by several sources, including stationary sources such as dry cleaners, gas stations, combustion sources, and laboratories; mobile sources such as automobiles; and area sources such as landfills. Adverse health effects associated with exposure to TACs may include carcinogenic (i.e., cancer -causing) and noncar cinogenic effects.

Noncarcinogenic effects typically affect one or more target organ systems and may be experienced on either short- term (acute) or long-term (chronic) exposure to a given TAC.

Diesel Particulate Matter (DPM). DPM is part of a complex mixture that makes up diesel exhaust. Diesel exhaust is composed of two phases, gas and particle, both of which contribute to health risks. More than 90% of DPM is less than 1 micrometer in diameter (about 1/70th the diameter of a human hair), and thus is a subset of PM2.5 (CARB 2023f). DPM is typically composed of carbon particles (“soot,” also called black carbon) and numerous organic compounds, including over 40 known cancer -causing organic substances. Examples of these chemicals include polycyclic aromatic hydrocarbons, benzene, formaldehyde, acetaldehyde, acrolein, and 1,3 -butadiene (CARB 2023f). CARB classified “particulate emissions from diesel-fueled engines” (i.e., DPM) as a TAC in August 1998 (17 CCR 93000). DPM is emitted from a broad range of diesel engines: on -road diesel engines of trucks, buses, and cars and off -road diesel engines including locomotives, marine vessels, and heavy -duty construction equipment, among others. Approximately 70% of all airborne cancer risk in California is associated with DPM (CARB 2000). To reduce the cancer risk associated with DPM, California Air Resources Board (CARB) adopted a diesel risk reduction plan in 2000 (CARB 2000). Because it is part of PM2.5, DPM also contributes to the same non-cancer health effects as PM2.5 exposure. These effects include premature death; hospitalizations and emergency department visits for exacerbated chronic heart and lung disease, including asthma; increased respiratory symptoms; and decreased lung function in children. Several studies suggest that exposure to DPM may also facilitate development of new allergies (CARB 202 3f). Those most vulnerable to non -cancer health effects are children whose lungs are still developing and the elderly who often have chronic health problems.

Odorous Compounds. Odors are generally regarded as an annoyance rather than a health hazard. Manifestations of a person’s reaction to odors can range from psychological (e.g., irritation, anger, or anxiety) to physiological (e.g., circulatory and respiratory effects, nausea, vomiting and headache). The ability to detect odors varies considerably among the population and overall is quite subjective. People may have different reactions to the same odor. An odor that is offensive to on e person may be perfectly acceptable to another (e.g., coffee roaster). An unfamiliar odor is more easily detected and is more likely to cause complaints than a familiar one. In a phenomenon known as odor fatigue, a person can become desensitized to almost any odor, and recognition may only occur with an alteration in the intensity. The occurrence and severity of odor impacts depend on the nature, frequency, and intensity of the source; wind speed and direction; and the sensitivity of receptors.

Valley Fever. Coccidioidomycosis, more commonly known as “Valley Fever,” is an infection caused by inhalation of the spores of the Coccidioides immitis fungus, which grows in the soils of the southwestern United States.

San Diego County (County) is not considered a highly endemic region for Valley Fever, as the latest report from the County of San Diego Health and Human Services Agency Public Health Services indicated the County has 6.3 cases per 100,000 people (County of San Diego 2021). In the zip code area of the Project site (91910), the case rate is reported as 11.9 cases per 100,000 people (County of San Diego 2021).

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2.1.3 Sensitive Receptors
Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved. People most likely to be affected by air pollution, as identified by the California Air Resources Board (CARB), include children, older adults, and people with cardiovascu lar and chronic respiratory diseases. According to the SDAPCD, sensitive receptors are those who are especially susceptible to adverse health effects from exposure to toxic air contaminants, such as children, the elderly, and the ill. Sensitive receptors include residences, schools (grades Kindergarten through 12), libraries, day care centers, nursing homes, retirement homes, health clinics, and hospitals within 2 kilometers of the facility (SDAPCD 2022a). The closest sensitive receptors to the project site are existing multi-family residences east of I-5, east of the project site’s boundaries.

Sensitive receptors located within 1,000 feet of the project site include:
▪ Multi-family residences east of I -5, approximately 430 feet east of the project site’s eastern boundary. (closest sensitive receptor)
▪ Holiday Gardens multi -family residences, east of I -5, approximately 640 feet east of the project site’s eastern boundary.
▪ Cabrillo Mobile Home Lodge east of I-5, approximately 435 feet northeast of the project site’s eastern boundary. ▪ Bison Mobile Home Park east of I-5, approximately 560 feet southeast of project site’s eastern boundary.

In addition, Mueller Charter School is located 1,130 feet southeast of project site’s eastern boundary.

2.2 Regulatory Setting

2.2.1 Federal

2.2.1.1 Criteria Pollutants
The federal Clean Air Act (CAA), passed in 1970 and last amended in 1990, forms the basis for the national air pollution control effort. The U.S. Environmental Protection Agency ( EPA) is responsible for implementing most aspects of the Clean Air Act (CAA), including the setting of National Ambient Air Quality Standards (NAAQS) for major air pollutants, hazardous air pollutant (HAP) standards, approval of state attainment plans, motor vehicle emission standards, stationary source emission standards and permits, acid rain control measures, stratospheric ozone (O3) protection, and enforcement provisions.

NAAQS are established by the EPA for “criteria pollutants” under the CAA, which are O 3, carbon monoxide ( CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), coarse particulate matter (PM10), fine particulate matter (PM2.5), and lead. The NAAQS describe acceptable air quality conditions designed to protect the health and welfare of the citizens of the nation. The CAA requires the EPA to reassess the NAAQS at least every 5 years to determine whether adopted standards are adequate to protect public health based on current scientific evidence. States with areas that exceed the NAAQS must prepare a state implementation p lan (SIP) that demonstrates how those areas will attain the standards within mandated time frames.

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2.2.1.2 Hazardous Air Pollutants
The 1977 CAA Amendments required the EPA to identify national emission standards for hazardous air pollutants to protect the public health and welfare. HAPs include certain volatile organic chemicals, pesticides, herbicides, and radionuclides that present a tangible hazard, based on scientific studies of exposure to humans and other mammals. Under the 1990 CAA Amendments, which expanded the control program for HAPs, 189 substances and chemical families were identified as HAPs.

2.2.2 State

2.2.2.1 Criteria Pollutants
The California Clean Air Act was adopted in 1988 and establishes the state’s air quality goals, planning mechanisms, regulatory strategies, and standards of progress. Under the California Clean Air Act, the task of air quality management and regulation has been legislatively granted to CARB, with subsidiary responsibilities assigned to air quality management districts and air pollution control districts at the regional and county levels. CARB is responsible for ensuring implementation of the California Clea n Air Act, responding to the federal CAA, and regulating emissions from motor vehicles and consumer products. Pursuant to the authority granted to it, CARB has established California Ambient Air Quality Standards (CAAQS), which are generally more restrictive than the NAAQS.

The NAAQS and CAAQS are presented in Table 2-1.

Table 2-1. Ambient Air Quality Standards
Pollutant
Averaging
Time
California Standards a National Standards b
Concentration c Primary c,d Secondary c,e
O3 1 hour 0.09 ppm (180 g/m3) — Same as primary
standardf 8 hours 0.070 ppm (137 g/m3) 0.070 ppm
(137 g/m3)f
NO2g 1 hour 0.18 ppm (339 g/m3) 0.100 ppm
(188 g/m3)
Same as primary
standard
Annual
arithmetic
mean

0.030 ppm (57 g/m3) 0.053 ppm
(100 g/m3)
CO 1 hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) None
8 hours 9.0 ppm (10 mg/m3) 9 ppm (10 mg/m3)
SO2h 1 hour 0.25 ppm (655 g/m3) 0.075 ppm
(196 g/m3)
—
3 hours — — 0.5 ppm (1,300 g/m3)
24 hours 0.04 ppm (105 g/m3) 0.14 ppm
(for certain areas)g
—
Annual — 0.030 ppm
(for certain areas)g
—
PM10i 24 hours 50 g/m3 150 g/m3

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Table 2-1. Ambient Air Quality Standards
Pollutant
Averaging
Time
California Standards a National Standards b
Concentration c Primary c,d Secondary c,e
Annual
arithmetic
mean
20 g/m3 — Same as primary
standard
PM2.5i 24 hours — 35 g/m3 Same as primary
standard
Annual
arithmetic
mean
12 g/m3 9.0 g/m3 15.0 g/m3
Leadj, k 30-day
average

1.5 g/m3 — —
Calendar
quarter
— 1.5 g/m3
(for certain areas)k
Same as primary
standard
Rolling 3-
month
average
— 0.15 g/m3
Hydrogen
sulfide
1 hour 0.03 ppm (42 µg/m3) — —
Vinyl
chloridej
24 hours 0.01 ppm (26 µg/m3) — —
Sulfates 24- hours 25 µg/m3 — —
Visibility
reducing
particles
8 hour
(10:00 a.m.
to 6:00
p.m. PST)
Insufficient amount to
produce an extinction
coefficient of 0.23 per
kilometer due to the
number of particles when
the relative humidity is
less than 70%
— —
Source: CARB 2016.

Notes: O3 = ozone; ppm = parts per million by volume; g/m3 = micrograms per cubic meter; NO 2 = nitrogen dioxide; CO = carbon monoxide; mg/m3= milligrams per cubic meter ; SO2 = sulfur dioxide; PM10 = particulate matter with an aerodynamic diameter less than or equal to 10 microns; PM2.5 = particulate matter with an aerodynamic diameter less than or equal to 2.5 microns. a California standards for O3, CO, SO2 (1-hour and 24-hour), NO2, suspended particulate matter (PM10, PM2.5), and visibility-reducing particles are values that are not to be exceeded. All others are not to be equaled or exceeded. CAAQS are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations. b National standards (other than O3, NO2, SO2, particulate matter, and those based on annual averages or annual arithmetic mean) are not to be exceeded more than once per year. The O 3 standard is attained when the fourth highest 8 -hour concentration measured at each site in a year, averaged over 3 years, is equal to or less than the standard. For PM 10, the 24-hour standard is attained when the expected number of days per calendar year with a 24 -hour average concentration above 150 µg/m3 is equal to or less than 1. For PM 2.5, the 24-hour standard is attained when 98% of the daily concentrations, averaged over 3 years, are equal to or less than the standard.
c Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based on a reference temperature of 25°Celsius (°C) and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.
d National Primary Standards: The levels of air quality necessary, with an adequate margin of safety, to protect the public health. e National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
f On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm.

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g To attain the national 1-hour standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 parts per billion (ppb). Note that the national 1-hour standard is in units of ppb. California standards are in units of ppm. To directly compare the national 1-hour standard to the California standards, the units can be converted from ppb to ppm. In this case, the national standard of 100 ppb is identical to 0.100 ppm. h On June 2, 2010, a new 1-hour SO2 standard was established, and the existing 24-hour and annual primary standards were revoked.

To attain the national 1-hour standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until 1 year after an area is designated for the 2010 standard, except that in areas designated nonattainment of the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved. i On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 g/m3 to 12.0 g/m3. The existing national 24-hour PM2.5 standards (primary and secondary) were retained at 35 g/m3, as was the annual secondary standard of 15 μg/m3.

The existing 24-hour PM10 standards (primary and secondary) of 150 g/m3 were also retained. The form of the annual primary and secondary standards is the annual mean averaged over 3 years. j CARB has identified lead and vinyl chloride as TACs with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants. k The national standard for lead was revised on October 15, 2008, to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until 1 year after an area is designated for the 2008 standard, except that in area s designated nonattainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.

Ambient Air Quality Monitoring Data
SDAPCD operates a network of ambient air monitoring stations throughout the County, which measure ambient concentrations of pollutants and determine whether the ambient air quality meets the CAAQS and the NAAQS.

SDAPCD monitors air quality conditions at 10 locations throu ghout the basin. The Chula Vista monitoring station, approximately 5 miles east of the project site represents the closest monitoring station to the project site for concentrations for O3, PM10, PM2.5, and NO2. The closest monitoring station for CO is the El Cajon monitoring station.

The Lexington Elementary School monitoring station is the only station measuring and SO2 in San Diego County.

Ambient concentrations of pollutants from 2020 through 2022 are presented in Table 2-2.

Table 2-2. Local Ambient Air Quality Data
Monitoring
Station Unit
Averaging
Time
Agency/
Method AAQS
Measured
Concentration by Year
Exceedances
by Year
2020 2021 2022 2020 2021 20222
Ozone (O 3)
Chula Vista ppm Maximum
1-hour
concentration
State 0.09 0.106 0.084 0.078 1 0 0
ppm Maximum
8-hour
concentration
State 0.070 0.086 0.067 0.067 4 0 0
Federal 0.070 0.086 0.066 0.066 4 0 0
Nitrogen Dioxide (NO 2)
Chula Vista ppm Maximum
1-hour
concentration
State 0.18 0.045 0.041 0.052 0 0 0
Federal 0.100 0.045 0.041 0.052 0 0 0
ppm Annual
concentration
State 0.030 0.009 0.008 0.009 0 0 0
Federal 0.053 0.008 0.007 0.009 0 0 0
Carbon Monoxide (CO)
El Cajon ppm State 20 3.3 3.0 2.2 0 0 0

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Table 2-2. Local Ambient Air Quality Data
Monitoring
Station Unit
Averaging
Time
Agency/
Method AAQS
Measured
Concentration by Year
Exceedances
by Year
2020 2021 2022 2020 2021 20222
Maximum
1-hour
concentration
Federal 35 1.7 1.8 1.2 0 0 0
ppm Maximum
8-hour
concentration
State 9.0 3.3 3.0 2.2 0 0 0
Federal 9 1.7 1.8 1.2 0 0 0
Sulfur Dioxide (SO 2)
Lexington
Elementary
School
ppm Maximum
1-hour
concentration
Federal 0.075 0.002 0.002 0.001 0 0 0
ppm Maximum
24-hour
concentration
State 0.04 0.000 0.000 0.000 0 0 0
Federal 0.140 0.000 0.000 0.000 0 0 0
ppm Annual
concentration
Federal 0.030 0.000 0.000 0.000 0 0 0
Coarse Particulate Matter (PM 10)a
Chula Vista g/
m3
Maximum
24-hour
concentration
State 50 68 46 38 ND ND ND
Federal 150 68 46 38 0 0 0
g/
m3
Annual
concentration
State 20 24.8 23.9 22.9 ND ND ND
Fine Particulate Matter (PM 2.5 )a
Chula Vista g/
m3
Maximum
24-hour
concentration
Federal 35 46.7 24.9 16.2 2 0 0
g/
m3
Annual
concentration
State 12 10.7 9.5 8.44 ND ND ND
Federal 12.0 10.7 9.5 8.44 2 0 0
Sources: CARB 2023g, SDAPCD 2020, SDAPCD 2021, SDAPCD 2022b Notes: ppm = parts per million; — = not available or applicable; g/m3 = micrograms per cubic meter; ND = insufficient data available to determine the value.

Data taken from CARB iADAM (http://www.arb.ca.gov/adam) and EPA AirData (http://www.epa.gov/airdata/) represent the highest concentrations experienced over a given year.

Exceedances of federal and state standards are only shown for O 3 and particulate matter. Daily exceedances for particulate matter are estimated days because PM 10 and PM 2.5 are not monitored daily. All other criteria pollutants did not exceed federal or state standards during the years shown. There is no federal standard for 1 -hour O3, annual PM 10, or 24-hour SO2, nor is there a state 24 - hour standard for PM2.5.

The Camp Pendleton monitoring station is located at 21441-W B Street, Oceanside, California.

The Rancho Carmel Drive monitoring station is located at 11403 Rancho Carmel Drive, San Diego.

The El Cajon monitoring station is located at 10537 Floyd Smith Drive, El Cajon, California. a Measurements of PM10 and PM2.5 are usually collected every 6 days and every 1 to 3 days, respectively. Number of days exceeding the standards is a mathematical estimate of the number of days concentrations would have been greater than the level of the standard had each day been monitored. The numbers in parentheses are the measured number of samples that exceeded the standard.

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SDAB Attainment Designation
Pursuant to the 1990 CAA Amendments, EPA classifies air basins (or portions thereof) as “attainment” or “nonattainment” for each criteria air pollutant, based on whether the NAAQS have been achieved. Generally, if the recorded concentrations of a pollutant are lower than the standard, the area is classified as “attainment” for that pollutant. If an area exceeds the standard, the area is classified as “nonattainment” for that pollutant. As previously discussed, these standards are set by EPA or CARB for the maximum level of a given air pollutant that can exist in the outdoor air without unacceptable effects on human health or the public welfare. If there is not enough data available to determine whether the standard is exceeded in an area, the area is designa ted as “unclassified” or “unclassifiable.”
The designation of “unclassifiable/attainment” means that the area meets the standard or is expected to be meet the standard despite a lack of monitoring data. Areas that achieve the standards after a nonattainment designation are redesignated as maintenan ce areas and must have approved maintenance plans to ensure continued attainment of the standards. The California Clean Air Act, like its federal counterpart, called for the designation of areas as “attainment” or “nonattainment,” but based on the CAAQS rather than the NAAQS.

Table 2-3 summarizes SDAB’s federal and state attainment designations for each of the criteria pollutants.

Table 2-3. SDAB Attainment Designation
Pollutant Federal Designation State Designation
O3 (8-hour) Nonattainment Nonattainment
O3 (1-hour) Attainmenta Nonattainment
CO Attainment Attainment
PM10 Unclassifiableb Nonattainment
PM2.5 Attainment Nonattainmentc
NO2 Attainment Attainment
SO2 Attainment Attainment
Lead Attainment Attainment
Sulfates (No federal standard) Attainment
Hydrogen sulfide (No federal standard) Unclassified
Visibility-reducing particles (No federal standard) Unclassified Vinyl chloride (No federal standard) No designation
Sources: SDAPCD 2022c, CARB 2023h
Definitions: attainment = meets the standards; nonattainment = does not meet the standards; unclassified or unclassifiable = insufficient data to classify
Notes: SDAB = San Diego; O 3 = ozone; CO = carbon monoxide; PM 10 = coarse particulate matter; PM 2.5 = fine particulate matter; NO2 = nitrogen dioxide; SO2 = sulfur dioxide.
a The federal 1-hour standard of 0.12 parts per million (ppm) was in effect from 1979 through June 15, 2005. The revoked standard is referenced here because it was employed for such a long period and because this benchmark is addressed in SIPs. b At the time of designation, if the available data does not support a designation of attainment or nonattainment, the area is designated as unclassifiable.
c CARB has not reclassified the region to attainment yet due to (1) incomplete data, and (2) the use of non-California Approved Samplers (CAS). While data collected does meet the requirements for designation of attainment with federal PM 2.5 standards, the data completeness requirements for state PM2.5 standards substantially exceed federal requirements and mandates, and have historically not been feasible for most air districts to adhere to given local resources. APCD has begun replacing most regional filter-based PM2.5 monitors as they reach the end of their useful life with continuous PM 2.5 air monitors to ensure collected data meets stringent completeness requirements in the future. APCD anticipates these new monitors will be approved as "CAS" monitors once CARB review the list of approved monitors, which has not been updated since 2013.

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2.2.2.2 Toxic Air Contaminants
The state Air Toxics Program was established in 1983 under AB 1807 (Tanner). The California TAC list identifies more than 200 pollutants, of which carcinogenic and noncarcinogenic toxicity criteria have been established for a subset of these pollutants pursuant to the California Health and Safety Code. In accordance with AB 2728, the state list includes the (federal) HAPs. The Ai r Toxics “Hot Spots” Information and Assessment Act of 1987 (AB 2588) seeks to identify and evaluate risk from air toxics sources; however, AB 2588 does not regulate air toxics emissions.

TAC emissions from individual facilities are quantified and prioritized. “High -priority” facilities are required to perform a health risk assessment (HRA), and if specific thresholds are exceeded, are required to communicate the results to the public in the form of notices and public meetings.

In 2000, CARB approved a comprehensive Diesel Risk Reduction Plan to reduce diesel emissions from both new and existing diesel-fueled vehicles and engines. Additional regulations apply to new trucks and diesel fuel, including the On-Road Heavy Duty Diesel Vehicle (In -Use) Regulation, the On -Road Heavy Duty (New) Vehicle Program, the In-Use Off -Road Diesel Vehicle Regulation, and the New Off -Road Compression-Ignition (Diesel) Engines and Equipment program. All of these regulations and programs have timetables by which manufacturers must comply and existing operators must upgrade their diesel powered equipment. Several Airborne Toxic Control Measures that reduce diesel emissions including In-Use Off-Road Diesel-Fueled Fleets (13 CCR 2449 et seq.) and In-Use On-Road Diesel-Fueled Vehicles (13 CCR 2025).

Idling of Commercial Heavy -Duty Trucks (13 CCR 2485)
In July 2004, CARB adopted an ATCM to control emissions from idling trucks. The ATCM prohibits idling for more than five minutes for all commercial trucks with a gross vehicle weight rating over 10,000 pounds. The ATCM contains an exception that allows trucks to idle while queuing or involved in operational activities.

In-Use Off -Road Diesel -Fueled Fleets (13 CCR 2449 et seq.) In July 2007, CARB adopted an ATCM for in-use off-road diesel vehicles. This regulation requires that specific fleet average requirements are met for NOx emissions and for particulate matter emissions. Where average requirements cannot be met, best available control technology requirements apply. The regulation also includes several recordkeeping and reporting requirements.

In response to AB 8 2X, the regulations were revised in July 2009 (effective December 3, 2009) to allow a partial postponement of the compliance schedule in 2011 and 2012 for existing fleets. On December 17, 2010, CARB adopted additional revisions to further delay the deadlines reflecting reductions in diesel emissions due to the poor economy and overestimates of diesel emissions in California. The revisions delayed the first compliance date until no earlier than January 1, 2014, for large fleets, with fina l compliance by January 1, 2023. The compliance dates for medium fleets were delayed until an initial date of January 1, 2017, and final compliance date of January 1, 2023. The compliance dates for small fleets were delayed until an initial date of January 1, 2019, and final compliance date of January 1, 2028. Correspondingly, the fleet average targets were made more stringent in future compliance years. The revisions a lso accelerated the phaseout of older equipment with newer equipment added to existing large and medium fleets over time, requiring the addition of Tier 2 or higher engines starting on March 1, 2011, with some exceptions: Tier 2 or higher engines on January 1, 2013, without exception; and Tier 3 or higher engines on January 1, 2018 (January 1, 2023, for small fleets).

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On October 28, 2011 (effective December 14, 2011), the Executive Officer approved amendments to the regulation.

The amendments included revisions to the applicability section and additions and revisions to the definition. The initial date for requiring the addition of Tier 2 or higher engines for large and medium fleets, with some exceptions, was revised to January 1, 2012. New provisions also allow for the removal of emission control devices for safety or visibility purposes. The regulation also was amended to combine the particulate matter and NOx fleet average targets under one, instead of two, sections. The amended fleet average targets are based on the fleet’s NOx fleet average, and the previous section regarding particulate matter performance requirements was deleted completely. The best available control technology requirements, if a fleet cannot comply with the fleet average requirements, were restructured and clarified. Other amendments to the regulations included minor administrative changes to the regulatory text.

In-Use On -Road Diesel -Fueled Vehicles (13 CCR 2025)
On December 12, 2008, CARB adopted an ATCM to reduce NOx and particulate matter emissions from most in-use on-road diesel trucks and buses with a gross vehicle weight rating greater than 14,000 pounds. The original ATCM regulation required fleets of on -road trucks to limit their NO x and particulate matter emissions through a combination of exhaust retrofit equipment and new vehicles. The regulation limited particulate matter emissions for most fleets by 2011, and limited NO x emissions for most fleets by 201 3. The regulation did not require any vehicle to be replaced before 2012 and never required all vehicles in a fleet be replaced.

In December 2009, the CARB Governing Board directed staff to evaluate amendments that would provide additional flexibility for fleets adversely affected by the struggling California economy. On December 17, 2010, CARB revised this ATCM to delay its implementation along with limited relaxation of its requirements. Starting on January 1, 2015, lighter trucks with a gross vehicle weight rating of 14,001 to 26,000 pounds with 20-year-old or older engines need to be replaced with newer trucks (2010 model year emissions equivalent as defined in the regulation). Trucks with a gross vehicle weight rating greater than 26,000 pounds with 1995 model year or older engines needed to be replaced as of January 1, 2015. Trucks with 1996 to 2006 model year engines must install a Level 3 (85% control) diesel particulate filter starting on January 1, 2012, to January 1, 2014, depending on the model year, and then must be replaced after eight years. Trucks with 2007 to 2009 model year engines have no requirements until 2023, at which time they must be replaced with 2010 model year emissions -equivalent engines, as defined in the regulation. Trucks with 2010 model year engines would meet the final compliance requirements. The ATCM provides a phase-in option under which a fleet operator would equip a percentage of trucks in the fleet with diesel particulate filters, starting at 30% as of January 1, 2012, with 100% by January 1, 2016. Under each option, delayed compliance is granted to fleet operators who have or will comply with requirements before the required deadlines.

On September 19, 2011 (effective December 14, 2011), the Executive Officer approved amendments to the regulations, including revisions to the compliance schedule for vehicles with a gross vehicle weight rating of 26,000 pounds or less to clarify that all vehicles must be equipped with 2010 model year emissions equivalent engines by 2023. The amendments included revised and additional credits for fleets that have downsized; implement early particulate matter retrofits; incorporate hybrid vehicles, alternat ive-fueled vehicles, and vehicles with heavy -duty pilot ignition engines; and implement early addition of newer vehicles. The amendments included provisions for additional flexibility, such as for low-usage construction trucks, and revisions to previous exemptions, delays, and extensions. Other amendments to the regulations included minor administrative changes to the regulatory text, such as recordkeeping and reporting requirements related to other revisions.

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California Health and Safety Code Section 41700
Section 41700 of the Health and Safety Code states that a person shall not discharge from any source whatsoever quantities of air contaminants or other material that cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or that endanger the comfort, repose, health, or safety of any of those persons or the public, or that cause, or have a natural tendency to cause, injury or damage to business or property. This section also applies to sources of objectionable odors.

2.2.3 Local

2.2.3.1 San Diego Air Pollution Control District
While CARB is responsible for the regulation of mobile emission sources within the state, local air quality management districts and air pollution control districts are responsible for enforcing standards and regulating stationary sources. The project site is located within the SDAB, which is under the jurisdiction of the SDAPCD, and is therefore, subject to the guidelines and regulations of SDAPCD. Federal and State attainment plans adopted by the SDAPCD are summarized below.

Federal Attainment Plans
SDAPCD has prepared the 2020 Plan for Attaining the National Ambient Air Quality Standards for Ozone in San Diego County (2020 Attainment Plan) that demonstrates how the region will further reduce air pollutant emissions to attain the current NAAQS for ozone. The 2020 Attainment Plan was approved by the SDAPCD on October 14, 2020. On November 19, 2020, CARB adopted the 2020 Attainment Plan for attaining the Federal 8-hour 75 ppb and 70 ppb Ozone standards and projects attainment for the standards by 2026 an d 2032, respectively (SDAPCD 2020a). The 2020 Attainment Plan will be submitted to the EPA as a revision to the California State Implementation Plan (SIP) for attaining the ozone NAAQS.

In December 2016, the SDAPCD adopted an update to the Eight-Hour Ozone Attainment Plan for San Diego County (2008 O 3 NAAQS). The 2016 Final Eight -Hour Ozone Attainment Plan for San Diego County indicates that local controls and state programs would allow the region to reach attainment of the federal 8 -hour O3 standard (1997 O3 NAAQS) by 2018 (SDAPCD 2016a). In this plan, SDAPCD relies on the Regional Air Quality Strategy (RAQS) to demonstrate how the region will comply with the federal O3 standard. The RAQS details how the region will manage and reduce O 3 precursors (NO x and VOCs) by identifying measures and regulations intended to reduce these pollutants. The control measures identified in the RAQS generally focus on stationary sources; however, the emissions inventories and projections in the RAQS address all potential sources, including those under the authority of CARB and EPA. Incentive programs for reduction of emissions from heavy -duty diesel vehicles, off -road equipment, and school buses are also established in the RAQS.

Currently, the County is designated as moderate nonattainment for the 2008 O 3 NAAQS and maintenance for the 1997 O3 NAAQS. As documented in the 2016 Final Eight -Hour Ozone Attainment Plan for San Diego County, the County has a likely chance of obtaining attainment due to the transition to low emission cars, stricter new source review rules, and continuing the requireme nt of general conformity for military growth and the San Diego International Airport. SDAPCD will also continue emission control measures inc luding ongoing implementation of existing regulations in ozone precursor reduction to stationary and area -wide sources, subsequent inspections of

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facilities and sources, and the adoption of laws requiring Best Available Retrofit Control Technology for control of emissions (SDAPCD 2016a).

State Attainment Plans
SDAPCD and the San Diego Association of Governments (SANDAG) are responsible for developing and implementing the clean air plan for attainment and maintenance of the ambient air quality standards in the SDAB.

The RAQS for the SDAB was initially adopted in 1991 and is updated every 3 years . The RAQS outlines SDAPCD’s plans and control measures designed to attain the CAAQS for O 3. The RAQS relies on information from CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in the County and the cities in the County, to forecast future emissions and then determine from that the strategies necessary for the reduction of emissions through regulatory controls. The CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of the development of their general plans (SANDAG 2021).

On March 9, 2023, SDAPCD adopted the 2022 Regional Air Quality Strategy (RAQS). The RAQS plan demonstrates how the San Diego region will further reduce air pollution emissions to meet state health-based standards for ground- level O3. The 2022 RAQS guides the SDAPCD in deploying tools, strategies, and resources to continue reducing pollutants that are precursors to ground -level O3, including NOx and VOC. The 2022 RAQS emphasizes O 3 control measures but also identifies complementary measures and strategies that can reduce emissions of Greenhouse Gases (GHGs) and PM. It also includes new analyses exploring O3 and its relationship to public health, mobile sources, under-resourced communities, and GHGs and climate change (SANDAG 2023). Further, the 2022 RAQS identifies strategies to expand SDAPCD regional partnerships, identify more opportunities to engage the public and communities of concern, and integrate environmental justice and equity across all proposed measures and strategies.

Regarding particulate matter emissions reduction efforts, in December 2005, SDAPCD prepared a report titled “Measures to Reduce Particulate Matter in San Diego County” to address implementation of Senate Bill (SB) 656 in San Diego County (SB 656 required additional controls to reduce ambient concentrations of PM 10 and PM2.5) (SDAPCD 2005). In the report, SDAPCD evaluated the implementation of source -control measures that would reduce particulate matter emissions associated with residential wood combustion; various construction activities including earthmoving, demolition, and grading; bulk material storage and handling; carryout and trackout removal and cleanup methods; inactive disturbed land; disturbed open areas; unpaved parking lots/staging areas; unpaved roads; and windblown dust (SDAPCD 2005).

SDAPCD Rules and Regulations
As stated previously, SDAPCD is responsible for planning, implementing, and enforcing federal and state ambient standards in the SDAB. The following rules and regulations apply to all sources in the jurisdiction of SDAPCD:
▪ SDAPCD Regulation II: Rule 10: Permits Required. Requires an Authority to Construct and Permit to Operate for new stationary sources of air pollution (SDAPCD 1996). ▪ SDAPCD Regulation IV: Prohibitions; Rule 50: Visible Emissions. Prohibits any activity causing air contaminant emissions darker than 20% opacity for more than an aggregate of 3 minutes in any consecutive 60-minute time period. In addition, Rule 50 prohibits any diesel pile -driving hammer activity

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causing air contaminant emissions for a period or periods aggregating more than 4 minutes during the driving of a single pile (SDAPCD 1997).
▪ SDAPCD Regulation IV: Prohibitions; Rule 51: Nuisance. Prohibits the discharge, from any source, of such quantities of air contaminants or other materials that cause or have a tendency to cause injury, detriment, nuisance, annoyance to people and/or the public, or damage to any business or property (SDAPCD 1976). ▪ SDAPCD Regulation IV: Prohibitions; Rule 55: Fugitive Dust. Regulates fugitive dust emissions from any commercial construction or demolition activity capable of generating fugitive dust emissions, including active operations, open storage piles, and inactive disturbed areas, as well as track-out and carry-out onto paved roads beyond a project site (SDAPCD 2009).
▪ SDAPCD Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories (SDAPCD 2015a).
▪ SDAPCD Regulation IV: Prohibitions; Rule 67.7: Cutback and Emulsified Asphalts. This rule prohibits manufacturers, distributors, and end users of cutback and emulsified asphalt materials for the paving, construction or maintenance of parking lots, driveways, streets and highways from applying asphalt material or road oils which conta in more than 0.5 percent by volume VOC which evaporate at 260º C (500º F) or less (SDAPCD 1979).

2.2.3.2 San Diego Association of Governments
SANDAG is the regional planning agency for the County and serves as a forum for regional issues relating to transportation, the economy, community development, and the environment. SANDAG serves as the federally designated metropolitan planning organization for the County. With respect to air quality planning and other regional issues, SANDAG has prepared San Diego Forward: The Regional Plan (Regional Plan) for the San Diego region (SANDAG 2015). The Regional Plan combines the big -picture vision for how the region will grow over the next 35 years with an implementation program to help make that vision a reality. The Regional Plan, including its Sustainable Communities Strategy (SCS), is built on an integrated set of public policies, strategies, and investments to maintain, manage, and improve the transportation system so that it meets the diverse needs of the San Diego region through 2050. The Regional Plan was updated in 2021, which was the result of years of planning, data analysis, and community engagement to reimagine the San Diego region with a transformative transportation system, a sustainable pattern of growth and development, and innovative demand and management strategies (SANDAG 2021). The 2021 Regional Plan includes a SCS, which describes coordinated transportation and land use planning that exceeds the state’s target for reducing per capita GHG emissions set by CARB. The state-mandated target is a 19% reduction —compared with 2005—in per capita GHG emissions from cars and light -duty trucks by 2035. The 2021 Regional Plan achieves a 2 0% reduction by then. The 2021 Regional Plan also puts forth a forecasted development pattern that is driven by regional goals for sustainability, mobility, housing affordability, and economic prosperity.

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2.2.3.3 City of Chula Vista
General Plan
The City of Chula Vista General Plan was updated by the City on December 13, 2005, and most recently amended in 2020. The General Plan provides a long-term strategy to address planning issues for the growth and development of the City and is composed of th e following six elements: land use and transportation, economic development, public facilities and services, growth management, environmental, and housing (City of Chula Vista 2005). The project site is located in the Bayfront Planning Area and Harbor District subarea of the General Plan (City of Chula Vista 2005). The policies for improving air quality in the General Plan are as follows:

Land Use and Transportation Element
Policy LUT-23.1: Encourage the use of bicycles and walking as alternatives to driving.

Policy LUT-23.2: Foster the development of a system of inter-connecting bicycle routes throughout the City and region.

Policy LUT-23.5: Provide linkages between bicycle facilities that utilize circulation element alignments and open space corridors.

Policy LUT-23.8: Provide and maintain a safe and efficient system of sidewalks, trails, and pedestrian crossings.

Policy LUT -23.14: Require new development projects to provide internal bikeway systems with connections to the citywide bicycle networks.

Environmental Element
Policy E 6.1: Encourage compact development featuring a mix of uses that locate residential areas within reasonable walking distance to jobs, services, and transit.

Policy E 6.2: Promote and facilitate transit system improvements in order to increase transit use and reduce dependency on the automobile.

Policy E 6.3: Facilitate the use of alternative fuel and low - and zero-emission vehicles and equipment in the community.

Policy E 6.4: Do not site new or re -powered fossil-fueled baseload or peaking -type Electric Generating Facilities and other major toxic emitters within 1,000 feet of sensitive receptors, or site sensitive receptors within 1,000 feet of such facilities.

Policy E 6.5: Ensure Electrical Generating Facilities incorporate cleaner fuel sources and least polluting technologies in order to help transition the City to a less fossil fuel- dependent future, while meeting Chula Vista’s energy demand.

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Policy E 6.6: Explore incentives to promote voluntary air pollutant reductions, including incentives for developers who go above and beyond applicable requirements and for facilities and operations that are not otherwise regulated.

Policy E 6.8: Encourage climate resilient design techniques in new buildings and infrastructure to reduce future risks from climate change-related impacts such as wildfires, extreme heat, and flooding.

Policy E 6.9: Discourage the use of landscaping equipment powered by two-stroke gasoline engines within the City and promote less-polluting alternatives to their use.

