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b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwatermanagement of the basin? RESPONSE:
No Impact. The Project is located within the San Joaquin Valley Groundwater Basin, specifically within the Modesto Groundwater Subbasin under the jurisdiction of the Central Valley Regional Water Quality Control Board (CVRWQCB).
According to the Department of Water Resources, groundwater within the Modesto Subbasin declined on average 15 feet between 1970 and 2000 (DWR, 2004; Modesto General Plan EIR, 2019). This reduction is attributed to pumping to support urban and agricultural land use. On April 23rd, 2023, borings indicated groundwater occurred at depth about 40 feet below ground surface (Universal Engineering Services, 2023).
The Project proposes to install approximately 12,000 linear feet of 12-inch potable water main within existing public right-of-way and will convert water supply for the existing Stanislaus Elementary School from a well to the City’s potable water system Construction may temporarily increase water demand from the City’s existing adjacent potable water system; however, this increase is temporary and is not anticipated to be substantial due to the size of the Project and the anticipated intermittent use of water during the various construction activities. Upon completion of Project construction, the area will return to pre-Project conditions, and will result in no substantive changes on groundwater use or recharge. The Project will have no impact on water demand since increased school enrollment is not anticipated to directly result from Project implementation. Furthermore, the Project will not indirectly support population growth beyond what has already been approved in the General Plan due to Project consistency with the approved Water Master Plan. The existing well within Stanislaus Elementary School property boundaries will be abandoned pursuant to a Demolition and Abandonment Plan that will be prepared for the Project by the Contractor prior to start of construction in accordance with City Standard Specifications No. Chapter 13. Demolition and Abandonment Plan. Mitigation Measure MM HYDRO-03: Demolition and Abandonment Plan.
For the reasons above, the Project will not substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the Project may impede sustainable groundwater management of the basin. No impacts are anticipated.
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i. result in a substantial erosion or siltation on- or off-site; RESPONSE:
Less than Significant Impact. The Project will not result in substantial erosion or siltation on-or off-site due to permanent changes in drainage patterns. Construction will temporarily alter drainage patterns and implementation of Mitigation Measures MM HYDRO—01, and MM HYDRO-02: StormwaterBMPs throughout Project Construction, will protect water quality in surface waters during construction. The Project will return disturbed surfaces to pre-project conditions and will not permanently change the direction or volume of surface flows discharging into the municipal storm drain system or involve direct modification of the topography or additional impervious surfaces at the Project Location. The proposed fire hydrants will not substantively change the area of impervious surfaces or the volume, rate, or patterns of surface flows. Likewise, the Project does not involve modifications of a stream or river. The Project is not near a stream or river and would be located south of the nearest irrigation canal located on the north side of Kiernan Avenue and east of Darby’s Pet Paradise.
According to Project plans, the Project will follow existing conditions and will result in surfaces restored to preproject conditions with the exception of the fire hydrants. Project improvements will result in no substantive permanent changes in impervious surfaces or topography. Additional impervious surfaces are not proposed for the Project and the construction of these project components will include drainage plans meeting the applicable city, county, and Caltrans standards for compliance with existing conditions in areas adjacent to the Project for discretionary approvals. Therefore, substantial changes to the rate or volume of surface runoff from the proposed Project will not occur. During construction the Project will remove approximately 0.3 acres of impervious surfaces and temporarily disrupt soils and existing drainage. However, substantial erosion or siltation either on-or-off-site would not occur due to implementation of a SWPPP by the contractor as verified by the City of Modesto Utilities Department.
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As a result, less than significant impacts to substantial increases in the rate or amount of surface runoff in a manner which would result in substantial erosion or siltation on- or off-site are not anticipated.
ii. substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
RESPONSE:
Less than Significant Impact. Increased impervious surfaces are not proposed with the Project. According to plans, the Project will not substantially change existing topography and surface conditions. Runoff at the Project Site will not change from existing conditions since impervious surfaces are not proposed; therefore the Project will not substantially increase the rate or amount of surface runoff. The Project Site will remain the same postconstruction.
For the reasons below, less than significant impacts are anticipated related to the amount of surface runoff and flooding either on- or off-site. No Mitigation Measures are needed.
iii. create or contribute runoff waterwhich would exceed the capacity of existing or planned stormwaterdrainage systems or provide substantial additional sources of polluted runoff; or RESPONSE:
Less than Significant Impact. The Project does not anticipate permanent increases in impervious surfaces or significant alterations in drainage patterns. Likewise, the Project would not result in changed land use or new sources of pollution which could enter runoff. The Project location will be returned to pre project conditions after construction. Therefore, the volume and rate of runoff with the Project in place will remain substantially consistent with existing conditions and no impacts on existing or planned stormwater drainage systems will occur. Since the Project Location will return to pre-Project conditions, with the exception of the fire hydrants, after Project construction is complete, the Project will not result in changes to topography, area of impervious surfaces or introduce new sources of pollution. During construction water quality BMPs will be implemented by the contractor pursuant to Mitigation Measures Hydro-01 through Hydro-03 of the MMRP. Implementation of these mitigation measures for erosion control during construction will result in runoff conditions that are substantially similar to existing conditions.
As a result, less than significant impacts are anticipated, and no additional Mitigation Measures are needed.
iv. impede or redirect flood flows?
RESPONSE:
Less than Significant Impact. According to the FEMA Flood Hazard Map, the Project Location and Local Vicinity are not located in a designated flood zone that many result in potential inundation at the Project Location (FEMA 2015). The entire Project is within Zone X defined as “Area of Minimal Flood Hazard” potential (Universal Engineering Services, 2023).
In addition, plans for Project development indicate general consistency between the completed Project and the existing drainage patterns at the site and surrounding the Project Site. Construction will temporarily modify topography and could alter localized drainage to redirect surface flows within Kiernan Avenue right-of-way around active construction. Due to the scale of the Project, involving approximately 75 linear feet of active construction daily, significant impacts are not anticipated. Since the Project does not propose to permanently impede or redirect flood flows within the Project Area, the impacts are considered less than significant. No Mitigation Measures are needed.
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to Project inundation? RESPONSE:
No Impact. See Section 5.10.3, Response a) through c) iv above. The California Department of Conservation does not place the Project Location within a zone at risk for a tsunami (CA Department of Conversation, 2015). The Project Area is located within southwestern San Joaquin Valley, which is not geographically close to ocean or large bodies of water.
For the reasons above, the proposed Project is anticipated to have no impacts related to release of pollutants due to Project inundation in a flood hazard, tsunami or seiche zone. Therefore, no Mitigation Measures are needed.
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e) Conflict with or obstruct implementation of a waterquality control plan or sustainable groundwater management plan? RESPONSE:
Less than Significant with Mitigation Incorporated. See Section 5.10.3, Responses a) through d) above. The Project Area is located within the San Joaquin Valley Groundwater Basin and Modesto Groundwater subbasin. The Project will follow current requirements for pollution source control and flood control or sustainable ground water management plan. A Local Storm Water Pollution Prevention Plan (SWPPP) pursuant to the NPDES will be incorporated into Project specifications. In addition, the Project contractor will implement stormwater pollution prevention measures and erosion control pursuant to Modesto General Plan Policies (See Table 16: Consistency with Modesto GP Floodway and Water Quality Applicable Mitigating Policies above) Mitigation Measures MM HYDRO-02: StormwaterBMPs throughout Project Construction, and Modesto Standard Specifications No. 2.12 Pre-construction Requirements; 2.02 Improvement Plan Submittal
For the reasons above, Project impacts are less than significant with mitigation incorporated during construction activities.
MITIGATION MEASURES
MM HYDRO-01: Local SWPPP. Prior to Plan approval and Bid Award, the City of Modesto Utilities staff shall verify that a Local SWPPP is developed and incorporated in the plan set for implementation during Project construction for construction areas.
The Local SWPPP should identify the Water Quality Manager for the Project, be kept on site in the construction trailer for the duration of construction and shall incorporate daily updates on water quality compliance activities by the Water Quality Manager, conforming with the approved Local SWPPP. The objectives of the Local SWPPP are to identify pollutant sources from construction that may affect the quality of stormwater discharge, to implement source control practices for each pollutant source, and to either filter or contain and dispose of polluted water and materials prior to discharge from construction areas. The intent of the SWPPP is to minimize pollutants in stormwater discharges from the Project into the existing drainage system from construction, and to protect receiving water quality and beneficial uses downstream. The Local SWPPP may include, but is not limited to, the following elements:
a. Detail erosion control measures pursuant to CASQA Factsheet EC-1 to EC-16 implementing BMPs intended to control sedimentation and erosion in disturbed areas during construction activities. BMPs include:
i. Incorporation of erosion control into the construction schedule (EC-1); ii. Minimal land disturbance and avoidance measures in sensitive land areas (EC-2) including natural water bodies or natural drainage systems.
iii. Stabilization measures in disturbed areas via Hydraulic mulch (EC-3), Hydroseeding (EC-4), Soil binders (EC-5), straw mulch (EC-6), geotextiles and mats (EC-7), wood mulching (EC-8), compost blankets (EC-14), nonvegetative stabilization (EC-16);
iv. Collect sediment-laden runoff in temporary sediment basins (EC-9), velocity dissipation devices (EC-10), slop drains (EC-11), streambank stabilization (EC-12); Soil testing prior to start of construction to ensure selection of appropriate BMPs and prepare soil for vegetation enhancements (EC-15);
2. Detail sediment control measures pursuant to CASQA Factsheet SE-1 to SE-14 implementing soil prevention and control measures:
i. Protect all stockpiles from stormwater run-on using temporary perimeter sediment barriers such as compost berms (SE-13), temporary silt dikes (SE-12), fiber rolls (SE-5), silt fences (SE-1), sandbags (SE-8), gravel bags (SE-6), or biofilter bags (SE-14).
3. Detail drain inlet protection in the public right-of-way pursuant to CASQA Factsheet SE-10 implement SE-2, Sediment Basin or SE-3, Sediment Trap and/or used in conjunction with other drainage control, erosion control, and sediment control BMPs to protect the site;
4. Detail stabilized entrance and egress from construction site to minimize track-out.
5. Detail on-site concrete wash out area to minimize track-out.
6. Detail stockpile management, material storage & delivery areas to minimize dust and control loose materials.
7. Detail solid waste management practices implementing waste disposal in covered waste receptacles.
8. Detail location of temporary sanitary waste facilities implementing proper disposal practices including:
i. Place covered trash and recycling cans in accessible areas for use near active construction.
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ii. Cover and maintain dumpsters. Check frequently for leaks. Never clean a dumpster by hosing it down on-site where wash water can enter the storm drain system.
iii. Dispose of trash daily.
iv. Sweeping areas around dumpsters and prohibiting the disposal of liquid chemicals or waste in dumpsters.
9. List name and contact number of person responsible for implementation of and adherence to Local SWPPP.
10. State size of project in square feet or acres or cubic yards.
MM HYDRO-02: StormwaterBMPs throughout Project Construction. Prior to start of Project construction and on an ongoing basis throughout construction, the City of Modesto Utilities Department shall verify that Best Management Practices for Construction from the SWPPP or functional equivalent are implemented by the contractor and verified with inspections throughout construction activities. Inspections by the City of Modesto will ensure that the Project contractor maintains the following BMPs for general business practice, vehicle maintenance, clean up, education, and erosion prevention:
General Business Practice
1. Schedule activities such as excavation, saw cutting, and paving during dry weather.
2. Keep materials out of the rain. Store them under cover with temporary roofs or plastic sheets/tarps, protected from rainfall, runoff, and wind.
3. Use as little water as possible for dust control to avoid excess runoff of sediment.
4. Keep pollutants off exposed surfaces.
5. Make sure portable toilets are in good working order. Check frequently for leaks.
Vehicle Maintenance
6. Maintain all vehicles and heavy equipment per manufacturers specifications. Inspect frequently for leaks.
7. Designate one area for vehicle parking, vehicle refueling, and routine equipment maintenance. The designated area should be well away from gutters and storm drains and fitted with spill containment.
8. Perform major vehicle maintenance and vehicle/equipment washing off site.
9. Use drip pans or drop cloths to catch drips and spills.
10. Do not use diesel fuel to lubricate equipment or parts.
Clean Up
11. Ensure that there are appropriate spill kits on site and that all employees are trained on the locations and use of the kits.
12. Never hose down streets to clean up tracked dirt. Use wet/dry sweep or vacuum methods.
13. Clean up leaks, drips, and other spills immediately. This will prevent contaminated soil or residue on paved surfaces.
14. Never hose down surfaces where materials have spilled. Use dry cleanup methods whenever possible.
15. Clean up spills on dirt areas by digging up and properly disposing of contaminated soil.
16. Sweep up dry spilled materials immediately. Never attempt to bury them or “wash them away” with water.
17. Report significant spills to the appropriate spill response agencies immediately.
Employee and Client Education
18. Educate your employees. Include water quality training in new employee orientations and conduct annual review sessions.
19. Educate your customers. Post BMPs where clients and employees can see them. Handling Materials and Wastes
20. Practice source reduction – minimize waste when ordering materials. Only order the amounts needed to complete the job.
21. Use recycled and recyclable materials whenever possible.
22. Never bury waste materials or leave them in the street.
23. Dispose of all waste properly.
Erosion Prevention
24. Reestablish stable upper/top crust on disturbed surfaces. This includes application of water or chemical stabilizers.
Re-vegetation (permanent or temporary) is an excellent form of erosion control for any site.
25. Avoid excavation and grading activities during wet weather.
26. Construct diversion dikes to channel runoff around the site. Line channels with grass or roughened pavement to reduce runoff velocity.
27. Plant permanent vegetation as soon as possible, once excavation and grading activities are complete.
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11. LAND USE AND PLANNING
Issues
Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
XI. LAND USE AND PLANNING. Would the Project:
a) Physically divide an
established community?
b) Cause a significant
environmental impact due
to a conflict with any land
use plan, policy, or
regulation adopted for the
purpose of avoiding or
mitigating an environmental
effect?
DISCUSSION
a) Physically divide an established community?
RESPONSE:
Less than Significant Impact. The Project will be implemented within existing developed roads and within the parcel for the Stanislaus Elementary School to serve the existing school use. Although the Project will result in temporary disruption of these areas during construction it will not divide the established community or approved land use on either a temporary or permanent basis. The other parcels adjacent to the Project and the surrounding local vicinity are developed with agricultural land uses and are planned for development with village residential (VR) pursuant to the City of Modesto General Plan Land Use Map. See Figure 3B. City of Modesto General Plan Land Use Map.
The Project involves subsurface installation of a potable water main within the public right-of-way that is planned to avoid existing travel lanes, utilities, structures, and existing habitable buildings. Underground improvements along Dale Road and Tully Road will connect to existing dead-end 12-inch potable water mains owned and operated by the City of Modesto. Upon the competition of the Project improvements to the public right-of-way, surfaces will return to preProject conditions with the exception of the above ground fire hydrants. However, the above-ground improvements will provide future fire suppression for the surrounding area and remove gaps in the service area. Backfilling and repaving of the public right-of-way will occur pursuant to CalTrans 2014 Manual on Uniform Traffic Control Devices, Stanislaus County 2016 General Plan EIR Circulation Element, and City of Modesto Standard Specifications, 3.02 Design: C) Pavement Design. In addition, due to temporary Project construction, the contractor will implement a traffic control plan for work within the paved right-of-way pursuant to the City’s Standard Specifications, Chapter 8. Utility and Trench Sections: Traffic Control Plan, and CALTRANS standards, Part 7 Traffic Control for School Areas and Part 6. Temporary Traffic Control. The traffic control plan will ensure that safe and consistent through access is maintained during shortterm Project construction along Dale Road, Kiernan Avenue, and Tully Road.
As a result, the Project does not anticipate impacts to physical division of an established community. Project implementation will not divide an established community and are consistent with concepts evaluated in the City’s Water Master Plan. No Mitigation Measures are needed.
b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect? RESPONSE:
Less than Significant Impact. The Project Alignment will be implemented mostly within the public right-of-way. The Project does not propose to change existing land use patterns or conflict with existing plans, policies, or regulations. The Project is intended to extend the City of Modesto’s water system to serve the existing school, replacing well water with water from the City’s potable water system, and to correct deficiencies in the water system by replacing capped mains with a loop system serving established and approved land use in the Local Vicinity The Project Area is within the Kiernan/Carver North Comprehensive Planning District (CPD) and Kiernan Business Park Specific Plan (SCH #2007052071); therefore, the City’s Land Use policies LUP-22 through LUP-25, which support the FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH #2024121117 #8..
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buildout of CPDs and Specific Plans that require new public facilities, water, wastewater, and stormwater infrastructure, are consistent with Project plans and previously approved specific plans (Modesto General Plan, 2019; Kiernan Business Park Specific Plan, 2009- Figure III.12: Proposed Water Facilities System).
Since the proposed Project will not exceed what has been anticipated under the City’s Water Master Plan, and City General Plan, Project implementation is not expected to cause significant environmental impact due to conflicts with a land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. The Project is intended to mitigate 1,2,3-TCP contamination within the SUSD Water System and provide the SUSD service area with safe, drinking water complaint with drinking water standards. The Project will not As a result, less than significant impacts are anticipated. No Mitigation Measures are necessary.
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12. MINERAL RESOURCES
Issues
Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
MINERAL RESOURCES. Would the Project:
a) Result in the loss of
availability of a known
mineral resource that would
be a value to the region and
the residents of the state?
b) Result in the loss of
availability of a locally
important mineral resource
recovery site delineated on
a local general plan, specific
plan or other land use plan?
DISCUSSION
a) Result in the loss of availability of a knownmineral resource that would be a value to the region and the residents of the state?
RESPONSE:
No Impact. Stanislaus County’s mineral production consists of mineral from the construction processes (sand, gravel), industrial processes (diatomite, clay, mineral pigments, magnesite, quartz, dimension stone), and metallic minerals (chromite, placer gold, manganese, mercury, platinum, and silver) (California Department of Conservation, Division of Mines and Geology 1993; Modesto GP EIR, 2019). The only mineral resources that are actively mined throughout the County include sand and gravel. No areas within the City of Modesto’s UAGP planning area are classified as Mineral Resource Zones under the Surface Mining and Reclamation Act. The planning area is underlain by areas zoned under MRZ-3a for sand and gravel and minerals with undetermined significance.
The Project is being implemented to achieve City standards for fire flow and state drinking water standards and does not conflict with the approved General Plan or Water Master Plan. The Project would support the approved land use in the City’s General Plan and would not induce substantial additional growth and development; therefore, indirect project impacts on mineral resources would not occur as a result of the Project. Best Management Practices to maintain continuous access to adjacent properties and manage drainage and water quality. Areas disturbed during project construction will be restored to pre-project conditions, with the exception of the fire hydrants, which will serve the local area. For these reasons, significant impacts would not result from the project. b) Result in the loss of availability of a locally important mineral resource recovery site delineatedon a local general plan, specific plan or other land use plan?
RESPONSE:
No Impact. See Response 12, a). There are no locally important mineral resource recovery sites delineated in the County’s General Plan and City of Modesto. The Project would not induce additional growth beyond what is approved with existing zoning and general plan. Therefore, Project implementation will not result in direct or indirect impacts on mineral resources or the loss of availability of a locally important mineral resources recovery site delineated on a local general plan or other land use plan. No impacts are anticipated.
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13. NOISE
Issues
Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
XIII. NOISE. Would the Project result in:
a) Generation of a substantial
temporary or permanent
increase in ambient noise
levels in the vicinity of the
Project in excess of standards
established in the local
general plan or noise
ordinance, or applicable
standards of other agencies?
b) Generation of excessive
groundborne vibration or
groundborne noise levels?
c) For a Project located within
the vicinity of a private
airstrip or an airport land use
plan or, where such a plan
has not been adopted, within
two miles of a public airport
or public use airport, would
the Project expose people
residing or working in the
Project area to excessive
noise levels?
REGULATORY FRAMEWORK
Federal Noise Control Act of 1972
In 1972, the U.S. Environmental Protection Agency (EPA) Office of Noise Ambient and Control issued the Federal Noise Control Act, which established programs and guidelines to identify and address the effects of noise on public health, welfare, and the environment. The EPA established Levels of Environmental Noise recommended that Ldn should not exceed 55 dBA outdoors or 45 dBA indoors to prevent significant activity interference and annoyance in noise-sensitive areas (e.g. residences, schools, hospitals, etc.). 55 dBA was identified as an “adequate margin of safety” for noise level increase relative to a baseline noise exposure level of 55 dBA Ldn. The standards set by the EPA’s Federal Noise Control Act are advisory exposure levels below which there would be no risk to a community from any health or welfare effect of noise.
In 1981, EPA administrators determined that subjective issues such as noise would be better addressed at lower levels of government. Consequently, in 1982 responsibilities for regulating noise control policies were transferred to State and local governments. However, noise control guidelines and regulations contained in EPA rulings in prior years remain in place by designated Federal agencies, allowing more individualized control for specific issues by designated Federal, State, and local government agencies.
City of Modesto
General Plan
The City of Modesto General Plan Chapter VII – Environmental Resources and Open Space contains noise related policies which apply to the proposed Project. Applicable policies are presented below.
Policies
Construction activities are to comply with Modesto Municipal Code Title 4, Chapter 9. Implement noise-reducing construction practices as conditions of approval where substantial construction-related noise impacts would be likely to occur, such as with extended periods of pile driving, or where construction is expected to continue or where sensitive receptors would be affected by construction noise. Conditions of approval may include, but are not limited to:
a) Require construction equipment, including air compressors and pneumatic equipment to have properly maintained mufflers;
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c) Require that the quietist equipment available be used; and d) Require sections of haul routes that affect the fewest number of people. e) Incorporate construction practices and acoustic treatment in new residential construction to reduce typical indoor noise levels to 45 dB. Developers of residential buildings within the 65 dBA contours shown in the General Plan Master EIR shall demonstrate that interior noise has been reduced to 45 dB. Other types of development should be protected against noise intrusion at least to the levels.. f) At noise-sensitive land uses, increases in noise should not exceed 3 dBA where any other noise threshold or standard would be exceeded, and/or 5 dBA where noise levels would otherwise fall within acceptable limits, for the existing conditions scenario as compared to the buildout scenario. g) Additional study and/or mitigation for outdoor recreation areas will be required if:
h) For single-family dwellings, noise exceeds 65 dBA Ldn in one or more backyards; i) For multi-family dwellings, noise exceeds 65 dBA Ldn at common recreation areas, such as swimming pools or play areas or at private patios and balconies; or,
j) For other uses, noise exceeds the level considered “conditionally acceptable”. k) Limit trucking to specific routes, times, and speeds that avoid or minimize adverse effects on sensitive receptors. l) For construction activities involving high-powered vibratory tools or pile driving within 200 feet of an existing structure, demonstrate that Project construction would not exceed the CALTRANS construction vibration thresholds to ensure that no damage to sensitive structures would occur.
Municipal Code
The City of Modesto Municipal Code addresses noise regulations and standards in Chapter 9 Noise Regulations. According to Section 4-9.104 the following specific acts are subject to exemptions and declared to be public nuisances in violation of Section 4-9.102:
a) The loud and raucous discharge into the open air of the steam of any steam equipment or exhaust from any stationary internal-combustion engine;
b) The loud and raucous operation or use of any of the following before 7:00 AM or after 9:00 PM daily (except Saturday and Sunday and state or federal holidays, when the prohibited time shall be before 9:00 AM and after 9:00 PM):
a. A hammer, or any other device or implement used to pound or strike an object. b. An impact wrench or other tool or equipment powered by compressed air. c. A hand-powered saw.
d. Any tool or piece of equipment powered by an internal-combustion engine such as, but not limited to, chain saw, backpack blower, and lawn mower. Except as included in subsection (a)(6), motor vehicles, powered by an internal-combustion engine and subject to the California Vehicle Code, are excluded from this prohibition.
e. Any electrically powered (whether by alternating current electricity or by direct current electricity) tool or piece of equipment used for cutting, drilling, or shaping wood, plastic, metal, or other materials or objects, such as, but not limited to, a saw, drill, lathe or router. f. Any of the following: heavy equipment (such as but not limited to bulldozer, steam shovel, road grader, back hoe), ground drilling and boring equipment (such as but not limited to derrick or dredge), hydraulic crane, and boom equipment, portable power generator or pump, pavement equipment (such as but not limited to pneumatic hammer, pavement breaker, tamper, compacting equipment), pile-driving equipment, vibrating roller, sand blaster, gunite machine, trencher, concrete truck and hot kettle pump. g. Any construction, demolition, excavation, erection, alteration, or repair activity.
DISCUSSION
The responses in this section are based on the Noise Impact Analysis for Stanislaus Elementary School 1,2,3-TCP Mitigation Project conducted by Ganddini Group, dated December 14th, 2023 (Appendix E). Results from the noise impact analysis are based on long-term 24-hour noise measurements were taken from December 5th, 2023, to December 6th, 2023, for the purposes of determining noise impacts associated with on-site and off-site construction related noise. Locations for the longterm and short-term noise measurements are shown in Figure 8: Noise Measurements below.
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a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards establishedin the local general plan or noise ordinance, or applicable standards of other agencies?
RESPONSE:
Less than Significant with Mitigation Incorporated. Long-term noise measurements and short-term noise measurements were taken at various location along the Project Alignment to determined existing ambient noise levels. The short-term ambient noise levels ranged between 62.6 and 72.9 dBA Leq. Long-term hourly noise measurement ambient noise levels ranged from 43.6 to 59.8 dBA Leq. The dominant noise source in the Project vicinity was vehicle traffic associated with Dale Road, Kiernan Avenue, Tully Road, Carver Road, American Avenue, and other surrounding roadways. Existing sensitive land uses in the Project area that may be affected by Project noise include the existing residential, school, and transient lodging uses located adjacent or near Kiernan Avenue between Tully Road to Dale Road. See Table 1. Surrounding Land Uses.
Construction Noise On-site
Construction-related noise sources are regulated by the Federal Transit Administration (FTA); and City of Modesto’s Municipal Code, which prohibits the loud and raucous operation or use of construction equipment outside of the hours between the hours of 7:00 AM and 9:00 PM daily except on Saturday, Sunday, and state or federal holidays in which the hours are to be between 9:00 AM and 9:00 PM. Exemptions are giving under subsection (b) in the event of an urgent necessity and in the interest of public health and safety. Therefore, the Project will result in significant impacts if construction occurs outside of time zones specified within the City of Modesto Municipal Code; and if noise levels exceed dBA Leq for an 8-hour period at residential and noise-sensitive outdoor areas, according to the Federal Transit Administration construction noise criteria.
Based on calculations of Project construction noise at nearby sensitive receptors using FTA methodology and “worstcase conditions”, construction noise will range between 82 and 98 dBA Leq. Since the exact location of the pipeline within the road right of way or adjacent property is not known at this time, conservative assumptions were used.
For example, there are existing single-family adjacent to the pipeline route. Because the construction noise standards apply at the property line, the worst-case scenario was assumed to be 25 feet. Project construction noise will exceed the FTA noise threshold of 80 dBA Leq for an 8-hour period at residential and noise-sensitive outdoor areas. Although FTA standards only apply to residential land uses, impacts to commercial land uses, schools and parks were also considered.
Construction noise levels at the retail uses near the jack and bore site near the intersection of Dale Road and Kiernan Avenue may reach up to 82.5 dBA Leq. Retail land uses are not considered sensitive. Therefore, this impact is less than significant, and no mitigation is required.
Construction noise levels at the Elementary School may reach up to 92.0 dBA Leq at a distance of 50 feet on school grounds; construction noise levels at single-family homes near Tully Road and Kiernan Avenue may reach up to 92.0 dBA Leq at a distance of 50 feet on school grounds; construction noise along the pipeline alignment at residential land uses could reach up to 97.7 dBA Leq. These impacts are anticipated to be significant. As a result, Mitigation Measure MM NOI-01: Construction Noise, will be implementing during Project construction.
Construction Noise Off-site
Roadway noise levels were calculated for land uses adjacent to Kiernan Avenue in the Project vicinity based on the FHWA Traffic Noise Prediction Model methodology. As shown in the CalEEMod output files provided in the Air Quality, Global Climate Change, and Energy Impact Analysis prepared for the proposed Project (see Appendix A), the greatest number of construction-related vehicle trips per day would be a maximum of up to approximately 37 vehicle trips per day (32 for worker trips, 2 for vendor trips, and 2.44 for hauling trips). The most recent traffic count for Kiernan Avenue along the Project alignment is approximately 14,200 average daily trips (ADT)6. Roadway noise levels were calculated for the following scenarios:
Existing (without Project): This scenario refers to the existing year traffic noise conditions.
Existing Plus Project Construction: This scenario refers to the existing year plus Project construction traffic noise conditions.
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Modeling results show that the existing noise level along Kiernan Avenue is 73.4 dBA CNEL and the existing plus Project noise level would be 73.5 dBA CNEL. The proposed Project would result in a noise increase of less than one decibel and impacts would be less than significant. No mitigation measures are required.
With the implementation of Mitigation Measure MM NOI-01: Construction Noise, the Project will result in less than significant impact throughout on-site and off-site constriction activities.
b) Generation of excessive groundborne vibration or groundborne noise levels? RESPONSE:
Less than Significant Impact. The California Transportation and Construction Vibration Guidance Manual (CALTRANS, 2020) establishes criteria for groundborne vibration. The guidelines recommend that the threshold at which there is a risk of architectural damage is a peak particle velocity (PPV) of 0.25 inches/second (in/sec) for historic buildings, PPV of 0.3 in/sec at older residential structures, and a PPV of 0.5 in/sec at new residential structures and modern commercial/industrial buildings. According to CALTRANS, groundborne vibration becomes an annoyance when PPV of 0.4 in/sec is exceeded (CALTRANS, 2020).
The closest structures to the proposed construction activities include single family residential structures as close as 25 feet. Plate compactors are the most vibratory equipment that may be used near an existing structure. The peak particle velocity (PPV) per square foot associated with these vibratory plates is 0.21 at a distance of 25 feet (see Table 17: Construction Equipment Vibration Source Levels below). They are not, however, expected to be utilized within 25 feet of an existing structure. Other equipment anticipated to be used during Project construction generate lower PPV. Therefore, groundborne vibration generated by Project construction would not exceed the levels necessary to cause architectural damage. Use of plate compactors would not exceed the threshold for annoyance due to vibration (PPV of 0.4 in/sec) at residential receptors along the Project route. This impact would be less than significant.
TABLE 17: CONSTRUCTION EQUIPMENT VIBRATION SOURCE LEVELS Equipment WWsĂƚϮϱŌ͕ŝŶͬƐĞĐ ƉƉƌŽdžŝŵĂƚĞ>ǀΎĂƚϮϱŌ
Pile Driver (impact) Upper range 1.518 112
typical 0.644 104
Pile Driver (sonic) Upper range 0.734 105
typical 0.170 93
Clam shovel drop (slurry well) 0.202 94
Hydromill (slurry wall) In soil 0.008 66
In rock 0.017 75
Vibratory Roller 0.210 94
Hoe Ram 0.089 87
Large Bulldozer 0.089 87
Cassion Drilling 0.089 87
Loaded Trucks 0.076 86
Jackhammer 0.035 79
Small Bulldozer 0.003 58
Source: Noise Impact Analysis, Ganddini 2023 (Appendix E) Notes: Based on Federal Transit Administration Transit Noise and Vibration Impact Assessment Manual, 2018. *RMS velocity in decibels, VbB re 1 micro-in/sec
Substantial sources of groundborne vibration during post-construction Project operations will include the movement of passenger vehicles and trucks on paved and generally smooth surfaces. Loaded trucks generally have a PPV of 0.076 at a distance of 25 feet (CALTRANS, 2020), which is a substantially lower PPV than that of a vibratory roller (0.210 in/sec PPV at 25 feet). Therefore, groundborne vibration levels generated by Project operations would not exceed those modeled for Project construction.
As a result, less than significant impacts are anticipated. No Mitigation Measures are required.
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c) For a Project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not beenadopted, within twomiles of a public airport or public use airport, would the Project expose people residing or working in the Project area to excessive noise levels? RESPONSE:
No Impact. The closest airport to the Project Site is the Modesto City-County Airport located approximately 6 miles to the southeast of the Project Alignment. The proposed Project is that of the installation of approximately 12,000 linear feet of 12-inch potable water pipeline along Tully Road; Kieran Avenue; and Dale Road. Therefore, due to both the nature of the proposed Project and the distance to the nearest airport, the proposed Project would not expose people residing or working in the area to excessive noise levels.
As a result, impacts are not anticipated; therefore, no Mitigation Measures are required.
MITIGATION MEASURES
MM NOI-01: Construction Noise. Throughout Project construction, the following construction noise impacts must be implemented by the Project contractor and City of Modesto Utilities Department in order for noise levels during construction activities to be considered less than significant:
1. During all Project site excavation and grading on-site, construction contractors shall equip all construction equipment, fixed or mobile, with properly operating and maintained mufflers, consistent with manufacturer standards.
2. The contractor shall place all stationary construction equipment so that emitted noise is directed away from the noise sensitive receptors nearest the Project site. One-inch plywood or acoustical blankets capable of achieving a reduction level of at least 10 dB shall be used to keep equipment noise from exceeding the 80 dBA noise level standard.
3. Equipment shall be shut off and not left to idle when not in use.
4. Whenever possible, electric power will be used in lieu of internal combustion engine power.
5. The contractor shall locate equipment staging in areas that will create the greatest distance between construction-related noise/vibration sources and sensitive receptors nearest the Project site during all Project construction.
6. Jackhammers, pneumatic equipment, and all other portable stationary noise sources shall be shielded, and noise shall be directed away from sensitive receptors.
7. The Project proponent shall mandate that the construction contractor prohibit the use of music or sound amplification on the Project site during construction.
8. The construction contractor shall limit haul truck deliveries to the same hours specified for construction equipment.
9. The quietest equipment available will be utilized when feasible; and,
10. Haul routes that affect the fewest number of people will be utilized whenever possible.
11. Construction activities near and at the school site shall be limited to only when the school is not in use.
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Figure 8: Noise Measurement Locations
City of Modesto
Stanislaus Elementary School 1,2,3-TCP Mitigation Project Source: Noise Impact Analysis, Appendix E (Ganddini, 2023) Not to Scale
Legend
Noise Measurement Location >
NM1
Short-Term Noise MeasurementLong-Term Noise Measurement ST NM
LT NM
PROJECT
Fire Hydrant
#8..
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14. POPULATION AND HOUSING
Issues
Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
XIV. POPULATION AND HOUSING. Would the Project:
a) Induce substantial unplanned
population growth in an area,
either directly (for example,
by proposing new homes and
businesses) or indirectly (for
example, through extension
of roads or other
infrastructure)?
b) Displace substantial numbers
of existing people or housing,
necessitating the
construction of replacement
housing elsewhere?
DISCUSSION
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homesand businesses) or indirectly (for example, through extension of roads or other infrastructure)? RESPONSE:
No Impact. In 2010, the population of Stanislaus County reached approximately 514,453 residents (Stanislaus County GP EIR, 2016). As of July 1st, 2022 the City of Modesto’s population has risen to 218,069 according to the US Census (US Census, 2022). According to the City of Modesto’s General Plan, population is projected to increase by approximately
27.6 percent between the study years for the General Plan between 2015 to 2050; as of 2023, roughly 250,000 residents are serviced by the City of Modesto’s eight water systems (City of Modesto, 2023). Population growth into Modesto’s UAGP over the years has been a result of urban expansion from growth pressure within San Francisco Bay Area. The City’s General Plan Circulation Element, Land Use Element, Housing Element, and Water Master Plan intend “to accommodate future growth in a controlled manner” (Modesto GP EIR, 2019).
The Project intends to install approximately 12,000 linear feet of potable water main in conformance with the City’s Water Master Plan and General Plan. The Project intends to mitigate 1,2,3-TCP contamination at the Stanislaus Elementary School by consolidating the City’s existing infrastructure with planned improvements that will connect to Stanislaus Union School District’s Water System. Since the Project is consistent with previously approved City documents and does not propose the construction of any structures (i.e. residences or commercial establishments) that would result in direct population growth or increased students at the school campus, the Project des not anticipated impacts.
As a result, the proposed Project is not anticipated to result in unplanned population growth by either implementing new homes or businesses, increasing school capacity, or indirectly extending infrastructure. Therefore, impacts are not anticipated, and no Mitigation Measures are needed.
b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
RESPONSE:
No Impact. See Response 14, a). The Project Alignment is within the public right-of-way along Dale Road, Kiernan Avenue, and Tully Road and will implement traffic control best management practices to maintain access to adjacent parcels along these roads during construction. Surrounding land uses consist of primarily agriculture fields and a mixture of commercial, industrial, institutional, and residential land use. No housing will be affected, and no people will be displaced temporarily or permanently by the extension of potable water pipeline.
For these reasons, no impacts related to the displacement of substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere is not anticipated to occur. Mitigation Measures are not needed.
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15. PUBLIC SERVICES
Issues
Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
XV. PUBLIC SERVICES. Would the Project:
a) Result in substantial adverse
physical impacts associated
with the provision of new or
physically altered
governmental facilities, need
for new or physically altered
governmental facilities, the
construction of which could
cause significant
environmental impacts, in
order to maintain acceptable
service ratios, response
times, or other performance
objectives for any of the
public services:
i. Fire Protection?
ii. Police Protection?
iii. Schools?
iv. Parks?
v. Other public facilities?
DISCUSSION
a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:
i. Fire Protection?
RESPONSE:
Less than Significant with Mitigation Incorporated. The Project is partially within the jurisdiction of Stanislaus Fire Protection District (SFPD) and Modesto Fire Department. The SFPD contains 56 full time personnel and two part time personnel with 5 fire stations that provide fire and emergency medical services. The Fire District services approximately 199 square miles of unincorporated Stanislaus County. The closest Fire Station to Stanislaus Elementary School is Station 26, approximately 6.9 miles to the northeast. The Modesto Fire Department contains 11 fully staffed stations and a future station planned within northeastern Modesto City Limits equipped to handle structural fires and emergencies (Modesto GP EIR, 2019). The other notable fire stations close to the Project Location are Modesto Fire Station 11, approximately 0.6 miles south of the Tully Road “dead-end” connection point, and Salida Fire Station 13, approximately 1.5 miles north of Tully Road and Kiernan intersection. Since the Project Location is within two fire jurisdictions, Mitigation Measure MM PUB-01: Coordination with Local Agencies for Traffic Control will help ensure coordination between the City of Modesto and Stanislaus County Fire Protection agencies.
The Project will remove existing dead end water mains in Tully Road and Dale Road, connecting existing mains in these roadways and extending potable water to the existing school, as well as improving water reliability for fire response within the Local Vicinity. The Project will replace a water well with a looped water zone within the City’s overall water system. A later connection will be constructed with the Project to connect the proposed water main in Kiernan to the school’s existing water meter; and extend north along Tully Road, where the installation of a fire hydrant will occur in the northeastern corner of the intersection for future fire suppression, where gaps in the City’s water distribution network currently exist. Improvements will remain consistent with City of Modesto Standard Specifications and Water Master Plan. The Project will not increase school use or capacity. Likewise, population and level of activity within the local vicinity will not increase or result in the need for an additional fire station, equipment, or staff over the long-term. Project will not change land use, either directly or indirectly, from what was considered FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH #2024121117 #8..
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and approved in the existing General Plan and Water Master Plan. Therefore, there will not be an increased need for fire response beyond what has already been identified in the City’s approved Water Master Plan and General Plan. The Project proposes to maintain fire flow requirements (33 pounds per square inch at 4000 gallons per minute) pursuant to Modesto Policy FS-1.
Construction will occur within eleven (11) months, requiring a crew of approximately 16, which is not of a duration or scale that would result in substantial need for changes in the existing public services or physically altered facilities beyond what is already been planned and approved. During construction an approved traffic control plan, including input from the Fire Department, will be followed by the construction crew to reduce conflicts and delays from construction within the public right-of-way. This will allow fire protection services to function according to agency standards. Therefore, Fire Department and emergency response through the construction zone will be maintained pursuant to agency input and standards without the need for new or physically altered government facilities. As a result, less than significant impacts are expected during construction on fire and emergency services.
The standard application of the City’s plan check, inspection process will verify the implementation of fire protection performance objectives during construction and long-term operation. In addition, Mitigation Measure MM PUB-01:
Coordination with Local Agencies for Traffic Control, will help to facilitate fire protection services are maintained throughout Project construction activities.
For these reasons, impacts are considered less than significant with the implementation of Mitigation Measure MM PUB-01: Coordination with Local Agencies for Traffic Control. ii. Police Protection?
RESPONSE:
Less than Significant with Mitigation Incorporated. See Section 13, a) i). The Project is partially within District 63 of the Modesto Police Department; Dale Road and the intersection of Dale Road and Kiernan Avenue is within the service boundaries of the City’s Police Department. Kiernan Avenue, Tully Road and Stanislaus Elementary School are within the jurisdiction of the Stanislaus Sherriff’s Department, and traffic laws are enforced by the State Highway Patrol along Kiernan Avenue within the boundaries of the Project. The closest police stations to the Project are California Highway Patrol Modesto Area Office, approximately 1.9 miles east of the proposed Project Alignment, and Modesto Police Department (3005 Evergreen Avenue #600, Modesto, CA 95350), approximately 3.2 miles south of the Project Alignment.
During construction an approved traffic control plan will be followed. To ensure proper coordination for the implementation of the traffic control plan occurs between the City Utilities Department, Engineering Department, City Police, County Sheriff, and Highway Patrol, Mitigation Measure MM PUB-01: Coordination with Local Agencies for Traffic Control. This will allow services to function according to agency standards, and access will remain open throughout construction along the Project Alignment. The proposed Project will not permanently increase population or change land use resulting in increased need for police services either directly or indirectly.
Since the Project is a part of the approved Water Master Plan, intended to benefit the school and the City’s public works facilities, the Project will not impact the level of police protection at the Project Location. The Project does not propose to increase population or change land use.
As a result of the reasons above, less than significant impacts to police protection are expected. No Mitigation Measures are needed.
iii. Schools?
RESPONSE:
Less than Significant with Mitigation Incorporated. The Project Area is serviced by Stanislaus Union School District.
As mentioned within Section 2. Project Description, the Project is located within the property lines of Stanislaus Elementary School. Other education facilities closest to the Project Alignment include Big Valley Christian High School, approximately 0.9 miles from the Tully Road existing “dead-end” connection point. However, due to the Project Location relative to Big Valley Christian High School temporary, impacts during intermittent Project construction nor long-term maintenance are anticipated. Stanislaus Union School District would review plans for FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH #2024121117 #8..
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the service pipe to the elementary school and the construction schedule would be coordinated with the school district pursuant to Mitigation Measure MM HAZ-02: Coordination with Stanislaus Union School District.
Project Activities anticipated to occur within 0.25 miles of Stanislaus Elementary School include installation of 12,000 linear feet of potable water main and thirteen (13) fire hydrants using open trench construction and jack and bore construction. The installation of a service pipe for water service to the school as well as an extension, fire hydrant, and stub north of the water main in Kiernan Avenue will be installed with jack and bore construction to connect the proposed main along Kiernan Avenue to the southeastern corner of the elementary school and the northeastern corner of the Tully Drive/Kiernan Avenue intersection. Potentially significant impacts as a result of construction activities are anticipated. Construction activities may temporarily prohibit young children from biking and walking during peak hours for drop-off and pick-up, especially during the installation of the service pipe. As mentioned above, the Project’s traffic control plan pursuant to City Standards and Specifications will maintain access to Stanislaus Elementary School during the academic school year and hours of operation. However, environmental impacts including noise and air quality may prohibit open trenching and jack and bore construction from occurring during education hours. As a result, the Project should implement Mitigation Measure MM HAZ-02: Coordination with Stanislaus Union School District, which will specify construction hours within a 400-foot radius of Stanislaus Elementary School for protection to sensitive receptors throughout the School’s operations and ensure coordination occurs with SUSD prior to construction activities.
Additionally, the Project will not increase population or density either directly or indirectly within the planning area; therefore, the project will not result in changes to school enrollment. iv. Parks?
RESPONSE:
Less than Significant Impact. The Project is public works improvement and will not result in any short-term or permanent changes in demand for parks services. As mentioned within Section 16. Recreation, the closest parkland and open spaces are approximately 1 mile east of the proposed Project. The Project does not propose to change land use resulting, either directly or indirectly, in an increase in density or population that would affect park use.
Therefore, long-term impacts are not anticipated.
In addition, the Project Alignment is planned to be constructed with the public right-of-way; therefore, an approved traffic control plan will be implemented in compliance with City Standard Specifications. As a result, access to existing park land adjacent to Project Components is not anticipated to be impacted by Project construction. Less than significant impacts are anticipated; no Mitigation Measures are needed.
v. Other public facilities?
RESPONSE:
No Impact. The Project Alignment is north of Modesto City Limits, adjacent to primarily agricultural, industrial, and commercial land uses under jurisdiction of the City and Stanislaus County. See Table 1. Surrounding Land Uses and Table 2. Existing Diverse Uses Within Local Vicinity of the Project Alignment. The City Utilities Department will facilitate coordination on the Project between other city departments, County and the state. Therefore, construction is not anticipated to result in significant temporary or permanent changes to public facilities.
MITIGATION MEASURES
MM PUB-01: Coordination with Local Agencies and Special Districts for Traffic Control. Prior to start of construction, Modesto’s City Engineering Division must ensure coordination is facilitated between local agencies and special districts within Modesto City Limits and Stanislaus County including Stanislaus Consolidated Fire Protection District, Modesto Fire Department, California Highway Patrol, Stanislaus County Sherrif’s Department, Stanislaus School District, and Modesto Police Department. Coordination between Local Agencies shall involve the review of the Project’s traffic control plan and construction schedule prior to City of Modesto’s approval to ensure all agency Best Management Practices and standards are incorporated into the traffic control plan. This coordination shall also include Stanislaus Elementary School so that installation of the service pipe does not occur during school hours or pick-up and drop-off times to avoid conflicts with the operation of the school.
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16. RECREATION
Issues
Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
RECREATION.
a) Would the Project increase
the use of existing
neighborhood and regional
parks or other recreational
facilities such that substantial
physical deterioration of the
facility would occur or be
accelerated?
b) Does the Project include
recreational facilities or
require the construction or
expansion of recreational
facilities which might have an
adverse physical effect on the
environment?
REGULATORY COMPLIANCE
The Quimby Act
The Quimby Act of 1965, Section 66477 of the California Government Code, enables local governments, cities, or counties to require the dedication of land or impose a requirement of the payment of the in-lieu fees for development of community parks as well as setting minimal standards for parks.
