kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
MEMORANDUM
To: Dana Privitt, Kimley-Horn and Associates, Inc.
From: Ace Malisos, Kimley-Horn and Associates, Inc.
Date: November 20, 2023
Subject: Clinton Keith Road and Mitchell Road Shopping Center Project , Murrieta, CA – Cumulative Gas Station Air Quality Analysis
PURPOSE
The purpose of this memorandum is to identify cumulative gas station air quality impacts associated with Clinton Keith Road and Mitchell Road Shopping Cente r Project (Project), located in the City of Murriet a, California (City).
PROJECT LOCATION
The project site is generally located north of Clin ton Keith Road and east of Mitchell Road in the Cit y of Murrieta, County of Riverside. The project site enc ompasses approximately 5.24 acres and is currently vacant. The project site is approximately 0.3 mile west of Interstate 215 (I-215) and approximately 2. 7 miles northeast of Interstate 15 (I-15).
PROJECT DESCRIPTION
The proposed Project assumes the subdivision of approximately 5.24 acres into three parcels to allow for the development of the two southernmost parcels for commercial uses. Therefore, the development area assumed in this analysis is 2.3 acres. The proposed Project is a commercial development composed of a convenience store and gasoline station, automated car wash, and drive-thru coffee store; refer to Exhibit 1: Site Plan.
Convenience Store and Gasoline Station
The convenience store would consist of approximatel y 3,700 square feet (sf), generally located on the northwestern portion of the project site. The gas s tation would include 12 fueling pumps, located to t he south of the convenience store.
Car Wash
The approximate 1,458-sf automated drive-thru car w ash would be located directly north of the convenience store. The car wash would include a con veyor wash tunnel with one vacuum and one dryer system. Overall, the car wash is anticipated to consume approximately 150,000 gallons of water per year.
Drive-thru Coffee Store
The proposed drive-thru coffee store would consist of approximately 886 sf. The coffee store would be located on the southeastern portion of the project site. The drive-thru entrance would be located to t he
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
northeast of the building and the drive-thru exit would be located on the western side of the building. An approximate 336-sf outdoor seating area would be situated to the east of the coffee store.
Project Parking and Circulation
The Project would provide 33 parking stalls, with vehicle parking located throughout the project site. The property owner has an existing reciprocal access ag reement with the property owner to the east of the project site (the location of the Del Taco restaura nt). Vehicular access for the project site would be provided via one existing driveway on Clinton Keith Road associated with the Del Taco restaurant east of the project site that would continue to be a right- in-right-out only driveway; one proposed driveway o n Clinton Keith Road; one proposed driveway on Mitchell Road; and one proposed driveway on Sierra Lane.
The proposed driveway on Clinton Keith Road would b e an “Entrance Only” driveway. The proposed driveways on Mitchell Road and Sierra Lane would be full access driveways. All proposed driveways would be unsignalized.
Project Construction
Construction of the proposed Project is expected to commence in 2024 with a construction duration of approximately 12 months and would be completed in o ne phase. Total grading for the proposed Project is estimated to require approximately 12,252 cubic yards of cut and approximately 12,252 cubic yards of fill; earthwork is expected to balance on site.
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
Exhibit 1: Site Plan
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
REGULATORY SETTING
Beginning in 1988, emissions from gas stations were significantly reduced due to air quality regulatio ns requiring reformulated gasoline and emission control technology. Data from the California Air Resources Board’s (CARB) statewide ambient air monitoring net work shows that concentrations of benzene, the most toxic of the gas station emissions, have decreased by approximately 90 percent since 1989. 1 Gasoline Dispensing Facility Regulations
Since 2001, CARB has adopted a number of significan t enhancements to gasoline dispensing facilities' (GDFs) vapor recovery systems. These efforts are ne cessary to ensure the continued effective operation of the vapor recovery systems during the transfer and dispensing of gasoline at these facilities.
Vapor recovery systems collect gasoline vapors that would otherwise escape into the atmosphere during fuel delivery to the underground storage tanks (Phase I) or fuel storage and vehicle fueling (Phase II). The Enhanced Vapor Recovery (EVR) regulations became state law on April 1, 2001. These regulations provide more stringent requirements for vapor recovery systems in order to reduce gasoline vapor emissions.