Policy E 6.10: The siting of new sensitive receivers within 500 feet of highways resulting from development or redevelopment projects shall require the preparation of a health risk assessment as part of the CEQA review of the project. Attendant health risks identified in the Health Risk Assessment (HRA) shall be feasibly mitigated to the maximum extent practicable, in accordance with CEQA, in order to help ensure that applicable federal and state standards are not exceeded.

Policy E 6.11: Develop strategies to minimize CO hot spots that address all modes of transportation.

Policy E 6.12: Promote clean fuel sources that help reduce the exposure of sensitive uses to pollutants.

Policy E 6.13: Encourage programs and infrastructure to increase the availability and usage of energy-efficient vehicles, such as hybrid electric vehicles, electric vehicles, or those that run on alternative fuels.

Policy E 6.14: Transition the City fleet to 100% “clean” vehicles by integrating hybrid and alternative fuel vehicles as current municipal fleet vehicles are replaced.

Policy E 6.15: Site industries: and other stationary emitters in a way that minimizes the potential impacts of poor air quality on homes, schools, hospitals, and other land uses where people congregate, and disadvantaged populations.

Policy E 6.B.1: Protect and develop shade tree cover along streets and within parking lots as a priority, particularly in new developments or tree-deficient areas.

Policy E 6.B.2: Preferentially plant female street trees to reduce pollen, especially in the most populated areas.

Policy E 6.B.3: Prioritize natural filtration, as opposed to impermeable hardscaping, within new development projects, along roadways, and adjacent to stream and river banks.

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Policy E 6.B.4: Update the building code to support best practices in “green building” design, construction, and operations.

Policy E 6.B.5: Provide fast-track permitting for projects that implement “green building” design and construction.

Policy E 6.B.6: Encourage or require all new building construction to incorporate green roofs and encourage conversions of existing roof space to green roofs to reduce heat island effect.

Chula Vista Bayfront Specific Plan
Chapter 19.81 of the CVMC defines the scope and purpose of the Bayfront Specific Plan. This chapter of the CVMC is intended to implement the Chula Vista General Plan and the Chula Vista Local Coastal Program (LCP) Land Use Plan (LUP) and their goals, objectives, and policies. Chapter 19.84 of the CVMC provides for the classification of land use and the regulation of development by land use and zoning parcel. The project is zoned as Industrial in the Bayfront Specific Plan. Chapter 19.85 of the CVMC outlines the development criteria for the Bayfront Specific Plan.

Chula Vista Bayfront Local Coastal Program Land Use Plan The Chula Vista Bayfront LCP Amendment Bayfront Specific Plan was adopted in 2012 and amended in 2017. It governs the development of 722 acres of the City’s bayfront. The LCP provides a detailed plan for the orderly growth, development, redevelopment, and conservation of the City jurisdictional parcels located within the Chula Vista Bayfront coastal area. Each coastal city and county’s LCP is required to be pursuant to the California Coastal Act and approved by the California Coastal Commission. This LCP i s consistent with the City General Plan and represents a step toward systematic implementation of the General Plan in the bayfront. The LUP provides land use and development policies to ensure that development within the bayfront will be consistent with the provisions of the California Coastal Act. The project site is within the Harbor District subarea, described in the LCP. The LUP outlines objectives and policies as the standard review for coastal development permits (City of Chula Vista 2012).

2.3 Significance Criteria and Methodology

2.3.1 Thresholds of Significance
The significance criteria used to evaluate the Project impacts to air quality is based on the recommendations provided in Appendix G of the CEQA Guidelines. For the purposes of this air quality analysis, a significant impact would occur if the Project would (14 CCR 15000 et seq.):

1. Conflict with or obstruct implementation of the applicable air quality plan.

2. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard.

3. Expose sensitive receptors to substantial pollutant concentrations.

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4. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) indicates that, where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to determine whether the Project would have a significant impact on air quality.

2.3.2 South Coast Air Quality Management District
The City of Chula Vista has chosen to use emissions-based thresholds from the SCAQMD to address the significance of air quality impacts resulting from projects subject to CEQA environmental review. A project would result in a substantial contribution to an existing air quality violation of the National Ambient Air Quality Standards (NAAQS) or California Ambient Air Quality Standards (CAAQS) for O 3, which is a nonattainment pollutant, if the project’s construction emissions would exceed SCAQMD’s VOC or NO x significance thresholds shown in Table 2-4. These emission - based thresholds for O 3 precursors are intended to serve as a surrogate for an “ozone significance threshold” (i.e., the potential for adverse O 3 impacts to occur) because O 3 itself is not emitted directly, and the effects of an individual project’s emissions of O 3 precursors (VOC and NO x) on O3 levels in ambient air cannot be determined through air quality models or other quantitative methods.

Table 2-4. SCAQMD Air Quality Significance Thresholds
Criteria Pollutants Mass Daily Thresholds
Pollutant Construction (Pounds per Day) Operation (Pounds per Day) VOCs 75 55
NOx 100 55
CO 550 550
SOx 150 150
PM10 150 150
PM2.5 55 55
Leada 3 3
Source: SCAQMD, March 2023
Notes: SCAQMD = South Coast Air Quality Management District; VOCs = volatile organic compounds; NO x = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = coarse particulate matter; PM2.5 = fine particulate matter.

GHG emissions thresholds for industrial proposed projects, as added in the March 2015 revision to the SCAQMD Air Quality Significance Thresholds, were not include included in Table 2-4 as they will be addressed within the GHG emissions analysis and not the air quality study.
a The phaseout of leaded gasoline started in 1976. Since gasoline no longer contains lead, the project is not anticipated to re sult in impacts related to lead; therefore, it is not discussed in this analysis.

2.3.3 Approach and Methodology
The California Emissions Estimator Model (CalEEMod) Version 2022 .1 was used to estimate emissions from construction and operation of the project (CAPCOA 2022) as well as existing emissions. CalEEMod is a statewide computer model developed in cooperation with air districts throughout the state to quantify criteria air pollutant and GHG emissions associated with construction activities and operation of a variety of land use projects, such as residential, commercial, and industrial facilities. CalEEMod input parameters, including the land use type used to

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represent the project and its size, construction schedule, and anticipated use of construction equipment, were based on information provided by the project applicant and default model assumptions if project specifics were unavailable. Table 2-5 provides a summary of the land use inputs included in the CalEEMod modeling for construction and operation of the project.

Table 2-5. CalEEMod Land Use Development Summary for the Proposed Project Planning
Area Project Component
CalEEMod Land
Use Type
Land
Use
Amount
(Size)
Land Use
Size
Metric
Building Square
Footage
Land Use
Acreage
A Industrial/Business
Park (w/commercial)
Industrial Park 198 ksf 198,000 9.29
Parking Parking Lot 2 Ac 0
Trucks associated
with business park
uses
User Defined
Commercial
1 User
Defined
0 0
B-1 Industrial/Business
Park (w/commercial)
Industrial Park 470 ksf 470,000 26.13
Parking Parking Lot 793 sp 0
Miscellaneous
surface areas
(walkways,
landscaped slopes,
loading/unloading
areas, etc.)
Other Asphalt
Surfaces

8.2 ac 0
Trucks associated
with business park
uses
User Defined
Industrial
1 User
Defined
0 0
B-2 Resort Hotel Hotel 175 rm 254,100 9.36
Quality Restaurant Quality
Restaurant
36 Ksf 36,000
Parking Parking Lot 2 ac 0
Notes: ksf = 1,000 square feet; ac = acre, rm = rooms, sp = parking space As noted previously, the project site is being redeveloped. Planning Area A will not have any construction emissions associated but will re-purpose the existing building through a rezoning. Table 2-6 provides a summary of the existing land uses on the project site and the CalEEMod parameters used to estimate existing emissions.

Table 2-6. CalEEMod Land Use Development Summary for the Existing Site Planning
Area Existing Uses
CalEEMod
Land Use
Type
Land
Use
Amount
(Size)
Land Use
Size
Metric
Building
Square
Footage
Land Use
Acreage
A Warehousing Warehouse 231.174 ksf 231,174 9.29
B-1 Manufacturing/Asse
mbly
Manufacturing 601.225 ksf 601,225 26.13

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Table 2-6. CalEEMod Land Use Development Summary for the Existing Site Planning
Area Existing Uses
CalEEMod
Land Use
Type
Land
Use
Amount
(Size)
Land Use
Size
Metric
Building
Square
Footage
Land Use
Acreage
B-2 Manufacturing/Asse
mbly
Manufacturing 165,612 ksf 165,612 9.36
Notes: Manufacturing uses on Planning Areas B-1 and B-2 continued as recently as 2020.

2.3.3.1 Construction Emissions
Criteria air pollutant emissions associated with construction of the project were estimated using CalEEMod for the following emission sources: operation of off-road construction equipment, fugitive dust, VOC off-gassing from paving and architectural coating, on-road hauling, and vendor (material delivery) trucks, and worker vehicles. Construction scenario assumptions, including phasing, equipment mix, and vehicle trips, were based on CalEEMod default values with an estimated construction start date in August 2024 and buildout completed in September 2029. As noted previously, Planning Area A is already built-out and is only requiring rezoning. Accordingly, no construction emissions for Planning Area A have been estimated and included in the analysis.

Table 2-7 provides a summary of the project construction schedule. The construction schedule used in the analysis represents a “worst -case” analysis scenario since emission factors for construction equipment decrease as the analysis year increases due to improvements in technology and more stringent regulatory requirements. The duration of construction activity and associated equipment represents a reasonable approximation of the expected construction fleet as required pursuant to CEQA guidelines.

Table 2-7. Project Construction Schedule
Planning
Area Construction Task Start Date End Date Workdays B-1 Site Preparation 8/5/2024 8/30/2024 20
Grading 9/2/2024 11/1/2024 45
Building Construction 11/4/2024 7/10/2026 440
Paving 7/13/2026 8/28/2026 35
Architectural Coating 8/31/2026 10/16/2026 35
B-2 Grading 8/1/2028 8/28/2028 20
Building Construction 8/29/2028 7/16/2029 230
Paving 7/17/2029 8/13/2029 20
Architectural Coating 8/14/2029 9/10/2029 20
Source: CalEEMod, Appendix A
CalEEMod default trip length values were used for the distances for worker (11.97 miles), vendor truck (7.63 miles), and haul truck trips (20 miles). In addition, it was assumed that one onsite truck would be present to water exposed and unpaved roads on the project site. The water truck was assumed to water surfaces and unpaved roads up to two times per day with up to 0.25 mile per onsite trip. It was also assumed that heavy construction equipment would be operating at the site for approximately 5 days per week (22 days per month) during project construction.

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Construction scenario assumptions, including phasing, vehicle trips, and equipment mix, used for estimating project-generated construction emissions are shown in Table 2-8.

Table 2-8. Construction Scenario Assumptions
PA Task
Daily One -Way Vehicle Trips Equipment
Workers Vendors
Haul
Trucks
Onsite
Trucks
Equipment Type
(HP) Quantity
Daily
Usage
Hours
B-1 Site
Preparation
18 2 0 4 Rubber Tired
Dozers (367)
3 8
Tractors/Loaders/
Backhoes (84)
4 8
Grading 20 2 140 4 Graders (148) 1 8
Excavators (36) 2 8
Tractors/Loaders
Backhoes (84)
2 8
Scrapers (423) 2 8
Rubber Tired
Dozers (367)
1 8
Building
Construction
198 78 0 0 Forklifts (82) 3 8
Generator Sets
(14)
1 8
Cranes (367) 1 7
Welders (46) 1 8
Tractors/Loaders
Backhoes (84)
3 7
Paving 16 2 0 0 Pavers (81) 2 8
Paving Equipment
(89)
2 8
Rollers (36) 2 8
Architectural
Coating
40 2 0 0 Air Compressors
(37)
1 6
B-2 Grading 16 6 0 4 Graders (148) 1 8
Excavators (36) 1 8
Tractors/Loaders
Backhoes (84)
3 8
Rubber Tired
Dozers (367)
1 8
Building
Construction
292 150 0 0 Forklifts (82) 3 8
Generator Sets
(14)
1 8
Cranes (367) 1 7
Welders (46) 1 8
Tractors/Loaders
Backhoes (84)
3 7

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Table 2-8. Construction Scenario Assumptions
PA Task
Daily One -Way Vehicle Trips Equipment
Workers Vendors
Haul
Trucks
Onsite
Trucks
Equipment Type
(HP) Quantity
Daily
Usage
Hours
Paving 16 2 0 0 Pavers (81) 2 8
Paving Equipment
(89)
2 8
Rollers (36) 2 8
Architectural
Coating
20 2 0 0 Air compressors
(37)
1 6
Source: CalEEMod, Appendix A
Notes: PA = Planning Area; HP = horsepower
Construction of the project would be subject to SDAPCD Rule 55 – Fugitive Dust Control. This rule requires that construction of project components include steps to restrict visible emissions of fugitive dust beyond the property line (SDAPCD 2009b). Compliance with Rule 55 would limit fugitive dust (PM10 and PM2.5) that may be generated during grading and construction activities. To reflect implementation of proposed dust control strategies, it was assumed that the exposed areas would be watered two times per day (61% reduction in PM10 and PM2.5).

2.3.3.2 Operational Emissions
Project-generated operational criteria air pollutant emissions were estimated for area sources, energy sources, and mobile sources using CalEEMod. The first full year of operations was assumed to be 20 30, consistent with the anticipated end of construction. This provides a conservative estimate as emissions would decrease as the buildout year increase because of improved vehicle technologies and more stringent regulations. The calculation of area, energy, and mobile air pollutant emissions is explained below.

Area Sources
CalEEMod was used to estimate operational emissions from area sources, including emissions from consumer product use, architectural coatings, and landscape maintenance equipment. Emissions associated with natural gas usage in space heating and water heatin g are calculated in the building energy use module of CalEEMod, as described in the following text.

Consumer products are chemically formulated products used by household and institutional consumers, including detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products. Other paint products, furniture coatings, or architectural coatings are not considered consumer products (CAPCOA 2022). Consumer product VOC emissions are estimated in CalEEMod based on the floor area of nonresidential buildings and on the default factor of pounds of VOC per building square foot per day. For parking lot land uses, CalEEMod estimates VOC emissions associated with use of parking surface degreasers based on a square footage of parking s urface area and pounds of VOC per square foot per day.

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VOC off-gassing emissions result from evaporation of solvents contained in surface coatings such as in paints and primers using during building maintenance. CalEEMod calculates the VOC evaporative emissions from application of nonresidential surface coatings based on the VOC emission factor, the building square footage, the assumed fraction of surface area, and the reapplication rate. The VOC emission factor is based on the VOC content of the surface coatings, and SDAPCD Rule 67.0.1 (Architectural Coatings) governs the VOC (or ROG) content for interior and exterior coatings, which is 50 grams per liter VOC for the interiors and exteriors of the buildings. The CalEEMod default of 100 grams per liter was assumed for parking area coatings. The model default reapplication rate of 10% of area per year is assumed. Consistent with CalEEMod defaults, it is assumed that the nonresidential surface area for painting equals 2.0 times the floor square footage, with 75% assumed for interior coating and 25% assumed for exte rior surface coating (CAPCOA 2022). For the parking lot, the architectural coating area is assumed to be 6% of the total square footage, consistent with the supporting CalEEMod studies provided as an appendix to the CalEEMod User’s Guide (CAPCOA 2022).

Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chain saws, and hedge trimmers. The emissions associated from landscape equipment use are estimated based on CalEEMod default values for emission factors (grams per square foot of nonresidential building space per day) and number of summer days (when landscape maintenance would generally be performed) and winter days. For San Diego County, the average annual “summer” days are estimated to 365 days; however, it is assumed that landscaping equipment would li kely only operate during the week (not weekends), so operational days were assumed to be 180 days per year in CalEEMod (CAPCOA 2022).

Energy Sources
As represented in CalEEMod, energy sources include emissions associated with natural gas usage. Electricity use would contribute indirectly to criteria air pollutant emissions; however, the emissions from electricity use are only quantified for GHGs in Cal EEMod, since criteria pollutant emissions occur at the site of the power plant, which is typically off site.

The energy use from nonresidential land uses (natural gas usage per square foot per year) is calculated in CalEEMod based on the California Commercial End -Use Survey database and the energy use from residential land uses is calculated in CalEEMod based on the Residential Appliance Saturation Study. The current version of CalEEMod assumes compliance with the 2019 Title 24 Building Energy Efficiency Standards (CAPCOA 2022). However, construction of the proposed Project would be required to comply with the 2022 Title 24 Standards at a minimum and depending on timing of full project buildout, may be required to comply with future, more stringent energy codes.

The project may include some refrigeration uses, as such the industrial/business park with commercial land uses were modeled based on the estimated energy use from a refrigerated warehouse to provide a conservative estimate of potential future energy use as non-refrigerated industrial buildings would require less energy.

Mobile Sources
The project would generate criteria pollutant emissions from mobile sources (vehicular traffic) because of the passenger vehicle trips associated with the industrial/business park with commercial, hotel, and restaurant uses (i.e., employees, customers, deliveries).

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Emissions from the mobile sources during operation of the project were estimated in CalEEMod . Mizuta Traffic Consulting. provided daily trips for vehicles. Because there may be additional truck traffic associated with the proposed industrial/business park with commercial land use for Planning Area B -1, Mizuta Traffic provided a breakdown of truck trips by axle -type based on the South Coast Air Quality Management District’s (SCAQMD) Warehouse Truck Trip Study Data Results and Usage (SCAQMD 2014). Planning Area A includes up to 198,000 square feet of industrial/business park with commercial uses , similar to the land uses included in Planning Area B-1, as such the same passenger vehicle versus truck percent breakdown and truck breakdown by axle was applied to Planning Area A. Planning Area B-2 would include potential hotel and restaurant uses, which would not result in higher truck trips than the CalEEMod default fleet mix, as such the default fleet mix was used for Planning Area B-2.

Table 2-9 provides a summary of the project trip generation and vehicle fleet breakdown for the Planning Areas.

Table 2-9. Project Trip Generation
Planning Area Vehicle Type Average Daily Trips Notes A Passenger Cars 2,900 Includes LDA, LDT1, LDT2, MDV
Trucks 268 2-axle (16.7%); 3-axle (20.7%);
4+axle (62.6%)
All 3,168
B-1 Passenger Cars 6,884 Includes LDA, LDT1, LDT2, MDV
Trucks 636 2-axle (16.7%); 3-axle (20.7%);
4+axle (62.6%)
All 7,520
B-2 All 5,000
All All 15,688
Source: Mizuta Traffic Consulting, 2023
Notes: LDA = Light Duty Auto, LDT1 = Light -Duty Trucks (0-3,750 pounds), LDT2 = Light Duty Trucks ( 3,75-5,750 pounds), MDV = Medium-Duty Trucks (5,751-8,500 pounds), 2-axle trucks (5,801 – 14,000 pounds), 3-axle trucks (14,001-33,000 pounds), 4+axle trucks (33,001-60,000 pounds)
The commercial passenger vehicle trip lengths were assumed to be CalEEMod default trip lengths of 9.93 miles home-work trips, 6.68 miles for work-other trips, and 6.12 miles for other-other trips. A home-work trip represents trips traveling in either direction between home and work locations . A work -other trip is made by an employee traveling in either direction between a work location and all other locations that are not home. An other -other trip is made by a person traveling in either direction between land uses that do not involve home or work locations (e.g. school, park, gym).

The light-duty, medium-heavy-duty, and heavy -duty truck trip lengths were based on weighted trip length using EMFAC data on regional trip distances and the SCAQMD 2014 Survey The weighted trip length was estimated to be

15.59 miles. Additionally, truck trips were assumed to be 100% primary trips. Vehicle emissions occur during startup, operation (running), and idling, as well as from evaporative losses when the engines are resting. The emissions factors for trucks and passenger vehicles were determined using CalEEMod.

Project truck idling would be limited to 5 minutes in accordance with CARB’s adopted Airborne Toxic Control Measure; however, for modeling purposes, it was conservatively assumed that the trucks would idle for a total of 15 minutes: 5 minutes at the entrance, 5 minutes at the loading dock, and 5 minutes at the exit of the Project site.

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Vehicle emissions occur during startup, operation (running), and idling, as well as from evaporative losses when the engines are resting. The emissions factors for motor vehicles were determined using CalEEMod defaults.

The Local Mobility Analysis prepared by Mizuta Traffic Consulting included trip generation from existing uses on the project site that would be replaced by the project. Table 2-10 provides a summary of the existing vehicle trips.

Table 2-10. Existing Project Site Trip Generation
Planning Area Vehicle Type Average Daily Trips
A-1 All 1,156
B-1 All 2,405
B-2 All 663
Total All 4,224
Notes: Manufacturing uses on Planning Areas B-1 and B-2 continued as recently as 2020. Trip generation for existing uses passed on Rohr Wohl Local Mobility Analysis prepared by Mizuta Traffic Consulting (July 2023).

Off -Road Equipment
Planning Areas A and B -1 may include some industrial uses such as warehousing. I t is common for industrial buildings to require cargo handling equipment to move empty containers and empty chassis to and from the various pieces of cargo handling equipment that receive and distribute containers. The most common type of cargo handling equipment are forklifts, pallet jacks, and yard trucks, which are designed for moving cargo containers.

Yard trucks are also known as yard goats, utility tractors, hustlers, yard hostlers, and yard tractors. The SCAQMD published a summary of operational survey results from 34 operating high-cube warehouses (SCAQMD 2014). The SCAQMD survey reported an average of 0.12 forklifts/pallet jacks per 1,000 square feet of building area, which was applied to the project . This estimate is for total forklifts and pallet jacks. Pallet jacks are small as they are primarily used to lift small loads in tight quarters (and are electric or manual); therefore, assuming all pieces of equipment are forklifts is conservative. The SCAQMD study also identified 3.6 yard trucks per 1 million square feet.

For this project, based on the maximum square footage of building space permitted by the project, on-site modeled operational equipment includes a total of 56 forklifts for Planning Area B-1 and 24 forklifts for Planning Area A for a total of 80 forklifts. In addition, one yard truck each was assumed for Planning Area A and B -1. Of the total 80 forklifts, approximately half were assumed to be electric with the remaining modeled as diesel with Tier 4 compliant engines. The yard trucks were assumed to be diesel. See Appendix A for detail calculations.

Stationary Sources
A stationary source is defined as any building, structure, facility, or installation which emits or may emit any pollutants.

Planning Areas A and B -1 may include refrigerated uses; accordingly, back-up generators may be required during emergency outages. One 500-hp emergency back-up generator was included for each building in Planning Areas with potential refrigerated uses (A and B-1). Emergency backup diesel generators are considered stationary sources and subject to permitting from the SDAPCD. The modeling assumed the generators would be consistent with statewide average emission factors for a 2030 operational year and would operate up to 50 hours annually.

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2.3.3.3 Health Risk Assessments
Construction Health Risk Assessment
An HRA was performed to evaluate potential health risk associated with construction of the project. The following discussion summarizes the dispersion modeling and HRA methodology; supporting construction HRA documentation, including detailed assumptions, is presented in Appendix B.

For risk assessment purposes, PM 10 in diesel exhaust is considered DPM, originating mainly from off -road equipment operating at a defined location for a given length of time at a given distance from sensitive receptors.

Less-intensive, more-dispersed emissions result from on road vehicle e xhaust (e.g., heavy-duty diesel trucks). For the construction HRA, the CalEEMod scenario for the project was adjusted to reduce diesel truck one -way trip distances to 1, 320 feet (0. 25 miles) to estimate emissions from truck pass -by at proximate receptors. The air dispersion modeling methodology was based on S DAPCD’s accepted modeling practices ( SDAPCD 2022a). Air dispersion modeling was performed using the EPA’s American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) Version 22112 modeling system (computer software) with the Lakes Environmental Software implementation/user interface, AERMOD View Version 11.2.0. The HRA followed the Office of Environmental Health Hazard Assessment (OEHHA) 2015 guidelines (OEHHA 2015) and S DAPCD guidance to calculate the health risk impacts at all proximate receptors as further discussed below. The dispersion modeling included the use of standard regulatory default options. AERMOD parameters were selected consistent with the SDAPCD and EPA guidance and identified as representative of the Project site and Project activities. Principal parameters of this modeling are presented in Table 2-11.

Table 2-11. American Meteorological Society/Environmental Protection Agency Regulatory Model Principal Parameters
Parameter Details
Meteorological Data The SDAPCD was consulted to obtain the most representative meteorological data set for the project site. The SDAPCD provided meteorological data for the Chula Vista meteorological station, which was located at 84 East J Street in Chula Vista, approximately 2.5 miles east of the project site. The latest three-year data set from the Chula Vista station was for the 2010-2012 years.

Urban versus Rural
Option
Rural dispersion option was selected due to the close proximity to the coastline. The rural dispersion option is the modeling default for San Diego County (SDAPCD 2022a).

Terrain
Characteristics
Digital elevation model files were imported into AERMOD so that complex terrain features were evaluated as appropriate for the site. This accounts for complex terrain within 2 kilometers of the site. The National Elevation Dataset (NED) dataset with resolution of 1 arc-second was used. The AERMAP terrain preprocessor, which can process U.S. Geological Survey (USGS) Digital Elevation Model (DEM) data and data from the NED, is also used to generate the terrain elevations for the receptor locations.

The AERMAP program generates an output file that contains the receptor pathway data for AERMOD.

Source Release
Characterizations
Air dispersion modeling of DPM emissions was conducted assuming the off-road equipment would operate in accordance with the modeling scenario estimated in CalEEMod (Appendix A). The construction equipment and on-site truck travel DPM emissions were modeled as a line of adjacent volume sources across the project site

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Table 2-11. American Meteorological Society/Environmental Protection Agency Regulatory Model Principal Parameters
Parameter Details
to represent project construction with a release height of 5 meters, plume height of 10 meters, and plume width of 10 meters (SCAQMD 2008).

Source: See Appendix B.

Notes: AERMOD = American Meteorological Society/Environmental Protection Agency Regulatory Model; SDAPCD = San Diego Air Pollution Control District; SCAQMD = South Coast Air Quality Management District; SJVAPCD = San Joaquin Valley Air Pollution Control District; EPA = U.S. Environmental Protection Agency.

Regarding receptors, the construction scenario used a 2-kilometer by 2-kilometer Cartesian receptor grid with less than 50-meter spacing to establish the impact area and evaluate locations of maximum health risk impact. Discrete receptors were placed over residential receptors in closest proximity to the site.

The health risk calculations were performed using the Hotspots Analysis and Reporting Program Version 2 (HARP2) Air Dispersion and Risk Tool (ADMRT, Version 22118). AERMOD was run with all sources emitting unit emissions (1 gram per second) to obtain the necessary input values for HARP2. The line of volume sources was partitioned evenly based on the 1 gram per second emission rate. The ground-level concentration plot files were then used to estimate the long-term cancer health risk to an individual, and the non-cancer chronic health indices. There is no reference exposure level for acute health impacts from DPM, and, thus, acute risk was not evaluated.

Operational Heath Risk Assessment
CARB’s Air Quality and Land Use Handbook: A Community Health Perspective encourages consideration of the health impacts of distribution centers that accommodate more than 100 trucks per day on sensitive receptors sited within 1,000 feet from the source in the land use decision-making process (CARB 2005). For the operational health risk, the operation year 2030 was assumed consistent with completion of project construction. Emissions from the operation of the project include truck trips, truck idling emissio ns, potential Truck Refrigeration Units (TRU), diesel-fueled cargo handling equipment, and potential emergency backup generators at each of the industrial business park with commercial uses . For risk assessment purposes, PM 10 in diesel exhaust is considered DPM, originating mainly from trucks traveling on site and off site , TRUs, and truck idling located at the loading docks.

Truck and cargo handling equipment emissions were based on CalEEMod. Emission factors representing the vehicle and equipment mix and emissions for 20 30 were used to estimate emissions associated with operation of the project. Truck idling would be limited to 5 minutes in accordance with CARB’s adopted Airborne Toxic Control Measure; however, truck idling was conservatively assumed to idle for 15 minutes. 3 Therefore, the analysis conservatively overestimates DPM emissions from idling. All deliveries would occur Monday through Sunday.

Conservatively, 2030 CalEEMod and a constant 2030 emission factor data set was used for the entire duration of the analysis (i.e., 30 years). Use of the 2030 emission factors would overstate potential impacts since this approach does not include reductions in emissions due to fleet turnover or cleaner technology with lower emissions. The truck travel DPM emissions were calculated by applying the exhaust PM10 emission factor from CalEEMod and the total truck trip number over the length of the distance travel ed. In addition, the on -site truck idling exhaust emissions

3 Although the project is required to comply with CARB’s idling limit of 5 minutes, on -site idling emissions was estimated for 15 minutes of truck idling, which would consider on-site idling while the trucks are waiting to pull up to the loading dock, idling at the loading dock, and idling during check-in and check-out.

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were calculated by applying the idle exhaust PM 10 emission factor from EMFAC2021 and total truck trip over the total idling time (i.e., 15 minutes).

The dispersion modeling was performed using AERMOD (Version 22112). The truck traffic was modeled as a line of adjacent volume sources including the following truck routes: north bound to and from I-5 Bay Boulevard; south bound to and from I-5 via Bay Boulevard; and east bound to and from I-5 and I-805 via H Street and Dispersion modeling receptors were places at proximate sensitive receptors along the truck routes. Emission sources were modeled as line volume sources with the exception of the emergency generators, which were modeled as point sources.

As previously described, health effects from carcinogenic air toxics are usually described in terms of cancer risk.

The SCAQMD recommends a carcinogenic (cancer) risk threshold of 10 in one million. Some TACs increase noncancer health risk due to long-term (chronic) exposures. A hazard index less than one (1.0) means that adverse health effects are not expected. Within this analysis, noncarcinogenic exposures of less than 1.0 are considered less than significant. The exhaust from diesel engines is a complex mixture of gases, vapors, and particles, many of which are known human carcinogens. DPM has established cancer risk factors and relative exposure values for long-term chronic health hazard impacts. No short -term, acute relative exposure values are establi shed and regulated and are therefore not addressed in this assessment.

Dudek evaluated the project’s potential cancer and noncancer health impacts using exposure periods appropriate to evaluate long-term emission increases (third trimester of pregnancy to 30 years). Emissions dispersion of DPM was modeled using AERMOD, then cancer risk and noncancer health impacts subsequently using the CARB HARP2 (ADMRT, Version 2 2118). The health risk results were then compared to SCAQMD thresholds to assess project significance. Principal parameters of this modeling are presented in Table 2-12.

Table 2-12. Operational Health Risk Assessment American Meteorological Society/ U.S. Environmental Protection Agency Regulatory Model Operational Principal Parameters
Parameter Details
Meteorological
Data
The SDAPCD was consulted to obtain the most representative meteorological data set for the project site. The SDAPCD provided meteorological data for the Chula Vista meteorological station, which was located at 84 East J Street in Chula Vista, approximately

2.5 miles east of the project site. The latest three-year data set from the Chula Vista station was for the 2010-2012 years.

Urban versus
Rural Option
Rural dispersion option was selected due to the close proximity to the coastline. The rural dispersion option is the modeling default for San Diego County (SDAPCD 2022a).

Geological Survey (USGS) Digital Elevation Model (DEM) data and data from the NED, is also used to generate the terrain elevations for the receptor locations. The AERMAP program generates an output file that contains the receptor pathway data for AERMOD.

Emission Sources
and Release
Parameters
Air dispersion modeling of off-site and on-site truck travel, TRUs, and truck idling were conducted using emissions generated using EMFAC2021 and CalEEMod. Forklift and yard truck emissions were estimated using CalEEMod. Stationary source equipment estimates

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Source Release
Characterizations
With the exception of the emergency generators, which were modeled as point sources, the remaining sources were all modeled as line volume sources. Release parameters were based on guidance from SCAQMD, EPA, SDAPCD, and the San Joaquin Valley Air Pollution Control District. (EPA 2022b; SCAQMD 2008; SJVAPCD 2022, SDAPCD 2022a).

Source: See Appendix B.

Note: AERMOD = American Meteorological Society/Environmental Protection Agency Regulatory Model; SDAPCD = San Diego Air Pollution Control District; SCAQMD = South Coast Air Quality Management District; SJVAPCD = San Joaquin Valley Air Pollution Control District; EPA = U.S. Environmental Protection Agency.

Regarding receptors, a Cartesian receptor grid with less than 50-meter spacing was utilized to establish the impact area and evaluate locations of maximum health risk impact. Dispersion modeling receptors were places at proximate sensitive receptors along the truck routes.

Cancer risk is defined as the increase in probability (chance) of an individual developing cancer due to exposure to a carcinogenic compound, typically expressed as the increased chances in one million. Maximum Individual Cancer Risk is the estimated proba bility of a maximally exposed individual potentially contracting cancer as a result of exposure to TACs over a period of 30 years for residential receptor locations. The HRA assumes exposure would start in the third trimester of pregnancy through 30 years for all residential sensitive receptor locations. The exposure pathway for DPM is inhalation only.

2.4 Impact Analysis

2.4.1 Would the Project conflict with or obstruct implementation of the applicable air quality plan?
Analysis
As stated in Section 2.2.3, Local, SDAPCD and SANDAG are responsible for developing and implementing the clean air plans for attainment and maintenance of the NAAQS and CAAQS in the SDAB; specifically, the SIP and RAQS. 4 The federal O 3 maintenance plan, which is part of the SIP, was last updated in 2020. The SIP includes a demonstration that current strategies and tactics will maintain acceptable air quality in the SDAB based on the NAAQS. The RAQS was initially adopted in 1991 and is u pdated every 3 years (most recently in 20 22). The RAQS outlines SDAPCD’s plans and control measures designed to attain the CAAQS for O 3. The SIP and RAQS rely on information from CARB and SANDAG, including mobile and area source emissions, as well as information regarding projected growth in San Diego County and the cities in the County, to project future emissions and then determine from that the strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source

4 For this discussion, the relevant federal air quality plan is the O3 maintenance plan (SDAPCD 2016b). The RAQS is the applicable plan for purposes of state air quality planning. Both plans reflect growth projections in the SDAB.

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emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by San Diego County and the cities in the County as part of the development of their general plans. The 2022 RAQS continues to build upon previous progress to reduce ground-level ozone, but also complements regional actions addressing greenhouse gases and climate change.

If a project proposes development that is greater than that anticipated in the local plan and SANDAG’s growth projections, the project might conflict with the SIP and RAQS and may contribute to a potentially significant cumulative impact on air quality.

Existing Population and Housing Setting
The approximately 44.78-acre project site was used for agriculture until 1941, when it was developed as the Rohr Aircraft Facility, which employed thousands of Chula Vista residents for more than 60 years. The site is currently developed with two main indu strial buildings and several smaller outbuildings. One of the buildings on site is approximately 282,004 square feet and was used for research and development, tooling, and warehousing and distribution of aftermarket products until early 2021. The other two larger buildings on site have a combined square footage of 733,977. There are also 11 smaller outbuildings totaling 32,860 square feet. These buildings were used for manufacturing, warehouse, and distribution operations until approximately 2020.

Population
SANDAG estimates future population, housing, land use, and economic growth throughout San Diego County and in individual cities, including the City of Chula Vista. On May 25, 2018, the Series 14 2050 Regional Growth Forecast was accepted by the SANDAG Board of Directors for planning purposes (SANDAG 2018). This forecast serves as the foundation for San Diego Forward: The Regional Plan and other planning documents across the region. SANDAG projects the region’s population will grow by 437,000 people between 2016 and 2050. This forecast is consistent with previous expectations although future growth rates have been reduced due to increased domestic migration out of the region. The growth in population will drive job growth and housing demand within the region , adding nearly 440,000 jobs and more than 280,000 housing units by 2050 (SANDAG 2021b).

The City of Chula Vista is anticipated to have a population of 284,835 by 2025, which comprises approximately

8.2% of the population in the San Diego region. As shown in Table 2-13, the SANDAG Series 1 4 Regional Growth Forecast for 2050 predicts population, housing, and employment for the San Diego Region, as well as for the City of Chula Vista, for 2016 through 2050.

Table 2-13. San Diego Region vs. City of Chula Vista Population, Housing, and Employment Forecast
Planning Area
Year
201 6 Year 202 5 Year 2035 Year 2050 Increase
Percent
Change
Population
City of Chula
Vista
265,357 284,835 288,141 323,469 58,112 21.9%
San Diego
Regiona
3,309,510 3,470,848 3,620,348 3,746,073 436,563 13.2%

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Table 2-13. San Diego Region vs. City of Chula Vista Population, Housing, and Employment Forecast
Planning Area
Year
201 6 Year 202 5 Year 2035 Year 2050 Increase
Percent
Change
Housing
City of Chula
Vista
82,794 91,635 95,621 109,474 26,680 32.2%
San Diego
Region
1,190,555 1,288,216 1,409,866 1,471,299 280,744 23.6%
Employment
City of Chula
Vista
74,078 83,027 98,701 116,185 42,107 56.8%
San Diego
Region
1,646,419 1,761,747 1,921,475 2,086,318 439,899 26.7%
Sources: SANDAG 2021b.