DISCUSSION
a) Would the Project increase the use of existing neighborhood and regional parks or otherrecreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? RESPONSE:
No Impact. The closest parkland and open spaces to the Project Alignment are McKinley Colony Park, approximately 1.7 miles south of the proposed Project, and the Virginia Corridor Trailway traversing in a north-south direction, approximately 1.0 miles east of the Project Alignment (Modesto GP EIR, 2019; Figure VI-11-1: Existing Park System in City Limits). Due to distance, the Project will not directly impact parks. The Project will support long-term goals outlined in the City of Modesto’s General Plan and Water Master Plan. The Project is a subterranean water main that will connect Stanislaus Elementary School to the City of Modesto’s potable water system, replacing reliance on a well for drinking water. As such, a lateral connection will be constructed between the new main in Kiernan Avenue and the school’s water meter located near the south and east parcel boundaries of the school, approximately 500 feet from the Stanislaus Elementary School playground. Construction of the service pipe is not anticipated to disrupt sensitive receptors or the physical deterioration of the playground, since trenching will occur outside of the play area limits and construction is proposed outside of the school’s operating hours.
The Project is a subterranean public works improvement that will temporarily disrupt the public right-of-way using open trench and jack and bore methods. Through access within the streets will be maintained during construction with the implementation of an approved traffic control plan by the contractor; therefore, construction would not alter traffic resulting temporary changes to park utilization within the Local Vicinity or outlying areas. Upon completion, the public right-of-way and Project Location will be restored to existing conditions. The Project does not propose structures or buildings that will directly increase population or level of activity, resulting in permanently increased use of neighborhood and regional parks or other recreational facilities. The Project will temporarily increase daytime, weekday population at the Project location during construction; however, significantly increased park uses, resulting in substantial or accelerated physical deterioration of nearby parks, is not expected during construction due to the size of the Project and anticipated size of the construction crew.
As a result, the Project will have no impact on recreational facilities. No Mitigation Measures are required.
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b) Does the Project include recreational facilities or require the construction or expansion of recreational facilitieswhich might have an adverse physical effect on the environment? RESPONSE:
No Impact. The Project will not construct or expand recreational facilities. The Project is a subterranean utility that will not permanently affect land use or transportation. During construction the contractor will be required to implement mitigation measures and BMPs to reduce physical effects of construction on the environment to less than significance.
Upon completion of construction the Project will restore areas affected by construction to existing conditions. Therefore, the Project will have no temporary or permanent impacts related to construction or expansion of recreational facilities which will have an adverse physical effect on the environment, and no mitigation is required.
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17. TRANSPORTATION
Issues
Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
XVII. TRANSPORTATION. Would the Project:
a) Conflict with a program, plan,
ordinance or policy
addressing the circulation
system, including transit,
roadway, bicycle and
pedestrian facilities?
b) Conflict or be inconsistent
with CEQA Guidelines §
15064.3, subdivision (b)?
c) Substantially increase
hazards due to a geometric
design feature (e.g., sharp
curves or dangerous
intersections) or
incompatible uses (e.g., farm
equipment)?
d) Result in inadequate
emergency access?
REGULATORY COMPLIANCE
CEQA Guidelines
In December 2018, CEQA Guidelines Section 15064.3, subdivision (b) was adopted by the California Natural Resources Agency. The updated guidelines outline the specific considerations for evaluating a project’s transportation impacts; identifying “vehicle miles traveled” (VMT) as the most appropriate measure for determining impact levels. The updated guidelines focus primarily on transit priority areas, shifting the focus from driver delay to GHG reductions, the utilization of multimodal networks, and mixed land uses.
Section 15064.3 subdivision (b) considers all the following acceptable criteria for analyzing transportation impacts:
(1) Land Use Projects. Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor should be presumed to cause a less than significant transportation impact. Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact.
(2) Transportation Projects. Transportation projects that reduce, or have no impact on, vehicle miles traveled should be presumed to cause a less than significant transportation impact. For roadway capacity projects, agencies have discretion to determine the appropriate measure of transportation impact consistent with CEQA and other applicable requirements. To the extent that such impacts have already been adequately addressed at a programmatic level, such as in a regional transportation plan EIR, a lead agency may tier from that analysis as provided in Section 15152. (3) Qualitative Analysis. If existing models or methods are not available to estimate the vehicle miles traveled for the particular project being considered, a lead agency may analyze the project's vehicle miles traveled qualitatively. Such a qualitative analysis would evaluate factors such as the availability of transit, proximity to other destinations, etc. For many projects, a qualitative analysis of construction traffic may be appropriate. (4) Methodology. A lead agency has discretion to choose the most appropriate methodology to evaluate a project's vehicle miles traveled, including whether to express the change in absolute terms, per capita, per household or in any other measure. A lead agency may use models to estimate a project's vehicle miles traveled and may revise those estimates to reflect professional judgment based on substantial evidence. Any assumptions used to estimate vehicle miles traveled and any revisions to model outputs should be documented and explained in the environmental document prepared for the project. The standard of adequacy in Section 15151 shall apply to the analysis described in this section.
Source: CEQA Guidelines Section 15064.3- Determining the Significance of Transportation Impacts.
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DISCUSSION
a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?
RESPONSE:
Less than Significant Impact. As mentioned within Section II. Project Description, the Project Alignment will be constructed within the public right-of-way Dale Road, a minor arterial12 within the city of Modesto’s jurisdiction; Kiernan Avenue, Principal Arterial13 within CALTRANS right-of-way; and Tully Road, a minor arterial within the County public rightof-way.
The Project plans to install 12,000 linear feet of potable water pipeline within the public Right-of-Way, in addition to Project Components on City-owned parcels. No permanent changes to the City of Modesto’s circulation system are proposed with the Project; however, Project construction is anticipated to cause temporary and intermittent traffic impacts. As anticipated within the Project’s Air Quality, Greenhouse Gas, & Energy Technical Memorandum (Appendix A), construction worker trips will generate an estimated 82,944 vehicle miles travelled (VMT) during Project construction.
Project construction is anticipated to take eleven (11) months. b) Conflict or be inconsistent with CEQA Guidelines § 15064.3, subdivision (b)? RESPONSE:
Less than Significant with Mitigation Incorporated. CEQA Guidelines Section 15064.3, subdivision (b) pertains to vehicle miles traveled that are expected from a Project. The Project does not propose changes to existing or approved land use and will not facilitate permanently increased traffic trips or increased VMT. As mentioned above, Appendix A, Air Quality, Greenhouse, & Energy Technical Memorandum anticipates temporary Project construction will generate 82,944 construction works trips and 15,154 vendor and hauling trips during temporary Project construction activities, totaling 98,098 VMT. As a result of temporary increases in truck trips along local roadways, the Project will implement Mitigation Measure MM TRAF-01: Traffic Control Plan to ensure BMPs for temporary increases in VMT minimize disruptions to agricultural production, Stanislaus Elementary School pick-ups and drop-off, or the roadways within the Local Vicinity.
The traffic control plan includes land closures, barricades, signage along roadways, and designated work areas/ limits for construction activities. Long-term increases in VMT as a result of the Project are not anticipated. In addition, the traffic control plan will ensure City of Modesto, Stanislaus County, and CALTRANS standards for traffic control are being implemented throughout Project construction. In addition to MM TRAF-01: Traffic Control Plan, the Project proposes to obtain an encroachment permit pursuant to MM TRAF-02: Encroachment Permit, which will ensure that the Project Manager is compliant with standards established by CANTRANS, Stanislaus County, and the City of Modesto.
As a result, the Project does not anticipate conflicts or inconsistencies with CEQA Guidelines related to VMT with the implementation of Mitigation Measure MM TRAF-01: Traffic Control Plan and MM TRAF-02: Encroachment Permit.
c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
RESPONSE:
No Impact. The Project will be constructed below ground surface. The only above ground features are the fire hydrants for fire suppression; twelve fire hydrants are proposed on the south side of Kiernan Avenue and one will be in the northeastern corner of the Tully Road and Kiernan Avenue intersection; the fire hydrants will be installed per the City of Modesto’s Standard Specification within the margins of the public right-of-way and will be designed to avoid permanent hazards from a geometric design feature. During construction, the Project will require transport of heavy equipment to the Project location and the use of heavy equipment. Work within public right-of-way requires review and approval of an encroachment permit by the City, which will include a traffic control plan with BMPS such as temporary barriers and detours and will not allow permanent changes to Kiernan Avenue; no new driveways will be constructed with the project.
Therefore, no impacts are anticipated.
12 A Minor Arterial is meant to carry moderate- to high-volume traffic to and from collectors to other Minor Arterials, Principal Arterials, Expressways, and Freeways with a secondary function of land access. Minor Arterials located within areas zoned for heavy or light industrial or that are expected to carry large or heavy trucks shall be constructed to Industrial Major Collector standards (Stanislaus County GP EIR, 2016) 13 A Principal Arterial is to move high volumes of people and goods between urban areas within the County at higher speeds, while still providing access to abutting properties as permitted by the standards for each Principal Arterial class. Principal Arterials serve a similar function to that of Freeways and Expressways and provide access to the interregional freeway system (Stanislaus County GP EIR, 2016).
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d) Result in inadequate emergency access?
RESPONSE:
Less than Significant with Mitigation Incorporated. In the long-term, The Project location will return to pre-project conditions. However, the addition of the fire hydrants will result in a permanent above-ground structures that will change the existing landscape; this is not anticipated to be a significant impact since the fire hydrants will provide additional fire suppression to the surrounding area. There will be no impact on vehicular access near the Project Alignment or in the Local Vicinity.
However, potential for delay within the Local Vicinity during Project construction is likely, since equipment will temporarily block access, although continuous access will be maintained to developed properties throughout the duration of construction with the implementation of the City’s Standard Specifications. Therefore, throughout Project construction, the Project contractor will implement a traffic control plan pursuant to Mitigation Measure MM TRAF-01:
Traffic Control Plan. The traffic control plan will be available to first responders including Modesto Police Department, Stanislaus Sherrif’s Department, Stanislaus Consolidated Fire Protection District, and Modesto Fire Department throughout construction activities.
As a result, the Project anticipates less than significant impacts due to the implementation of Mitigation Measure MM TRAF-01: Traffic Control Plan.
MITIGATION MEASURES
MM TRAF-01: Traffic Control Plan- The City of Modesto Engineering Department shall approve a Traffic Control Plan prepared by a licensed traffic engineer, for all project-affected roadways and intersections prior to mobilization of the Project. The Traffic Control Plan shall comply with requirements in encroachment permits issued by Stanislaus County, City of Modesto and Caltrans. The Traffic Control Plan shall be implemented the contractor continuously during construction and shall include, but not be limited to, the following measures from CALTRANS, Stanislaus County, and the City of Modesto:
City of Modesto:
1. Public Notification: Two weeks, one week and 24 hours prior to beginning any work in an area or the project, provide written public notice to all residents, businesses, churches, property owners, tenants, and applicable parties adjacent to and within a 1/4-mile radius of the project area (Pursuant to Modesto Standard Specification No. 12.04 Traffic Control Requirements);
2. Right-of-way Lane Access: A minimum of one 11-foot-wide lane shall be open in each direction at non intersections, and a minimum of one 11-foot-wide lane for each striped movement at an intersection, for traffic during working hours, unless otherwise described by the Contract Documents (Pursuant to Modesto Standard Specification No.
12.04 Traffic Control Requirements)
3. Work Schedule: Normal work schedule is limited to the hours of 7:00 a.m. to 3:30 p.m. outside of the full path of the traveled way. Normal work schedule is limited to the hours of 8:30 a.m. to 3:30 p.m. when any work by the Contractor is within the traveled way, unless otherwise described by the Contract Documents (Pursuant to Modesto Standard Specification No. 12.04 Traffic Control Requirements)
4. Private Driveways: Notify the owner of the private driveway fifteen (15) calendar days prior to implementing the Traffic Control Plan (Pursuant to Modesto Standard Specification No. 12.04 Traffic Control Requirements);
5. Trenches: Backfill all trenches at the end of each workday (Pursuant to Modesto Standard Specification No. 12.04 Traffic Control Requirements);
6. Aggregate base: Provide aggregate base and compact all areas within the roadway and shoulder (Pursuant to Modesto Standard Specification No. 12.04 Traffic Control Requirements);
7. Temporary Paving & Delineators: Provide temporary paving and temporary delineators or striping at the end of each workday (Pursuant to Modesto Standard Specification No. 12.04 Traffic Control Requirements);
8. Schools: Notify schools within ½ mile of the work zone, two weeks, one week and 24 hours before implementing the approved Traffic Control Plan in the vicinity of the school;
9. Signs: Post “No Parking, Tow Away” signs on barricades along the roadway at least 48 hours prior to the construction work in that area;
City of Modesto’s BMPs are based on CATRANS standards and traffic control measures outlined within the CALTRANS Manual on Uniform Traffic Control Devices (CAMUTCD, 2014 Edition).
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MM TRAF-02: Encroachment Permit- Prior to the issuance of permits and active Project construction, the City’s Engineering and Utilities Departments in coordination with Stanislaus County and CALTRANS, must obtain an approved encroachment permit for work within the public right-of-way with plans showing no new driveways along Kiernan. Throughout Project construction, the Project contractor will be responsible for the enforcement of the encroachment permit.
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18. TRIBAL CULTURAL RESOURCES
Issues
Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
XVIII. TRIBAL CULTURAL RESOURCES.
a) Would the Project cause a
substantial adverse change in
the significance of a tribal
cultural resource, defined in
Public Resources Code §
21074 as either a site,
feature, place, cultural
landscape that is
geographically defined in
terms of the size and scope of
the landscape, sacred place,
or object with cultural value
to a California Native
American tribe, and that is:
i. Listed or eligible for
listing in the California
Register of Historical
Resources, or in a local
register of historical
resources as defined in
Public Resources Code
section 5020.1(k), or
ii. A resource determined
by the lead agency, in its
discretion and
supported by
substantial evidence, to
be significant pursuant
to criteria set forth in
subdivision (c) of Public
Resources Code §
5024.1. In applying the
criteria set forth in
subdivision (c) of Public
Resource Code §
5024.1, the lead agency
shall consider the
significance of the
resource to a California
Native American tribe.
REGULATORY COMPLIANCE
NHPA Section 106 Native American Consultation
Section 106 of the NHPA requires tribal consultation in all steps of the process when a federal agency project or effort may affect historic properties that are either located on tribal lands, or when any Native American tribe or Native Hawaiian organization attaches religious or cultural significance to the historic property, regardless of the property’s location (U.S.
General Services Administration 2022).
Assembly Bill (AB) 52
Assembly Bill (AB) 52 became effective on July 1st, 2015, and requires lead agencies to provide notice to any California Native American tribes that have requested notice of projects. Upon the receipt of the notice, the tribe has 30 days to request consultation with the lead agency. AB 52 created a new category of resources formally known as “Tribal Cultural Resources”.
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Public Resources Code 21074 defines “Tribal cultural resources as any of the following “Sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American tribe that are either: (A) Included or determined to be eligible for inclusion in the California Register of Historical Resources and/or (B) Included in a local register of historical resources as defined in subdivision (k) of Section 5020.1. This may include a resource determined by the Lead Agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Section 5024.1 for the purposes of this paragraph, the lead agency shall consider the significance of the resource to a California Native American tribe.”
DISCUSSION
a) Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code § 21074 as eithera site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or RESPONSE:
Less than Significant Impact. The cultural records search indicated that no cultural resources have been found or recorded on the current Project Location and the Project Location is vacant. Therefore, it is not anticipated that the Project will not have impacts on resources that are listed or eligible for listing in the California Register of Historical Resources or in a local register of historical resources.
In addition to the cultural resources search, a Sacred Lands File (SLF) search was conducted with the Native American Heritage Commission (NAHC). The results of the SLF search, received on November 29th, 2023, were negative, indicating the absence of cultural resources in the Project Area (See Appendix C).
Therefore, based on the results from the SLF, impacts to tribal cultural resources pursuant to Public Resources Code Section 21074 and 5020.1(k) are less than significant. However, impact is subject to change depending on the result of trial outreach explained in response b) below.
ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code § 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code § 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.
RESPONSE:
Less than Significant Impact (Pending Response to Scoping Letters). See Response a) above. As mentioned in the Cultural Resources section, the Project Area is located within the traditional boundaries of the Northern Yokuts. This tribe along with others who are relatively close to the Project Alignment and were historically present within the region are believed to have knowledge of cultural resources in the Project Area. Therefore, within the NAHC response letter from November 29th, 2023, the NAHC suggested that other cultural resources should be contacted for more information regarding known and recorded sites. The NAHC provided a list of Native American tribes that could assist in identifying potentially significant cultural resources due to these tribes’ presence in the Project Area. These tribes included the Calaveras Band of Mi-Wuk Indians, Calavera Band of Mi-Wuk Indians- Grimes, California Valley Miwok Indians, Confederated Villages of Lisjan Nation, North Valley Yokuts, Southern Serra Miwuk Nation, Tule River Indian Tribe, Wilton Rancheria, and the Wuksachi Indian Tribe/ Eshom Valley Band.
The City of Modesto completed Tribal Consultation pursuant to AB52 and Section 106 of the NHPA Native American Consultation. Based on preliminary review of the SLF, significant impacts were not anticipated.
Scoping letters were sent to the tribes on September 10, 2024. Follow-up phone calls were completed on September 11, 2024. No responses were received. Tribal consultation is considered complete indicating no significant impacts anticipated from the Project and no mitigation measures are required.
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19. UTILITIES AND SERVICES
Issues
Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
UTILITIES AND SERVICE SYSTEMS. Would the Project:
a) Require or result in the
relocation or construction of
new or expanded water,
wastewater treatment or
storm water drainage,
electric power, natural gas, or
telecommunications
facilities, the construction or
relocation of which could
cause significant
environmental effects?
b) Have sufficient water
supplies available to serve
the Project and reasonably
foreseeable future
development during normal,
dry and multiple dry years?
c) Result in a determination by
the wastewater treatment
provider, which serves or
may serve the Project that it
has adequate capacity to
serve the Project’s Projected
demand in addition to the
provider’s existing
commitments?
d) Generate solid waste in
excess of state or local
standards, or in excess of the
capacity of local
infrastructure, or otherwise
impair the attainment of solid
waste reduction goals?
e) Comply with federal, state,
and local management and
reduction statutes and
regulations related to solid
waste?
DISCUSSION
a) Require or result in the relocation or construction of new or expanded water, wastewatertreatment or storm waterdrainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
RESPONSE:
Less than Significant Impact. As mentioned within Section 2. Project Description, storm water inlets are located on the west and east side of Dale Road, near the Kiernan Avenue and Dale Road intersection. Overhead 12,000- volt and 69,000-volt electrical lines are operated and maintained by Modesto Irrigation District (MID) along the north side of Kiernan Avenue, west side of Tully Road, and east side of Dale Road. Modesto Irrigation District operates and maintains a surficial concrete-lined, irrigation system, consisting of canals and laterals, surrounding the Project in the local vicinity, which convey water from the Stanislaus River for agriculture in the Local Vicinity.
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owns gas lines within Tully Road, Kiernan Road, and Dale Road right-of-way. See Figure 9. Existing and Proposed Utilities.
At the Project Location, water and wastewater services are provided by the Stanislaus Union School District (SUSD) Water System No. CA500249. SUSD Water System is within the Stanislaus Elementary School property limits and provide water services with one active well (Well 02), PS Code 5000249-004, one inactive well (Well 01), PS Code CA5000249-001, an 8000 gallon (gal) static tank with a usable capacity of 7,435-gal, distribution piping, and appurtenances. SUSD contains an on-site septic system for wastewater services. Project implementation requires the construction of approximately 12,000 linear feet of potable water main and consolidation of SUSD Water System into the City of Modesto’s water distribution network. Consolidation and expansion of the water system is required due to 1,2,3-TCP contamination of the SUSD Water System groundwater well (Well 02). The Project is proposed to expand the water system will improve the quality of water resources for the existing SUSD consumer base, who are currently reliant upon bottled drinking water.
Improvements to the water system are outlined within the City’s Water Master Plan and General Plan, which identify, and quantify available water supplies, projected water use, maintenance needs, and system reliability pursuant to California Water Code Section 10610 et seq. (Urban Water Management Plan). The Project does not propose to develop infrastructure or public utility improvements that have not already been considered and approved by the City of Modesto.
Since the proposed Project is anticipated to connect to existing 12-inch “dead-end” connection points along Dale Road and Tully Road, conflicts with existing utilities have the potential to occur. However, Best Management Practices (BMPs) within Project plans intend to reduce potential conflicts with existing utilities through potholing prior to Project construction in accordance with Modesto Standard Specification No. 6.08 Installation and proposed jack and bore construction14 under existing utilities to avoid relocation.
As a result, the Project anticipates less than significant impacts. No mitigation measures are needed. b) Have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years?
RESPONSE:
No Impact. The proposed Project is consistent with the of the City’s Water Master Plan and would not induce growth beyond what is currently approved in the City’s General Plan. Therefore, the Project will improve the City’s water infrastructure according to planned buildout of the City’s General Plan and Water Master Plan by replacing two dead end water mains with a looped system between Dale Avenue and Tully Avenue. The Project will also extend the proposed water main through the Kiernan Avenue and Tully Road intersection for the installation of a fire hydrant in the northeastern corner and future extension of the City’s Water Master Plan. The fire hydrant will provide fire suppression for adjacent properties and fill gaps in the City’s require water infrastructure pursuant to Modesto’s Standard Specifications.
The Project does not propose to develop infrastructure that would increase population or density at any of the Project Locations or Local Vicinity. As a result, no impacts are foreseen, as the Project is not anticipated to substantially impact water supplies that serve the Project and reasonably foreseeable future development during normal and multiple dry years. No Mitigation Measures are needed. c) Result in a determination by the wastewater treatment provider, which serves or may serve the Project that it has adequate capacity to serve the Project’s Projected demand in addition to the provider’s existing commitments?
RESPONSE:
14 The jack and bore location will be video inspected to ensure that City Storm Drain and Sanitary Sewer utilities within 5 feet of the proposed boring locations are not disrupted. This will occur pursuant to City of Modesto Standard Specification No. 8.03 Design.
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No Impact. Wastewater flows at the Project Location collect within an on-site septic tank. Since the proposed Project does not anticipate an increase in the generation of wastewater over the long-term, SUSD’s septic system does not need to account for increased capacity due to Project activities. Therefore, changes to the facilities existing commitments are not anticipated. No impacts are anticipated, and Mitigation Measures are not required for the Project.
d) Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals? RESPONSE:
Less than Significant Impact. The California Integrated Waste Management Board (CIWMB) oversees, manages, and tracks waste generated within California. Assembly Bill (AB) 939 and Senate Bill 1322 shaped the CIWMB and required that all California cities and counties implement programs to reduce, recycle, and compost at least 50 percent of wastes by 2000 (PRC Section 41780). To remain compliant with CIWMB, cities and counties track diverted waste by counting the materials disposed at landfills and subtracting that amount from the base-year amount.
The Project does not propose to increase population or density at the Project Site. Therefore, waste management services or submittal of an approved Waste Management and Recycling Plan for the Project location is not necessary. The Project will install new infrastructure and may result in disposal of some debris during construction. As a result, the contractor will implement minimum housekeeping practices according to the California Stormwater BMPs Handbook pursuant to Standard Condition SC UTL-01: Waste Management Plan for the Project, which will include temporary lidded bin at the Site for collection, disposal, recycling, and transport of construction waste.
Upon completion of construction, no waste is expected to result after Project construction; regular disposal agreements/ methods are not required. However, during Project construction Standard Condition SC UTL-01:
Waste Management Plan will be implemented to prevent minimize impacts throughout Project construction. No Mitigation Measures are needed.
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste? RESPONSE:
No Impact. The Project will not increase solid waste production over the long term since the Project does not propose to convert the land use from open space to development. No impacts are anticipated, and no mitigation measures are required. Temporary construction activities will comply with the City’s Standard Specifications for waste management referenced in Section 19. d).
MITIGATION MEASURE
SC UTL-01: Waste Management Plan- Prior to Project construction, the City’s Utilities Department shall ensure Project specifications include standards conditions pertaining to good housekeeping practices. The City’s standard plan check and review process will ensure the following measures are included in Project Specifications and maintain throughout active construction within the Project Area:
1. Site Clean Up: The Contractor shall keep the Project Site clean and free of dust, mud, and debris resulting from the Contractor's operations. Daily clean up throughout the project shall be required as the Contractor progresses with the work. Extra precautions and cleanup efforts shall be made prior to weekends, holidays and predicted storm events.
2. Continuous Street Sweeping throughout active construction.
Spillage of earth, gravel, concrete, asphalt, or other materials resulting from hauling operations along or across any public traveled way shall be removed immediately by the Contractor at his expense. If site is not kept sufficiently clean, the City will take measures to clean it and back charge the Contractor.
3. Solid Waste Management: Refer to CASQA Factsheet WM-5 and WM-6. a. Select designated waste collection areas onsite.
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b. Inform trash-hauling contractors that you will accept only watertight dumpsters for onsite use.
Inspect dumpsters for leaks and repair any dumpster that is not watertight. c. Locate containers in a covered area or in a secondary containment. d. Provide an adequate number of containers with lids or covers that can be placed over the container to keep rain out or to prevent loss of wastes when it is windy. e. Cover waste containers at the end of each workday and when it is raining. f. Plan for additional containers and more frequent pickup during the demolition phase of construction.
g. Collect site trash daily, especially during rainy and windy conditions. h. Remove this solid waste promptly since erosion and sediment control devices tend to collect litter. i. Make sure that toxic liquid wastes (used oils, solvents, and paints) and chemicals (acids, pesticides, additives, curing compounds) are not disposed of in dumpsters designated for construction debris. j. Do not hose out dumpsters on the construction site. Leave dumpster cleaning to the trash hauling contractor.
k. Arrange for regular waste collection before containers overflow. l. Clean up immediately if a container does spill. Q Make sure that construction waste is collected, removed, and disposed of only at authorized disposal areas.
4. Material Storage and Delivery Area: Refer to CASQA Factsheet WM-1. a. Chemicals must be stored in watertight containers with appropriate secondary containment or in a storage shed.
b. Temporary storage areas should be located away from vehicular traffic. c. Material delivery and storage areas should be located away from waterways, if possible. d. Employees and subcontractors should be trained on the proper material delivery and storage practices.
5. Concrete Waste Management: Refer to CASQA Factsheet WM-8. a. Store dry and wet materials under cover, away from drainage areas. Refer to WM-1, Material Delivery and Storage for more information
b. Perform washout of concrete trucks in designated areas only, where washout will not reach stormwater.
c. Do not wash sweepings from exposed aggregate concrete into the street or storm drain. Collect and return sweepings to aggregate base stockpile or dispose in the trash.
6. Spill Prevention and Control: Refer to CASQA Factsheet WM-3. a. Ensure that stockpile coverings are installed securely to protect from wind and rain.
7. Temporary Sanitary Waste Facilities: Refer to CASQA WM-10 a. Instruct employees and subcontractors how to safely differentiate between non-hazardous liquid waste and potential or known hazardous liquid waste.
b. Instruct employees, subcontractors, and suppliers that it is unacceptable for any liquid waste to enter any storm drainage device, waterway, or receiving water. c. Educate employees and subcontractors on liquid waste generating activities and liquid waste storage and disposal procedures. Q Hold regular meetings to discuss and reinforce disposal procedures (incorporate into regular safety meetings).
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Kiernan Avenue
Carver Road Carver Road
Kiernan Avenue
Kaiser Permanente
Modesto
Medical Center
Dale Road Dale Road Bangs Ave Bangs Ave Pelandale Ave Pelandale Ave Claratina Ave Tully Road Tully Road Tully Road
Dale Road
Bangs Ave
Pelandale Ave
American Ave.
Kiernan Substation
(MID)
âx
âx
âx
Esri, HERE, Garmin, (c) OpenStreetMap contributors, and the GIS user community, Source: Esri, Maxar,Earthstar Geographics, and the GIS User Community Figure 9: Existing & Proposed Utilities
City of Modesto
Stanislaus Elementary School 123-TCP Mitigation Project 0 0.25 0.5 0.75 1 0.125
Mile
¯
Existing Stanislaus Elementary School Property Site
12,000 volt primary overhead (MID)
Telephone Lines (AT&T)
Lateral Number Six
Lateral Number Six
Lateral Number One
Irrigation Ditch
Modesto Main Canal
(east-west)
Existing Gas Lines (PG&E)
Connection Point to Existing Pipeline
69,000 volt transmission overhead (MID)
âx Underground Electrical Transformer (MID)
Electrical Poles (MID)
Existing Overhead Transformer (MID)
¬« Fire Hydrant
Project
Hydrological Flowlines
Modesto City Limits
¬«
¬«
¬«
¬«
¬«
¬«
¬«
¬«
¬«
¬«
¬«
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20. WILDFIRE
Issues Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the Project:
a) Substantially impair an
adopted emergency
response plan or emergency
evacuation plan?
b) Due to slope, prevailing
winds, and other factors,
exacerbate wildfire risks, and
thereby expose Project
occupants to pollutant
concentrations from a
wildfire or the uncontrolled
spread of a wildfire?
c) Require the installation or
maintenance of associated
infrastructure (such as roads,
fuel breaks, emergency
water sources, power lines
or other utilities) that may
exacerbate fire risk or that
may result in temporary or
ongoing impacts to the
environment?
d) Expose people or structures
to significant risks, including
downslope or downstream
flooding or landslides, as a
result of runoff, post-fire
slope instability, or drainage
changes?
REGULATORY COMPLIANCE
2019 CEQA Guidelines
In 2019, CEQA Guidelines were amended to address the need to evaluate wildfire impacts since it has worsened in recent history.
While wildfires have been prevalent throughout California’s history and more acres of California have burned in the past decade than in the previous 90 years (CALFIRE, Top 20 Largest California Wildfires 2022). Wildfires are caused from natural sources, such as lightening or meteors, and from human activities such as downed powerlines, electrical sources, associated with development (CA Attorney General 2022). As development expands, there is greater potential for wildland fire to occur at wildland-urban interfaces. Approximately one-third of California’s housing units are currently located within these areas (CA Attorney General 2022). As a result of the increased risk to wildfire risks within the state of California, CEQA recognizes best practices to disclose, analyze, and mitigate wildfire impacts can be found within local jurisdictions by utilizing general plan documents.
CALFIRE Fire Hazard Severity Zones
The CALFIRE Hazard Severity Zone (FHSZs) is “a mapped area that designated zones (based on factors such as fuel, slope, and fire weather) with varying degrees of fire hazard” (CALFIRE 2022). CALFIRE released a FHSZ Viewer that identifies areas where wildfires are prone to occur (CALFIRE FHSZ Viewer, 2022). The utilization of this tool is meant to limit wildfire damage in preliminary phases of planning to mitigate and prevent activities or land uses that would cause greater risk for a wildfire.
According to CALFIRE’s FHSZ Viewer, the Project Components are not within designated Fire Hazard Severity Zones (CALFIRE FHSZ Viewer). The closest lands that are categorized as such are east and west of the Project Location, approximately 15 and 18 miles from the Project Location, outside of City Limits.
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DISCUSSION
a) Substantially impair an adoptedemergency response plan or emergency evacuation plan? RESPONSE:
Less than Significant with Mitigation Incorporated. The Project is located primarily within the Dale Road, Kiernan Avenue, and Tully Road right-of-way. According to the City of Modesto Water Master Plan, Figure 11-1. City of Modesto Emergency Evacuation Routes, Kiernan Avenue is an established evacuation route. As mentioned within Section 9.
Hazards and Hazardous Waste, Response e), the Project will implement a Traffic Control Plan pursuant to Mitigation Measure MM TRAF-01: Traffic Control Plan to ensure emergency access and safety throughout construction activities are maintained.
Due to the Project Location’s proximity to the closest CALFIRE Fire Hazard Severity Zone (CALFIRE FHSZ Viewer), Project implementation is not anticipated to involve significant impacts to evacuation routes and emergency response plans within vulnerable, fire-prone areas. An emergency at the Project Location will be served by Stanislaus Consolidated Fire Protection District Station 26, located at 3318 Topeka St in downtown Riverbank, approximately 6.9 miles northeast of Stanislaus Elementary School. Station 26 is equipped with one (1) Type 1 Engine, one (1) Type 6 Grass, and one (1) water rescue boat; and staffed with 3 personnel. Other notable fire stations in proximity to the Project Location include Modesto Fire Station 11, approximately 0.6 miles south of the Tully Road “dead-end” connection point, and Salida Fire Station 13, approximately 1.5 miles north of Tully Road and Kiernan intersection. Fire stations closest to the Project Location will also assist in providing access to evacuation routes during disasters according to The City of Modesto Emergency Operations Plan and Local Hazard Mitigation Plan.
Due to required implementation of CAL-OSHA standards for worker safety and safety requirements outlined in the City of Modesto’s Standard Specifications including erecting and maintain barricades, guards, warning signs, and lights (Standard Specification No. 12.06 General Irrigation, Part B Rules and Regulations); and bracing excavations and utilize shoring methods to protect trenches (Standard Specification No. 8.04 Materials, Part D Bracing Excavations, the Project is not anticipated to require additional or unique emergency response services.
As a result of the reasons above, the Project will implement Project Mitigation Measure MM TRAF-01: Traffic Control Plan during Project construction to reduce impacts to a less than significant level.
b) Due to slope, prevailing winds, and otherfactors, exacerbate wildfire risks, and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolledspread of a wildfire? RESPONSE:
Less Than Significant. Project construction would increase traffic and activity on a temporary and intermittent basis along Dale Road, Kiernan Avenue, and Tully Road; at Stanislaus Elementary School and in the Project Area. However, due to the size of the construction crew (approximately 18 workers) and scale of the project (approximately 100 linear feet of active construction daily), as well as safety measures that will be implemented by the contractor during construction, this increase is not expected to be significant.
The Project Site is relatively flat and does not contain steep slopes that may exacerbate wildfire risks. In addition, Modesto experiences significant seasonal variation in wind speeds over the course of the year; but primarily experiences calm winds during most of the year between August and April, averaging 5.7 miles per hour (Waetherspark.com, 2023).
The Project Location is not within a CALFIRE Fire Hazard Severity Zone, as a result the Project Area is not susceptible to fire. However, deciduous fruit orchards and other agricultural land uses abutting the Project Alignment and Stanislaus Elementary School that may be susceptible to fire if BMPs are not implemented during Project construction. For this reason, Best Management Practices for construction will ensure safety at the job site through proper materials and equipment storage and regular inspections of equipment on-site are performed to ensure flammable gasoline is not leaking.
Therefore, the impacts due to slope, prevailing winds, and other factors related to wildfire are less than significant.
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c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
RESPONSE:
No Impact. The Project proposes installation and long-term maintenance of a subterranean water main, which will not exacerbate fire risk or result in elevated long-term fire risk. The Project is intended to improve reliability of the City’s water system within the Local Vicinity and will support fire flow and fire response within the Local Vicinity. Project plans indicate open trench and jack and bore construction will be used to install approximately 12,000 linear feet of potable water pipeline within the CALTRANS, County, and City right-of-way. The City of Modesto’s Standard Specifications require use of trench plates and exclusion fencing for active areas of construction and the contractor will be required to implement CAL-OSHA standards for worker safety which will manage continuous access, emergency response, and fire risk during construction. Therefore, Project construction is not expected to substantially exacerbate fire risk on a temporary or intermittent basis.
The Project will consolidate Stanislaus Union School District’s Water System with the City of Modesto’s Water Distribution Network to provide potable water services for Stanislaus Elementary School and abandon on-site Well 02 pursuant to Stanislaus County and California Department of Water Resources requirements, which is currently contaminated with 1,2,3-TCP. Prior to construction activities, the Project Area will be potholed and marked by the Project contractor to avoid existing infrastructure including gas lines, electrical, power lines, etc. and to avoid potential disruptions. Existing utilities along the Project Area are outlined in Section 19. Utilities and Services. See Figure 9. Existing and Proposed Utilities.
Upon the competition of the proposed construction, substantial changes in maintenance activities due to Project implementation would not be needed. On-site inspections may occur at the Project Location in substantial conformance with existing inspections and would not interfere with existing land use and activities in the Local Vicinity beyond existing conditions as well as what has already been approved and considered by the City of Modesto’s Water Master Plan and General Plan documents.
For the reasons above, no impacts are anticipated. No Mitigation Measures are needed.
d) Expose people or structuresto significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? RESPONSE:
No Impact. Refer to Response 20. c). The City’s Standard Specifications and CAL-OSHA standards will be implemented to reduce short-term localized temporary and intermittent risks during construction related to drainage, runoff and soil instability. According to CALFIRE’s Fire Hazard Safety Zone Map, the area is designated as Local Responsibility exhibiting no high-moderate fire hazards. Therefore, based on this assessment, the Project Location is not in an area with unique features or elevated risk from wildfire, slope, flooding, runoff, landslides, and drainage. In addition, the Project would not substantively change long-term level of activity, topography, or land use patterns at the Project Location or in the Local Vicinity. The prevailing land use to within the Local Vicinity is agriculture, industrial, and commercial within a setting consisting of gently sloping topography. The Project does not propose to change existing land use or change existing topography via grading. Upon Project competition, the Project Area will return to pre-Project conditions; the only above-ground changes consist of the fire hydrants which will provide fire suppression to the surrounding areas. The Project is consistent with the City’s Municipal Code and will be verified during the standard application of the City’s plan check and inspection process prior to and during construction.
For these reasons, no impacts are anticipated. No Mitigation Measures are needed.
MITIGATION MEASURES
See Mitigation Measure MM TRAF-01: Traffic Control Plan in Section 17) Transportation.
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21. MANDATORY FINDINGS OF SIGNIFICANCE
Issues
Potentially
Significant Impact
Less than Significant
Impact with
Mitigation
Incorporated
Less than Significant
Impact No Impact
MANDATORY FINDINGS OF SIGNIFICANCE. Would the Project:
a) Does the Project have the
potential to substantially
degrade the quality of the
environment, substantially
reduce the habitat of a fish or
wildlife species, cause a fish
or wildlife population to drop
below self-sustaining levels,
threaten to eliminate a plant
or animal community,
substantially reduce the
number or restrict the range
of a rare or endangered plant
or animal or eliminate
important examples of the
major periods of California
history or prehistory?
b) Does the Project have
impacts that are individually
limited, but cumulatively
considerable? (“Cumulatively
considerable” means that the
incremental effects of a
Project are considerable
when viewed in connection
with the effects of past
Projects, the effects of other
current Projects, and the
effects of probable future
Projects.)
c) Does the Project have
environmental effects which
will cause substantial adverse
effects on human beings,
either directly or indirectly?
DISCUSSION
a) Does the Project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the numberor restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? RESPONSE:
Less than Significant with Mitigation Incorporated. The discussion for Environmental Checklist indicates only short-term, temporary impacts will occur with Project implementation. Mitigation measures to reduce all potentially significant impacts to less than significance are provided in this document. Due to its location within street right-of-way and developed land, the Project has very limited potential to result in direct significant impacts on wildlife or habitat. Mitigation Measures MM BIO-01: Preconstruction Nesting Bird Clearance Survey has been incorporated in this ISMND to require preconstruction surveys and nest protections if needed and will reduce impacts on nesting migratory birds and Swainson’s hawk which are protected under federal and state regulations and may be found in proximity with Project construction. Less than significant impacts with mitigation would occur.
The Project is anticipated to be implemented within areas that have been previously disturbed and within engineered fill. Mitigation measures requiring preconstruction training for cultural resources and treatment protocols for buried resources, should they be encountered, have been included in this document. Therefore, impacts on major periods of FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH #2024121117 #8..
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California history or prehistory would be avoided and/or reduced to a less than significant levels by implementation of mitigation measures MM CUL-01: Worker Environmental Awareness Training, MM CUL-02: Cultural Resources Discovery, and MM CUL-03: Human Remains.
b) Does the Project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a Project are considerable whenviewed in connection with the effects of past Projects, the effects of other current Projects, and the effects of probable future Projects.) RESPONSE:
Less than Significant with Mitigation Incorporated. As the preceding sections identify, the Project would extend the City of Modesto’s existing water service area and replace a substandard water well for the Stanislaus Elementary School. The Project would improve system reliability, water quality and fire flow. It will not change level of maintenance activity required to operate the City’s water delivery system as a whole or increase school attendance or capacity. The Project is consistent with the planned buildout of the General Plan and the Water Master Plan. Consequently, Project operation would not increase the level of impact on any resource above what is currently anticipated with full buildout of the General Plan as analyzed in the Certified General Plan EIR and the EIR for the City’s Water Master Plan.
As the preceding sections identify, the Project would not require increased ongoing operations and maintenance-related activity, that would differ materially from what is now occurring. The Project would improve system reliability, it would likely decrease the level of maintenance activity required to operate the District’s wastewater collection system as a whole.
Potentially significant impacts have been identified for ten resources in the Project vicinity: aesthetics, agricultural resources, biological resources, cultural resources, geology and soils, hazardous materials, hydrology, transportation, and tribal resources. Project impacts will be reduced to less than significance with the implementation of recommended mitigation measures identified herein: aesthetics (MM AES-01: Construction Lighting Plan, MM AES-02: Coordination with Private Landowners), agricultural resources (MM AG-01: Buffer and Setback Guidelines), biological resources (MM BIO-01: Preconstruction Nesting Bird Clearance Survey), cultural resources (MM CUL-01: Worker Environmental Awareness Training, MM CUL-02: Cultural Resources Discovery, and MM CUL-03: Human Remains), geology and soils (MM GEO-01 through MM GEO-11), hazardous materials (MM HAZ-01: Coordination with Stanislaus Union School District ), hydrology (MM HYDRO-01: Local SWPPP, MM HYDRO-02: StormwaterBMPs throughout Project Construction, MM HYDRO-03: Demolition and Abandonment Plan), transportation and wildfire (MM TRAF-01: Traffic Control Plan).
For the reasons stated above, the Project does not have the potential to achieve short-term, to the disadvantage of long-term, environmental goals.
c) Does the Project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
RESPONSE:
Less than Significant with Mitigation Incorporated. The Project will improve the quality of drinking water for an elementary school and would not result in substantial adverse effects on human beings, either directly or indirectly. The City has committed to a number of standards and best management practices to reduce potential impacts as well as mitigation measures for the project which will be implemented to reduce potentially significant impacts to less than significant levels:
- As discussed in the Project Description, to manage traffic in the safest and most efficient manner possible, the City will require the Project Contract Documents to include a Traffic Control Plan with detailed delineation of work zones, work hours, lane closures, signage locations, and provisions to maintain safe and uninterrupted residential, business, recreational, and institutional access while providing for vehicle, pedestrian, bicyclist and transit passage through work area. Development of the Traffic Control Plan will be coordinated with the City’s staff (MM TRAF-01: Traffic Control Plan).
- Construction noise will be controlled by requiring the contractor in the Project Contract Documents to follow all applicable laws and policies as discussed in the Environmental Commitments portion of the Project Description as well as the noise analysis and limit construction activities near the school to hours when this facility is not in use. (MM NOI-01: Construction Noise).
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- Construction and demolition would also generate dust and would require the use of diesel and gasoline internal combustion equipment that emits various pollutants, but the project would have limited (less than significant) potential to impact air quality and human health because of the proposed implementation of fugitive dust control measures as well as the short duration of construction activity and the small number of pieces of equipment in use at any given time(MM hydro-01: Local SWPPP and MM HYDRO-02: StormwaterBMPs Throughout Project Construction).
- Construction of the Project would involve monitoring during ground-disturbing activities for cultural, archaeological and paleontological resources, as well as documentation and repatriation of found artifacts which is are considered full mitigation for the project (MM CUL-01: Worker Environmental Awareness Training, MM CUL-02: Cultural ResourcesDiscovery, and MM CUL-03: Human Remains).
With the implementation of mitigation measures, the cumulative impacts of the project would be less than significant.
The project would have substantial benefits to the community by modernizing and improving the reliability of the City’s wastewater infrastructure; reducing overall maintenance needs and costs; and substantially reducing the potential for failures that can result in major repairs and/or service shutdowns.
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VII. REPORT PREPRATION
This section lists those individuals who contributed to the preparation of this Initial Study/ Mitigated Negative Declaration.
7.1 CITY OF MODESTO
Jim Alves Senior Civil Engineer (City of Modesto)
7.2 AGENCIES OF PERSONS CONTACTED
The following agencies or persons were contacted during the preparation of this document.
Contact Affiliation
Lori Trottier, AICP CEP Ardurra Group
Riley Christie, ENV SP, LEED AP ND Ardurra Group
Omar Khelifi Ardurra Group
Dolores Salgado Ardurra Group
Travis McGill ELMT
David Brunzell BCR Consulting
Cate Howe Ganddini
Giancarlo Ganddini Ganddini
Kate Wilson Ganddini
Roma Stromberg Ganddini
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VIII. REFERENCES
The following references were utilized during preparation of this Initial Study/ Environmental Checklist.
PROJECT DESCRIPTION
1. City of Modesto Water Master Plan, Draft Environmental Impact Report, Project No. 15.042, October 2019
2. City of Modesto Wastewater Master Plan, Draft Environmental Impact Report, Project No. 15.043, June 2019,
3. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR
4. Stanislaus County General Plan and Airport Land Use Compatibility Plan Update, Draft Program Environmental Impact Report, adopted April 2016, https://www.stancounty.com/planning/pl/gp/current/DraftEIR.pdf
5. Feasibility Study/ Preliminary Engineering Report for Stanislaus Elementary School 1,2,3-TCP Mitigation, August 2023, prepared by Ardurra Group
AESTHETICS
6. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Section 19. Effects on Visual Resources
7. Stanislaus County General Plan and Airport Land Use Compatibility Plan Update, Draft Program Environmental Impact Report, adopted April 2016, https://www.stancounty.com/planning/pl/gp/current/DraftEIR.pdf a. Aesthetics
8. Modesto Designated Landmarks (Appendix D), City of Modesto, Report of the Natural Preservation Commission, https://www.modestogov.com/DocumentCenter/View/15052/EIR-14-001-EXH-Landmarks-Summary-Report-1-7- 17-PDF?bidId=
AGRICULTURE AND FORESTRY RESOURCES
9. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Section 4. Effects on Agricultural Lands
b. Figure V-4-1: Important Farmland Within City of Modesto Planning Area c. Figure 5-2: Williamson Act Contracts
10. California Department of Conservation, California Important Farmland Finder, 2022, https://maps.conservation.ca.gov/dlrp/ciff/
11. California Department of Conservation. 2004. A Guide to the Farmland Mapping and Monitoring Program, 2004 Edition. Available at: www.conservation.ca.gov/dlrp/fmmp/Documents/ fmmp_guide_2004.pdf.