State and federal vapor recovery regulations that address gasoline and gas stations include the following:
In 1988, the Benzene Airborne Toxic Control Measure (ATCM) 2 required all existing and new gas
stations with annual throughput 3 greater than 480,000 gallons to install vapor recovery systems 4 by 1991.
From 1995 to 2005, national standards required On-B oard Refueling Vapor Recovery (ORVR) to be phased in on all passenger cars and trucks.
In 2001, the Certification Procedure for Vapor Recovery Systems at Gasoline Dispensing Facilities (CP-201) 5 required enhanced vapor recovery (EVR) systems to be phased in for existing gas stations in state ozone nonattainment areas 6 and new stations statewide. CARB certification procedures have been used to specify performance st andards for gas station vapor recovery systems since 1975.
In 2003, California’s Phase 3 Reformulated Gasoline (CaRFG Phase 3) Regulations 7 lowered Reid Vapor Pressure requirements on gas used in motor vehicles below the national standard. In 2015, specifications for Enhanced Conventional ( ECO) Nozzles 8 were approved for non-retail gas stations.
1 California Air Pollution Control Officers Associat ion, Gasoline Service Station Industrywide Risk Assessme nt Technical Guidance Manual , 2021.
2 California Code of Regulations, Title 17 § 93101.
3 Annual throughput is the amount of gas dispensed at a gas station in one year. 4 On Board Refueling Vapor Recovery is a vehicle sy stem that captures gasoline vapor emissions during vehicle fueling. 5 California Air Resources Board, Certification procedure for Vapor Recovery Systems at Gasoline Dispensing Facilities (CP-201) , April 23, 2015, available at: https://ww2.arb.ca.gov/sites/default/files/2022-03/cp201%20effective%20040122.pdf, accessed June 2023. 6 A state ozone nonattainment area is an area with ozone levels above the state air quality standard. 7 California Code of Regulations, Title 13 § 2260.
8 Enhanced Conventional (ECO) Nozzles reduce liquid gasoline emissions due to gas spilling on the grou nd after vehicle fueling, or spillage.
ECO nozzles allow only three drops of liquid gasoline to spill from the nozzle.
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
In 2018, CARB approved specifications for Enhanced ORVR-Vehicle Recognition (EOR) nozzles 9 for gas stations with vapor assist control systems.
In 2018, CARB approved amendments to specifications for fill pipes 10 and openings of motor vehicle fuel tanks.
CARB Air Quality and Land Use Handbook
The CARB Air Quality and Land Use Handbook (2005) provides recommendations for siting new sensitive land uses in proximity to gasoline dispensing facilities. CARB notes that the cancer risk for a typical gasoline dispensing facility is likely to be less than 10 in a million at the fence line under urban air disper sion conditions. However, CARB recommends the following land use buffers:
Typical Gas Dispensing Facilities (annual throughpu t less 3.6 million gallons) : Avoid siting new sensitive land uses within 50 feet of typical gas d ispensing facilities. CARB developed the buffer distance based on statistics reported in their staff reports on Enhanced Vapor Recovery. Large Gasoline Dispensing Facility (annual throughput of 3.6 million gallons per year or greater) :
Avoid siting new sensitive land uses within 300 feet of a large gasoline dispensing facility. The risk levels for large gasoline dispensing facilities wit h a throughput of 3.6 million gallons per year is about 10 in one million at a distance of 50 feet fr om the fence line. At nine million gallons per year, the potential risk could be around 25 in one million at 50 feet, dropping to about five in one million at 300 feet.
Gasoline Service Station Industrywide Risk Assessment Technical Guidance CARB and the California Air Pollution Control Officers Association (CAPCOA) developed the 2021 Gasoline Service Station Industrywide Risk Assessment Technical Guidance Manual (Technical Guidance) based on health analyses conducted to evaluate the health im pacts of emissions from gasoline service stations operating throughout the state. The Technical Guida nce provides an update to the CAPCOA Air Toxics “Hot Spots” Program Gasoline Service Station Indust rywide Risk Assessment Guidelines (1997). The Technical Guidance also provides recommended proced ures for preparing gas station emission inventories and HRAs to meet the requirements of individual facilities subject to Assembly Bill 2588.