Note:
a The San Diego Region includes both incorporated and unincorporated areas of the region.

Housing
According to SANDAG’s 2050 Regional Growth Forecast, the City is expected to gain 58,112 new residents and 26,680 new households between 2016 and 2050 (SANDAG 2021b). Furthermore, SANDAG, through its Regional Housing Needs Allocation, estimated that the City would experience a demand for 11,105 housing units through the 2021 and 2029 planning period, of which 4,527 new housing units would be for affordable to low- and very- low-income households and 6,578 new housing units would be for moderate - and above -moderate-income households. The City of Chula Vista anticipates that much of the new construction will result from building out the master-planned communities in the East Planning Area, such as Otay Ranch, infill development, and mixed -use development (SANDAG 2021c).

To encourage the development of adequate housing to meet the needs of low and moderate -income households and to further geographic and community balance, the City’s adopted Housing Element provides for a Balanced Communities Policy, requiring 10% affordabl e housing for low - and moderate -income households within developments of 50 or more residential units. 5,6 This inclusionary housing program will serve as only one component of the City ’s overall housing strategy and will complement other affordable housing efforts, including preservation of existing assisted housing, development of new assisted housing with public subsidies, first -time homebuyer assistance, and rehabilitation loans for l ow-income homeowners. The City find s that such an inclusionary housing policy is beneficial to increasing the supply of housing affordable to households of lower and moderate incomes and to meet the City’s regional share of housing needs given the demographics of the community

5 Low-income households are households of persons who claim primary residency at the same unit with combined incomes that are greater than 50%, but not more than 80% of the Area Median Income for the San Diego area based on household size as determined annually by the U.S. Department of Housing and Urban Development. Household size is calculated by the number of persons residing at the same unit as their primary residence. 6 Moderate-income households are households of persons who claim primary residency at the same unit with combined incomes between 80% to 120% of the Area Median Income for the San Diego area based on household size as determined annually by the U.S. Department of Housing and Urban Development. Household size is calculated by the number of persons residing at the same unit as their primary residence.

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and its needs, past housing production performance, and the existing opportunities and constraints as detailed in its Housing Element (City of Chula Vista 2012a).

The City’s new General Plan Housing Element was adopted on July 13, 2021, and amended on September 13, 2022. The Housing Element establishes clear goals and objectives to inform future housing decisions for the 2021 to 2029 housing cycle. As part of the Housing Element update, the City must demonstrate there is sufficient capacity to accommodate the number of housing units identified in the Regional Housing Needs Assessment (RHNA). As such, the RHNA allocation was released by SANDAG in November 2019 and helped inform preparation of the 2021 Housing Element. Tables 2-14 and 2-15 show the past performance RHNA from the 5 th Cycle (2013–2020) and the current RHNA allocation for the 6th Cycle (2021–2029), respectively (City of Chula Vista 2020b).

Table 2-14. Past Performance RHNA 5th Cycle (2013–2020) Income Level
RHNA Allocation by
Level
Total Units to Date
(all years)
Total Remaining RHNA
(2019 –2021)
Very Low 3,209 91 3,118
Low 2,439 557 1,882
Moderate 2,257 328 1,929
Above Moderate 4,956 7,614 2,658
Total 12,861 8,590 4,271
Source: City of Chula Vista 2020.

Note: RHNA = Regional Housing Needs Assessment.

Table 2-15. RHNA Allocation for the 6th Cycle (2021–2029) Income Category RHNA Allocation by Level Percentage of Total Units Very Low 2,750 25%
Low 1,777 16%
Moderate 1,911 17%
Above Moderate 4,667 42%
Total 11,105 100%
Source: City of Chula Vista 2020.

Note: RHNA = Regional Housing Needs Assessment.

The General Plan incorporates a Housing Element (adopted July 13, 2021) that identifies strategies to expand housing opportunities for the City’s various economic segments. Under the Housing Element, the provision of new housing opportunities within mixed use areas and at higher density levels, particularly transit focus area s, is encouraged. A primary issue of the Housing Element is the shortfall of housing, particularly affordable housing, in the City and the region. The 2021 Housing Element of the General Plan provides implementation mechanisms for effectively addressing Ch ula Vista’s housing needs throughout the 2021 –2029 planning period. Existing programs and policies of the 2013 –2020 Housing Element are evaluated in the 2021 Housing Element to identify revisions and the current needs of Chula Vista’s population (City of Chula Vista 20 21c).

Goals and policies listed in the General Plan encourage the provision of a wide range of housing choices by location, type of unit, and price level, in particular the establishment of permanent affordable housing for low and moderate- income households. Gen eral Plan goals and polic ies ensure the availability of housing opportunities to persons

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regardless of race, color, ancestry, national origin, religion, sex, disability, marital status, familial status, source of income, or sexual orientation and support efforts to increase homeownership rates to build individual wealth (City of Chula Vista 2021c).

Employment
Employment and job growth have an influence on housing needs in the region and in the City. SANDAG’s forecast of job growth for the City and the San Diego region from 2016 to 2050 estimates that the City’s job growth is projected to be faster than growth projected in the San Diego region. Job growth in the City is expected to increase by 56.8%, while job growth in the San Diego region is projected to be 26.7% between 2016 and 2050.

As shown in Table 2-16 according to the U.S. Census Bureau, the City’s labor force 16 years and older in 2021 was 128,931 people, with the leading industries being education, health care, and social services; retail trade; and professional, scientific, management, and administration services.

Table 2-16. Employment by Industry in City of Chula Vista Labor Force Status Persons
Employed Population 16 Years and Over 128,931
Agriculture 470
Construction 8,761
Manufacturing 10,526
Wholesale Trade 3,459
Retail Trade 14,338
Transportation and Warehousing 8,246
Information 1,354
Finance, Real Estate 6,965
Professional, Scientific, Management, and Administration 14,288 Educational, Health Care, and Social Services 32,149
Arts, Accommodations, and Food Services 10,6301
Public Administration 11,462
Other Services 6,301
Source: U.S. Census Bureau 2021.

Planning Areas A, B-1, and B-2 of the project site are located within the Chula Vista Bayfront Local Coastal Program and currently lie within the General Industrial (I) Zoning and Industrial (I) General Plan land use designations. The proposed project would amend the General Plan to change the land use designation on the project site from Industrial (I) to Rohr Wohl Specific Plan. The zoning of the area would be amended to allow for a flexible combination of light industrial, office, commercial and visitor-oriented uses.

As described above, the SANDAG Series 14 estimates population in Chula Vista would grow from 284,835 in 2025 to 288,141 in 2035; and employment would increase from 83,027 jobs in 2025 to 98,701 jobs in 2035 (SANDAG 2018). Based on the anticipated increase in jobs of 15,674 in the City, the proposed project would account for

6.4% of that increase. Construction jobs associated with the proposed project would be temporary and would not require permanent relocation into the City. Once operational, the estimated 1,000 jobs that would result from the

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proposed project would result in some amount of population growth within the City due to new employment opportunities, however, this population growth would not be considered to be greater than what is planned by the General Plan and SANDAG growth estimates because the proposed project would restore what was previously a major job center for the City of Chula Vista.

The proposed project would rejuvenate an underutilized property creating employment opportunities and restoring the approximate 1,000 jobs that existed on site. Furthermore, the Growth Management Element of the City of Chula Vista’s General Plan outlines the measures necessary to direct and coordinate growth and development in ways to improve the quality of life for current and future residents of Chula Vista. The proposed pro ject fosters a development pattern that promotes orderly growth by developing on a site with existing industrial uses . As such, the project would not contribute to substantial population and employment growth and associated VMT that was not anticipated for the project site in the existing General Plan and SANDAG Growth Estimates . The anticipated growth in employment and population and consequently VMT would be within regional growth forecasts.

Implementation of the proposed project would not conflict with or obstruct the implementation of the RAQS and/or applicable portions of the SIP, and the impact would be less than significant.

Level of Significance Before Mitigation
Based on the analysis above, implementation of the project would not result in development more than that anticipated in local plans or increases in population/housing growth beyond those contemplated by SANDAG. As such, vehicle trip generation and planned development for the project are anticipated in the SIP and RAQS. The project would be consistent at a regional level with the underlying growth forecasts in the RAQS. Impacts would be less than significant.

Mitigation Measures
No mitigation is required.

Level of Significance After Mitigation
Impacts would be less than significant.

2.4.2 Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Air pollution is largely a cumulative impact. The nonattainment status of regional pollutants is a result of past and present development, and SDAPCD develops and implements plans for future attainment of the NAAQS and CAAQS.

Based on these considerations, project-level thresholds of significance for criteria pollutants are relevant in the determination of whether the Project’s individual emissions would have a cumulatively significant impact on air quality.

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Construction
Construction of the proposed project would result in the temporary addition of pollutants to the local airshed caused by on-site sources (i.e., off-road construction equipment, soil disturbance, and VOC off-gassing) and off-site sources (vendor and haul truck trips, and worker vehicle trips). Construction emissions can vary substantially day to day, depending on the level of activity, the specific type of operation, and for dust, the prevailing weather conditions.

Criteria air pollutant emissions associated with construction activities were quantified using CalEEMod. Default values provided by the program were used where detailed project information was not available. A detailed depiction of the construction schedule —including information regarding phasing, equipment used during each phase, haul trucks, vendor trucks, and worker vehicles—is included in Section 2.3.3.1 above.

Development of the project would generate air pollutant emissions from entrained dust, off-road equipment, vehicle emissions, asphalt pavement application, and architectural coatings. As described previously, fugitive dust would be limited through compliance with SDAPCD Rule 55, which requires the restriction of visible emissions of fugitive dust beyond the property line. This measure is incorporated into the project as PDF-AQ-1.

Table 2-17 shows the estimated maximum unmitigated daily construction emissions associated with the construction phases of the Project. Complete details of the emissions calculations are provided in Appendix A, Air Quality Emissions CalEEMod Output Files.

Table 2-17. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions - Unmitigated
Year
VOC NO x CO SO x PM 10 PM 2.5
Pounds Per Day
Summer
2024 3.82 48.33 36.16 0.13 21.80 4.12
2025 2.00 13.65 23.42 0.04 2.63 0.63
2026 85.21 12.87 22.69 0.04 2.58 0.63
2028 2.11 14.06 26.31 0.05 8.20 1.47
2029 87.42 13.32 25.58 0.05 3.76 0.94
Winter
2024 3.81 48.80 36.10 0.13 14.10 2.53
2025 1.99 13.81 22.31 0.04 2.63 0.63
2026 85.21 13.04 21.70 0.04 2.58 0.63
2028 2.09 14.23 24.96 0.05 3.78 0.97
2029 2.02 13.59 24.24 0.05 3.76 0.94
Maximum Daily
Emissions

87.42 48.80 36.16 0.13 21.80 4.12
SCAQMD Threshold 75 100 550 150 150 55
Threshold Exceeded? Yes No No No No No
Notes: VOC = volatile organic compound; NO x = oxides of nitrogen; CO = carbon monoxide; SO x = sulfur oxides; PM 10 = coarse particulate matter; PM2.5 = fine particulate matter;

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See unmitigated results in Rohr-Wohl Specific Plan – Mitigated PM/VOC Detailed Report.pdf in Appendix A for complete results. The values shown are the maximum summer or winter daily emissions results from CalEEMod.

As shown in Table 2-17, daily construction emissions for the project would not exceed the SCAQMD’s significance thresholds for VOC, primarily from painting emissions. Therefore, the project would have a potentially significant impact related to emissions of criteria air pollutant emissions during construction and mitigation is required to reduce the impact. Mitigation Measure AQ-1 (MM AQ-1) would require the use of super compliant VOC paint, which is 10 mg of VOC per liter.

Table 2-18 shows the mitigated emissions from construction with the incorporation of MM AQ -1. As shown, the mitigated construction emissions from the project would fall below the SCAQMD’s thresholds of significance, resulting in a less than significant impact with mitigation incorporated.

Table 2-18. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions - Mitigated
Year
VOC NO x CO SO x PM 10 PM 2.5
Pounds Per Day
Summer
2024 0.95 48.33 36.16 0.13 8.30 4.12
2025 1.21 13.65 23.42 0.04 2.28 0.63
2026 21.23 12.87 22.69 0.04 2.27 0.63
2028 1.45 14.06 26.31 0.05 3.55 1.47
2029 21.70 13.32 25.58 0.05 3.55 0.94
Winter
2024 1.23 48.80 36.10 0.13 7.08 2.53
2025 1.19 13.81 22.31 0.04 2.28 0.63
2026 21.23 13.04 21.70 0.04 2.27 0.63
2028 1.43 14.23 24.96 0.05 3.55 0.97
2029 1.39 13.59 24.24 0.05 3.55 0.94
Maximum Daily
Emissions

21.70 48.80 36.16 0.13 8.30 4.12
SCAQMD Threshold 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Notes: VOC = volatile organic compound; NO x = oxides of nitrogen; CO = carbon monoxide; SO x = sulfur oxides; PM 10 = coarse particulate matter; PM2.5 = fine particulate matter;
See mitigated results in Rohr-Wohl Specific Plan – Mitigated PM/VOC Detailed Report.pdf in Appendix A for complete results.

The values shown are the maximum summer or winter daily emissions results from CalEEMod and include fugitive dust mitigation pursuant to PDF AQ-1.)
Operations
Operation of the proposed project would generate VOC, NO x, CO, SO x, PM 10, and PM 2.5 emissions from mobile sources (vehicle trips), area sources (consumer products, landscape maintenance equipment), and energy sources.

Criteria air pollutant emissions associated with long-term operations were quantified using CalEEMod. In addition, the emissions from existing uses on the project site were also estimated using CalEEMod.

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Table 2-19 presents the unmitigated maximum daily emissions associated with the operation of the project in 2030 after all phases of construction have been completed. The existing emissions are also shown as well as the net project emissions. Complete details of the emissions calculations are provided in Appendix A, Air Quality Emissions CalEEMod Output Files . Emissions represent maximum of summer and winter. “Summer” emissions are representative of the conditions that may occur during the O3 season (May 1 to October 31), and “winter” emissions are representative of the conditions that may occur during the balance of the year (November 1 to April 30).

Table 2-19. Estimated Maximum Daily Operational Criteria Air Pollutant Emissions Source
VOC NO x CO SO x PM 10 PM 2.5
Pounds per Day
Project Summer
Mobile 35.45 62.33 297.18 1.15 91.47 24.02
Area 28.72 0.35 41.67 0.00 0.07 0.06
Energy 0.54 9.85 8.28 0.06 0.75 0.75
Offroad (forklifts, yard
trucks)

2.99 25.58 46.28 0.08 0.88 0.81
Stationary (Emergency
Generators)

4.10 11.47 10.46 0.02 0.60 0.06
Subtotal 71.81 109.57 403.87 1.30 93.78 25.69
Existing Summer
Mobile 14.38 10.66 100.95 0.22 17.66 4.61
Area 29.89 0.37 43.37 0.00 0.08 0.06
Energy 0.51 9.22 7.75 0.06 0.70 0.70
Offroad (forklifts, yard
trucks)

4.90 45.62 49.12 0.08 2.6 2.39
Stationary (Emergency
Generators)
0 0 0 0 0 0
Subtotal 49.67 65.88 201.20 0.35 21.04 7.75
Net Summer
Mobile 21.07 51.67 196.23 0.93 73.81 19.41
Area -1.17 -0.02 -1.70 0.00 -0.01 0.00
Energy 0.03 0.63 0.53 0.00 0.05 0.05
Offroad (forklifts, yard
trucks)
-1.91 -20.04 -2.84 0.00 -1.72 -1.58
Stationary (Emergency
Generators)

4.10 11.47 10.46 0.02 0.60 0.06
Total 22.13 43.70 202.67 0.96 72.73 17.95
SCAQMD Threshold 55 55 550 150 150 55
Threshold exceeded? No No No No No No
Project Winter
Mobile 35.02 66.38 278.55 1.11 91.47 24.02
Area 21.87 0.00 0.00 0.00 0.00 0.00
Energy 0.54 9.85 8.28 0.06 0.75 0.75

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Table 2-19. Estimated Maximum Daily Operational Criteria Air Pollutant Emissions Source
VOC NO x CO SO x PM 10 PM 2.5
Pounds per Day
Offroad (forklifts, yard
trucks)

2.99 25.58 46.28 0.08 0.88 0.81
Stationary (Emergency
Generators)

4.10 11.47 10.46 0.02 0.60 0.06
Subtotal 64.53 113.28 343.57 1.26 93.70 25.64
Existing Winter
Mobile 13.97 11.71 95.96 0.21 17.66 4.61
Area 22.77 0.00 0.00 0.00 0.00 0.00
Energy 0.51 9.22 7.75 0.06 0.70 0.70
Offroad (forklifts, yard
trucks)

4.90 45.62 49.12 0.08 2.60 2.39
Stationary (Emergency
Generators)

0.00 0.00 0.00 0.00 0.00 0.00
Subtotal 42.15 66.56 152.83 0.34 20.96 7.70
Net Winter
Mobile 21.05 54.67 182.59 0.90 73.81 19.41
Area -0.90 0.00 0.00 0.00 0.00 0.00
Energy 0.03 0.63 0.53 0.00 0.05 0.05
Offroad (forklifts, yard
trucks)
-1.91 -20.04 -2.84 0.00 -1.72 -1.58
Stationary (Emergency
Generators)

4.10 11.47 10.46 0.02 0.60 0.06
Total 22.37 46.72 190.74 0.93 72.74 17.94
SCAQMD Threshold 55 55 550 150 150 55
Threshold exceeded? No No No No No No
Notes: VOC = volatile organic compound; NO x = oxides of nitrogen; CO = carbon monoxide; SO x = sulfur oxides; PM 10 = coarse particulate matter; PM2.5 = fine particulate matter; <0.01 = reported value is less than 0.01.

See Rohr-Wohl Specific Plan Regional – Unmitigated Operational Detailed Report 10/11/2023.pdf, and Existing Land Uses Rohr Wohl Detailed Report.pdf in Appendix A for complete results.

Note that emissions shown would be less with the incorporation of MM-AQ-4 and MM-AQ-5.

As shown in Table 2-19, the net daily operational emissions for the project would not exceed the SCAQMD’s thresholds for any criteria air pollutant. Therefore, the project would result in a less than significant impact related to emissions of criteria air pollutant emissions during operation.

Level of Significance Before Mitigation
In analyzing cumulative impacts from a project, the analysis must specifically evaluate the project’s contribution to the cumulative increase in pollutants for which the SDAB is designated as nonattainment for the CAAQS and NAAQS.

If the project does not exceed thresholds and is determined to have less than significant project-specific impacts, it may still contribute to a significant cumulative impact on air quality if the emissions from the project components, in combination with the emissions from other proposed or reasonably foreseeable future projects, are in excess of

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established thresholds. However, the project would only be considered to have a significant cumulative impact if its contribution accounts for a significant proportion of the cumulative total emissions (i.e., it represents a “cumulatively considerable contribution” to the cumulative air quality impact).

Additionally, for the SDAB, the RAQS serves as the long-term regional air quality planning document for the purpose of assessing cumulative operational emissions within the basin to ensure the SDAB continues to make progress toward NAAQS and CAAQS attainment status. As such, cumulative projects located in the San Diego region would have the potential to result in a cumulative impact to air quality if, in combination, they would conflict with or obstruct implementation of the RAQS. Similarly, individual projects that are inconsistent with the regional planning documents on which the RAQS is based would have the potential to result in cumulative impacts if they represent development beyond regional projections.

The SDAB has been designated as a federal nonattainment area for O 3 and a state nonattainment area for O 3, PM10, and PM2.5. PM10 and PM2.5 emissions associated with construction generally result in near-field impacts. The nonattainment status is the result of cumulative emissions from all sources of these air pollutants and their precursors within the SDAB. As shown in Table 2-17, the unmitigated construction emissions would exceed the SCAQMD’s VOC thresholds of significance and result in a potentially significant impact. As shown in Table 2-19, net operational emissions generated by the project would not result in emissions that exceed significance thresholds for any criteria air pollutant. Long-term operational air quality impacts would be less than significant.

Mitigation Measures
MM-AQ-1: Low VOC Paints. The project shall use super-compliant VOC paint (defined as less than 10 g/L of VOC) during project construction for architectural coatings.

Level of Significance After Mitigation
With the incorporation of MM-AQ-1, the project construction emissions of VOC are reduced to a less than significant level. As shown in Table 2-18, the mitigated emissions of all criteria pollutants from the project’s construction would be below the significance levels. Construction would be short term, temporary in nature, and activities would be considered typical of a non-residential project. Once construction is completed, construction-related emissions would cease. Regarding long-term cumulative operational emissions in relation to consistency with local air quality plans, the SIP and RAQS serve as the primary air quality planning documents for the state and SDAB, respectively. The SIP and RAQS rely on SANDAG growth projections based on population, vehicle trends, and land use plans developed by the cities and by the County as part of the development of their general plans. Therefore, projects that propose development that is consistent with the growth anticipated by local plans would be consistent with the SIP and RAQS and would not be considered to result in cumulatively considerable impacts from operational emissions. As discussed in Section 2.4.1 of this report, the Project is consistent with the SANDAG growth projections. Thus, it would be consistent at a regional level with the underlying growth forecasts in the SIP and RAQS.

As a result, the project would not result in a cumulatively considerable contribution to regional O 3 concentrations or other criteria pollutant emissions. Cumulative impacts for construction and operation would be less than significant after mitigation for the project.

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2.4.3 Would the Project expose sensitive receptors to substantial pollutant concentrations?
Carbon Monoxide Hotspots
A CO hot spot is a localized concentration of CO that is above the state or national 1-hour or 8-hour ambient air standards for the pollutant. Projects that do not generate CO concentrations in excess of the health -based CAAQS would not contribute a significant level of CO such that localized air quality and human health would be substantially degraded.

Ambient CO levels are monitored at the Lexington Elementary School air monitoring station in El Cajon, approximately 14 miles northeast of the project site and represents ambient CO in the project area. Ambient CO levels monitored at this representative monitoring station indicate that the highest recorded 1-hour concentration of CO is 2.2 ppm (the State standard is 20 ppm) and highest 8-hour concentration is 1.2 ppm (the State standard is 9 ppm) during the past 3 years of available data (EPA 2022a). As discussed above, the highest CO concentrations typically occur during peak traffic hours, so CO impacts calculated under peak traffic conditions represent a worst- case analysis.

The City does not have guidance regarding CO hotspots and has in the past referenced the County of San Diego’s CO hotspot screening guidance (County of San Diego 2007). Per guidance, any project that would place receptors within 500 feet of a signalized intersection operating at or below LOS E (peak -hour trips exceeding 3,000 trips) must conduct a “hotspot” analysis for CO. Likewise, projects that will cause road intersections to operate at or below a level of service (LOS) E (i.e., with intersection peak -hour trips exceeding 3,000) will also have to conduct a CO “hotspot” analysis.

Since the last update of the County’s guidance (2007), the County has evaluated the potential for the growth anticipated under its General Plan Update to result in CO “hot spots” throughout the County (County of San Diego 2009). To do this, the County reviewed the CO “hot spot” analysis conducted by the South Coast Air Quality Management District (SCAQMD) for their request to the USEPA for redesignation as a CO attainment area (SCAQMD 2003). In SCAQMD’s analysis, they modeled the four most congested intersections identified in their basin (South Coast Air Basin [SCAB]), which included the following:
▪ Long Beach Boulevard and Imperial Highway – proximity to the Lynwood monitoring station, which consistently records the highest 8-hour CO concentrations in the SCAB each year. ▪ Wilshire Boulevard and Veteran Avenue – the most congested intersection in Los Angeles County, with an average daily traffic volume of 100,000 vehicles/day.
▪ Highland Avenue and Sunset Boulevard – one of the most congested intersections in the City of Los Angeles.
▪ Century Boulevard and La Cienega Boulevard – one of the most congested intersections in the City of Los Angeles.

The SCAQMD’s analysis found that these intersections had an average 7.7 ppm 1-hour CO concentrations predicted by the models, which is only 38.5% of the 1 -hour CO CAAQS of 20 ppm. Therefore, even the most congested intersections in SCAQMD’s air basin would not experience a CO “hot spot”.

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The air quality monitoring station closest to the most congested intersection in Los Angeles County (Wilshire Boulevard/Veteran Avenue) is the VA Hospital, West Los Angeles Station (Site ID 060370113) located at Wilshire Boulevard and Sawtelle Boulevard, approximately 0.5 miles to the southwest. Ambient CO levels monitored at this representative monitoring station are outlined in Table 2-20 for the original analysis year (2002), and for the most recent year of available data (2023). As shown, there is noticeable improvement in background levels of CO since the SCAQMD’s regional hotspot analysis.

Table 2-20. Ambient Carbon Monoxide Concentrations for SCAQMD’s Most Congested Intersection
Year
CO Concentration (ppm)
Maximum 1 -hour Maximum 8 -hour
2002 4.3 2.7
2023 1.2 1.1
Source: EPA 2022a
The City of Chula Vista General Plan EIR evaluated the most impacted intersections as a result of General Plan buildout and predicted a maximum 1 -hour concentration of 6. 7 ppm (the California standard is 20 ppm and the Federal standard is 35 ppm) and a maximum 8-hour concentration of 5.4 ppm (the California and Federal standards are 9 ppm).

The Local Mobility Analysis prepared for the project by Mizuta Traffic Consulting evaluated Level of Service performance for the project and in all scenarios, traffic volumes were well below the 100,000 vehicles per day.

In addition, the CO “hot spot” analysis performed by the SCAQMD included emissions for 1997 and 2002. Both running exhaust emission factors and idling emission factors predicted by the EMFAC model decreased from 1997 through 2002 as outlined in Table 2-21 below. This decrease in CO emission factors is indicative of a phase-out of older vehicles and increasingly strict emissions standards implemented by CARB. Emission factors for San Diego County from the EMFAC2007 Model, which were used in the General Plan Update analysis, indicated that running exhaust emissions of CO would be less than 6.708 g CO per mile in 2010. Continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion means that the potential for CO hotspots in the SDAB is likely to decrease.

Table 2-21. Carbon Monoxide Emission Factors Predicted by the EMFAC Model Year
CO Emission Factors (grams CO/mile)
Running Exhaust Idling Exhaust
1997 13.13 2.43
2002 7.98 1.30
Source: South Coast Air Quality Management District 2003 The County of San Diego concluded in its General Plan Update (2011) that because the most congested intersections in San Diego are less congested than those from the SCAB, and because emissions of CO would be lower than those used in the SCAQMD analysis, CO concentrations would be lower within San Diego County, and no CO “hot spots” are anticipated as was concluded in the SCAQMD analysis.

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Given that proposed development will not result in traffic that exceeds traffic volumes considered in the County’s General Plan Update analysis, coupled with the considerably low level of CO concentrations in the project area (see Table 2), and continued improvements in vehicle emissions, the project is not anticipated to result in CO “hot spots”.

Consequently, implementation of the project would not result in CO concentrations in excess of the health protective CAAQS or NAAQS, and as such, would not expose sensitive receptors to significant pollutant concentrations or health effects. Therefore, impacts related to sensitive receptor exposure to substantial CO concentrations would be less than significant, and no mitigation measures are required.

Toxic Air Contaminants
As discussed in 2.3.3.3, a construction HRA was performed to estimate the Maximum Individual Cancer Risk and the Chronic Hazard Index for existing sensitive receptors (existing residences) as a result of project construction.

Results of the construction HRA are presented in Table 2-22.

Table 2-22. Construction Health Risk Assessment Results – Unmitigated Impact Parameter Units
Project
Impact
CEQA
Threshold
Level of
Significance
Maximum Individual Cancer Risk –
Residential
Per Million 21.78 10 Potentially
Significant
Chronic Hazard Index – Residential Index Value 0.01 1.0 Less than Significant.

Source: Appendix B.

Note: CEQA = California Environmental Quality Act.

As shown in Table 2-22, the DPM emissions from construction of the project would result in a Maximum Individual Cancer Risk of 20 in 1 million and a Chronic Hazard Index of 0.011. The Chronic Hazard Index would be below the

1.0 significance threshold; however, the project would exceed the cancer risk threshold of 10 in a million and would be potentially significant without mitigation.

Mitigation Measure AQ-2 (MM-AQ-2) would require the use of electric infrastructure and specific electric equipment during construction and Mitigation Measure AQ -3 (MM-AQ-3) would require that all diesel-fueled off -road construction equipment greater than 75 horsepower be zero -emissions or equipped with CARB Tier 4 Final compliant engines (as set forth in Section 2423 of Title 13 of the California Code of Regulations, and Part 89 of Title 40 of the Code of Federal Regulations). Table 2-23 summarizes the results of the HRA for project construction after mitigation.

Table 2-23. Construction Health Risk Assessment Results - Mitigated Impact Parameter Units
Impact
Level
CEQA
Threshold
Level of
Significance
Maximum Individual Cancer Risk –
Residential
Per Million 5.60 10 Less than
Significant.

Chronic Hazard Index – Residential Index Value 0.0029 1.0 Less than Significant.

Source: Appendix B
Notes: CEQA = California Environmental Quality Act

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As shown in Table 2-23, mitigated project construction activities would result in a Maximum Individual Cancer Risk of 5.60 in 1 million at the maximally exposed residence , which is less than the significance threshold of 10 in 1 million. Mitigated project construction would result in a Chronic Hazard Index of 0.0029, which is below the 1.0 significance threshold. The project construction health risk impacts would be less than significant after mitigation.

Operational Health Risk
As discussed in 2.3.3.3, an operational HRA was performed to estimate the Maximum Individual Cancer Risk and the Chronic Hazard Index for existing sensitive receptors (existing residences) as a result of project operations.

Results of the operational HRA are presented in Table 2-24.

Table 2-24. Operational Health Risk Assessment Results – Unmitigated Impact Parameter Units
Project
Impact
CEQA
Threshold
Level of
Significance
Maximum Individual Cancer Risk –
Residential
Per Million 205.74 10 Potentially
Significant
Chronic Hazard Index – Residential Index Value 0.055 1.0 Less than Significant.

Source: Appendix B.

Note: CEQA = California Environmental Quality Act.

As shown in Table 2-24, the DPM emissions from operation of the project would result in a Maximum Individual Cancer Risk of 205 in 1 million and a Chronic Hazard Index of 0.055. The Chronic Hazard Index would be below the

1.0 significance threshold; however, the project would exceed the cancer risk threshold of 10 in a million and would be potentially significant without mitigation.

Mitigation measures are required to minimize operational-related air quality impacts. Mitigation Measure AQ-4 (MM- AQ-4) would require all off-road cargo handling equipment to be zero-emission. Mitigation Measure AQ-5 (MM-AQ- 5) would require any emergency generator used on the site to be Tier 4 Final. Mitigation Measure AQ-6 (MM-AQ-6) would reduce emissions from diesel -fueled trucks. Table 2-25 summarizes the mitigated operational health risk levels associated with the project.

Table 2-25. Operational Health Risk Assessment Results - Mitigated Impact Parameter Units
Impact
Level
CEQA
Threshold
Level of
Significance
Maximum Individual Cancer Risk –
Residential
Per Million 7.65 10 Less than
Significant.

Chronic Hazard Index – Residential Index Value 0.002 1.0 Less than Significant.

Source: Appendix B.

Notes: CEQA = California Environmental Quality Act
As shown in Table 2-25, mitigated project operations would result in a Maximum Individual Cancer Risk of 7.65 in 1 million at the maximally exposed residence , which is less than the significance threshold of 10 in 1 m illion.

Mitigated project operations would result in a Chronic Hazard Index of 0.002, which is below the 1.0 significance threshold. The project operational health risk impacts would be less-than-significant after mitigation.

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Health Effects of Criteria Air Pollutants
Construction and operation of the project would not result in emissions that exceed SDAPCD’s emission thresholds for any criteria air pollutants. The SDAPCD thresholds are based on the SDAB complying with the NAAQS and CAAQS which are protective of public health; therefore, no adverse effects to human health would result from the project.

The following provides a general discussion of criteria air pollutants and their health effects.

Regarding VOCs, some VOCs would be associated with motor vehicles and construction equipment, while others are associated with architectural coatings and asphalt off -gassing, the emissions of which would not result in exceedances of County of San Diego thr esholds. Generally, the VOCs in architectural coatings and asphalt are of relatively low toxicity. Additionally, SDAPCD Rule 67.0.1 restricts the VOC content of coatings for both construction and operational applications.

In addition, VOCs and NOx are precursors to O3, for which the SDAB is designated as nonattainment with respect to the NAAQS and CAAQS (the SDAB is designated by EPA as an attainment area for the 1 -hour O3 NAAQS standard and 1997 8-hour NAAQS standard). The health effects associated with O 3, as discussed in Section 2.1. 2, Criteria Air Pollutants, are generally associated with reduced lung function. The contribution of VOCs and NO x to regional ambient O3 concentrations is the result of complex photochemistry. The increases in O3 concentrations in the SDAB due to O 3 precursor emissions tend to be found downwind from the source location to allow time for the photochemical reactions to occur. However, the potential for exacerbating excessive O3 concentrations would also depend on the time of year that the VOC emissions would occur because exceedances of the O3 NAAQS and CAAQS tend to occur between April and October when solar radiation is highest. The holistic effect of a single project’s emissions of O 3 precursors is speculative due to the lack of quantitative methods to assess this impact.

Nonetheless, the VOC and NO x emissions associated with Project construction could minimally contribute to regional O3 concentrations and the associated health impacts. Due to the minimal contribution during construction and operation, as well as the existing good air quality in coastal San Diego areas, health impacts would be considered less than significant.

Regarding NO2, which is a constituent of NO x, construction of the Project would not contribute to exceedances of the NAAQS and CAAQS for NO 2 since NO x emissions would be less than the applicable SDAPCD threshold. As described in Section 3.1, NO2 health impacts are associated with respiratory irritation, which may be experienced by nearby receptors during the periods of heaviest use of off -road construction equipment. However, these operations would be relatively short term, and the off-road construction equipment would be operating on various portions of the site and would not be concentrated in one portion of the site at any one time. Construction of the Project would not require any stationary emission sources that would create substantial, localized NO2 impacts.

As discussed earlier, PM2.5 and PM10 pose a greater health risk than larger-size particles. When inhaled, these tiny particles can penetrate the human respiratory system’s natural defenses and damage the respiratory tract. PM 2.5 and PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections. Similar to O3, construction of the Project would not exceed thresholds for PM 10 or PM2.5 and would not contribut e to exceedances of the NAAQS and CAAQS for particulate matter. Due to the minimal contribution of particulate matter during construction and operation, health impacts would be considered less than significant.

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Based on the preceding considerations, health impacts from project-related criteria air pollutant emissions would be considered less than significant.

Level of Significance Before Mitigation
The Project would cause a potentially significant impact to sensitive receptors during construction and operations from DPM emissions.

Mitigation Measures
Mitigation Measure AQ-2 Provision of Electrical Infrastructure for Construction and Use of Electric Construction Equipment. After the grading phase of Project construction, the Project Applicant or successor in interest shall provide temporary electrical hook ups to the power grid, rather than diesel -fueled generators, for contractors’ electric construction tools, such as saws, drills and compressors. The use of diesel-fueled generators for on-site construction activities shall be prohibited unless electrical infrastructure is not yet available on the Project site. Diesel-fueled generators may be used for off -site construction work. All off-road equipment with a power rating below 19 kilowatts (e.g., plate compactors, pressure washers) used during Project construction must be electric-powered. The Project Applicant or successor in interest shall include these requirements in applicable bid documents, purchase orders, and contracts with successful contractors.

Mitigation Measure AQ-3 Tier 4 Final Construction Equipment. Prior to the commencement of any construction activities, the applicant or its designee shall provide evidence to the City of Chula Vista (City) that for off-road equipment with engines rated at 75 horsepower or greater, no construction equipment shall be used that is less than Tier 4 Final. In the event of changed circumstances (e.g., changes in availability of specific types of construction equipment), the applicant may submit a request to the City to apply an equivalent method of achieving project-generated construction emissions that fall below the numeric cancer risk standards established by the South Coast Air Quality Management District (SCAQMD). Documentation using industry-standard emission estimation methodologies shall be furnished to the City Community Development Department demonstrating that estimated project-generated construction emissions would not exceed the applicable SCAQMD cancer risk threshold with the alternate construction method(s). If the document ation demonstrates project -generated construction emissions will remain below the applicable SCAQMD cancer risk threshold, then the City may approve the alternate construction method(s) at the Development Director's discretion. Required construction equipm ent fleet and methodologies approved by the City shall be included in the in the contract specifications for the applicant’s contractor
Mitigation Measure AQ-4 Cargo Handling Equipment. All cargo handling equipment (including yard trucks, hostlers, yard goats, pallet jacks, and forklifts) shall be zero-emission vehicles. Each building shall include the necessary charging stations or other necessary

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infrastructure for cargo handling equipment. The building manager or their designee shall be responsible for enforcing these requirements.