12. California Department of Conservation. 2016a. Williamson Act Lands GIS data for Stanislaus County. Available at:
ftp://ftp.consrv.ca.gov/pub/dlrp/FMMP/2016/.
AIR QUALITY
13. Appendix A- Air Quality, Global Climate Change, and Energy Impact Analysis for Stanislaus Elementary School 1,2,3- TCP Mitigation Project, Gandini Group, December 14th, 2023.
14. City of Modesto General Plan Update Air Quality and Greenhouse Gas Assessment, Modesto, California, February 13th, 2018, updated June 12th, 2018, https://www.modestogov.com/DocumentCenter/View/15054/EIR-14-001- DOC-AQ-GHG-Technical-Appendix-6-12-18-PDF?bidId=
15. California Resources Board Ambient Air Quality Standards, adopted May 4th, 2016, https://ww2.arb.ca.gov/sites/default/files/2020-07/aaqs2.pdf
16. San Joaquin Valley Air Pollution Control District (SJVAPCD), Ambient Air Monitoring Network, https://ww2.valleyair.org/air-quality-information/air-monitoring/
17. CALGREEN, the Green Building Code Part 11, Title 24, California Code of Regulations, https://up.codes/viewer/california/ca-green-code-2019
BIOLOGICAL RESOURCES
18. US Fish and Wildlife Service, Migratory Bird Treaty Act of 1918, https://www.fws.gov/law/migratory-bird-treaty-act1918 FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH #2024121117 #8..
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19. California Fish and Game Code, California Legislative Information, https://leginfo.legislature.ca.gov/faces/codesTOCSelected.xhtml?tocCode=FGC&tocTitle=+Fish+and+Game+Code+ -+FGC
CULTURAL RESOURCES
20. Appendix C- Cultural Resources Assessment for Stanislaus Elementary School 1,2,3-TCP Mitigation Project, Modesto and Unincorporated Stanislaus County, CA, BCR Consulting, 2023.
ENERGY
21. Appendix A- Air Quality, Global Climate Change, and Energy Impact Analysis for Stanislaus Elementary School 1,2,3- TCP Mitigation Project, Gandini Group, December 14th, 2023.
22. 23. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Chapter V. Energy
24. City of Modesto Water Master Plan, Draft Environmental Impact Report, Project No. 15.042, October 2019 a. Chapter 10. Greenhouse Gas Emissions and Energy Resources
25. Modesto Irrigation District, About MID, n.d., https://www.mid.org/about/default.html
26. CALGREEN, the Green Building Code Part 11, Title 24, California Code of Regulations, https://up.codes/viewer/california/ca-green-code-2019
27. Stanislaus County General Plan and Airport Land use, Compatibility Plan Update Draft Program EIR, April 2016, https://www.stancounty.com/planning/pl/gp/current/DraftEIR.pdf a. Section 3.3. Air Quality
GEOLOGY AND SOILS
28. Appendix C- Cultural Resources Assessment for Stanislaus Elementary School 1,2,3-TCP Mitigation Project Modesto and Unincorporated Stanislaus County, CA, BCR Consulting, 2023.
29. Appendix D- Soils and Geotechnical Investigation, Stanislaus Elementary School 1,2,3-TCP Mitigation Project, Modesto, Stanislaus County, California, prepared by Universal Engineering Services on June 1st, 2023
30. City of Modesto Water Master Plan, Draft Environmental Impact Report, Project No. 15.042, October 2019 a. Chapter 9. Geology, Soils, and Seismicity
b. Table 9-1. Regional Faults in Proximity to the Study Area
31. USGS Geologic Hazards Science Center, Quaternary Faults Map, https://usgs.maps.arcgis.com/apps/webappviewer/index.html?id=5a6038b3a1684561a9b0aadf88412fcf
32. California Department of Conservation, Fault Activity Map of California, 2015, https://maps.conservation.ca.gov/cgs/fam/
33. California Department of Conservation, Landslide Inventory (Beta), 2015, https://maps.conservation.ca.gov/cgs/lsi/
34. City of Modesto Standard Specifications, 2014, https://www.modestogov.com/DocumentCenter/View/1615/2014- City-of-Modesto-Standard-Specifications-PDF
35. City of Modesto Engineering and Transportation Department Standard Specifications, 2021, https://www.modestogov.com/ArchiveCenter/ViewFile/Item/1118
36. California Department of Conservation, Geologic Map of California, 2015, https://maps.conservation.ca.gov/cgs/gmc/
GREENHOUSE GAS EMISSIONS
37. City of Modesto 2050 General Plan Update and Environmental Report, Final Technical Memorandum: Climate Change Vulnerability Assessment, adopted June 2022, https://gp2050.modestogov.com/wpcontent/uploads/2022/06/Modesto-VulnerabilityAssessment-Final_June-2022.pdf
38. Appendix A- Air Quality, Global Climate Change, and Energy Impact Analysis for Stanislaus Elementary School 1,2,3- TCP Mitigation Project, Gandini Group, December 14th, 2023.
HAZARDS AND HAZARDOUS MATERIALS
39. California Fire Hazard Severity Zone Viewer (FHSZ Viewer), CAL FIRE, https://egis.fire.ca.gov/FHSZ/
40. EnviroStor, Department of Toxic Substances, Cortese List, 2023, https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=modesto FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH #2024121117 #8..
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41. GeoTracker, California State Waterboards,
https://geotracker.waterboards.ca.gov/map/?myaddress=California&from=header&cqid=2272458732
42. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Section 16. Hazards and Hazardous Materials
43. Stanislaus County Local Hazard Mitigation Plan, Stanislaus County Office of Emergency Services, updated 2017, https://www.stanoes.com/pdf/lhmp/2017-lhmp.pdf
a. 2016 Stanislaus County- Dam Inundation Hazard
44. City of Modesto Water Master Plan, Draft Environmental Impact Report, Project No. 15.042, October 2019 a. Chapter 11. Hazards and Hazardous Materials
i. Figure 11-1. City of Modesto Evacuation Routes
45. California Department of Water Resources, California Well Standards, Combined, Part III. Destruction of Water Wells, 2023, https://water.ca.gov/Programs/Groundwater-Management/Wells/Well-Standards/Combined-WellStandards/Water-Destruction
46. Stanislaus County, Stanislaus County Groundwater Well Siting and Construction Guidelines, May 5th, 2023, https://www.stancounty.com/er/pdf/05-05-2023-stanislaus-cnty-well-siting-guidelines-redline.pdf
HYDROLOGY AND WATER QUALITY
47. Appendix D- Soils and Geotechnical Investigation, Stanislaus Elementary School 1,2,3-TCP Mitigation Project, Modesto, Stanislaus County, California, prepared by Universal Engineering Services on June 1st, 2023
48. California Water Boards- State Water Resources Control Board, Regional Water Quality Control Boards, PorterCologne Water Quality Control Act, amended January 2023, https://www.waterboards.ca.gov/laws_regulations/docs/portercologne.pdf
49. U.S. Department of Homeland Security, Federal Emergency Management Agency, Glossary, https://www.fema.gov/about/glossary
50. State of California Delta Protection Commission, Delta Protection Act, https://delta.ca.gov/delta-protection-act/
51. FEMA’s National Flood Hazard Layer (NFHL) Viewer, https://hazardsfema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b5529aa9cd
52. California Department of Conservation (DOC), Geologic Hazards Data and Maps (Tsunami), https://cadoc.maps.arcgis.com/home/webmap/viewer.html?useExisting=1&layers=2769c700c0694548b5435a60f f52b807
53. City of Modesto Water Master Plan, Draft Environmental Impact Report, Project No. 15.042, October 2019 a. Chapter 12. Hydrology and Water Quality
i. Table 12-1: Beneficial Uses of Water Bodies Potentially Affected by the Proposed Program
54. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Section 5. Increased Demand for Long-Term Water Supplies
LAND USE AND PLANNNG
55. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Section 20. Land Use and Planning
56. City of Modesto Water Master Plan, Draft Environmental Impact Report, Project No. 15.042, October 2019 a. Chapter 3. Introduction to the Environmental Analysis, 3.6.2 Mineral Resources
57. Kiernan Business Park Specific Plan Amendment #4 Project EIR, State Clearinghouse No. 2007062071, Final Certified EIR Date: September 1st, 2009, City Council Resolution No. 2009-418, https://www.modestogov.com/DocumentCenter/View/6640/Environmental-Impact-Report-Volume-I-PDF
MINERAL RESOURCES
58. City of Modesto Water Master Plan, Draft Environmental Impact Report, Project No. 15.042, October 2019 a. Chapter 3. Introduction to the Environmental Analysis, 3.6.2 Mineral Resources
59. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Chapter V-17. Geology, Soils, and Mineral Resources
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NOISE
60. Appendix E- Noise Impact Analysis for Stanislaus Elementary School 1,2,3-TCP Mitigation Project, Ganddini Group, dated December 14th, 2023.
POPULATION AND HOUSING
61. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Chapter VI. Growth-Inducing Impacts
62. City of Modesto Water Master Plan, Draft Environmental Impact Report, Project No. 15.042, October 2019 a. Chapter 15. Population and Housing
b. Table 15-2: Housing Unit Growth in Modesto, Ceres, Turlock, and Unincorporated Stanislaus County Communities (2015-2050)
PUBLIC SERVICES
63. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Chapter V. Increased Demand for Fire Services
b. Section 13. Increased Demand for Police Services
c. Section 12. Increased Demand for Schools
RECREATION
64. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Section 11. Increased Demand for Parks and Open Space i. Figure VI-11-1: Existing Park System in the City Limits
TRANSPORTATION
65. Appendix A- Air Quality, Global Climate Change, and Energy Impact Analysis for Stanislaus Elementary School 1,2,3- TCP Mitigation Project, Gandini Group, December 14th, 2023.
66. California Code Register 2023 tit. 14 Section 15064.3- Determining the Significance of Transportation Impacts
TRIBAL CULTURAL RESOURCES
67. Appendix C- Cultural Resources Assessment for Stanislaus Elementary School 1,2,3-TCP Mitigation Project Modesto and Unincorporated Stanislaus County, CA, BCR Consulting, 2023.
UTILITIES AND SERVICES
68. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Section 5. Increased Demand for Long-term Water Supplies b. Section 6. Increased Demand for Sanitary Sewer Services c. Section 15. Generation of Solid Waste
WILDFIRE
69. City of Modesto General Plan Master Environmental Impact Report, SCH#2014042081, March 2019, https://www.modestogov.com/2070/Master-Environmental-Impact-Report-EIR a. Chapter V. Increased Demand for Fire Services
70. City of Modesto Water Master Plan, Draft Environmental Impact Report, Project No. 15.042, October 2019 a. Chapter 11. Hazards and Hazardous Materials
71. WeatherSpark.com, Climate and Average Weather Year Round in Modesto, 2023, https://weatherspark.com/y/1325/Average-Weather-in-Modesto-California-United-States-Year-Round FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH #2024121117 #8..
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STANISLAUS ELEMENTARY SCHOOL 1,2,3-TCP MITIGATION PROJECT CITY OF MODESTO PAGE 118
November 2024
IX. APPENDICIES
Appendices Provided Under Separate Cover
FINAL INITIAL STUDY/ MITIGATED NEGATIVE DECLARATION SCH #2024121117 #8..
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<UNHIDDEN>
STANISLAUS ELEMENTARY SCHOOL
1,2,3-TCP MITIGATION
AIR QUALITY, GLOBAL CLIMATE CHANGE,
AND ENERGY IMPACT ANALYSIS
City of Modesto
December 14, 2023
(Revised October 8, 2024)
prepared by
Katie Wilson, M.S.
Catherine Howe, MS
GANDDINI GROUP INC.
555 Parkcenter Drive, Suite 225
Santa Ana, CA 92705
(714) 795-3100 | ganddini.com Project No. 19689
#8..
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Stanislaus Elementary School 1,2,3-TCP Mitigation
Air Quality, Global Climate Change, and Energy Impact Analysis i 19689
TABLE OF CONTENTS
EXECUTIVE SUMMARY ................................................................................................................................................ IV
1. INTRODUCTION .................................................................................................................................................... 1 Purpose and Objectives ................................................................................................................................................. 1 Project Location ............................................................................................................................................................... 1 Project Description .......................................................................................................................................................... 2 Phasing and Timing ......................................................................................................................................................... 5 Sensitive Receptors in Project Vicinity....................................................................................................................... 5
2. AIR QUALITY ANALYSIS ..................................................................................................................................... 8 Existing Air Quality Conditions .................................................................................................................................... 8 Local Air Quality ................................................................................................................................................... 8 Pollutants............................................................................................................................................................. 10 Other Pollutants of Concern .......................................................................................................................... 12 Regulatory Setting ........................................................................................................................................................ 12 Federal – United States Environmental Protection Agency .................................................................. 13 State – California Air Resources Board ....................................................................................................... 13 Regional ............................................................................................................................................................... 14 San Joaquin Valley Air Pollution Control District (SJVAPCD) ............................................................... 14 Air Quality Guidance Documents ................................................................................................................. 18 Local – City of Modesto .................................................................................................................................. 19 Monitored Air Quality ................................................................................................................................................. 24 Ozone ................................................................................................................................................................... 24 Carbon Monoxide ............................................................................................................................................. 24 Nitrogen Dioxide ............................................................................................................................................... 24 Particulate Matter ............................................................................................................................................. 24 Air Quality Standards ................................................................................................................................................... 27 Significance Thresholds ................................................................................................................................... 27 Regional Air Quality .......................................................................................................................................... 27 Toxic Air Contaminants ................................................................................................................................... 28 Odor Impacts...................................................................................................................................................... 28 Short-Term Construction Emissions ........................................................................................................................ 32 Methodology ...................................................................................................................................................... 32 Construction-Related Regional Impacts ...................................................................................................... 33 Construction-Related Health Impacts ......................................................................................................... 33 Construction-Related Toxic Air Contaminant Impacts............................................................................ 34 Construction-Related Odor Impacts ............................................................................................................ 34 Long-Term Operational Emissions ........................................................................................................................... 36 Operations-Related Regional Air Quality Impacts .................................................................................... 36 Operations-Related Local Air Quality Impacts .......................................................................................... 36 Operations-Related Health Impacts ............................................................................................................. 37 Operations-Related Odor Impacts ............................................................................................................... 37 Cumulative Air Quality Impacts ................................................................................................................................ 38
3. GLOBAL CLIMATE CHANGE ANALYSIS........................................................................................................ 39 Existing Greenhouse Gas Environment .................................................................................................................. 39 Water Vapor ....................................................................................................................................................... 39 Carbon Dioxide (CO2) ...................................................................................................................................... 39 Methane (CH4) ................................................................................................................................................... 40 Nitrous Oxide (N2O) ......................................................................................................................................... 40 Chlorofluorocarbons (CFC) ............................................................................................................................ 40 #8..
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Stanislaus Elementary School 1,2,3-TCP Mitigation
Air Quality, Global Climate Change, and Energy Impact Analysis ii 19689
Hydrofluorocarbons (HFC) ............................................................................................................................. 40 Perfluorocarbons (PFC) ................................................................................................................................... 40 Sulfur Hexafluoride (SF6) ................................................................................................................................. 41 Aerosols ............................................................................................................................................................... 41 Global Warming Potential ............................................................................................................................... 41 Greenhouse Gas Standards and Regulation .......................................................................................................... 43 International ....................................................................................................................................................... 43 Federal ................................................................................................................................................................. 43 State of California ............................................................................................................................................. 46 Regional – San Joaquin Valley Air Pollution Control District ................................................................ 59 Local – City of Modesto .................................................................................................................................. 59 Significance Thresholds ............................................................................................................................................... 60 Appendix G of State CEQA Guidelines ....................................................................................................... 60 Thresholds of Significance for this Project ................................................................................................. 60 Methodology .................................................................................................................................................................. 60 Project Greenhouse Gas Emissions ......................................................................................................................... 60 Consistency With Applicable Greenhouse Gas Reduction Plans and Policies ............................................. 62 Cumulative Greenhouse Gas Impacts ..................................................................................................................... 66
4. NEPA ANALYSIS .................................................................................................................................................. 67 Federal Clean Air Act Conformity ............................................................................................................................ 67 Criteria Pollutant Emissions ............................................................................................................................ 67 Greenhouse Gas Emissions ............................................................................................................................ 67
5. ENERGY ANALYSIS ............................................................................................................................................. 71 Existing Conditions ....................................................................................................................................................... 71 Overview ............................................................................................................................................................. 71 Electricity ............................................................................................................................................................. 72 Natural Gas ......................................................................................................................................................... 72 Transportation Energy Resources ................................................................................................................ 72 Regulatory Background ............................................................................................................................................... 73 Federal Regulations .......................................................................................................................................... 73 State Regulations .............................................................................................................................................. 74 Project Energy Demands and Energy Efficiency Measures .............................................................................. 80 Evaluation Criteria ............................................................................................................................................ 80 Methodology ...................................................................................................................................................... 80 Construction Energy Demands ..................................................................................................................... 80 Operational Energy Demands ....................................................................................................................... 82 Transportation and Operational Fuel Consumption ..................................................................................... 82 Renewable Energy and Energy Efficiency Plan Consistency ............................................................................ 83 Conclusions .................................................................................................................................................................... 83
6. EMISSIONS REDUCTION MEASURES ........................................................................................................... 90 Construction Measures ............................................................................................................................................... 90 Operational Measures ................................................................................................................................................. 90
7. REFERENCES ......................................................................................................................................................... 91 Appendices
Appendix A Glossary
Appendix B CalEEMod Model Detailed Report and EMFAC Data #8..
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Stanislaus Elementary School 1,2,3-TCP Mitigation
Air Quality, Global Climate Change, and Energy Impact Analysis iii 19689
List of Tables
Table 1. Local Monthly Climate Data.............................................................................................................................. 9 Table 2. State and Federal Criteria Pollutant Standards ......................................................................................... 22 Table 3. San Joaquin Valley Attainment Status ......................................................................................................... 23 Table 4. Air Quality Monitoring Summary .................................................................................................................. 26 Table 5. SJVAPCD Air Quality Significance Thresholds .......................................................................................... 30 Table 6. Screening Levels for Potential Odor Sources ............................................................................................ 31 Table 7. Construction-Related Regional Pollutant Emissions ................................................................................ 35 Table 8. Global Warming Potentials and Atmospheric Lifetimes ......................................................................... 42 Table 9. Project-Related Greenhouse Gas Emissions .............................................................................................. 61 Table 10. Project Consistency with CARB Scoping Plan Policies and Measures ............................................... 64 Table 11. Federal Conformity Analysis and De Minimus Thresholds .................................................................... 69 Table 12. Greenhouse Gas Emissions Comparison to Federal Conformity Thresholds ................................... 70 Table 13. Total Electricity System Power (California 2022) ..................................................................................... 84 Table 14. MID 2022 Power Content Mix ..................................................................................................................... 85 Table 15. Construction Equipment Fuel Consumption Estimates .......................................................................... 86 Table 16. Construction Worker Fuel Consumption Estimates ................................................................................ 87 Table 17. Construction Vendor Fuel Consumption Estimates (MHD & HHD Trucks) ..................................... 88 Table 18. Construction Hauling Fuel Consumption Estimates (HHD Trucks) ..................................................... 89 List of Figures
Figure 1. Project Location Map .......................................................................................................................................... 6 Figure 2. Site Plan .................................................................................................................................................................. 7 #8..
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Stanislaus Elementary School 1,2,3-TCP Mitigation
Air Quality, Global Climate Change, and Energy Impact Analysis iv 19689
EXECUTIVE SUMMARY
The purpose of this air quality, global climate change, and energy impact analysis is to provide an assessment of the impacts resulting from development of the proposed Stanislaus Elementary School 1,2,3-TCP Mitigation project and to identify measures that may be necessary to reduce potentially significant impacts.
Construction-Source Emissions
Project construction-source emissions would not exceed applicable regional thresholds of significance established by the San Joaquin Valley Air Pollution Control District (SJVAPCD).
As discussed herein, the project will comply with all applicable SJVAPCD construction-source emission reduction rules and guidelines. Project construction source emissions would not cause or substantively contribute to violation of the California Ambient Air Quality Standards (CAAQS) or National Ambient Air Quality Standards (NAAQS).
Given the temporary and short-term construction schedule, the project would not result in a long-term (i.e., lifetime or 30-year) exposure to TACs as a result of project construction. Furthermore, construction-based particulate matter (PM) emissions (including diesel exhaust emissions) do not exceed any SJVAPCD regional thresholds. Therefore, impacts from TACs during construction would be less than significant.
Established requirements addressing construction equipment operations, and construction material use, storage, and disposal requirements act to minimize odor impacts that may result from construction activities.
Moreover, construction-source odor emissions would be temporary, short-term, and intermittent in nature and would not result in persistent impacts that would affect substantial numbers of people. Potential construction-source odor impacts are therefore considered less than significant.
Operational-Source Emissions
Project operational-sourced emissions would not exceed applicable regional thresholds of significance established by the SJVAPCD. Project operational-source emissions would not result in or cause a significant toxic air contaminant (TAC) impact as discussed in the Operations-Related Local Air Quality Impacts section of this report. Additionally, project-related trips will not cause or result in CO concentrations exceeding applicable state and/or federal standards (CO “hotspots). Project operational-source emissions would therefore not adversely affect sensitive receptors within the vicinity of the project.
The project's emissions meet SJVAPCD thresholds and will not result in a significant cumulative impact. The project does not propose any such uses or activities that would result in potentially significant operationalsource odor impacts. Potential operational-source odor impacts are therefore considered less than significant.
Greenhouse Gases
The project's GHG emissions would not conflict with the goals of SB-32, City of Modesto General Plan and the CARB Scoping Plan; therefore, the project’s GHG emissions are less than significant and would not conflict with an applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases.
Energy
For new development such as that proposed by the Stanislaus Elementary School 1,2,3-TCP Mitigation project, compliance with California Building Standards Code Title 24 energy efficiency requirements (CALGreen), are considered demonstrable evidence of efficient use of energy. As discussed below, the project would provide for, and promote, energy efficiencies required under other applicable federal and State of #8..
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Stanislaus Elementary School 1,2,3-TCP Mitigation
Air Quality, Global Climate Change, and Energy Impact Analysis v 19689
California standards and regulations, and in so doing would meet or exceed all California Building Standards Code Title 24 standards. Moreover, energy consumed by the project’s operation is calculated to be comparable to, or less than, energy consumed by other pipeline uses of similar scale and intensity that are constructed and operating in California. On this basis, the project would not result in the inefficient, wasteful, or unnecessary consumption of energy. Impacts are considered to be less than significant. #8..
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Stanislaus Elementary School 1,2,3-TCP Mitigation
Air Quality, Global Climate Change, and Energy Impact Analysis 1 19689
1. INTRODUCTION
This section describes the purpose of this air quality, global climate change, and energy impact analysis, project location, proposed development, and study area. Figure 1 shows the project location map and Figure 2 illustrates the project site plan.
PURPOSE AND OBJECTIVES
This study was performed to address the possibility of regional/local air quality impacts and global climate change impacts, from project related air emissions. The objectives of the study include:
documentation of the atmospheric setting
discussion of criteria pollutants and greenhouse gases discussion of the air quality and global climate change regulatory framework analysis of the construction related air quality and greenhouse gas emissions analysis of the operations related air quality and greenhouse gas emissions analysis of the conformity of the proposed project with the SJAPCD thresholds analysis of the project’s energy use during construction and operation recommendations for mitigation measures
The City of Modesto is the lead agency for this air quality and GHG analysis, in accordance with the CEQA authorizing legislation. Although this is a technical report, effort has been made to write the report clearly and concisely. A glossary is provided in Appendix A to assist the reader with technical terms related to air quality and global climate change.
PROJECT LOCATION
The proposed project is located within northwest unincorporated Stanislaus County in central San Joaquin Valley, “Central Valley.” The Project is approximately 0.5 miles north from the City Limits of Modesto, within Modesto’s Sphere of Influence (SOI), and also within the Study Area of the City’s Water Master Plan. dŚĞ WƌŽũĞĐƚǁŝůůďĞĐŽŶƐƚƌƵĐƚĞĚŝŶƉƵďůŝĐƌŝŐŚƚͲŽĨͲǁĂLJŽƵƚƐŝĚĞŽĨƚƌĂǀĞůůĂŶĞƐĂŶĚŽƵƚƐŝĚĞŽĨƚŚĞĐĞŶƚĞƌŵĞĚŝĂŶ ĨŽƌ<ŝĞƌŶĂŶǀĞŶƵĞ͕ĞŝƚŚĞƌǁŝƚŚŝŶŽƌĂĚũĂĐĞŶƚƚŽĞdžŝƐƚŝŶŐƉĂǀĞĚƐƚƌĞĞƚĂƌĞĂƐ͕ƚŽƚŚĞŶŽƌƚŚŽĨƚŚĞ<ŝĞƌŶĂŶͬ ĂƌǀĞƌEŽƌƚŚŽŵƉƌĞŚĞŶƐŝǀĞWůĂŶŶŝŶŐŝƐƚƌŝĐƚ;WͿ͕ĂŶĚŶŽƌƚŚŽĨƚŚĞŝƚLJ>ŝŵŝƚƐŽĨDŽĚĞƐƚŽ. dŚĞWƌŽũĞĐƚ ƉƌŽƉŽƐĞƐƚŽŝŶƐƚĂůůϭϮͲŝŶĐŚĚŝĂŵĞƚĞƌƐĞƌǀŝĐĞĐŽŶŶĞĐƚŝŽŶƐƚŽĞdžƚĞŶĚǁĂƚĞƌƐĞƌǀŝĐĞĨƌŽŵƚŚĞŝƚLJ͛ƐƉƌŽƉŽƐĞĚ ǁĂƚĞƌŵĂŝŶǁŝƚŚŝŶƚŚĞ<ŝĞƌŶĂŶǀĞŶƵĞƉƵďůŝĐƌŝŐŚƚͲŽĨͲǁĂLJƚŽƚŚĞŶŽƌƚŚƐŝĚĞŽĨƚŚĞ<ŝĞƌŶĂŶǀĞŶƵĞƌŝŐŚƚͲŽĨͲ ǁĂLJ͖ ŽŶĞ ŽĨ ƚŚĞƐĞ ƐĞƌǀŝĐĞ ĐŽŶŶĞĐƚŝŽŶƐ ŝƐ ƉƌŽƉŽƐĞĚ ƚŽ ĐŽŶŶĞĐƚ ƚŚĞ ƐŽƵƚŚĞĂƐƚĞƌŶ ĐŽƌŶĞƌ ŽĨ ^ƚĂŶŝƐůĂƵƐ
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Direction of Pipeline
Construction
Lat/Long; Elevation Area of Disturbance
Tully Road ~ 825 ft North from the existing “deadend” in the City’s existing water system in Tully Road to a point
Beginning of proposed alignment:
Latitude 37.710473 °N/Longitude
121.013059°W; 91-92 ft AMSL
Open Trenching: 6-ft x 8-ft
for 11,897 linear feet
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of connection in the proposed
water main proposed in
Kiernan Avenue’s eastbound
lanes. The Project will also
install a service connection
continuing north from Kiernan
Avenue’s eastbound lane and
terminating in the northeastern
corner of Kiernan Ave. & Tully
Road intersection with a fire
hydrant that will be installed as
part of the Project.
Jack and Bore Pits:
5 Jacking Pits: 12-ft wide x
10-ft long x 15-ft deep
5 Receiving Pits: 12-ft wide x
24-ft long x 15-ft deep
Kieran
Avenue
~
10,782
ft
West from Tully Road and
Kiernan Avenue intersection to
the Dale Road and Kiernan
Avenue intersection.
---
Dale Road ~135 ft South from Kiernan Avenue
and Dale Road intersection to a
connection point with the
City’s existing water system.
End of Proposed Alignment:
Latitude 37.710636 °N/Longitude -
121.050073°W; 91-92 ft AMSL
Stanislaus
Elementary
School
Service
Connection
~155 ft North from the proposed
water main in the eastbound
lanes of Kiernan Avenue and
across the westbound right-ofway, terminating at the
southeast property corner of
the school
Beginning of Proposed Service
Connection: Latitude 37.710911 °N /
Longitude -121.027040°W; 91 ft AMSL
End of Proposed Service Connection:
Latitude 37.711339 °N / Longitude -
121.027053 °W; 91 ft AMSL
Reference: See Figure 2A: Water Improvements Local Vicinity Map Notes: 1) LF= Linear Feet
2) Average dimensions of trenching are 6-feet wide by 8-feet deep. 3) AMSL= Above Mean Sea Level
A vicinity map showing the project location is provided on Figure 1.
PROJECT DESCRIPTION
The proposed Project is the consolidation of Stanislaus Union School District (SUSD) service area (Water System No. CA5000249) with the City of Modesto, through an extension of water and wastewater services, and the abandonment of the existing Well 02. Stanislaus Elementary School is one of six schools located within SUSD (five (5) elementary schools; one (1) junior high school); however, Stanislaus Elementary School is the only school currently being serviced by Water System No. CA5000249 since it is the only school within the district located outside of Modesto’s Water System and City Limits.
Proposed Water Improvements
Water improvements will construct a total of approximately 11,897 linear feet of 12-inch potable water pipeline along Tully Road; Kiernan Avenue; and Dale Road. See Table 4: Project Alignment. The pipeline will extend to the north from the existing dead-end 12-inch diameter potable water main in Tully Road, along approximately 700 linear feet to the Tully Road and Kiernan Avenue intersection. The Project will continue north through the Tully Road and Kiernan Avenue intersection towards the northeast intersection corner and will terminate at the fire hydrant that is proposed with the Project. The proposed fire hydrant is at the northeast corner of the Kiernan Avenue and Tully Road intersection and will require approximately 155 linear feet of pipeline connection extending between the fire hydrant and the proposed main in Kiernan Avenue.
The fire hydrant is needed for fire flow compliance with the City’s performance criteria throughout the City’s service area. From the intersection at Tully Road and Kiernan Avenue, the Project will also extend west towards Dale Road along the southside of Kiernan Avenue. The Project will install approximately 135 linear feet of water main within Dale Road south of the Dale Road and Kiernan Avenue intersection. 2 #8..
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Due to the connections to two existing dead-end 12-inch diameter pipelines along Tully Road and Dale Road, the proposed water improvements will meet fire flow requirements (33 psi at 4,000 gpm); meet the City’s operational and performance criteria; and result in high pipeline turnover rates which benefit water quality within the distribution system. The entire alignment will be buried underground using open trench construction as well as jack and bore construction to avoid direct impacts to existing utilities and structures.
Temporary areas of disturbance as a result of trenching are anticipated to be 4-feet wide and 8-feet deep along the entire 11,897 linear feet of Project Alignment, consisting of approximately 1.1 acres. Jack and bore construction will consist of not more than a total of 5 jack and bore locations, each, including two pits1, one entry (jacking), and one exit pit. Jacking pits are approximately 12-ft wide by 10-ft long by 15-ft deep and receiving pits are approximately 12-feet wide by 204-feet long x 15-feet deep, resulting in approximately 0.03 acres of disturbance. As a result, earthwork quantities are approximately 3,348 cubic yards (CY) of export and 4,680 CY of import.
One service connection, consisting of 155 linear feet of 12-inch diameter pipe will be installed from the proposed main in Kiernan Avenue to provide a water service connection for the school on the north side of Kiernan Avenue, at the southeastern corner of the Stanislaus Elementary School parcel; this component of the Project will be installed using jack and bore construction to avoid open trenches crossing Kiernan Avenue.
Throughout Project construction, a traffic control plan will be implemented that includes lane closures, barricades, and signs to guide the flow of traffic through the construction zone along Kiernan Avenue, Tully Road, and Dale Road. Following the installation of the Project Alignment, the existing Well 02 is intended to be abandoned. Abandonment and permanent sealing of SUSD Well 02 will occur in accordance with requirements set forth by the Environmental Resources Department of Stanislaus County.
Project Objectives
Due to presence of 1,2,3-TCP in Well 02, the Stanislaus Elementary School’s water system needs additional water services. Therefore, the intended outcome of the proposed Project is the following:
Provide Stanislaus Elementary School with a source of drinking water that meets water quality standards;
Provide sufficient hydraulic capacity to meet 4,000 gallons per minute (gpm) fire flow requirements while maintaining a 20-pounds per square inch (psi) residual pressure at the school; Build a Project that is consistent with the City’s 2019 Water Master Plan (WMP) identified future improvements.
To achieve these objectives, the Project proposes to extend the City of Modesto’s Water system to the school and stop the extraction of contaminated groundwater from Well 02.
Project Elements
Construction Activities
Construction activities will occur between 7:30 AM and 4:30 PM, Monday through Friday; weekend work will be avoided when feasible, however, weekend or night work might occur to accommodate traffic. The installation rate of the water and sewer mains are expected to average 100 feet per day. 1 For the purposes of noise, air quality/GHG, and traffic modeling, assumptions were made about the location of jacking and receiving pits based on a “worst-case scenario”. Under “worst-case” conditions, boring locations are located closest to sensitive receptors adjacent to the Project Alignment: one (1) along the east side of Dale Road, approximately 150 feet from sensitive receptors; three (3) along the north side of Kiernan Avenue, bordering the southern perimeter of Stanislaus Elementary School, approximately 50 ft from the closest sensitive receptors; and one (1) along the west side of Tully Road, approximately 50 ft from the closest sensitive receptors.
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Construction activities will involve approximately six to eight crew members2 at any one time for a total of 16 people on the job. Crew members will get to the construction site utilizing personal vehicles, approximately 16 vehicles at any one time, accessing the construction site via local roadways (Carver Road, Dale Road, Tully Road, etc.) or regional transportation routes (State Route (SR) 99; SR 219 (Kiernan Avenue); SR 108). Personal vehicles will be parked along the public right-of-way, adjacent to the Project Alignments within the roadway, shoulder, or the streets, or in a designated laydown yard on the Stanislaus Elementary School property.
Throughout Project construction, a traffic control plan will be utilized along all impacted public rights-of-way (Kiernan Avenue, Dale Road, & Tully Road). Temporary fencing will be constructed around each work area to secure construction sites and prevent theft/vandalism that has the potential to occur overnight, concluding daily construction activities. In addition to fencing, active construction will either be backfilled or covered with trench plates at the end of each day. Water for construction and potable water during construction activities will be supplied by the City of Modesto’s water system.
Construction Equipment
During Project implementation, construction activities will involve the utilization of various diesel-powered equipment along various locations of the Project Alignment for the duration of Project construction. Potential equipment on-site during construction includes one (1) scraper, five (5) tractors/ loaders/ backhoes, one (1) off-highway trucks, one (1) plate compactor, one (1) excavator, one (1) other material handling equipment, one (1) paving equipment, one (1) other construction equipment, two (2) pumps, one (1) skid steer loaders, one (1) surfacing equipment, one (1) rubber tiered dozer, and one (1) crane. During temporary Project construction, equipment will be kept at a designated laydown yard or the Project contractor’s own facility.
Staging
Staging areas will be located inside existing public right-of-way along various locations of the Project Alignment or on adjacent parcels. These staging locations will depend on the portion of the alignment under construction. Staging will also be located within a portion of the Stanislaus Elementary School parking lot.
Phasing
The Project Construction is not anticipated to be phased. As mentioned above, the contractor will lay approximately 100 feet of pipeline per day for approximately eight months until the entire Project Alignment has been implemented. Utility potholing and determining locations of existing “dead-end” connections will occur prior to open trench construction and excavation.
Long-Term Operations and Maintenance
The proposed Project Alignment is anticipated to be operational for 50 or more years upon initial construction.
The City will operate and manage the potable water conveyance pipeline to Stanislaus Elementary School, serving approximately 360 students and staff. The City of Modesto does not anticipate additional staffing needs for long-term operation and maintenance of the proposed Project. Monthly worker trips over the lifetime of the proposed Project will be required to conduct routine inspections and ensure proper long-term maintenance. Since a portion of the proposed Project will occur within CALTRANS right-of-way (Kiernan Avenue), the City will establish a long-term maintenance agreement with CALTRANS pursuant to a parallel encroachment policy exception for an arterial.
Figure 2 illustrates the proposed site plan.
2 The number of construction crew members is an assumption based on the scale of the proposed Project and type of infrastructure being implemented.
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PHASING AND TIMING
The proposed project is anticipated to be operational in 2025. The project is anticipated to be built in one phase with project construction anticipated to start no sooner than the beginning of fall 2024 and conclude in fall of 2025, lasting for approximately eleven months. The construction schedule utilized in the analysis represents a “worst-case” analysis scenario even if construction was to occur any time after the respective dates since emission factors for construction decrease as time passes and the analysis year increases due to emission regulations becoming more stringent.3
SENSITIVE RECEPTORS IN PROJECT VICINITY
The surrounding land uses are primarily agricultural fields and urban commercial uses as shown in the table below.
Land Use
Stanislaus County
General Plan
City of Modesto
General Plan Zoning
Project
o1-ঞom
County and City Right-ofWay; Stanislaus Elementary
School
General Agriculture (Deciduous
Fruits and Nuts)
Village Residenঞal (VR)-
Keiran/ Carver North
Comprehensive Planning
District
AG-40
North Large-scale agriculture General Agriculture (Deciduous Fruits and Nuts, Field Crops) Village Residenঞal (VR) AG-40 South Large-scale agriculture;
Kaiser Permanente Modesto
Medical Center
Community Commercial; Urban
Vacant; Urban Industrial; General
Agriculture (Pasture, Deciduous
Fruits and Nuts)
Village Residenঞal (VR);
Business Park (BP); Mixed
Use (MU)
AG 10;
Modesto
East Large-scale agriculture General Agriculture (Deciduous Fruits and Nuts, Field Crops) Business Park (BP) AG-40
West Large-scale agriculture General Agriculture (Deciduous Fruits and Nuts) Business Park (BP) AG-40
Source: (1) Stanislaus County GIS, Updated May 2023. (2) Modesto General Plan EIR, 2019.
Those who are sensitive to air pollution include children, the elderly, and persons with preexisting respiratory or cardiovascular illness. For CEQA purposes, a sensitive receptor is generically defined as a location where human populations, especially children, seniors, and sick persons are found, and there is reasonable expectation of continuous human exposure according to the averaging period for the AAQS (e.g., 24-hour, 8- hour, 1-hour). These typically include residences, hospitals, and schools.4 Commercial and industrial facilities are not included in the definition because employees do not typically remain on-site for 24 hours.
The nearest sensitive receptors to the project site are the existing residential, school, and transient lodging uses located adjacent or near Kiernan Avenue between Tully Road to Dale Road. Other air quality sensitive land uses are located further from the project site and would experience lower impacts.
3 As shown in the California Emissions Estimator Model (CalEEMod) User’s Guide Version 2020.4.0, Section 4.3.2 “OFFROAD Equipment” as the analysis year increases, emission factors for the same equipment pieces decrease due to the natural turnover of older equipment being replaced by newer less polluting equipment and new regulatory requirements. 4 San Joaquin Valley Air Pollution Control District (SJVAPCD) Guidance for Assessing and Mitigation Air Quality Impacts, March 19, 2015. http://valleyair.org/transportation/GAMAQI.pdf
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Figure 1
Regional Location Map
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Figure 2
Proposed Project
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2. AIR QUALITY ANALYSIS
EXISTING AIR QUALITY CONDITIONS
Local Air Quality
The project is located within the City of Modesto which lies within the San Joaquin Valley Air Basin (SJVAB).
The project area is under the jurisdiction of the SJVAPCD. The SJVAB consists of eight counties: Fresno, Kern (western and central), Kings, Madera, Merced, San Joaquin, Stanislaus, and Tulare. Air pollution in the SJVAB can be attributed to both human-related (anthropogenic) and natural (non-anthropogenic) activities that produce emissions. Air pollution from significant anthropogenic activities in the SJVAB includes a variety of industrial-based sources as well as on- and off-road mobile sources. Activities that tend to increase mobile activity include increases in population, increases in general traffic activity (including automobiles, trucks, aircraft, and rail), urban sprawl (which will increase commuter driving distances), and general local land management practices as they pertain to modes of commuter transportation. These sources, coupled with geographical and meteorological conditions unique to the area, stimulate the formation of unhealthy air.5 The San Joaquin Valley’s (SJV) topography and meteorology provide ideal conditions for trapping air pollution for long periods of time and producing harmful levels of air pollutants, including ozone and particulate matter.
Low precipitation levels, cloudless days, high temperatures, and light winds during the summer in the SJV are conducive to high ozone levels resulting from the photochemical reaction of nitrogen oxides (NOx) and volatile organic compounds (VOC). Inversion layers in the atmosphere during the winter can trap emissions of directly emitted PM2.5 (particulate matter that is 2.5 microns or less in diameter) and PM2.5 precursors (such as NOx and sulfur dioxide (SO2)) within the SJV for several days, accumulating to unhealthy levels. The region also houses the State’s major arteries for goods and people movement, I-5 to the west and CA Highway 99 through the Central Valley, thereby attracting a large volume of vehicular traffic. Another compounding factor is the region’s historically high rate of population growth compared to other regions of California. Increased population typically results in an even greater increase in vehicle activity and more consumer product use, leading to increased emissions of air pollution, including NOx. In fact, mobile sources account for about 80 percent of the Central Valley’s total NOx emissions inventory. Since NOx is a significant precursor for both ozone and PM2.5, reducing NOx from mobile sources is critical for progressing the Central Valley towards attainment of ozone and PM2.5 standards.6
The geography of mountainous areas to the east, west and south, in combination with long summers and relatively short winters, contributes to local climate episodes that prevent the dispersion of pollutants.
Transport, as affected by wind flows and inversions, also plays a role in the creation of air pollution.7 The temperature and precipitation levels for the City of Modesto are shown below in Table 1. Table 1 shows that July is typically the warmest month and January and December are typically the coolest months. Rainfall in the project area varies considerably depending on the location and season. Almost all the annual rainfall comes from the fringes of mid-latitude storms from late November to early April, with summers being almost completely dry.
5 San Joaquin Valley Air Pollution Control District, Guidance for Assessing and Mitigating Air Quality Impacts, March 19, 2015. https://ww2.valleyair.org/media/g4nl3p0g/gamaqi.pdf
6 San Joaquin Valley Air Pollution Control District, Guidance for Assessing and Mitigating Air Quality Impacts, March 19, 2015. https://ww2.valleyair.org/media/g4nl3p0g/gamaqi.pdf
7 San Joaquin Valley Air Pollution Control District, Guidance for Assessing and Mitigating Air Quality Impacts, March 19, 2015. https://ww2.valleyair.org/media/g4nl3p0g/gamaqi.pdf
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Descriptor Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Avg. Max. Temperature 55.1 62.1 68.2 74.2 82.2 89.3 94.2 92.9 87.9 78.3 62.8 55.0 Avg. Min. Temperature 39.3 42.8 45.9 49.0 54.3 59.2 62.4 61.6 58.2 51.9 42.8 39.3 Avg. Total Precipitation (in.) 2.6 2.5 2.0 1.0 0.6 0.2 0.0 0.0 0.2 0.7 1.4 2.1 Source: https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca5738
Data from the Modesto City CO AP, CA station (045738).
Local Monthly Climate Data
Table 1
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Pollutants
Pollutants are generally classified as either criteria pollutants or non-criteria pollutants. Federal ambient air quality standards have been established for criteria pollutants, whereas no ambient standards have been established for non-criteria pollutants. For some criteria pollutants, separate standards have been set for different periods. Most standards have been set to protect public health. For some pollutants, standards have been based on other values (such as protection of crops, protection of materials, or avoidance of nuisance conditions). A summary of federal and state ambient air quality standards is provided in the Regulatory Framework section.
Criteria Pollutants
The criteria pollutants consist of: ozone, nitrogen dioxide, carbon monoxide, sulfur dioxide, lead, and particulate matter. These pollutants can harm your health and the environment, and cause property damage.
The Environmental Protection Agency (EPA) calls these pollutants “criteria” air pollutants because it regulates them by developing human health-based and/or environmentally-based criteria for setting permissible levels.
The following provides descriptions of each of the criteria pollutants.
Nitrogen Dioxides
Nitrogen Oxides (NOx) is the generic term for a group of highly reactive gases which contain nitrogen and oxygen. While most NOx are colorless and odorless, concentrations of nitrogen dioxide (NO2) can often be seen as a reddish-brown layer over many urban areas. NOx form when fuel is burned at high temperatures, as in a combustion process. The primary manmade sources of NOx are motor vehicles, electric utilities, and other industrial, commercial, and residential sources that burn fuel. NOx reacts with other pollutants to form, ground-level ozone, nitrate particles, acid aerosols, as well as NO2, which cause respiratory problems. NOx and the pollutants formed from NOx can be transported over long distances, following the patterns of prevailing winds. Therefore, controlling NOx is often most effective if done from a regional perspective, rather than focusing on the nearest sources.
Ozone
Ozone (O3) is not usually emitted directly into the air but at ground-level is created by a chemical reaction between NOx and volatile organic compounds (VOC) in the presence of sunlight. Motor vehicle exhaust, industrial emissions, gasoline vapors, chemical solvents as well as natural sources emit NOx and VOC that help form O3. Ground-level O3 is the primary constituent of smog. Sunlight and hot weather cause ground-level O3 to form with the greatest concentrations usually occurring downwind from urban areas. O3 is subsequently considered a regional pollutant. Ground-level O3 is a respiratory irritant and an oxidant that increases susceptibility to respiratory infections and can cause substantial damage to vegetation and other materials.
Because NOx and VOC are O3 precursors, the health effects associated with O3 are also indirect health effects associated with significant levels of NOx and VOC emissions.
Carbon Monoxide
Carbon monoxide (CO) is a colorless, odorless gas that is formed when carbon in fuel is not burned completely.
It is a component of motor vehicle exhaust, which contributes about 56 percent of all CO emissions nationwide. In cities, 85 to 95 percent of all CO emissions may come from motor vehicle exhaust. Other sources of CO emissions include industrial processes (such as metals processing and chemical manufacturing), residential wood burning, and natural sources such as forest fires. Woodstoves, gas stoves, cigarette smoke, and unvented gas and kerosene space heaters are indoor sources of CO. The highest levels of CO in the outside air typically occur during the colder months of the year when inversion conditions are more frequent.
The air pollution becomes trapped near the ground beneath a layer of warm air. CO is described as having only a local influence because it dissipates quickly. Since CO concentrations are strongly associated with motor vehicle emissions, high CO concentrations generally occur in the immediate vicinity of roadways with high 10 #8..