Gasoline Service Station Industrywide Risk Assessment Supplemental Policy Guidance Document CARB developed the 2022 Gasoline Service Station Industrywide Risk Assessme nt Supplemental Policy Guidance Document (Supplemental Policy Guidance or Guidance) to provide recommendations regarding public policy for gas stations and discuss potential community-scale health impacts caused by gas station emissions. The Supplemental Policy Guidance analyzed various scenarios including multiple gas stations.
Single Gas Stations. The Guidance notes that the ca ncer risk from gas stations significantly decreases as the receptor moves further from the source. For a s ingle gas station, cancer risk drops by about half the value from 10 to 20 meters (33 to 66 feet) away from the source, and quickly drops to below 1 chance per million at about 60 to 70 meters (197 to 230 feet).
9 Enhanced ORVR Vehicle Recognition (EOR) nozzles re duce gasoline vapor emissions during vehicle fuelin g by forming a tight seal at the vehicle/nozzle interface.
10 A fill pipe is part of a vehicle fueling system t hat connects the gas cap to the fuel tank.
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
Multiple Gas Stations. CARB included an analysis of four gas three million gallon per year stations (one at each corner of the intersection). CARB found for th e four-gas station scenario, that the 100-meter (32 8- foot) separation distance in urban conditions, the zones of impact for each station interact with each other at cancer risks of 5 to 10 chances per million but no longer impact each other as the separation dista nce increases. For rural conditions, the zones of impact for each station at cancer risks of 5 to 10 chances per million completely separate at a separation distance of 200 meters (656 feet).
South Coast Air Quality Management District Rules
The gasoline station is subject to and required to comply with SCAQMD Rules and permits identify a maximum annual throughput allowed based on specific fuel storage and dispensing equipment that is proposed by the operator.
Rule 201 – Permit to Construct requires a permit prior to the installation of any equipment “the use of which may cause the issuance of air contamin ants...”. SCAQMD Regulation II, List and Criteria Identifying Information Required of Applic ants Seeking a Permit to construct from the South Coast Air Quality Management District, provides the requirements for the application for a Permit to Construct. SCAQMD Rule 203, Permit to Ope rate, requires a permit following the completion of construction permitted by the Permit to Construct. Rule 203 – Permit to Operate states that a person shall not operate or use any equipment or agricultural permit unit, the use of which may cause the issuance of air contaminants, or the use of which may reduce or control the issuance of air contaminants, without first obtaining a written permit to operate from the Executive Officer or except as provided in Rule 202. Rule 461 – Gasoline Transfer and Dispensing requires testing of vapor recovery systems for gasoline dispensing facilities from certified vapor recovery testing companies and contractors.
This rule applies to the transfer of gasoline from any tank truck, trailer, or railroad tank car into any stationary storage tank or mobile fueler, and f rom any stationary storage tank or mobile fueler into any mobile fueler or motor fuel tank.
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
CUMULATIVE IMPACTS
California Environmental Quality Act Guidelines
Under the California Environmental Quality Act (CEQ A) Guidelines, “a cumulative impact consists of an impact which is created as a result of the combinat ion of the project evaluated together with other projects causing related impacts” (14 CCR §15130(a) (1)). According to CEQA, an Environmental Impact Report (EIR) must discuss cumulative impacts if the incremental effect of a project, combined with the effects of other projects is “cumulatively consider able” (14 CCR §15130(a)). That section defines “cumulatively considerable” to mean “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” (14 CCR 15065) . Together, these projects compose the cumulative scenario which forms the basis of the cumulative impact analysis.
For purposes of this analysis, the proposed Project would cause a cumulatively considerable and therefore significant cumulative impact if:
The cumulative effects of other past, current, and probable future projects without the Project are not significant and the Project’s incremental impact is substantial enough, when added to the cumulative effects, to result in a significant impact.
The cumulative effects of other past, current, and probable future projects without the Project are already significant and the Project would result in a cumulatively considerable contribution to the already significant effect. The standards used herein to determine whether the contribution is cumulatively considerable include the existing baseline environmental conditions, and whether the Project would cause a substantial increase in i mpacts, or otherwise exceed an established threshold of significance.