Mitigation Measure AQ-5 Tier 4 Emergency Generators . The project operations shall be conditioned to operate with Tier 4 Final certified emergency generators.

Mitigation Measure AQ-6 Truck Requirements and Restrictions. Prior to issuance of a building permit, the City shall confirm the following:
▪ The loading docks shall be designed to accommodate SmartWay trucks. ▪ Applicant shall provide project specifications, drawings, and calculations that demonstrate that main electrical supply lines and panels have been sized to support heavy truck charging facilities when these trucks become available. - The calculations shall be based on reasonable predictions from currently available truck manufacturer’s data. Electrical system upgrades that exceed reasonable costs shall not be required.

Prior to issuance of a certificate of occupancy, the City shall confirm the following:
▪ Any tenant lease agreement shall require tenants that do not already operate 2010 and newer trucks to apply in good faith for funding to replace/retrofit their trucks, such as Carl Moyer, VIP, Prop 1B, SmartWay Finance, or other similar funds. If awarded, the tenant shall be required to accept and use the funding. Tenants shall be encouraged to consider the use of alternative fueled trucks, as well as new or retrofitted diesel trucks.

Tenants shall also be encouraged to become SmartWay Partners, if eligible. This measure shall not apply to trucks that are not owned or operated by the facility operator or facility tenants since it would be legally infeasible to prohibit access to the site by any truck that is otherwise legal to operate on California roads and highways.
▪ Legible, durable, weather-proof signs shall be placed at truck access gates, loading docks, and truck parking areas that identify applicable California Air Resources Board (CARB) anti-idling regulations. At a minimum, each sign shall include instructions for truck drivers to shut off engines when not in use; instructions for drivers of diesel trucks to restrict idling to no more than 5 minutes once the vehicle is stopped, the transmission is set to “neutral” or “park,” and the parking brake is engaged; and telephone numbers of the building facilities manager and CARB to report violations. Prior to the issuance of an occupancy permit, the City shall conduct a site inspection to ensure that the signs are in place.

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Level of Significance After Mitigation
As shown in Tables 2-23 and 2-25, the project’s construction and operational health risks would be reduced to a less than significant level after implementation of mitigation. The project impacts to sensitive receptors would be less-than-significant after mitigation.

2.4.4 Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Construction
Odors would be generated from vehicles and/or equipment exhaust emissions during construction of the project.

Odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment and architectural coatings. Such odors are temporary and for the types of construction activities anticipat ed for Project components, would generally remain localized and occur at magnitudes that would not affect substantial numbers of people. Therefore, impacts associated with odors during construction would be considered less than significant.

Operational
Due to the subjective nature of odor impacts, the number of variables that can influence the potential for an odor impact, and the variety of odor sources, there are no quantitative or formulaic methodologies to determine if potential odors would have a significant impact. Examples of land uses and industrial operations that are commonly associated with odor complaints include agricultural uses, wastewater treatment plants, food processing facilities, chemical plants, composting, refineries, landfills, dair ies, and fiberglass molding facilities. In addition to the odor source, the distance between the sensitive receptor(s) and the odor source, as well as the local meteorological conditions, are considerations in the potential for a project to frequently expose the public to objectionable odors.

Although localized air quality impacts are focused on potential impacts to sensitive receptors, such as residences and schools, other land uses where people may congregate (e.g., workplaces) or uses with the intent to attract people (e.g., restaurants and visitor -serving accommodations) should also be considered in the evaluation of potential odor nuisance impacts. The project is a commercial development, which is not expected to produce any nuisance odors; therefore, impacts related to odors caused by the project would be less than significant.

Level of Significance Before Mitigation
The project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people; the impact would be less than significant.

Mitigation Measures
No mitigation is required.

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Level of Significance After Mitigation
Impacts would be less than significant.

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3 Greenhouse Gas Emissions

3.1 Environmental Setting

3.1.1 Climate Change Overview
Climate change refers to any significant change in measures of climate, such as temperature, precipitation, or wind patterns, lasting for an extended period of time (decades or longer). The Earth's temperature depends on the balance between energy entering and leaving the planet’s system. Many factors, both natural and human, can cause changes in Earth’s energy balance, including variations in the sun's energy reaching Earth, changes in the reflectivity of Earth’s atmosphere and surface, and changes in the greenhouse effect, which affects the amount of heat retained by Earth’s atmosphere (EPA 2022c).

The greenhouse effect is the trapping and build -up of heat in the atmosphere (troposphere) near the Earth’s surface. The greenhouse effect traps heat in the troposphere through a threefold process as follows: Short -wave radiation emitted by the Sun is abso rbed by the Earth; the Earth emits a portion of this energy in the form of long-wave radiation; and GHGs in the upper atmosphere absorb this long-wave radiation and emit it into space and toward the Earth. The greenhouse effect is a natural process that contributes to regulating the Earth’s temperature and creates a pleasant, livable environment on the Earth. Human activities that emit additional GHGs to the atmosphere increase the amount of infrared radiation that gets absorbed before escaping into space, thus enhancing the greenhouse effect and causing the Earth’s surface temperature to rise.

The scientific record of the Earth’s climate shows that the climate system varies naturally over a wide range of time scales and that in general, climate changes prior to the Industrial Revolution in the 1700s can be explained by natural causes, such as changes in solar energy, volcanic eruptions, and natural changes in GHG concentrations.

Recent climate changes, in particular the warming observed over the past century, however, cannot be explained by natural causes alone. Rather, it is extremely likely that human activities have been the dominant cause of that warming since the mid-20th century and is the most significant driver of observed climate change (IPCC 2014; EPA 2022c). Human in fluence on the climate system is evident from the increasing GHG concentrations in the atmosphere, positive radiative forcing, observed warming, and improved understanding of the climate system (IPCC 2014). The atmospheric concentrations of GHGs have increased to levels unprecedented in the last 800,000 years, primarily from fossil fuel emissions and secondarily from emissions associated with land use changes (IPCC 2014).

Continued emissions of GHGs will cause further warming and changes in all components of the climate system, which is discussed further in Section 3.1.5, Potential Effects of Climate Change.

3.1.2 Greenhouse Gases and other Climate Forcing Substances A GHG is any gas that absorbs infrared radiation in the atmosphere; in other words, GHGs trap heat in the atmosphere. GHGs include, but are not limited to, carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), ozone (O3), water vapor, hydrofluorocarbons (HFCs), hydrochlorofluorocarbons (HCFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF 6).7 Some GHGs, such as CO 2, CH 4, and N 2O, occur naturally and are emitted to the

7 California Health and Safety Code 38505 identifies seven GHGs that CARB is responsible to monitor and regulate to reduce emissions: CO2, CH4, N2O, SF6, HFCs, PFCs, and NF3.

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atmosphere through natural processes and human activities. Of these gases, CO 2 and CH 4 are emitted in the greatest quantities from human activities. Manufactured GHGs, which have a much greater heat -absorption potential than CO 2, include fluorinated gases, such as HFCs, HCFCs, PFCs, and SF 6, which are associated with certain industrial products and processes. A summary of the most common GHGs and their sources is included in the following text.8 Also included is a discussion of other climate forcing substances.

Carbon Dioxide (CO 2). CO2 is a naturally occurring gas and a by -product of human activities and is the principal anthropogenic GHG that affects the Earth’s radiative balance. Natural sources of CO2 include respiration of bacteria, plants, animals, and fungus; evaporation from oceans; volcanic out -gassing; and decomposition of dead organic matter. Human activities that generate CO 2 are from the combustion of fuels such as coal, oil, natural gas, and wood and changes in land use.

Methane (CH4). CH4 is produced through both natural and human activities. CH4 is a flammable gas and is the main component of natural gas. Methane is produced through anaerobic (without oxygen) decomposition of waste in landfills, flooded rice fields, animal digestion, decomposition of animal wastes, production and distribution of natural gas and petroleum, coal production, and incomplete fossil fuel combustion.

Nitrous Oxide (N 2O). N2O is produced through natural and human activities, mainly through agricultural activities and natural biological processes, although fuel burning and other processes also create N 2O. Sources of N 2O include soil cultivation practices (microbial processes in soil and water), especially the use of commercial and organic fertilizers, manure management, industrial processes (such as in nitric acid production, nylon production, and fossil-fuel-fired power plants), vehicle emissions, and using N2O as a propellant (such as in rockets, racecars, and aerosol sprays).

Fluorinated Gases. Fluorinated gases (also referred to as F-gases) are synthetic powerful GHGs emitted from many industrial processes. Fluorinated gases are commonly used as substitutes for stratospheric ozone -depleting substances (e.g., CFCs, HCFCs, and halons). The most prevalent fluorinated gases include the following:
▪ Hydrofluorocarbons: HFCs are compounds containing only hydrogen, fluorine, and carbon atoms. HFCs are synthetic chemicals used as alternatives to ozone-depleting substances in serving many industrial, commercial, and personal needs. HFCs are emitted as by-products of industrial processes and are used in manufacturing. ▪ Perfluorocarbons: PFCs are a group of human -made chemicals composed of carbon and fluorine only.

These chemicals were introduced as alternatives, with HFCs, to the ozone depleting substances. The two main sources of PFCs are primary aluminum production and semiconductor manufacturing. Since PFCs have stable molecular structures and do not break down through the chemical processes in the lower atmosphere, these chemicals have long lifetimes, ranging between 10,000 and 50,000 years. ▪ Sulfur Hexafluoride: SF6 is a colorless gas soluble in alcohol and ether and slightly soluble in water. SF6 is used for insulation in electric power transmission and distribution equipment, semiconductor manufacturing, the magnesium industry, and as a tracer gas for leak detection. ▪ Nitrogen Trifluoride: NF3 is used in the manufacture of a variety of electronics, including semiconductors and flat panel displays.

8 The descriptions of GHGs are summarized from the Intergovernmental Panel on Climate Change (IPCC) Fourth Assessment Report (2007), CARB’s Glossary of Air Pollution Terms (2023i), and EPA’s Glossary of Climate Change Terms (2016).

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Chlorofluorocarbons (CFCs). CFCs are synthetic chemicals that have been used as cleaning solvents, refrigerants, and aerosol propellants. CFCs are chemically unreactive in the lower atmosphere (troposphere) and the production of CFCs was prohibited in 1987 due to the chemical destruction of stratospheric O3.

Hydrochlorofluorocarbons (HCFCs). HCFCs are a large group of compounds, whose structure is very close to that of CFCs—containing hydrogen, fluorine, chlorine, and carbon atoms—but including one or more hydrogen atoms. Like HFCs, HCFCs are used in refrigerants and propellants. HCFCs were also used in place of CFCs for some applications; however, their use in general is being phased out.

Black Carbon. Black carbon is a component of fine particulate matter, which has been identified as a leading environmental risk factor for premature death. It is produced from the incomplete combustion of fossil fuels and biomass burning, particularly from older diesel engines and forest fires. Black carbon warms the atmosphere by absorbing solar radiation, influences cloud formation, and darkens the surface of snow and ice, which accelerates heat absorption and melting. Black carbon is a short -lived species that varies spatially, which makes it difficult to quantify the global warming potential. Diesel particulate matter emissions are a major source of black carbon and are toxic air contaminates (TACs) that have been regulated and controlled in California f or several decades to protect public health. In relation to declining diesel particulate matter from the California Air Resources Board’s (CARB’s) regulations pertaining to diesel engines, diesel fuels, and burning activities, CARB estimates that annual black carbon emissions in California have reduced by 70% between 1990 and 2010, with 95% control expected by 2020 (CARB 2014).

Water Vapor. The primary source of water vapor is evaporation from the ocean, with additional vapor generated by sublimation (change from solid to gas) from ice and snow, evaporation from other water bodies, and transpiration from plant leaves. Water vapor is the most important, abundant, and variable GHG in the atmosphere and maintains a climate necessary for life.

Ozone (O3). Tropospheric O3, which is created by photochemical reactions involving gases from both natural sources and human activities, acts as a GHG. Stratospheric O3, which is created by the interaction between solar ultraviolet radiation and molecular oxygen (O 2), plays a decisive role in the stratospheric radiative balance. Depletion of stratospheric O 3, due to chemical reactions that may be enhanced by climate change, results in an increased ground-level flux of ultraviolet-B radiation.

Aerosols. Aerosols are suspensions of particulate matter in a gas emitted into the air through burning biomass (plant material) and fossil fuels. Aerosols can warm the atmosphere by absorbing and emitting heat and can cool the atmosphere by reflecting light.

3.1.3 Global Warming Potential
Gases in the atmosphere can contribute to climate change both directly and indirectly. Direct effects occur when the gas itself absorbs radiation. Indirect radiative forcing occurs when chemical transformations of the substance produce other GHGs, when a gas influences the atmospheric lifetimes of other gases, and/or when a gas affects atmospheric processes that alter the radiative balance of the Earth (e.g., affect cloud formation or albedo) (EPA 2022c). The Intergovernmental Panel on Climate Change (IPCC) developed the global warming potential (GWP) concept to compare the ability of each GHG to trap heat in the atmosphere relative to another gas. The GWP of a GHG is defined as the ratio of the time-integrated radiative forcing from the instantaneous release of 1 kilogram of

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a trace substance relative to that of 1 kilogram of a reference gas (IPCC 2014). The reference gas used is CO 2; therefore, GWP-weighted emissions are measured in metric tons CO2 equivalent (MT CO2e).

The current version of the CalEEMod (version 2022) assumes that the GWP for CH4 is 25 (so emissions of 1 MT of CH4 are equivalent to emissions of 25 MT of CO 2), and the GWP for N 2O is 298, based on the IPCC Fourth Assessment Report (IPCC 2007). The GWP values identified in CalEEMod were applied to the project.

3.1.4 Sources of Greenhouse Gas Emissions
Global Inventory
Anthropogenic GHG emissions worldwide in 2020 (the most recent year for which data is available) totaled approximately 49,800 million metric tons (MMT) of CO2e, excluding land use change and forestry (PBL 2022). The top six GHG emitters include China, the United States, the Russian Federation, India, Japan, and the European Union, which accounted for approximately 60% of the total global emissions, or approximately 30,270 MMT CO2e (PBL 2022). Table 3-1 presents the top GHG-emissions-producing entities.

Table 3-1. Six Top GHG Producer Entities
Emitting Countries 2020 GHG Emissions (MMT CO 2e) a,b
China 14,300
United States 5,640
European Union 3,440
India 3,520
Russian Federation 2,210
Japan 1,160
Total 30,270
Source: PBL 2022.

Notes: MMT CO2e = million metric tons of carbon dioxide equivalent. a Column may not add due to rounding.
b GHG emissions do not include land use change and forestry-related GHG emissions.

National Inventory
Per the EPA Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 to 20 21, total United States GHG emissions were approximately 6,340.2 MMT CO2e in 2021 (EPA 2023a). Total U.S. emissions have decreased by

2.3 percent from 1990 to 2021, down from a high of 15.8 percent above 1990 levels in 2007. Emissions increased from 2020 to 2021 by 5.2 percent (314.3 MMT CO2e). Net emissions (i.e., including sinks) were 5,586.0 MMT CO2e in 2021. Overall, net emissions increased 6.4 percent from 2020 to 2021 and decreased 16.6 percent from 2005 levels Between 2020 and 2021, the increase in total GHG emissions was driven largely by an increase in CO 2 emissions from fossil fuel combustion due to economic activity rebounding after the height of the COVID -19 pandemic. The CO2 emissions from fossil fuel combustion increased by 6.8 percent from 2020 to 2021, including a 11.4 percent increase in transportation sector emissions and a 7.0 percent increase in electric power sector emissions. The increase in electric power sector emissions was due in part to an increase in electricity demand of

2.4 percent since 2020. Overall, there has been a decrease in electric power sector emissions from 1990 through 2021, which reflects the combined impacts of long -term trends in many factors, including population, economic

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growth, energy markets, technological changes including energy efficiency, and the carbon intensity of energy fuel choices (EPA 2023a).

State Inventor y
According to California’s 2000 –2020 GHG emissions inventory (202 2 edition), California emitted approximately 369.2 MMT CO2e in 2020, including emissions resulting from out-of-state electrical generation (CARB 2022a). The sources of GHG emissions in California include transportation, industry, electric power production from both in-state and out-of-state sources, residential and commercial activities, agriculture, high -GWP substances, and recycling and waste. Table 2 presents California GHG emission source c ategories and their relative contributions to the emissions inventory in 2020.

Between 2000 and 2019, per-capita GHG emissions in California have dropped from a peak of 14.0 MT per person in 2001 to 10.5 MT per person in 2019, representing an approximate 25% decrease. In addition, total GHG emissions in 2019 were approximately 7 MMT CO2e lower than 2018 emissions (CARB 2022a).

Table 3-2. GHG Emissions Sources in California
Source Category
Annual GHG Emissions
(MMT CO 2e) Percent of Total*
Transportation 145.6 38.2%
Industrial uses 73.9 19.4%
Electricity generationa 62.4 16.4%
Residential and commercial uses 38.8 10.2%
Agriculture and Forestry 30.9 8.1%
High GWP substances 21.3 5.6%
Recycling and waste 8.4 2.2%
Totals 381.3 100%
Source: CARB 2023j
Notes: GHG = greenhouse gas; GWP = global warming potential; MMT CO2e = million metric tons of carbon dioxide equivalent.

Emissions reflect 2020 California GHG inventory.

Totals may not sum due to rounding.
a Includes emissions associated with imported electricity, which account for 19.82 MMT CO2e.

Per capita GHG emissions in California have dropped from a 2001 peak of 13.8 MT per person to 9.7 MT per person in 2021, a 30% decrease. In 2016, statewide GHG emissions dropped below the 2020 GHG Limit of 431 MMT CO2e and have remained below the limit since that time (CARB 2022a).

Local Inventories
As part of Chula Vista’s climate action program and its commitment to reduce GHG emissions, the Economic Development Department’s Conservation Section performs emission inventories to identify GHG sources and to help guide policy decisions. The 2020 GHG Em issions Inventory is the City’s latest evaluation of its progress in reaching its emissions reduction goal and builds upon past inventory efforts.

In 2020, community GHG emissions from Chula Vista totaled 1,098,000 MT CO2e (City of Chula Vista, 2017). The sector with the greatest level of emissions was transportation or mobile sources at 581,000 MT CO2e or fifty three

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percent (53%) of total emissions. The electricity sector was the second highest source at 260,000 MT CO 2e representing 24% of total community emissions, followed by the natural gas energy use at 191,000 MT CO2e or 17% of total emission and the lowest contributor to total MT CO2e was solid waste at 50,000 MT CO2e or 5%)of the total.

Compared to 2005 and 2018, total citywide emissions in 2020 were 17% and 4% lower. 2020 per capita emissions are approximately 37% below 2005 levels and 11% below 2018 levels. Emissions from all energy sectors have decreased by 4% or 21,000 MT CO 2e in total since 2005 . Transportation-based emissions are estimated to have decreased 19% or 136,000 MT CO2e since 2005 and 87,000 MT CO2e or 13%, since 2018. The solid waste sector had emissions 18% below the 2005 baseline and 4% lower than 2018. Emissions from water (embedded energy) were eight 8% above 2018 emissions but are still 74% below the baseline. Emissions from wastewater remained even at 3,000 MT CO2e (Chula Vista 2022).

3.1.5 Potential Effects of Climate Change
Globally, climate change has the potential to affect numerous environmental resources through uncertain impacts related to future air temperatures and precipitation patterns. The 2014 IPCC Synthesis Report indicated that warming of the climate system is unequivocal and since the 1950s, many of the observed changes are unprecedented over decades to millennia. Signs that global climate change has occurred include warming of the atmosphere and ocean, diminished amounts of snow and ice, and rising sea levels (IPCC 2014).

In California, climate change impacts have the potential to affect sea -level rise, agriculture, snowpack and water supply, forestry, wildfire risk, public health, frequency of severe weather events, and electricity demand and supply.

The primary effect of global climate change has been a rise in average global tropospheric temperature. Reflecting the long-term warming trend since pre-industrial times, observed global mean surface temperature for the decade 2006–2015 was 0.87°C (1.6°F) (likely between 0.75 °C [1.4°F] and 0.99°C [1.8°F]) higher than the average over the 1850–1900 period (IPCC 2018). Scientific modeling predicts that continued emissions of GHGs at or above current rates would induce more extreme climate changes during the twenty-first century than were observed during the twentieth century. Human activities are estimated to have caused approximately 1.0°C (1.8°F) of global warming above pre-industrial levels, with a likely range of 0.8 °C to 1.2 °C (1.4°F to 2.2 °F) (IPCC 2018). Global warming is likely to reach 1.5°C (2.7°F) between 2030 and 2052 if it continues to increase at the current rate (IPCC 2018).

Although climate change is driven by global atmospheric conditions, climate change impacts are felt locally. A scientific consensus confirms that climate change is already affecting California. The Office of Environmental Health Hazard Assessment identifie d various indicators of climate change in California, which are scientifically based measurements that track trends in various aspects of climate change. Many indicators reveal discernible evidence that climate change is occurring in California and is having significant, measurable impacts in the state. Changes in the state’s climate have been observed, including an increase in annual average air temperature with record warmth from 2012 to 2016, more frequent extreme heat events, more extreme drought, a decline in winter chill, an increase in cooling degree days and a decrease in heating degree days, and an increase in variability of statewide precipitation (OEHHA 2018).

Warming temperatures and changing precipitation patterns have altered California’s physical systems—the ocean, lakes, rivers, and snowpack—upon which the state depends. Winter snowpack and spring snowmelt runoff from the Sierra Nevada and southern Cascade Mountains provide approximately one-third of the state’s annual water supply.

Impacts of climate on physical systems have been observed such as high variability of snow -water content (i.e., amount of water stored in snowpack), decrease in snowmelt runoff, glacier change (loss in area), rise in sea

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levels, increase in average lake water temperature and coastal ocean temperature, and a decrease in dissolved oxygen in coastal waters (OEHHA 2018).

Impacts of climate change on biological systems, including humans, wildlife, and vegetation, have also been observed, including climate change impacts on terrestrial, marine, and freshwater ecosystems. As with global observations, species responses include those consistent with warming: elevational or latitudinal shifts in range, changes in the timing of key plant and animal life cycle events, and changes in the abundance of species and in community composition. Humans are better able to adapt to a changing climate than plants and animals in natural ecosystems. Nevertheless, climate change poses a threat to public health as warming temperatures and changes in precipitation can affect vector -borne pathogen transmission and disease patterns in California as we ll as the variability of heat-related deaths and illnesses. In addition, since 1950, the area burned by wildfires each year has followed an increasing trend overall.

CNRA has released four California Climate Change Assessments (in 2006, 2009, 2012, and 2018), which have addressed the following: acceleration of warming across the state, more intense and frequent heat waves, greater riverine flows, accelerating sea level rise, more intense and frequent drought, more severe and frequent wildfires, more severe storms and extreme weath er events, shrinking snowpack and less overall precipitation, and ocean acidification, hypoxia, and warming. To address local and regional gov ernments’ need for information to support action in their communities, the Fourth Assessment (CNRA 2019) includes reports for nine regions of the state. Key highlights for the San Diego Region include the following (CNRA 2019):
▪ Temperature is projected to increase substantially, along with mean temperature, heat wave frequency will increase, with more intensity and longer duration.
▪ Precipitation will remain highly variable but will change in character, with wetter winters, drier springs, and more frequent and severe droughts punctuated by more intense individual precipitation events. ▪ Wildfire risk will increase in the future as climate warms. The risk for large catastrophic wildfires driven by Santa Ana wind events will also likely increase as a result of a drier autumns leading to low antecedent precipitation before the height of the Santa Ana wind season. ▪ The sea level along San Diego County is expected to rise. High tides combined with elevated shoreline water levels produced by locally and distantly driven wind -driven waves will drive extreme events. Longer -term sea level will increase rapidly in the second half of the century and will be punctuated by short periods of storm-driven extreme sea levels that will imperil existing infrastructure, structures, and ecosystems with increasing frequency.

3.2 Regulatory Setting

3.2.1 Federal
Massachusetts v. EPA. In Massachusetts v. EPA (April 2007), the U.S. Supreme Court directed the U.S. Environmental Protection Agency (EPA) administrator to determine whether GHG emissions from new motor vehicles cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare, or whether the science is too

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uncertain to make a reasoned decision. In December 2009, the administrator signed a final rule with the following two distinct findings regarding GHGs under Section 202(a) of the federal Clean Air Act (CAA):
▪ The Administrator found that elevated concentrations of GHGs —carbon dioxide ( CO2), methane ( CH4), nitrous oxide ( N2O), ozone (O 3), water vapor, hydrofluorocarbons ( HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—in the atmosphere threaten the public health and welfare of current and future generations. This is the “endangerment finding.”
▪ The Administrator further found the combined emissions of GHGs —CO2, CH4, N2O, and HFCs —from new motor vehicles and new motor vehicle engines contribute to the GHG air pollution that endangers public health and welfare. This is the “cause or contribute finding.” These two findings were necessary to establish the foundation for regulation of GHGs from new motor vehicles as air pollutants under the Clean Air Act.

Energy Independence and Security Act. The Energy Independence and Security Act of 2007 (December 2007), among other key measures, would do the following, which would aid in the reduction of national GHG emissions:

1. Increase the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard requiring fuel producers to use at least 36 billion gallons of biofuel by 2022.

2. Set a target of 35 miles per gallon for the combined fleet of cars and light trucks by model year 2020 and direct National Highway Traffic Safety Administration (NHTSA) to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for work trucks.

3. Prescribe or revise standards affecting regional efficiency for heating and cooling products and procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances.

Federal Vehicle Standards. In response to a U.S. Supreme Court ruling, the Bush Administration issued Executive Order (EO) 13432 in 2007 directing the EPA, the Department of Transportation, and the Department of Energy to establish regulations that reduce GHG emissions from motor vehicles, non-road vehicles, and non-road engines by 2008. In 2009, the NHTSA issued a final rule regulating fuel efficiency and GHG emissions from cars and light-duty trucks for model year 2011, and in 2010, the EPA and NHTSA issued a final rule regulating cars and light -duty trucks for model years 2012–2016 (75 FR 25324–25728).

In 2010, President Barack Obama issued a memorandum directing the Department of Transportation, Department of Energy, EPA, and NHTSA to establish additional standards regarding fuel efficiency and GHG reduction, clean fuels, and advanced vehicle infrastruc ture. In response to this directive, the EPA and NHTSA proposed stringent, coordinated federal GHG and fuel economy standards for model years 2017 –2025 light -duty vehicles. The proposed standards projected to achieve 163 grams per mile of CO 2 by model year 2025 on an average industry fleet-wide basis, which is equivalent to 54.5 miles per gallon if this level were achieved solely through fuel efficiency.

The final rule was adopted in 2012 for model years 2017–2021 (77 FR 62624–63200). On January 12, 2017, the EPA finalized its decision to maintain the current GHG emissions standards for model years 2022–2025 cars and light trucks (EPA 2022b).

In addition to the regulations applicable to cars and light-duty trucks described above, in 2011, the EPA and NHTSA announced fuel economy and GHG standards for medium- and heavy-duty trucks for model years 2014–2018 (76

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FR 57106–57513). The standards for CO 2 emissions and fuel consumption are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles. According to the EPA, this regulatory program will reduce GHG emissions and fuel consumption for the affected vehicles by 6%–23% over the 2010 baselines.

In August 2016, the EPA and NHTSA announced the adoption of the phase two program related to the fuel economy and GHG standards for medium- and heavy-duty trucks. The phase two program will apply to vehicles with model year 2018 through 2027 for certain tr ailers, and model years 2021 through 2027 for semi -trucks, large pickup trucks, vans, and all types and sizes of buses and work trucks. The final standards are expected to lower CO2 emissions by approximately 1.1 billion metric tons (MT) and reduce oil consumption by up to 2 billion barrels over the lifetime of the vehicles sold under the program (EPA and NHTSA 2016).

In August 2018, the EPA and NHTSA proposed to amend certain fuel economy and GHG standards for passenger cars and light trucks and establish new standards for model years 2021 through 2026. Compared to maintaining the post- 2020 standards in place at the time, the 2018 proposal would increase U.S. fuel consumption by about half a million barrels per day (2%–3% of total daily consumption, according to the Energy Information Administration) and would impact the global climate by 3/1000th of 1°C by 2100 (EPA and NHTSA 2018). California and other states have stated their intent to challenge federal actions that would delay or eliminate GHG reduction measures, and have committed to cooperating with other countries to implement global climate change initiatives.

In 2019, the EPA and NHTSA published the Safer Affordable Fuel -Efficient Vehicles Rule Part One: One National Program (SAFE -1), which revoked California’s authority to set its own GHG emissions standards and set zero - emission vehicle (ZEV) mandates in Cali fornia. In March 2020, Part Two was issued which set CO 2 emissions standards and corporate average fuel economy standards for passenger vehicles and light -duty trucks for model years 2021 through 2026. In response to EO 13990, on December 21, 2021, NHTSA finalized the corporate average fuel economy (CAFE) Preemption rulemaking to withdraw its portions of the Part One Rule. The final rule concluded that the Part One Rule overstepped the agency’s legal authority and established overly broad prohibitions that did not account for a variety of important state and local interests.

Then, in March 2022, NHTSA established new fuel economy standards that would require an industry-wide fleet average of approximately 49 miles per gallon for passenger cars and light trucks in model year 2026, by increasing fuel efficiency by 8% annually for model years 2024 and 2025, and 10% annually for model year 2026.

Inflation Reduction Act of 2022. The Inflation Reduction Act was signed into law by President Biden in August 2022.

The bill includes specific investment in energy and climate reform and is projected to reduce GHG emissions within the U.S. by 40% as compared to 2005 levels by 2030. The bill allocates f unds to boost renewable energy infrastructure (e.g., solar panels and wind turbines), includes tax credits for the purchase of electric vehicles, and includes measures that will make homes more energy efficient.

3.2.2 State
The statewide GHG emissions regulatory framework is summarized below by category: state climate change targets, building energy, renewable energy and energy procurement, mobile sources, solid waste, water, and other state regulations and goals. The following text describes executive orders (EO), legislation [assembly bills (AB) and senate

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bills (SB)], regulations, and other plans and policies that would directly or indirectly reduce GHG emissions and/or address climate change issues.

State Climate Change Targets
The state has taken several actions to address climate change. These include executive orders, legislation, and CARB plans and requirements. These are summarized below.

Executive Order (EO) S-3-05. EO S-3-05 (June 2005) established the following statewide goals: GHG emissions should be reduced to 2000 levels by 2010, GHG emissions should be reduced to 1990 levels by 2020, and GHG emissions should be reduced to 80% below 1990 levels by 2050.

EO S-3-05 also directed the California EPA to report biannually on progress made toward meeting the GHG targets and the impacts to California due to global warming, including impacts to water supply, public health, agriculture, the coastline, and forestry. The Climate Action Team was formed, which subsequently issued reports from 2006 to 2010 (CAT 2016).

Assembly Bill (AB) 32. In furtherance of the goals established in EO S-3-05, the legislature enacted AB 32 (Núñez and Pavley). The bill is referred to as the California Global Warming Solutions Act of 2006 (September 27, 2006). AB 32 provided initial direction on creating a comprehensive multiyear program to limit California’s GHG emissions at 1990 levels by 2020 and initiate the transformations required to achieve the state’s long-range climate objectives.

EO B-30-15. EO B-30-15 (April 2015) identified an interim GHG reduction target in support of targets previously identified under EO S-3-05 and AB 32. EO B-30-15 set an interim target goal of reducing statewide GHG emissions to 40% below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the l ong-term goal of reducing statewide GHG emissions to 80% below 1990 levels by 2050, as set forth in EO S-3-05. To facilitate achievement of this goal, EO B -30-15 calls for an update to CARB’s Scoping Plan to express the 2030 target in terms of MMT CO2e. The executive order also calls for state agencies to continue to develop and implement GHG emissions reduction programs in support of the reduction targets. Sector -specific agencies in transportation, energy, water, and forestry were required to prepare GHG reduction plans by September 2015, followed by a report on action taken in relation to these plans in June 2016. EO B -30-15 does not require local agencies to take any action to meet the new interim GHG reduction target.

Senate Bill (SB) 32 and AB 197. SB 32 and AB 197 (enacted in 2016) are companion bills that set a new statewide GHG reduction targets, make changes to CARB’s membership and increase legislative oversight of CARB’s climate change-based activities, and expand dissemination of GHG and other air-quality-related emissions data to enhance transparency and accountability. More specifically, SB 32 codified the 2030 emissions reduction goal of EO B-30-15 by requiring CARB to ensure that statewide GHG emissions are reduced to 40% below 1990 levels by 2030. AB 197 established the Joint Legislative Committee on Climate Change Policies, consisting of at least three members of the Senate and three members of the Assembly to provide ongoing oversight over implementation of the state’s climate policies. AB 197 also added two members of the Legislature to CARB as nonvoting members; requires CARB to make available and update (at least annually via its website) emissions data for GHGs, criteria air pollutants, and toxic air contaminants (TACs) from reporting facilities; and requires CARB to identify specific information for GHG emissions reduction measures when updating the Scoping Plan.

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EO B-55-18. EO B-55-18 (September 2018) establishes a statewide policy for the state to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net-negative emissions thereafter. The goal is an addition to the existing statewide targets of reducing the state’s GHG emissions. CARB will work with relevant state agencies to ensure that future scoping plans identify and recommend measures to achieve the c arbon neutrality goal.

AB 1279. The Legislature enacted AB 1279, the California Climate Crisis Act, in September 2022. The bill declares the policy of the state to achieve net zero GHG emissions as soon as possible, but no later than 2045, and achieve and maintain net negative GHG emissi ons thereafter. Additionally, the bill requires that by 2045, statewide anthropogenic GHG emissions be reduced to at least 85% below 1990 levels. Although AB 1279 establishes an overall policy to achieve net zero greenhouse gas emissions as soon as possible, but no later than 2045, recognizing the need to implement carbon dioxide removal and carbon capture, utilization and storage technologies, the Legislature established a specific target of 85% below 1990 levels by 2045 for anthropogenic GHG emis sions.

Therefore, the net zero target does not directly apply to development projects, but the 2045 target of 85% below 1990 levels represents the reductions required to contribute to accomplishing the State’s overall net zero policy.

California Air Resources Board’s Climate Change Scoping Plan. One specific requirement of AB 32 was for CARB to prepare a scoping plan for achieving the maximum technologically feasible and cost -effective GHG emission reductions by 2020 (Health and Safety Code Section 38561[a]), and to update the plan at least once every 5 years.

In 2008, CARB approved the first scoping plan. The Climate Change Scoping Plan: A Framework for Change (Scoping Plan) included a mix of recommended strategies that combined direct regulations, market -based approaches, voluntary measures, policies, and other emission reduction programs calculated to meet the 2020 statewide GHG emissions limit and initiate the transformations needed to achieve the st ate’s long-range climate objectives. The key elements of the Scoping Plan include the following (CARB 2008):

1. Expanding and strengthening existing energy efficiency programs, as well as building and appliance standards.

2. Achieving a statewide renewable energy mix of 33%.

3. Developing a California cap-and-trade program that links with other Western Climate Initiative partner programs to create a regional market system and caps sources contributing 85% of California’s GHG emissions.

4. Establishing targets for transportation -related GHG emissions for regions throughout California, and pursuing policies and incentives to achieve those targets.

5. Adopting and implementing measures pursuant to existing state laws and policies, including California’s clean car standards, goods movement measures, and the Low Carbon Fuel Standard (17 CCR 95480 et seq.).

6. Creating targeted fees, including a public goods charge on water use, fees on high global warming potential (GWP) gases, and a fee to fund the administrative costs of the State of California’s long-term commitment to AB 32 implementation.

The Scoping Plan also identified local governments as essential partners in achieving California’s goals to reduce GHG emissions because they have broad influence and, in some cases, exclusive authority over activities that contribute to significant direct and indirect GHG emissions through their planning and permitting processes, local ordinances, outreach and education efforts, and municipal operations. Specifically, the Scoping Plan encouraged local governments to adopt a reduction goal for municipal operations, and for community emissions to reduce GHGs by approximately 15% from then levels (2008) by 2020. Many local governments developed community-scale local GHG reduction plans based on this Scoping Plan recommendation.