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traffic volumes and traffic congestion, active parking lots, and in automobile tunnels. Areas adjacent to heavily traveled and congested intersections are particularly susceptible to high CO concentrations.
CO is a public health concern because it combines readily with hemoglobin and thus reduces the amount of oxygen transported in the bloodstream. The health threat from lower levels of CO is most serious for those who suffer from heart disease such as angina, clogged arteries, or congestive heart failure. For a person with heart disease, a single exposure to CO at low levels may cause chest pain and reduce that person’s ability to exercise; repeated exposures may contribute to other cardiovascular effects. High levels of CO can affect even healthy people. People who breathe high levels of CO can develop vision problems, reduced ability to work or learn, reduced manual dexterity, and difficulty performing complex tasks. At extremely high levels, CO is poisonous and can cause death.
Sulfur Dioxide
Sulfur Oxide (SOx) gases (including sulfur dioxide [SO2]) are formed when fuel containing sulfur, such as coal and oil is burned, and from the refining of gasoline. SOx dissolve easily in water vapor to form acid and interacts with other gases and particles in the air to form sulfates and other products that can be harmful to people and the environment.
Lead
Lead (Pb) is a metal found naturally in the environment as well as manufactured products. The major sources of lead emissions have historically been motor vehicles and industrial sources. Due to the phase out of leaded gasoline, metal processing is now the primary source of lead emissions to the air. High levels of lead in the air are typically only found near lead smelters, waste incinerators, utilities, and lead-acid battery manufacturers.
Exposure of fetuses, infants and children to low levels of lead can adversely affect the development and function of the central nervous system, leading to learning disorders, distractibility, inability to follow simple commands, and lower intelligence quotient. In adults, increased lead levels are associated with increased blood pressure.
Particulate Matter
Particulate matter (PM) is the term for a mixture of solid particles and liquid droplets found in the air.
Particulate matter is made up of a number of components including acids (such as nitrates and sulfates), organic chemicals, metals, and soil or dust particles. The size of particles is directly linked to their potential for causing health problems. Particles that are less than 10 micrometers in diameter (PM10) are the particles that generally pass through the throat and nose and enter the lungs. Once inhaled, these particles can affect the heart and lungs and cause serious health effects. Particles that are less than 2.5 micrometers in diameter (PM2.5) have been designated as a subset of PM10 due to their increased negative health impacts and its ability to remain suspended in the air longer and travel further.
Reactive Organic Gases (ROG)
Although not a criteria pollutant, reactive organic gases (ROGs), or volatile organic compounds (VOCs), are defined as any compound of carbon—excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate—that participates in atmospheric photochemical reactions.
Although there are slight differences in the definition of ROGs and VOCs, the two terms are often used interchangeably. Indoor sources of VOCs include paints, solvents, aerosol sprays, cleansers, tobacco smoke, etc. Outdoor sources of VOCs are from combustion and fuel evaporation. A reduction in VOC emissions reduces certain chemical reactions that contribute to the formulation of O3. VOCs are transformed into organic aerosols in the atmosphere, which contribute to higher PM10 and lower visibility. 11 #8..
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Other Pollutants of Concern
Toxic Air Contaminants (TACs)
In addition to the above-listed criteria pollutants, TACs are another group of pollutants of concern. Sources of TACs include industrial processes such as petroleum refining and chrome plating operations, commercial operations such as gasoline stations and dry cleaners, and motor vehicle exhaust. Cars and trucks release at least forty different TACs. The most important of these TACs, in terms of health risk, are diesel particulates, benzene, formaldehyde, 1,3-butadiene, and acetaldehyde. Public exposure to TACs can result from emissions from normal operations as well as from accidental releases. Health effects of TACs include cancer, birth defects, neurological damage, and death.
TACs are less pervasive in the urban atmosphere than criteria air pollutants, however they are linked to shortterm (acute) or long-term (chronic or carcinogenic) adverse human health effects. There are hundreds of different types of TACs with varying degrees of toxicity. Sources of TACs include industrial processes, commercial operations (e.g., gasoline stations and dry cleaners), and motor vehicle exhaust.
According to the 2013 California Almanac of Emissions and Air Quality, the majority of the estimated health risk from TACs can be attributed to relatively few compounds, the most important of which is diesel particulate matter (DPM). Diesel particulate matter is a subset of PM2.5 because the size of diesel particles are typically
2.5 microns and smaller. The identification of diesel particulate matter as a TAC in 1998 led the California Air Resources Board (CARB) to adopt the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-fueled Engines and Vehicles in September 2000. The plan’s goals are a 75-percent reduction in diesel particulate matter by 2010 and an 85-percent reduction by 2020 from the 2000 baseline. Diesel engines emit a complex mixture of air pollutants, composed of gaseous and solid material. The visible emissions in diesel exhaust are known as particulate matter or PM, which includes carbon particles or “soot”. Diesel exhaust also contains a variety of harmful gases and over 40 other cancer-causing substances. California’s identification of diesel particulate matter as a TAC was based on its potential to cause cancer, premature deaths, and other health problems. Exposure to diesel particulate matter is a health hazard, particularly to children whose lungs are still developing and the elderly who may have other serious health problems. Overall, diesel engine emissions are responsible for the majority of California’s potential airborne cancer risk from combustion sources.
Asbestos
Asbestos is listed as a TAC by the ARB and as a Hazardous Air Pollutant by the EPA. Asbestos occurs naturally in mineral formations and crushing or breaking these rocks, through construction or other means, can release asbestiform fibers into the air. Asbestos emissions can result from the sale or use of asbestos-containing materials, road surfacing with such materials, grading activities, and surface mining. The risk of disease is dependent upon the intensity and duration of exposure. When inhaled, asbestos fibers may remain in the lungs and with time may be linked to such diseases as asbestosis, lung cancer, and mesothelioma. The nearest likely locations of naturally occurring asbestos, as identified in the General Location Guide for Ultramafic Rocks in California prepared by the California Division of Mines and Geology, is located Tuolumne County approximately 30 miles northeast of the site. Due to the distance to the nearest natural occurrences of asbestos, the project site is not likely to contain asbestos.
REGULATORY SETTING
The proposed project is addressed through the efforts of various international, federal, state, regional, and local government agencies. These agencies work jointly, as well as individually, to improve air quality through legislation, regulations, planning, policy-making, education, and a variety of programs. The agencies responsible for improving the air quality are discussed below. 12 #8..
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Federal – United States Environmental Protection Agency The United States Environmental Protection Agency (USEPA) is responsible for setting and enforcing the NAAQS for atmospheric pollutants. It regulates emission sources that are under the exclusive authority of the federal government, such as aircraft, ships, and certain locomotives. The NAAQS pollutants were identified using medical evidence and are shown below in Table 2.
The EPA and the California Air Resource Board (CARB) designate air basins where ambient air quality standards are exceeded as “nonattainment” areas. If standards are met, the area is designated as an “attainment” area. If there is inadequate or inconclusive data to make a definitive attainment designation, they are considered “unclassified.” National nonattainment areas are further designated as marginal, moderate, serious, severe, or extreme as a function of deviation from standards. Each standard has a different definition, or ‘form’ of what constitutes attainment, based on specific air quality statistics. For example, the Federal 8- hour CO standard is not to be exceeded more than once per year; therefore, an area is in attainment of the CO standard if no more than one 8-hour ambient air monitoring values exceeds the threshold per year. In contrast, the Federal annual PM2.5 standard is met if the three-year average of the annual average PM2.5 concentration is less than or equal to the standard. Attainment status is shown in Table 3.
As part of its enforcement responsibilities, the EPA requires each state with federal nonattainment areas to prepare and submit a State Implementation Plan (SIP) that demonstrates the means to attain the national standards. The State Implementation Plan (SIP) must integrate federal, state, and local components and regulations to identify specific measures to reduce pollution, using a combination of performance standards and market-based programs within the timeframe identified in the State Implementation Plan (SIP).
As indicated below in Table 3, the Basin has been designated by the EPA as a non-attainment area for ozone (O3) and suspended particulates (PM2.5). Currently, the Basin is in attainment with the ambient air quality standards for carbon monoxide (CO), lead, sulfur dioxide (SO2), suspended particulate matter (PM-10), and nitrogen dioxide (NO2).
State – California Air Resources Board
The California Air Resources Board (CARB), which is a part of the California Environmental Protection Agency (CalEPA), is responsible for the coordination and administration of both federal and state air pollution control programs within California. In this capacity, the CARB conducts research, sets the CAAQS, compiles emission inventories, develops suggested control measures, provides oversight of local programs, and prepares the State Implementation Plan (SIP). The CAAQS for criteria pollutants are shown in Table 2. In addition, the CARB establishes emission standards for motor vehicles sold in California, consumer products (e.g., hairspray, aerosol paints, and barbeque lighter fluid), and various types of commercial equipment. Furthermore, the motor vehicle emission standards established by CARB include compliance with the Safer Affordable Fuel-Efficient Vehicles (SAFE) Rule, issued by NHTSA and EPA in March 2020 (published on April 30, 2020 and effective after June 29, 2020). The SAFE Rule sets fuel economy and carbon dioxide standards that increase 1.5 percent in stringency each year from model years 2021 through 2026 and apply to both passenger cars and light trucks. CARB also sets fuel specifications to further reduce vehicular emissions.
The San Joaquin Valley has been designated by the CARB as a nonattainment area for ozone, PM10 and PM2.5. Currently, the San Joaquin Valley is in attainment with the ambient air quality standards for CO, lead, SO2, NO2, SO2, vinyl chloride, and sulfates and is unclassified for visibility reducing particles and hydrogen sulfide.
On June 20, 2002, the CARB revised the PM10 annual average standard to 20 μg/m3 and established an annual average standard for PM2.5 of 12 μg/m3. These standards were approved by the Office of Administrative Law in June 2003 and are now effective.
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On December 12, 2008, the CARB adopted Resolution 08-43, which limits NOx, PM10 and PM2.5 emissions from on-road diesel truck fleets that operate in California. On October 12, 2009, Executive Order R-09-010 was adopted that codified Resolution 08-43 into Section 2025, Title 13 of the California Code of Regulations.
This regulation requires that by the year 2023 all commercial diesel trucks that operate in California shall meet model year 2010 (Tier 4) or latter emission standards. In the interim period, this regulation provides annual interim targets for fleet owners to meet. This regulation also provides a few exemptions including a once-peryear 3-day pass for trucks registered outside of California.
The CARB is also responsible for regulations pertaining to TACs. The Air Toxics “Hot Spots” Information and Assessment Act (AB 2588, 1987, Connelly) was enacted in 1987 as a means to establish a formal air toxics emission inventory risk quantification program. AB 2588, as amended, establishes a process that requires stationary sources to report the type and quantities of certain substances their facilities routinely release into the South Coast Air Basin. The data is ranked by high, intermediate, and low categories, which are determined by: the potency, toxicity, quantity, volume, and proximity of the facility to nearby receptors.
AB 617 Nonvehicular air pollution: criteria air pollutants and toxic air contaminants This bill requires the state board to develop a uniform statewide system of annual reporting of emissions of criteria air pollutants and TACs for use by certain categories of stationary sources. The bill requires those stationary sources to report their annual emissions of criteria air pollutants and TACs, as specified. This bill required the state board, by October 1, 2018, to prepare a monitoring plan regarding technologies for monitoring criteria air pollutants and TACs and the need for and benefits of additional community air monitoring systems, as defined. The bill requires the state board to select, based on the monitoring plan, the highest priority locations in the state for the deployment of community air monitoring systems. The bill requires an air district containing a selected location, by July 1, 2019, to deploy a system in the selected location. The bill would authorize the air district to require a stationary source that emits air pollutants in, or that materially affect, the selected location to deploy a fence-line monitoring system, as defined, or other specified real-time, on-site monitoring. The bill authorizes the state board, by January 1, 2020, and annually thereafter, to select additional locations for the deployment of the systems. The bill would require air districts that have deployed a system to provide to the state board air quality data produced by the system. By increasing the duties of air districts, this bill would impose a state-mandated local program. The bill requires the state board to publish the data on its Internet Web site.
Regional
San Joaquin Valley Air Pollution Control District (SJVAPCD) The SJVAPCD develops rules and regulations, establishes permitting requirements for stationary sources, inspects emission sources, and enforces such measures through educational programs or fines, when necessary. The SJVAPCD is directly responsible for reducing emissions from stationary, mobile, and indirect sources.
The SJVAPCD has developed plans to attain State and Federal standards for ozone and particulate matter.
The SJVAPCD’s air quality plans include emissions inventories to measure the sources of air pollutants, to evaluate how well different control methods have worked, and to show how air pollution will be reduced. The plans also model and estimate future levels of pollution and make sure that the San Joaquin Valley will meet air quality goals. The SJVAPCD’s attainment plans are subject to approval by the SJVAPCD’s Governing Board.
SJVAPCD Attainment Plans
Consistent with Clean Air Act requirements, the SJVAPCD has adopted attainment plans that demonstrate how the SJVAPCD will attain and maintain the National Ambient Air Quality Standards. These plans are developed through a public process, formally adopted by the State, and submitted by the Governor's designee 14 #8..
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to the US EPA. The Clean Air Act requires EPA to review each plan and any plan revisions and to approve the plan or plan revisions if consistent with the Clean Air Act.
Each attainment plan includes a comprehensive and exhaustive list of regulatory and incentive-based measures to reduce emissions of ozone and particulate matter precursors throughout the Valley. Consistent with the direction of each plan, the Governing Board adopted regulatory measures that, in the majority of cases, exceed the plan commitment for a given source category, especially through the implementation of the Confined Animal Facilities Rule (4570), Phase II of the Stationary Internal Combustion Engines Rule (4702), Stationary Gas Turbines Rule (4703), and multiple rules for Boilers, Steam Generators, and Process Heaters (4306, 4307, 4320).
Many of the rules implemented through the Extreme Ozone Attainment Demonstration Plan and 2007 Ozone Plan, such as the Indirect Source Review (ISR) rule, are the first of their type in the nation, or are deemed the most stringent in the nation. The SJVAPCD’s (ISR) Rule bridges the gap between regulations and incentives to maximize reductions while minimizing socioeconomic impacts. The ISR rule requires developers of new development projects to reduce emissions during both the construction and operational phases of the project.
SJVAPCD works closely with developers to maximize on-site emissions reductions. However, if developers are not able to fully achieve required reductions through on-site measures, fees may be collected to fund offsite emission reduction projects.
State Implementation Plan
The SJVAPCD’s attainment plans are a regional component of the State Implementation Plan (SIP). The SIP includes annual increases in air pollutant emissions resulting from regional growth (including constructiongenerated emissions) anticipated according to local land use plans (e.g., general plans, regional transportation plans). The SIP also assumes the incremental increase in emissions will be partially offset through the implementation of stationary, area, and indirect source control measures contained within the SIP. The SIP is the State of California’s plan for attaining the National Ambient Air Quality Standards (NAAQS). The contents of a typical SIP fall into several categories:
State-adopted control measures which consists of either rules/regulations or source-specific requirements (e.g., orders and consent decrees);
State-submitted comprehensive air quality plans, such as attainment plans, maintenance plans, rate of progress plans, and transportation control plans demonstrating how these state regulatory and source-specific controls, in conjunction with federal programs, will bring and/or keep air quality in compliance with federal air quality standards;
State- submitted "non-regulatory" requirements, such as emission inventories, small business compliance assistance programs; statutes demonstrating legal authority, monitoring networks, etc.); and
Additional requirements promulgated by EPA (in the absence of a commensurate State provision) to satisfy a mandatory section 110 or part D (Clean Air Act) requirement.
SJVAPCD Rules and Regulations
During construction and operation, the project must comply with applicable rules and regulations. The following are rules that the project may be required to comply with, either directly, or indirectly:
District Rule 4101 Visible Emissions
This rule prohibits the emissions of visible air contaminants to the atmosphere. The rule prohibits the discharge into the atmosphere from any single source of emission, any air contaminant, other than uncombined water vapor, for a period or periods aggregating more than three (3) minutes in any one hour which is as dark or darker in shade as that designated as No. 1 on the Ringelmann Chart. 15 #8..
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Rule 4102 Nuisance
The purpose of this rule is to protect the health and safety of the public. The rule prohibits anyone from discharging air contaminants or other materials which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public or which endanger the comfort, repose, health or safety of any such person or the public or which cause or have a natural tendency to cause injury or damage to business or property. The provisions of this rule do not apply to odors emanating from agricultural operations in the growing of crops or raising of fowl or animals.
Rule 4601 Architectural Coatings
The purpose of this rule is to limit VOC emissions from architectural coatings by regulating the storage, cleanup, and labeling requirements. Painting Practices: The rule requires that all containers containing architectural coatings (including any volatile material used for thinning or cleanup) be closed when not in use.
The rule also sets limits on the number of VOCs in architectural coating and prohibits thinning such that the limits would be exceeded.
Rule 4641, Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations This rule limits VOC emissions by restricting the application and manufacturing of cutback asphalt8, slow cure asphalt, or emulsified asphalt.
Rule 4702 Internal Combustion Engines (Certified Equipment for Internal Combustion Engines) This rule requires stationary engines to meet certain exhaust limits for NOx and CO, but these limits are not applicable to standby engines as long as they are used fewer than 200 hours per year (e.g., for testing during non-emergencies).
District Regulation II (Permits)
District Regulation II (Permits) applies to permitted emission sources and includes rules such as SJVAPCD permit requirements (Rule 2010), New and Modified Stationary Source Review (Rule 2201), and implementation of Emission Reduction Credit Banking (Rule 2301). Many industrial projects and some commercial projects require SJVAPCD permits. Rule 2010 states that “any person who plans to or does operate, construct, alter, or replace any source of emission of air contaminants” must obtain approval of the Air Pollution Control Officer and receive an Authority to Construct and a Permit to Operate. Examples of air contaminant emitting equipment and processes include (but are not limited to) the following:
Agricultural products processing
Bulk material handling
Chemical blending, mixing, manufacturing, storage, etc. Combustion equipment (boilers, engines, heaters, incinerators, etc.) Metals etching, melting, plating, refining, etc.
Plastics & fiberglass forming and manufacturing
Petroleum production, manufacturing, storage, and distribution Rock & mineral mining and processing
Solvent use (degreasing, dry-cleaning, etc.)
Surface coating and preparation (painting, blasting, etc.) District Regulation II ensures that stationary source emissions will be reduced or mitigated to below the SJVAPCD’s significance thresholds. However, the Lead Agency can, and should, make an exception to this 8 Cutback asphalt is manufactured by blending asphalt cement with a petroleum solvent. 16 #8..
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determination if special circumstances suggest that the emissions from any permitted or exempt source may cause a significant air quality impact. For example, if a source may emit objectionable odors, then odor impacts on nearby receptors should be considered a potentially significant air quality impact.
SJVAPCD implementation of New Source Review (NSR) ensures that there is no net increase in emissions above specified thresholds from New and Modified Stationary Sources for all nonattainment pollutants and their precursors. Furthermore, in general, permitted sources emitting more than the NSR Offset Thresholds for any criteria pollutant must offset all emission increases in excess of the thresholds. However, under certain circumstances, the SJVAPCD may be precluded by state law or other SJVAPCD rule requirements from requiring a stationary source to offset emissions increases.
District Regulation VIII (Fugitive PM10 Prohibition)
The purpose of Regulation VIII (Reg. VIII) is to reduce ambient concentrations of fine particulate matter (PM10) by requiring actions to prevent, reduce or mitigate anthropogenic fugitive dust emissions. Reg. VIII requires property owners, contractors, developers, equipment operators, farmers and public agencies to control fugitive dust emissions from specified outdoor fugitive dust sources, including:
Construction sites
Excavation, Demolition, and other earthmoving activities Bulk material handling, storage and transport
Carryout and trackout
Vacant land
Paved and unpaved roads
Unpaved vehicle traffic areas
Regulation VIII specifies the following measures to control fugitive dust:
Apply water to unpaved surfaces and areas
Use non-toxic chemical or organic dust suppressants on unpaved roads and traffic areas Limit or reduce vehicle speed on unpaved roads and traffic areas Maintain areas in a stabilized condition by restricting vehicle access Install wind barriers
During high winds, cease outdoor activities that disturb the soil. Keep bulk materials sufficiently wet when handling
Store and handle materials in a three-sided structure When storing bulk materials, apply water to the surface or cover the storage pile with a tarp Don’t overload haul trucks. Overloaded trucks are likely to spill bulk materials Cover haul trucks with a tarp or other suitable cover. Or, wet the top of the load enough to limit visible dust emissions
Clean the interior of cargo compartments on emptied haul trucks prior to leaving a site Prevent trackout by installing a trackout control device Clean up trackout at least once a day. If along a busy road or highway, clean up trackout immediately Monitor dust-generating activities and implement appropriate measures for maximum dust control For projects in which construction related activities would disturb equal to or greater than 1-acre of surface area, the SJVAPCD recommends that demonstration of receipt of a SJVAPCD approved Dust Control Plan or Construction Notification form, before issuance of the first grading permit, be made a condition of project approval. It should be noted that although compliance with District Regulation VIII substantially reduces project specific fugitive dust emissions, it may not be sufficient to reduce project specific emissions to less than significant levels. Furthermore, District Regulation VIII does not reduce construction exhaust emissions. 17 #8..
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District Rule 9510 (Indirect Source Review)
District Rule 9510 (ISR) is intended to reduce a project’s impact on air quality through project design elements or mitigation by payments of applicable off-site mitigation fees. Compliance with Rule 9510 will reduce construction exhaust NOx and PM10 emissions by 20 percent and 45 percent respectively. Compliance with Rule 9510 will reduce operational emissions of NOx and PM10 emissions by 33.3 percent and 50 percent respectively. Individual development projects would be subject to ISR requirements if upon full build-out the project would include or exceed any one of the following:
50 dwelling units;
2,000 square feet of commercial space;
25,000 square feet of light industrial space;
100,000 square feet of heavy industrial space;
20,000 square feet of medical office space;
39,000 square feet of general office space;
9,000 square feet of educational space;
10,000 square feet of government space;
20,000 square feet of recreational space; or
9,000 square feet of space not identified above
The ISR rule also applies to any transportation or transit project where construction exhaust emissions equal or exceed two (2.0) tons NOx or two (2.0) tons of PM10.
For projects subject to District Rule 9510, the SJVAPCD recommends that demonstration of compliance with District Rule 9510, including payment of all applicable fees before issuance of the first building permit, be made a condition of project approval.
It should be noted that although compliance with District Rule 9510 substantially reduces project specific impacts on air quality, it may not be sufficient to reduce project specific emissions to less than significant levels.
District Rule 9410 (Employer Based Trip Reduction)
The eTRIP Rule (Rule 9410, Employer Based Trip Reduction), requires larger employers to establish an Employer Trip Reduction Implementation Plan (eTRIP). An eTRIP is a set of measures that encourages employees to use alternative transportation and ridesharing for their morning and evening commutes. Each measure contributes to a workplace where it is easier for employees to choose to use ridesharing or alternative transportation. Through this rule, single-occupancy vehicle trips are reduced, thus reducing emissions of oxides of nitrogen (NOx), volatile organic compounds (VOC) and particulate matter (PM).
Air Quality Guidance Documents
SJVAPCD Guidance for Assessing and Mitigating Air Quality Impacts As a public agency, the SJVAPCD takes an active part in the intergovernmental review process under CEQA.
The SJVAPCD is available to assist governmental agencies and project proponents in understanding how to characterize project-related impacts on air quality and how to reduce or mitigate those impacts. As part of this ongoing effort, the SJVAPCD develops and publishes technical guidance relevant to assessing project specific emissions of criteria pollutants and assessing potential health risks to sensitive receptors. One such document is the Guidance for Assessing and Mitigating Air Quality Impacts which was prepared by the 18 #8..
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SJVAPCD in 2015 with the most current updates found at https://ww2.valleyair.org/ceqa. The purpose of this document is to provide technical guidance for the review of air quality impacts from proposed projects within the boundaries of the SJVAPCD. The guide provides SJVAPCD staff uniform procedures for assessing potential air quality impacts of proposed projects and for preparing the air quality section of environmental documents. The guide is intended to be a user-friendly advisory document for use by other agencies, consultants, and project proponents. The Guidance for Assessing and Mitigating Air Quality Impacts and supplemental information is used in this analysis.
Local – City of Modesto
Local jurisdictions, such as the City of Modesto, have the authority and responsibility to reduce air pollution through its police power and decision-making authority. Specifically, the City is responsible for the assessment and mitigation of air emissions resulting from its land use decisions. In accordance with CEQA requirements and the CEQA review process, the City assesses the air quality impacts of new development projects, requires mitigation of potentially significant air quality impacts by conditioning discretionary permits, and monitors and enforces implementation of such mitigation.
In accordance with the CEQA requirements, the City does not, however, have the expertise to develop plans, programs, procedures, and methodologies to ensure that air quality within the City and region will meet federal and state standards. Instead, the City relies on the expertise of the SJVAPCD and utilizes the SJVAPCD Guidance for Assessing and Mitigating Air Quality Impacts as the guidance document for the environmental review of plans and development proposals within its jurisdiction.
The City of Modesto General Plan was adopted on March 5, 2019. The policies related to air quality that are applicable to the proposed project from the Environmental Resources, Open Space, and Conservation Element of the Modesto General Plan have been included below.
Policies
a. Implement measures to reduce motor vehicle use and related ozone precursor and PM10 emissions through changes to the transportation infrastructure. Potential measures to be implemented may include those shown in Section V-2 of the Final Master Environmental Impact Report.
b. Implement measures to reduce vehicle use and associated emissions related to existing and future land use development in the City of Modesto. Potential measures to be implemented may include those shown in Section V-2 of the Final Master Environmental Impact Report. c. Implement measures to reduce emissions associated with energy use by residences and businesses. Potential measures to be implemented may include those shown in Section V-2 of the Draft Master EIR.
d. The City of Modesto recognizes the efforts of the San Joaquin Valley Air Pollution Control District to identify the cumulative transportation and air quality impacts of all General Plan amendments approved during the previous year. This measure is intended to track the effectiveness of current air quality–related programs and guide revision to these programs through periodic review of cumulative air quality impacts in the City.
The following policies are intended to reduce air quality impacts through inter-agency coordination. e. Work with neighboring jurisdictions and affected agencies to address cross-jurisdictional and regional transportation and air quality issues.
f. Coordinate with other jurisdictions and other regional agencies in the San Joaquin valley to establish parallel air quality programs and implementation measures (trip reduction ordinances, indirect source programs, etc.).
g. Implement measures to reduce emissions associated with future development through the CEQA review process. Section V-2 of the MEIR describes those measures to be implemented, as well as additional measures that may be implemented at the discretion of the City. 19 #8..
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h. Consult with the SJVAPCD during CEQA review for discretionary projects with the potential for causing adverse air quality impacts.
i. Consider supporting investment in geographic information system technology.
The following policies are intended to accurately determine and fairly mitigate the local and regional air quality impacts of projects proposed in the City of Modesto.
o. Determine project air quality impacts using analysis methods and significance thresholds recommended by the SJVAPCD.
p. Ensure that identified air quality impacts are consistently and fairly mitigated. q. Ensure all air quality mitigation measures are feasible, implementable, and cost effective. r. Identify the cumulative transportation and air quality impacts of all General Plan amendments approved during the previous year.
s. Reduce the air quality impacts of development projects that may be insignificant by themselves, but cumulatively are significant.
t. Encourage innovative mitigation measures to reduce air quality impacts by coordinating with the SJVAPCD, project applicants, and other interested parties. u. Review of new development shall be coordinated with SJVAPCD staff to ensure all projects subject to the SJVAPCD Rule 9510 (Indirect Source Review) comply fully with the rule. This rule fulfills the SJVAPCD’s emission reduction commitments in the PM10 and Ozone Attainment Plans through emission reductions from the construction and use of development projects through design features and onsite measures. Rule 9510 applies to any applicant that seeks to gain a final discretionary approval for a development project, or any portion thereof, which meets certain minimum thresholds.
v. A Construction Health Risk Assessment shall be required on a project-by-project basis if, at the direction of SJVAPCD after applicant consultation, the specific project is considered to have a potentially significant project-level health risk impact, through refined modeling using 2015 OEHHA guidance (or the latest accepted methodology), to identify impacts and, if necessary, include measures determined by SJVAPCD to reduce exposure. x. Coordinate land use planning to prevent new odor complaints. Consult with SJVAPCD, as necessary, to identify the potential for odor complaints from various existing and planned or proposed land uses and development projects. Prohibit new sources of odors that have the potential to result in frequent odor complaints unless it can be shown that potential odor complaints can be mitigated where feasible. Prohibit sensitive receptors from locating near odor sources where frequent odor complaints would occur, unless it can be shown that potential odor complaints can be mitigated where feasible.
The following policies are consistent with the SJVAPCD Air Quality Guidelines for General Plans and are intended to integrate land use planning, transportation planning, and air quality planning to make the most efficient use of public resources and to create a healthier and more livable environment. y. Consider air quality when planning the land uses and transportation systems to accommodate the expected growth in this community.
z. All transportation improvement projects to be included in regional transportation plans (RTP, RTIP, CMP, etc.) should be consistent with the air quality goals and policies of the General Plan. aa. Consult with transit providers to determine project impacts on long-range transit plans and ensure that impacts are mitigated where feasible.
cc. Work with Caltrans and the Regional Transportation Planning Agency to minimize the air quality, mobility, and social impacts of large-scale transportation projects on existing neighborhoods.
The following policies are consistent with the SJVAPCD Air Quality Guidelines for General Plans and are intended to reduce emissions of PM10 and other particulates with local control potential. 20 #8..
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jj. Reduce particulate emissions from construction, grading, excavation, and demolition to the maximum extent feasible in accordance with the requirements of SJVAPCD Regulation VIII.
Regulation VIII was adopted to reduce the amount of particulate matter suspended in the atmosphere as a result of emissions generated from anthropogenic (man-made) fugitive dust sources.
kk. Require all access roads, driveways, and parking areas serving new commercial and industrial development to be constructed with materials that minimize particulate emissions in accordance with the requirements of SJVAPCD Regulation VIII and are appropriate to the scale and intensity of use.
ll. Reduce PM10 emissions from City–maintained roads to the maximum extent feasible.
The following controls are required to be implemented at all construction sites. mm. Effectively stabilize dust emissions using water, chemical stabilizer / suppressant, cover with a tarp or other suitable cover or vegetative ground cover, all disturbed areas, including storage piles, which are not being actively utilized for construction purposes. nn. Effectively stabilize dust emissions using water or chemical stabilizer / suppressant, all onsite unpaved roads and off-site unpaved access roads.
oo. Effectively control fugitive dust emissions utilizing application of water or by presoaking all land clearing, grubbing, scraping, excavation, land leveling, grading, cut & fill, and demolition activities.
pp. Wet all exterior surfaces of buildings that are more than six stories tall during demolition. qq. When materials are transported off site, cover all materials, or effectively wet them to limit visible dust emissions, and maintain at least six inches of freeboard space from the top of the container.
rr. Limit operations or expeditiously remove the accumulation of mud or dirt from adjacent public streets at the end of each workday (the use of dry rotary brushes is expressly prohibited except where preceded or accompanied by sufficient wetting to limit the visible dust emissions.) (Use of blower devices is expressly forbidden.)
ss. Following the addition of materials to, or the removal of materials from, the surface of outdoor storage piles, effectively stabilize said piles for fugitive dust emissions utilizing sufficient water or chemical stabilizer / suppressant.
tt. Within urban areas, immediately remove trackout when it extends 50 or more feet from the site and at the end of each workday.
uu. Prevent carryout and trackout for any site with 150 or more vehicle trips per day.
The following measures should be implemented at construction sites when required to mitigate significant PM10 impacts (note, these measures are to be implemented in addition to Regulation VIII requirements). vv. Limit traffic speeds on unpaved roads to 15 mph.
ww. Install sandbags or other erosion control measures to prevent silt runoff to public roadways from sites with a slope greater than one percent (1%).
The following measures are strongly encouraged at construction sites that are large in area, located near sensitive receptors, or which for any other reason warrant additional emissions reductions. xx. Install wheel washers for all exiting trucks, or wash off all trucks and equipment leaving the site. yy. Install wind breaks at windward side(s) of construction areas. zz. Suspend excavation and grading activity when winds exceed 20 mph (regardless of windspeed, an owner/operator must comply with Regulation VIII’s 20 percent (20%) opacity limitation). aaa. Limit the area subject to excavation, grading, and other construction activity at any one time.
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California Standards
Federal Primary
Standards
0.09 ppm/1-hour
0.07 ppm/8-hour 0.070 ppm/8-hour
(a) Decline in pulmonary function and localized lung edema in humans and animals; (b) Risk to public health implied by alterations in pulmonary morphology and host defense in animals; (c) Increased mortality risk; (d) Risk to public health implied by altered connective tissue metabolism and altered pulmonary morphology in animals after long-term exposures and pulmonary function decrements in chronically exposed humans; (e) Vegetation damage; and (f) Property damage.
20.0 ppm/1-hour
9.0 ppm/8-hour
35.0 ppm/1-hour
9.0 ppm/8-hour
(a) Aggravation of angina pectoris and other aspects of coronary heart disease; (b) Decreased exercise tolerance in persons with peripheral vascular disease and lung disease; (c) Impairment of central nervous system functions; and (d) Possible increased risk to fetuses.
0.18 ppm/1-hour
0.03 ppm/annual
100 ppb/1-hour
0.053 ppm/annual
(a) Potential to aggravate chronic respiratory disease and respiratory symptoms in sensitive groups; (b) Risk to public health implied by pulmonary and extra-pulmonary biochemical and cellular changes and pulmonary structural changes; and (c) Contribution to atmospheric discoloration.
0.25 ppm/1-hour
0.04 ppm/24-hour
75 ppb/1-hour
0.14 ppm/annual
(a) Bronchoconstriction accompanied by symptoms which may include wheezing, shortness of breath and chest tightness, during exercise or physical activity in persons with asthma.
50 μg/m3
/24-hour
20 μg/m3
/annual
150 μg/m3
/24-hour
12 μg/m3
/ annual 35 μg/m3
/24-hour
9 μg/m3
/annual
25 μg/m3
/24-hour No Federal Standards
(a) Decrease in ventilatory function; (b) Aggravation of asthmatic symptoms; (c ) Aggravation of cardio-pulmonary disease; (d) Vegetation damage; (e) Degradation of visibility; (f) property damage.
1.5 μg/m3
/30-day 0.15 μg/m3
/3-month
rolling (a) Learning disabilities; (b) Impairment of blood formation and nerve conduction.
Extinction coefficient
of 0.23 per kilometervisibility of 10 miles or
more due to particles
when humidity is less
than 70 percent.
No Federal Standards Visibility impairment on days when relative humidity is less than 70 percent.
Source: https://ww2.arb.ca.gov/sites/default/files/2020-07/aaqs2.pdf Table 2
Visibility
Reducing
Particles
Concentration / Averaging Time
Most Relevant Effects
(a) Exacerbation of symptoms in sensitive patients with respiratory or cardiovascular disease; (b) Declines in pulmonary function growth in children; (c) Increased risk of premature death from heart or lung diseases in elderly.
State and Federal Criteria Pollutant Standards
Air Pollutant
Ozone (O3)
Carbon
Monoxide
(CO)
Nitrogen
Dioxide (NO2)
Sulfur Dioxide
(SO2)
Suspended
Particulate
Matter (PM10)
Suspended
Particulate
Matter (PM2.5)
Sulfates
Lead
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Federal Standards1 State Standards2
Revoked6 Nonattainment/Severe
Nonattainment/Extreme5 Nonattainment
Attainment3 Nonattainment
Nonattainment4 Nonattainment
Attainment/Unclassified Attainment/Classified
Attainment/Unclassified Attainment
Attainment/Unclassified Attainment
No Designation/Classification Attainment
No Federal Standard Unclassified
No Federal Standard Attainment
No Federal Standard Unclassified
No Federal Standard Attainment
(1) See 40 CFR Part 81
(2) See CCR Title 17 Sections 60200-60210
(3)
(4)
(5)
(6)
On September 25, 2008, EPA redesignated the San Joaquin Valley to attainment for the PM10 National Ambient Air Quality Standard (NAAQS) and approved the 2007 PM10 Maintenance Plan.
The Valley is designated nonattainment for the 1997 PM2.5 NAAQS. EPA designated the Valley as nonattainment for the 2006 PM2.5 NAAQS on November 13, 2009 (effective December 14, 2009).
Though the Valley was initially classified as serious nonattainment for the 1997 8-hour ozone standard, EPA approved Valley reclassification to extreme nonattainment in the Federal Register on May 5, 2010 (effective June 4, 2010).
Effective June 15, 2005, the U.S. Environmental Protection Agency (EPA) revoked the federal 1-hour ozone standard, including associated designations and classifications. EPA had previously classified the District as extreme nonattainment for this standard. EPA approved the 2004 Extreme Ozone Attainment Demonstration Plan on March 8, 2010 (effective April 7, 2010). The District Governing Board adopted the 2023 Maintenance Plan and Redesignation Request and submitted to EPA in June of 2023. Although the standard is revoked, antibacksliding provisions can be terminated upon final approval of the Maintenance Plan from EPA.
Source (Federal and State Status): San Joaquin Valley Air Pollution Control District Ambeint Air Quality Standards and Attainment Status. https://ww2.valleyair.org/air-quality-information/ambient-air-quality-standards-valley-attainmnet-status/ Lead (Particulate)
Vinyl Chloride
Table 3
San Joaquin Valley Attainment Status
Pollutants
Ozone - one hour
Carbon monoxide
Nitrogen dioxide
Sulfur dioxide
Ozone - eight hour
PM10
PM2.5
Hydrogen Sulfide
Sulfates
Visibilty Reducing Particles
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MONITORED AIR QUALITY
The air quality at any site is dependent on the regional air quality and local pollutant sources. Regional air quality is determined by the release of pollutants throughout the air basin.
The SJVAPCD, the Air Resources Board, the United States National Park Service, and the Santa Rosa Rancheria in Lemoore operate an extensive air monitoring network to measure progress toward attainment of the NAAQS. Air quality monitoring networks are designed to monitor areas with: high population densities, areas with high pollutant concentrations, areas impacted by major pollutant sources, and areas representative of background concentrations. Some monitors are operated specifically for use in determining attainment status, while others are operated for other purposes, such as for generating daily air quality forecasts. In total, the SJVAPCD utilizes ozone and PM data from over 60 monitors operated at 29 sites in the San Joaquin Valley. All monitors must comply with the pollutant standard for the San Joaquin Valley to be considered as attainment for that standard.
The nearest air monitoring station to the project site is the Modesto Monitoring Station (Modesto Station).
The Modesto Station is located approximately 4.89 miles southeast of the project site at 814 14th Street, Modesto. As not all monitoring stations monitor all pollutants, data was also taken from the Turlock – S Minaret Street Monitoring Station (Turlock Station) located approximately 18.21 miles southeast of the project site at 900 S Minaret Street, Turlock. Table 4 presents the monitored pollutant levels from the Modesto and Turlock Stations. However, it should be noted that due to the air monitoring stations’ distances from the project site, recorded air pollution levels at the air monitoring station reflect with varying degrees of accuracy, local air quality conditions at the project site.
Table 4 summarizes 2021 through 2023 published monitoring data, which is the most recent 3-year period available. The data shows that during the past few years, the project area has exceeded the ozone standards.
Ozone
During the 2021 to 2023 monitoring period, the State 1-hour concentration standard for ozone was exceeded between one and three days each year at the Modesto Station. The State 8-hour ozone standard has been exceeded between five and 14 days each year over the past three years at the Modesto Station. The Federal 8-hour ozone standard was exceeded between four and 12 days each year over the past three years at the Modesto Station.
Ozone is a secondary pollutant as it is not directly emitted. Ozone is the result of chemical reactions between other pollutants, most importantly hydrocarbons and NO2, which occur only in the presence of bright sunlight.
Carbon Monoxide
CO is another important pollutant that is due mainly to motor vehicles. The Modesto Station did not record an exceedance of the state or federal 8-hour CO standard for the last three years.
Nitrogen Dioxide
Turlock Station did not record an exceedance of the State or Federal NO2 standards for the last three years.
Particulate Matter
The State 24-hour concentration standards for PM10 was exceeded between 268 and 59 days each year over the last three years at the Modesto Station. Over the past three years, the Federal 24-hour standards for PM10 were not exceeded at the Modesto Station.
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During the 2021 to 2023 monitoring period, the Federal 24-hour standard for PM2.5 was exceeded between three and 20 days each year at the Modesto Station.
According to the EPA, some people are much more sensitive than others to breathing fine particles (PM10 and PM2.5). People with influenza, chronic respiratory and cardiovascular diseases, and the elderly may suffer worsening illness and premature death due to breathing these fine particles. People with bronchitis can expect aggravated symptoms from breathing in fine particles. Children may experience decline in lung function due to breathing in PM10 and PM2.5. Other groups considered sensitive are smokers and people who cannot breathe well through their noses. Exercising athletes are also considered sensitive, because many breathe through their mouths during exercise.
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2021 2022 2023
Maximum 1-Hour Concentration (ppm) 0.106 0.113 0.099
Days > CAAQS (0.09 ppm) 311
Maximum 8-Hour Concentration (ppm) 0.089 0.086 0.084
Days > NAAQS (0.070 ppm) 10 4 12
Days > CAAQS (0.070 ppm) 11 5 14
Maximum 8-Hour Concentration (ppm) ***
Days > CAAQS (9 ppm) 000
Days > NAAQS (9 ppm) 000
Maximum 1-Hour Concentration (ppm) 0.040 0.045 0.047
Days > CAAQS (0.18 ppm) 000
Maximum 24-Hour Concentration (μg/m3
) 145.7 88.5 97.6
Days > NAAQS (150 μg/m3) 000
Days > CAAQS (50 μg/m3) 59 38 26
Annual Average (μg/m3) 36.9 32.5 24.0
Maximum 24-Hour Concentration (μg/m3) 66.8 53.9 43.2
Days > NAAQS (35 μg/m3) 20 10 3
Annual Average (μg/m3) 15 13.3 10.5
Notes:
(1) CAAQS = California Ambient Air Quality Standard; NAAQS = National Ambient Air Quality Standard; ppm = parts per million *
(2) Data taken from the Turlock - S Minaret Street Monitoring Station.
Source: http://www.arb.ca.gov/adam/topfour/topfour1.php. Data from the Modesto Monitoring Station, unless otherwise noted.
Year
Air Quality Monitoring Summary
Table 4
Pollutant (Standard)1
Ultra-Fine
Particulates
(PM2.5):
Ozone:
Carbon
Monoxide:
Nitrogen
Dioxide:2
Inhalable
Particulates
(PM10):
Means there was insufficient data available to determine value.
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AIR QUALITY STANDARDS
Significance Thresholds
Appendix G of the State CEQA Guidelines
Appendix G of the State CEQA Guidelines states that, where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make a significance determination. Pursuant to Appendix G, the project would result in a significant impact related to air quality if it would:
Conflict with or obstruct the implementation of the applicable air quality plan; Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard; Expose sensitive receptors to substantial pollutant concentrations; or Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.
The CEQA Guidelines Section 15064.7 provides the significance criteria established by the applicable air quality management district or air pollution control district, when available, may be relied upon to make determinations of significance. To assess the air quality impact using these five effects per CEQA guidelines, the SJVAPCD has established significance thresholds as stated in the SJVAPCD Guidance for Assessing and Mitigating Air Quality Impacts.
The SJVAPCD recommends that the Lead Agencies apply the adopted significance thresholds when evaluating project specific impacts on air quality within the San Joaquin Valley. If the Lead Agency determines the proposed project would exceed San Joaquin Valley Unified Air Pollution Control District Guidance for Assessing and Mitigating Air Quality Impacts March 19, 2015 Page 75 of 125 any of the significance thresholds, then an environmental document should be prepared. However, it is recognized that the final determination of whether a project would have a significant effect on air quality is ultimately within the purview of the Lead Agency pursuant to CEQA Guidelines (CCR §15064(c)).
Regional Air Quality
The significance of the impacts of the emissions from construction, operational non-permitted equipment and activities, and operational permitted equipment and activities are evaluated separately. The thresholds of significance are based on a calendar year basis. For construction emissions, the annual emissions are evaluated on a rolling 12-month period. A project evaluation should characterize emissions associated with the following:
Construction related emissions
Grading, excavation, road building, and other earth moving activities Travel by construction equipment, especially on unpaved surfaces Exhaust from construction equipment
Architectural coatings
Asphalt paving
Demolition and renovation of buildings
Off-road construction equipment
Operational related emissions
Permitted equipment and activities (Stationary Source Equipment) Non-permitted equipment and activities
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Mobile sources (on-site and on-road)
Non-permitted activities
The SJVAPCD current adopted thresholds of significance for criteria pollutant emissions and their application are identified in Table 5.
Toxic Air Contaminants
The SJVAPCD’s current thresholds of significance for toxic air contaminant (TAC) emissions from the operations of both permitted and non-permitted sources are combined and presented below. Carcinogens:
Maximally Exposed Individual risk equals or exceeds 10 in one million Non-Carginogens:
Acute: Hazard Index equals or exceeds 1 for the Maximally Exposed Individual Chronic: Hazard Index equals or exceeds 1 for the Maximally Exposed Individual Carcinogenic (cancer) risk is expressed as cancer cases per one million. Non-carcinogenic (acute and chronic) hazard indices (HI) are expressed as a ratio of expected exposure levels to acceptable exposure levels. The significance of the impacts of TAC emissions from both permitted and non-permitted equipment and activities is evaluated under a single threshold, for example 10 in one million.
Odor Impacts
The SJVAPCD Guidance for Assessing and Mitigating Air Quality Impacts states that while offensive odors rarely cause any physical harm, they can be unpleasant, leading to considerable distress among the public and often resulting in citizen complaints to local governments and the SJVAPCD. However, a project should be evaluated to determine the likelihood that the project would result in nuisance odors. Any project with the potential to frequently expose members of the public to objectionable odors should be deemed to have a significant impact. Nuisance odors may be assessed qualitatively taking into consideration project design elements and proximity to off-site receptors that potentially would be exposed to objectionable odors.
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. Rather, projects must be assessed on a case-bycase basis.
Odor impacts on residential areas and other sensitive receptors, such as hospitals, daycare centers, schools, etc., warrant the closest scrutiny, but consideration should also be given to other land uses where people may congregate, such as recreational facilities, worksites, and commercial areas. An analysis of potential odor impacts should be conducted for the following two situations:
Generators – projects that would potentially generate odorous emissions proposed to locate near existing sensitive receptors or other land uses where people may congregate, and Receivers – residential or other sensitive receptor projects or other projects built for the intent of attracting people locating near existing odor sources.