CEQA Guidelines Section 15064(h)(4) provides that t he mere existence of significant cumulative impacts caused by other projects alone shall not constitute substantial evidence that the proposed project’s incremental effects are cumulatively considerable (14 CCR 15064(h)(4)).
South Coast Air Quality Management District Thresholds
Criteria Pollutant Emissions Thresholds. The SCAQMD ’s approach of using mass emissions thresholds is key to determining whether a project’s individual e missions would result in a cumulatively considerabl e adverse contribution to the South Coast Air Basin’s existing air quality conditions. Appendix D of the SCAQMD White Paper on Potential Control Strategies to Addr ess Cumulative Impacts from Air Pollution (2003) notes that projects that result in emissions that do not exceed the project-specific SCAQMD regional thresholds of significance should result i n a less than significant impact on a cumulative ba sis unless there is other pertinent information to the contrary. If a project’s emissions are estimated to be less than the thresholds, the project would not be expected to result in a cumulatively considerable contribution to the significant cumulative impact.
Additionally, the SCAQMD Air Quality Management Pla n (AQMP) accounts for projected increases in air pollutant emissions, including construction emissions, resulting from regional growth anticipated in local land use plans such as general plans and regional t ransportation plans. Overall, the AQMP must
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
demonstrate that the increase in emissions will be more than offset through the implementation of AQMP control measures.
Toxic Air Contaminants. Emissions of toxic air contaminants (TACs) generally have localized effects. As the SCAQMD’s health risk exposure threshold of signific ance from stationary source TACs is based on the incremental increase in health risk from a project’ s TAC emissions, the SCAQMD considers implementation of the project-level mitigation requ irements to be sufficient for a finding of less tha n cumulatively considerable for cumulative impacts of TACs. However, to make this finding, it is assumed that a project would comply with all applicable emi ssion limits and mitigation measures required by th e U.S. Environmental Protection Agency (U.S. EPA), CA RB, SCAQMD rules and regulations, and local ordinances. Therefore, the project-level threshold of significance for evaluating stationary source TA Cs generated by a project should also be used to deter mine whether a project’s stationary source TAC emissions are cumulatively considerable.
CUMULATIVE GAS STATION AIR QUALITY IMPACTS
Geographic Context
Cumulative effects can generally be geographically classified as localized, site-specific issues, and regional level issues. The geographic context of cumulative air quality is the South Coast Air Basin (SCAB), wh ich includes the non-desert portions of Los Angeles, Ri verside, and San Bernardino counties, as well as al l of Orange County. Air quality is impacted by topograph y, dominant air flows, atmospheric inversions, location, and season; therefore, the SCAB represents the area most likely to be impacted by air emissions.
By its very nature, air pollution is largely a cumu lative impact. Ambient air quality standards are violated or approach nonattainment levels due to past develo pment, and attainment of standards can be jeopardized by increasing emissions-generating activity in the region. Although a project’s emissions may be individually limited, they may be cumulatively c onsiderable when taken in combination with past, present, and future development projects.
However, a smaller geographic context is appropriate for the localized effects of air quality. For localized effects, a smaller radius of the Project’s cumulati ve impacts have been conservatively analyzed using a radius of approximately 1,300 feet. There is one existing gas station and one proposed gas station within the vicinity of the project site, which were conser vatively determined to have the potential to intera ct with the proposed Project:
Existing ARCO AM/PM Gas Station : The existing gas station is located at 27698 Clinton Keith Road and northwest of the Clinton Keith Road and I-15 southbound ramp intersection. The existing gas station includes 12 fueling positions, which are lo cated approximately 1,290 feet east of the proposed Project’s fuel pumps.
Approved Gas Station (across Clinton Keith Road) : The approved future gas station is located at the southwest corner of Clinton Keith Road and McElwain Road. The approved project includes a service station with 12 fueling positions, a 3,734-sf convenience store, and a 1,295-sf automated car wash with approximately 27 parking spaces on approximately 1.8 acres. The fuel pumps would be located approximately 750 feet southeast of the proposed Project’s fuel pumps.
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
Cumulative Construction Emissions
Criteria Pollutants. The SCAB is designated nonatta inment for ozone (O 3), PM 10 , and PM 2.5 for State
standards, partial nonattainment for lead, and nona ttainment for O 3 and PM 2.5 for federal standards. As discussed in the Project’s Air Quality Analysis (June 2023), the Project’s construction-related emissions by themselves would not exceed the SCAQMD significance thresholds for criteria pollutants.