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In 2014, CARB approved the first update to the Scoping Plan. The First Update to the Climate Change Scoping Plan:

Building on the Framework (First Update) defined the state’s GHG emission reduction priorities for the next 5 years, and laid the groundwork to start the transition to the post -2020 goals set forth in EO S -3-05 and EO B -16-2012.

The First Update concluded that California is on track to meet the 2020 target but recommended a 2030 mid-term GHG reduction target be established to ensure a continuum of action to reduce emissions. The First Update recommended a mix of technologies in key economic sectors to reduce emissions through 2050, including energy demand reduction through efficiency and activity changes; large-scale electrification of on-road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean energy technologies. As part of the First Update, CARB recalculated the state’s 1990 emissions level, using more recent GWPs identified by the Intergovernmental Panel on Climate Change (IPCC), from 427 MMT CO2e to 431 MMT CO2e (CARB 2014).

In 2015, as directed by EO B-30-15, CARB began working on an update to the Scoping Plan to incorporate the 2030 target of 40% below 1990 levels by 2030 to keep California on its trajectory toward meeting or exceeding the long- term goal of reducing GHG emissions to 80% below 1990 levels by 2050 as set forth in EO S-3-05. The governor called on California to pursue a new and ambitious set of strategies, in line with the five climate change pillars from his inaugural address, to reduce GHG emissions and prepare for the unavoidable impacts of climate change. In the summer of 2016, the legislature affirmed the importance of addressing climate change through passage of SB 32.

In December 2017, CARB adopted California’s 2017 Climate Change Scoping Plan (2017 Scoping Plan) for public review and comment (CARB 2017). The 2017 Scoping Plan builds on the successful framework established in the initial Scoping Plan and First Update while identifying new, technologically feasible and cost-effective strategies that will serve as the framework to achieve the 2030 GHG target as established by SB 32 and define the state’s climate change priorities to 2030 and beyond. The strategies’ commitments include implementing renewable energy and energy efficiency strategies (including the mandates of SB 350), increasing stringency of the Low Carbon Fuel Standard, implementing measures identified in the Mobile Source and Freight Strategies, implementing measures identified in the proposed Short -Lived Climate Pollutant Reduction Strategy, and increasing stringency of SB 375 targets. To fill the gap in additional reductions needed to achieve the 2030 target, it recommen ds continuing the Cap-and-Trade Program and a measure to reduce GHGs from refineries by 20%.

For local governments, the 2017 Scoping Plan replaced the initial Scoping Plan’s 15% reduction goal with a recommendation to aim for a community-wide goal of no more than 6 MT CO 2e per capita by 2030, and no more than 2 MT CO 2e per capita by 2050, which are consistent with the state’s long -term goals. These goals are also consistent with the Under 2 Memorandum of Understanding (Under 2 2016) and the Paris Agreement, which are developed around the scientifically based levels necessary to limit global warming to below 2°C. The 2017 Scoping Plan recognized the benefits of local government GHG planning (e.g., through Climate Action Plans ( CAPs)) and provided more information regarding tools CARB is working on to support those efforts. It also recognized the CEQA streamlining provisions for project-level review where there is a legally adequate CAP.9 The Scoping Plan recommends strategies for implementation at the statewide level to meet the goals of AB 32, SB 32, and the executive orders, and establishes an overall framework for the measures that will be adopted to reduce California’s GHG emissions. A project is considered consistent with the statutes and executive orders if it meets the

9 Sierra Club v. County of Napa (2004) 121 Cal.App.4th 1490; San Francisco Tomorrow et al. v. City and County of San Francisco (2015) 229 Cal.App.4th 498; San Franciscans Upholding the Downtown Specific Plan v. City and County of San Francisco (2002) 102 Cal.App.4th 656; Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 719.

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general policies in reducing GHG emissions to facilitate the achievement of the state’s goals and does not impede attainment of those goals. A project would be consistent if it will further the objectives and not obstruct their attainment.

CARB adopted the 2022 Scoping Plan Update in December 2022, which outlines the state’s plan to reach carbon neutrality by 2045 or earlier, while also assessing the progress the state is making toward reducing GHG emissions by at least 40% below 1990 levels by 2030, as is required by SB 32 and laid out in the Second Update. The carbon neutrality goal requires CARB to expand proposed actions from only the reduction of anthropogenic sources of GHG emissions to also include those that capture and store carbon (e.g., through natural and working lands, or mechanical technologies). The carbon reduction programs build on and accelerate those currently in place, including moving to zero-emission transportation; phasing out use of fossil gas use for heating homes and buildings; reducing chemical and refrigerants with high GWP; providing communities with sustainable options for walking, biking, and public transit; displacement of fossil-fuel fired electrical generation through use of renewable energy alternatives (e.g., solar arrays and wind turbines); and scaling up new options such as green hydrogen (CARB 2022b).

The 2022 Scoping Plan also emphasizes that there is no realistic path to carbon neutrality without carbon removal and sequestration, and to achieve the state’s carbon neutrality goal, carbon reduction programs must be supplemented by strategies to remove a nd sequester carbon. Strategies for carbon removal and sequestration include carbon capture and storage from anthropogenic point sources, where CO2 is captured as it leaves a facility’s smokestack and is injected into geologic formations or used in industr ial materials (e.g., concrete); and carbon dioxide removal from ambient air, through mechanical (e.g., direct air capture with sequestration) or nature-based (e.g., management of natural and working lands) applications.

The 2022 Scoping Plan included Appendix D, Local Actions, which includes recommendations intended to build momentum for local government actions that align with the State’s climate goals, with a focus on local GHG reduction strategies (commonly referred to as climate action planning) and approval of new land use development projects, including through environmental review under CEQA. The recommendations provided in Appendix D are non-binding and should not be interpreted as a directive to local governments, but rather as evidence -based analytical tools to assist local governments with their role as essential partners in achieving California’s climate goals. Appendix D recognizes consistency with a CEQA-qualified GHG reduction plan such as a Climate Action Plan as a preferred option for evaluating potential GHG emission impacts under CEQA. Absent a qualified GHG reduction plan, Appendix D provides additional potential threshold options including key attributes that residential and mixed- use projects should ach ieve that would align with the State’s climate goals, a net -zero threshold, and use of air district recommended thresholds of significance.10
SB 605 and SB 1383. SB 605 (2014) required CARB to complete a comprehensive strategy to reduce emissions of short-lived climate pollutants in the state , and SB 1383 (2016) required CARB to approve and implement that strategy by January 1, 2018. The Short-Lived Climate Pollutants Reduction Strategy was approved by CARB in March 2017, and lays out a range of options to reduce short -lived climate pollutant emissions in California, including regulations, incentives, and other market -supporting activities. SB 1383 also establishes specific targets for t he reduction of short-lived climate pollutants (40% below 2013 levels by 2030 for CH4 and HFCs, and 50% below 2013 levels by 2030 for anthropogenic black carbon), and provides direction for reductions from dairy and livestock operations and landfills. Accordingly, and as mentioned above, CARB adopted its Short-Lived Climate Pollutant

10 The threshold approaches outlined in the 2022 Scoping Plan, Appendix D, are recommendations only and are not requirements; they do not supplant lead agencies’ discretion to develop their own evidence-based approaches for determining whether a project would have a potentially significant impact on GHG emissions.

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Reduction Strategy in March 2017. This strategy establishes a framework for the statewide reduction of emissions of black carbon, CH4, and fluorinated gases.

Building Energy
Title 24, Part 6. Title 24 of the California Code of Regulations was established in 1978 and serves to enhance and regulate California’s building standards. Although not initially promulgated to reduce GHG emissions, Part 6 of Title 24 specifically established Building Energy Efficiency Standards that are designed to ensure new and existing buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality. These energy efficiency standards are reviewed every few years by the Building Standards Commission and California Energy Commission (CEC), and revised if necessary (California Public Resources Code [PRC] Section 25402[b][1]). The regulations receive input from members of industry and the public, with the goal of “reducing of wasteful, uneconomic, inefficient, or unnecessary consumption of energy” (PRC Section 25402). These regulations are carefully scrutinized and analyzed for technological and economic feasibility (PRC Section 25402[d]) and cost effectiveness (PRC Sections 25402[b][2] and [b][3]). As a result, these standards save energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power plants, and help preserve the environment.

The 2022 Title 24 standards are the currently applicable building energy efficiency standards, and became effective on January 1, 2023. The 2022 Title 24 standards improve upon the 2019 standards for new construction of, and additions and alterations to, residential and nonresidential buildings. The CEC adopted the 2022 Title 24 Energy Code in August 2021 and the California Building Standards Commission approved incorporating the updated code into the California Building Standards Code (CALGreen) in December 2021. The 2022 Energy Code went into effect on January 1, 2023. The 2022 Energy Code focuses on four key areas in newly constructed homes and businesses:
▪ Encouraging electric heat pump technology for space and water heating, which consumes less energy and produces fewer emissions than gas-powered units.
▪ Establishing electric-ready requirements for single-family homes to position owners to use cleaner electric heating, cooking, and electric vehicle (EV) charging options whenever they choose to adopt those technologies. ▪ Expanding solar photovoltaic (PV) system and battery storage standards to make clean energy available onsite and complement the state’s progress toward a 100% clean electricity grid. ▪ Strengthening ventilation standards to improve indoor air quality.

Title 24, Part 11. In addition to the CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24) is commonly referred to as California’s Green B uilding Standards (CALGreen), and establishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requiremen ts), water conservation, material conservation, and interior air quality. The CALGreen standards took effect in January 2011 and instituted mandatory minimum environmental performance standards for all ground-up, new construction of commercial, low-rise residential and state-owned buildings, schools, and hospitals. The CALGreen 2022 standards, which are the current standards, became effective January 1, 2023.

Title 20. Title 20 of the California Code of Regulations requires manufacturers of appliances to meet state and federal standards for energy and water efficiency. Performance of appliances must be certified through the CEC to demonstrate compliance with standards. N ew appliances regulated under Title 20 include refrigerators,

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refrigerator-freezers, and freezers; room air conditioners and room air -conditioning heat pumps; central air conditioners; spot air conditioners; vented gas space heaters; gas pool heaters; plumbing fittings and plumbing fixtures; fluorescent lamp ballasts; lamps; emergency lighting; traffic signal modules; dishwaters; clothes washers and dryers; cooking products; electric motors; low voltage dry -type distribution transformers; power supplies; televisions and consumer audio and video equipment; and battery charger systems. Title 20 presents protocols for testing for each type of appliance covered under the regulations , and appliances must meet the standards for energy performance, energy design, water performance, and water design. Title 20 contains three types of standards for appliances: federal and state standards for federally regulated appliances, state standards f or federally regulated appliances, and state standards for non-federally regulated appliances.

AB 1109. Enacted in 2007, AB 1109 required the CEC to adopt minimum energy efficiency standards for general- purpose lighting to reduce electricity consumption by 50% for indoor residential lighting and by 25% for indoor commercial lighting.

SB 1. SB 1 (Murray) (August 2006) established a $3 billion rebate program to support the goal of the state to install rooftop solar energy systems with a generation capacity of 3,000 megawatts through 2016. SB 1 added sections to the Public Resources Code, inclu ding Chapter 8.8 (California Solar Initiative), that require building projects applying for ratepayer-funded incentives for photovoltaic systems to meet minimum energy efficiency levels and performance requirements. Section 25780 established that it is a goal of the state to establish a self -sufficient solar industry. The goals included establishing solar energy systems as a viable mainstream option for homes and businesses within 10 years of adoption, and placing solar energy systems on 50% of new homes within 13 years of adoption. SB 1, also termed “Go Solar California,” was previously titled “Million Solar Roofs.” California AB 1470 (Solar Water Heating). This bill established the Solar Water Heating and Efficiency Act of 2007.

AB 1470 makes findings and declarations of the Legislature relating to the promotion of solar water heating systems and other technologies that reduce natural gas demand. AB 1470 defines several terms for purposes of the act. The bill required a commission to evaluate the data available from a specified pilot program, and to design and implement a program of incentives for the installation of 200,000 solar water heating systems in homes and businesses throughout the state by 2017.

Renewable Energy and Energy Procurement
SB 1078 (2002) established the Renewables Portfolio Standard (RPS) program, which requires an annual increase in renewable generation by the utilities.

Under the program, a renewable electrical generation facility is one that uses biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small hydroelectric generation of 30 megawatts or less, digester gas, municipal solid w aste conversion, landfill gas, ocean wave, ocean thermal, or tidal current, and that meets other specified requirements with respect to its location.

SB 1368. SB 1368 (September 2006) required the CEC to develop and adopt regulations for GHG emission performance standards for the long -term procurement of electricity by local publicly owned utilities. These standards must be consistent with the standards adopted by the California Public Utilities Commission.

EO S-14-08. EO S-14-08 (November 2008) focused on the contribution of renewable energy sources to meet the electrical needs of California while reducing the GHG emissions from the electrical sector. This EO required that all

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retail suppliers of electricity in California serve 33% of their load with renewable energy by 2020. Furthermore, the EO directed state agencies to take appropriate actions to facilitate reaching this target. The California Natural Resources Agency (CNRA), through collaboration with the CEC and California Department of Fish and Wildlife (formerly the California Department of Fish and Game), was directed to lead this effort.

EO S-21-09 and SBX1-2. EO S-21-09 (September 2009) directed CARB to adopt a regulation consistent with the goal of EO S -14-08 by July 31, 2010. CARB was further directed to work with the California Public Utilities Commission and CEC to ensure that the regulation builds upon the RPS program and was applicable to investor - owned utilities, publicly owned utilities, direct access providers, and community choice providers. Under this order, CARB was to give the highest priority to those renewable resources that provide the greatest environmental benefits with the least environmental costs and impacts on public health and can be developed the most quickly in support of reliable, efficient, cost-effective electricity system operations. On September 23, 2010, CARB initially approved regulations to implement a Renewable Electricity Standard. However, this regulation was not finalized because of subsequent legislation (SB X1-2, Simitian, statutes of 2011) signed by Governor Brown in April 2011.

SB X1 2 expanded the Renewables Portfolio Standard by establishing a renewable energy target of 20% of the total electricity sold to retail customers in California per year by December 31, 2013, and 33% by December 31, 2020, and in subsequent years. Under the bill, a renewable electrical generation facility is one that uses biomass, solar thermal, photovoltaic, wind, geothermal, fuel cells using renewable fuels, small hydroelectric generation (30 megawatts or less), digester gas, municipal solid waste conversion, landfill gas, ocean wave, ocean thermal, or tidal current, and that meets other specified requirements with respect to its location.

SB X1-2 applies to all electricity retailers in the state including publicly owned utilities, investor -owned utilities, electricity service providers, and community choice aggregators. All of these entities must meet the renewable energy goals previously listed.

SB 350. SB 350 (October 2015, Clean Energy and Pollution Reduction Act) further expanded the RPS by establishing a goal of 50% of the total electricity sold to retail customers in California per year by December 31, 2030. In addition, SB 350 included the goal to double the energy efficiency savings in electricity and natural gas final end uses (e.g., heating, cooling, lighting, or class of energy uses on which an energy -efficiency program is focused) of retail custome rs through energy conservation and effic iency. The bill also requires the California Public Utilities Commission, in consultation with the CEC, to establish efficiency targets for electrical and gas corporations consistent with this goal. Regarding mobile sources, as one of its elements, SB 350 establishes a statewide policy for widespread electrification of the transportation sector, recognizing that such electrification is required for achievement of the state’s 2030 and 2050 reduction targets (see California Public Utilities Code Section 740.12).

SB 100. SB 100 (2018) increased the standards set forth in SB 350 establishing that 44% of the total electricity sold to retail customers in California per year by December 31, 2024, 52% by December 31, 2027, and 60% by December 31, 2030, be secured from qualifyin g renewable energy sources. SB 100 states that it is the policy of the state that eligible renewable energy resources and zero -carbon resources supply 100% of the retail sales of electricity to California. This bill requires that the achievement of 100% zero-carbon electricity resources do not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource shuffling.

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SB 1020. SB 1020 (September 2022) revises the standards from SB 100, requiring the following percentage of retail sales of electricity to California end-use customers come from eligible renewable energy resources and zero- carbon resources: 90% by December 31, 2035; 95% by December 31, 2040; and 100% by December 31, 2045.

Mobile Sources
State Vehicle Standards (AB 1493 and EO B -16-12). AB 1493 (July 2002) was enacted in a response to the transportation sector accounting for more than half of California’s CO2 emissions. AB 1493 required CARB to set GHG emission standards for passenger vehicles, light-duty trucks, and other vehicles determined by the state board to be vehicles that are primarily used for noncommercial personal transportation in the state. The bill required that CARB set GHG emission standards for motor vehicles manufactured in 2009 and all subsequent model years. CARB adopted the standards in September 2004. EO B -16-12 (March 2012) required that state entities under the governor’s direction and control support and facilitate the rapid commercialization of zero-emissions vehicles. It ordered CARB, CEC, California Public Utilities Commission, and other relevant agencies to work with the Plug -in Electric Vehicle Collaborative and the California Fuel Cell Partnership to establish benchmarks to help achieve benchmark goals by 2015, 2020, and 2025. On a statewide basis, EO B-16-12 established a target reduction of GHG emissions from the transportation sector equaling 80% less than 1990 levels by 2050. This directive did not apply to vehicles that have special performance requirements necessary for the protection of the public safety and welfare.

In March 2022, EPA reinstated California’s authority under the Clean Air Act to implement its own GHG emission standards and ZEV sales mandate. EPA’s action concludes its reconsideration of the 2019 SAFE-1 rule by finding that the actions taken under the previous administration as a part of SAFE -1 were decided in error and are now entirely rescinded.

Heavy Duty Truck and Bus Regulation. CARB adopted the final Heavy-Duty Truck and Bus Regulation on December 31, 2014, to reduce diesel particulate matter, a major source of black carbon, and oxides of nitrogen emissions from heavy-duty diesel vehicles (Cal. Code Regs. tit. 13, § 2025). The rule requires diesel particulate matter filters be applied to newer heavier trucks and buses by January 1, 2012, with older vehicles required to comply by January 1, 2015. The rule will require nearly all diesel trucks an d buses to be compliant with the 2010 model year engine requirement by January 1, 2023. CARB also adopted an Airborne Toxic Control Measure to limit idling of diesel-fueled commercial vehicles on December 12, 2013. This rule requires diesel -fueled vehicles with gross vehicle weights greater than 10,000 pounds to idle no more than 5 minutes at any location (Cal. Code Regs. tit. 13, § 2485).

EO S-1-07. Issued on January 18, 2007, EO S-1-07 sets a declining Low Carbon Fuel Standard for GHG emissions measured in CO2e grams per unit of fuel energy sold in California. The initial target of the Low Carbon Fuel Standard was to reduce the carbon intensity of California passenger vehicle fuels by at least 10% by 2020. The Low Carbon Fuel Standard was subsequently amended in 2018 to require a 20% reduction in carbon intensity by 2030. This new requirement aligns with the Calif ornia’s overall 2030 target of reducing climate changing emissions to 40% below 1990 levels by 2030, set by SB 32. CARB has adopted implementing regulations for both the 10% and 20% carbon intensity reduction targets.

SB 375. SB 375 (2008) addresses GHG emissions associated with the transportation sector through regional transportation and sustainability plans. SB 375 required CARB to adopt regional GHG reduction targets for the automobile and light -truck sector for 2020 and 2 035. Regional metropolitan planning organizations (MPOs) are then responsible for preparing a Sustainable Communities Strategy (SCS) within their Regional Transportation Plan

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(RTP). The goal of the SCS is to establish a forecasted development pattern for the region that, after considering transportation measures and policies, will achieve, if feasible, the GHG reduction targets. If an SCS is unable to achieve the GHG reduction target, a metropolitan planning organization must prepare an Alternative Planning Strategy demonstrating how the GHG reduction target would be achieved through alternative development patterns, infrastructure, or additional transportation measures or policies.

Pursuant to California Government Code Section 65080(b)(2)(K), a n SCS does not regulate the use of land; supersede the land use authority of cities and counties; or require that a city’s or county’s land use policies and regulations, including those in a general plan, be consistent with it. Nonetheless, SB 375 makes regional and local planning agencies responsible for developing those strategies as part of the federally required metropolitan transportation planning process and the state-mandated housing element process.

Advanced Clean Cars Program. The Advanced Clean Cars program (January 2012) is an emissions-control program for model years 2015 through 2025. The program combines the control of smog- and soot-causing pollutants and GHG emissions into a single coordinated package. The package includes elements to reduce smog -forming pollution, reduce GHG emissions, promote clean cars, and provide the fuels for clean cars. To improve air quality, CARB implemented new emission standards to reduce smog -forming emissions beginning with 2015 model year vehicles. It is estimated that by 2025, cars will emit 75% less smog-forming pollution than the average new car sold in 2012. To reduce GHG emissions, CARB, in conjunction with the EPA and NHTSA, adopted new GHG standards for model year 2017 to 2025 vehicles; the new standards are estimated to reduce GHG emissions by 34% in 2025.

The zero-emissions vehicle (ZEV) program will act as the focused technology of the Advanced Clean Cars program by requiring manufacturers to produce increasing numbers of ZEVs and plug-in hybrid electric vehicles in the 2018 to 2025 model years.

The ACC II program establishes the next set of LEV and ZEV requirements for model years after 2025 to contribute to meeting federal ambient air quality ozone standards and California’s carbon neutrality standards (CARB 2022c).

The ACC II rulemaking package also considers technological feasibility, environmental impacts, equity, economic impacts, and consumer impacts. The ACC II regulations were approved by the California Office of Administrative Law (OAL) and became effective on November 30, 2022.

AB 1236. AB 1236 (October 2015) (Chiu) required a city, county, or city and county to approve an application for the installation of electric vehicle charging stations, as defined, through the issuance of specified permits unless the city or county makes specified written findings based on substantial evidence in the record that the proposed installation would have a specific, adverse impact upon the public health or safety, and there is no feasible method to satisfactorily mitigate or avoid the specific, adverse impact. AB 1236 provided for appeal of that decision to the planning commission, as specified. The bill provided that the implementation of consistent statewide standards to achieve the timely and cost -effective installation of electric vehicle char ging stations is a matter of statewide concern. The bill required electric vehicle charging stations to meet specified standards. AB 1236 required a city, county, or city and county with a population of 200,000 or more residents to adopt an ordinance, by September 30, 2016, that created an expedited and streamlined permitting process for electric vehicle charging stations. The bill also required a city, county, or city and county with a population of fewer than 200,000 residents to adopt this ordinance by September 30, 2017.

EO N-79-20 (September 2020) requires CARB to develop regulations as follows: (1) Passenger vehicle and truck regulations requiring increasing volumes of new ZEVs sold in the State towards the target of 100% of in-State sales

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by 2035; (2) medium- and heavy-duty vehicle regulations requiring increasing volumes of new zero-emission trucks and buses sold and operated in the State towards the target of 100% of the fleet transitioning to zero -emission vehicles by 2045 everywhere feasible and for all drayage trucks to be zero emission by 2035; and (3) strategies, in coordination with other State agencies, the EPA and local air districts, to achieve 100% zero-emission from off-road vehicles and equipment operations in the State by 2035 . EO N -79-20 called for the development of a Zero - Emissions Vehicle Market Development Strategy, which was released February 2021, to be updated every 3 years, that ensures coordination and implementation of the EO and outlines actions to support new and used ZEV markets.

The primary mechanism for achieving the ZEV target for passenger cars and light trucks is the Advanced Clean Cars II (ACCII) Program, approved in August 2022. In addition to ACC II, the Clean Miles Standard regulation will also help enable the goal of 100% ZEV sales in 2035 by creating demand for ZEVs. This regulation will have aggressive requirements for electric miles that will transition ride -hailing fleets to zero -emission operations starting in 2023 and ramping up through 2030. This regulation was approved by CARB in 2021.

Advanced Clean Trucks (ACT) Regulation. The purpose of the ACT Regulation (June 2020) is to accelerate the market for zero-emission vehicles in the medium- and heavy-duty truck sector and to reduce emissions NOx, fine particulate matter, TACs, GHGs, and other criteria pollutants generated from on-road mobile sources (CARB 2022c). Requiring medium- and heavy-duty vehicles to transition to zero-emissions technology will reduce health risks to people living in and visiting California and is needed to help Cali fornia meet established near - and long-term air quality and climate mitigation targets.

EO B-16-12. EO B-16-12 (2012) directs state entities under the Governor’s direction and control to support and facilitate development and distribution ZEVs. On a statewide basis, EO B-16-12 also establishes a GHG emissions reduction target from the transportation sector equaling 80% less than 1990 levels by 2050. In furtherance of this executive order, the Governor convened an Interagency Working Group on ZEVs that has published multiple reports regarding the progress made on the penetration of ZEVs in the statewide vehicle fleet.

Water
SB X7-7/Water Conservation Act of 2009. This regulation required that all water suppliers increase their water use efficiency with an overall goal of reducing per capita urban water use by 20% by December 31, 2020. Each urban water supplier was required to develop water use targets to meet this goal.

EO B-29-15. In response to the ongoing drought in California, EO B -29-15 (April 2015) set a goal of achieving a statewide reduction in potable urban water usage of 25% relative to water use in 2013. The term of the executive order extended through February 28, 2016, although many of the directives have since become permanent water- efficiency standards and requirements. The executive order includes specific directives that set strict limits on water usage in the state. In response to EO B-29-15, the California Department of Water Resources modified and adopted a revised version of the Model Water Efficient Landscape Ordinance that, among other changes, significantly increased the requirements for landscape water use efficiency and broaden ed its applicability to include new development projects with smaller landscape areas.

EO B-37-16. Issued May 2016, EO B-37-16 directed the State Water Resources Control Board to adjust emergency water conservation regulations through the end of January 2017 to reflect differing water supply conditions across the state. The State Water Resources Control Board also developed a proposal to achieve a mandatory reduction of potable urban water usage that builds off the mandatory 25% reduction called for in EO B-29-15. The State Water

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Resources Control Board and Department of Water Resources will develop new, permanent water use targets that build on the existing state law requirements that the state achieve 20% reduction in urban water usage by 2020.

EO B -37-16 also specifies that the State Water Resources Control Board permanently prohibit water -wasting practices such as hosing off sidewalks, driveways, and other hardscapes; washing automobiles with hoses not equipped with a shut -off nozzle; using non -recirculated water in fountain s and other decorative water feature s; watering lawns in a manner that causes runoff, or within 48 hours after measurable precipitation; and irrigating ornamental turf on public street medians.

EO N-10-21. In response to a state of emergency due to severe drought conditions, EO N-10-21 (July 2021) called on all Californians to voluntarily reduce their water use by 15% from their 2020 levels. Actions suggested in EO N-10-21 include reducing landscape irrigation, running dishwashers and washing machines only when full, finding and fixing leaks, installing water-efficient showerheads, taking shorter showers, using a shut-off nozzle on hoses, and taking cars to commercial car washes that use recycled water.

Solid Waste
AB 939, AB 341, AB 1826, and SB 1383. In 1989, AB 939, known as the Integrated Waste Management Act (PRC Sections 40000 et seq.), was passed because of the increase in waste stream and decrease in landfill capacity.

The statute established the California Integrated Waste Management Board, which oversees a disposal reporting system. AB 939 mandated a reduction of waste being disposed of where jurisdictions were required to meet diversion goals of all solid waste through source reduction, recycling, and compo sting activities of 25% by 1995 and 50% by 2000.

AB 341 (Chapter 476, Statutes of 2011 [Chesbro]) amended the California Integrated Waste Management Act of 1989 to include a provision declaring that it is the policy goal of the state that not less than 75% of solid waste generated be source -reduced, recy cled, or composted by 2020, and annually thereafter. In addition, AB 341 required the California Department of Resources Recycling and Recovery (CalRecycle) to develop strategies to achieve the state’s policy goal. CalRecycle conducted several general stakeholder workshops and several focused workshops, and in August 2015 published a discussion document titled AB 341 Report to the Legislature, which identified five priority strategies that CalRecycle believed would assist the state in reaching the 75% goal by 2020, legislative and regulatory recommendations, and an evaluation of program effectiveness (CalRecycle 2015).

AB 1826 (Chapter 727, Statutes of 2014, effective 2016) requires businesses to recycle their organic waste (i.e., food waste, green waste, landscape and pruning waste, nonhazardous wood waste, and food -soiled paper waste that is mixed in with food waste) depending on the amount of waste they generate per week. This law also requires local jurisdictions across the state to implement an organic waste recycling program to divert organic waste generated by businesses, including multi -family residential dwelling s that consist of five or more units. The minimum threshold of organic waste generation by businesses decreases over time, which means an increasingly greater proportion of the commercial sector will be required to comply.

SB 1383 (Chapter 395, Statutes of 2016) establishes targets to achieve a 50% reduction in the level of the Statewide disposal of organic waste from the 2014 level by 2020 and a 75% reduction by 2025. CalRecycle was granted the regulatory authority required to achieve the organic waste disposal reduction targets and establishes an additional target that not less than 20% of currently disposed edible food is recovered for human consumption by 2025 (CalRecycle 2019).

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Other State Regulations and Goals
SB 97. SB 97 (Dutton) (August 2007) directed the Governor’s Office of Planning and Research to develop guidelines under CEQA for the mitigation of GHG emissions. In 2008, the Governor’s Office of Planning and Research issued a technical advisory as interim guidance regarding the analysis of GHG emissions in CEQA documents. The advisory indicated that the lead agency should identify and estimate a project’s GHG emissions, including those associated with vehicular traffic, energy consumption, water usage, and construction activities (OPR 2007). The advisory further recommended that the lead agency determine significance of the impacts and impose all mitigation measures necessary to reduce GHG emissions to a level that is less than significant. The CNRA adopted the CEQA Guidelines amendments in December 2009, which became effective in March 2010.

Under the amended CEQA Guidelines, a lead agency has the discretion to determine whether to use a quantitative or qualitative analysis or apply performance standards to determine the significance of GHG emissions resulting from a particular project (14 CCR 15064.4[a]). The CEQA Guidelines require a lead agency to consider the extent to which a project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]). The CEQA Guidelines also allow a lead agency to consider feasible means of mitigating the significant effects of GHG emissions, including reductions in emissions through the implementation of project features or off -site measures. The adopted amendments do not establish a GHG emissions threshold, instead allowing a lead agency to develop, adopt, and apply its own thresholds of significance or those developed by other agencies or experts. The CNRA also acknowledged that a lead agency may consider compliance with regulations or requirements implementing AB 32 in determining the significance of a project’s GHG emissions (CNRA 2009a).

With respect to GHG emissions, the CEQA Guidelines state in Section 15064.4(a) that lead agencies should “make a good faith effort, to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG emissions. The CEQA Guidelines note that an agency may identify emissions by either selecting a “model or methodology” to quantify the emissions or by relying on “qualitative analysis or other performance -based standards” (14 CCR 15064.4 [a]). Section 15064.4(b) states that the lead ag ency should consider the following when assessing the significance of impacts from GHG emissions on the environment: the extent a project may increase or reduce GHG emissions as compared to the existing environmental setting; whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project; and the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions (14 CCR 15064.4[b]).

EO S-13-08. EO Order S -13-08 (November 2008) is intended to hasten California’s response to the impacts of global climate change, particularly sea -level rise. Therefore, the executive order directs state agencies to take specified actions to assess and plan for such impacts. The final 2009 California Climate Adaptation Strategy report was issued in December 2009 (CNRA 2009b), and an update, Safeguarding California: Reducing Climate Risk, followed in July 2014 (CNRA 2014). To assess the state’s vulnerability, the report summarizes key climate change impacts to the state for the following areas: agriculture, biodiversity and habitat, emergency management, energy, forestry, ocean and coastal ecosystems and resources, public health, transportation, and water.

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3.2.3 Local

3.2.3.1 San Diego Association of Governments (SANDAG)
Regional Transportation Plan/Sustainable Communities Strategy The passage of SB 375 requires MPOs to prepare an SCS in their RTP. SANDAG serves as the MPO for the San Diego region and is responsible for developing and adopting a SCS that integrates transportation, land use, and housing to meet GHG reduction targets set by CARB. The RTP/SCS is updated every 4 years in collaboration the 18 cities and unincorporated County of San Diego, in addition to regional, state, and federal partners. The most recent, San Diego Forward: The 2021 Regional Plan was adopted in 2021 and provides guidance on meeting or exceed GHG targets through implementation of five key transportation strategies, including complete corridors, high-speed transit services, mobility hubs, flexible fleets, and a digital platform to tie the transportation system together. Through these strategies, the 2021 Regional Plan is projected to reduce per capita GHG emissions from cars and light-duty trucks to 20% below 2005 levels by 2035, exceeding the regions state-mandated target of 19% (SANDAG 2021).

3.2.3.2 City of Chula Vista
General Plan
The City of Chula Vista General Plan was updated by the City on December 13, 2005, and most recently amended in 2020. The General Plan provides a long-term strategy to address planning issues for the growth and development of the City and is composed of th e following six elements: land use and transportation, economic development, public facilities and services, growth management, environmental, and housing (City of Chula Vista 2005). The project site is located in the Bayfront Planning Area and Harbor Dist rict subarea of the General Plan (City of Chula Vista 2005). The goals and policies for improving air quality in the General Plan are as follows:

Land Use and Transportation Element
Policy LUT-23.1: Encourage the use of bicycles and walking as alternatives to driving.

Policy LUT-23.2: Foster the development of a system of inter-connecting bicycle routes throughout the City and region.

Policy LUT-23.5: Provide linkages between bicycle facilities that utilize circulation element alignments and open space corridors.

Policy LUT-23.8: Provide and maintain a safe and efficient system of sidewalks, trails, and pedestrian crossings.

Policy LUT -23.14: Require new development projects to provide internal bikeway systems with connections to the citywide bicycle networks.

Environmental Element
Policy E 6.1: Encourage compact development featuring a mix of uses that locate residential areas within reasonable walking distance to jobs, services, and transit.

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Policy E 6.2: Promote and facilitate transit system improvements in order to increase transit use and reduce dependency on the automobile.

Policy E 6.3: Facilitate the use of alternative fuel and low - and zero-emission vehicles and equipment in the community.

Policy E 6.9: Discourage the use of landscaping equipment powered by two-stroke gasoline engines within the City and promote less-polluting alternatives to their use.

Policy E 6.11: Develop strategies to minimize CO hot spots that address all modes of transportation.

Policy E 6.12: Promote clean fuel sources that help reduce the exposure of sensitive uses to pollutants.

Policy E 6.14: Transition the City fleet to 100% “clean” vehicles by integrating hybrid and alternative fuel vehicles as current municipal fleet vehicles are replaced.

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Policy E 6.B.1: Protect and develop shade tree cover along streets and within parking lots as a priority, particularly in new developments or tree-deficient areas.

Policy E 6.B.2: Preferentially plant female street trees to reduce pollen, especially in the most populated areas.

Policy E 6.B.3: Prioritize natural filtration, as opposed to impermeable hardscaping, within new development projects, along roadways, and adjacent to stream and river banks.

Policy E 6.B.4: Update the building code to support best practices in “green building” design, construction, and operations.

Policy E 6.B.5: Provide fast -track permitting for projects that implement “green building” design and construction.

Policy E 6.B.6: Encourage or require all new building construction to incorporate green roofs and encourage conversions of existing roof space to green roofs to reduce heat island effect.

Climate Action Plan
In September 2017, the City adopted its most recent Climate Action Plan (CAP). The CAP includes goals and policies to strengthen the City’s climate action efforts that have been underway since 2000. The City’s CAP identified a goal of reducing GHG emissions to 15% below 2005 emission levels by 2020 and 55 percent by 2030. The City’s implementation actions are focused on the following categories:
▪ Water Conservation and Reuse
▪ Waste Reduction
▪ Renewable and Efficient Energy
▪ Smart Growth and Transportation
Since the first GHG inventory in 1990 the City’s population has increased 84% but GHG emissions have only increased 42%, which has caused the per capita emissions to decrease 23% to 6.1 MT CO ₂e per person. CARB’s 2022 Scoping Plan has identified a goal of carbon neutrality by 2045 so the City will continue advancing to meet these ambitious goals. Notably, the City’s CAP is not considered a “qualified” CAP for tiering per CEQA Guidelines Section 15183.5 because it has not undergone environmental review.