The intensity of an odor source’s operations and its proximity to sensitive receptors influences the potential significance of odor emissions. The SJVAPCD has identified some common types of facilities that have been known to produce odors in the San Joaquin Valley Air Basin. These are presented in Table 6. 28 #8..
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The Lead Agency should prepare a more detailed analysis for any project that would result in an odor source and sensitive receptors being located closer to one another than the distances indicated in Table 6. When projects trigger the screening level distances in Table 6, the Lead Agency or consultant should contact the SJVAPCD’s Compliance Division for information regarding odor complaints.
Existing Odor Sources
For projects involving a new receptor being located near an existing odor source(s), the SJVAPCD’s Compliance Division should be contacted. The Compliance Division will provide information on odor complaints logged for the facility(ies) for the previous three years. Because offensive odors rarely cause any physical harm and no requirements for their control are included in state or federal air quality regulations, the SJVAPCD has no rules or standards related to odor emissions, other than its nuisance rule. Any actions related to odors are based on citizen complaints to local governments and the SJVAPCD. Lead Agencies can also make a determination of significance based on a review of SJVAPCD complaint records. For a project located near an existing source of odors, the impact is potentially significant when the project site is at least as close as any other site that has already experienced significant odor problems related to the odor source. Significant odor problems are defined as:
More than one confirmed complaint per year averaged over a three-year period, or Three unconfirmed complaints per year averaged over a three-year period.
An unconfirmed complaint means that either the odor/air contaminant release could not be detected, or the source/facility cannot be determined. Because of the subjective nature of odor impacts and the lack of quantitative or formulaic methodologies, the significance determination of potential odor impacts should be considered on a case-by-case basis.
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Permitted Equipment and Activities
Non-Permitted Equipment and
Activities
Emissions (tons/year) Emissions (tons/year) Emissions (tons/year) 100 100 100
10 10 10
10 10 10
27 27 27
15 15 15
15 15 15
Source: http://www.valleyair.org/transportation/ceqa_idx.htm SJVAPCD Air Quality Significance Thresholds
Table 5
CO
Pollutant/Precursor
Operational Emissions
Construction Emissions
Air Quality Thresholds of Significance - Criteria Pollutants Chronic: Hazard Index equals or exceeds 1 for the Maximally Exposed Individual NOx
ROG
SOx
PM10
PM2.5
Non-Carcinogens
Air Quality Thresholds of Significance - Toxic Air Contaminants Carcinogens Maximally Exposed Individual risk equals or exceeds 20 in one million Acute: Hazard Index equals or exceeds 1 for the Maximally Exposed Individual Stanislaus Elementary School 1,2,3-TCP Mitigation
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Distance
2 miles
1 miles
1 miles
1 miles
2 miles
1 mile
1 mile
1 mile
1 mile
1 mile
1 mile
1 mile
Transfer Station
Table 6
Screening Levels for Potential Odor Sources
Type of Facility
Wastewater Treatment Facilities
Sanitary Landfill
Painting/Coating Operations (e.e. auto body shops)
Feed Lot/Dairy
Rendering Plant
Source: San Joaquin Valley Air Pollution Control District Guidance for Assessing and Mitigating Air Quality Impacts (March 19, 2015) https://ww2.valleyair.org/media/g4nl3p0g/gamaqi.pdf.
Composting Facility
Petroleum Refinery
Asphalt Batch Plant
Chemical Manufacturing
Fiberglass Manufacturing
Food Processing Facility
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SHORT-TERM CONSTRUCTION EMISSIONS
Construction activities associated with the proposed project would have the potential to generate air emissions, TAC emissions, and odor impacts. Assumptions for the phasing, duration, and required equipment for the construction of the proposed project were obtained from the project applicant. The project includes the installation of approximately 12,000 linear feet of 12-inch diameter pipe. The entire alignment will be buried underground using open trench construction as well as jack and bore construction to avoid direct impacts to existing utilities and structures. Temporary areas of disturbance as a result of trenching is anticipated to be 6-feet wide and 8-feet deep along the entire 12,000 linear feet of project alignment, approximately 1.64 acres. Jack and bore construction will consist of 5 total pits.9 Jacking pits are approximately 12-feet wide by 10-feet long by 15-feet deep and receiving pits are approximately 12-feet wide by 24-feet long by 15-feet deep, resulting in approximately 0.03 acres of disturbance. Therefore, the total area of disturbance assumed for construction of the proposed project is approximately 1.67 acres. Per the project applicant, construction equipment is to include: one (1) scraper, five (5) tractors/loaders/backhoes, one (1) off-highway trucks, one (1) plate compactor, one (1) excavator, one (1) other material handling equipment, one (1) paving equipment, one (1) other construction equipment, two (2) pumps, one (1) skid steer loaders, one (1) surfacing equipment, one (1) rubber tired dozer, and one (1) crane. Based on these details and as construction is not anticipated to be phased, to provide a conservative scenario, the entirety of the project has been analyzed as occurring in one construction phase with all proposed equipment in operation simultaneously. It is estimated that the project would include approximately 4,680 cubic yards (CY) of import and 3,348 CY of export. See Appendix B for more details.
The proposed project is anticipated to start construction no sooner than the beginning of fall 2024, taking approximately 11 months to complete, with completion estimated by early fall 2025. The project is anticipated to be operational in 2025.
Methodology
The following provides a discussion of the methodology used to calculate regional construction air emissions for the criteria pollutants. The construction-related regional air quality impacts have been analyzed for both criteria pollutants and GHGs.
Emissions are estimated using the CalEEMod (Version 2022.1.1.28) software, which is a statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and GHG emissions from a variety of land use projects. CalEEMod was developed in collaboration with the air districts of California.
Regional data (e.g., emission factors, trip lengths, meteorology, source inventory, etc.) have been provided by the various California air districts to account for local requirements and conditions. The model is considered to be an accurate and comprehensive tool for quantifying air quality and GHG impacts from land use projects throughout California.
Daily regional emissions during construction are forecasted by assuming a conservative estimate of construction activities (i.e., assuming all construction occurs at the earliest feasible date) and applying the mobile source and fugitive dust emissions factors. The input values used in this analysis were adjusted to be project-specific for the construction schedule and the equipment used was based on CalEEMod defaults. The CalEEMod program uses the EMFAC2021 computer program to calculate the emission rates specific for Stanislaus County for construction-related employee vehicle trips and the OFFROAD2017 computer program to calculate emission rates for heavy truck operations. EMFAC2021 and OFFROAD2017 are computer 9 For modeling purposes, assumptions were made about the location of jacking and receiving pits based on a “worst-case scenario”.
Under “worst-case” conditions, boring locations are located closest to sensitive receptors adjacent to the project alignment: one (1) along the east side of Dale Road, approximately 150 feet from sensitive receptors; three (3) along the north side of Kiernan Avenue, bordering the southern perimeter of Stanislaus Elementary School, approximately 50 ft from the closest sensitive receptors; and one (1) along the west side of Tully Road, approximately 50 ft from the closest sensitive receptors. 32 #8..
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programs generated by CARB that calculates composite emission rates for vehicles. Emission rates are reported by the program in grams per trip and grams per mile or grams per running hour. Daily truck trips and CalEEMod default trip length data were used to assess roadway emissions from truck exhaust. The maximum daily emissions are estimated values for the worst-case day and do not represent the emissions that would occur for every day of project construction. The maximum daily emissions are compared to the SJVAPCD daily regional numeric indicators. Detailed construction equipment lists, construction scheduling, and emission calculations are provided in Appendix B.
The project will be required to comply with existing SJVAPCD rules for the reduction of fugitive dust emissions. District Regulation VIII establishes these procedures. Regulation VIII specifies the following measures to control fugitive dust: apply water to unpaved surfaces and areas, use non-toxic chemical or organic dust suppressants on unpaved roads and traffic areas, limit or reduce vehicle speed on unpaved roads and traffic areas, maintain areas in a stabilized condition by restricting vehicle access, install wind barriers, cease outdoor activities that disturb soil during high winds, keep bulk materials sufficiently wet when handling, store and handle materials in a three-sided structure, apply water to the surface or cover storage pile with a tarp for bulk storage, don’t overload trucks, cover haul trucks or wet the top, clean interior of cargo compartments on emptied haul trucks prior to leaving a site, install trackout control devices, and clean up trackout at least once a day. The SJVAPCD has determined that compliance with Regulation VIII and implementation of other control measures presented in their guidance manual10 constitutes sufficient mitigation to reduce PM10 impacts to a level considered less than significant.
For projects in which construction related activities would disturb equal to or greater than 1-acre of surface area, the SJVAPCD recommends that demonstration of receipt of a SJVAPCD approved Dust Control Plan or Construction Notification form, before issuance of the first grading permit, be made a condition of project approval. The project will disturb approximately 1.67 acres and a Dust Control Plan is recommended.
The phases of the construction activities which have been analyzed below for each phase are: (1) site preparation.11 Details pertaining to the project's construction timing and the type of equipment modeled for each construction phase are available in the CalEEMod output in Appendix B.
Construction-Related Regional Impacts
The construction-related criteria pollutant emissions for the construction of the proposed project are shown below in Table 7. Table 7 shows that none of the analyzed criteria pollutants would exceed the SJVAPCD regional emissions thresholds. Therefore, a less than significant regional air quality impact would occur from construction of the proposed pipeline extension project.
Construction-Related Health Impacts
Regarding health effects related to criteria pollutant emissions, the applicable significance thresholds are established for regional compliance with the state and federal ambient air quality standards, which are intended to protect public health from both acute and long-term health impacts, depending on the potential effects of the pollutant. Because regional emissions of criteria pollutants during construction of the project would be below the applicable thresholds, it would not contribute to long-term health impacts related to nonattainment of the ambient air quality standards. Therefore, significant adverse acute health impacts as a result of project construction are not anticipated.
10 San Joaquin Valley Air Pollution Control District, Guidance for Assessing and Mitigating Air Quality Impacts, March 19, 2015. https://ww2.valleyair.org/media/g4nl3p0g/gamaqi.pdf
11 The proposed project is the construction of a water pipeline. As stated in the project description, project construction is not anticipated to be phased and is to occur at approximately 100 feet of pipeline being laid per day for the entirety of the 11 month construction duration. Therefore, to be conservative, it was assumed that all construction activities would occur within one phase, site preparation, and that all anticipated construction equipment would be in operation during the duration of project construction. 33 #8..
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Construction-Related Toxic Air Contaminant Impacts
The greatest potential for TAC emissions would be related to diesel particulate emissions associated with heavy equipment operations during construction of the proposed project. According to the Office of Environmental Health Hazard Assessment (OEHHA)12, health effects from TACs are described in terms of individual cancer risk based on a lifetime (i.e., 30-year) resident exposure duration. Given the temporary and short-term construction schedule (approximately 11 months), the project would not result in a long-term (i.e., lifetime or 30-year) exposure as a result of project construction. Furthermore, construction-based particulate matter (PM) emissions (including diesel exhaust emissions) do not exceed any local or regional thresholds.
The project would comply with the CARB Air Toxics Control Measure that limits diesel powered equipment and vehicle idling to no more than 5 minutes at a location, and the CARB In-Use Off-Road Diesel Vehicle Regulation; compliance with these would minimize emissions of TACs during construction. Therefore, impacts from TACs during construction would be less than significant.
Construction-Related Odor Impacts
Potential sources that may emit odors during construction activities include the application of materials such as asphalt pavement. The objectionable odors that may be produced during the construction process are short-term in nature and the odor emissions are expected to cease upon the drying or hardening of the odor producing materials. Due to the short-term nature and limited amounts of odor producing materials being utilized, no significant impact related to odors would occur during construction of the proposed project. Diesel exhaust and VOCs would be emitted during construction of the project, which are objectionable to some; however, emissions would disperse rapidly from the project site and therefore should not reach an objectionable level at the nearest sensitive receptors. 12 Office of Environmental Health Hazard Assessment, Air Toxic Hot Spots Program Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessment, February 2015, https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf. 34 #8..
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ROG NOx CO SO2 PM10 PM2.5
0.31 2.79 3.15 0.01 0.34 0.20
10 10 100 27 15 15
No No No No No No
Notes:
Source: CalEEMod Version 2022.1.1.28.
(1) Includes both on-site and off-site emissions. On-site PM2.5 and PM-10 emissions show compliance with SJVAPCD Regulation VIII for fugitive dust.
Table 7
Construction-Related Regional Pollutant Emissions
Pollutant Emissions (tons/year)
Activity
Maximum Daily Emissions1
SJVAPCD Thresholds
Exceeds Thresholds?
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LONG-TERM OPERATIONAL EMISSIONS
The on-going operation of the proposed project would result in a long-term increase in air quality emissions.
This increase would be due to emissions from the project-generated operational emissions from the on-going use of the proposed project. The following section provides an analysis of potential long-term air quality impacts due to regional air quality impacts with the on-going operations of the proposed project.
Operations-Related Regional Air Quality Impacts
The potential operations-related air emissions have been discussed below for the criteria pollutants and cumulative impacts.
Operations-Related Criteria Pollutants Analysis
The project is the installation of approximately 12,000 linear feet of 12-inch diameter pipe. To conduct routine inspections and ensure proper long-term maintenance, the long-term operation of the project will require a minimal number of monthly worker trips. Additional staffing needs for long-term operation and maintenance of the proposed project are not anticipated. Therefore, operational emissions associated with the proposed project would be negligible and would not be anticipated to exceed SJVAPCD regional thresholds. Operation of the proposed project would result in a less than significant regional air quality impact.
Operations-Related Local Air Quality Impacts
Project-related air emissions may have the potential to exceed the State and Federal air quality standards in the project vicinity, even though these pollutant emissions may not be significant enough to create a regional impact to the San Joaquin Valley Air Basin (SJVAB). The proposed project has been analyzed for the potential local CO emission impacts from the project-generated vehicular trips and from the potential local air quality impacts from on-site operations. The following analysis analyzes the vehicular CO emissions, local impacts from on-site operations per SJVAPCD methodology, and odor impacts.
Local CO Emission Impacts from Project-Generated Vehicular Trips Emissions and ambient concentrations of carbon monoxide have decreased greatly in the recent past. These improvements are due largely to the introduction of lower emitting motor vehicles and cleaner burning fuels.
The last exceedance of either the state or national CO standard recorded at any of the SJVAB’s monitoring stations was in 1991. At present, all areas within the SJVAPCD have attained the federal CO standard and are attainment or unclassified for the state CO standard.
Despite the progress and success in achieving CO standards, localized CO concentrations still warrant concern in the San Joaquin Valley (SJV) and should still be assessed in environmental documents. The reasons for this are twofold. First, state and federal laws require the SJVAB to attain and maintain ambient air quality standards. The SJVAPCD must ensure that increased motor vehicle use and congestion do not nullify the great strides that have been made with respect to ambient concentrations of CO. Secondly, the SJVAPCD must safeguard against localized high concentrations of CO that may expose nearby sensitive receptors that may not be recorded at a given monitoring sites. Because elevated CO concentrations are often localized, heavy traffic volumes and congestion can lead to high levels of CO, or CO “hotspots”, while concentrations at the closest air quality monitoring station may be below state and federal standards.
Based on the CO Protocol Analysis developed by the California Department of Transportation (Caltrans), and due to the fact that increased CO concentrations are usually associated with roadways that are congested and with heavy traffic volume, the SJVAPCD has established that preliminary screening can be used to determine with fair certainty that the effect a project has on any given intersection would not result in a CO hotspot. Therefore, the SJVAPCD has established that if neither of the following criteria are met at all 36 #8..
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intersections affected by the developmental project, the project will result in no potential to create a violation of the CO standard:
A traffic study for the project indicates that the Level of Service (LOS) on one or more streets or at one or more intersections in the project vicinity will be reduced to LOS E or F; or A traffic study indicates that the project will substantially worsen an already existing LOS F on one or more streets or at more or more intersections in the project vicinity. If either of the above criteria can be associated with any intersection affected by the project, the applicant/consultant would need to conduct a CO analysis to determine a project’s significance.
As stated previously, the proposed project is that of the installation of a new water pipeline and additional City staffing needs for the long-term operation and maintenance of the project are not anticipated. The operation of the project is anticipated to include only monthly worker trips in order to conduct routine inspections and ensure proper long-term maintenance. Therefore, as the project operation includes only a negligible amount of monthly maintenance trips, and no traffic study was required or conducted for this project, no CO “hot spot” modeling was performed, and no significant long-term air quality impact is anticipated to local air quality with the on-going use of the proposed project.
Operations-Related Health Impacts
Regarding health effects related to criteria pollutant emissions, the applicable significance thresholds are established for regional compliance with the state and federal ambient air quality standards, which are intended to protect public health from both acute and long-term health impacts, depending on the potential effects of the pollutant. Long-term operation of the proposed project includes only monthly worker for routine inspections and maintenance. Therefore, regional emissions of criteria pollutants during operation of the project would be anticipated to be below the applicable thresholds and would not contribute to long-term health impacts related to nonattainment of the ambient air quality standards. Therefore, significant adverse acute health impacts as a result of project operation are not anticipated.
Operations-Related Odor Impacts
The proposed project is the consolidation of Stanislaus Union School District (SUSD) service area (Water System No. CA5000249) with the City of Modesto, through an extension of water and wastewater services, and the abandonment of the existing Well 02. The proposed project is neither a generator of odor emissions nor is it a sensitive receiver of existing odor emissions. Therefore, per the guidance identified in the SJVAPCD Guidance for Assessing and Mitigating Air Quality Impacts, no significant impact related to odors would occur during the on-going operations of the proposed project. 37 #8..
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CUMULATIVE AIR QUALITY IMPACTS
There are a number of cumulative projects in the project area that have not yet been built or are currently under construction. Since the timing or sequencing of the cumulative projects is unknown, any quantitative analysis to ascertain daily construction emissions that assumes multiple, concurrent construction projects would be speculative. Further, cumulative projects include local development as well as general growth within the project area. However, as with most developments, the greatest source of emissions is from mobile sources, which travel well out of the local area. Therefore, from an air quality standpoint, the cumulative analysis would extend beyond any local projects and when wind patterns are considered would cover an even larger area.
As stated in the SJVAPCD Guidance for Assessing and Mitigating Air Quality Impacts, when assessing whether there is a new significant cumulative effect, the Lead Agency shall consider whether the incremental effects of the project are cumulatively considerable. “Cumulatively considerable” means that the incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects [CCR §15064(h)(1)]. Per CEQA Guidelines §15064(h)(3) a Lead Agency may determine that a project’s incremental contribution to a cumulative effect is not cumulatively considerable if the project will comply with the requirements in a previously approved plan or mitigation program, including, but not limited to an air quality attainment or maintenance plan that provides specific requirements that will avoid or substantially lessen the cumulative problem within the geographic area in which the project is located.
Any proposed development project within the jurisdiction of SJVAPCD that would individually have a significant air quality impact would also be considered to have a significant cumulative air quality impact.
Therefore, if a project is significant based on the SJVAPCD thresholds of significance for criteria pollutants, then it is also cumulatively significant.
The proposed project does not exceed SJVAPCD air quality thresholds. As a result, the project would result in a less than significant cumulative impact for operational emissions.
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3. GLOBAL CLIMATE CHANGE ANALYSIS
EXISTING GREENHOUSE GAS ENVIRONMENT
Constituent gases of the Earth’s atmosphere, called atmospheric GHGs, play a critical role in the Earth’s radiation amount by trapping infrared radiation emitted from the Earth’s surface, which otherwise would have escaped to space. Prominent GHGs contributing to this process include carbon dioxide (CO2), methane (CH4), ozone, water vapor, nitrous oxide (N2O), and chlorofluorocarbons (CFCs). This phenomenon, known as the Greenhouse Effect, is responsible for maintaining a habitable climate. Anthropogenic (caused or produced by humans) emissions of these GHGs in excess of natural ambient concentrations are responsible for the enhancement of the Greenhouse Effect and have led to a trend of unnatural warming of the Earth’s natural climate, known as global warming or climate change. Emissions of gases that induce global warming are attributable to human activities associated with industrial/manufacturing, agriculture, utilities, transportation, and residential land uses. Transportation is responsible for 41 percent of the State’s GHG emissions, followed by electricity generation. Emissions of CO2 and nitrous oxide (NOx) are byproducts of fossil fuel combustion.
Methane, a potent GHG, results from off-gassing associated with agricultural practices and landfills. Sinks of CO2, where CO2 is stored outside of the atmosphere, include uptake by vegetation and dissolution into the ocean. The following provides a description of each of the GHGs and their global warming potential.
Water Vapor
Water vapor is the most abundant, important, and variable GHG in the atmosphere. Water vapor is not considered a pollutant; in the atmosphere it maintains a climate necessary for life. Changes in its concentration are primarily considered a result of climate feedbacks related to the warming of the atmosphere rather than a direct result of industrialization. The feedback loop in which water is involved is critically important to projecting future climate change. As the temperature of the atmosphere rises, more water is evaporated from ground storage (rivers, oceans, reservoirs, soil). Because the air is warmer, the relative humidity can be higher (in essence, the air is able to “hold” more water when it is warmer), leading to more water vapor in the atmosphere. As a GHG, the higher concentration of water vapor is then able to absorb more thermal indirect energy radiated from the Earth, thus further warming the atmosphere. The warmer atmosphere can then hold more water vapor and so on and so on. This is referred to as a “positive feedback loop”. The extent to which this positive feedback loop will continue is unknown as there is also dynamics that put the positive feedback loop in check. As an example, when water vapor increases in the atmosphere, more of it will eventually also condense into clouds, which are more able to reflect incoming solar radiation (thus allowing less energy to reach the Earth’s surface and heat it up).
Carbon Dioxide (CO2)
The natural production and absorption of CO2 is achieved through the terrestrial biosphere and the ocean.
However, humankind has altered the natural carbon cycle by burning coal, oil, natural gas, and wood. Since the industrial revolution began in the mid-1700s. Each of these activities has increased in scale and distribution. CO2 was the first GHG demonstrated to be increasing in atmospheric concentration with the first conclusive measurements being made in the last half of the 20th century. Prior to the industrial revolution, concentrations were fairly stable at 280 parts per million (ppm). The International Panel on Climate Change (IPCC Fifth Assessment Report, 2014) Emissions of CO2 from fossil fuel combustion and industrial processes contributed about 78% of the total GHG emissions increase from 1970 to 2010, with a similar percentage contribution for the increase during the period 2000 to 2010. Globally, economic and population growth continued to be the most important drivers of increases in CO2 emissions from fossil fuel combustion. The contribution of population growth between 2000 and 2010 remained roughly identical to the previous three decades, while the contribution of economic growth has risen sharply. 39 #8..
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Methane (CH4)
CH4 is an extremely effective absorber of radiation, although its atmospheric concentration is less than that of CO2. Its lifetime in the atmosphere is brief (10 to 12 years), compared to some other GHGs (such as CO2, N2O, and Chlorofluorocarbons (CFCs). CH4 has both natural and anthropogenic sources. It is released as part of the biological processes in low oxygen environments, such as in swamplands or in rice production (at the roots of the plants). Over the last 50 years, human activities such as growing rice, raising cattle, using natural gas, and mining coal have added to the atmospheric concentration of methane. Other anthropocentric sources include fossil-fuel combustion and biomass burning.
Nitrous Oxide (N2O)
Concentrations of N2O also began to rise at the beginning of the industrial revolution. In 1998, the global concentration of this GHG was documented at 314 parts per billion (ppb). N2O is produced by microbial processes in soil and water, including those reactions which occur in fertilizer containing nitrogen. In addition to agricultural sources, some industrial processes (fossil fuel-fired power plants, nylon production, nitric acid production, and vehicle emissions) also contribute to its atmospheric load. It is also commonly used as an aerosol spray propellant, (i.e., in whipped cream bottles, in potato chip bags to keep chips fresh, and in rocket engines and in race cars).
Chlorofluorocarbons (CFC)
CFCs are gases formed synthetically by replacing all hydrogen atoms in methane or ethane (C2H6) with chlorine and/or fluorine atoms. CFCs are nontoxic, nonflammable, insoluble, and chemically unreactive in the troposphere (the level of air at the Earth’s surface). CFCs have no natural source, but were first synthesized in 1928. It was used for refrigerants, aerosol propellants, and cleaning solvents. Due to the discovery that they are able to destroy stratospheric ozone, a global effort to halt their production was undertaken and in 1989 the European Community agreed to ban CFCs by 2000 and subsequent treaties banned CFCs worldwide by 2010. This effort was extremely successful, and the levels of the major CFCs are now remaining level or declining. However, their long atmospheric lifetimes mean that some of the CFCs will remain in the atmosphere for over 100 years.
Hydrofluorocarbons (HFC)
HFCs are synthetic man-made chemicals that are used as a substitute for CFCs. Out of all the GHGs, they are one of three groups with the highest global warming potential. The HFCs with the largest measured atmospheric abundances are (in order), HFC-23 (CHF3), HFC-134a (CF3CH2F), and HFC-152a (CH3CHF2).
Prior to 1990, the only significant emissions were HFC-23. HFC-134a use is increasing due to its use as a refrigerant. Concentrations of HFC-23 and HFC-134a in the atmosphere are now about 10 parts per trillion (ppt) each. Concentrations of HFC-152a are about 1 ppt. HFCs are manmade for applications such as automobile air conditioners and refrigerants.
Perfluorocarbons (PFC)
PFCs have stable molecular structures and do not break down through the chemical processes in the lower atmosphere. High-energy ultraviolet rays about 60 kilometers above Earth’s surface are able to destroy the compounds. Because of this, PFCs have very long lifetimes, between 10,000 and 50,000 years. Two common PFCs are tetrafluoromethane (CF4) and hexafluoroethane (C2F6). Concentrations of CF4 in the atmosphere are over 70 ppt. The two main sources of PFCs are primary aluminum production and semiconductor manufacturing.
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Sulfur Hexafluoride (SF6)
SF6 is an inorganic, odorless, colorless, nontoxic, nonflammable gas. SF6 has the highest global warming potential of any gas evaluated; 23,900 times that of CO2. Concentrations in the 1990s were about 4 ppt.
Sulfur hexafluoride is used for insulation in electric power transmission and distribution equipment, in the magnesium industry, in semiconductor manufacturing, and as a tracer gas for leak detection.
Aerosols
Aerosols are particles 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.
Cloud formation can also be affected by aerosols. Sulfate aerosols are emitted when fuel containing sulfur is burned. Black carbon (or soot) is emitted during biomass burning due to the incomplete combustion of fossil fuels. Particulate matter regulation has been lowering aerosol concentrations in the United States; however, global concentrations are likely increasing.
Global Warming Potential
The Global Warming Potential (GWP) was developed to allow comparisons of the global warming impacts of different gases. Specifically, it is a measure of how much energy the emissions of 1 ton of a gas will absorb over a given period of time, relative to the emissions of 1 ton of carbon dioxide (CO2). The larger the GWP, the more that a given gas warms the Earth compared to CO2 over that time period. The time period usually used for GWPs is 100 years. GWPs provide a common unit of measure, which allows analysts to add up emissions estimates of different gases (e.g., to compile a national GHG inventory), and allows policymakers to compare emissions reduction opportunities across sectors and gases. A summary of the atmospheric lifetime and the global warming potential of selected gases are summarized in Table 8. As shown in Table 8, the global warming potential of GHGs ranges from 1 to 22,800.
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Atmospheric Lifetime
Global Warming Potential1
(100 Year Horizon)
__ 2 1
12 28-36
114 265-298
1-270 12-14,800
2,600-50,000 7,390-12,200
740 17,200
3,200 22,800
Notes:
Source: http://www3.epa.gov/climatechange/ghgemissions/gases.html (1) Compared to the same quantity of CO2 emissions.
(2)
Table 8
Global Warming Potentials and Atmospheric Lifetimes
Carbon dioxide's lifetime is poorly defined because the gas is not destroyed over time, but instead moves among different parts of the ocean–atmosphere–land system. Some of the excess carbon dioxide will be absorbed quickly (for example, by the ocean surface), but some will remain in the atmosphere for thousands of years, due in part to the very slow process by which carbon is transferred to ocean sediments.
Gas
Carbon Dioxide (CO2)
Methane (CH4)
Nitrous Oxide (N2O)
Hydrofluorocarbons (HFCs)
Perfluorocarbons (PFCs)
Nitrogen trifluoride (NF3)
Sulfur Hexafluoride (SF6)
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GREENHOUSE GAS STANDARDS AND REGULATION
International
Montreal Protocol
In 1988, the United Nations established the Intergovernmental Panel on Climate Change (IPCC) to evaluate the impacts of global climate change and to develop strategies that nations could implement to curtail global climate change. In 1992, the United States joined other countries around the world in signing the United Nations’ Framework Convention on Climate Change (UNFCCC) agreement with the goal of controlling GHG emissions. As a result, the Climate Change Action Plan was developed to address the reduction of GHGs in the United States. The plan consists of more than 50 voluntary programs.
Additionally, the Montreal Protocol was originally signed in 1987 and substantially amended in 1990 and 1992. The Montreal Protocol stipulates that the production and consumption of compounds that deplete ozone in the stratosphere—CFCs, halons, carbon tetrachloride, and methyl chloroform—were to be phased out, with the first three by the year 2000 and methyl chloroform by 2005.
The Paris Agreement
The Paris Agreement became effective on November 4, 2016. Thirty days after this date at least 55 Parties to the United Nations Framework Convention on Climate Change (Convention), accounting in total for at least an estimated 55 % of the total global GHG emissions, had deposited their instruments of ratification, acceptance, approval or accession with the Depositary.
The Paris Agreement built upon the Convention and – for the first time – attempted to bring all nations into a common cause to undertake ambitious efforts to combat climate change and adapt to its effects, with enhanced support to assist developing countries to do so. As such, it charts a new course in the global climate effort.
The Paris Agreement’s central aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius. Additionally, the agreement aims to strengthen the ability of countries to deal with the impacts of climate change. To reach these ambitious goals, appropriate financial flows, a new technology framework and an enhanced capacity building framework will be put in place, thus supporting action by developing countries and the most vulnerable countries, in line with their own national objectives. The Agreement also provides for enhanced transparency of action and support through a more robust transparency framework.
Federal
The USEPA is responsible for implementing federal policy to address GHGs. The federal government administers a wide array of public-private partnerships to reduce the GHG intensity generated in the United States. These programs focus on energy efficiency, renewable energy, methane and other non-CO2 gases, agricultural practices, and implementation of technologies to achieve GHG reductions. The USEPA implements numerous voluntary programs that contribute to the reduction of GHG emissions. These programs (e.g., the ENERGY STAR labeling system for energy-efficient products) play a significant role in encouraging voluntary reductions from large corporations, consumers, industrial and commercial buildings, and many major industrial sectors.
In Massachusetts v. Environmental Protection Agency (Docket No. 05–1120), argued November 29, 2006 and decided April 2, 2007, the U.S. Supreme Court held that not only did the EPA have authority to regulate GHGs, but the EPA's reasons for not regulating this area did not fit the statutory requirements. As such, the 43 #8..
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U.S. Supreme Court ruled that the EPA should be required to regulate CO2 and other GHGs as pollutants under the federal Clean Air Act (CAA).
In response to the FY2008 Consolidations Appropriations Act (H.R. 2764; Public Law 110-161), EPA proposed a rule on March 10, 2009 that requires mandatory reporting of GHG emissions from large sources in the United States. On September 22, 2009, the Final Mandatory Reporting of GHG Rule was signed and published in the Federal Register on October 30, 2009. The rule became effective on December 29, 2009. This rule requires suppliers of fossil fuels or industrial GHGs, manufacturers of vehicles and engines, and facilities that emit 25,000 metric tons or more per year of GHG emissions to submit annual reports to EPA.
On December 7, 2009, the EPA Administrator signed two distinct findings under section 202(a) of the Clean Air Act. One is an endangerment finding that finds concentrations of the six GHGs in the atmosphere threaten the public health and welfare of current and future generations. The other is a cause or contribute finding, that finds emissions from new motor vehicles and new motor vehicle engines contribute to the GHG pollution which threatens public health and welfare. These actions will not themselves impose any requirements on industry or other entities. However, it is a prerequisite to finalizing the EPA’s proposed GHG emission standards for light-duty vehicles, which were jointly proposed by the EPA and Department of Transportation on September 15, 2009.
Clean Air Act
In Massachusetts v. Environmental Protection Agency (Docket No. 05–1120), the U.S. Supreme Court held in April of 2007 that the USEPA has statutory authority under Section 202 of the federal Clean Air Act (CAA) to regulate GHGs. The court did not hold that the USEPA was required to regulate GHG emissions; however, it indicated that the agency must decide whether GHGs cause or contribute to air pollution that is reasonably anticipated to endanger public health or welfare. On December 7, 2009, the USEPA Administrator signed two distinct findings regarding GHGs under Section 202(a) of the CAA. The USEPA adopted a Final Endangerment Finding for the six defined GHGs (CO2, CH4, N2O, HFCs, PFCs, and SF6) on December 7, 2009. The Endangerment Finding is required before USEPA can regulate GHG emissions under Section 202(a)(1) of the CAA consistently with the United States Supreme Court decision. The USEPA also adopted a Cause or Contribute Finding in which the USEPA Administrator found that GHG emissions from new motor vehicle and motor vehicle engines are contributing to air pollution, which is endangering public health and welfare. These findings do not, by themselves, impose any requirements on industry or other entities. However, these actions were a prerequisite for implementing GHG emissions standards for vehicles.
Energy Independence Security Act
The Energy Independence and Security Act of 2007 (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 percent greater efficiency for light bulbs by phasing out incandescent light bulbs between 2012 and 2014; requiring approximately 200 percent greater efficiency for light bulbs, or similar energy savings, by 2020; and
While superseded by the USEPA and NHTSA actions described above, (i) establishing miles per gallon targets for cars and light trucks and (ii) directing the NHTSA to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for trucks. 44 #8..
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Additional provisions of EISA address energy savings in government and public institutions, promote research for alternative energy, additional research in carbon capture, international energy programs, and the creation of green jobs.13
Executive Order 13432
In response to the Massachusetts v. Environmental Protection Agency ruling, the President signed Executive Order 13432 on May 14, 2007, directing the USEPA, along with the Departments of Transportation, Energy, and Agriculture, to initiate a regulatory process that responds to the Supreme Court’s decision. Executive Order 13432 was codified into law by the 2009 Omnibus Appropriations Law signed on February 17, 2009.
The order sets goals in the areas of energy efficiency, acquisition, renewable energy, toxics reductions, recycling, sustainable buildings, electronics stewardship, fleets, and water conservation. Light-Duty Vehicle GHG and Corporate Average Fuel Economy Standards.
On May 19, 2009, President Obama announced a national policy for fuel efficiency and emissions standards in the United States auto industry. The adopted federal standard applies to passenger cars and light-duty trucks for model years 2012 through 2016. The rule surpasses the prior Corporate Average Fuel Economy standards (CAFE)14 and requires an average fuel economy standard of 35.5 miles per gallon (mpg) and 250 grams of CO2 per mile by model year 2016, based on USEPA calculation methods. These standards were formally adopted on April 1, 2010. In August 2012, standards were adopted for model year 2017 through 2025 for passenger cars and light-duty trucks. By 2025, vehicles are required to achieve 54.5 mpg (if GHG reductions are achieved exclusively through fuel economy improvements) and 163 grams of CO2 per mile.
According to the USEPA, a model year 2025 vehicle would emit one-half of the GHG emissions from a model year 2010 vehicle.15 In 2017, the USEPA recommended no change to the GHG standards for light-duty vehicles for model years 2022-2025.
Issued by NHTSA and EPA in March 2020 (published on April 30, 2020 and effective after June 29, 2020), the Safer Affordable Fuel-Efficient Vehicles Rule would maintain the CAFE and CO2 standards applicable in model year 2020 for model years 2021 through 2026. The estimated CAFE and CO2 standards for model year 2020 are 43.7 mpg and 204 grams of CO2 per mile for passenger cars and 31.3 mpg and 284 grams of CO2 per mile for light trucks, projecting an overall industry average of 37 mpg, as compared to 46.7 mpg under the standards issued in 2012. This Rule also excludes CO2- equivalent emission improvements associated with air conditioning refrigerants and leakage (and, optionally, offsets for nitrous oxide and methane emissions) after model year 2020.16
On May 12, 2021, the National Highway Traffic Safety Administration (NHTSA) published a notice of proposed rulemaking in the Federal Register, proposing to repeal “The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National Program,” published Sept. 27, 2019 (SAFE I Rule), in which NHTSA codified regulatory text and made additional pronouncements regarding the preemption of state and local laws related to fuel economy standards. Specifically, this document proposes to fully repeal the regulatory text and appendices promulgated in the SAFE I Rule. In addition, this document proposes to repeal and withdraw the interpretative statements made by the Agency in the SAFE I Rule preamble, including those 13 A green job, as defined by the United States Department of Labor, is a job in business that produces goods or provides services that benefit the environment or conserve natural resources.
14 The Corporate Average Fuel Economy standards are regulations in the United States, first enacted by Congress in 1975, to improve the average fuel economy of cars and light trucks. The U.S Department of Transportation has delegated the National Highway Traffic Safety Administration as the regulatory agency for the Corporate Average Fuel Economy standards. 15 United States Environmental Protection Agency, EPA and NHTSA Set Standards to Reduce Greenhouse Gases and Improve Fuel Economy for Model Years 2017-2025 Cars and Light Trucks, August 2012, https://nepis.epa.gov/Exe/ZyPDF.cgi/P100EZ7C.PDF?Dockey=P100EZ7C.PDF. 16 National Highway Traffic Safety Administration (NHTSA) and U.S. Environmental Protection Agency (USEPA), 2018. Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules, The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks 2018. Available at: https://www.gpo.gov/fdsys/pkg/FR-2018-08-24/pdf/2018- 16820.pdf.
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regarding the preemption of particular state Greenhouse Gas (GHG) Emissions standards or Zero Emissions Vehicle (ZEV) mandates. As such, this document proposes to establish a clean slate with respect to NHTSA's regulations and interpretations concerning preemption under the Energy Policy and Conservation Act (EPCA).17
In December 2021, the EPA finalized federal GHG emissions standards for passenger cars and light trucks for model years 2023 through 2026. The updated standards will result in avoiding more than 3 billion tons of GHG emissions through 2050. These standards set the light-duty vehicle GHG program on track to provide a strong launch point for the agency’s next phase of standards for model year 2027 and beyond.18 On April 12, 2023, EPA announced new, more ambitious proposed standards to further reduce harmful air pollutant emissions from light-duty and medium-duty vehicles starting with model year 2027. The proposal builds upon EPA’s final standards for federal greenhouse gas emissions standards for passenger cars and light trucks for model years 2023 through 2026 and leverages advances in clean car technology to unlock benefits to Americans ranging from reducing climate pollution, to improving public health, to saving drivers money through reduced fuel and maintenance costs. The proposed standards would phase in over model years 2027 through 2032.19
State of California
California Air Resources Board
CARB, a part of the CalEPA, is responsible for the coordination and administration of both federal and state air pollution control programs within California. In this capacity, CARB conducts research, sets state ambient air quality standards (CAAQS), compiles emission inventories, develops suggested control measures, and provides oversight of local programs. CARB establishes emissions standards for motor vehicles sold in California, consumer products (such as hairspray, aerosol paints, and barbecue lighter fluid), and various types of commercial equipment. It also sets fuel specifications to further reduce vehicular emissions.
In 2004, the California Air Resources Board (CARB) adopted an Airborne Toxic Control Measure to limit heavyduty diesel motor vehicle idling in order to reduce public exposure to diesel particulate matter and other TACs (Title 13 California Code of Regulations [CCR], Section 2485). The measure applies to diesel-fueled commercial vehicles with gross vehicle weight ratings greater than 10,000 pounds that are licensed to operate on highways, regardless of where they are registered. This measure generally does not allow diesel-fueled commercial vehicles to idle for more than 5 minutes at any given location with certain exemptions for equipment in which idling is a necessary function such as concrete trucks. While this measure primarily targets diesel particulate matter emissions, it has co-benefits of minimizing GHG emissions from unnecessary truck idling.
In 2008, CARB approved the Truck and Bus regulation to reduce particulate matter and nitrogen oxide emissions from existing diesel vehicles operating in California (13 CCR, Section 2025, subsection (h)). CARB has also promulgated emission standards for off-road diesel construction equipment of greater than 25 horsepower such as bulldozers, loaders, backhoes and forklifts, as well as many other self-propelled off-road diesel vehicles. The regulation, adopted by the CARB on July 26, 2007, aims to reduce emissions by installation of diesel soot filters and encouraging the retirement, replacement, or repower of older, dirtier engines with newer emission-controlled models. While these regulations primarily target reductions in criteria air pollutant emission, they have co-benefits of minimizing GHG emissions due to improved engine efficiencies. 17 https://www.federalregister.gov/documents/2021/05/12/2021-08758/corporate-average-fuel-economy-cafe-preemption 18 United States Environmental Protection Agency (EPA), Regulations for Emissions from Vehicles and Engines, Final Rule to Revise Existing National GHG Emissions Standards for Passenger Cars and Light Trucks Through Model Year 2026. https://www.epa.gov/regulations-emissions-vehicles-and-engines/final-rule-revise-existing-national-ghg-emissions 19 United States Environmental Protection Agency (EPA), Regulations for Emissions from Vehicles and Engines, Proposed Rule: MultiPollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles. https://www.epa.gov/regulations-emissions-vehicles-and-engines/proposed-rule-multi-pollutant-emissions-standards-model 46 #8..
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The State currently has no regulations that establish ambient air quality standards for GHGs. However, the State has passed laws directing CARB to develop actions to reduce GHG emissions, which are listed below.
Assembly Bill 1493
California Assembly Bill 1493 enacted on July 22, 2002, required the CARB to develop and adopt regulations that reduce GHGs emitted by passenger vehicles and light duty trucks. In 2005, the CARB submitted a “waiver” request to the EPA from a portion of the federal Clean Air Act in order to allow the State to set more stringent tailpipe emission standards for CO2 and other GHG emissions from passenger vehicles and light duty trucks. On December 19, 2007 the EPA announced that it denied the “waiver” request. On January 21, 2009, CARB submitted a letter to the EPA administrator regarding the State’s request to reconsider the waiver denial. The EPA approved the waiver on June 30, 2009. After adopting these initial greenhouse gas standards for passenger vehicles, CARB adopted continuing standards for future model years.
Executive Order S-3-05
The California Governor issued Executive Order S-3-05, GHG Emission, in June 2005, which established the following reduction targets:
By 2010, California shall reduce GHG emissions to 2000 levels; By 2020, California shall reduce GHG emissions to 1990 levels; and By 2050, California shall reduce GHG emissions to 80 percent below 1990 levels.
The Executive Order directed the secretary of the CalEPA to coordinate a multi-agency effort to reduce GHG emissions to the target levels. To comply with the Executive Order, the secretary of CalEPA created the California Climate Action Team (CAT), made up of members from various state agencies and commissions.
The team released its first report in March 2006. The report proposed to achieve the targets by building on the voluntary actions of businesses, local governments, and communities and through State incentive and regulatory programs.
Assembly Bill 32 (California Health and Safety Code, Division 25.5 – California Global Warming Solutions Act of 2006)
In 2006, the California State Legislature adopted Assembly Bill (AB) 32 (codified in the California Health and Safety Code [HSC], Division 25.5 – California Global Warming Solutions Act of 2006), which focuses on reducing GHG emissions in California to 1990 levels by 2020. HSC Division 25.5 defines GHGs as CO2, CH4, N2O, HFCs, PFCs, and SF6 and represents the first enforceable statewide program to limit emissions of these GHGs from all major industries with penalties for noncompliance. The law further requires that reduction measures be technologically feasible and cost effective. Under HSC Division 25.5, CARB has the primary responsibility for reducing GHG emissions. CARB is required to adopt rules and regulations directing state actions that would achieve GHG emissions reductions equivalent to 1990 statewide levels by 2020.
Senate Bill 32 and Assembly Bill 197
In 2016, the California State Legislature adopted Senate Bill (SB) 32 and its companion bill AB 197, and both were signed by Governor Brown. SB 32 and AB 197 amends HSC Division 25.5 and establishes a new climate pollution reduction target of 40 percent below 1990 levels by 2030 and includes provisions to ensure the benefits of state climate policies reach into disadvantaged communities. 47 #8..
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Climate Change Scoping Plan (2008)
A specific requirement of AB 32 was to prepare a Climate Change Scoping Plan for achieving the maximum technologically feasible and cost-effective GHG emission reduction by 2020 (Health and Safety Code section 38561 (h)). CARB developed an AB 32 Scoping Plan that contains strategies to achieve the 2020 emissions cap. The initial Scoping Plan was approved in 2008, and contains 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 emission limit and initiate the transformations needed to achieve the State’s long-range climate objectives.
As required by HSC Division 25.5, CARB approved the 1990 GHG emissions inventory, thereby establishing the emissions limit for 2020. The 2020 emissions limit was originally set at 427 MMTCO2e using the GWP values from the IPCC SAR. CARB also projected the state’s 2020 GHG emissions under no-action-taken (NAT) conditions – that is, emissions that would occur without any plans, policies, or regulations to reduce GHG emissions. CARB originally used an average of the state’s GHG emissions from 2002 through 2004 and projected the 2020 levels at approximately 596 MMTCO2e (using GWP values from the IPCC SAR). Therefore, under the original projections, the state must reduce its 2020 NAT emissions by 28.4 percent in order to meet the 1990 target of 427 MMTCO2e.
First Update to the Climate Change Scoping Plan (2014)
The First Update to the Scoping Plan was approved by CARB in May 2014 and builds upon the initial Scoping Plan with new strategies and recommendations. In 2014, CARB revised the target using the GWP values from the IPCC AR4 and determined that the 1990 GHG emissions inventory and 2020 GHG emissions limit is 431 MMTCO2e. CARB also updated the State’s 2020 NAT emissions estimate to account for the effect of the 2007–2009 economic recession, new estimates for future fuel and energy demand, and the reductions required by regulation that were recently adopted for motor vehicles and renewable energy. CARB’s projected statewide 2020 emissions estimate using the GWP values from the IPCC AR4 is 509.4 MMTCO2e. 2017 Climate Change Scoping Plan
In response to the 2030 GHG reduction target, CARB adopted the 2017 Climate Change Scoping Plan at a public meeting held in December 2017. The 2017 Scoping Plan outlines the strategies the State will implement to achieve the 2030 GHG reduction target of 40 percent below 1990 levels. The 2017 Scoping Plan also addresses GHG emissions from natural and working lands of California, including the agriculture and forestry sectors. The 2017 Scoping Plan considered the Scoping Plan Scenario and four alternatives for achieving the required GHG reductions but ultimately selected the Scoping Plan Scenario.
