ATTACHMENT " ' °
SIERRACLUB
QELTA- SiERRA GROUP
1{ h y' 4 i`".( 4 r' Ei"i
November 30, 2022
City of Lathrop Planning Commissioners
390 Towne Centre Drive
Lathrop, California
Via [email protected]. us
Re: 9. 1 Lathrop Crossroads Industrial Project Site Plan Review SPR- 22- 64; Initial Study/ Mitigated Negative Declaration for the Lathrop Crossroads Industrial Project located at 1101 D' Arcy Parkway, Lathrop, CA Dear Lathrop Planning Commissioners,
We request that the Initial Study/ Mitigated Negative Declaration for the Lathrop Crossroads Industrial Project not be adopted, nor either project options approved. Instead a complete EIR must be prepared to more fully analyze the energy needs and air quality impacts associated with either of the proposed projects, option 1 or option 2. Attached is an excerpt of the Initial Study/Mitigated Negative Declaration for the Lathrop Crossroads Industrial Project sections that are the basis for additional environmental review.
The Attorney General' s office has prepared a best practices document, which outlines additional mitigation measures not included for consideration.
Warehouses over 100, 000 can generate significant truck trips ( approximately 10, 638 miles daily is the estimate) that negatively impact air quality and our region is classified as non- attainment and issues relating to PM2. 5 exist which must be mitigated. The air quality modelling that was performed was for gasoline engine and the land use specified as a refrigerated warehouse. Refrigerated warehouses require refrigerated diesel trucks for transport. While the hazards of diesel were discussed, the air quality impacts associated with diesel trucks was not considered. The large size of the parking lot suggests that there will be the possibility of overnight truck parking which must be mitigated by having electric plug ins so that the diesel engines do not run continuously emitting the hazardous emissions referenced in the initial study.
We urge further review of possible mitigation measures to lessen the impact on residents and nearby communities
Sincerely,
Mary Elizabeth, M. S., R. E. H. S.
Detta- Sierra Group Conservation Chair, Sierra Club
mebeth( a outlook. com
1 2
Excerpts of the Initial Study1
Project Description: The project proposes to develop approximately 25 acres of vacant land currently used for percolation of treated wastewater. Two development options are proposed: 1) a single building of approximately 453,904 square feet of floor area; 2) development of three buildings with a total floor area of 396, 179 square feet. Under both options, the buildings would be available for manufacturing or warehouse activities. Access would be provided from adjacent D’Arcy Parkway. New on-site water and sewer lines would be connected to existing City mains in the adjacent street vicinity; the project proposes a storm drainage collection system that would include detention ponds and that would ultimately discharge into the City’ s storm drainage system
As indicated in the CalEEMod run (see Appendix A), the maximum VMT generated by traffic associated with project development ( under Alternative 1) would be 3,882,805 annually under unmitigated conditions, or approximately 10,638 miles daily. Based on estimates by SJCOG, such vehicle traffic would consume approximately 304,212 gallons of gasoline and diesel fuel daily. With the project features and regulations that would mitigate GHG emissions, as described in Chapter
10.0, Greenhouse Gas Emissions, total annual maximum VMT would be 3,254,657, or 8,917 miles daily. Project vehicle traffic under this condition would consume approximately 254,998 gallons of gasoline and diesel fuel daily - a decrease of approximately 16.2% from business- as-usual conditions.
Under the Alternative 2 scenario, daily gasoline and diesel fuel consumption under unmitigated and mitigated conditions would be approximately 262,632 gallons and 220,957 gallons, respectively.
APPENDIX A AIR QUALITY MODELING RESULTS
EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied
1 https:// files.ceqanet. opr.ca.gov/ 281901- 1/ attachment/ AmW0WZz7d8MqB6w6QtPL4uj4HnLajLTPjGL9v4jMB_JIbL7isEJ9ATjYvsymJmzdue3y82NK3Ww5cw60