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3.3 Significance Criteria and Methodology

3.3.1 Thresholds of Significance
CEQA Guidelines
The significance criteria used to evaluate the project’s GHG emissions impacts is based on the recommendations provided in Appendix G of the CEQA Guidelines. For the purposes of this GHG emissions analysis, the project would have a significant environmental impact if it would (14 CCR 15000 et seq.):

1. Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?

2. Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs? Global climate change is a cumulative impact; a project participates in this potential impact through its incremental contribution combined with the cumulative increase of all other sources of GHGs. There are currently no established thresholds for assessi ng whether the GHG emissions of a project, such as the project, would be considered a cumulatively considerable contribution to global climate change; however, all reasonable efforts should be made to minimize a project’s contribution to global climate cha nge. In addition, while GHG impacts are recognized exclusively as cumulative impacts (CAPCOA 2008) , GHG emissions impacts must also be evaluated on a project-level under CEQA.

With respect to GHG emissions, the CEQA Guidelines Section 15064.4(a) states that lead agencies “shall make a good-faith effort, based to the extent possible on scientific and factual data, to describe, calculate or estimate” GHG emissions resulting from a project. The CEQA Guidelines note that an agency has the discretion to either quantify a project’s GHG emissions or rely on a “qualitative analysis or performance -based standards” (14 CCR 15064.4[a]). A lead agency may use a “model or methodology” to estimate greenhouse gas emissions and has the discretion to select the model or methodology it considers “most appropriate to enable decision makers to intelligently take into account the project’s incremental contribution to climate change” (14 CCR 15064.4[c]). The CEQA Guidelines provide that the lead agency should consider the following when determining the significance of impacts from GHG emissions on the environment (14 CCR 15064.4[b]):

The extent a project may increase or reduce GHG emissions as compared to the existing environmental setting.

1. Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project.

2. The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.

In addition, the CEQA Guidelines specify that “[w]hen adopting or using thresholds of significance, a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies, or recommended by experts, provided the de cision of the lead agency to adopt such thresholds is supported by substantial evidence” (14 CCR 15064.7[c]).

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The extent to which a project increases or decreases GHG emissions in the existing environmental setting should be estimated in accordance with Section 15064.4, Determining the Significance of Impacts from Greenhouse Gas Emissions, of the State CEQA Guidelines. The State CEQA Guidelines indicate that when calculating GHG emissions resulting from a project, lead agencies shall make a good -faith effort based on scientific and factual data (Section 15064.4 (a)), and lead agencies have discretion to select the model or methodology deemed most appropriate for enabling decision makers to intelligently assess the project’s incremental contribution to climate change (Section 15064.4 (c)).

The State CEQA Guidelines do not indicate an amount of GHG emissions that constitutes a significant impact on the environment. Instead, they authorize the lead agency to consider thresholds of significance previously adopted or recommended by other public agencies or recommended by experts, provided the decision of the lead agency to adopt such thresholds is supported by substantial evidence (State CEQA Guidelines Sections 15064.4(a) and 15064.7(c)).

Governor’s Office of Planning and Research Guidance
The Governor’s Office of Planning and Research technical advisory titled, CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review, states that “public agencies are encouraged but not required to adopt thresholds of significance for environmental impacts. Even in the absence of clearly defined thresholds for GHG emissions, the law requires that such emissions from CEQA projects must be disclosed and mitigated to the extent feasible whenever the lead agency determines that the project contributes to a significant, cumulative climate change impact” (OPR 2018). Furthermore, the advisory document indicates that “in the absence of regulatory standards for GHG emissions or other scientific data to clearly define what constitutes a ‘significant impact,’ individual lead agencies may undertake a project-by-project analysis, consistent with available guidance and current CEQA practice” (OPR 2008).

SCAQMD Guidance
In October 2008, the SCAQMD proposed recommended numeric CEQA significance thresholds for GHG emissions for lead agencies to use in assessing GHG impacts of residential and commercial development projects as presented in its Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold (SCAQMD 2008). This guidance document, which builds on the previous guidance prepared by the California Air Pollution Control Officers Association, explored various approaches for establishing a significa nce threshold for GHG emissions. The draft interim CEQA thresholds guidance document was not adopted or approved by the Governing Board. However, in December 2008, the SCAQMD adopted an interim 10,000 MT CO 2e per-year screening level threshold for stationary source/industrial projects for which the SCAQMD is the lead agency (see SCAQMD Resolution No. 08-35, December 5, 2008).

The SCAQMD formed a GHG CEQA Significance Threshold Working Group to work with SCAQMD staff on developing GHG CEQA significance thresholds until statewide significance thresholds or guidelines are established. From December 2008 to September 2010, the SCAQMD hosted working group meetings and revised the draft threshold proposal several times, although it did not officially provide these proposals in a subsequent document. The SCAQMD has continued to consider adoption of significance thresholds for residenti al and general land use development projects. The most recent proposal, issued in September 2010 proposed the use of 3,000 MT CO 2e per year for mixed-use projects.

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In the absence of an adopted numerical threshold for the project region or by SCAQMD, the significance of the project- related GHG emissions can be determined by evaluating the project’s compliance with regulations or requirements adopted to implement statewide, regional, or local plans for the reduction or mitigation of GHG emissions.

Approach to Determining Significance
Given that neither the City, nor CARB, SDAPCD, nor SCAQMD have adopted a numerical threshold of significance for GHG emissions within the City or region, the approach for evaluating the project’s impacts related to GHG emissions relies on compliance with applicable plans, policies, or regulations adopted for the purposed of reducing the emissions of GHGs. The compliance evaluation is the sole basis for determining the significance of the project’s GHG-related impacts on the environment.

The significance of the project’s GHG impacts is based on the project’s compliance with statewide GHG reduction regulations and requirements. At the state level, guidance on reduction strategies for GHG emissions has been provided through the CARB Scoping Plans and at the local level through the SANDAG’s RTP/SCS and the City’s CAP and General Plan. Although the City’s most recent CAP adopted in 2017 is not qualified for tiering per CEQA Guidelines 15183.5, a project’s potential to conflict with the CAP is e valuated in the context of ensuring a project does not conflict with broad regional and state goals.

The Scoping Plan (approved by CARB in 2008 and updated in 2014, 2017, and 2022) provides a framework for actions to reduce California’s GHG emissions and requires CARB and other state agencies to adopt regulations and other initiatives to reduce GHGs. As discussed above, 2030 marks the next statutory statewide milestone target applicable to the proposed project. Given that the 2017 Scoping Plan is the Update developed for identifying how the state will achieve the 2030 reduction target, it is the most relevant plan for evaluating the project’s consistency with statewide GHG emission reduction strategies. The Scoping Plan is not directly applicable to specific projects, nor is it intended to be used for project-level evaluations.11 Under the Scoping Plan, however, there are several state regulatory measures aimed at the identification and reduction of GHG emissions. CARB and other state agencies have adopted many of the measures identified in the Scoping Plan. Most of these measures focus on area source emissions (e.g., energy usage, high-GWP GHGs in consumer products) and changes to the vehicle fleet (i.e., hybrid, electric, and more fuel-efficient vehicles) and associated fuels (e.g., Low Carbon Fuel Standard), among others.

CARB’s 2017 Scoping Plan specifically emphasizes the importance of reducing VMT of on -road vehicles to lower mobile-source GHG emissions to achieve statewide reduction targets. The 2017 Scoping Plan recommends a 15% reduction in total light-duty VMT from the business-as-usual scenario in 2050 in alignment with the Mobile Source Strategy (CARB 2017 and CARB 2021). CARB analysis on the relationship of VMT reductions to state climate goals found that certain land use development projects that have total VMT pe r capita of 14.3% lower than existing conditions, and light-duty VMT per capita of 16.8% lower than existing conditions could be considered consistent with transportation assumptions assumed for the 2017 Scoping Plan and with the state’s long -term (i.e., 2050) GHG reduction goals (CARB 2019). Per Section 15064.3 of the revised (2022) State of California Environmental Quality Act (CEQA) Guidelines, VMT is the most appropriate measure of transportation impacts, and is defined as the amount and distance of automobile traffic attributable to a project (OPR 2022). This methodology is consistent

11 The Final Statement of Reasons for the amendments to the State CEQA Guidelines reiterates the statement in the Initial Statement of Reasons that “[t]he Scoping Plan may not be appropriate for use in determining the significance of individual projects because it is conceptual at this stage and relies on the future development of regulations to implement the strategies identified in the Scoping Plan” (CNRA 2009).

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with the guidance provided in OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA, which assists with making significance determinations for transportation impacts in accordance with SB 743. Per the CEQA Guidelines, VMT is the most approp riate metric to ensure that transportation impacts from project -level environmental review under CEQA align with the state’s long-term GHG reduction goals (OPR 2018).

CARB adopted the 2022 Scoping Plan Update in May 2022 to discuss progress toward reaching the 2030 target and to address how the state will achieve carbon neutrality by 2045, as required by EO B -55-18. As the official guidance on approach to reaching the 2045 statewide goal, consideration of the 2 022 Plan is considered appropriate for evaluation of GHG emission impacts of the proposed Project.

In the 2022 Plan, CARB builds on and accelerates programs already in place to reduce anthropogenic sources of GHG emissions and introduces new strategies to capture and store carbon. Appendix D: Local Actions of the Draft Plan outlines local actions that residential and mixed-use projects can implement to address their largest sources of emissions including transportation electrification, VMT reduction, and building decarbonization. CARB identifies these three sources as “Priority Areas” given that they rep resent those with the highest GHG reduction potential and GHG reduction opportunities for which local governments and agencies have the most authority (CARB 2022b).

Importantly, the 2022 Update emphasizes that there is no realistic path to reaching the 2045 goal of carbon neutrality without removing and sequestering carbon from the atmosphere. So, in addition to programs that aim to reduce GHG emissions, the Draft Plan proposes strategies to capture and store carbon, highlighting the importance of nature-based solutions through preservation and climate smart management of the state’s natural and working lands (NWLs). Modeling conducted for the Draft Scoping Plan shows that California’s NWLs are projected to be a net source of emissions (i.e., releasing more CO2 emissions than they store) through 2045, which is historically due to human activities, such as land use change, and natural disturbances, such as wildfire. Therefore, the ability of the state’s NWLs to act as a net sink (i.e., sequester and store more at mospheric CO2 than they release) to help support the state’s carbon neutrality goals is dependent on climate smart land management.

If the project does not conflict with the regulations and actions outlined in the applicable state plans (i.e., City’s CAP, 2022 Scoping Plan, and local plans (i.e., S ANDAG RTP/SCS and City’s General Plan), the Project could appropriately rely on their use as showing compliance with performance -based standards adopted to fulfill the statewide goal for reducing GHG emissions. The project’s compliance with regulatory programs adopted by CARB, and other state and local agencies is therefore used to evaluate the significance of the project’s GHG emissions.

Nevertheless, and in accordance with Section 15064.4 of the State CEQA Guidelines, GHG emissions resulting from construction and operation of the project were quantitatively estimated. The project site consists of developed land occupied by the former Rohr Aircraft Facility and includes several industrial buildings historically used for manufacturing, warehousing, research and development, and related office uses . The potential impacts from project related GHG emissions were assessed based on the increase i n GHG emissions from the project by subtracting emissions from the existing land use that were in operation up until 2020 and form the baseline conditions. The City’s GHG inventories use 1990, 2005, and 2012 as recent inventory dates. The 2021 SANDAG RTP/SCS uses 2016 as a baseline year. CARB’s Scoping Plan is based on reducing 1990 emissions 40% by 2030.

The GHG emissions associated with implementation of the project were estimated using industry standard and accepted software tools, techniques, and emissi ons factors, as described below for construction and operation.

Estimation of emissions is for informational purposes only, for comparison with existing environmental conditions.

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3.3.2 Approach and Methodology

3.3.2.1 Construction
CalEEMod Version 2022.1 was used to estimate potential project generated GHG emissions during construction.

Construction of the project would result in GHG emissions primarily associated with use of off -road construction equipment, on-road hauling, and vendor (material delivery) trucks, and worker vehicles. All details for construction criteria air pollutants discussed in Section 2.3.3, are also applicable for the estimation of construction related GHG emissions.

As such, see Section 2.3.2 for a discussion of construction emissions calculation methodology and assumptions.

3.3.2.2 Operation
As with the air quality analysis, emissions from the operational phase of the project were estimated primarily using CalEEMod Version 2022.1 An operational year of 2030 was assumed consistent with completion of project construction.

Area Sources
CalEEMod was used to estimate operational GHG emissions from area sources, such as landscape maintenance equipment. Emissions associated with natural gas usage in space heating and water heating are calculated in the building energy use module of CalEEMod, as described in the following text.

Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chain saws, and hedge trimmers. The emissions associated from landscape equipment use are estimated based on Ca lEEMod default values for emission factors (grams per square foot of nonresidential building space per day) and number of summer days (when landscape maintenance would generally be performed) and winter days. For San Diego County, the average annual “summe r” days are estimated to 365 days; however, it is assumed that landscaping equipment would likely only operate during the week (not weekends), so operational days were assumed to be 180 days per year in CalEEMod (CAPCOA 2022).

Energy Sources
As represented in CalEEMod, energy sources include emissions associated with building electricity and natural gas usage (non-hearth). Electricity use would contribute indirectly to GHGs, since GHG emissions occur at the site of the power plant, which is typically off site. Annual natural gas (non -hearth) and electricity emissions were estimated in CalEEMod using the emission factors for San Diego Gas and Electric Company (SDG&E), which would be the energy source provider for the Project. SDG&E receives electric power from a variety of sources. In 2021,

44.5% of SDG&E’s power mix came from eligible renewable energy sources, including biomass/waste, geothermal, solar, and wind sources (SDG&E 2022).

In CalEEMod 2022, the default energy use from nonresidential land uses is based on 2019 consumption estimates from the CEC’s 2018-2030 Uncalibrated Commercial Sector Forecast (Commercial Forecast), and the energy use from residential land uses is based on the 2019 Residential Appliance Saturation Survey (RASS). The Commercial Forecast and RASS datasets derive energy intensities of different end use categories for different land use subtypes for electricity demand forecast zones (EDFZ) throughout the state. However, the energy use estimates are based on existing buildings and residences and are not representative of those constructed in compliance with energy

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efficiency requirements of the latest Title 24 Building Energy Efficiency Standards (e.g., the average residence surveyed in the RASS was constructed in 1974). Therefore, per Appendix D , Technical Source Documentation for Emissions Calculations, of the CalEEMod Version 2022.1 User Guide, “the default energy consumption estimates provided in CalEEMod based on the Commercial Forecast and RASS are very conservative, overestimating expected energy use compared to what would be expected for new buildings subject to the latest Energy Code with more stringent energy efficiency measures” (CAPCOA 2022).

Because the project may include refrigerated uses in the future, the industrial business park with commercial land uses were modeled with the energy estimates for a refrigerated warehouse, which represented a higher amount of energy use.

Mobile Sources
All details for criteria air pollutants discussed in Section 2.3.3 (Approach and Methodology, Operations subsection), are also applicable for the estimation of operational-related GHG emissions are also applicable for the estimation of operational mobile source GHG emissions. Regulatory measures related to mobile sources include AB 1493 (Pavley) and related federal standards. AB 1493 required that CARB establish GHG emission standards for automobiles, light- duty trucks, and other vehicles that are primarily used for noncommercial personal transportation in the state. In addition, the NHTSA and EPA have established corporate fuel economy standards and GHG emission standards, respectively, for automobiles and light-, medium , and heavy-duty vehicles. Implementation of these standards and fleet turnover (replacement of older vehicles with newer ones) will gradually reduce emissions from the Project’s motor vehicles. The effectiveness of fuel economy improvements was evaluated using the CalEEMod emission factors for motor vehicles in 2028 to the extent it was captured in CalEEMod 2022.1 which is based on EMFAC2021.

Water and Wastewater
Supply, conveyance, treatment, and distribution of water for the Project require the use of electricity, which would result in associated indirect GHG emissions. Similarly, wastewater generated by the project requires the use of electricity for conveyance and treatment, along with GHG emissions generated during wastewater treatment. The GHG emissions associated with Project water consumption were estimated using CalEEMod defaults.

Solid Waste
The Project would generate solid waste, and therefore, result in CO2e emissions associated with landfill off-gassing.

CalEEMod default values for solid waste generation were used to estimate GHG emissions associated with solid waste.

Refrigerants
Refrigerants are substances used in the equipment for air conditioning (A/C) and refrigeration. Most of the refrigerants used today are HFCs or blends thereof, which can have high GWP values. All equipment that uses refrigerants has a charge size (i.e. quantity of refrigerant the equipment contains) and an operational refrigerant leak rate, and each refrigerant has a GWP that is specific to that refrigerant. CalEEMod quantifies refrigerant emissions from leaks during regular operation and routine servicing over the equipment lifetime, and then derives average annual emissions from the lifetime estimates.

Refrigerant emissions are associated with buildings and mobile sources primarily from A/C usage.

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As noted previously, the project may include refrigerated uses in the future, as such the industrial business park with commercial land uses were modeled as refrigerated warehouses to account for additional refrigerant.

3.4 Impact Analysis

3.4.1 Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment, or would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
As discussed previously, the project’s compliance with regulatory programs adopted by CARB, and other state and local agencies is used to evaluate the significance of the project’s GHG emissions. The project’s potential to conflict with applicable GHG reduction plans is evaluated below.

Project Potential to Conflict with the City’s Climate Action Plan The City’s most recent CAP adopted in 2017 identified new goals and policies to strengthen the City’s past climate action planning efforts. While the CAP is not qualified for tiering per CEQA Guidelines Section 15183.5, a project’s potential to conflict with the CAP is evaluated in context of ensuring the project does not conflict with broad regional and state goals. In general, if a project implements all applicable measures of the CAP, then the project would be found to have a less than cumulatively considerable contribution to climate change impacts.

The proposed project’s potential to conflict with relevant CAP strategies is provided in Table 3 -3. As shown, the project would not conflict with all of the applicable CAP strategies designed to reduce GHG emissions within the City, including measures to reduce GHG emission from energy, transportation, water use, and solid waste generation during construction and operations.

Table 3-3. Project Potential to Conflict with City of Chula Vista Climate Action Plan Action Objective Reduction Strategy Potential to Conflict Water Conservation and
Reuse
Water Education and
Enforcement
Expand education and
enforcement (through
fines) targeting landscape
water waste.

Not applicable. This is a
City measure, however,
the project would not
impede City efforts
regarding education and
enforcement. The project
would be designed in
accordance with the
City’s Landscape Water
Conservation Ordinance.

Water Efficiency
Upgrades
Update the City’s
Landscape Water
Conservation Ordinance
to promote more water‐
Not applicable. This is a
City measure, however
the project would not
impeded the City’s efforts

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Table 3-3. Project Potential to Conflict with City of Chula Vista Climate Action Plan Action Objective Reduction Strategy Potential to Conflict wise landscaping
designs.
focused on water
efficiency upgrades. The
project would be
designed in accordance
with the City’s Landscape
Water Conservation
Ordinance.

Require water-savings
retrofits in existing
buildings at a specific
point in time (not point of
sale).

Not applicable. The
project would construct
new buildings on the
project site in Planning
Areas B-1 and B-2. Within
Planning Area A, the
project is incorporating
updates to the existing
building.

Water Reuse Plan and
System Installations
Develop a Water Reuse
Master Plan to maximize
the use of stormwater,
recycled water, and
onsite water reclamation.

Not applicable. This is a
City measure, however,
the project would not
impede the City’s efforts
in developing a water
reuse plan.

Streamline complex
graywater systems permit
review.

Not applicable. This is a
City measure, however,
the project would not
impede the City’s efforts
to streamline permitting.

Waste Reduction Zero Waste Plan Develop a Zero Waste
Plan to supplement
statewide green waste
recycling, and plastic bag
ban efforts.

Not applicable. This is a
City measure, however,
the project would not
impede the City’s efforts
to implement a Zero
Waste Plan. The project
would comply with
regulatory measures to
reduce waste during
construction and
operations.

Renewable and Efficient
Energy
Energy Education and
Enforcement
Expand education
targeting key community
segments (i.e., do-it-
yourself and Millennials)
and facilitating energy
performance disclosure
(i.e., Green Leases and
Home Energy Ratings).

Not applicable. This is a
City measure, however,
the project would not
impede the City’s efforts
to expand education and
enforcement.

Leverage the building
inspection process to
Not applicable. This is a
City measure, however,

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Table 3-3. Project Potential to Conflict with City of Chula Vista Climate Action Plan Action Objective Reduction Strategy Potential to Conflict distribute energy‐
related information and
to deter unpermitted, low
performing energy
improvements.
the project would not
impede the City’s efforts
to leverage the building
inspection process to
distribute energy-related
information.

Clean Energy Sources Incorporate solar
photovoltaic into all new
residential and
commercial buildings (on
a project-level basis).

Provide more grid‐
delivered clean energy
(up to 100%) through
Community Choice
Aggregation or other
mechanism.

No conflict. The project
would develop new
commercial buildings that
will comply with CalGreen
Standards for
photovoltaic systems.

Energy Efficiency
Upgrades
Expand the City’s “cool
roof” standards to include
re-roofs and western
areas.

Not applicable. This is a
City measure, however,
the project would not
impede the City’s efforts
regarding “cool roof”
standards.

Facilitate more energy
upgrades in the
community through tax
breaks, rebates, and
more local energy
efficiency programming.

Not applicable. This is a
City measure, however,
the project would not
impede the City’s efforts
in facilitating energy
upgrades in the
community.

Require energy‐savings
retrofits in existing
buildings at a specific
point in time (not at point
of sale).

Not applicable. The
project would construct
new buildings on the
project site in Planning
Areas B-1 and B-2. Within
Planning Area A, the
project is incorporating
updates to the existing
building.

Robust Urban Forests Plant more shade trees to
save energy, address
heat island issues, and
improve air quality.

No conflict. The project
would include new
landscaping in
accordance with Specific
Plan standards.

Smart Growth and
Transportation
Complete Streets and
Neighborhoods
Incorporate “Complete
Streets” principles into
the Bicycle and
Not applicable. This is a
City measure, however,
the project would not

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Table 3-3. Project Potential to Conflict with City of Chula Vista Climate Action Plan Action Objective Reduction Strategy Potential to Conflict Pedestrian Master Plans
and Capital Improvement
Program.
impede the City’s efforts
in developing “complete
streets”.

Encourage higher density
and mixed‐ use
development in Smart
Growth areas, especially
around trolley stations
and other transit nodes.

No conflict. The project
would develop more
robust uses on an
underutilized site in an
areas targeted for growth
by the City.

Transportation Demand
Management
Utilize bike facilities,
transit access/passes,
and other Transportation
Demand Management
and congestion
management offerings.

Not applicable. The
project would not impede
efforts to utilize bike,
transit, and other
Transportation Demand
Management measures.

Expand bike-sharing, car-
sharing, and other “last
mile” transportation
options.

Not applicable. The
project would not impede
efforts to expand bike-
sharing, car-sharing, and
other Transportation
Demand Management
options.

Alternative Fuel Vehicle
Readiness
Support the installation of
more local alternative
fueling stations and
designate preferred
parking for alternative
fuel vehicles.

Not applicable. The
project would not impede
efforts to install more
local alternative fueling
stations.

Designate preferred
parking for alternative
fuel vehicles.

Not applicable. The
project would not impede
efforts to designate
preferred parking for
alternative fuel vehicles.

Design all new residential
and commercial buildings
to be “Electric Vehicle
Ready.”
Consistent. The project
would comply with
CalGreen requirements
for provision of electric
vehicle charging
equipment.

Source: City of Chula Vista, 2017
Project Potential to Conflict with State Reduction Targets and CARB’s 20 22 Scoping Plan As discussed above, the California State Legislature passed AB 32 to provide initial direction to limit California’s GHG emissions to 1990 levels by 2020 and initiate the state’s long-range climate objectives. Since the passage of AB 32, the State has adop ted GHG emissions reduction targets for future years beyond the initial 2020 horizon year. CARB is required to develop the Scoping Plan, which provides the framework for actions to achieve the State’s

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GHG emission targets. While the Scoping Plan is not directly applicable to specific projects, nor is it intended to be used for project -level evaluations, it is the official framework for the measures and regulations that will be implemented to reduce Cali fornia’s GHG emissions in alignment with the adopted targets. Therefore, a project would be found to not conflict with the statutes if it would meet the Scoping Plan policies and would not impede attainment of the goals therein.

For the project, the relevant GHG emissions reduction targets include those established by SB 32 and AB 1279, which require GHG emissions be reduced to 40% below 1990 levels by 2030, and 85% below 1990 levels by 2045, respectively. In addition, AB 1279 requires the state achieve net zero GHG emissions by no later than 2045 and achieve and maintain net negative GHG emissions thereafter. CARB’s 2017 Scoping Plan update was the first to address the state’s strategy for achieving the 2030 GHG reduction target set forth in SB 32 (CARB 2017), and the most recent CARB 2022 Scoping Plan update outlines the state’s plan to reduce emissions and achieve carbon neutrality by 2045 in alignment with AB 1279 and assesses progress is making toward the 2030 SB 32 target (CARB 2022). As such, given that SB 32 and AB 1279 are the relevant GHG emission targets, the 2017 and 2022 Scoping Plan updates that outline the strategy to achieve those targets, are the most applicable to the Project.

The 2017 Climate Change Scoping Plan Update (Second Update) included measures to promote renewable energy and energy efficiency (including the mandates of SB 350), increase stringency of the Low Carbon Fuel Standard (LCFS), measures identified in the Mobile Source and Freight Strategies, measures identified in the proposed Short- Lived Climate Pollutant Plan, and increase stringency of SB 375 targets. The 2022 Scoping Plan for Achieving Carbon Neutrality (Third Update) builds upon and accelerates programs currently in place, including moving to zero- emission transportation; phasing out use of fossil gas use for heating homes and buildings; reducing chemical and refrigerants with high GWP; providing communities with sustainable options for walking, biking, and public transit; and displacement of fossil-fuel fired electrical generation through use of renewable energy alternatives (e.g., solar arrays and wind turbines) (CARB 2022).

Many of the measures and programs included in the Scoping Plan would result in the reduction of project-related GHG emissions with no action required at the project-level, including GHG emission reductions through increased energy efficiency and renewable energy production (SB 350), reduction in carbon intensity of transportation fuels (LCFS), and the accelerated efficiency and electrification of the statewide vehicle fleet (Mobile Source Strategy).

The 2045 carbon neutrality goal required CARB to expand proposed actions in the Third Update to include those that capture and store carbon in addition to those that reduce only anthropogenic sources of GHG emissions. The proposed project would support the state’s carbon neutrality goals, as implementation includes addition of urban- tree and native plantings throughout the project site, which represent opportunities for potential carbon removal and sequestration over the project life -time. However, the Thir d Update emphasizes that reliance on carbon sequestration in the state’s natural and working lands will not be sufficient to address residual GHG emissions, and achieving carbon neutrality will require research, development, and deployment of additional me thods to capture atmospheric GHG emissions (e.g., mechanical direct air capture). Given that the specific path to neutrality will require development of technologies and programs that are not currently known or available, the project’s role in supporting the statewide goal would be speculative and cannot be wholly identified at this time.

Table 3-4 evaluates the project’s potential to conflict with the measures from the 2022 Scoping Plan, that are relevant and applicable to the project.

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Table 3-4. Project Potential to Conflict with 2022 Scoping Plan Sector Action Potential to Conflict
GHG Emissions
Reductions Relative to
the SB 32 Target
40% below 1990 levels by 2030 No conflict. While the SB 32 GHG emissions reduction target is not an
Action that is analyzed independently, it is
included in Table 2-1 of the 2022 Scoping
Plan for reference. The project would not
obstruct or interfere with agency efforts to
meet the SB 32 reduction goal.

Specifically, the project would include
MM-AQ-4 and MM-AQ-6 which would
reduce GHG emissions from both onsite
and off-site mobile GHG sources.

Smart Growth/VMT VMT per capita reduced 25% below
2019 levels by 2030, and 30% below
2019 levels by 2045
No conflict. The project would not obstruct
or interfere with agency efforts to meet
this regional VMT reduction goal, including
through implementation of SB 375. The
project would be consistent with the
SANDAG 2021 Regional Plan, which is the
regional growth management strategy
that targets per capita GHG reduction
from passenger vehicles and light trucks
in the San Diego Region pursuant to SB
375.

Light-duty Vehicle (LDV)
Zero Emission Vehicles
(ZEVs)
100% of LDV sales are ZEV by 2035 No conflict. As this action pertains to LDV sales within California, the project would
not obstruct or interfere with its
implementation. Furthermore, the project
would support the transition from fossil
fuel LDV to ZEV through its provision of EV
chargers.

Truck ZEVs 100% of medium-duty vehicle (MDV)/
heavy-duty vehicle (HDV) sales are ZEV
by 2040
No conflict. As this action pertains to MDV
and HDV sales within California, the
project would not obstruct or interfere
with its implementation. Furthermore, the
project would comply with the 2022
CALGreen code.

Electricity Generation Sector GHG target of 38 million metric tons of carbon dioxide equivalent
(MMTCO2e) in 2030 and 30 MMTCO2e
in 2035
Retail sales load coverage1
20 gigawatts (GW) of offshore wind by
2045
Meet increased demand for
electrification without new fossil gas-
fired resources
No conflict. As this action pertains to the
statewide procurement of renewable
energy, the project would not obstruct or
interfere with its implementation.

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Table 3-4. Project Potential to Conflict with 2022 Scoping Plan Sector Action Potential to Conflict
New Residential and
Commercial Buildings
All electric appliances beginning 2026
(residential) and 2029 (commercial),
contributing to 6 million heat pumps
installed statewide by 2030
No conflict. The project would not obstruct
or interfere with CARB’s efforts to meet
the all-electric appliance and heat pump
goals. As designed, the project would
currently involve connecting the proposed
buildings to the existing natural gas
infrastructure. However, the project would
comply with regulations to convert to all-
electric if applicable.

Construction
Equipment
25% of energy demand electrified by
2030 and 75% electrified by 2045
No conflict. As this action pertains to the
electrification of off-road equipment
across California, the project would not
obstruct or interfere with its
implementation. However, the project
would support the action through MM-AQ-
2 and MM-AQ-4, which require the use of
specific electric construction equipment
and cargo handling equipment,
respectively.

Low Carbon Fuels for
Transportation
Biomass supply is used to produce
conventional and advanced biofuels, as
well as hydrogen
No conflict. The project would not obstruct
or interfere with CARB’s efforts to
increase the provision of low carbon fuels
for transportation. The development and
use of biofuels in trucks and automobiles
would occur at the state and regional
level. PDF-GHG-1 also includes a leasing
preference for tenants with a facility
owned fleet that utilizes alternative and or
zero emission vehicles.

Low Carbon Fuels for
Buildings and Industry
In 2030s biomethane blended in
pipeline
Renewable hydrogen blended in fossil
gas pipeline at 7% energy (~20% by
volume), ramping up between 2030
and 2040
In 2030s, dedicated hydrogen pipelines
constructed to serve certain industrial
clusters
No conflict. The project would not obstruct
or interfere with CARB’s efforts to
increase the provision of low carbon fuels
for use in buildings and industry. The
blending of biomethane and use of
renewable hydrogen in existing natural
gas pipelines would happen at the scale
of the utility provider and without action
required by the project.

High GWP Potential
Emissions
Low GWP refrigerants introduced as
building electrification increases,
mitigating HFC emissions
No conflict. The project would not obstruct
or interfere with agency efforts to
introduce low GWP refrigerants. The State
has established a prohibition on the sale
or distribution of bulk HFCs identified as
having a high GWP through SB 1206.

Source: CARB 2022b.

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Based on the analysis in Table 3-4, the project would not conflict with the applicable strategies and measures in the 2022 Scoping Plan.

Consistency with SB 32 and 2017 Scoping Plan.

Table 3-5 highlights measures that have been developed under the 2017 Scoping Plan and presents the project’s potential to conflict with the applicable 2017 Scoping Plan measures. The project would comply with all regulations adopted in furtherance of the Scoping Plan to the extent required by law and to the extent that they are applicable to the project.

Table 3-5. Project Potential to Conflict with 2017 Scoping Plan GHG Emission Reduction Strategies
Scoping Plan Measure
Measure
Number Potential to Conflict
Transportation Sector
Advanced Clean Cars T-1 No conflict. The project would not obstruct or interfere with CARB’s efforts to implement this
measure because the project’s employees and
customers would purchase vehicles in
compliance with CARB vehicle standards that
are in effect at the time of vehicle purchase.

Low Carbon Fuel Standard T-2 No conflict. The project would not obstruct or interfere with CARB’s Low Carbon Fuel
Standard because motor vehicles driven by the
Project’s employees and customers would use
compliant fuels.

Last-Mile Delivery N/A No conflict. The project would not obstruct or interfere with CARB’s efforts to implement this
measure. Per PDF-GHG-1, leasing preference
would be given to tenants with facility owned
fleets that utilizes alternative and or zero
emission vehicles. This measure would help to
reduce GHG and air pollutant emissions
associated with the last-mile of goods delivery.

Reduction in VMT N/A No conflict. The project would not prevent CARB from implementing this measure.

Additionally, the project would support this
measure through siting of an employment-rich
development in a housing-rich community. The
provision of employment opportunities in a
housing-rich area (where many of the City’s
residents have to leave the City for work) would
help to lower the VMT per employee.

Goods Movement Efficiency Measures

1. Port Drayage Trucks

2. Transport Refrigeration Units Cold Storage
Prohibition
T-6 No conflict. The project would not prevent
CARB from implementing this measure.

Furthermore, per MM-AQ-4, the project would
include all-electric cargo handling equipment,
including yard trucks and forklifts. The project

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Table 3-5. Project Potential to Conflict with 2017 Scoping Plan GHG Emission Reduction Strategies
Scoping Plan Measure
Measure
Number Potential to Conflict

3. Cargo Handling Equipment, Anti -Idling,
Hybrid, Electrification

4. Goods Movement Systemwide Efficiency
Improvements

5. Commercial Harbor Craft Maintenance and
Design Efficiency

6. Clean Ships

7. Vessel Speed Reduction
would also include anti-idling measures,
including increased signage on site and
training of logistic staff to reduce trucking
queuing times on site per PDF-GHG-1. The
project would not prevent CARB or other
agencies from implementing the other
measures related to Goods Movement.

Heavy-Duty Vehicle GHG Emission Reduction
▪ Tractor-Trailer GHG Regulation
▪ Heavy-Duty Greenhouse Gas Standards for
New Vehicle and Engines (Phase I)
T-7 No conflict. The project would not obstruct or
interfere with agency efforts to implement this
measure. The Tractor Trailer GHG regulation
and Heavy-Duty Truck GHG standards set GHG
emission standards for truck engines for a
given model year. Phase I sets GHG emission
and fuel economy standards for heavy-duty
trucks for model years 2014–2018. Phase II
sets standards for model years for 2019–
2027. Over the life of the project, the truck
fleet would turn over and utilize newer engines
with stricter emissions standards. Additionally,
as a part of PDF-GHG-1, the project would
include a leasing preference for tenants that
utilize a truck fleet that includes
alternative/zero-emissions vehicles.

Medium and Heavy-Duty GHG Phase 2 N/A No conflict. The measure sets GHG emission and vehicle fuel standards model years 2018-
2027 for certain trailers and model years
2021-2027 for semi-trucks, large pickup
trucks, vans, and all types and sizes of buses
and work trucks. Over the life of the project,
the truck fleet would turn over and utilize
newer engines with stricter emissions
standards. Additionally, as a part of PDF-GHG-
1, preference for tenants that utilize a truck
fleet that includes alternative/zero-emissions
vehicles.

Electricity and Natural Gas Sector
Energy Efficiency Measures (Electricity) E-1 No conflict. The project would be constructed in accordance with the CALGreen code and
Title 24 building standards. Title 24
requirements for non-residential projects include
high efficiency indoor and outdoor lighting
requirements, thermostat, and HVAC energy

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Table 3-5. Project Potential to Conflict with 2017 Scoping Plan GHG Emission Reduction Strategies
Scoping Plan Measure
Measure
Number Potential to Conflict
efficiency requirements, and electrical metering
requirements. Additionally, per PDF-GHG-2, the
project would provide a minimum 3% of the
total roof area for photovoltaic arrays at
building construction for industrial/warehouse
buildings. All other proposed land uses shall
provide a minimum 10% of the total roof area
for photovoltaic arrays at building construction.
also go beyond what is required by Title 24
building standards to include on site solar
photovoltaic system that would cover 25% of
the total roof area and could be expanded to
50% of the total roof area at later date.

Energy Efficiency (Natural Gas) CR-1 No conflict. The project would be constructed in accordance with the CALGreen code and
Title 24 building standards.