CARB states that the Scoping Plan Scenario “is the best choice to achieve the State’s climate and clean air goals.”20 Under the Scoping Plan Scenario, the majority of the reductions would result from the continuation of the Cap-and-Trade regulation. Additional reductions are achieved from electricity sector standards (i.e., utility providers to supply at least 50 percent renewable electricity by 2030), doubling the energy efficiency savings at end uses, additional reductions from the LCFS, implementing the short-lived GHG strategy (e.g., hydrofluorocarbons), and implementing the mobile source strategy and sustainable freight action plan. The alternatives were designed to consider various combinations of these programs, as well as consideration of a carbon tax in the event the Cap-and-Trade regulation is not continued. However, in July 2017, the California Legislature voted to extend the Cap-and-Trade regulation to 2030. Implementing this Scoping Plan will ensure that California’s climate actions continue to promote innovation, drive the generation of new jobs, and achieve continued reductions of smog and air toxics. The ambitious approach draws on a decade of successful programs that address the major sources of climate-changing gases in every sector of the economy:
20 California Air Resources Board, California’s 2017 Climate Change Scoping Plan, November 2017, https://www.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf 48 #8..
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More Clean Cars and Trucks: The plan sets out far-reaching programs to incentivize the sale of millions of zero-emission vehicles, drive the deployment of zero-emission trucks, and shift to a cleaner system of handling freight statewide.
Increased Renewable Energy: California’s electric utilities are ahead of schedule meeting the requirement that 33 percent of electricity come from renewable sources by 2020. The Scoping Plan guides utilities to 50 percent renewables, as required under SB 350.
Slashing Super-Pollutants: The plan calls for a significant cut in super-pollutants such as methane and HFC refrigerants, which are responsible for as much as 40 percent of global warming. Cleaner Industry and Electricity: California’s renewed cap-and-trade program extends the declining cap on emissions from utilities and industries and the carbon allowance auctions. The auctions will continue to fund investments in clean energy and efficiency, particularly in disadvantaged communities. Cleaner Fuels: The Low Carbon Fuel Standard will drive further development of cleaner, renewable transportation fuels to replace fossil fuels.
Smart Community Planning: Local communities will continue developing plans which will further link transportation and housing policies to create sustainable communities. Improved Agriculture and Forests: The Scoping Plan also outlines innovative programs to account for and reduce emissions from agriculture, as well as forests and other natural lands.
The 2017 Scoping Plan also evaluates reductions of smog-causing pollutants through California’s climate programs.
2022 Climate Change Scoping Plan
CARB adopted the 2022 Scoping Plan for Achieving Carbon Neutrality on November 16, 2022. The 2022 Scoping Plan lays out the sector-by-sector roadmap for California, the world’s fifth largest economy, to achieve carbon neutrality by 2045 or earlier, outlining a technologically feasible, cost-effective, and equity-focused path to achieve the state’s climate target. The Plan addresses recent legislation and direction from Governor Newsom and extends and expands upon earlier plans with a target of reducing anthropogenic emissions to 85 percent below 1990 levels by 2045. The plan also takes the unprecedented step of adding carbon neutrality as a science-based guide and touchstone for California’s climate work. Specifically, this plan:
Identifies a path to keep California on track to meet its SB 32 GHG reduction target of at least 40 percent below 1990 emissions by 2030.
Identifies a technologically feasible, cost-effective path to achieve carbon neutrality by 2045 and a reduction in anthropogenic emissions by 85 percent below 1990 levels. Focuses on strategies for reducing California’s dependency on petroleum to provide consumers with clean energy options that address climate change, improve air quality, and support economic growth and clean sector jobs.
Integrates equity and protecting California’s most impacted communities as driving principles throughout the document.
Incorporates the contribution of natural and working lands (NWL) to the state’s GHG emissions, as well as their role in achieving carbon neutrality.
Relies on the most up-to-date science, including the need to deploy all viable tools to address the existential threat that climate change presents, including carbon capture and sequestration, as well as direct air capture.
Evaluates the substantial health and economic benefits of taking action. Identifies key implementation actions to ensure success.
SB 32, Pavley. California Global Warming Solutions Act of 2006 (1) The California Global Warming Solutions Act of 2006 designates the State Air Resources Board as the state agency charged with monitoring and regulating sources of emissions of greenhouse gases. The state 49 #8..
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board is required to approve a statewide greenhouse gas emissions limit equivalent to the statewide greenhouse gas emissions level in 1990 to be achieved by 2020 and to adopt rules and regulations in an open public process to achieve the maximum, technologically feasible, and cost-effective greenhouse gas emissions reductions. This bill would require the state board to ensure that statewide greenhouse gas emissions are reduced to 40% below the 1990 level by 2030. (2) This bill would become operative only if AB 197 of the 2015–16 Regular Session is enacted and becomes effective on or before January 1, 2017. AB 197 requires that the California Air Resources Board, which directs implementation of emission-reduction programs, should target direct reductions at both stationary and mobile sources. AB 197 of the 2015-2016 Regular Session was approved on September 8, 2016.
Senate Bill 1368
Senate Bill 1368 (SB 1368) is the companion Bill of AB 32 and was adopted September, 2006. SB 1368 requires the California Public Utilities Commission (CPUC) to establish a performance standard for baseload generation of GHG emissions by investor-owned utilities by February 1, 2007, and for local publicly owned utilities by June 30, 2007. These standards could not exceed the GHG emissions rate from a baseload combined-cycle, natural gas-fired plant. Furthermore, the legislation states that all electricity provided to the State, including imported electricity, must be generated by plants that meet the standards set by California Public Utilities Commission (CPUC) and California Energy Commission (CEC).
Executive Order S-1-07
Executive Order S-1-07 was issued in 2007 and proclaims that the transportation sector is the main source of GHG emissions in the State, since it generates more than 40 percent of the State’s GHG emissions. It establishes a goal to reduce the carbon intensity of transportation fuels sold in the State by at least ten percent by 2020. This Order also directs the CARB to determine whether this Low Carbon Fuel Standard (LCFS) could be adopted as a discrete early-action measure as part of the effort to meet the mandates in AB 32.
On April 23, 2009 CARB approved the proposed regulation to implement the low carbon fuel standard and began implementation on January 1, 2011. The low carbon fuel standard is anticipated to reduce GHG emissions by about 16 MMT per year by 2020. CARB approved some amendments to the LCFS in December 2011, which were implemented on January 1, 2013. In September 2015, the Board approved the re-adoption of the LCFS, which became effective on January 1, 2016, to address procedural deficiencies in the way the original regulation was adopted. In 2018, the Board approved amendments to the regulation, which included strengthening and smoothing the carbon intensity benchmarks through 2030 in-line with California's 2030 GHG emission reduction target enacted through SB 32, adding new crediting opportunities to promote zero emission vehicle adoption, alternative jet fuel, carbon capture and sequestration, and advanced technologies to achieve deep decarbonization in the transportation sector.
The LCFS is designed to encourage the use of cleaner low-carbon transportation fuels in California, encourage the production of those fuels, and therefore, reduce GHG emissions and decrease petroleum dependence in the transportation sector. Separate standards are established for gasoline and diesel fuels and the alternative fuels that can replace each. The standards are “back-loaded”, with more reductions required in the last five years, than during the first five years. This schedule allows for the development of advanced fuels that are lower in carbon than today’s fuels and the market penetration of plug-in hybrid electric vehicles, battery electric vehicles, fuel cell vehicles, and flexible fuel vehicles. It is anticipated that compliance with the low carbon fuel standard will be based on a combination of both lower carbon fuels and more efficient vehicles.
Reformulated gasoline mixed with corn-derived ethanol at ten percent by volume and low sulfur diesel fuel represent the baseline fuels. Lower carbon fuels may be ethanol, biodiesel, renewable diesel, or blends of these fuels with gasoline or diesel as appropriate. Compressed natural gas and liquefied natural gas also may be low carbon fuels. Hydrogen and electricity, when used in fuel cells or electric vehicles are also considered as low carbon fuels for the low carbon fuel standard.
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Senate Bill 97
Senate Bill 97 (SB 97) was adopted August 2007 and acknowledges that climate change is a prominent environmental issue that requires analysis under CEQA. SB 97 directed the Governor’s Office of Planning and Research (OPR), which is part of the State Natural Resources Agency, to prepare, develop, and transmit to the CARB guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions, as required by CEQA, by July 1, 2009. The Natural Resources Agency was required to certify and adopt those guidelines by January 1, 2010.
Pursuant to the requirements of SB 97 as stated above, on December 30, 2009, the Natural Resources Agency adopted amendments to the state CEQA guidelines that address GHG emissions. The CEQA Guidelines Amendments changed 14 sections of the CEQA Guidelines and incorporate GHG language throughout the Guidelines. However, no GHG emissions thresholds of significance were provided and no specific mitigation measures were identified. The GHG emission reduction amendments went into effect on March 18, 2010, and are summarized below:
Climate action plans and other greenhouse gas reduction plans can be used to determine whether a project has significant impacts, based upon its compliance with the plan. Local governments are encouraged to quantify the greenhouse gas emissions of proposed projects, noting that they have the freedom to select the models and methodologies that best meet their needs and circumstances. The section also recommends consideration of several qualitative factors that may be used in the determination of significance, such as the extent to which the given project complies with state, regional, or local GHG reduction plans and policies. OPR does not set or dictate specific thresholds of significance. Consistent with existing CEQA Guidelines, OPR encourages local governments to develop and publish their own thresholds of significance for GHG impacts assessment. When creating their own thresholds of significance, local governments may consider the thresholds of significance adopted or recommended by other public agencies, or recommended by experts. New amendments include guidelines for determining methods to mitigate the effects of greenhouse gas emissions in Appendix F of the CEQA Guidelines.
OPR is clear to state that “to qualify as mitigation, specific measures from an existing plan must be identified and incorporated into the project; general compliance with a plan, by itself, is not mitigation”. OPR’s emphasizes the advantages of analyzing GHG impacts on an institutional, programmatic level. OPR therefore approves tiering of environmental analyses and highlights some benefits of such an approach. Environmental impact reports (EIRs) must specifically consider a project's energy use and energy efficiency potential.
Senate Bill 100
Senate Bill 100 (SB 100) requires 100 percent of total retail sales of electricity in California to come from eligible renewable energy resources and zero-carbon resources by December 31, 2045. SB 100 was adopted September 2018.
The interim thresholds from prior Senate Bills and Executive Orders would also remain in effect. These include Senate Bill 1078 (SB 1078), which requires retail sellers of electricity, including investor-owned utilities and community choice aggregators, to provide at least 20 percent of their supply from renewable sources by 2017. Senate Bill 107 (SB 107) which changed the target date to 2010. Executive Order S-14-08, which was signed on November 2008 and expanded the State’s Renewable Energy Standard to 33 percent renewable energy by 2020. Executive Order S-21-09 directed the CARB to adopt regulations by July 31, 2010 to enforce S-14-08. Senate Bill X1-2 codifies the 33 percent renewable energy requirement by 2020. 51 #8..
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Senate Bill 375
Senate Bill 375 (SB 375) was adopted September 2008 and aligns regional transportation planning efforts, regional GHG emission reduction targets, and land use and housing allocation. SB 375 requires Metropolitan Planning Organizations (MPO) to adopt a sustainable communities strategy (SCS) or alternate planning strategy (APS) that will prescribe land use allocation in that MPOs Regional Transportation Plan (RTP). The CARB, in consultation with each MPO, will provide each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 2020 and 2035. These reduction targets will be updated every eight years but can be updated every four years if advancements in emissions technologies affect the reduction strategies to achieve the targets. The CARB is also charged with reviewing each MPO’s sustainable communities strategy or alternate planning strategy for consistency with its assigned targets.
The proposed project is located within the SCAG jurisdiction, which has authority to develop the SCS or APS.
For the SCAG region, the targets set by the CARB are at eight percent below 2005 per capita GHG emissions levels by 2020 and 19 percent below 2005 per capita GHG emissions levels by 2035. These reduction targets became effective October 2018.
Senate Bill X7-7
Senate Bill X7-7 (SB X7-7), enacted on November 9, 2009, mandates water conservation targets and efficiency improvements for urban and agricultural water suppliers. SB X7-7 requires the Department of Water Resources (DWR) to develop a task force and technical panel to develop alternative best management practices for the water sector. In addition, SB X7-7 required the DWR to develop criteria for baseline uses for residential, commercial, and industrial uses for both indoor and landscaped area uses. The DWR was also required to develop targets and regulations that achieve a statewide 20 percent reduction in water usage.
Assembly Bill 939 and Senate Bill 1374
Assembly Bill 939 (AB 939) requires that each jurisdiction in California to divert at least 50 percent of its waste away from landfills, whether through waste reduction, recycling or other means. Senate Bill 1374 (SB 1374) requires the California Integrated Waste Management Board to adopt a model ordinance by March 1, 2004, suitable for adoption by any local agency to require 50 to 75 percent diversion of construction and demolition of waste materials from landfills.
California Code of Regulations (CCR) Title 24, Part 6
CCR Title 24, Part 6: California’s Energy Efficiency Standards for Residential and Nonresidential Buildings (Title 24) were first established in 1978 in response to a legislative mandate to reduce California’s energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy efficiency technologies and methods. Although it was not originally intended to reduce GHG emissions, electricity production by fossil fuels results in GHG emissions and energy efficient buildings require less electricity. Therefore, increased energy efficiency results in decreased GHG emissions.
The Energy Commission adopted 2008 Standards on April 23, 2008, and Building Standards Commission approved them for publication on September 11, 2008. These updates became effective on August 1, 2009.
CalEEMod modeling defaults to 2008 standards. 2013 Standards were approved and have been effective since July 1, 2014. 2016 Standards were adopted January 1, 2017. 2019 standards were published July 1, 2019 and became effective January 1, 2020. All buildings for which an application for a building permit is submitted on or after January 1, 2020 must follow the 2019 standards. The 2016 residential standards were estimated to be approximately 28 percent more efficient than the 2013 standards, whereas the 2019 residential standards are estimated to be approximately 7 percent more efficient than the 2016 standards.
Furthermore, once rooftop solar electricity generation is factored in, 2019 residential standards are estimated to be approximately 53 percent more efficient than the 2016 standards. Under the 2019 standards, nonresidential buildings are estimated to be approximately 30 percent more efficient than the 2016 standards. 52 #8..
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Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions.
Per Section 100 Scope, the 2019 Title 24, Part 6 Building Code now requires healthcare facilities, such as assisted living facilities, hospitals, and nursing homes, to meet documentation requirements of Title 24, Part 1 Chapter 7 – Safety Standards for Health Facilities. A healthcare facility is defined as any building or portion thereof licensed pursuant to California Health and Safety Code Division 2, Chapter 1, Section 1204 or Chapter 2, Section 1250.
Section 120.1 Ventilation and Indoor Air Quality included both additions and revisions in the 2019 Code. This section now requires nonresidential and hotel/motel buildings to have air filtration systems that use forced air ducts to supply air to occupiable spaces to have air filters. Further, the air filter efficiency must be either MERV 13 or use a particle size efficiency rating specific in the Energy Code AND be equipped with air filters with a minimum 2-inch depth or minimum 1-inch depth if sized according to the equation 120.1-A. If natural ventilation is to be used the space must also use mechanical unless ventilation openings are either permanently open or controlled to stay open during occupied times. The 2019 version of the Code also completely revised the minimum ventilation requirements including DVC airflow rates within Section 120.1 Table 120.1–A. Table 120.1-A now includes air classification and recirculation limitations, these are based on either the number of occupants or the CFM/ft2 (cubic feet per minute per square foot), whichever is greater.
Section 120.1 Ventilation and Indoor Air Quality also included additions for high-rise residential buildings.
Requirements include that mechanical systems must provide air filters that and that air filters must be MERV 13 or use a particle size efficiency rating specified in the Energy Code. Window operation is no longer a method allowed to meet ventilation requirements, continuous operation of central forced air system handlers used in central fan integrated ventilation system is not a permissible method of providing the dwelling unit ventilation airflow, and central ventilation systems that serve multiple dwelling units must be balanced to provide ventilation airflow to each dwelling unit. In addition, requirements for kitchen range hoods were also provided in the updated Section 120.1.
Per Section 120.1(a) healthcare facilities must be ventilated in accordance with Chapter 4 of the California Mechanical Code and are NOT required to meet the ventilations requirements of Title 24, Part 6.
Section 140.4 Space Conditioning Systems included both additions and revisions within the 2019 Code. The changes provided new requirements for cooling tower efficiency, new chilled water-cooling system requirements, as well as new formulas for calculating allowed fan power. Section 140.4(n) also provide a new exception for mechanical system shut-offs for high-rise multifamily dwelling units, while Section 140.4(o) added new requirements for conditioned supply air being delivered to space with mechanical exhaust.
Section 120.6 Covered Processes added information in regards to adiabatic chiller requirements that included that all condenser fans for air-cooled converseness, evaporative-cooled condensers, adiabatic condensers, gas coolers, air or water fluid coolers or cooling towers must be continuously variable speed, with the speed of all fans serving a common condenser high side controlled in unison .Further, the mid-condensing setpoint must be 70 degrees Fahrenheit for all of the above mentioned systems.
New regulations were also adopted under Section 130.1 Indoor Lighting Controls. These included new exceptions being added for restrooms, the exception for classrooms being removed, as well as exceptions in regard to sunlight provided through skylights and overhangs.
Section 130.2 Outdoor Lighting Controls and Equipment added automatic scheduling controls which included that outdoor lighting power must be reduced by 50 to 90 percent, turn the lighting off during unoccupied times and have at least two scheduling options for each luminaire independent from each other and with a 2- hour override function. Furthermore, motion sensing controls must have the ability to reduce power within 15 minutes of area being vacant and be able to come back on again when occupied. An exception allows for lighting subject to a health or life safety statute, ordinance, or regulation may have a minimum time-out period 53 #8..
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longer than 15 minutes or a minimum dimming level above 50% when necessary to comply with the applicable law.
The 2022 Building Energy Efficiency Standards will become effective on January 1, 2023. 21 The core focus of the building standards has been efficiency, but the 2019 Energy Code ventured into onsite generation by requiring solar PV on new homes, providing significant GHG savings. The 2022 update builds off this progress with expanded solar standards and the move to onsite energy storage that will help Californians save on utility bills while bolstering the grid. The 2022 Energy Code update focuses on four key areas in new construction of homes and businesses:
Encouraging electric heat pump technology and use, which consumes less energy and produces fewer emissions than traditional HVACs and water heaters.
Establishing electric-ready requirements when natural gas is installed, which positions 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 percent clean electricity grid. Strengthening ventilation standards to improve indoor air quality.
The 2022 Energy Code affects homes by establishing energy budgets based on efficient heat pumps for space or water heating to encourage builders to install heat pumps over gas-fueled HVAC units; requiring homes to be electric-ready, with dedicated 240-volt outlets and space (with plumbing for water heaters) so electric appliances can eventually replace installed gas appliances; increasing minimum kitchen ventilation requirements so that fans over cooktops have higher airflow or capture efficiency to better exhaust pollution from gas cooking and improve indoor air quality; and allowing exceptions to existing solar PV standards when roof area is not available (such as for smaller homes). In addition, the effect on businesses includes establishing combined solar PV and battery standards for select businesses with systems being sized to maximize onsite use of solar energy and avoid electricity demand during times when the grid must use gas-powered plants; establishing new efficiency standards for commercial greenhouses (primarily cannabis growing); and improving efficiency standards for building envelope, various internal systems, and grid integration equipment, such as demand-responsive controls to buoy grid stability.22,23 California Code of Regulations (CCR) Title 24, Part 11 (California Green Building Standards) On January 12, 2010, the State Building Standards Commission unanimously adopted updates to the California Green Building Standards Code, which went into effect on January 1, 2011. The 2016 version of the California Green Building Standards became effective January 1, 2017. 2016 CALGreen Code: The 2016 residential standards were estimated to be approximately 28 percent more efficient than the 2013 standards. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions. During the 2016-2017 fiscal year, the Department of Housing and Community Development (HCD) updated CALGreen through the 2015 Triennial Code Adoption Cycle.
HCD also increased the required construction waste reduction from 50 percent to 65 percent of the total building site waste. This increase aids in meeting CalRecycle’s statewide solid waste recycling goal of 75 percent for 2020 as stated in Chapter 476, Statutes of 2011 (AB 341). HCD adopted new regulations requiring recycling areas for multifamily projects of five or more dwelling units. This regulation requires 21 California Energy Commission (CEC). 2022. Building Energy Efficiency Standards. https://www.energy.ca.gov/programs-andtopics/programs/building-energy-efficiency-standards/2022-building-energy-efficiency. 22 https://www.lightnowblog.com/2021/08/california-energy-commission-adopts-2022-building-energy-efficiency-standards/ 23 State of California Energy Commission. 2022 Building Energy Efficiency Standards Summary. https://www.energy.ca.gov/sites/default/files/2021-08/CEC_2022_EnergyCodeUpdateSummary_ADA.pdf 54 #8..
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developers to provide readily accessible areas adequate in size to accommodate containers for depositing, storage and collection of non-hazardous materials (including organic waste) for recycling. This requirement assists businesses that were required as of April 1, 2016, to meet the requirements of Chapter 727, Statutes of 2014 (AB 1826).
HCD adopted new regulations to require information on photovoltaic systems and electric vehicle chargers to be included in operation and maintenance manuals. Currently, CALGreen section 4.410.1 Item 2(a) requires operation and maintenance instructions for equipment and appliances. Photovoltaic systems and electric vehicle chargers are systems that play an important role in many households in California, and their importance is increasing every day. HCD incorporated these two terms in the existing language in order to provide clarity to code users as to additional systems requiring operation and maintenance instructions.
HCD updated the reference to Clean Air Standards of the USEPA applicable to woodstoves and pellet stoves.
HCD also adopted a new requirement for woodstoves and pellet stoves to have a permanent label indicating they are certified to meet the emission limits. This requirement provides clarity to the code user and is consistent with the USEPA’s New Source Performance Standards. HCD updated the list of standards which can be used for verification of compliance for exterior grade composite wood products. This list now includes four standards from the Canadian Standards Association (CSA): CSA O121, CSA O151, CSA O153 and CSA O325. HCD updated heating and air-conditioning system design references to the ANSI/ACCA 2 Manual J, ANSI/ACCA 1 Manual D, and ANSI/ACCA 3 Manual S to the most recent versions approved by ANSI. HCD adopted a new elective measure for hot water recirculation systems for water conservation. The United States Department of Energy estimates that 3,600 to 12,000 gallons of water per year can be saved by the typical household (with four points of hot water use) if a hot water recirculation system is installed. 2019 CALGreen Code: During the 2019-2020 fiscal year, the Department of Housing and Community Development (HCD) updated CALGreen through the 2019 Triennial Code Adoption Cycle. The 2019 version of the California Green Building Standards became effective January 1, 2020.
HCD modified the best management practices for stormwater pollution prevention adding Section 5.106.2 for projects that disturb one or more acres of land. This section requires projects that disturb one acre or more of land or less than one acre of land but are part of a larger common plan of development or sale must comply with the postconstruction requirement detailed in the applicable National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities issued by the State Water Resources Control Board. The NPDES permits require postconstruction runoff (post-project hydrology) to match the preconstruction runoff pre-project hydrology) with installation of postconstruction stormwater management measures.
HCD added sections 5.106.4.1.3 and 5.106.4.1.5 in regard to bicycle parking. Section 5.106.4.1.3 requires new buildings with tenant spaces that have 10 or more tenant-occupants, provide secure bicycle parking for 5 percent of the tenant-occupant vehicular parking spaces with a minimum of one bicycle parking facility. In addition, Section 5.106.4.1.5 states that acceptable bicycle parking facility for Sections 5.106.4.1.2 through
5.106.4.1.4 shall be convenient from the street and shall meeting one of the following: (1) covered, lockable enclosures with permanently anchored racks for bicycles; (2) lockable bicycle rooms with permanently anchored racks; or (3) lockable, permanently anchored bicycle lockers.
HCD amended section 5.106.5.3.5 allowing future charging spaces to qualify as designated parking for clean air vehicles.
HCD updated section 5.303.3.3 in regard to showerhead flow rates. This update reduced the flow rate to 1.8 GPM.
HCD amended section 5.304.1 for outdoor potable water use in landscape areas and repealed sections
5.304.2 and 5.304.3. The update requires nonresidential developments to comply with a local water efficient landscape ordinance or the current California Department of Water Resource’s’ Model Water Efficient 55 #8..
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Landscape Ordinance (MWELO), whichever is more stringent. Some updates were also made in regard to the outdoor potable water use in landscape areas for public schools and community colleges.
HCD updated Section 5.504.5.3 in regard to the use of MERV filters in mechanically ventilated buildings. This update changed the filter use from MERV 8 to MERV 13. MERV 13 filters are to be installed prior to occupancy, and recommendations for maintenance with filters of the same value shall be included in the operation and maintenance manual.
The 2022 California Green Building Standards Code became effective on January 1, 2023.24 In the 2022 version of the Code, HCD amended Section 5.106.5.3 in regard to increasing the EV capable space percentages and adding a new requirement for installed Level 2 DCFC chargers.
HCD under Section 5.106.5.4 added new regulation for electric vehicle charging readiness requirements for new construction of warehouse, grocery stores, and retail stores with planned off-street loading spaces. 25 However, as this project does not propose any buildings, building efficiency regulations would not be applicable
Executive Order B-30-15
On April 29, 2015, Governor Brown issued Executive Order B-30-15. Therein, the Governor directed the following:
Established a new interim statewide reduction target to reduce GHG emissions to 40 percent below 1990 levels by 2030.
Ordered all state agencies with jurisdiction over sources of GHG emissions to implement measures to achieve reductions of GHG emissions to meet the 2030 and 2050 reduction targets. Directed CARB to update the Climate Change Scoping Plan to express the 2030 target in terms of million metric tons of carbon dioxide equivalent.
Executive Order B-29-15
Executive Order B-29-15, mandates a statewide 25 percent reduction in potable water usage. EO B-29-15 signed into law on April 1, 2015.
Executive Order B-37-16
Executive Order B-37-16, continuing the State's adopted water reductions, was signed into law on May 9, 2016. The water reductions build off the mandatory 25 percent reduction called for in EO B-29-15.
Executive Order N-79-20
Executive Order N-79-20 Signed in September 2020, Executive Order N-79-20 establishes as a goal that where feasible, all new passenger cars and trucks, as well as all drayage/cargo trucks and off-road vehicles and equipment, sold in California, will be zero-emission by 2035. The executive order sets a similar goal requiring that all medium and heavy-duty vehicles will be zero-emission by 2045 where feasible. It also directs CARB to develop and propose rulemaking for passenger vehicles and trucks, medium-and heavy-duty fleets where feasible, drayage trucks, and off-road vehicles and equipment “requiring increasing volumes” of new zero emission vehicles (ZEVs) “towards the target of 100 percent.” The executive order directs the California 24 California Building Standards Commission (CBSC). 2022. California Green Building Standards.
Website: https://codes.iccsafe.org/content/CAGBC2022P1. 25 https://www.dgs.ca.gov/BSC/Resources/2022-Title-24-California-Code-Changes 56 #8..
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Environmental Protection Agency, the California Geologic Energy Management Division (CalGEM), and the California Natural Resources Agency to transition and repurpose oil production facilities with a goal toward meeting carbon neutrality by 2045. Executive Order N-79-20 builds upon the CARB Advanced Clean Trucks regulation, which was adopted by CARB in July 2020.
SBX1 2
Signed into law in April 2011, SBX1 2, requires one-third of the State’s electricity to come from renewable sources. The legislation increases California’s current 20 percent renewables portfolio standard target in 2010 to a 33 percent renewables portfolio standard by December 31, 2020.
Senate Bill 350
Signed into law October 7, 2015, SB 350 increases California’s renewable electricity procurement goal from 33 percent by 2020 to 50 percent by 2030. This will increase the use of Renewables Portfolio Standard (RPS) eligible resources, including solar, wind, biomass, geothermal, and others. In addition, SB 350 requires the state to double statewide energy efficiency savings in electricity and natural gas end uses by 2030. To help ensure these goals are met and the greenhouse gas emission reductions are realized, large utilities will be required to develop and submit Integrated Resource Plans (IRPs). These IRPs will detail how each entity will meet their customers resource needs, reduce greenhouse gas emissions and ramp up the deployment of clean energy resources.
Governor Newsom’s September 2022 Climate Legislation
On September 16, 2022, California enacted some of the nation’s most aggressive climate measures in history as Governor Gavin Newsom signed a sweeping package of legislation to cut pollution, protect Californians from big polluters, and accelerate the state’s transition to clean energy. The Governor partnered with legislative leaders to advance groundbreaking measures to achieve carbon neutrality no later than 2045 and 90 percent clean energy by 2035, establish new setback measures protecting communities from oil drilling, capture carbon pollution from the air, advance nature-based solutions, and more.
Over the next two decades, the California Climate Commitment will:
Create 4 million new jobs
Cut air pollution by 60 percent
Reduce state oil consumption by 91 percent
Save California $23 billion by avoiding the damages of pollution Reduce fossil fuel use in buildings and transportation by 92 percent Cut refinery pollution by 94 percent26
The following describes a few of the many bills signed in through the Governor’s climate package.
Assembly Bill 1279
Establishes a clear, legally binding, and achievable goal for California to achieve statewide carbon neutrality as soon as possible, and no later than 2045, and establishes an 85% emissions reduction target as part of that goal.
26 https://www.gov.ca.gov/2022/09/16/governor-newsom-signs-sweeping-climate-measures-ushering-in-new-era-of-world-leadingclimate-action/ 57 #8..
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Senate Bill 1137
Establishes a setback distance of 3,200 feet between any new oil well and homes, schools, parks or businesses open to the public. Ensures comprehensive pollution controls for existing oil wells within 3,200 feet of these facilities.
Senate Bill 1020
Creates clean electricity targets of 90 percent by 2035 and 95 percent by 2040 with the intent of advancing the state’s trajectory to the existing 100 percent clean electricity retail sales by 2045 goal.
Senate Bill 905
Establishes a clear regulatory framework for carbon removal and carbon capture, utilization and sequestration.
Bans the practice of injecting carbon dioxide for the purpose of enhanced oil recovery.
Assembly Bill 1757
Requires the state to develop an achievable carbon removal target for natural and working lands.
Energy Sector and CEQA Guidelines Appendix F
The CEC first adopted Energy Efficiency Standards for Residential and Nonresidential Buildings (CCR, Title 24, Part 6) in 1978 in response to a legislative mandate to reduce energy consumption in the state. Although not originally intended to reduce GHG emissions, increased energy efficiency and reduced consumption of electricity, natural gas, and other fuels would result in fewer GHG emissions from residential and nonresidential buildings subject to the standard. The standards are updated periodically (typically every three years) to allow for the consideration and inclusion of new energy efficiency technologies and methods. The 2016 update to the Energy Efficiency Standards for Residential and Nonresidential Buildings focuses on several key areas to improve the energy efficiency of renovations and addition to existing buildings as well as newly constructed buildings and renovations and additions to existing buildings. The major efficiency improvements to the residential Standards involve improvements for attics, walls, water heating, and lighting, whereas the major efficiency improvements to the nonresidential Standards include alignment with the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) 90.1-2013 national standards. Furthermore, the 2016 update required that enforcement agencies determine compliance with CCR, Title 24, Part 6 before issuing building permits for any construction.27 Part 11 of the Title 24 Building Energy Efficiency Standards is referred to as the California Green Building Standards (CALGreen) Code. The purpose of the CALGreen Code is to “improve public health, safety and general welfare by enhancing the design and construction of buildings through the use of building concepts having a reduced negative impact or positive environmental impact and encouraging sustainable construction practices in the following categories: (1) Planning and design; (2) Energy efficiency; (3) Water efficiency and conservation; (4) Material conservation and resource efficiency; and (5) Environmental air quality.”28 As of January 1, 2011, the CALGreen Code is mandatory for all new buildings constructed in the state. The CALGreen Code establishes mandatory measures for new residential and non-residential buildings. Such mandatory measures include energy efficiency, water conservation, material conservation, planning and design, and overall environmental quality. The CALGreen Code was most recently updated in 2022 to include new mandatory measures for residential and nonresidential uses; the new measures took effect on January 1, 2023.
27 California Energy Commission, 2016 Building Energy Efficiency Standards, June 2015, http://www.energy.ca.gov/2015publications/CEC-400-2015-037/CEC-400-2015-037-CMF.pdf 28 California Building Standards Commission, 2010 California Green Building Standards Code, (2010). 58 #8..
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Regional – San Joaquin Valley Air Pollution Control District The project is within the San Joaquin Valley Air Basin, which is under the jurisdiction of SJVAPCD. The SJVAPCD has adopted the Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (December 17, 2009), the District Policy – Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA When Serving as the Lead Agency (December 17, 2009), and the Final Staff Report Addressing Greenhouse Gas Emissions Impacts Under the California Environmental Quality Act (December 17, 2009).29
Per these guidelines, the SJVAPCD has determined the process for evaluating GHG significance is as follows:
Projects determined to be exempt from the requirements of CEQA would be determined to have a less than significant individual and cumulative impact for GHG emissions and would not require further environmental review, including analysis of project specific GHG emissions. Projects exempt under CEQA would be evaluated consistent with established rules and regulations governing project approval and would not be required to implement BPS.
Projects complying with an approved GHG emission reduction plan or GHG mitigation program which avoids or substantially reduces GHG emissions within the geographic area in which the project is located would be determined to have a less than significant individual and cumulative impact for GHG emissions.
Such plans or programs must be specified in law or approved by the lead agency with jurisdiction over the affected resource and supported by a CEQA compliant environmental review document adopted by the Final Staff Report -Climate Change Action Plan: Addressing GHG Emissions Impacts under CEQA SJVAPCD December 17, 2009, 66 lead agency. Projects complying with an approved GHG emission reduction plan or GHG mitigation program would not be required to implement BPS. Projects implementing Best Performance Standards would not require quantification of project specific GHG emissions. Consistent with CEQA Guideline, such projects would be determined to have a less than significant individual and cumulative impact for GHG emissions. Projects not implementing Best Performance Standards would require quantification of project specific GHG emissions and demonstration that project specific GHG emissions would be reduced or mitigated by at least 29%, compared to BAU, including GHG emission reductions achieved since the 2002-2004 baseline period. Projects achieving at least a 29% GHG emission reduction compared to BAU, consistent with GHG emission reduction targets established in ARB’s AB 32 Scoping Plan, would be determined to have a less than significant individual and cumulative impact for GHG. Projects requiring preparation of an Environmental Impact Report would require quantification of project specific GHG emissions. Projects implementing BPS or achieving at least a 29 percent GHG emission reduction compared to BAU would be determined to have a less than significant individual and cumulative impact for GHG.
Local – City of Modesto
The City of Modesto does not currently have a Climate Action Plan (CAP). 29 https://ww2.valleyair.org/permitting/climate-change-action-plan/ 59 #8..
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SIGNIFICANCE THRESHOLDS
Appendix G of State CEQA Guidelines
The CEQA Guidelines recommend that a lead agency consider the following when assessing the significance of impacts from GHG emissions on the environment:
The extent to which the 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;
The extent to which the project complies with regulations or requirements adopted to implement an adopted statewide, regional, or local plan for the reduction or mitigation of GHG emissions.30 Thresholds of Significance for this Project
As shown above, the SJVAPCD does not have an adopted threshold of significance for GHG emissions; however, the SJVAPCD has adopted the Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (December 17, 2009) and District Policy – Addressing GHG Emission Impacts for Stationary Source Projects Under CEQA When Serving as the Lead Agency (December 17, 2009). As stated in these guidance documents, projects complying with an approved GHG emissions reduction plan or GHG mitigation program which avoids or substantially reduces GHG emissions within the geographic area in which the project is located would be determined to have a less than significant individual and cumulative impact for GHG emissions.
METHODOLOGY
The proposed project is that of the installation of approximately 12,000 linear feet of 12-inch diameter pipe.
Therefore, the proposed project has the potential to generate GHG emissions from mobile sources and construction equipment. However, it should be noted that mobile sources were not included in the analysis as additional staffing needs for long-term operation and maintenance of the proposed project are not anticipated and only a minimal number of daily worker trips will be needed for routine inspections and maintenance. Therefore, additional vehicle trips and emissions associated with the operation of the proposed project would be negligible.
CalEEMod Version 2022.1.1.28 was used to calculate the GHG emissions from the construction of the proposed project. The construction-related GHG emissions were included in the analysis and were based on a 30-year amortization rate. The construction related GHG emissions were calculated by CalEEMod and in the manner detailed above in Section 2. The CalEEMod Output is available in Appendix B.
PROJECT GREENHOUSE GAS EMISSIONS
The GHG emissions have been calculated based on the parameters described above. A summary of the results is shown below in Table 9 and the CalEEMod Model run for the proposed project is provided in Appendix B.
Table 9 shows that the greenhouse emissions for the proposed project (without credit for any reductions from sustainable design, and/or regulatory requirements) would be 23.1 MTCO2e (amortized over 30-years) for project construction.
30 The Governor’s Office of Planning and Research recommendations include a requirement that such a plan must be adopted through a public review process and include specific requirements that reduce or mitigate the project’s incremental contribution of GHG emissions. If there is substantial evidence that the possible effects of a particular project are still cumulatively considerable, notwithstanding compliance with the adopted regulations or requirements, an EIR must be prepared for the project. 60 #8..
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Bio-CO2 NonBio-CO2 CO2 CH4 N2O CO2e
0.00 23.00 23.00 0.00 0.00 23.10
0.00 23.00 23.00 0.00 0.00 23.10
Notes:
Source: CalEEMod Version 2022.1.1.28 for Opening Year 2025. (1) Construction GHG emissions CO2e based on a 30-year amortization rate.
Total Emissions
Construction1,2
Table 9
Project-Related Greenhouse Gas Emissions
Category
Greenhouse Gas Emissions (Metric Tons/Year)
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CONSISTENCY WITH APPLICABLE GREENHOUSE GAS REDUCTION PLANS AND POLICIES The proposed project could have the potential to conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases. The City of Modesto does not currently have a Climate Action Plan (CAP); therefore, the project and its GHG emissions have been compared to the goals of the CARB Scoping Plan.
Scoping Plan
Emission reductions in California alone would not be able to stabilize the concentration of greenhouse gases in the earth’s atmosphere. However, California’s actions set an example and drive progress towards a reduction in greenhouse gases elsewhere. If other states and countries were to follow California’s emission reduction targets, this could avoid medium or higher ranges of global temperature increases. Thus, severe consequences of climate change could also be avoided.
The CARB Board approved a Climate Change Scoping Plan in December 2008. The Scoping Plan outlines the State’s strategy to achieve the 2020 greenhouse gas emissions limit. The Scoping Plan “proposes a comprehensive set of actions designed to reduce overall greenhouse gas emissions in California, improve our environment, reduce our dependence on oil, diversify our energy sources, save energy, create new jobs, and enhance public health” (California Air Resources Board 2008). The measures in the Scoping Plan have been in place since 2012.
This Scoping Plan calls for an “ambitious but achievable” reduction in California’s greenhouse gas emissions, cutting approximately 30 percent from business-as-usual emission levels projected for 2020, or about 10 percent from today’s levels. On a per-capita basis, that means reducing annual emissions of 14 tons of carbon dioxide for every man, woman and child in California down to about 10 tons per person by 2020.
In May 2014, CARB released its First Update to the Climate Change Scoping Plan (CARB 2014). This Update identifies the next steps for California’s leadership on climate change. While California continues on its path to meet the near-term 2020 greenhouse gas limit, it must also set a clear path toward long-term, deep GHG emission reductions. CARB’s First Update “lays the foundation for establishing a broad framework for continued emission reductions beyond 2020, on the path to 80 percent below 1990 levels by 2050,” and many of the emission reduction strategies recommended by CARB would serve to reduce the Project’s post2020 emissions level to the extent required by applicable by law.
In November 2017, CARB release the 2017 Scoping Plan. This Scoping Plan incorporates, coordinates, and leverages many existing and ongoing efforts and identifies new policies and actions to accomplish the State’s climate goals, and includes a description of a suite of specific actions to meet the State’s 2030 GHG limit. In addition, Chapter 4 of the Scoping Plan provides a broader description of the many actions and proposals being explored across the sectors, including the natural resources sector, to achieve the State’s mid and longterm climate goals.
Guided by legislative direction, the actions identified in the 2017 Scoping Plan reduce overall GHG emissions in California and deliver policy signals that will continue to drive investment and certainty in a low carbon economy. The 2017 Scoping Plan builds upon the successful framework established by the Initial Scoping Plan and First Update, while identifying new, technologically feasible, and cost-effective strategies to ensure that California meets its GHG reduction targets in a way that promotes and rewards innovation, continues to foster economic growth, and delivers improvements to the environment and public health, including in disadvantaged communities. The Plan includes policies to require direct GHG reductions at some of the State’s largest stationary sources and mobile sources. These policies include the use of lower GHG fuels, efficiency regulations, and the Cap-and Trade Program, which constrains and reduces emissions at covered sources.
Independent studies confirm CARB’s determination that the state’s existing and proposed regulatory framework will put the state on a pathway to reduce its GHG emissions level to 40 percent below 1990 levels 62 #8..
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by 2030, and to 80 percent below 1990 levels by 2050 if additional appropriate reduction measures are adopted.31 Even though these studies did not provide an exact regulatory and technological roadmap to achieve the 2030 and 2050 goals, they demonstrated that various combinations of policies could allow the statewide emissions level to remain very low through 2050, suggesting that the combination of new technologies and other regulations not analyzed in the studies would allow the state to meet the 2050 target.
In November of 2022, the CARB released the 2022 Scoping Plan. The 2022 Scoping Plan lays out a path to achieve targets for carbon neutrality and reduce anthropogenic GHG emissions by 85 percent below 1990 levels no later than 2045, as directed by Assembly Bill 1279. The actions and outcomes in the plan will achieve significant reductions in fossil fuel combustion by deploying clean technologies and fuels, further reductions in short-lived climate pollutants, support for sustainable development, increased action on natural and working lands to reduce emissions and sequester carbon, and the capture and storage of carbon. As the latest, 2022 Scoping Plan builds upon previous versions, project consistency with applicable strategies of the 2008, 2017, and 2022 Plan are assessed in Table 10. As shown in Table 10, the project is consistent with the applicable strategies within the Scoping Plan.
Furthermore, at a level of 23.1 MTCO2e per year, the project's GHG emissions would be in compliance with the reduction goals of the CARB Scoping Plan, AB-32 and SB-32. Furthermore, the project will comply with applicable Green Building Standards and City of Modesto’s policies regarding sustainability (as dictated by the City's General Plan). Impacts are considered to be less than significant.
31 Energy and Environmental Economics (E3). “Summary of the California State Agencies’ PATHWAYS Project: Long-term Greenhouse Gas Reduction Scenarios” (April 2015); Greenblatt, Jeffrey, Energy Policy, “Modeling California Impacts on Greenhouse Gas Emissions” (Vol. 78, pp. 158–172). The California Air Resources Board, California Energy Commission, California Public Utilities Commission, and the California Independent System Operator engaged E3 to evaluate the feasibility and cost of a range of potential 2030 targets along the way to the state’s goal of reducing GHG emissions to 80 percent below 1990 levels by 2050.
With input from the agencies, E3 developed scenarios that explore the potential pace at which emission reductions can be achieved, as well as the mix of technologies and practices deployed. E3 conducted the analysis using its California PATHWAYS model. Enhanced specifically for this study, the model encompasses the entire California economy with detailed representations of the buildings, industry, transportation and electricity sectors. https://www.ethree.com/wpcontent/uploads/2017/02/E3_Project_Overview_20150406.pdf 63 #8..
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Table 10 (1 of 2)
Project Consistency with CARB Scoping Plan Policies and Meaures Project Compliance with Measure
No Conflict. These are CARB enforced standards; vehicles that access the project (that are required to comply with the standards) will comply with the strategy.
No Conflict. The project will be compliant with any applicable portions of the current Title 24 standards.
No Conflict. These are CARB enforced standards; vehicles that access the project (that are required to comply with the standards) will comply with the strategy.
No Conflict. These are CARB enforced standards; vehicles that access the project (that are required to comply with the standards) will comply with the strategy.
No Conflict. These are CARB enforced standards; vehicles that access the project (that are required to comply with the standards) will comply with the strategy.
No Conflict. The California Green Building Standards Code (proposed Part 11, Title 24) was adopted as part of the California Building Standards Code in the CCR. Part 11 establishes voluntary standards, that are mandatory in the 2019 edition of the Code, on planning and design for sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and internal air contaminants. In addition, the 2022 edition of the Code took effect January 1, 2023. The project is the installation of a water pipeline, however, it project will be subject to any applicable portions of these mandatory standards.
No Conflict. CARB identified five measures that reduce HFC emissions from vehicular and commercial refrigeration systems; vehicles that access the project that are required to comply with the measures will comply with the strategy.
No Conflict. The state is currently developing a regulation to reduce methane emissions from municipal solid waste landfills. The project will be required to comply with local programs, such as City and/or County recycling and waste reduction programs, which comply, with the 75 percent reduction required by 2020 per AB 341.
No Conflict. The project is the installation of a new water pipeline and will comply with all applicable City ordinances and CAL Green requirements.
Project Compliance with Recommended Action
No Conflict. These are CARB enforced standards; vehicles that access the project (that are required to comply with the standards) will comply with the strategy.
No Conflict. These are CARB enforced standards; vehicles that access the project (that are required to comply with the standards) will comply with the strategy.
2008 Scoping Plan Measures to Reduce Greenhouse Gas Emissions California Light-Duty Vehicle Greenhouse Gas Standards – Implement adopted standards and planned second phase of the program. Align zeroemission vehicle, alternative and renewable fuel and vehicle technology programs with long-term climate change goals.
Energy Efficiency – Maximize energy efficiency building and appliance standards; pursue additional efficiency including new technologies, policy, and implementation mechanisms. Pursue comparable investment in energy efficiency from all retail providers of electricity in California.
Low Carbon Fuel Standard – Develop and adopt the Low Carbon Fuel Standard.
Recycling and Waste – Reduce methane emissions at landfills. Increase waste diversion, composting, and commercial recycling. Move toward zerowaste.