Therefore, the Project’s cumulative construction im pacts would be less than significant. Project construction would comply with regulatory requireme nts, including SCAQMD Rule 403 (dust control).
SCAQMD rules, mandates, and compliance with adopted AQMP emissions control measures would also be imposed on construction projects throughout the SCAB, which would include related cumulative projects.
Construction Toxic Air Contaminants. Similar to the Project, the greatest potential for TAC emissions at each related project would generally involve diesel particulate emissions associated with heavy equipment operations during grading and earthwork a ctivities. According to SCAQMD methodology, health effects from carcinogenic air toxics are usu ally described in terms of individual cancer risk.
Individual cancer risk is the likelihood that a person exposed to concentrations of TACs over a lifetime will contract cancer, based on the use of standard risk-assessment methodology.
Based on SCAQMD guidance, individual construction p rojects that exceed the SCAQMD’s thresholds for project specific impacts would cause a cumulatively considerable increase in emissions for those pollutants for which the SCAB is non-attainment. As shown in the Project Air Quality Analysis, construction emissions would not exceed any of the SCAQMD’s regi onal or localized significance thresholds.
Additionally, the Project’s Health Risk Assessment (June 2023) determined that the health risk from TA C exposure would be less than significant. Therefore, the Project’s contribution to cumulative air quali ty would not be cumulatively considerable. Cumulative construction impacts would be less than significant.
Cumulative Operational Impacts
Criteria Pollutants. The SCAQMD has not established separate significance thresholds for cumulative operational emissions. The nature of air emissions is largely a cumulative impact. As a result, no sin gle project is sufficient in size to, by itself, result in nonattainment of ambient air quality standards. Instead, individual project emissions contribute to existing cumulatively significant adverse air quality impacts.
The SCAQMD developed the operational thresholds of significance based on the level above which individual project emissions would result in a cumu latively considerable contribution to SCAB’s existi ng air quality conditions. According to the SCAQMD, if an individual project results in criteria pollutan t emissions that exceed SCAQMD thresholds, then the p roject would also result in a cumulatively considerable net increase. Therefore, a project tha t exceeds the SCAQMD operational thresholds would also be a cumulatively considerable contribution to a significant cumulative impact and, inversely, emission volumes below the SCAQMD operational thresholds are not cumulatively considerable.
As discussed in the Project’s Air Quality Analysis (June 2023), the Project’s operational emissions (including mobile, area, energy, and gas station so urces) by themselves would not exceed the SCAQMD significance thresholds for criteria pollutants. Th erefore, the Project’s operational emissions would not
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
result in a cumulatively considerable contribution to significant cumulative air quality impacts.
Additionally, adherence to SCAQMD rules and regulat ions would alleviate potential impacts related to cumulative conditions on a project-by-project basis . Project operations would not contribute a cumulatively considerable net increase of any nonattainment criteria pollutant.
Operational Toxic Air Contaminants. The new fuel fa cility would require permit to construct and permit to operate approval from the SCAQMD, which will rev iew the facility design and location for compliance with SCAQMD standards for criteria pollutants and air quality. All tanks and dispensers would be equipped with the latest Phase I and Phase II Enhanced Vapor Recovery (EVR) air pollution control equipment technology per CARB regulations. The Phase I EVR equipment controls the vapors in the return path from the tanks back to the tanker truck during offloading filling operations. Phase I EVR systems are 98 percent effective in controlling fugitive emissions from es caping into the environment. The Phase II EVR equipment, which also includes “in-station diagnost ics,” controls and monitors the vapors in the retur n path from the vehicles back to the tanks. Phase II EVR systems are 95 percent effective in controlling fugitive emissions from escaping into the environme nt. Therefore, the operations expected to occur at the proposed fueling and maintenance facility would not emit toxic chemicals in any significant quantity.
As such, TAC emission impacts during operation of the Project and related cumulative projects would be controlled and captured.
A health risk assessment was prepared for the appro ved gas station across Clinton Keith Road and determined that health impacts would be below SCAQMD thresholds. The proposed Project’s Health Risk Assessment (June 2023) also determined that health risk from gas station TAC exposure would be less than significant. Therefore, the Project’s contribution to cumulative air quality would not be cumulatively considerable and cumulative operational impacts would be less than significant.