Renewables Portfolio Standard (33% by 2020) E-3 No conflict. The project would procure electricity from SDG&E, which is in compliance
with the Renewables Portfolio Standard for
2020.

Renewables Portfolio Standard (50% by 2050) N/A No conflict. The project would procure electricity from SDG&E, which is on trajectory
to be compliance with the Renewables
Portfolio Standard for 2050.

Water Sector
Water Use Efficiency W-1 No conflict. The project would be constructed in accordance with CALGreen and Title 24
building standards. The CALGreen standards
require that plumbing fixtures do not exceed
the established flow rates. The CALGreen
standards also outline requirements for water-
efficient landscaping design. Per PDF-GHG-2,
the project would include a plant palette
emphasizing drought-tolerant plants and use of
water-efficient irrigation techniques.

Green Building Standards Code (Greening New
Public Schools, Residential and Commercial
Buildings)
GB-1 No conflict. The project would be constructed
in accordance with CALGreen and Title 24
building standards. Title 24 requirements for
non-residential projects include high efficiency
indoor and outdoor lighting requirements,
thermostat and HVAC energy efficiency
requirements, and electrical metering
requirements. Additionally, per PDF-GHG-2, the
project would provide a minimum 3% of the
total roof area for photovoltaic arrays at

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Table 3-5. Project Potential to Conflict with 2017 Scoping Plan GHG Emission Reduction Strategies
Scoping Plan Measure
Measure
Number Potential to Conflict
building construction for industrial/warehouse
buildings. All other proposed land uses shall
provide a minimum 10% of the total roof area
for photovoltaic arrays at building construction.
also go beyond what is required by Title 24
building standards to include on site solar
photovoltaic system that would cover 25% of
the total roof area and could be expanded to
50% of the total roof area at later date. The
CALGreen standards require that plumbing
fixtures do not exceed the established flow
rates. The CALGreen standards also outline
requirements for water efficient landscaping
design. Per PDF-GHG-2, the project would
include a plant palette emphasizing drought-
tolerant plants and use of water-efficient
irrigation techniques.

Source: CARB 2014, 2017.

Notes: GHG = greenhouse gas; CARB = California Air Resources Board; SDG&E = San Diego Gas & Electric ; VMT = vehicle miles traveled; SB = Senate Bill; N/A = not applicable; SF6 = sulfur hexafluoride.

Based on the analysis in Table 3-5, the project would not conflict with the applicable strategies and measures in the 2017 Scoping Plan.

Consistency with AB 32 and 2008 Scoping Plan.

The project would not conflict with the applicable statewide regulatory programs designed to reduce GHG emissions consistent with AB 32, as described in Table 3-6.

Table 3-6. Consistency with Assembly Bill 32 Regulatory Programs Regulatory Program Potential to Conflict
Construction
CARB In-Use Off-Road Regulation No conflict. Off-road equipment used for construction of the project will utilize equipment in compliance with CARB Airborne Toxic Control Measures.

Mobile Sources
California Assembly Bill 1493
(Pavley Standards)
No conflict. This regulatory program applies to vehicle manufacturers, and not directly to land use development. However, the vehicles operated by future occupants of and visitors to the project would benefit from and be consistent with this regulatory program in the form of reduced GHG emissions from the vehicle fleet for model years 2017 through 2025.

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Table 3-6. Consistency with Assembly Bill 32 Regulatory Programs Regulatory Program Potential to Conflict
Advanced Clean Cars Program No conflict. This regulatory program applies to vehicle manufacturers, and not directly to land use development. However, the vehicles operated by future occupants of and visitors to the project would benefit from and be consistent with this regulatory program in the form of reduced GHG emissions from the vehicle fleet for model years 2017 through 2025.

Low Carbon Fuel Standard Regulation No conflict. This regulatory program applies to fuel suppliers, and not directly to land use development. However, the vehicles operated by future occupants of and visitors to the Project would benefit from and be consistent with this regulatory program in the form of reduced GHG emissions from the vehicle fleet.

Heavy-Duty Vehicle GHG Emission
Reduction Regulation
No conflict. This regulatory program is intended to reduce fuel use and GHG emissions from medium- and heavy-duty vehicles, semi-trucks, pickup trucks and vans, and all types and sizes of work trucks and buses in between. The project construction and operational analysis includes the benefit of reductions from these programs.

CARB In-Use On-Road Heavy-Duty
Diesel Vehicles Regulation
No conflict. This regulatory program applies to vehicle manufacturers, and not directly to land use development. However, the vehicles operated during project construction and operations would benefit from and be consistent with this regulatory program in the form of reduced GHG emissions from the vehicle fleet.

Energy Use
California Title 20 Standards
Appliance Energy Efficiency Standards
No conflict. The project would result in new land use development that would be outfitted with appliances that comply with the CEC’s Title 20 standards.

California Title 24, Part 6 Standards
Building Energy Efficiency Standards
No conflict. The project will design and construct buildings in compliance with the CEC’s 2022 Title 24 standards. Title 24 requirements for non-residential projects include high efficiency indoor and outdoor lighting requirements, thermostat, and HVAC energy efficiency requirements, and electrical metering requirements.

Additionally, per PDF-GHG-2, the project would provide a minimum 3% of the total roof area for photovoltaic arrays at building construction for industrial/warehouse buildings. All other proposed land uses shall provide a minimum 10% of the total roof area for photovoltaic arrays at building construction. also go beyond what is required by Title 24 building standards to include on site solar photovoltaic system that would cover 25% of the total roof area and could be expanded to 50% of the total roof area at later date.

California Title 24, Part 11 Standards
Green Building Standards Code
No conflict. The development proposed by the project would comply with the CALGreen Code. The CALGreen Code requires that plumbing fixtures do not exceed the established flow rates outlined in Section

4.2.2. The CALGreen standards also outline requirements for water efficient landscaping design. Per PDF-GHG-2, the project would include a plant palette emphasizing drought-tolerant plants and use of water-efficient irrigation techniques.

California Senate Bill X1-2
Renewable Portfolio Standards
No conflict. This regulatory program applies to investor-owned utilities, electric service providers, and community choice aggregators, and not

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Table 3-6. Consistency with Assembly Bill 32 Regulatory Programs Regulatory Program Potential to Conflict
directly to land use development. However, the project would benefit from and be consistent with this regulatory because electricity would be purchased from SDG&E, which is required to procure 45% and 50% of retail sales from renewable energy resources by 2027 and 2030, respectively.

Water Supply, Treatment and Distribution
Senate Bill X7-7
Water Use Efficiency Program
No conflict. This regulatory program is implemented through the California Department of Water Resources and urban water suppliers, not land use developers. The project would be consistent with water conservation objectives through use of the latest water-efficiency technologies, including those relating to water-conserving plumbing fixtures, weather-sensitive irrigation controls, drought-tolerant landscaping palette.

Executive Order B-29-15 No conflict. Mandatory water reductions are implemented via EO B- 29-15 and a regulatory framework developed by the State Water Resources Control Board. These regulatory programs apply to urban water suppliers, not land use developers. The project would be consistent with water conservation objectives through use of the latest water-efficiency technologies, including those relating to water- conserving plumbing fixtures, weather-sensitive irrigation controls, drought-tolerant landscaping palettes...

California Title 24, Part 11 Standards
Green Building Standards Code
No conflict. The project would be required to comply with the CALGreen Code. The use of water saving design elements (such as water-efficient toilets/urinals and faucets) will allow the project to comply with the required 20% reduction in indoor potable water use.

Source: CARB 2008.

Notes: CARB = California Air Resources Board; GHG = greenhouse gas; CEC = California Energy Commission; CALGreen = California Green Building Standards; SDG&E = San Diego Gas & Electric.

Based on the analysis in Table 3-6, the project would not conflict with AB 32 Regulatory Programs.

Project Potential to Conflict with SANDAG RTP/SCS
At the regional level, the SANDAG’s RTP/SCS has been adopted for the purpose of reducing GHG emissions attributable to passenger vehicles in the San Diego region. In October 2015, SANDAG adopted its Regional Plan, which was subsequently updated in 2021.

The 2021 Regional Plan identifies the following ten Implementation Actions designed as specific steps taken to bring projects, polices, and programs to reality, and each one supports the 2021 Regional Plan’s defined strategies.

1. Apply the Social Equity Planning Framework and ensure that equity is considered throughout 2021 Regional Plan implementation.

2. Develop Comprehensive Multimodal Corridor Plans (CMCPs) to refine 2021 Regional Plan projects at the corridor level and qualify the region for future funding opportunities.

3. Update SANDAG policies, including the TransNet Ordinance, to reflect 2021 Regional Plan projects and priorities.

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4. Evaluate the transition to free public transit and develop a Value Pricing and User Fee Implementation Strategy.

5. Seek new local funding in addition to pursuing state and federal funding opportunities.

6. Advance the Next Operating System (Next OS) by preparing technical and planning studies and initiating pilot opportunities.

7. Implement the Regional Transportation Improvement Program (RTIP) and near-term projects.

8. Partner with local jurisdictions, tribal governments, agencies in Mexico, the military, and other agencies on collaborative efforts to implement the 2021 Regional Plan.

9. Expand regional programs and seek funding to fully support low-carbon transportation options, roadway safety and maintenance, habitat conservation, and nature-based climate solutions.

10. Advance a data science program to better understand travel behavior in the region, update travel demand modeling tools, and improve transparency and reporting on program effectiveness and project delivery.

Eleven policy and program areas are identified within the 2021 Regional Plan that support the ten priority Implementation Actions. These eleven policy and program areas are provided in Table 3-7 with analysis of the project consistency and represents the Project’s potential to conflict with the SANDAG 2021 Regional Plan.

Table 3-7. Project Consistency with SANDAG 2021 Regional Plan Programs, Planning,
and Policies Implementation Actions
Potential to Conflict
Land Use and Habitat The 2021 Regional Plan vision for land use focuses on development and growth in
Mobility Hub areas to preserve the region’s
habitat and open space while supporting
transportation investments and reducing
VMT. SANDAG will leverage partnerships with
cities and the county through the Smart
Growth Incentive Program and other grant
programs to provide funds for transportation-
related improvements and planning efforts
that support smart growth in Mobility Hubs.

No conflict. The proposed project
is in a Transit Priority Areas
identified for 2025, 2035, and
2050 in the 2021 Regional Plan.

The project is also in an identified
employment center where growth
should be targeted.

Housing
The 2021 Regional Plan addresses the
housing crisis through Mobility Hubs,
bringing locations where people live and
work closer together and providing more
housing options for more San Diegans
through increased density. SANDAG will rely
on building stronger partnerships with local
jurisdictions to increase housing in the
region, especially housing available to low-
income residents.

No conflict. The project does not
include housing, however, the
project is in an area identified as
an employment center by the
Regional Plan.

Climate Action Planning
To help reach regional and state greenhouse
gas (GHG) emissions–reduction targets, the
2021 Regional Plan focuses heavily on the
conversion to clean transportation and a
shift from personal vehicle dependency
through the 5 Big Moves. To help local
No conflict. This action is not
within the purview of this project
and is instead directed towards
local governments and those
preparing plans for local
jurisdictions. Implementation of

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Table 3-7. Project Consistency with SANDAG 2021 Regional Plan Programs, Planning,
and Policies Implementation Actions
Potential to Conflict
jurisdictions make this transition and
achieve broader reductions in GHG
emissions, SANDAG will provide technical
assistance, guidance resources, templates,
and grant funding to incorporate the 5 Big
Moves and Sustainable Communities
Strategy actions into their climate action
plans (CAP) and plan for more well-
connected, sustainable, healthy
communities that are accessible to all.
the proposed project would not
prevent SANDAG from providing
the expressed guidance and
resources for incorporating the 5
Big Moves and SCS actions into
local CAPs.

Climate Adaptation and
Resilience
The 2021 Regional Plan aims to better
prepare San Diego communities and
habitats for these climate change impacts by
considering evacuation and rapid mobility
needs in our transit corridors, evaluating and
considering climate vulnerabilities to the
region’s transportation infrastructure, and
using natural lands and conservation to
absorb and protect against climate change
impacts. SANDAG will establish a
coordinated effort across agencies and local
jurisdictions for a more holistic,
comprehensive, equitable, sustainable, and
resilient region.

No conflict. The proposed project
is being developed on existing
underdeveloped land and will not
convert any natural working
lands.

Electric Vehicles
Electrification is included in the 2021
Regional Plan as a way to reach regional
greenhouse gas (GHG) emission–reduction
targets. Electric vehicles (EVs) are zero-
emission vehicles that include plug-in battery
EVs and hydrogen fuel cell EVs. SANDAG
aims to incentivize and encourage the
incorporation of all types of EVs into Flexible
Fleets, Transit Leap, and goods movement
and to support funding programs that
increase the number of EVs and charging
stations throughout the region and within
Mobility Hubs and as part of the Complete
Corridor strategy.

No conflict. The Proposed Project
would include electric vehicle
charging infrastructure required
by the most recent CalGreen
standards.

Parking and Curb
Management
The 2021 Regional Plan promotes policies
that use land more efficiently and encourage
people to consider switching from driving
alone to walking, biking, taking transit,
carpooling, and using shared mobility.

Effective parking-management policies
include reduced parking requirements,
including near transit, unbundling parking
from housing costs, and parking cash-out
No conflict. The project is located
in a Transit Priority Area within
1,000 feet of the H Street Transit
Station. In addition, according to
SANDAG’s VMT Screening Map,
the project is in a VMT-efficient
area.

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Table 3-7. Project Consistency with SANDAG 2021 Regional Plan Programs, Planning,
and Policies Implementation Actions
Potential to Conflict
incentives for employees that commute to
work without personal vehicles.

Transportation Demand
Management
Transportation Demand Management (TDM)
innovations have the potential to transform
the way people travel within and between
communities. Managing demands on the
existing transportation system is a vital
strategy for making the overall system more
effective in reducing drive-alone commute
trips. SANDAG will continue to administer
and monitor the iCommute program by
providing regional rideshare, employer
outreach, and bike education and secure
parking services to help reduce commute-
related traffic congestion and vehicle miles
traveled.

No conflict. The project is located
in a Transportation Priority Area
near the H Street Transit Station
within a VMT-efficient area. The
proposed project is in census
tract 12600. The SANDAG
average VMT per employee is

18.90 and the threshold of 85
percent would be 16.06 VMT per
employee or below. The average
VMT per employee of this tract is

15.91, which is below the
regional average VMT per
employee of 18.90 as well as
below the VMT per employee
threshold (i.e. 85 percent of the
reginal mean) of 16.06.

Vision Zero
Vision Zero is a national campaign to
eliminate all traffic-related deaths and
serious injuries by focusing on policies and
the redesign of streets to create a
transportation system that is safe for
everyone. In adopting Vision Zero, SANDAG
will work toward Zero by collecting and
analyzing crash data to identify safety issues
and recommend solutions; developing a
regional safety policy; continuing to construct
the Regional Bike Network; working with
local jurisdictions to conduct outreach for
and build out their complete streets
networks; and funding educational
programs, including opportunities to
collaborate with tribal nations.

No conflict. This action is not
within the purview of this project
and is instead directed towards
SANDAG to prepare and
implement a regional safety
policy and to coordinate with local
jurisdictions to provide resources
and assistance on safe roadway
design. Implementation of the
proposed project would not
prevent SANDAG from providing
the expressed guidance and
resources for Vision Zero
planning efforts.

Fix It First
To optimize investments in the region’s
transportation infrastructure, the Regional
Plan and the 5 Big Moves focus on improving
upon existing roads, rails, and sidewalks.

The Fix It First strategy aims to repair existing
roads and create a system for sustained
maintenance in the future, creating a safe
and efficient transportation network for all
users.

No conflict. This action is not
within the purview of this Project
and is instead aimed at repair
and maintenance of the regional
transportation system.

Implementation of the Proposed
Project would not prevent
SANDAG from improving the
existing roads, rails, and
sidewalks.

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Table 3-7. Project Consistency with SANDAG 2021 Regional Plan Programs, Planning,
and Policies Implementation Actions
Potential to Conflict
Transportation System
Management and
Operations
Transportation System Management and
Operations (TSMO) employs a series of
intelligent transportation system strategies
designed to maximize the capacity and
efficiency of the existing and future
transportation system. TSMO includes the
establishment of institutional and
governance actions to help advance and
facilitate cross-agency collaboration to
ensure existing and proposed transportation
systems are not operated or managed as
independent systems but as a multimodal
transportation system.

No conflict. This action is not
within the purview of this project
and is instead directed towards
SANDAG to develop the TSMO
through cross-agency
collaboration. Implementation of
the proposed project would not
prevent SANDAG from employing
the strategies in support of TSMO
and multimodal transportation
system.

Value Pricing and User
Fees
The 2021 Regional Plan incorporates a
variety of value pricing and user fee
strategies as tools to improve mobility by
encouraging changes in travel behaviors
while generating revenue to address aging
infrastructure and expand travel options.

These strategies include a network of
Managed Lanes, a mileage-based road
usage charge, a fee on the fares charged for
rides provided by transportation network
companies, and further subsidization of
transit fares.

No conflict. This action is not
within the purview of this project
and is instead directed towards
SANDAG to develop and
implement pricing and fee
strategies. Implementation of the
Proposed Project would not
prevent SANDAG from designing
fee structures and other pricing
tools to support infrastructure
and expansion of travel options.

Source: SANDAG 2021a.

As shown in Table 3-7, the project would not conflict with actions from the SANDAG 2021 Regional Plan.

Project Potential to Conflict with City of Chula Vista General Plan The proposed project would amend the General Plan to change the land use designation on the project site from Industrial (I) to Rohr Wohl Specific Plan; allowed uses on site would be governed by the Specific Plan. The General Plan is the primary source of long-range planning and policy direction that is used to guide development within the City and serves as a policy guide for determining the appropriate physical development and character of Chula Vista.

While specific plans are not required to rigidly conf orm to the City’s General Plan, they must demonstrate consistency with the goals and policies set forth in the General Plan to demonstrate that the specific plan and General Plan are in general harmony. The Specific Plan has been prepared in conformance wi th the goals and policies of the City of Chula Vista General Plan as amended, in providing a commercial/light Industrial use on an underutilized property, creating new employment opportunities, and providing regulations that support the success of an employment area of the City. Table 3-8 provides a summary of applicable policies and the project’s potential to conflict with those policies.

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Table 3-8. Project Consistency with the City of Chula Vista General Plan Policy Potential to Conflict
Environmental Element
Objective E-6. Improve local air quality and reduce greenhouse gas emissions by minimizing the release of air pollutants and toxic air contaminants and limiting the exposure of people to such pollutants.

Policies E 6.1: Encourage compact development
featuring a mix of uses that locate residential areas
within reasonable walking distance to jobs, services,
and transit.

No conflict. The project is located on an existing
developed site near transit in a transportation planning area and VMT-efficient area.

Policy E 6.2 : Promote and facilitate transit system
improvements in order to increase transit -use and
reduce dependency on the automobile.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6.3: Facilitate the use of alternative fuel and low- and zero-emission vehicles and equipment in the
community.

No conflict. This is a City-wide measure, however the
project would not impede the City’s efforts to facilitate the use of alternative fuel and low- and zero-emission
vehicles and equipment in the community. The project
includes PDF-GHG-1 which includes a leasing
preference for tenants with a facility owned fleet that utilizes alternative and or zero emission vehicles.

Additionally, Mitigation Measure AQ-4 requires the use
of zero-emission cargo handling equipment.

Policy E 6.4: Do not site new or re-powered fossil-
fueled baseload or peaking-type Electric-Generating
Facilities and other major toxic emitters within 1,000
feet of sensitive receptors, or site sensitive receptors within 1,000 feet of such facilities
Not applicable. The project does not include Electric-
Generating Facilities and is not a major toxic emitter.

The Health Risk Assessment prepared for the project
resulted in the incorporation of Mitigation Measures
AQ-4, AQ-5, and AQ-6, which require the use of zero-
emission cargo handling equipment, the cleanest tier
of emergency generators, and truck requirements,
respectively that serve to reduce toxic air
contaminants in the form of diesel particulate matter.

With the incorporation of mitigation, the project does
not result in a significant impact to sensitive receptors.

Policy E 6.5: Ensure Electrical Generating Facilities
incorporate cleaner fuel sources and least-polluting
technologies in order to help transition the City to a
less fossil fuel dependent future, while meeting Chula
Vista’s energy demand.

Not applicable. The project does not include Electric-
Generating Facilities.

Policy E 6.6: Explore incentives to promote voluntary
air pollutant reductions, including incentives for
developers who go above and beyond applicable
requirements and for facilities and operations that
are not otherwise regulated.

No c onflict. This action is not within the purview
of this project and is instead directed towards
the City to implement.

Policy E 6.7: Encourage innovative energy
conservation practices and air quality improvements
in new development and redevelopment projects
consistent with the City's Air Quality Improvement
Plan Guidelines or its equivalent, pursuant to the
City's Growth Management Program
No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

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Table 3-8. Project Consistency with the City of Chula Vista General Plan Policy Potential to Conflict
Policy E 6.8: Encourage climate resilient design
techniques in new buildings and infrastructure to
reduce future risks from climate change-related
impacts such as wildfires, extreme heat, and flooding.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6.9: Discourage the use of landscaping
equipment powered by two-stroke gasoline engines
within the City and promote less-polluting alternatives to their use.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6.10: The siting of new sensitive receivers
within 500 feet of highways resulting from
development or redevelopment projects shall require
the preparation of a health risk assessment as part of
the CEQA review of the project. Attendant health risks
identified in the Health Risk Assessment (HRA) shall
be feasibly mitigated to the maximum extent
practicable, in accordance with CEQA, in order to help
ensure that applicable federal and state standards
are not exceeded.

Not applicable. The project does not include the siting of new sensitive receptors. The Health Risk
Assessment prepared for the project resulted in the
incorporation of Mitigation Measures AQ-4, AQ-5, and
AQ-6, which require the use of zero-emission cargo
handling equipment, the cleanest tier of emergency
generators, and truck requirements, respectively that
serve to reduce toxic air contaminants in the form of
diesel particulate matter. With the incorporation of
mitigation, the project does not result in a significant impact to sensitive receptors.

Policy E 6.11: Develop strategies to minimize CO hot
spots that address all modes of transportation.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement. The project was evaluated for potential to
cause a hotspot and was determined to not result in a
significant impact.

Policy E 6.12: Promote clean fuel sources that help
reduce the exposure of sensitive uses to pollutants
No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6.13: Encourage programs and infrastructure
to increase the availability and usage of energy-
efficient vehicles, such as hybrid electric vehicles,
electric vehicles, or those that run on alternative
fuels.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6.14: Transition the City fleet to 100%
“clean” vehicles by integrating hybrid and alternative
fuel vehicles as current municipal fleet vehicles are
replaced
No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6.15: Site industries: and other stationary
emitters in a way that minimizes the potential
impacts of poor air quality on homes, schools,
hospitals, and other land uses where people
congregate, and disadvantaged populations.

No conflict. The project location was previously used
for industrial uses. There are existing residences
located within 500 feet of the project’s eastern
boundaries. A Health Risk Assessment was prepared
for the project and resulted in the incorporation of
Mitigation Measures AQ-4, AQ-5, and AQ-6, which
require the use of zero-emission cargo handling
equipment, the cleanest tier of emergency generators,
and truck requirements, respectively that serve to
reduce toxic air contaminants in the form of diesel
particulate matter. With the incorporation of

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Table 3-8. Project Consistency with the City of Chula Vista General Plan Policy Potential to Conflict
mitigation, the project does not result in a significant impact to sensitive receptors.

Policy E 6.16: Encourage the use of bicycles through
support of bike share opportunities, community bike
programs, and the provision of bicycle parking
opportunities such as bike racks and bike lockers
No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Objective E-6B. Prioritize greening efforts to keep air, water, and land clean.

Policy E 6B.1: Protect and develop shade tree cover
along streets and within parking lots as a priority,
particularly in new developments or tree-deficient
areas.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6B.2: Preferentially plant female street trees to reduce pollen, especially in the most populated
areas.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6B.3: Prioritize natural filtration, as opposed to impermeable hardscaping, within new
development projects, along roadways, and adjacent
to stream and riverbanks.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6B.4: Update the building code to support
best practices in “green building” design,
construction, and operations.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6B.5: Provide fast-track permitting for
projects that implement “green building” design and
construction.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 6B.6: Encourage or require all new building
construction to incorporate green roofs and
encourage conversions of existing roof space to
green roofs to reduce heat island effect.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Objective E-. 7 Promote energy conservation through the efficient use of energy and through the development of local, non-fossil fuel-based renewable sources of energy Policy E 7.1: Promote development of regulations and
building design standards that maximize energy
efficiency through appropriate site and building
design and through the use of energy-efficient
materials, equipment, and appliances.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 7.2: Encourage and support the local
research, development, generation, and use of non-
fossil, fuel-based renewable sources of energy,
including wind and solar resources, that meet local
energy needs in an environmentally sensitive manner
and reduce dependence on imported energy.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 7.3: Develop and provide pertinent
information about the benefits of energy conservation
and available energy conservation incentive
programs to all segments of the community.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

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Table 3-8. Project Consistency with the City of Chula Vista General Plan Policy Potential to Conflict
Policy E 7.4: Pursue and encourage the expansion of
local energy conservation, energy efficiency, and
related incentive programs.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 7.5: Pursue 40% City-wide electricity supply
from clean, renewable resources by 2017.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 7.6: Encourage the construction and
operation of green buildings, considering such
programs as the Leadership in Energy and
Environmental Design (LEEDTM) Green Building
Rating System
No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 7.7: Support tree planting programs that will
be implemented to reduce energy needs.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 7.8: Ensure that residential and non-
residential construction complies with all applicable
City of Chula Vista energy efficiency measures and
other green building measures that are in effect at
the time of discretionary permit review and Approval
or building permit issuance, whichever is applicable.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement. The project will comply with applicable
regulations.

Objective E-. 8. Minimize the amount of solid waste generated within the General Plan area that requires landfill disposal.

Policy E 8.1: Promote efforts to reduce waste,
minimize the need for additional landfills, and provide economically and environmentally sound resource
recovery, management, and disposal facilities.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 8.2: Support the development of composting
programs for commercial and residential
development.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 8.3: Implement source reduction strategies,
including curbside recycling, use of small collection
facilities for recycling, and composting.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 8.4: Provide information about applicable
solid waste reduction programs to all segments of the
community, including other governmental institutions.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 8.5: Encourage the reduction of household
hazardous waste generation and disposal by
promoting the use of safe substitutes, and by
promoting and facilitating recycling of household
hazardous waste.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Policy E 8.6: Permit recycling operations and
businesses that utilize recyclable materials within
industrial zones in close proximity to Otay Landfill,
subject to conformance with applicable SPA Plan-
level policies and zoning regulations.

No conflict. This action is not within the purview of this project and is instead directed towards the City to
implement.

Source: City of Chula Vista, 2005

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Based on the preceding information, the project would not conflict with applicable General Plan Policies.

Quantification of GHG Emissions
Construction of the Project would result in GHG emissions, which are primarily associated with the use of off -road construction equipment, haul trucks, on-road vendor trucks, and worker vehicles.

Construction Emissions
Construction of the Project would result in GHG emissions, which are primarily associated with the use of off -road construction equipment, haul trucks, on-road vendor trucks, and worker vehicles.

CalEEMod 2022 was used to calculate the annual GHG emissions based on the construction scenario described in Section 3.32. Construction of the project is anticipated to commence in August 2024 for Planning Area B-1 and would be completed in October 2026. Planning Area B-2 is anticipated to begin construction in August 2028 and be completed in September 2029. On -site sources of GHG emissions include off -road equipment and off -site sources including vendor trucks and worker vehicles. Table 3-9 presents construction emissions for the project in 2024 through 2029 from on-site and off-site emission sources.

Table 3-9. Estimated Annual Construction Greenhouse Gas Emissions Year
CO 2 CH 4 N2O R CO 2e
Metric Tons per Year
2024 514.19 0.02 0.04 0.31 527.74
2025 713.83 0.03 0.04 0.62 728.09
2026 402.46 0.02 0.02 0.31 410.14
2028 365.93 0.01 0.03 0.27 374.14
2029 538.36 0.02 0.04 0.37 550.61
Total 2,590.72
Amortized 30-Year Construction Emissions 86.36
Source: CalEEMod 2022.

Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; R = refrigerant; CO2e = carbon dioxide equivalent; <0.01 = reported value less than 0.01. Totals may not add due to rounding. See Appendix A for complete results. Values shown are the mitigated emissions from implementation of MM-AQ-2 and MM-AQ-3.

Numbers may not add due to rounding.

As shown in Table 3-9, the estimated total GHG emissions during construction of would be approximately 2,590.72 MT CO2e over the construction period. Estimated project-generated construction emissions amortized over 30 years would be 83.36 MT CO2e per year. As with project-generated construction criteria air pollutant emissions, GHG emissions generated during construction of the project would be short-term in nature, lasting only for the duration of the construction period, and would not represent a long-term source of GHG emissions.

Operational Emissions
Operation of the project would generate GHG emissions through vehicle trips by residents, employees, customers, and visitors to and from the project site; landscape maintenance equipment operation; energy use (generation of electricity consumed by the project); solid waste disposal; generation of electricity associated with water supply,

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treatment, and distribution and wastewater treatment; and refrigerants. CalEEMod was used to calculate the annual GHG emissions based on the operational assumptions described in Section 3.3.2.2, Operation. The estimated operational project -generated GHG emissions from area sources, energy usage, motor vehicles, solid waste generation, and water usage and wastewater generation are shown in Table 3-10.

Table 3-10. Estimated Annual Operational Greenhouse Gas Emissions Source
CO 2 CH 4 N2O R CO 2e
metric tons per year
Project
Mobile 17,704.90 0.67 1.29 16.05 18,121.81
Area 13.99 0.00 0.00 14.04
Energy 3,590.87 0.49 0.04 0 3,615.82
Water 144.37 5.54 0.13 0 322.69
Waste 85.39 8.53 0.00 0 298.75
Refrigeration 0 0 0 2,183.79 2,183.79
Offroad (forklifts, yard trucks) 0 0 0 0 0
Stationary (Emergency
Generators)

47.60 0.00 0.00 0.00 47.76
Subtotal 21.587.12 15.24 1.47 2,199.84 24,604.66
Existing
Mobile 3,525.74 0.20 0.16 6.56 3,584.87
Area 14.57 0.00 0.00 14.63
Energy 4,121.47 0.30 0.02 4,135.12
Water 457.95 7.53 0.18 700.24
Waste 104.23 10.42 0.00 364.68
Refrigeration 33.05 33.05
Offroad (forklifts, yard trucks) 1,430.18 0.06 0.01 1,435.09 Stationary (Emergency
Generators)
0 0 0 0 0
Subtotal 9,654.15 18.51 0.37 39.61 10,267.67
Net
Mobile 14,179.16 0.47 1.13 9.49 14,536.94
Area -0.58 0 0 0 -0.59
Energy -530.60 0.19 0.02 0.00 -519.30
Water -313.58 -1.99 -0.05 0 -377.55
Waste -18.84 -1.89 0 0 -65.93
Refrigeration 0 0 0 2150.74 2150.74
Offroad (forklifts, yard trucks) -1,430.18 -0.06 -0.01 0.00 -1,435.09 Stationary (Emergency
Generators)

47.6 0 0 0 47.76
Total 11,932.98 -3.28 1.09 2,160.23 14,336.98
Amortized 30-Year Construction Emissions 86.36

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Table 3-10. Estimated Annual Operational Greenhouse Gas Emissions Source
CO 2 CH 4 N2O R CO 2e
metric tons per year
Project Operations + Amortized Construction Total 14,423.34 Source: CalEEMod 2022.

Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; R= refrigerant; CO2e = carbon dioxide equivalent; <0.01 = reported value less than 0.01. Values shown are the mitigated emissions from implementation of MM-AQ-4, MM-AQ-5, and MM-AQ-6.

Numbers may not add due to rounding.

See Rohr-Wohl Specific Plan – Regional – Mitigated Operational Detailed Report.pdf in Appendix A for complete results.

As shown in Table 3-8, estimated annual project generated GHG emissions would be approximately 14,336.98 MT CO2e per year; with amortized construction emissions of approximately 86.36 MT CO 2e per year, total project emissions would be approximately 14,423.34 MT CO2e per year.

Level of Significance Before Mitigation
As discussed above, the project’s significance is based on its potential to conflict with the applicable plans adopted for the purpose of reducing GHG emissions, including the City’s CAP, the 2022 Scoping Plan, the 2017 Scoping Plan, AB 32 Regulations, SANDAG’s RTP/SCS and the City’s General Plan. As shown in the above tables, the project would not conflict with applicable GHG reduction plans and regulations, accordingly, the impact would be less than significant.

Mitigation Measures
No mitigation is required.

Level of Significance After Mitigation
Impacts would be less than significant.

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4 Energy

4.1 Environmental Setting
The San Diego region, like many other urban areas, faces challenges related to its energy supply and future growth.

The region relies on a combination of sources for electricity, including natural gas, renewables, and imported power.

California, including San Diego, had been making significant strides in increasing the share of renewable energy in its power mix, with a focus on solar and wind energy.

4.1.1 Electricity
According to the U.S. Energy Information Administration (EIA), California used approximately 247,249,865 megawatt-hours of electricity in 2021 (EIA 2022a). Electricity usage in California for different land uses varies substantially by the types of uses in a building, type of construction materials used in a building, and the efficiency of all electricity -consuming devices within a building. Due to the state’s energy efficiency building standards and efficiency and conservation programs, California’s electr icity use per capita in the residential and commercial sector is lower than any other state except Hawaii (EIA 2023a).

San Diego Gas & Electric (SDG&E) provides electricity to the Project. SDG&E supplies power to 3.6 million people, through 1.4 million electric meters, and across a 4,100 square-mile service area that includes San Diego County and southern Orange County (SDG&E 2021). According to the California Energy Commission, demand forecasts anticipate that approximately 22.7 billion kWh of electricity will be used in SDG&E’s service area in 2024 (CEC 2023a).

SDG&E receives electric power from a variety of sources. According to the 2022 SDG&E Power Content Label, eligible renewable energy accounts for 44.5% of SDG&E’s overall energy resources, with biomass and biowaste at

2.9%, solar at 28.0%, wind power at 13.9%, unspecified power12 0.8%, and natural gas at 54.4. (CEC 2023c). Within San Diego County, annual electricity use in 2022 was approximately 20.2 billion kWh per year (CEC 2023b).

4.1.2 Natural Gas
Natural gas is a combustible mixture of hydrocarbon compounds (primarily methane) used as a fuel source. The majority of the natural gas consumed in California is obtained from sources located outside the state and delivered through high-pressure transmission pipelines. Natural gas provides almost one -third of the state’s total energy requirements and is used in electricity generation, space heating, cooking, water heating, industrial processes, and as a transportation fuel. Natural gas is measured in terms of cubic feet.

According to the EIA, California used approximately 2,092,612 million cubic feet of natural gas in 2021 (EIA 2023b).

The majority of California’s natural gas customers are residential and small commercial customers (core customers). These customers account for approximately 35% of the natural gas delivered by California utilities (CPUC 2021). Large consumers, such as electric generators and industrial customers (noncore customers), account for approximately 65% of the natural gas delivered by California uti lities (CPUC 2021). CPUC regulates California

12 Unspecified power is electricity that has been purchased through open market transactions and is not traceable to a specific generation source.

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natural gas rates and natural gas services, including in -state transportation over transmission and distribution pipeline systems, storage, procurement, metering, and billing. Most of the natural gas used in California comes from out -of-state natural gas b asins. Biogas (e.g., from wastewater treatment facilities or dairy farms) is just beginning to be delivered into the gas utility pipeline systems; however, the State has adopted regulations requiring its development to reduce statewide emissions of methane by 40% below 2013 levels by 2030 (CPUC 2022).

SDG&E provides San Diego County and southern Orange County with natural gas service, encompassing approximately 4,100 square miles. Within San Diego County, gas consumption in 2022 was approximately 522 million therms, with 281 million therms for residential use and 241 million therms for non -residential use (CEC 2023d).

4.1.3 Petroleum
According to the EIA, California used approximately 605 million barrels of petroleum in 2021, with the majority (511 million barrels) used for the transportation sector, (EIA 2023c). There are 42 U.S. gallons in a barrel, so this equates to a total daily use of approximately 14.4 million gallons of petroleum among all sectors and 12.2 million gallons for the transportati on sector. Petroleum usage in California includes petroleum products such as motor gasoline, distillate fuel, liquefied petroleum gases, an d jet fuel. At the federal and state levels, various policies, rules, and regulations have been enacted to improve vehicle fuel efficiency, promote the development and use of alternative fuels, reduce transportation‐source air pollutants and greenhouse gas (GHG) emissions, and reduce vehicle miles traveled (VMT). Section 4.6.2, Relevant Plans, Policies, and Ordinances, discusses in more detail both federal and state regulations that would help increase fuel efficiency of motor vehicles and reduce GHG emissions.