Water – Continue efficiency programs and use cleaner energy sources to move and treat water.
2017 Scoping Plan Recommended Actions
to Reduce Greenhouse Gas Emissions
Implement Mobile Source Strategy: Further increase GHG stringency on all light-duty vehicles beyond existing Advanced Clean Car regulations.
Vehicle Efficiency Measures – Implement light-duty vehicle efficiency measures.
Medium/Heavy-Duty Vehicles – Adopt medium and heavy-duty vehicle efficiency measures.
Green Building Strategy – Expand the use of green building practices to reduce the carbon footprint of California’s new and existing inventory of buildings.
High Global Warming Potential Gases – Adopt measures to reduce high global warming potential gases.
Implement Mobile Source Strategy: At least 1.5 million zero emission and plug-in hybrid light-duty electric vehicles by 2025 and at least 4.2 million zero emission and plug-in hybrid light-duty electric vehicles by 2030.
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Table 10 (2 of 2)
Project Consistency with CARB Scoping Plan Policies and Meaures No Conflict. These are CARB enforced standards; vehicles that access the project (that are required to comply with the standards) will comply with the strategy.
No Conflict. These are CARB enforced standards; vehicles that access the project (that are required to comply with the standards) will comply with the strategy.
No Conflict. The project is the installation of a water pipeline. However the project will be compliant with any applicbale portions of the current Title 24 standards.
No Conflict. The project will be required to comply with local programs, such as City and/or County recycling and waste reduction programs,which comply, with the 75 percent reduction required by 2020 per AB 341.
Project Compliance with Recommended Actions
Not Applicable. This action is in regard to vehicle sales, with an aim to have 100 percent of light-duty vehicle sales be ZEVs by 2035. The proposed project would not interfere with such policymaking.
No Conflict. The Project would not result in an unmitigated impact to VMT.
Additional staffing needs for long-term operation and maintenance of the proposed project are not anticipated and only a minimal number of daily worker trips are anticipated to conduct routine inspections and ensure proper long-term maintenance. Therefore, the additional vehicle trips from the existing operations associated with the operation of the proposed project would be minimal.
Not Applicable. This action is in regard to residential and commercial appliances and the proposed project is a water pipeline installation project and would not interfere with such policymaking.
Not Applicable. This action is in regard to appliance sales and the proposed project is a water pipeline installation project and would not interfere with such policymaking.
Notes:
(1) Source: CARB Scoping Plan (2008, 2017, and 2022)
100 percent of light-duty vehicle sales are ZEVs by 2035.
VMT per capita reduced 25 percent below 2019 levels by 2030 and 30 percent below 2019 levels by 2045.
All electric appliances in new construction beginning 2026 (residential) and 2029 (commercial).
For existing residential buildings, 80 percent of appliance sales are electric by 2030 and 100 percent of appliance sales are electric by 2035 (appliances replaced at end of life).
For existing commercial buildings, 80 percent of appliance sales are electric by 2030 and 100 percent of appliance sales are electric by 2045 (appliances replaced at end of life)
Implement SB 350 by 2030: Establish annual targets for statewide energy efficiency savings and demand reduction that will achieve a cumulative doubling of statewide energy efficiency savings in electricity and natural gas end uses by 2030.
By 2019, develop regulations and programs to support organic waste landfill reduction goals in the SLCP and SB 1383.
2022 Scoping Plan Priority Key Actions and Recommendations Implement Mobile Source Strategy: Last Mile Delivery: New regulation that would result in the use of low NOX or cleaner engines and the deployment of increasing numbers of zero-emission trucks primarily for class 3-7 last mile delivery trucks in California. This measure assumes ZEVs comprise 2.5 percent of new Class 3–7 truck sales in local fleets starting in 2020, increasing to 10 percent in 2025 and remaining flat through 2030.
Implement Mobile Source Strategy: Innovative Clean Transit: Transition to a suite of to-be-determined innovative clean transit options. Assumed 20 percent of new urban buses purchased beginning in 2018 will be zero emission buses with the penetration of zero-emission technology ramped up to 100 percent of new sales in 2030. Also, new natural gas buses, starting in 2018, and diesel buses, starting in 2020, meet the optional heavy-duty low-NOX standard.
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CUMULATIVE GREENHOUSE GAS IMPACTS
Although the project is expected to emit GHGs, the emission of GHGs by a single project into the atmosphere is not itself necessarily an adverse environmental effect. Rather, it is the increased accumulation of GHG from more than one project and many sources in the atmosphere that may result in global climate change.
Therefore, in the case of global climate change, the proximity of the project to other GHG emission generating activities is not directly relevant to the determination of a cumulative impact because climate change is a global condition. According to CAPCOA, “GHG impacts are exclusively cumulative impacts; there are no noncumulative GHG emission impacts from a climate change perspective.”32 The resultant consequences of that climate change can cause adverse environmental effects. A project’s GHG emissions typically would be very small in comparison to state or global GHG emissions and, consequently, they would, in isolation, have no significant direct impact on climate change.
The state has mandated a goal of reducing statewide emissions to 1990 levels by 2020, even though statewide population and commerce are predicted to continue to expand. In order to achieve this goal, CARB is in the process of establishing and implementing regulations to reduce statewide GHG emissions. Consistent with CEQA Guidelines Section 15064h(3),33 the City, as lead agency, has determined that the project’s contribution to cumulative GHG emissions and global climate change would be less than significant if the project is consistent with the applicable regulatory plans and policies to reduce GHG emissions.
As discussed in the Consistency With Applicable Greenhouse Gas Reduction Plans and Policies section above, the project is consistent with the CARB Scoping Plan.
Thus, given the project’s consistency with the CARB Scoping Plan, the project would not conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of GHGs.
Given this consistency, it is concluded that the project’s incremental contribution to greenhouse gas emissions and their effects on climate change would not be cumulatively considerable.
32 Source: California Air Pollution Control Officers Association, CEQA & Climate change: Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act, (2008). 33 The State CEQA Guidelines were amended in response to SB 97. In particular, the State CEQA Guidelines were amended to specify that compliance with a GHG emissions reduction program renders a cumulative impact insignificant. Per State CEQA Guidelines Section 15064(h)(3), a project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project will comply with an approved plan or mitigation program that provides specific requirements that will avoid or substantially lessen the cumulative problem within the geographic area of the project. To qualify, such a plan or program must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process to implement, interpret, or make specific the law enforced or administered by the public agency. Examples of such programs include a “water quality control plan, air quality attainment or maintenance plan, integrated waste management plan, habitat conservation plan, natural community conservation plan, [and] plans or regulations for the reduction of greenhouse gas emissions.” 66 #8..
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4. NEPA ANALYSIS
FEDERAL CLEAN AIR ACT CONFORMITY
Criteria Pollutant Emissions
Section 176(c) of the Federal Clean Air Act prohibits federal participation in any project that is in conflict with the State Implementation Plan (SIP). Participation includes funding, permitting or other non-direct involvement. Based on the General Conformity requirements (40 CFR Section 93.153), if the total direct and indirect emissions from the proposed project are below the Federal Conformity de minimus” emissions thresholds, the proposed project would be exempt from performing a comprehensive Air Quality Conformity Analysis and would be considered to be in conformity with the SIP and have less than significant impacts.
Table 11 provides the current General Conformity de minimus” emissions thresholds in tons per year (tpy) for the San Joaquin Valley Air Basin and the estimated short-term emissions from the proposed project. Table 11 shows that project-related construcঞon emissions would be less than the de minimus thresholds for all pollutants.
In addition, the project is the installation of approximately 12,000 linear feet of 12-inch diameter pipe. To conduct routine inspections and ensure proper long-term maintenance, the long-term operation of the project will require a minimal number of monthly worker trips. Additional staffing needs for long-term operation and maintenance of the proposed project are not anticipated. Therefore, operational emissions associated with the proposed project would be negligible and would not be anticipated to exceed any of the federal de minimus conformity thresholds.
Greenhouse Gas Emissions
Consistent with section 102(2)(C) of National Environmental Policy Act (NEPA), Federal agencies must disclose and consider the reasonably foreseeable effects of their proposed actions including the extent to which a proposed action would result in reasonably foreseeable GHG emissions that contribute to climate change.
The Council on Environmental Quality (CEQ) published their National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change in January 2023.34 The CEQ guidance document assists agencies in analyzing greenhouse gas (GHG) and climate change effects under NEPA.
The CEQ guidance document identifies and explains that the following steps should be taken when analyzing a proposed action's climate change effects under NEPA:
(1) Quantify the reasonably foreseeable GHG emissions (including direct and indirect emissions) of a proposed action, the no action alternative, and any reasonable alternatives. (2) Disclose and provide context for the GHG emissions and climate impacts associated with a proposed action and alternatives, including by, as relevant, monetizing climate damages using estimates of the SCGHG, placing emissions in the context of relevant climate action goals and commitments, and providing common equivalents
(3) Analyze reasonable alternatives, including those that would reduce GHG emissions relative to baseline conditions, and identify available mitigation measures to avoid, minimize, or compensate for climate effects.
Although the guidance document sets forth the forementioned steps to analyze a project’s greenhouse gas emissions under NEPA, it does not, however, provide a numerical threshold. Code of Federal Regulations Title 40, Chapter 1, Subchapter C, Part 98 includes mandatory greenhouse gas reporting requirements, which 34 https://www.federalregister.gov/documents/2023/01/09/2023-00158/national-environmental-policy-act-guidance-onconsideration-of-greenhouse-gas-emissions-and-climate 67 #8..
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includes a greenhouse gas threshold of 25,000 MTCO2e per year to assess impacts. Therefore, a threshold of 25,000 MTCO2e per year was utilized to assess the impacts of the greenhouse gas emissions in relation to NEPA.
Table 12 shows that the total for the proposed project’s emissions (without credit for any reductions from sustainable design and/or regulatory requirements) would be 23.1 MTCO2e per year. Therefore, as shown in Table 12, the proposed project’s greenhouse gas emissions do not exceed the threshold of 25,000 MTCO2e per year.
Based on the federal conformity analysis, the project does not exceed the annual de minimus conformity thresholds and is therefore in conformance with the Clean Air Act.
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ROG NOx CO SO2 PM10 PM2.5
10 100 100 100 100 70
0.31 2.79 3.15 0.02 0.34 0.20
No No No No No No
Notes:
Source: CalEEMod Version 2022.1.1.28.
(1) Federal General Conformity thresholds obtained from 40 CFR 93.153 (2)
De Minimus Threshold1
Exceeds Thresholds?
Includes both on-site and off-site emissions. On-site PM2.5 and PM-10 emissions show compliance with SJVAPCD Regulation VIII for fugitive dust.
Construction Emissions2
Table 11
Federal Conformity Analysis and De Minimus Thresholds
Pollutant Emissions (tons/year)
Activity
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Bio-CO2 NonBio-CO2 CO2 CH4 N2O CO2e
0.00 23.00 23.00 0.00 0.00 23.10
0.00 23.00 23.00 0.00 0.00 23.10
25,000
Exceeds Threshold? No
Notes:
Source: CalEEMod Version 2022.1.1.28.
(1) Construction GHG emissions CO2e based on a 30 year amortization rate. (2) The proposed project is the installation of a new water pipeline. Therefore, operation of the proposed project includes only a minimal number of monthly worker trips in order to conduct routine inspections and ensure proper long-term maintenance.
As operational emissions are anticipated to be negligble and only from monthly maintenance vehilce trips, only construction related GHG emissions have been included in this analysis.
NEPA GHG Emissions Screening Threshold
Table 12
Greenhouse Gas Emissions Comparison to Federal Conformity Thresholds Category
Greenhouse Gas Emissions (Metric Tons/Year)
Total Emissions
Construction1,2
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5. ENERGY ANALYSIS
EXISTING CONDITIONS
This section provides an overview of the existing energy conditions in the project area and region.
Overview
California’s estimated annual energy use as of 2022 included:
Approximately 287,220 gigawatt hours of electricity;35 Approximately 2,056,267 million cubic feet of natural gas per year;36 and Approximately 23.2 billion gallons of transportation fuel (for the year 2015).37 As of 2021, the year of most recent data currently available by the United States Energy Information Administration (EIA), energy use in California by demand sector was:
Approximately 41.2 percent transportation;
Approximately 23.6 percent industrial;
Approximately 18.2 percent residential; and
Approximately 17.1 percent commercial.38
California's electricity in-state generation system generates approximately 203,257 gigawatt-hours each year.
In 2022, California produced approximately 71 percent of the electricity it uses; the rest was imported from the Pacific Northwest (approximately 12 percent) and the U.S. Southwest (approximately 17 percent). Natural gas is the main source for electricity generation at approximately 47.46 percent of the total in-state electric generation system power as shown in Table 13.
A summary of and context for energy consumption and energy demands within the State is presented in “U.S.
Energy Information Administration, California State Profile and Energy Estimates, Quick Facts” excerpted below:
In 2022, California was the seventh-largest producer of crude oil among the 50 states, and, as of January 2022, the state ranked third in crude oil refining capacity. California is the largest consumer of jet fuel and second-largest consumer of motor gasoline among the 50 states.
In 2020, California was the second-largest total energy consumer among the states, but its per capita energy consumption was less than in all but three other states. In 2022, renewable resources, including hydroelectric power and small-scale, customer-sited solar power, accounted for 49% of California's in-state electricity generation. Natural gas fueled another 42%.
Nuclear power supplied almost all the rest.
35 California Energy Commission. Energy Almanac. Total Electric Generation. [Online] 2022. https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2022-total-system-electric-generation. 36 Natural Gas Consumption by End Use. U.S. Energy Information Administration. [Online] 2022. https://www.eia.gov/dnav/ng/ng_cons_sum_dcu_SCA_a.htm.
37 California Energy Commission. Revised Transportation Energy Demand Forecast 2018-2030. [Online] 2021. https://www.energy.ca.gov/data-reports/planning-and-forecasting 38 U.S. Energy Information Administration. California Energy Consumption by End-Use Sector, 2021.
California State Profile Overview.[Online] 2023 https://www.eia.gov/state/?sid=CA#tabs-2 71 #8..
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In 2022, California was the fourth-largest electricity producer in the nation. The state was also the nation’s third-largest electricity consumer, and additional needed electricity supplies came from out-ofstate generators.39 As indicated above, California is one of the nation’s leading energy-producing states, and California per capita energy use is among the nation’s most efficient. Given the nature of the proposed project, the remainder of this discussion will focus on the three sources of energy that are most relevant to the project—namely, electricity and natural gas for building uses, and transportation fuel for vehicle trips associated with the proposed project.
Electricity
Electricity would be provided to the project by Modesto Irrigation District (MID). MID provides electric and irrigation and treats surface water for drinking. The MID electric service area includes the greater Modesto area (north of the Tuolumne River, Waterford, Salida, Mountain House (Northwest of Tracy) and parts of Ripon, Escalon, Oakdale and Riverbank. MID is an independent, publicly owned utility.40 Table 14 identifies MID’s specific proportional shares of electricity sources in 2022. As shown in Table 14, the 2022 MID Power Mix has renewable energy at 30.1 percent of the overall energy resources, of which solar energy is at 13.9 percent, eligible hydroelectric is at 0.2 percent, and wind is at 16 percent; other energy sources include large hydroelectric at 17.8 percent, natural gas at 13.6 percent, nuclear at 1.8 percent other at 0.1 percent, and unspecified sources at 36.6 percent.
Natural Gas
Natural gas would be provided to the project by Pacific Gas and Electric (PGE). The following summary of natural gas resources and service providers, delivery systems, and associated regulation is excerpted from information provided by the California Public Utilities Commission (CPUC).
The CPUC regulates natural gas utility service for approximately 11 million customers that receive natural gas from Pacific Gas and Electric (PG&E), Southern California Gas (SoCalGas), San Diego Gas & Electric (SDG&E), Southwest Gas, and several smaller investor-owned natural gas utilities. The CPUC also regulates independent storage operators Lodi Gas Storage, Wild Goose Storage, Central Valley Storage and Gill Ranch Storage.
The vast majority of California's natural gas customers are residential and small commercial customers, referred to as "core" customers. Larger volume gas customers, like electric generators and industrial customers, are called "noncore" customers. Although very small in number relative to core customers, noncore customers consume about 65% of the natural gas delivered by the state's natural gas utilities, while core customers consume about 35%.
The PUC regulates the California utilities' natural gas rates and natural gas services, including in-state transportation over the utilities' 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 basins. In 2017, for example, California utility customers received 38% of their natural gas supply from basins located in the U.S. Southwest, 27% from Canada, 27% from the U.S. Rocky Mountain area, and 8% from production located in California.”41 Transportation Energy Resources
39 State Profile Overview. [Online] [Cited: April 20, 2023.] https://www.eia.gov/state/?sid=CA#tabs-2 40 https://www.mid.org/about/default.html
41 California Public Utilities Commission. Natural Gas and California. http://www.cpuc.ca.gov/natural_gas/ 72 #8..
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The project would attract additional vehicle trips with resulting consumption of energy resources, predominantly gasoline and diesel fuel. Gasoline (and other vehicle fuels) are commercially provided commodities and would be available to the project patrons and employees via commercial outlets.
The most recent data available shows the transportation sector emits 38 percent of the total greenhouse gases in the state and about 84 percent of smog-forming oxides of nitrogen (NOx).42,43 About 27 percent of total United States energy consumption in 2022 was for transporting people and goods from one place to another. In 2022, petroleum comprised about 90 percent of all transportation energy use.44 In 2022, about 135.06 billion gallons (or about 3.22 billion barrels) of finished motor gasoline were consumed in the United States, an average of about 370 million gallons (or about 8.81 million barrels) per day.45
REGULATORY BACKGROUND
Federal and state agencies regulate energy use and consumption through various means and programs. On the federal level, the United States Department of Transportation, the United States Department of Energy, and the United States Environmental Protection Agency are three federal agencies with substantial influence over energy policies and programs. On the state level, the PUC and the California Energy Commissions (CEC) are two agencies with authority over different aspects of energy. Relevant federal and state energy-related laws and plans are summarized below.
Federal Regulations
Corporate Average Fuel Economy (CAFE) Standards
First established by the U.S. Congress in 1975, the Corporate Average Fuel Economy (CAFE) standards reduce energy consumption by increasing the fuel economy of cars and light trucks. The National Highway Traffic Safety Administration (NHTSA) and U.S. Environmental Protection Agency (USEPA) jointly administer the CAFE standards. The U.S. Congress has specified that CAFE standards must be set at the “maximum feasible level” with consideration given for: (1) technological feasibility; (2) economic practicality; (3) effect of other standards on fuel economy; and (4) need for the nation to conserve energy.46 Issued by NHTSA and EPA in March 2020 (published on April 30, 2020 and effective after June 29, 2020), the Safer Affordable Fuel-Efficient Vehicles Rule would maintain the CAFE and CO2 standards applicable in model year 2020 for model years 2021 through 2026. The estimated CAFE and CO2 standards for model year 2020 are 43.7 mpg and 204 grams of CO2 per mile for passenger cars and 31.3 mpg and 284 grams of CO2 per mile for light trucks, projecting an overall industry average of 37 mpg, as compared to 46.7 mpg under the standards issued in 2012.47
On May 12, 2021, the National Highway Traffic Safety Administration (NHTSA) published a notice of proposed rulemaking in the Federal Register, proposing to repeal “The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National Program,” published Sept. 27, 2019 (SAFE I Rule), in which NHTSA codified regulatory text and made additional pronouncements regarding the preemption of state and local laws related to fuel economy standards. Specifically, this document proposed to fully repeal the regulatory 42 CARB. California Greenhouse Gas Emissions Inventory – 2022 Edition. https://ww2.arb.ca.gov/ghg-inventory-data 43 CARB. 2016 SIP Emission Projection Data. https://www.arb.ca.gov/app/emsinv/2017/emseic1_query.php?F_DIV=- 4&F_YR=2012&F_SEASON=A&SP=SIP105ADJ&F_AREA=CA
44 US Energy Information Administration. Use of Energy in the United States Explained: Energy Use for Transportation. https://www.eia.gov/energyexplained/?page=us_energy_transportation 45 https://www.eia.gov/tools/faqs/faq.php?id=23&t=10
46 https://www.nhtsa.gov/lawsregulations/corporate-average-fuel-economy. 47 National Highway Traffic Safety Administration (NHTSA) and U.S. Environmental Protection Agency (USEPA), 2018. Federal Register / Vol. 83, No. 165 / Friday, August 24, 2018 / Proposed Rules, The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks 2018. Available at: https://www.epa.gov/regulations-emissions-vehicles-andengines/safer-affordable-fuel-efficient-safe-vehicles-final-rule. 73 #8..
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text and appendices promulgated in the SAFE I Rule. In addition, this document proposed to repeal and withdraw the interpretative statements made by the Agency in the SAFE I Rule preamble, including those regarding the preemption of particular state Greenhouse Gas (GHG) Emissions standards or Zero Emissions Vehicle (ZEV) mandates. As such, this document proposed to establish a clean slate with respect to NHTSA's regulations and interpretations concerning preemption under the Energy Policy and Conservation Act (EPCA).
This action is effective as of January 28, 2022. 48
Intermodal Surface transportation Efficiency Act of 1991 (ISTEA) The Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) promoted the development of intermodal transportation systems to maximize mobility as well as address national and local interests in air quality and energy. ISTEA contained factors that Metropolitan Planning Organizations (MPOs) were to address in developing transportation plans and programs, including some energy-related factors. To meet the new ISTEA requirements, MPOs adopted explicit policies defining the social, economic, energy, and environmental values guiding transportation decisions.
The Transportation Equity Act of the 21st Century (TEA-21) The Transportation Equity Act for the 21st Century (TEA-21) was signed into law in 1998 and builds upon the initiatives established in the ISTEA legislation, discussed above. TEA-21 authorizes highway, highway safety, transit, and other efficient surface transportation programs. TEA-21 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 good transportation decisions. TEA-21 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.
State Regulations
Integrated Energy Policy Report (IEPR)
Senate Bill 1389 requires the California Energy Commission (CEC) to prepare a biennial integrated energy policy report that assesses major energy trends and issues facing the State’s electricity, natural gas, and transportation fuel sectors and provides policy recommendations to conserve resources; protect the environment; ensure reliable, secure, and diverse energy supplies; enhance the state’s economy; and protect public health and safety. The Energy Commission prepares these assessments and associated policy recommendations every two years, with updates in alternate years, as part of the Integrated Energy Policy Report.
The 2022 Integrated Energy Policy Report (2022 IEPR) was adopted in February 28, 2023. The 2022 IEPR provides updates on a variety of energy issues facing California. These issues will require action if the state is to meet its climate, energy, air quality, and other environmental goals while maintaining reliability and controlling costs. The 2022 IEPR also discusses the California Energy Commission’s equity and environmental justice efforts, its development of a more easily navigable online data platform via the California Energy Planning Library, and an update to the California Energy Demand Forecast. The report also provides information on emerging topics related to energy reliability, western electricity integration, hydrogen, gasoline prices, gas transition, and distributed energy resources.49 The 2023 Integrated Energy Policy Report (2023 IEPR) was completed in January 2024. The 2023 IEPR discusses speeding connection of clean resources to the electricity grid, the potential use of clean and 48 https://www.federalregister.gov/documents/2021/05/12/2021-08758/corporate-average-fuel-economy-cafe-preemption 49 California Energy Commission. Final 2022 Integrated Energy Policy Report. February 2023. https://www.energy.ca.gov/datareports/reports/integrated-energy-policy-report/2022-integrated-energy-policy-report-update 74 #8..
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renewable hydrogen, and the California Energy Demand Forecast to 2040. The report also provides updates on topics such as gas decarbonization, energy efficiency, the Clean Transportation Program, Assembly Bill 1257 (Bocanegra, Chapter 749, Statutes of 2013), and publicly owned utilities’ progress toward peak demand reserves and margins.50
State of California Energy Plan
The CEC is responsible for preparing the State Energy Plan, which identifies emerging trends related to energy supply, demand, conservation, public health and safety, and the maintenance of a healthy economy. The Plan calls for the state to assist in the transformation of the transportation system to improve air quality, reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies and fleet operators and encouragement of urban designs that reduce vehicle miles traveled and accommodate pedestrian and bicycle access.
California Building Standards Code (Title 24)
The California Building Standards Code Title 24 was previously discussed in Section 3 of this report.
California Building Energy Efficiency Standards (Title 24, Part 6) The California Building Energy Efficiency Standards for Residential and Nonresidential Buildings (California Code of Regulations, Title 24, Part 6) were adopted to ensure that building construction and system design and installation achieve energy efficiency and preserve outdoor and indoor environmental quality. The 2019 Title 24 standards include efficiency improvements to the lighting and efficiency improvements to the nonresidential standards include alignment with the American Society of Heating and Air-Conditioning Engineers.
For example, window operation is no longer a method allowed to meet ventilation requirements, continuous operation of central forced air system handlers used in central fan integrated ventilation system is not a permissible method of providing the dwelling unit ventilation airflow, and central ventilation systems that serve multiple dwelling units must be balanced to provide ventilation airflow to each dwelling unit. In addition, requirements for kitchen range hoods were also provided in the updated Section 120.1. Ventilation and Indoor Air Quality included both additions and revisions in the 2019 Code. This section now requires nonresidential and hotel/motel buildings to have air filtration systems that use forced air ducts to supply air to occupiable spaces to have air filters. Further, the air filter efficiency must be either MERV 13 or use a particle size efficiency rating specific in the Energy Code AND be equipped with air filters with a minimum 2-inch depth or minimum 1-inch depth if sized according to the equation 120.1-A. If natural ventilation is to be used the space must also use mechanical unless ventilation openings are either permanently open or controlled to stay open during occupied times.
New regulations were also adopted under Section 130.1 Indoor Lighting Controls. These included new exceptions being added for restrooms, the exception for classrooms being removed, as well as exceptions in regard to sunlight provided through skylights and overhangs.
The 2016 residential standards were estimated to be approximately 28 percent more efficient than the 2013 standards, whereas the 2019 residential standards were estimated to be approximately 7 percent more efficient than the 2016 standards. Furthermore, once rooftop solar electricity generation was factored in, 2019 residential standards were estimated to be approximately 53 percent more efficient than the 2016 standards. Under the 2019 standards, nonresidential buildings were estimated to be approximately 30 percent more efficient than the 2016 standards. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases greenhouse gas emissions. California Energy Commission. Final 2023 Integrated Energy Policy Report. January 2024. https://www.energy.ca.gov/datareports/reports/integrated-energy-policy-report/2023-integrated-energy-policy-report 75 #8..
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The current California Building Energy Efficiency Standards (Title 24 standards) are the 2022 Building Energy Efficiency Standards became which effective on January 1, 2023. 51 All buildings for which an application for a building permit is submitted on or after January 1, 2022 must follow the 2022 standards. The core focus of the building standards has been efficiency, but the 2019 Energy Code ventured into onsite generation by requiring solar PV on new homes, providing significant GHG savings. The 2022 update builds off this progress with expanded solar standards and the move to onsite energy storage that will help Californians save on utility bills while bolstering the grid. The 2022 Energy Code update focuses on four key areas in new construction of homes and businesses:
Encouraging electric heat pump technology and use, which consumes less energy and produces fewer emissions than traditional HVACs and water heaters.
Establishing electric-ready requirements when natural gas is installed, which positions 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 percent clean electricity grid. Strengthening ventilation standards to improve indoor air quality.
The 2022 Energy Code affects homes by establishing energy budgets based on efficient heat pumps for space or water heating to encourage builders to install heat pumps over gas-fueled HVAC units; requiring homes to be electric-ready, with dedicated 240-volt outlets and space (with plumbing for water heaters) so electric appliances can eventually replace installed gas appliances; increasing minimum kitchen ventilation requirements so that fans over cooktops have higher airflow or capture efficiency to better exhaust pollution from gas cooking and improve indoor air quality; and allowing exceptions to existing solar PV standards when roof area is not available (such as for smaller homes). In addition, the effect on businesses includes establishing combined solar PV and battery standards for select businesses with systems being sized to maximize onsite use of solar energy and avoid electricity demand during times when the grid must use gas-powered plants; establishing new efficiency standards for commercial greenhouses (primarily cannabis growing); and improving efficiency standards for building envelope, various internal systems, and grid integration equipment, such as demand-responsive controls to buoy grid stability.52,53 California Building Energy Efficiency Standards (Title 24, Part 11) The 2019 California Green Building Standards Code (California Code of Regulations, Title 24, Part 11), commonly referred to as the CALGreen Code, went into effect on January 1, 2020. The 2019 CALGreen Code includes mandatory measures for non-residential development related to site development; energy efficiency; water efficiency and conservation; material conservation and resource efficiency; and environmental quality.
As previously discussed in Section 3 of this report, the Department of Housing and Community Development (HCD) updated CALGreen through the 2019 Triennial Code Adoption Cycle. HCD modified the best management practices for stormwater pollution prevention adding Section 5.106.2 for projects that disturb one or more acres of land. This section requires projects that disturb one acre or more of land or less than one acre of land but are part of a larger common plan of development or sale must comply with the postconstruction requirement detailed in the applicable National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities issued by the State Water Resources Control Board. The NPDES permits require postconstruction 51 California Energy Commission (CEC). 2022. Building Energy Efficiency Standards. https://www.energy.ca.gov/programs-andtopics/programs/building-energy-efficiency-standards/2022-building-energy-efficiency. 52 https://www.lightnowblog.com/2021/08/california-energy-commission-adopts-2022-building-energy-efficiency-standards/ 53 State of California Energy Commission. 2022 Building Energy Efficiency Standards Summary. https://www.energy.ca.gov/sites/default/files/2021-08/CEC_2022_EnergyCodeUpdateSummary_ADA.pdf 76 #8..
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runoff (post-project hydrology) to match the preconstruction runoff pre-project hydrology) with installation of postconstruction stormwater management measures.
HCD added sections 5.106.4.1.3 and 5.106.4.1.5 in regard to bicycle parking. Section 5.106.4.1.3 requires new buildings with tenant spaces that have 10 or more tenant-occupants, provide secure bicycle parking for 5 percent of the tenant-occupant vehicular parking spaces with a minimum of one bicycle parking facility. In addition, Section 5.106.4.1.5 states that acceptable bicycle parking facility for Sections 5.106.4.1.2 through
5.106.4.1.4 shall be convenient from the street and shall meeting one of the following: (1) covered, lockable enclosures with permanently anchored racks for bicycles; (2) lockable bicycle rooms with permanently anchored racks; or (3) lockable, permanently anchored bicycle lockers.
HCD amended section 5.106.5.3.5 allowing future charging spaces to qualify as designated parking for clean air vehicles.
HCD updated section 5.303.3.3 in regard to showerhead flow rates. This update reduced the flow rate to 1.8 GPM.
HCD amended section 5.304.1 for outdoor potable water use in landscape areas and repealed sections
5.304.2 and 5.304.3. The update requires nonresidential developments to comply with a local water efficient landscape ordinance or the current California Department of Water Resource’s’ Model Water Efficient Landscape Ordinance (MWELO), whichever is more stringent. Some updates were also made in regard to the outdoor potable water use in landscape areas for public schools and community colleges.
HCD updated Section 5.504.5.3 in regard to the use of MERV filters in mechanically ventilated buildings. This update changed the filter use from MERV 8 to MERV 13. MERV 13 filters are to be installed prior to occupancy, and recommendations for maintenance with filters of the same value shall be included in the operation and maintenance manual.
The 2022 California Green Building Standards Code became effective on January 1, 2023.54 HCD amended Section 5.106.5.3 in regard to increasing the EV capable space percentages and adding a new requirement for installed Level 2 DCFC chargers.
HCD under Section 5.106.5.4 added new regulation for electric vehicle charging readiness requirements for new construction of warehouse, grocery stores, and retail stores with planned off-street loading spaces. 55 However, as this project does not propose any buildings, building efficiency regulations would not be applicable.
Senate Bill 100
Senate Bill 100 (SB 100) requires 100 percent of total retail sales of electricity in California to come from eligible renewable energy resources and zero-carbon resources by December 31, 2045. SB 100 was adopted September 2018.
The interim thresholds from prior Senate Bills and Executive Orders would also remain in effect. These include Senate Bill 1078 (SB 1078), which requires retail sellers of electricity, including investor-owned utilities and community choice aggregators, to provide at least 20 percent of their supply from renewable sources by 2017. Senate Bill 107 (SB 107) which changed the target date to 2010. Executive Order S-14-08, which was signed on November 2008 and expanded the State’s Renewable Energy Standard to 33 percent renewable 54 California Building Standards Commission (CBSC). 2022. California Green Building Standards.
Website: https://codes.iccsafe.org/content/CAGBC2022P1. 55 https://www.dgs.ca.gov/BSC/Resources/2022-Title-24-California-Code-Changes 77 #8..
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energy by 2020. Executive Order S-21-09 directed the CARB to adopt regulations by July 31, 2010 to enforce S-14-08. Senate Bill X1-2 codifies the 33 percent renewable energy requirement by 2020.
Senate Bill 350
As previously discussed in Section 3 of this report, Senate Bill 350 (SB 350) was signed into law October 7, 2015, SB 350 increases California’s renewable electricity procurement goal from 33 percent by 2020 to 50 percent by 2030. This will increase the use of Renewables Portfolio Standard (RPS) eligible resources, including solar, wind, biomass, geothermal, and others. In addition, SB 350 requires the state to double statewide energy efficiency savings in electricity and natural gas end uses by 2030. To help ensure these goals are met and the greenhouse gas emission reductions are realized, large utilities will be required to develop and submit Integrated Resource Plans (IRPs). These IRPs will detail how each entity will meet their customers resource needs, reduce greenhouse gas emissions and ramp up the deployment of clean energy resources.
Assembly Bill 32
As discussed in Section 3 of this report, in 2006 the California State Legislature adopted Assembly Bill 32 (AB 32), the California Global Warming Solutions Act of 2006. AB 32 requires CARB, to adopt rules and regulations that would achieve GHG emissions equivalent to statewide levels in 1990 by 2020 through an enforceable statewide emission cap which will be phased in starting in 2012. Emission reductions shall include carbon sequestration projects that would remove carbon from the atmosphere and best management practices that are technologically feasible and cost effective. Please see Section 3 for further detail on AB 32.
Assembly Bill 1493/Pavley Regulations
As discussed in Section 3 of this report, California Assembly Bill 1493 enacted on July 22, 2002, required CARB to develop and adopt regulations that reduce GHGs emitted by passenger vehicles and light duty trucks.
In 2005, the CARB submitted a “waiver” request to the EPA from a portion of the federal Clean Air Act in order to allow the State to set more stringent tailpipe emission standards for CO2 and other GHG emissions from passenger vehicles and light duty trucks. On December 19, 2007 the EPA announced that it denied the “waiver” request. On January 21, 2009, CARB submitted a letter to the EPA administrator regarding the State’s request to reconsider the waiver denial. The EPA approved the waiver on June 30, 2009.
Executive Order S-1-07/Low Carbon Fuel Standard
As discussed in Section 3 of this report, Executive Order S-1-07 was issued in 2007 and proclaims that the transportation sector is the main source of GHG emissions in the State, since it generates more than 40 percent of the State’s GHG emissions. It establishes a goal to reduce the carbon intensity of transportation fuels sold in the State by at least ten percent by 2020. This Order also directs CARB to determine whether this Low Carbon Fuel Standard (LCFS) could be adopted as a discrete early-action measure as part of the effort to meet the mandates in AB 32.
On April 23, 2009 CARB approved the proposed regulation to implement the low carbon fuel standard. The low carbon fuel standard is anticipated to reduce GHG emissions by about 16 MMT per year by 2020. The low carbon fuel standard is designed to provide a framework that uses market mechanisms to spur the steady introduction of lower carbon fuels. The framework establishes performance standards that fuel producers and importers must meet each year beginning in 2011. Separate standards are established for gasoline and diesel fuels and the alternative fuels that can replace each. The standards are “back-loaded”, with more reductions required in the last five years, than during the first five years. This schedule allows for the development of advanced fuels that are lower in carbon than today’s fuels and the market penetration of plug-in hybrid electric vehicles, battery electric vehicles, fuel cell vehicles, and flexible fuel vehicles. It is anticipated that compliance with the low carbon fuel standard will be based on a combination of both lower carbon fuels and more efficient vehicles.
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Reformulated gasoline mixed with corn-derived ethanol at ten percent by volume and low sulfur diesel fuel represent the baseline fuels. Lower carbon fuels may be ethanol, biodiesel, renewable diesel, or blends of these fuels with gasoline or diesel as appropriate. Compressed natural gas and liquefied natural gas also may be low carbon fuels. Hydrogen and electricity, when used in fuel cells or electric vehicles are also considered as low carbon fuels for the low carbon fuel standard.
California Air Resources Board
CARB’s Advanced Clean Cars Program
Closely associated with the Pavley regulations, the Advanced Clean Cars emissions control program was approved by CARB in 2012. The program combines the control of smog, soot, and GHGs with requirements for greater numbers of zero-emission vehicles for model years 2015–2025.15 The components of the Advanced Clean Cars program include the Low-Emission Vehicle (LEV) regulations that reduce criteria pollutants and GHG emissions from light- and medium-duty vehicles, and the Zero-Emission Vehicle (ZEV) regulation, which requires manufacturers to produce an increasing number of pure ZEVs (meaning battery electric and fuel cell electric vehicles), with provisions to also produce plug-in hybrid electric vehicles (PHEV) in the 2018 through 2025 model years.56
Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling The Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling (Title 13, California Code of Regulations, Division 3, Chapter 10, Section 2435) was adopted to reduce public exposure to diesel particulate matter and other air contaminants by limiting the idling of diesel-fueled commercial motor vehicles. This section applies to diesel-fueled commercial motor vehicles with gross vehicular weight ratings of greater than 10,000 pounds that are or must be licensed for operation on highways. Reducing idling of diesel-fueled commercial motor vehicles reduces the amount of petroleum-based fuel used by the vehicle.
Regulation to Reduce Emissions of Diesel Particulate Matter, Oxides of Nitrogen, and other Criteria Pollutants, form In-Use Heavy-Duty Diesel-Fueled Vehicles
The Regulation to Reduce Emissions of Diesel Particulate Matter, Oxides of Nitrogen and other Criteria Pollutants, from In-Use Heavy-Duty Diesel-Fueled Vehicles (Title 13, California Code of Regulations, Division 3, Chapter 1, Section 2025) was adopted to reduce emissions of diesel particulate matter, oxides of nitrogen (NOX) and other criteria pollutants from in-use diesel-fueled vehicles. This regulation is phased, with full implementation by 2023. The regulation aims to reduce emissions by requiring the installation of diesel soot filters and encouraging the retirement, replacement, or repower of older, dirtier engines with newer emissioncontrolled models. The newer emission-controlled models would use petroleum-based fuel in a more efficient manner.
Sustainable Communities Strategy
The Sustainable Communities and Climate Protection Act of 2008, or Senate Bill 375 (SB 375), coordinates land use planning, regional transportation plans, and funding priorities to help California meet the GHG reduction mandates established in AB 32.
As previously stated in Section 3 of this report, Senate Bill 375 (SB 375) was adopted September 2008 and aligns regional transportation planning efforts, regional GHG emission reduction targets, and land use and housing allocation. SB 375 requires Metropolitan Planning Organizations (MPO) to adopt a sustainable communities strategy (SCS) or alternate planning strategy (APS) that will prescribe land use allocation in that MPOs Regional Transportation Plan (RTP). CARB, in consultation with each MPO, will provide each affected region with reduction targets for GHGs emitted by passenger cars and light trucks in the region for the years 56 California Air Resources Board, California’s Advanced Clean Cars Program, January 18, 2017. www.arb.ca.gov/msprog/acc/acc.htm. 79 #8..
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2020 and 2035. These reduction targets will be updated every eight years but can be updated every four years if advancements in emissions technologies affect the reduction strategies to achieve the targets. CARB is also charged with reviewing each MPO’s sustainable communities strategy or alternate planning strategy for consistency with its assigned targets.
PROJECT ENERGY DEMANDS AND ENERGY EFFICIENCY MEASURES
Evaluation Criteria
In compliance with Appendix G of the State CEQA Guidelines, this report analyzes the project’s anticipated energy use to determine 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; or Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
In addition, Appendix F of the State CEQA Guidelines states that the means of achieving the goal of energy conservation includes the following:
Decreasing overall per capita energy consumption;
Decreasing reliance on fossil fuels such as coal, natural gas and oil; and Increasing reliance on renewable energy sources.
Methodology
Information from the CalEEMod 2022.1.1.28 Output contained in Appendix B, utilized for air quality and greenhouse gas analyses in Sections 2 and 3 of this report, were also utilized for this analysis. The CalEEMod outputs detail project related construction equipment, transportation energy demands, and facility energy demands.
Construction Energy Demands
The construction is anticipated to occur no sooner than the beginning of fall 2024 and conclude in the beginning of fall 2025, lasting approximately 11 months, and be completed in one phase. The staging of construction vehicles and equipment will be located inside existing public right-of-way, adjacent parcels, and a portion of the Stanislaus Elementary School parking lot and will depend on the portion of the alignment under construction. The approximately 11-month schedule is relatively short, and the estimated area of disturbance during project construction is approximately 1.67 acres.57 Construction Equipment Electricity Usage Estimates
As stated previously, Electrical service will be provided by Modesto Irrigation District. The focus within this section is the energy implications of the construction process, specifically the power cost from on-site electricity consumption during construction of the proposed project. Based on the 2021 National Construction Estimator, Richard Pray (2021),58 the typical power cost per 1,000 square feet of building construction per month is estimated to be $2.37. The project includes construction of an approximately 12,000 linear foot pipeline extension. Therefore, the project does not include the construction of buildings. 57 Temporary areas of disturbance as a result of trenching is anticipated to be 4-feet wide and 8-feet deep along the entire approximately 12,000 linear feet of project alignment, approximately 1.1 acres. Jack and bore construction will consist of 5 total pits.
Jacking pits are approximately 12-feet wide by 10-feet long by 15-feet deep and receiving pits are approximately 12-feet wide by 24-feet long by 15-feet deep, resulting in approximately 0.03 acres of disturbance. Therefore, the total area of disturbance assumed for the proposed project is approximately 1.13 acres.
58 Pray, Richard. 2021 National Construction Estimator. Carlsbad : Craftsman Book Company, 2021. 80 #8..
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Construction Equipment Fuel Estimates
Fuel consumed by construction equipment would be the primary energy resource expended over the course of project construction. Fuel consumed by construction equipment was evaluated with the following assumptions:
Construction schedule of 11 months
All construction equipment was assumed to run on diesel fuel Typical daily use of 8 hours, with some equipment operating from ~7 hours Aggregate fuel consumption rate for all equipment was estimated at 18.5 hp-hr/gallon (from CARB’s 2017 Emissions Factors Tables and fuel consumption rate factors as shown in Table D-21 of the Moyer Guidelines: (https://www.arb.ca.gov/msprog/moyer/guidelines/2017gl/2017_gl_appendix_d.pdf). Diesel fuel would be the responsibility of the equipment operators/contractors and would be sources within the region.
Project construction represents a “single-event” for diesel fuel demand and would not require on-going or permanent commitment of diesel fuel resources during long term operation.
Using the CalEEMod data input for the air quality and greenhouse gas analyses (Sections 2 and 3 of this report), the project’s construction phase would consume electricity and fossil fuels as a single energy demand, that is, once construction is completed their use would cease. CARB’s 2017 Emissions Factors Tables show that on average, aggregate fuel consumption (gasoline and diesel fuel) would be approximately 18.5 hp-hrgal. Table 15 shows the results of the analysis of construction equipment.
As presented in Table 15, project construction, would consume an estimated 105,782 gallons of diesel fuel.
As stated previously, project construction would represent a “single-event” diesel fuel demand and would not require on-going or permanent commitment of diesel fuel resources for this purpose.
Construction Worker Fuel Estimates
It is assumed that construction worker trips are from light duty autos (LDA), light duty truck 1 (LDT1), and light duty truck 2 (LDT2) at a mix of 25 percent/50 percent/25 percent, respectively, along area roadways.59 With respect to estimated VMT, the construction worker trips would generate an estimated 82,944 VMT.
Data regarding project related construction worker trips were based on CalEEMod 2022.1.1.28 model defaults.
Vehicle fuel efficiencies for construction workers were estimated in the air quality and greenhouse gas analyses (Sections 2 and 3 of this report) using information generated using CARB’s 2021 EMFAC model (see Appendix B for details). An aggregate fuel efficiency of 26.2 miles per gallon (mpg) was used to calculate vehicle miles traveled for construction worker trips. Table 16 shows that an estimated 3,167 gallons of fuel would be consumed for construction worker trips.
Construction Vendor/Hauling Fuel Estimates
Tables 17 and 18 show the estimated fuel consumption for vendor and hauling during building construction.
With respect to estimated VMT, the vendor and hauling trips would generate an estimated 15,154 VMT. Data regarding project related construction worker trips were based on CalEEMod 2022.1.1.28 model defaults.
For the architectural coatings it is assumed that the contractors would be responsible for bringing coatings and equipment with them in their light duty vehicles. Therefore, vendors delivering construction material or 59 CalEEMod User's Guide Appendix C (April 2022) states that construction work trips are made by a fleet consisting of 25 percent light-duty auto (or passenger car), 50 percent light-duty truck type 1 (LDT1), and 25 percent light duty truck type 2 (LDT2). 81 #8..
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hauling debris from the site during project construction would use medium to heavy duty vehicles with an average fuel consumption of 7.9 mpg for medium heavy-duty trucks and 6.05 mpg for heavy heavy-duty trucks (see Appendix B for details). 60 Tables 17 and 18 show that an estimated 2,429 gallons of fuel would be consumed for vendor and hauling trips.
Construction Energy Efficiency/Conservation Measures
Construction equipment used over the approximately eleven-month construction phase would conform to CARB regulations and California emissions standards and is evidence of related fuel efficiencies. There are no unusual project characteristics or construction processes that would require the use of equipment that would be more energy intensive than is used for comparable activities; or equipment that would not conform to current emissions standards (and related fuel efficiencies). Equipment employed in the construction of the project would therefore not result in inefficient wasteful, or unnecessary consumption of fuel.
The project would utilize construction contractors which practice compliance with applicable CARB regulation regarding retrofitting, repowering, or replacement of diesel off-road construction equipment. Additionally, CARB has adopted the Airborne Toxic Control Measure to limit heavy-duty diesel motor vehicle idling in order to reduce public exposure to diesel particulate matter and other Toxic Air Contaminants. Compliance with these measures would result in a more efficient use of construction-related energy and would minimize or eliminate wasteful or unnecessary consumption of energy. Idling restrictions and the use of newer engines and equipment would result in less fuel combustion and energy consumption.