Project Specific Cumulative Buffer Distances
Based on the CARB Air Quality and Land Use Handbook , gas station emissions are reduced to a less than significant level at 50 feet for average gas statio ns (with an annual throughput of less than 3.6 mill ion gallons per year) and 300 feet for large gas statio ns (with a throughput of 9 million gallons per year or greater). The proposed Project would have an initial throughput of approximately 2.4 million gallons per year and a maximum throughput of approximately 3.0 million gallons per year. Therefore, a buffer distance of 50 feet from each gas station is appropriate for the Project.
As noted above, the CARB Industrywide Risk Assessment Supplemental Policy Guidance Document (2022) analyzed four gas stations (one at each corner of a n intersection) and determined that that with a the 100-meter (328-foot) separation distance, the zones of impact for each station interact with each othe r at cancer risks of 5 to 10 chances per million (i.e ., less than the SCAQMD’s threshold). The gas stati ons would no longer impact each other as the separation distance increases.
Exhibit 2: Cumulative Project Locations shows the locations of the proposed Project as well as the existing ARCO gas station and the approved gas station. As depicted on Exhibit 2 , the proposed Project’s gasoline dispensing pumps would be approximately 750 feet from the gasoline dispensing pumps at the approved Gas Station (across Clinton Keith Road) cumulative project. Additionally, the Project’s pumps are approximately 1,290 feet from the existing ARCO cum ulative project’s gasoline dispensing pumps.
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
Furthermore, Exhibit 2 shows that none of the surrounding sensitive recep tors (residences and future daycare) would be within 328 feet of more than one gas station. As noted above, the CARB Industrywide Risk Assessment Supplemental Policy Guidance Docume nt (2022) shows that four gas stations (one on each corner of a typical intersection) have less th an significant health risk impacts when there is a 100- meter (328-foot) separation distance. It is noted t hat the 328-foot separation distance is conservativ e, because the Project would not be located on an inte rsection with three other gas stations. Nonetheless, the surrounding sensitive receptors would not be wi thin 328 feet of more than one gas station. As the Project’s incremental impacts would not exceed SCAQ MD thresholds, and the surrounding sensitive receptors would not be within 328 feet of more than one gas station, health risk impacts would not be cumulatively considerable.
Therefore, the Project’s long-term operational emissions would not result in a cumulatively considerable net increase of any criteria pollutant or TAC.
CONCLUSION
Project implementation would result in less than si gnificant cumulative construction and cumulative operational air quality impacts. The Project would have an annual throughput of less than 3.6 million gallons and would not be within 50 feet of sensitiv e receptors. The Project would be required to insta ll vapor recovery systems per CARB’s ATCM, comply with CARB’s Vapor Recovery System Certification Procedure, and Use Enhanced Conventional (ECO) and Enhanced ORVR-Vehicle Recognition (EOR) nozzles, among others. The Project would also be required to comply with SCAQMD Rule 201 (Permit to Construct), Rule 203 (Permit to Operate), and Rule 461 (Gasolin e Transfer and Dispensing). As discussed above, the Project’s cumulative contribution would not be cumulatively considerable and mitigation measures would not be required. Therefore, the proposed Project would not result in significant cumulative effects.
REFERENCES
1. California Air Pollution Control Officers Associati on, Gasoline Service Station Industrywide Risk Assessment Technical Guidance Manual , 2021.
2. California Air Resources Board, Air Quality and Land Use Handbook , 2005.
3. California Air Resources Board, Gasoline Service Station Industrywide Risk Assessme nt Supplemental Policy Guidance Document , 2022.
4. Kimley-Horn, Clinton Keith Road and Mitchell Road Shopping Center Project Air Quality Analysis , June 2023.
5. Kimley-Horn, Clinton Keith Road and Mitchell Road Shopping Cente r Project Health Risk Assessment , June 2023.
6. South Coast Air Quality Management District, White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution , 2003.
kimley-horn.com 1100 W. Town and Country Road, Suite 700, Orange, CA 92868 714 939 1030
Exhibit 2: Cumulative Project Locations