Market forces have driven the price of petroleum products steadily upward over time, and technological advances have made use of other energy resources or alternative transportation modes increasingly feasible.

4.2 Regulatory Setting

4.2.1 Federal

4.2.1.1 Federal Energy Policy and Conservation Act and CAFE Standards In 1975, Congress enacted the federal Energy Policy and Conservation Act, which established the first fuel economy standards, known as the Corporate Average Fuel Economy (CAFE) standards, for on-road motor vehicles in the United States. Pursuant to the act, the National Highway Traffic Safety Administration (NHTSA) is responsible for establishing additional vehicle standards. In 2012, new CAFE standards for passenger cars and light trucks were approved for model years 2017 through 2021 (77 FR 62624–63200). Fuel economy is determined based on each manufacturer’s average fuel economy for the fleet of vehicles available for sale in the United States.

4.2.1.2 Energy Policy Act of 1992 and 2005
The Energy Policy Act of 1992 was passed to reduce the country’s dependence on foreign petroleum and improve air quality. The act includes several parts intended to build an inventory of alternative fuel vehicles (AFVs) in large, centrally fueled fleets in metropolitan areas. The act requires certain federal, state, and local government and private fleets to purchase a percentage of light -duty AFVs capable of running on alternative fuels each year. In

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addition, financial incentives are also included in the act. Federal tax deductions are allowed for businesses and individuals to cover the incremental cost of AFVs. The Energy Policy Act also requires states to consider a variety of incentive programs to help promote AFVs. The Energy Policy Act provides renewed and expanded tax credits for electricity generated by qualified energy sources, such as landfill gas; provides bond financing, tax incentives, grants, and loan guarantees for clean renewable energy and rural community electrification; and establishes a federal purchase requirement for renewable energy.

In January 2005, the new Energy Policy Act was signed into law. It addresses energy production in the United States, including energy efficiency, renewable energy, oil and gas, coal, Tribal energy, nuclear matters and security, vehicles and motor fuels, including ethanol, hydrogen, electricity, energy tax incentives, hydropower and geothermal energy, and climate change technology. The Energy Policy Act provides loan guarantees for entities that develop or use innovative technologies that avoid the by -production of greenhouse gases. Another provision of the Energy Policy Act is the Renewable Fuel Standard (RFS), which increases the amount of biofuel that must be mixed with gasoline sold in the United States.

4.2.1.3 Energy Independence and Security Act of 2007
On December 19, 2007, the Energy Independence and Security Act of 2007 (EISA) was signed into law. In addition to setting increased CAFE standards for motor vehicles, the EISA facilitates the reduction of national GHG emissions by requiring the following:
▪ Increasing the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard (RFS) that requires fuel producers to use at least 36 billion gallons of biofuel in 2022. ▪ Prescribing or revising standards affecting regional efficiency for heating and cooling products, procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances. ▪ Requiring approximately 25% greater efficiency for light bulbs by phasing out incandescent light bulbs between 2012 and 2014; requiring approximately 200% greater efficiency for light bulbs, or similar energy savings, by 2020.
▪ While superseded by the U.S. Environmental Protection Agency (EPA) and NHTSA actions described previously, establishing miles per gallon targets for cars and light trucks and directing the NHTSA to establish a fuel economy program for medium-and heavy-duty trucks and create a separate fuel economy standard for trucks.

This federal legislation requires ever -increasing levels of renewable fuels (the RFS) to replace petroleum (EPA 2023b). EPA is responsible for developing and implementing regulations to ensure that transportation fuel sold in the United States contains at least a minimum volume of renewable fuel.

The RFS program was created under the Energy Policy Act and established the first renewable fuel volume mandate in the United States. As required under the Energy Policy Act, the original RFS program required 7.5 billion gallons of renewable fuel to be blended into gasoline by 2012. Under the EISA, the RFS program was expanded in several ways that laid the foundation for achieving significant reductions in GHG emissions from the use of renewable fuels, reducing imported petroleum, and encouraging the develo pment and expansion of the renewable fuels sector in the United States. The updated program is referred to as “RFS2” and includes the following:

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▪ The EISA expanded the RFS program to include diesel, in addition to gasoline. ▪ The EISA increased the volume of renewable fuel required to be blended into transportation fuel from 9 billion gallons in 2008 to 36 billion gallons by 2022. ▪ The EISA established new categories of renewable fuel and set separate volume requirements for each one. ▪ The EISA required EPA to apply lifecycle GHG performance threshold standards to ensure that each category of renewable fuel emits fewer GHGs than the petroleum fuel it replaces.

Additional provisions of the EISA address energy savings in government and public institutions, research for alternative energy, additional research in carbon capture, international energy programs, and the creation of green (environmentally beneficial) jobs.

4.2.1.4 Intermodal Surface Transportation Efficiency Act of 1991 The Intermodal Surface Transportation Efficiency Act (ISTEA) of 1991 promoted the development of intermodal transportation systems to maximize mobility and address national and local interests in air quality and energy.

ISTEA contained factors for metropolitan planning organizations to address in developing transportation plans and programs, including some energy ‐related factors. To meet the new ISTEA requirements, metropolitan planning organizations adopted policies defining the social, economic, energy, a nd environmental values guiding transportation decisions.

4.2.1.5 Transportation Equity Act for the 21st Century
The Transportation Equity Act for the 21st Century was signed into law in 1998 and builds on the initiatives established in the ISTEA legislation (previously discussed). The Transportation Equity Act authorizes highway, highway safety, transit, and other efficient surface transportation programs. The act continues the program structure established for highways and transit under ISTEA, such as flexibility in the use of funds, emphasis on measures to improve the environment, and focus on a strong planning process as the foundation of transportation decisions. The Transportation Equity Act also provides for investment in research and its application to maximize the performance of the transportation system through, for example, deployment of intelligent transportation systems to help improve operations and management of transportation systems and vehicle safety.

4.2.2 State
Warren -Alquist Act
The California legislature passed the Warren -Alquist Act in 1974. The Warren -Alquist Act created the California Energy Commission (CEC). The legislation also incorporated the following three key provisions designed to address the demand side of the energy equation:
▪ The act directed the CEC to formulate and adopt the nation’s first energy conservation standards for buildings constructed and appliances sold in California. ▪ The act removed the responsibility of electricity demand forecasting from the utilities, which had a financial interest in high-demand projections, and transferred it to a more impartial CEC.

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▪ The CEC was directed to embark on an ambitious research and development program, with a particular focus on fostering what were characterized as non-conventional energy sources.

State of California Energy Action Plan
CEC and CPUC approved the first State of California Energy Action Plan in 2003. The Energy Action Plan established shared goals and specific actions to support that adequate, reliable, and reasonably priced electrical power and natural gas supplies are provided, and identified policies, strategies, and actions that are cost effective and environmentally sound for California’s consumers and taxpayers. In 2005, CEC and CPUC adopted a second Energy Action Plan to reflect various policy changes and actions of the preceding 2 years.

At the beginning of 2008, CEC and CPUC determined that it was not necessary or productive to prepare a new Energy Action Plan. This determination was based, in part, on a finding that the state’s energy policies have been significantly influenced by the pa ssage of Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006 (discussed below). Rather than produce a new Energy Action Plan, CEC and CPUC prepared an update that examines the state’s ongoing actions in the context of global climate change.

Assembly Bill 32 and S enate Bill 32
In 2006, the State Legislature enacted AB 32, the California Global Warming Solutions Act of 2006. AB 32 requires California to reduce its GHG emissions to 1990 levels by 2020. In 2016, the Legislature enacted Senate Bill (SB) 32, which extended the horizo n year of the state’s codified GHG reduction planning targets from 2020 to 2030, requiring California to reduce its GHG emissions to 40% below 1990 levels by 2030. In accordance with AB 32 and SB 32, the California Air Resources Board (CARB) prepares scopi ng plans to guide the development of statewide policies and regulations for the reduction of GHG emissions. Many of the policy and regulatory concepts identified in the scoping plans focused on increasing energy efficiencies, using renewable resources, and reducing the consumption of petroleum-based fuels (such as gasoline and diesel). As such, the state’s GHG emissions reduction planning framework creates co-benefits for energy-related resources.

Senate Bills 1078 (2002), 107 (2006), X1 -2 (2011), 350 (2015), 100 (2018), SB 1020 (2022) Senate Bill (SB) 1078 established the California Renewable Portfolio Standard (RPS) Program and required that a retail seller of electricity purchase a specified minimum percentage of electricity generated by eligible renewable energy resources as defined in any given year, culminating in a 20% standard by December 31, 2017. These retail sellers include electrical corporations, community choice aggregators, and electric service providers. The bill relatedly required the CEC to certify eligible renewable ene rgy resources, design and implement an accounting system to verify compliance with the RPS by retail sellers, and allocate and award supplemental energy payments to cover above-market costs of renewable energy.

SB 107 (2006) accelerated the RPS established by SB 1078 by requiring that 20% of electricity retail sales be served by renewable energy resources by 2010 (not 2017). Additionally, SB X1-2 (2011) requires all California utilities to generate 33% of their e lectricity from eligible renewable energy resources by 2020. Specifically, SB X1-2 sets a three -stage compliance period: by December 31, 2013, 20% had to come from renewables; by December 31, 2016, 25% had to come from renewables; and by December 31, 2020, 33% will come from renewables.

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SB 350 (2015) expanded the RPS because it requires retail seller and publicly owned utilities to procure 50% of their electricity from eligible renewable energy resources by 2030, with interim goals of 40% by 2024 and 45% by 2027.

SB 100 (2018) accelerated and expanded the standards set forth in SB 350 by establishing that 44% of the total electricity sold to retail customers in California per year by December 31, 2024, 52% by December 31, 2027, and 60% by December 31, 2030 be secured from qualifying renewable energy sources. SB 100 also states that it is the policy of the state that eligible renewable energy resources and zero -carbon resources supply 100% of the retail sales of electricity to California by 2045. This bill requires t hat the achievement of 100% zero -carbon electricity resources does not increase the carbon emissions elsewhere in the western grid and that the achievement not be achieved through resource shuffling.

SB 1020 (2022) revises the standards from SB 100, requiring the following percentage of retail sales of electricity to California end-use customers come from eligible renewable energy resources and zero-carbon resources:
▪ 90% by December 31, 2035
▪ 95% by December 31, 2040
▪ 100% by December 31, 2045
Consequently, utility energy generation from non -renewable resources is expected to be reduced based on implementation of the RPS requirements described above.

California Building Standards
The California Building Standards Code was established in 1978 and serves to enhance and regulate California’s building standards . While not initially promulgated to reduce GHG emissions, Part 6 of Title 24 specifically established Building Energy Efficiency Standards that are designed to ensure that new and existing buildings in California achieve energy efficiency and preserve outdoor and indoor environmental quality. These energy efficiency standards are reviewed every 3 years by the Building Standards Commission and the California Energy Commission (CEC) and revised if necessary ( California Public Resources Code Section 25402[b][1]). The regulations receive input from members of industry, as well as the public, to “reduce the wasteful, uneconomic, inefficient, or unnecessary consumption of energy” ( California Public Resources Code Section 25402). These regulations are carefully scrutinized and analyzed for technological and economic feasibility ( California Public Resources Code Section 25402[d]) and cost effectiveness (California Public Resources Code Section 25402[b][2–3]). As a result, these standards save energy, increase electricity supply reliability, increase indoor comfort, avoid the need to construct new power plants, and help preserve the environment. The current Title 24 standards are the 2022 Title 24 building energy efficiency standards, which became effective January 1, 2023.

In addition to CEC’s efforts, in 2008, the California Building Standards Commission adopted the nation’s first green building standards. The California Green Building Standards Code (Part 11 of Title 24), which is commonly referred to as California’s Green Building Standards (CALGreen), establishes minimum mandatory standards and voluntary standards pertaining to the planning and design of sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and interior air quality.

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Integrated Energy Policy Report
The CEC is responsible for preparing integrated energy policy reports that identify emerging trends related to energy supply, demand, and conservation; public health and safety; and maintenance of a healthy economy. The CEC’s 2023 Integrated Energy Policy Report discusses the state’s policy goals of decarbonizing buildings, ensuring energy reliability, decarbonizing the state’s gas system, the state’s energy demand forecast, and quantifying the benefits of the clean transportation program (CEC 2023e). SB 100 calls for California’s electricity system to become 100% zero- carbon by 2045. CEC, CPUC, and CARB are working together to identify pathways to deeply decarbonize the state’s electricity system in response to SB 100. The aim is to leverage California’s clean electricity system to decarbonize, or remove carbon from, other portions of the state’s energy system. Over time these policies and trends would serve to beneficially reduce a project’s GHG emissions profile and energy consumption as they are implemented.

State Vehicle Standards
In response to the transportation sector accounting for more than half of California’s CO2 emissions, AB 1493 was enacted in 2002. AB 1493 required CARB to set GHG emissions standards for passenger vehicles, light-duty trucks, and other vehicles determined by the state board to be vehicles whose primary use is noncommercial personal transportation in the state. The bill required that CARB set GHG emissions standards for motor vehicles manufactured in 2009 and all subsequent model years. The 2009 –2012 standards resulted in a reduction in approximately 22% of GHG emissions compared to emissions from the 2002 fleet, and the 2013–2016 standards resulted in a reduction of approximately 30%.

In 2012, CARB approved a new emissions -control program for model years 2017 through 2025. The program combines the control of smog, soot, and global -warming gases with requirements for greater numbers of zero - emissions vehicles into a single package of standards called Advanced Clean Cars, detailed below. By 2025, when the rules would be fully implemented, new automobiles would emit 34% fewer global-warming gases and 75% fewer smog-forming emissions.

Although the focus of the state’s vehicle standards is on the reduction of air pollutants and GHG emissions, one co-benefit of implementation of these standards is a reduced demand for petroleum-based fuels.

Advanced Clean Car Program
The Advanced Clean Cars (ACC) I program (January 2012) is an emissions -control program for model years 2015 through 2025. The program combines the control of smog- and soot-causing pollutants and GHG emissions into a single coordinated package of regulations: the Low-Emission Vehicle (LEV) regulation for criteria air pollutant and GHG emissions and a technology forcing regulation for zero-emission vehicles (ZEV) that contributes to both types of emission reductions. The package includes elements to reduce smog-forming pollution, reduce GHG emissions, promote clean cars, and provide the fuels for clean cars. To improve air quality, CARB has implemented new emission standards to reduce smog -forming emissions beginning with 2015 model year vehicles. It is estim ated that in 2025 cars will emit 75 percent less smog-forming pollution than the average new car sold in 2015. The ZEV program will act as the focused technology of the ACC I program by requiring manufacturers to produce increasing numbers of ZEVs and plug-in hybrid EVs in the 2018 to 2025 model years.

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The ACC II program is currently in development to establish the next set of LEV and ZEV requirements for model years after 2025 to contribute to meeting federal ambient air quality ozone standards and California’s carbon neutrality standards. The main objectives of ACC II are:

11. Maximize criteria and GHG emission reductions through increased stringency and real-world reductions.

12. Accelerate the transition to ZEVs through both increased stringency of requirements and associated actions to support wide-scale adoption and use.

An ACC II rulemaking package, which considers technological feasibility, environmental impacts, equity, economic impacts, and consumer impacts, was approved by the Office of Administrative Law (OAL) on November 30, 2022 .

This requires that, by 2035, all new passenger cars, trucks, and sports utility vehicles (SUVs) will be zero emissions by 2035. However, as detailed previously, EPA and NHTSA published the Safer Affordable Fuel -Efficient (SAFE) Vehicles Rule, which revokes California’s authority to set its own GHG emissions standards and set ZEV mandates in California. Since California and 22 other states, as well as the District of Columbia and four cities, filed suit against the EPA and a petition for reconsideration of the SAFE Rule, the ACC II rulemaking ’s course may vary depending on the results of this ongoing litigation.

Advanced Clean Trucks Program
The purpose of the ACT Regulation (June 2020) is to accelerate the market for zero -emission vehicles in the medium- and heavy -duty truck sector and to reduce emissions NO x, fine particulate matter, TACs, GHGs, and other criteria pollutants generated from on -road mobile sources (CARB 2021). Requiring medium - and heavy - duty vehicles to transition to zero -emissions technology will reduce health risks to people living in and vi siting California and is needed to help California meet established near - and long -term air quality and climate mitigation targets. The regulation has two components including (1) a manufacturer sales requirement and (2) a reporting requirement:

1. Zero-emission truck sales: Manufacturers who certify Class 2b -8 chassis or complete vehicles with combustion engines will be required to sell zero-emission trucks as an increasing percentage of their annual California sales from 2024 to 2035. By 2035, zero-emission truck/chassis sales would need to be 55% of Class 2b – 3 truck sales, 75% of Class 4 – 8 straight truck sales, and 40% of truck tractor sales.

2. Company and fleet reporting: Large employers including retailers, manufacturers, brokers and others will be required to report information about shipments and shuttle services. Fleet owners, with 50 or more trucks, will be required to report about their ex isting fleet operations. This information will help identify future strategies to ensure that fleets purchase available zero -emission trucks and place them in service where suitable to meet their needs.

4.2.3 Local

4.2.3.1 San Diego Gas & Electric ( SDG&E) Individual Integrated Resource Plan
SDG&E’s Conforming Portfolio identifies a need for approximately 700 gigawatt-hours of incremental renewable power in addition to the assumed increases in energy efficiency and behind -the-meter solar, to meet the 2030 planning

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target (approximately 4% of the total energy in the portfolio) (SDG&E 2021). SDG&E’s Conforming Portfolio demonstrates that the utility has reduced its GHG emissions in the early years of the planning period, reflecting its current position in relation to its RPS targets—in 2018, approximately 45% of its energy mix came from delivering renewable resources (compared to an RPS requirement of 29%), it has aggressively adopted energy storage, and does not use coal resources. SDG&E is fully compliant with RPS and long-term contracting requirements. SDG&E continues its efforts to meet resource-specific renewable procurement mandates, as required, but does not expect to procure additional resources for RPS compliance purposes until after 2030.City of Chula Vista Climate Action Plan Since 2000, Chula Vista has been implementing a Climate Action Plan (CAP) to address climate change issues and its impacts on the City. The City’s Climate Action Plan is a group of documents including various GHG emission inventories, the original Carbon Dioxide Reduction Plan (2000), Climate Mitigation Plan (2008), new Climate Adaptation Plan (2011), and Municipal Action (2014). The City’s Increased Energy Efficiency Ordinance, Green Building Standards, and Solar Ready Ordinances are products of the Climate Action Plan. Actions and goals of the 2017 CAP relate to energy and water efficient buildings, smart growth and clean transit, zero waste, increased local energy and water resources, leading by example, and community resilience (City of Chula Vista 2017).

4.2.3.2 Chula Vista Climate Adaptation Strategies – Implementation Plans The Climate Adaptation Strategies – Implementation Plans document developed by the Climate Change Working Group includes 11 strategies to adapt Chula Vista to the potential impacts of global climate change, including energy supply. The strategies to reduce energy demand include cool paving, shade trees, and cool roofs. For each strategy, the plans outline specific implementation components, critical steps, costs, and timelines. To limit the necessary staffing and funding required to implement the strategies , the plans were also designed to build upon existing municipal efforts rather than create new, stand-alone policies or programs. Initial implementation of all 11 strategies is intended to be phased in over a 3-year period from plan adoption (City of Chula Vista 2011).

4.2.3.3 Chula Vista Green Building Standards
The City of Chula Vista amended the Municipal Code Ordinance 15.12 pertaining to green building practices to include residential and non -residential remodels and additions. The Code contains Residential Mandatory Measures and Non-Residential Mandatory Measures and also provides Voluntary Measures that can be used by developers to improve energy efficiency and reduce environmental impacts through design and construction.

4.2.3.4 San Diego Regional Energy Efficiency Plan/City of Chula Vista Energy Strategy and Action Plan
The San Diego Regional Energy Strategy serves as the energy policy blueprint for the region through 2050 . The Regional Energy Strategy provides long-term goals in eleven topic areas: energy efficiency, renewable energy, distributed generation, transportation fuels, land use and transportation planning, border energy issues, and the green economy (SANDAG 2014).

The City has adopted an energy plan to address long-term energy issues and to protect its residents from unreliable energy supply and volatile prices. The plan, called the Chula Vista Energy Strategy and Action Plan, addresses demand side management, energ y efficient and renewable energy outreach programs for businesses and

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residents, energy acquisition, power generation, and distributed energy resources and legislative actions (City of Chula Vista 2001).

4.2.3.5 City of Chula Vista Solar Ready Ordinances
CVMC, Section 15.28.015, solar water heater pre -plumbing, and Section 15.24.065, photovoltaic pre -wiring requirements, are referred to as the Solar Ready ordinances. Section 15.28.015 requires all new residential units to include plumbing specifically desi gned to allow the later installation of a system which utilizes solar energy as the primary means of heating domestic potable water. Section 15.24.065 requires all new residential units to include electrical conduit specifically designed to allow the later installation of a photovoltaic system which utilizes solar energy as a means to provide electricity.

4.2.3.6 City of Chula Vista General Plan
The City of Chula Vista General Plan recognizes that to ensure adequate and reliable energy service, efficient energy efforts throughout the City and transitioning to non -fossil fuel alternatives will help to extend limited supplies, reduce the need for ex pensive new regional power generators and transmission lines, and contribute to Chula Vista’s economic sustainability and regional competitiveness. The General Plan includes objectives in the Public Facilities and Services Element to ensure adequate energy supplies throughout Chula Vista (Objective PFS 22) and in the Environmental Element to promote conservation through the efficient use of energy and through the development of local, non-fossil fuel-based renewable sources of energy (Objective E 7) (City of Chula Vista 2005).

4.3 Significance Criteria and Methodology

4.3.1 Thresholds of Significance
The significance criteria used to evaluate the project impacts to energy are based on Appendix G of the CEQA Guidelines. According to Appendix G of the CEQA Guidelines, a significant impact related to energy would occur if the project would:

Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.

Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Result in cumulatively considerable impacts.

Appendix F: Energy Conservation of the CEQA Guidelines provides the following six criteria to evaluate energy impacts:

1. The project’s energy requirements and its energy use efficiencies by amount and fuel type for each stage of the project including construction, operation, maintenance and/or removal. If appropriate, the energy intensiveness of materials maybe discussed.

2. The effects of the project on local and regional energy supplies and on requirements for additional capacity.

3. The effects of the project on peak and base period demands for electricity and other forms of energy.

4. The degree to which the project complies with existing energy standards.

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5. The effects of the project on energy resources.

6. The project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives.

4.3.2 Approach and Methodology
CalEEMod Version 2022.1 (CAPCOA 2022) was used to estimate the potential project-energy consumption during construction and operation. Construction of the project would result in petroleum consumption primarily associated with use of off -road construction equipment, on-road hauling and vendor (material delivery) trucks, and worker vehicles. All details specific to construction and operation are discussed in Section 2., Air Quality, specifically in Approach and Methodology (Construction Emissions and Operational Emissions), are also applicable for the estimation of construction-related and operations-related energy consumption.

4.4 Impact Analysis

4.4.1 Would the project result in potentially significant environmental impact due to wasteful, inefficient, or
unnecessary consumption of energy resources, during
Project construction or operation?
This section addresses the Project’s energy requirements during construction and operation pursuant to Appendix F, criteria 1.

Construction Emissions
Electricity Usage
Temporary electric power for as-necessary lighting and electronic equipment, such as computers inside temporary construction trailers, would be provided by SCE. The electricity used for such activities would be temporary, would be substantially less than that required for Project operation, and would therefore have a negligible contribution to the Project’s overall energy consumption.

Natural Gas Usage
Natural gas is not anticipated to be required during construction of the Project. Fuels used for construction would primarily consist of diesel and gasoline, which are discussed under the subsection “Petroleum Usage,” below. Any minor amounts of natural gas that may be consumed as a result of Project construction would be temporary and negligible, and would not have an adverse effect; therefore, impacts would be less than significant.

Petroleum Usage
Petroleum would be consumed throughout construction of the Project. Fuel consumed by construction equipment would be the primary energy resource expended over the course of construction, and VMT associated with the transportation of construction materials and construction worker commutes would also result in petroleum

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consumption. Heavy-duty construction equipment associated with construction activities and haul trucks involved in relocating dirt around the Project site are assumed to use diesel fuel. Construction workers would travel to and from the Project site throughout the duration of construction. It is assumed that construction workers would travel to and from the Project site in gasoline-powered vehicles.

Heavy-duty construction equipment of various types would be used during Project construction. CalEEMod was used to estimate construction equipment usage; results are included in Appendix A. Fuel consumption from construction equipment was estimated by converting the total CO 2 emissions from each construction phase to gallons using conversion factors for CO2 to gallons of gasoline or diesel. The conversion factor for gasoline is 8.78 kilograms per metric ton of CO2 per gallon, and the conversion factor for diesel is 10.21 kilograms per metric ton of CO2 per gallon (The Climate Registry 2023). The estimated diesel fuel usage from construction equipment, and vendor trucks, as well as estimated gasoline fuel usage from worker vehicles is shown in Table 4-1.

Table 4-1. Construction Petroleum Demand
Project
Off -road
Equipment
(diesel)
Vendor
Trucks
(diesel)
Haul Trucks
(Diesel)
Onsite
Trucks
(Diesel)
Worker
Vehicles
(gasoline)
Gallons
2024 22,294 3,791 20,524 51 4,527
2025 27,807 22,615 0 0 24,066
2026 17,068 11,754 0 0 13,248
2028 12,077 14,532 0 0 15,916
2029 11,030 14,975 0 0 16,571
Total 90,275 67,668 20,524 51 74,327
Source: Appendix A and Appendix C
In summary, construction of the project is conservatively anticipated to consume 74,327 gallons of gasoline and 178,518 gallons of diesel. Project construction would represent a “single-event” petroleum demand and would not require on-going or permanent commitment of petroleum resources for this purpose. Therefore, impacts would be less than significant.

Operational Emissions
Electricity Usage
The operational phase would require electricity for multiple purposes, including building heating and cooling, lighting, and electronics. CalEEMod was used to estimate project emissions from electricity uses (see Appendix A).

Default electricity generation rates in CalEEMod were used based on the proposed land use and climate zone .

Table 4-2 shows the estimated annual Operational Electricity Demand by land use.

Table 4-2. Project Annual Operational Electricity Demand Summary Electricity Demand kWh/year
Industrial Business Park with Commercial – Planning Area B-1 9,462,500.99 Parking Lot – Planning Area B-1 272,452.12

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Table 4-2. Project Annual Operational Electricity Demand Summary Electricity Demand kWh/year
Hotel – Planning Area B-2 2,985,252.49
Restaurant – Planning Area B-2 1,282,419.84
Industrial Business Park with Commercial – Planning Area A 3,986,330.21 Total Project Electricity Demand 17,988,955.64
Source: Appendix A.

Note: kWh = kilowatt hour, CalEEMod Land Use shown in ( ) As shown in Table 4-2, the project is anticipated to consume approximately 17,988,956 kilowatt hours of electricity per year. The most recent energy data from the California Energy Commission shows that in 2022 the County of San Diego consumed 20,242 gigawatt hours (GWh) (CEC 2023b). The project would represent a 0.9% increase in the total demand for electricity. The Project would not represent a significant demand on electricity supplies that would require additional capacity. The Project’s electricity demand would also not result in peak and base period demands that would affect energy supplies or require additional capacity.

The project proposes industrial and commercial uses reflecting contemporary energy efficient/energy conserving designs and operational programs. Uses proposed by the Project are not inherently energy intensive, and the project electricity demands in total would be comparable to other projects of similar scale and configuration. Additionally, the project would be required to comply with the applicable Title 24 standards and PDF-GHG-2, which requires building efficiencies and the provision of solar photovolta ics, and would further ensure that the project energy demands would not be inefficient, wasteful, or otherwise unnecessary and impacts would be less than significant.

Natural Gas Usage
Natural gas consumption during operation would be required for various purposes, including, but not limited to, building heating and cooling. Default natural gas generation rates in CalEEMod for the proposed land use and climate zone were used. The project is estimated to have a total natural gas demand of 36,688,148.32 kBTU per year. The most recent energy data from the California Energy Commission shows that in 2022 the County of San Diego consumed 522.3 million therms (CEC 2023d). The project would represent a 0.007% increase in the total demand for natural gas.

The project proposes conventional industrial and commercial uses reflecting contemporary energy efficient/energy conserving designs and operational programs. Uses proposed by the project are not inherently energy intensive, and the project natural gas demands in total would be comparable to other projects of similar scale and configuration. Additionally, the Project is subject to statewide mandatory energy requirements as outlined in Title 24, Part 6, of the California Code of Regulat ions. Prior to project approval, the applicant would ensure that the project would meet Title 24 requirements applicable at that time, as required by state regulations through their plan review process. Thus, the natural gas consumption of the project would not be considered inefficient or wasteful, and impacts would be less than significant.

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Petroleum Usage
During operations, most of the fuel consumption resulting from the project would involve the use of motor vehicles traveling to and from the project site, as well as fuels used for alternative modes of transportation that may be used by employees, customers and visitors of the project.

Petroleum fuel consumption associated with motor vehicles traveling to and from the project site is a function of the VMT as a result of project operation. Similar to construction, f uel consumption from transportation was estimated by converting the total CO2 emissions from each construction phase to gallons using conversion factors for CO2 to gallons of gasoline or diesel. The conversion factor for gasoline is 8.78 kilograms per metric ton of CO 2 per gallon, and the conversion factor for diesel is 10.21 ki lograms per metric ton of CO 2 per gallon (The Climate Registry 2023). Fuel demand estimates for the project are provided in Table 4-3.

Table 4-3. Total Project-generated Transportation Annual Fuel Demand Vehicle Type Vehicle MT CO 2 Kg/CO 2/Gallon
Estimated Annual Fuel
Consumption (gallons)
Gasoline 9596.14 8.78 929,232
Diesel 8108.76 10.21 822,363
Total 1,751,595
Source: Appendix A.

Notes: Fuel use includes compliance with MM-AQ-4, which requires the use of electric-fueled cargo handling equipment.

As summarized in Table 4-3, the project would result in an estimated annual fuel demand of 1,751,595 gallons of fuel. San Diego County was estimated to consume 248,717,737 gallons of diesel fuel in 2023 from Light Heavy Duty Trucks, Medium Heavy Duty Trucks, and Heavy Heavy Duty Trucks (CARB 2024). The Project would a 0.33% increase in diesel. San Diego County was estimated to consume 1.3 billion gallons of gasoline in 2023 from light- duty passenger vehicles (CARB 2024). The project would represent a 0.07% increase in gasoline. The Project’s transportation fuel demand would not create a great demand that additional capacity would be required.

Fuel would be provided by current and future commercial vendors. Trip generation and VMT generated by the project are consistent with other industrial/commercial uses of similar scale and configuration . That is, the project does not propose uses or operations that would inherently result in excessive and wasteful vehicle trips and VMT, nor associated excess and wasteful vehicle energy consumption.

Enhanced fuel economies realized pursuant to federal and state regulatory actions, and related transition of vehicles to alternative energy sources (e.g., electricity, natural gas, biofuels, hydrogen cells) would likely decrease future gasoline fuel demands per VMT. Location of the project proximate to regional and local roadway systems tends to reduce VMT within the region, acting to reduce regional vehicle energy demands. In addition, the project is located within walking distance to the H Street Transit Station and is in a transit priority area and VMT-efficient area.

In compliance with CALGreen, the project would promote the use of bicycles as an alternative mean of transportation by providing short -term and/or long-term bicycle parking accommodations. Facilitating pedestrian and bicycle access for employees would reduce VMT and associated energy consumption. As supported by the preceding discussions, Project transportation energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary and impacts would be less than significant.

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Summary
As supported by the preceding analyses, Project construction and operations would not result in the inefficient, wasteful or unnecessary consumption of energy. The Project would therefore not cause or result in the need for additional energy producing or transmission facilities. The Project would not engage in wasteful or inefficient uses of energy and aims to achieve energy conservations goals within the State of California.

Level of Significance Before Mitigation
Impacts would be less than significant.

Mitigation Measures
No mitigation is required.

Level of Significance After Mitigation
Impacts would be less than significant.

4.4.2 Would the project c onflict with or obstruct a state or local plan for renewable energy or energy efficiency?
The project would be subject to and would comply with, at a minimum, the California Building Energy Efficiency Standards (24 CCR Part 6). Part 6 of Title 24 establishes energy efficiency standards for nonresidential buildings constructed in California in order to reduce energy demand and consumption. As such, the project would comply with the California code requirements for energy efficiency.

Part 11 of Title 24 sets forth voluntary and mandatory energy measures that are applicable to the project under CALGreen. CALGreen institutes mandatory minimum environmental performance standards for all ground-up, new construction of commercial, low-rise residential, high-rise residential, state-owned buildings, schools, and hospitals, as well as certain residential and nonresidential additions and alterations . Additionally, energy consumed by the project’s operation is calculated to be comparable to energy consumed by other industrial uses of similar scale and intensity that are constructed and operating in California. On this basis, the project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. This impact would be less than significant.

Level of Significance Before Mitigation
Impacts would be less than significant.

Mitigation Measures
No mitigation is required.

Level of Significance After Mitigation
Impacts would be less than significant.

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4.4.3 Would the Project result in a cumulatively considerable energy impact?
Cumulative projects that could exacerbate the project’s impacts include any projects that could result in wasteful, inefficient, or unnecessary use of energy. However, the project would not result in wasteful, inefficient, or unnecessary use of energy during construction or operation. Construction will result in short -term and temporary energy demands. Operation of the Project would not result in a wasteful, inefficient, or unnecessary use of energy or conflict with an applicable plan. Therefore, the project would have a less-than-significant impact with regards to cumulative energy impacts.

Level of Significance Before Mitigation
Impacts would be less than significant.

Mitigation Measures
No mitigation is required.

Level of Significance After Mitigation
Impacts would be less than significant.

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5 References
California Air Pollution Control Officers Association (CAPCOA). 2022. California Emissions Estimator Model (CalEEMod) User’s Guide, Version 2022.1. Prepared by ICF, in collaboration with Sacramento Metropolitan Air Quality Management District, Fehr & Peers, STI, and Ramboll. April. Available:
https://caleemod.com/documents/user-guide/CalEEMod_User_Guide_v2022.1.pdf CARB (California Air Resources Board). 2000. Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles. October 2000. Available: http://www.arb.ca.gov/diesel/documents/ rrpfinal.pdf.

CARB. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April 2005.

CARB. 2008. Climate Change Scoping Plan. December 2008. https://ww2.arb.ca.gov/our-work/programs/ab-32- climate-change-scoping-plan/2008-scoping-plan-documents.

CARB. 2014. First Update to the Climate Change Scoping Plan Building on the Framework Pursuant to AB 32 – The California Global Warming Solutions Act of 2006. May 2014. Accessed August 2014. http://www.arb.ca.gov/cc/scopingplan/2013_update/first_update_climate_change_scoping_plan.pdf.

CARB. 2016. “Ambient Air Quality Standards.” May 4, 2016. Available: https://ww2.arb.ca.gov/sites/default/ files/2020-07/aaqs2.pdf.

CARB. 2017. The 2017 Climate Change Scoping Plan Update. January 20. https://www.arb.ca.gov/cc/ scopingplan/2030sp_pp_final.pdf.

CARB. 2022a. Current California GHG Emission Inventory Data 2000-2019 GHG Inventory (2022 Edition).

October 26, 2022. Accessed December 2022. https://ww2.arb.ca.gov/sites/default/files/classic/cc/ inventory/2000-2020_ghg_inventory_trends.pdf .

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6 Preparers
Elena Nuño, Senior Air Quality Specialist

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Appendix A
Air Quality Emissions CalEEMod Output Files
▪ Regional Emissions Output
▪ HRA CalEEMod Output

Air Quality and Greenhouse Gas Emissions
Technical Report
Rohr Wohl Specific
Plan Project,
City of Chula Vista, California
FEBRUARY 2024
Prepared for:

CITY OF CHULA VISTA
276 Fourth Avenue
Chula Vista, California
Contact: Arturo Ortuno
Prepared by:

605 Third Street
Encinitas, California 92024
Contact: Elena Nuño, Air Quality Specialist

Printed on 30% post-consumer recycled material.

14541 i FEBRUARY 2024