Additionally, as required by California Code of Regulations Title 13, Motor Vehicles, section 2449(d)(3) Idling, limits idling times of construction vehicles to no more than five minutes, thereby minimizing or eliminating unnecessary and wasteful consumption of fuel due to unproductive idling of construction equipment.
Enforcement of idling limitations is realized through periodic site inspections conducted by County building officials, and/or in response to citizen complaints.
Therefore, as the project's construction is required to comply with CARB regulations and does not include the need of construction processes that would require the use of equipment that is more energy efficient, the proposed project annual construction related fuel consumption would not be considered significant.
Operational Energy Demands
Energy consumption in support of or related to project operations would include transportation energy demands (energy consumed by employee and patron vehicles accessing the project site) and facilities energy demands (energy consumed by building operations and site maintenance activities).
Transportation and Operational Fuel Consumption
As stated previously, additional staffing needs for long-term operation and maintenance of the proposed project are not expected. However, a minimal number of daily worker trips are anticipated to conduct routine inspections and ensure proper long-term maintenance. Therefore, the increase in project generated trips is minimal and the project’s transportation and operational energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary.
60 CalEEMod User's Guide Appendix C (April 2022) states that vendor trips are made by a fleet consisting of 50 percent medium trucks (MHDT) and 50 percent heavy trucks (HHDT) and that hauling and onsite truck trips are made by a fleet consisting of 100 percent HHDT.
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Facility Energy Demands (Electricity and Natural Gas)
In 2022, the non-residential sector of the County of Stanislaus consumed approximately 3,219 million kWh of electricity and approximately 141 million therms of gas. 61,62 The project is the installation of approximately 12,000 linear feet of 12-inch diameter pipe and, therefore, project operation would not require any additional consumption of energy or natural gas. Furthermore, any potential energy demands of the proposed project would be comparable to other water distribution projects of similar scale and configuration. Therefore, the project facilities’ energy demands, and energy consumption would not be considered inefficient, wasteful, or otherwise unnecessary.
RENEWABLE ENERGY AND ENERGY EFFICIENCY PLAN CONSISTENCY Regarding federal transportation regulations, the project site is located in an already developed area. Access to/from the project site is from existing roads. These roads are already in place so the project would not interfere with, nor otherwise obstruct intermodal transportation plans or projects that may be proposed pursuant to the ISTEA.
Regarding Pavley (AB 1493) regulations, an individual project does not have the ability to comply or conflict with these regulations because they are intended for agencies and their adoption of procedures and protocols for reporting and certifying GHG emission reductions from mobile sources. The vehicles associated with the proposed project would be required to comply with federal and state fuel efficiency standards; however, as stated previously the project requires a minimal number of vehicle trips during operation.
Regarding the State’s Renewable Energy Portfolio Standards, as applicable, the project would be required to meet or exceed the energy standards established in the California Green Building Standards Code, Title 24, Part 11 (CALGreen). CALGreen Standards require that new buildings reduce water consumption, employ building commissioning to increase building system efficiencies, divert construction waste from landfills, and install low pollutant-emitting finish materials.
As shown in Section 3 above, the proposed project would be consistent with the applicable goals of the CARB Scoping Plan.
CONCLUSIONS
As supported by the preceding analyses, project construction would not result in the inefficient, wasteful or unnecessary consumption of energy. The proposed project does not include any unusual project characteristics or construction processes that would require the use of equipment that would be more energy intensive than is used for comparable activities and is a water supply infrastructure project that is not proposing any additional features that would require a larger energy demand than other projects of similar scale and configuration. The energy demands of the project are anticipated to be accommodated within the context of available resources and energy delivery systems. 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.
Notwithstanding, the project proposes a water supply infrastructure project and will not have any long-term effects on an energy provider’s future energy development or future energy conservation strategies.
61 California Energy Commission, Electricity Consumption by County. https://ecdms.energy.ca.gov/elecbycounty.aspx 62 California Energy Commission, Gas Consumption by County. http://ecdms.energy.ca.gov/gasbycounty.aspx 83 #8..
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California InState
Generation
(GWh)
Percent of
California InState
Generation
Northwest
Imports
(GWh)
Southwest
Imports
(GWh)
Total
Imports
(GWh)
Total
California
Energy Mix
(GWh)
Total
California
Power Mix
273 0.13% 181 5,716 5,897 6,170 2.15%
96,457 47.46% 44 7,994 8,038 104,495 36.38%
65 0.03% - - - 65 0.02%
315 0.15% - - - 315 0.11%
- 0.00% 12,485 7,943 20,428 20,428 7.11%
97,110 47.78% 12,710 21,653 34,363 121,473 45.77%
17,627 8.67% 397 8,342 8,739 26,366 9.18%
14,607 7.19% 10,803 1,118 11,921 26,528 9.24%
73,913 36.37% 10,270 18,668 28,940 131,853 35.81%
5,366 2.64% 771 25 797 6,162 2.15%
11,110 5.47% 253 2,048 2,301 13,412 4.67%
3,005 1.48% 211 13 225 32,230 1.12%
40,494 19.92% 231 8,225 8,456 48,950 17.04%
13,938 6.86% 8,804 8,357 17,161 31,099 10.83%
106,147 52.22% 21,471 28,129 49,599 155,747 54.23%
203,257 100% 34,180 49,782 83,962 287,220 100%
(1) Source: California Energy Commission. 2022 Total System Electric Generation. hhttps://www.energy.ca.gov/data-reports/energyalmanac/california-electricity-data/2022-total-system-electric-generation Table 13
Total Electricity System Power (California 2022)
Geothermal
Small Hydro
Solar
Biomass
Fuel Type
Coal
Natural Gas
Large Hydro
Unspecified Sources of Power
Renewables
Total Thermal and Unspecified
Total Non-GHG and Renewables
Wind
Total Energy
Notes:
Oil
Other (Waste Heat/Petroleum Coke)
Nuclear
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2022 MID Power Mix
30.1%
0%
0%
0.2%
13.9%
16%
0.0%
17.8%
13.6%
1.8%
0.1%
36.6%
100%
(1)
*
https://www.mid.org/about/newsroom/currents/documents/2022%20PCL.pdf Unspecified sources of power means electricity from transactions that are not traceable to specific generation sources.
Natural Gas
Nuclear
Other
Unspecified Sources of power*
Total
Notes:
Wind
Coal
Large Hydroelectric
Table 14
MID 2022 Power Content Mix
Energy Resources
Eligible Renewable
Biomass & Biowaste
Geothermal
Eligible Hydroelectric
Solar
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Number
of Days Offroad Equipment Type2 Amount
Usage
Hours
Horse
Power
Load
Factor
HP
hrs/day
Total Fuel
Consumption
(gal diesel fuel)3
240 Rubber Tired Dozers 1 7 367 0.40 1,028 13,331
240 Tractors/Loaders/Backhoes 5 8 84 0.37 1,243 16,128
240 Scrapers 1 8 423 0.48 1,624 21,072
240 Off-Highway Trucks 1 8 376 0.38 1,143 14,829
240 Plate Compactors 1 8 8 0.43 28 357
240 Excavators 1 8 36 0.38 109 1,420
240 Other Material Handling Equipment 1 8 93 0.40 298 3,861 240 Paving Equipment 1 8 89 0.36 256 3,325
240 Other Construction Equipment 1 8 82 0.42 276 3,574
240 Pumps 2 8 11 0.74 130 1,690
240 Skid Steer Loaders 1 8 71 0.37 210 2,726
240 Surfacing Equipment 1 8 399 0.30 958 12,423
240 Cranes 1 8 367 0.29 851 11,046
105,782
Notes:
(1)
(2)
(3) Using Carl Moyer Guidelines Table D-21 Fuel consumption rate factors (bhp-hr/gal) for engines less than 750 hp. (Source: https://www.arb.ca.gov/msprog/moyer/guidelines/2017gl/2017_gl_appendix_d.pdf) Table 15
Construction Equipment Fuel Consumption Estimates
Phase1
CONSTRUCTION FUEL DEMAND (gallons of diesel fuel)
Per the project applicant, construction equipment is to include: one (1) scraper, five (5) tractors/ loaders/ backhoes, one (1) off-highway trucks, one (1) plate compactor, one (1) excavator, one (1) other material handling equipment, one (1) paving equipment, one (1) other construction equipment, two (2) pumps, one (1) skid steer loaders, one (1) surfacing equipment, one (1) rubber tired dozer, and one (1) crane.
Construction of the proposed project is not anticipated to be phased. Therefore, to provide a conservative scenario, the entirety of the project has been analyzed as occurring in one construction phase with all proposed equipment in operation simultaneously.
Site Preparation
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Number
of Days
Worker
Trips/Day
Trip Length
(miles)
Vehicle Miles
Traveled
Average Vehicle
Fuel Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
240 32 10.8 82,944 26.2 3,167
3,167
Notes:
(1)
(2) Per CalEEMod User's Guide Appendix C (April 2022), CalEEMod assumes that construction work trips are made by a fleet consisting of 25 percent light-duty auto (or passenger car), 50 percent light-duty truck type 1 (LDT1), and 25 percent light duty truck type 2 (LDT2).
Assumptions for the worker trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.1.28 defaults.
Table 16
Construction Worker Fuel Consumption Estimates
Phase
Total Construction Worker Fuel Consumption
Site Preparation
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Number
of Days
Vendor
Trips/Day
Trip Length
(miles)
Vehicle Miles
Traveled
Average Vehicle
Fuel Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
240 2 7.17 3,442 7.0 493
493
Notes:
(1)
(2) Per CalEEMod User's Guide Appendix C (April 2022), CalEEMod assumes vendor trips are made by a fleet consisting of 50 percent medium trucks (MHDT) and 50 percent heavy trucks (HHDT).
Site Preparation
Table 17
Construction Vendor Fuel Consumption Estimates (MHD & HHD Trucks) Phase
Total Construction Vendor Fuel Consumption
Assumptions for the vendor trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.1.28 defaults.
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Number
of Days
Hauling
Trips/Day
Trip Length
(miles)
Vehicle Miles
Traveled
Average Vehicle
Fuel Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
240 2.44 20 11,712 6.1 1,936
1,936
Notes:
(1)
Total Construction Hauling Fuel Consumption
Assumptions for the hauling trip length and vehicle miles traveled are consistent with CalEEMod 2022.1.28 defaults.
Site Preparation
Table 18
Construction Hauling Fuel Consumption Estimates (HHD Trucks) Phase
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6. EMISSIONS REDUCTION MEASURES
CONSTRUCTION MEASURES
Adherence to SJVAPCD Regulation VIII is required.
No construction mitigation measures are required. However, SJVAPCD recommends that, as a condition of project approval, projects in which construction related activities would disturb equal to or greater than 1- acre of surface area include a SJVAPCD approved Dust Control Plan or Construction Notification form before issuance of the first grading permit. The project will disturb approximately 1.67 acres. Therefore, it is recommended that a Dust Control Plan or Construction Notification form be completed for the proposed project.
OPERATIONAL MEASURES
No operational measures are required.
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7. REFERENCES
California Air Resources Board
2008 Resolution 08-43
2008 Recommended Approaches for Setting Interim Significance Thresholds for Greenhouse Gases under the California Environmental Quality Act
2008 Climate Change Scoping Plan, a framework for change. 2011 Supplement to the AB 32 Scoping Plan Functional Equivalent Document 2013 Almanac of Emissions and Air Quality.
Source: https://www.arb.ca.gov/aqd/almanac/almanac13/almanac13.htm 2014 First Update to the Climate Change Scoping Plan, Building on the Framework Pursuant to AB32, the California Global Warming Solutions Act of 2006. May.
2017 California's 2017 Climate Change Scoping Plan. November. 2022 2022 Scoping Plan for Achieving Carbon Neutrality. November 16.
City of Modesto
2019 General Plan 2040. March 5.
Governor’s Office of Planning and Research
2008 CEQA and Climate: Addressing Climate Change Through California Environmental Quality Act (CEQA) Review
2018 CEQA Guideline Sections to be Added or Amended
Intergovernmental Panel on Climate Change (IPCC)
2014 IPCC Fifth Assessment Report, Climate Change 2014: Synthesis Report Office of Environmental Health Hazard Assessment
2015 Air Toxics Hot Spots Program Risk Assessment Guidelines San Joaquin Valley Air Pollution Control District
2000 Environmental Review Guidelines. August.
2009 Final Staff Report Addressing Greenhouse Gas Emissions Impacts Under the California Environmental Quality Act. December 17.
2015 Guidance for Assessing and Mitigating Air Quality Impacts. March 15. 91 #8..
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U.S. Environmental Protection Agency (EPA)
2017 Understanding Global Warming Potentials
(Source: https://www.epa.gov/ghgemissions/understanding-global-warming-potentials) U.S. Geological Survey
2011 Reported Historic Asbestos Mines, Historic Asbestos Prospects, and Other Natural Occurrences of Asbestos in California
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APPENDICES
Appendix A Glossary
Appendix B CalEEMod Model Detailed Report and EMFAC Data Apx-1
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APPENDIX A
GLOSSARY
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AQMP Air Quality Management Plan
BACT Best Available Control Technologies
CAAQS California Ambient Air Quality Standards
CalEPA California Environmental Protection Agency
CARB California Air Resources Board
CCAA California Clean Air Act
CCAR California Climate Action Registry
CEQA California Environmental Quality Act
CFCs Chlorofluorocarbons
CH4 Methane
CNG Compressed natural gas
CO Carbon monoxide
CO2 Carbon dioxide
CO2e Carbon dioxide equivalent
DPM Diesel particulate matter
EPA U.S. Environmental Protection Agency
GHG Greenhouse gas
GWP Global warming potential
HIDPM Hazard Index Diesel Particulate Matter
HFCs Hydrofluorocarbons
IPCC International Panel on Climate Change
LCFS Low Carbon Fuel Standard
LST Localized Significance Thresholds
MTCO2e Metric tons of carbon dioxide equivalent
MMTCO2e Million metric tons of carbon dioxide equivalent MPO Metropolitan Planning Organization
NAAQS National Ambient Air Quality Standards
NOx Nitrogen Oxides
NO2 Nitrogen dioxide
N2O Nitrous oxide
O3 Ozone
OPR Governor’s Office of Planning and Research
PFCs Perfluorocarbons
PM Particle matter
PM10 Particles that are less than 10 micrometers in diameter PM2.5 Particles that are less than 2.5 micrometers in diameter PMI Point of maximum impact
PPM Parts per million
PPB Parts per billion
RTIP Regional Transportation Improvement Plan
RTP Regional Transportation Plan
SJVAPCD San Joaquin Valley Air Pollution Control District SF6 Sulfur hexafluoride
SIP State Implementation Plan
SOx Sulfur Oxides
TAC Toxic air contaminants
VOC Volatile organic compounds
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APPENDIX B
CALEEMOD MODEL DETAILED REPORT AND EMFAC DATA
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19689 Stanislaus Elementary School 1,2,3-TCP Mitigation - CONSTRUCTION ANALYSIS ONLY Detailed Report
Table of Contents1. Basic Project Information
1.1. Basic Project Information1.2. Land Use Types1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds2.2. Construction Emissions by Year, Unmitigated
3. Construction Emissions Details
3.1. Site Preparation (2024) - Unmitigated3.3. Site Preparation (2025) - Unmitigated
4. Operations Emissions Details
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Apx-5
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4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
5. Activity Data
5.1. Construction Schedule5.2. Off-Road Equipment
5.2.1. Unmitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving5.8. Construction Electricity Consumption and Emissions Factors5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
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5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary6.2. Initial Climate Risk Scores6.3. Adjusted Climate Risk Scores6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores7.2. Healthy Places Index Scores7.3. Overall Health & Equity Scores7.4. Health & Equity Measures7.5. Evaluation Scorecard7.6. Health & Equity Custom Measures
8. User Changes to Default Data
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1. Basic Project Information1.1. Basic Project Information Data Field ValueProject Name 19689 Stanislaus Elementary School 1,2,3-TCP Mitigation - CONSTRUCTION ANALYSIS ONLY
Construction Start Date 9/1/2024Lead Agency City of ModestoLand Use Scale Project/siteAnalysis Level for Defaults CountyWindspeed (m/s) 3.10Precipitation (days) 25.4Location 37.711112524016144, -121.02856621462826County StanislausCity UnincorporatedAir District San Joaquin Valley APCDAir Basin San Joaquin ValleyTAZ 2201EDFZ 15Electric Utility Modesto Irrigation DistrictGas Utility Pacific Gas & ElectricApp Version 2022.1.1.28
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special LandscapeArea (sq ft)
Population Description
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—
— 0.00 0.00 1.67 Acre 1.67 Other Asphalt
Surfaces
Project is a ~12,000linear ft pipeline. Temporarydisturbance area of6ft wide x 8 ft deepfor entire 12,000linear feet or ~1.64acres. Five jack &bore pits totaling~0.03 acres ofdisturbance. Totalproject disturbanceis ~1.67 acres.
1.3. User-Selected Emission Reduction Measures by Emissions SectorNo measures selected2. Emissions Summary2.1. Construction Emissions Compared Against ThresholdsCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,Summer(Max)
—————————————————
Unmit. 4.48 41.3 43.4 0.09 1.72 2.95 4.67 1.58 1.27 2.85 — 10,025 10,025 0.41 0.12 1.68 10,073Daily,Winter(Max) —————————————————
Unmit. 4.46 41.3 43.0 0.09 1.72 2.95 4.67 1.58 1.27 2.85 — 9,996 9,996 0.41 0.12 0.04 10,042AverageDaily(Max) —————————————————
Unmit. 1.72 15.3 17.3 0.04 0.61 1.23 1.84 0.56 0.53 1.09 — 4,166 4,166 0.17 0.05 0.28 4,185Annual(Max) —————————————————
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Unmit. 0.31 2.79 3.15 0.01 0.11 0.22 0.34 0.10 0.10 0.20 — 690 690 0.03 0.01 0.05 693
2.2. Construction Emissions by Year, UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily -Summer(Max)
—————————————————
2024 4.48 41.3 43.4 0.09 1.72 2.95 4.67 1.58 1.27 2.85 — 10,025 10,025 0.41 0.12 1.68 10,0732025 4.14 36.6 41.8 0.09 1.46 2.95 4.41 1.35 1.27 2.61 — 10,015 10,015 0.40 0.12 1.58 10,063Daily -Winter(Max) —————————————————
2024 4.46 41.3 43.0 0.09 1.72 2.95 4.67 1.58 1.27 2.85 — 9,996 9,996 0.41 0.12 0.04 10,0422025 4.12 36.7 41.4 0.09 1.46 2.95 4.41 1.35 1.27 2.61 — 9,987 9,987 0.40 0.12 0.04 10,033AverageDaily —————————————————
2024 1.06 9.86 10.3 0.02 0.41 0.70 1.11 0.38 0.30 0.68 — 2,388 2,388 0.10 0.03 0.17 2,3992025 1.72 15.3 17.3 0.04 0.61 1.23 1.84 0.56 0.53 1.09 — 4,166 4,166 0.17 0.05 0.28 4,185Annual — — — — — — — — — — — — — — — — —2024 0.19 1.80 1.87 < 0.005 0.07 0.13 0.20 0.07 0.06 0.12 — 395 395 0.02 < 0.005 0.03 3972025 0.31 2.79 3.15 0.01 0.11 0.22 0.34 0.10 0.10 0.20 — 690 690 0.03 0.01 0.05 693
3. Construction Emissions Details3.1. Site Preparation (2024) - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —
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Daily,Summer(Max)
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Off-RoadEquipment
4.26 40.9 41.5 0.09 1.71 — 1.71 1.58 — 1.58 — 9,537 9,537 0.39 0.08 — 9,570 DustFromMaterialMovement
— — — — — 2.65 2.65 — 1.19 1.19 — — — — — — —
ArchitecturalCoatings
0.06 — — — — — — — — — — — — — — — —
Onsitetruck
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4.26 40.9 41.5 0.09 1.71 — 1.71 1.58 — 1.58 — 9,537 9,537 0.39 0.08 — 9,570 DustFromMaterialMovement
— — — — — 2.65 2.65 — 1.19 1.19 — — — — — — —
ArchitecturalCoatings
0.06 — — — — — — — — — — — — — — — —
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0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 AverageDaily
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Off-RoadEquipment
1.02 9.76 9.90 0.02 0.41 — 0.41 0.38 — 0.38 — 2,277 2,277 0.09 0.02 — 2,285 DustFromMaterialMovement
— — — — — 0.63 0.63 — 0.29 0.29 — — — — — — —
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0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —Off-RoadEquipment
0.19 1.78 1.81 < 0.005 0.07 — 0.07 0.07 — 0.07 — 377 377 0.02 < 0.005 — 378 DustFromMaterialMovement
— — — — — 0.12 0.12 — 0.05 0.05 — — — — — — —
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< 0.005 — — — — — — — — — — — — — — — —
Onsitetruck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — —Daily,Summer(Max) —————————————————
Worker 0.16 0.10 1.88 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 268 268 0.01 0.01 1.14 272Vendor < 0.005 0.06 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 46.1 46.1 < 0.005 0.01 0.12 48.3Hauling < 0.005 0.22 0.05 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 174 174 < 0.005 0.03 0.42 183Daily,Winter(Max) —————————————————
Worker 0.14 0.13 1.44 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 239 239 0.02 0.01 0.03 242Vendor < 0.005 0.07 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 46.1 46.1 < 0.005 0.01 < 0.005 48.2Hauling < 0.005 0.23 0.05 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 174 174 < 0.005 0.03 0.01 182AverageDaily —————————————————
Worker 0.03 0.03 0.36 0.00 0.00 0.06 0.06 0.00 0.01 0.01 — 58.7 58.7 < 0.005 < 0.005 0.12 59.7Vendor < 0.005 0.02 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 11.0 11.0 < 0.005 < 0.005 0.01 11.5Hauling < 0.005 0.05 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 41.5 41.5 < 0.005 0.01 0.04 43.5 Apx-12
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Annual — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 9.72 9.72 < 0.005 < 0.005 0.02 9.88Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 1.82 1.82 < 0.005 < 0.005 < 0.005 1.91Hauling < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 6.87 6.87 < 0.005 < 0.005 0.01 7.21
3.3. Site Preparation (2025) - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Onsite — — — — — — — — — — — — — — — — —Daily,Summer(Max) —————————————————
Off-RoadEquipment
3.93 36.3 40.0 0.09 1.46 — 1.46 1.34 — 1.34 — 9,537 9,537 0.39 0.08 — 9,570 DustFromMaterialMovement
— — — — — 2.65 2.65 — 1.19 1.19 — — — — — — —
ArchitecturalCoatings
0.06 — — — — — — — — — — — — — — — —
Onsitetruck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,Winter(Max)
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3.93 36.3 40.0 0.09 1.46 — 1.46 1.34 — 1.34 — 9,537 9,537 0.39 0.08 — 9,570 DustFromMaterialMovement
— — — — — 2.65 2.65 — 1.19 1.19 — — — — — — —
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uralCoatings
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1.64 15.1 16.7 0.04 0.61 — 0.61 0.56 — 0.56 — 3,975 3,975 0.16 0.03 — 3,989 DustFromMaterialMovement
— — — — — 1.10 1.10 — 0.50 0.50 — — — — — — —
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0.02 — — — — — — — — — — — — — — — —
Onsitetruck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — —Off-RoadEquipment
0.30 2.76 3.04 0.01 0.11 — 0.11 0.10 — 0.10 — 658 658 0.03 0.01 — 660 DustFromMaterialMovement
— — — — — 0.20 0.20 — 0.09 0.09 — — — — — — —
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< 0.005 — — — — — — — — — — — — — — — —
Onsitetruck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — —Daily,Summer(Max) —————————————————
Worker 0.15 0.09 1.73 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 262 262 0.01 0.01 1.05 266Vendor < 0.005 0.06 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 45.3 45.3 < 0.005 0.01 0.12 47.4 Apx-14
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Hauling < 0.005 0.21 0.05 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 171 171 < 0.005 0.03 0.41 179 Daily,Winter(Max)
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Worker 0.13 0.12 1.32 0.00 0.00 0.24 0.24 0.00 0.06 0.06 — 234 234 0.01 0.01 0.03 237Vendor < 0.005 0.07 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 45.3 45.3 < 0.005 0.01 < 0.005 47.3Hauling < 0.005 0.22 0.05 < 0.005 < 0.005 0.05 0.05 < 0.005 0.01 0.02 — 171 171 < 0.005 0.03 0.01 179AverageDaily —————————————————
Worker 0.06 0.04 0.57 0.00 0.00 0.10 0.10 0.00 0.02 0.02 — 100 100 < 0.005 < 0.005 0.19 102Vendor < 0.005 0.03 0.01 < 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 — 18.9 18.9 < 0.005 < 0.005 0.02 19.7Hauling < 0.005 0.09 0.02 < 0.005 < 0.005 0.02 0.02 < 0.005 0.01 0.01 — 71.1 71.1 < 0.005 0.01 0.07 74.5Annual — — — — — — — — — — — — — — — — —Worker 0.01 0.01 0.10 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 16.6 16.6 < 0.005 < 0.005 0.03 16.9Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.13 3.13 < 0.005 < 0.005 < 0.005 3.27Hauling < 0.005 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 11.8 11.8 < 0.005 < 0.005 0.01 12.3
4. Operations Emissions Details4.10. Soil Carbon Accumulation By Vegetation Type4.10.1. Soil Carbon Accumulation By Vegetation Type - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetation
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
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4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) LandUse
ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,Summer(Max)
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Total — — — — — — — — — — — — — — — — —Daily,Winter(Max) —————————————————
Total — — — — — — — — — — — — — — — — —Annual — — — — — — — — — — — — — — — — —Total — — — — — — — — — — — — — — — — —
4.10.3. Avoided and Sequestered Emissions by Species - UnmitigatedCriteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e
Daily,Summer(Max)
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Avoided — — — — — — — — — — — — — — — — —Subtotal — — — — — — — — — — — — — — — — —Sequestered —————————————————
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Subtotal — — — — — — — — — — — — — — — — —
Removed
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Avoided — — — — — — — — — — — — — — — — —Subtotal — — — — — — — — — — — — — — — — —Sequestered —————————————————
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Subtotal — — — — — — — — — — — — — — — — ———————————————————Annual — — — — — — — — — — — — — — — — —Avoided — — — — — — — — — — — — — — — — —Subtotal — — — — — — — — — — — — — — — — —Sequestered —————————————————
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5. Activity Data
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5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase DescriptionSite Preparation Site Preparation 9/1/2024 8/1/2025 5.00 240 —
5.2. Off-Road Equipment5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load FactorSite Preparation Rubber Tired Dozers Diesel Average 1.00 7.00 367 0.40Site Preparation Tractors/Loaders/Back hoes
Diesel Average 5.00 8.00 84.0 0.37
Site Preparation Scrapers Diesel Average 1.00 8.00 423 0.48Site Preparation Off-Highway Trucks Diesel Average 1.00 8.00 376 0.38Site Preparation Plate Compactors Diesel Average 1.00 8.00 8.00 0.43Site Preparation Excavators Diesel Average 1.00 8.00 36.0 0.38Site Preparation Other Material Handling Equipment
Diesel Average 1.00 8.00 93.0 0.40
Site Preparation Paving Equipment Diesel Average 1.00 8.00 89.0 0.36Site Preparation Other Construction Equipment
Diesel Average 1.00 8.00 82.0 0.42
Site Preparation Pumps Diesel Average 2.00 8.00 11.0 0.74Site Preparation Skid Steer Loaders Diesel Average 1.00 8.00 71.0 0.37Site Preparation Surfacing Equipment Diesel Average 1.00 8.00 399 0.30Site Preparation Cranes Diesel Average 1.00 8.00 367 0.29
5.3. Construction Vehicles5.3.1. Unmitigated
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Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation
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Site Preparation Worker 32.0 10.8 LDA,LDT1,LDT2Site Preparation Vendor 2.00 7.17 HHDT,MHDTSite Preparation Hauling 2.44 20.0 HHDTSite Preparation Onsite truck —
— HHDT
5.4. Vehicles5.4.1. Construction Vehicle Control Strategies Control Strategies Applied PM10 Reduction PM2.5 ReductionWater unpaved roads twice daily 55% 55%Limit vehicle speeds on unpaved roads to 25 mph 44% 44%
5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior AreaCoated (sq ft)
Non-Residential Interior AreaCoated (sq ft)
Non-Residential Exterior AreaCoated (sq ft)
Parking Area Coated (sq ft)
Site Preparation 0.00 0.00 0.00 0.00 2,880
5.6. Dust Mitigation5.6.1. Construction Earthmoving Activities Phase Name Material Imported (Cubic
Yards)
Material Exported (CubicYards)
Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Site Preparation 4,680 3,348 345 0.00
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5.6.2. Construction Earthmoving Control Strategies
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Water Exposed Area 2 61% 61%
5.7. Construction Paving
Land Use Area Paved (acres) % AsphaltOther Asphalt Surfaces 1.67 100%
5.8. Construction Electricity Consumption and Emissions FactorskWh per Year and Emission Factor (lb/MWh) Year kWh per Year CO2 CH4 N2O2024 0.00 478 0.03 < 0.0052025 0.00 478 0.03 < 0.005
5.18. Vegetation5.18.1. Land Use Change5.18.1.1. Unmitigated Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year) Apx-20
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6. Climate Risk Detailed Report6.1. Climate Risk SummaryCal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 whichassumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location UnitTemperature and Extreme Heat 21.4 annual days of extreme heatExtreme Precipitation 1.80 annual days with precipitation above 20 mmSea Level Rise — meters of inundation depth
Wildfire 0.00 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures fromobserved historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall ifreceived over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), andconsider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled withextreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 metersWildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical dataof climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. Thefour simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range ofdifferent rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.6.2. Initial Climate Risk Scores Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability ScoreTemperature and Extreme Heat N/A N/A N/A N/AExtreme Precipitation N/A N/A N/A N/ASea Level Rise N/A N/A N/A N/AWildfire N/A N/A N/A N/AFlooding N/A N/A N/A N/ADrought N/A N/A N/A N/ASnowpack Reduction N/A N/A N/A N/AAir Quality Degradation N/A N/A N/A N/A Apx-21
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The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing thegreatest exposure.The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5representing the greatest ability to adapt.The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reductionmeasures.
6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability ScoreTemperature and Extreme Heat N/A N/A N/A N/AExtreme Precipitation N/A N/A N/A N/ASea Level Rise N/A N/A N/A N/AWildfire N/A N/A N/A N/AFlooding N/A N/A N/A N/ADrought N/A N/A N/A N/ASnowpack Reduction N/A N/A N/A N/AAir Quality Degradation N/A N/A N/A N/A The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing thegreatest exposure.The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5representing the greatest ability to adapt.The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reductionmeasures.6.4. Climate Risk Reduction Measures7. Health and Equity Details7.1. CalEnviroScreen 4.0 ScoresThe maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
Indicator Result for Project Census TractExposure Indicators —
AQ-Ozone 66.8
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AQ-PM 54.5
AQ-DPM 19.6Drinking Water 97.8Lead Risk Housing 41.1Pesticides 93.0Toxic Releases 46.1Traffic 26.3Effect Indicators —
CleanUp Sites 0.00Groundwater 2.11Haz Waste Facilities/Generators 3.64Impaired Water Bodies 0.00Solid Waste 0.00Sensitive Population —
Asthma 51.1Cardio-vascular 37.6Low Birth Weights 10.1Socioeconomic Factor Indicators —
Education 49.8Housing 40.3Linguistic 53.9Poverty 60.6Unemployment 52.5
7.2. Healthy Places Index ScoresThe maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census TractEconomic
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Above Poverty 41.44745284
Employed 56.93571154Median HI 43.02579238Education
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Bachelor's or higher 35.41639933High school enrollment 100Preschool enrollment 9.444373155Transportation —
Auto Access 53.75336841Active commuting 10.714744Social —
2-parent households 75.23418452Voting 45.28422944Neighborhood —
Alcohol availability 54.77993071Park access 58.37289876Retail density 37.14872321Supermarket access 57.12819197Tree canopy 67.72744771Housing —
Homeownership 38.44475812Housing habitability 47.76081098Low-inc homeowner severe housing cost burden 50.37854485Low-inc renter severe housing cost burden 73.36070833Uncrowded housing 34.15886052Health Outcomes —
Insured adults 34.59514949Arthritis 20.9
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Asthma ER Admissions 49.1
High Blood Pressure 30.8Cancer (excluding skin) 40.8Asthma 21.6Coronary Heart Disease 31.2Chronic Obstructive Pulmonary Disease 17.9Diagnosed Diabetes 41.8Life Expectancy at Birth 11.6Cognitively Disabled 28.0Physically Disabled 32.1Heart Attack ER Admissions 49.4Mental Health Not Good 29.3Chronic Kidney Disease 35.4Obesity 23.9Pedestrian Injuries 50.1Physical Health Not Good 33.1Stroke 29.9Health Risk Behaviors —
Binge Drinking 48.9Current Smoker 23.5No Leisure Time for Physical Activity 39.0Climate Change Exposures —
Wildfire Risk 0.0SLR Inundation Area 0.0Children 10.6Elderly 64.7English Speaking 56.4Foreign-born 36.4 Apx-25
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19689 Stanislaus Elementary School 1,2,3-TCP Mitigation - CONSTRUCTION ANALYSIS ONLY Detailed Report, 10/4/2024 22 / 23
Outdoor Workers 32.7
Climate Change Adaptive Capacity
—
Impervious Surface Cover 33.4Traffic Density 27.7Traffic Access 0.0Other Indices —
Hardship 63.6Other Decision Support
—
2016 Voting 48.7
7.3. Overall Health & Equity Scores
Metric Result for Project Census TractCalEnviroScreen 4.0 Score for Project Location (a) 38.0Healthy Places Index Score for Project Location (b) 41.0Project Located in a Designated Disadvantaged Community (Senate Bill 535) NoProject Located in a Low-Income Community (Assembly Bill 1550) NoProject Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.7.4. Health & Equity MeasuresNo Health & Equity Measures selected.7.5. Evaluation ScorecardHealth & Equity Evaluation Scorecard not completed.7.6. Health & Equity Custom MeasuresNo Health & Equity Custom Measures created.8. User Changes to Default Data Apx-26
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19689 Stanislaus Elementary School 1,2,3-TCP Mitigation - CONSTRUCTION ANALYSIS ONLY Detailed Report, 10/4/2024 23 / 23
Screen Justification
Construction: Construction Phases Construction anticipated to begin Fall 2024 and be completed by Fall 2025, taking ~11 months to complete. Therefore, assumed a start date of early September 2024 ending early August2025. As stated in Projet Description, project is not anticipated to be phased & contractor willlay ~100 ft of pipeline per day.
Construction: Off-Road Equipment Per project description equipment to include: 1-scraper, 5-tractors/loaders/backhoes, 1-off-highway truck, 1-plate compactor, 1-excavator, 1-other material handling equipment, 1-paving equipment, 1-other construction equipment, 2-pumps, 1-skid steer loader, 1-surfacingequipment, 1-rubber tired dozer, & 1-crane. To be conservative, it was assumed that allconstruction equipment would be in operation during the duration of project construction.Project to include ~3,348 CY export & ~4,680 CY import.
Construction: Trips and VMT Per Project Description, up to 16 construction workers working per day, which results in ~32 one-way trips per day. To be conservative, 2 vendor trips added to account for water trucks.
Construction: Architectural Coatings Traffic coating would occur in roadway where pipeline is being installed. Pipeline is 12,000 LF x 4 ft wide which equals a potential for up to 48,000 sf in roadway ROW. Per CalEEMod User'sGuide(2022) Appendix C Section 4.8, CalEEMod assumes ~6% of parking lot areas will be coated.Therefore, ~2,880 sf assumed for potential coating for roadway areas.
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Source: EMFAC2021 (v1.0.2) Emissions Inventory
Region Type: Air BasinRegion: San Joaquin ValleyCalendar Year: 2024Season: AnnualVehicle Classification: EMFAC2007 CategoriesUnits: miles/day for CVMT and EVMT, trips/day for Trips, kWh/day for Energy Consumption, tons/day for Emissions, 1000 gallons/day for Fuel Consumption Region Calendar Year Vehicle Category Model Year Speed Fuel Population Trips Energy Consumption Fuel Consumption Fuel Consumption Total Fuel Consumption Total VMT Total VMT Miles Per Gallon Vehicle Class San Joaquin Valley 2024 HHDT Aggregate Aggregate Gasoline 14.26923503 285.4989 0 0.208856287 208.8562873 1853178.413 705.1751657 11208126.26 6.05 HHDT San Joaquin Valley 2024 HHDT Aggregate Aggregate Diesel 75540.42982 1311827 0 1832.446977 1832446.977 11080187.54 San Joaquin Valley 2024 HHDT Aggregate Aggregate Electricity 212.263297 3559.011 46923.73868 0 0 25610.0205San Joaquin Valley 2024 HHDT Aggregate Aggregate Natural Gas 1559.052033 13418.38 0 20.52257967 20522.57967 101623.5225San Joaquin Valley 2024 LDA Aggregate Aggregate Gasoline 1396040.642 6460217 0 1879.142372 1879142.372 1910877.745 55651025.96 60215384.7 31.51 LDA San Joaquin Valley 2024 LDA Aggregate Aggregate Diesel 3574.544528 15178.67 0 2.56390661 2563.90661 112884.9583 San Joaquin Valley 2024 LDA Aggregate Aggregate Electricity 56530.82162 283590.1 1044501.358 0 0 2705383.603 San Joaquin Valley 2024 LDA Aggregate Aggregate Plug-in Hybrid 36607.58071 151372.3 264938.2613 29.17146597 29171.46597 1746090.185 San Joaquin Valley 2024 LDT1 Aggregate Aggregate Gasoline 132549.9964 568365.8 0 177.1498941 177149.8941 177295.2602 4330431.678 4346098.934 24.51 LDT1 San Joaquin Valley 2024 LDT1 Aggregate Aggregate Diesel 70.12019936 201.4517 0 0.035743248 35.74324775 897.8907497San Joaquin Valley 2024 LDT1 Aggregate Aggregate Electricity 162.1298891 800.9995 2897.681935 0 0 7505.343227 San Joaquin Valley 2024 LDT1 Aggregate Aggregate Plug-in Hybrid 139.537005 576.9855 1210.906009 0.109622843 109.6228427 7264.022186 San Joaquin Valley 2024 LDT2 Aggregate Aggregate Gasoline 627210.9415 2907658 0 1032.721557 1032721.557 1038442.923 24738370.26 25151792.29 24.22 LDT2 San Joaquin Valley 2024 LDT2 Aggregate Aggregate Diesel 1735.202254 8281.607 0 2.195003587 2195.003587 74255.90809 San Joaquin Valley 2024 LDT2 Aggregate Aggregate Electricity 3211.923975 16415.56 44992.87026 0 0 116536.9221 San Joaquin Valley 2024 LDT2 Aggregate Aggregate Plug-in Hybrid 4455.774394 18424.63 35711.20912 3.526362907 3526.362907 222629.1991 San Joaquin Valley 2024 LHDT1 Aggregate Aggregate Gasoline 61035.20702 909333.6 0 231.5879776 231587.9776 364615.1665 2183997.723 4295909.202 11.78 LHDT1 San Joaquin Valley 2024 LHDT1 Aggregate Aggregate Diesel 58964.19692 741695.4 0 133.0271889 133027.1889 2101668.864San Joaquin Valley 2024 LHDT1 Aggregate Aggregate Electricity 136.6778687 1909.303 6662.793509 0 0 10242.615 San Joaquin Valley 2024 LHDT2 Aggregate Aggregate Gasoline 9690.581586 144375.2 0 40.4212088 40421.2088 102414.741 338996.5257 1150157.856 11.23 LHDT2 San Joaquin Valley 2024 LHDT2 Aggregate Aggregate Diesel 22034.0548 277160.7 0 61.99353223 61993.53223 808649.4788 San Joaquin Valley 2024 LHDT2 Aggregate Aggregate Electricity 35.37650647 468.2778 1607.510525 0 0 2511.85159 San Joaquin Valley 2024 MCY Aggregate Aggregate Gasoline 72131.45693 144262.9 0 9.662809904 9662.809904 9662.809904 397968.797 397968.797 41.19 MCY San Joaquin Valley 2024 MDV Aggregate Aggregate Gasoline 603341.7501 2720908 0 1115.375628 1115375.628 1132266.797 21447403.32 22086040.56 19.51 MDV San Joaquin Valley 2024 MDV Aggregate Aggregate Diesel 9136.287951 42317.49 0 14.22000987 14220.00987 349976.2265 San Joaquin Valley 2024 MDV Aggregate Aggregate Electricity 3563.058628 18203.02 49844.84223 0 0 129104.1106 San Joaquin Valley 2024 MDV Aggregate Aggregate Plug-in Hybrid 3361.829524 13901.17 24569.64142 2.671159153 2671.159153 159556.9045 San Joaquin Valley 2024 MH Aggregate Aggregate Gasoline 8368.221093 837.1568 0 16.64893506 16648.93506 20398.43966 73441.61156 108727.0967 5.33 MHSan Joaquin Valley 2024 MH Aggregate Aggregate Diesel 4046.860917 404.6861 0 3.749504597 3749.504597 35285.48513 San Joaquin Valley 2024 MHDT Aggregate Aggregate Gasoline 4102.384281 82080.5 0 49.54614262 49546.14262 248592.3107 232785.3097 1963841.913 7.90 MHDT San Joaquin Valley 2024 MHDT Aggregate Aggregate Diesel 35629.61693 427304.9 0 196.3595694 196359.5694 1706105.994San Joaquin Valley 2024 MHDT Aggregate Aggregate Electricity 105.3935739 1334.617 6566.449551 0 0 5970.977911 San Joaquin Valley 2024 MHDT Aggregate Aggregate Natural Gas 358.0916483 2773.915 0 2.686598731 2686.598731 18979.63179 San Joaquin Valley 2024 OBUS Aggregate Aggregate Gasoline 1293.408525 25878.52 0 13.68661197 13686.61197 21790.1299 65025.8265 119780.7772 5.50 OBUS San Joaquin Valley 2024 OBUS Aggregate Aggregate Diesel 694.8682592 8946.252 0 7.99908921 7999.08921 53775.81972San Joaquin Valley 2024 OBUS Aggregate Aggregate Electricity 2.098518815 41.98716 239.8267442 0 0 216.2366432 San Joaquin Valley 2024 OBUS Aggregate Aggregate Natural Gas 13.05684082 116.2059 0 0.104428721 104.428721 762.8943354San Joaquin Valley 2024 SBUS Aggregate Aggregate Gasoline 1103.053416 4412.214 0 6.838528214 6838.528214 20698.91048 67587.25208 173519.2719 8.38 SBUSSan Joaquin Valley 2024 SBUS Aggregate Aggregate Diesel 3904.184742 56532.6 0 10.65785774 10657.85774 87343.2412 San Joaquin Valley 2024 SBUS Aggregate Aggregate Electricity 11.90280977 160.2921 341.1750972 0 0 323.8628191San Joaquin Valley 2024 SBUS Aggregate Aggregate Natural Gas 724.3049401 10487.94 0 3.202524526 3202.524526 18264.91575 San Joaquin Valley 2024 UBUS Aggregate Aggregate Gasoline 323.2416707 1292.967 0 4.368511345 4368.511345 15987.84296 22139.35711 106366.3689 6.65 UBUS San Joaquin Valley 2024 UBUS Aggregate Aggregate Diesel 235.9037236 943.6149 0 2.434681385 2434.681385 22916.36038 San Joaquin Valley 2024 UBUS Aggregate Aggregate Electricity 30.74245853 122.9698 3180.789994 0 0 1824.244126San Joaquin Valley 2024 UBUS Aggregate Aggregate Natural Gas 562.7442454 2250.977 0 9.184650232 9184.650232 59486.40732 Apx-28
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GANDDINI GROUP INC.
714.795.3100 | ganddini.com
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2201 N. Grand Avenue #10098 | Santa Ana, CA 92711-0098 | (714) 716-5050 www.ELMTConsulting.com
October 5, 2024
ARDURRA
Contact: Lori Trottier
3737 Birch Street
Newport Beach, California 92660
SUBJECT: Biological Resources Assessment for the Proposed Stanislaus Elementary School 1, 2, 3-TCP Mitigation Project Located in Stanislaus County, California Introduction
This report contains the findings of ELMT Consulting’s (ELMT) biological resources assessment for Stanislaus Elementary School 1, 2, 3-TCP Mitigation Project (project, project site), located in Stanislaus County, California. The habitat assessment was conducted by biologist Jacob H. Lloyd Davies on December 5, 2023, to document baseline conditions and assess the potential for special-status1 plant and wildlife species to occur within the project site that could pose a constraint to implementation of the proposed project. Special attention was given to the suitability of the project site to support special-status plant and wildlife species identified by the California Department of Fish and Wildlife’s (CDFW) California Natural Diversity Database (CNDDB), and other electronic databases as potentially occurring in the general vicinity of the project. Additionally, the report also addresses resources protected under the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (FGC), federal Clean Water Act (CWA) regulated by the United States Army Corps of Engineers (Corps) and Regional Water Quality Control Board (Regional Board) respectively, and Section 1602 of the FGC administered by CDFW.
Project Location
The proposed project site is generally located north and east of State Route 99, south of the Stanislaus River, and west of State Route 108 in unincorporated Stanislaus County, California. The project is located approximately 0.5 miles north of the City Limits of Modesto, within part of Modesto’s approved Sphere of Influence (SOI), and also within the Study Area of the City’s Water Master Plan. Specifically, the project occupies an east/west oriented right-of-way alignment, within Kiernan Avenue, between Sections 1 (Township 3 South, Range 8 East) and 36 (Township 2 South, Range 8 East), and Sections 6 (Township 3 South, Range 9 East) and 31 (Township 2 South, Range 9 East) Mt. Diablo Base and Meridian. The alignment continues briefly south before terminating on Dale Road at the western end and continues briefly both south and north along Tully Road before terminating at the eastern end. Refer to Exhibits 1-3 in Attachment A.
Project Description
The proposed Project is the consolidation of Stanislaus Union School District (SUSD) service area (Water 1 As used in this report, “special-status” refers to plant and wildlife species that are federally and State listed, proposed, or candidates; plant species that have been designated with a California Native Plant Society Rare Plant Rank; wildlife species that are designated by the CDFW as fully protected, species of special concern, or watch list species; and specially protected natural vegetation communities as designated by the CDFW.
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