DATE: July 16, 2024
TO: Jennifer Dorgan, Allen Matkins
FROM: Haseeb Qureshi, Michael Tirohn
JOB NO: 16167-02 AQ & GHG Assessment
1313 EAST PHILLIPS ROAD AIR QUALITY & GREENHOUSE GAS
ASSESSMENT
Jennifer Dorgan,
Urban Crossroads, Inc. is pleased to provide the following Air Quality & Greenhouse Gas Assessment for the 1313 East Phillips Road (Project), which is located in the City of Pomona.
PROJECT OVERVIEW
It is our understanding that the Project site will maintain four existing structures/buildings totaling approximately 39,547 square feet (sf) consisting of a large unenclosed shed and three buildings for administrative support services. The total site area is 472,660 sf, which will encompass exterior storage yards. A site plan is presented in Exhibit 1.
SUMMARY OF FINDINGS
Results of the assessment indicate that the Project would result in a less than significant impact with respect to air quality and greenhouse gas, requiring no mitigation measures.
Attachment No. 10
Jennifer Dorgan, Allen Matkins
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EXHIBIT 1: SITE PLAN
Jennifer Dorgan, Allen Matkins
July 9, 2024
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PROJECT AIR QUALITY IMPACTS
AIR QUALITY SETTING
SOUTH COAST AIR BASIN (SCAB)
The Project site is located in the SCAB within the jurisdiction of South Coast Air Quality Management District (SCAQMD) (3). The SCAQMD was created by the 1977 Lewis -Presley Air Quality Management Act, which merged four county air pollution control bodies into one regional district. Under the Act, the SCAQMD is responsible for bringing air quality in areas under its jurisdiction into conformity with federal and state air quality standards. As previously stated, the Project site is located within the SCAB, a 6,745 -square mile subregio n of the SCAQMD, which includes portions of Los Angeles, Riverside, and San Bernardino Counties, and all of Orange County.
The SCAB is bounded by the Pacific Ocean to the west and the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east. The Los Angeles County portion of the Mojave Desert Air Basin is bounded by the San Gabriel Mountains to the south and west, the Los Angeles / Kern County border to the north, and the Los Angeles / San Bernardino County border to the east. The Riverside County portion of the Salton Sea Air Basin is bounded by the San Jacinto Mountains in the west and spans eastward up to the Palo Verde Valley.
Regional Climate
The regional climate has a substantial influence on air quality in the SCAB. In addition, the temperature, wind, humidity, precipitation, and amount of sunshine influence the air quality.
The annual average temperatures throughout the SCAB vary from the low to middle 60s degrees Fahrenheit (°F). Due to a decreased marine influence, th e eastern portion of the SCAB shows greater variability in average annual minimum and maximum temperatures. January is the coldest month throughout the SCAB, with average minimum temperatures of 47°F in downtown Los Angeles and 36°F in San Bernardino. All portions of the SCAB have recorded maximum temperatures above 100°F.
Although the climate of the SCAB can be characterized as semi-arid, the air near the land surface is quite moist on most days because of the presence of a marine layer. This shallow laye r of sea air is an important modifier of SCAB climate. Humidity restricts visibility in the SCAB, and the conversion of sulfur dioxide (SO2) to sulfates (SO4) is heightened in air with high relative humidity.
The marine layer provides an environment for that conversion process, especially during the spring and summer months. The annual average relative humidity within the SCAB is 71 percent (%) along the coast and 59% inland. Since the ocean effect is dominant, periods of heavy early morning fog are fre quent and low stratus clouds are a characteristic feature. These effects decrease with distance from the coast.
More than 90% of the SCAB’s rainfall occurs from November through April. The annual average rainfall varies from approximately nine inches in R iverside to fourteen inches in downtown Los Angeles. Monthly and yearly rainfall totals are extremely variable. Summer rainfall usually consists of widely scattered thunderstorms near the coast and slightly heavier shower activity in the eastern portion of the SCAB with frequency being higher near the coast.
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Due to its generally clear weather, about three -quarters of available sunshine is received in the SCAB. The remaining one-quarter is absorbed by clouds. The ultraviolet portion of this abundant radiation is a key factor in photochemical reactions. On the shortest day of the year there are approximately 10 hours of possible sunshine, and on the longest day of the year there are approximately 14½ hours of possible sunshine.
The importance of wind to air pollution is considerable. The direction and speed of the wind determines the horizontal dispersion and transport of the air pollutants. During the late autumn to early spring rainy season, the SCAB is subjected to wind flows associated with the traveli ng storms moving through the region from the northwest. This period also brings five to ten periods of strong, dry offshore winds, locally termed “Santa Anas” each year. During the dry season, which coincides with the months of maximum photochemical smog concentrations, the wind flow is bimodal, typified by a daytime onshore sea breeze and a nighttime offshore drainage wind.
Summer wind flows are created by the pressure differences between the relatively cold ocean and the unevenly heated and cooled land surfaces that modify the general northwesterly wind circulation over southern California. Nighttime drainage begins with the radiational cooling of the mountain slopes. Heavy, cool air descends the slopes and flows through the mountain passes and canyons as it follows the lowering terrain toward the ocean. Another characteristic wind regime in the SCAB is the “Catalina Eddy,” a low level cyclonic (counterclockwise) flow centered over Santa Catalina Island which results in an offshore flow to the southwe st. On most spring and summer days, some indication of an eddy is apparent in coastal sections.
In the SCAB, there are two distinct temperature inversion structures that control vertical mixing of air pollution. During the summer, warm high -pressure descending (subsiding) air is undercut by a shallow layer of cool marine air. The boundary between these two layers of air is a persistent marine subsidence/inversion. This boundary prevents vertical mixing which effectively acts as an impervious lid to poll utants over the entire SCAB. The mixing height for the inversion structure is normally situated 1,000 to 1,500 feet above mean sea level.
A second inversion -type forms in conjunction with the drainage of cool air off the surrounding mountains at night fol lowed by the seaward drift of this pool of cool air. The top of this layer forms a sharp boundary with the warmer air aloft and creates nocturnal radiation inversions.
These inversions occur primarily in the winter when nights are longer and onshore flow is weakest. They are typically only a few hundred feet above mean sea level. These inversions effectively trap pollutants, such as nitrogen oxides (NO X) and carbon monoxide (CO) from vehicles, as the pool of cool air drifts seaward. Winter is therefore a period of high levels of primary pollutants along the coastline.
Wind Patterns and Project Location
The distinctive climate of the Project area and the SCAB is determined by its terrain and geographical location. The SCAB is located in a coastal plain wit h connecting broad valleys and low hills, bounded by the Pacific Ocean in the southwest quadrant with high mountains forming the remainder of the perimeter.
Wind patterns across the south coastal region are characterized by westerly and southwesterly onshore winds during the day and easterly or northeasterly breezes at night. Winds are characteristically light although the speed is somewhat greater during the dry summer months than during the rainy winter season.
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Criteria Pollutants
Both the U.S. Environme ntal Protection Agency (EPA) and the California Air Resources Board (CARB) have established ambient air quality standards for common pollutants. These ambient air quality standards are levels of contaminants representing safe levels that avoid specific adv erse health effects associated with each pollutant. The ambient air quality standards cover what are called “criteria” pollutants because the health and other effects of each pollutant are described in criteria documents. The six criteria pollutants are ozone (O3) (precursor emissions include NOX and reactive organic gases (ROG), CO, particulate matter (PM), nitrogen dioxide (NO 2), sulfur dioxide (SO2), and lead. Areas that meet ambient air quality standards are classified as attainment areas, while areas t hat do not meet these standards are classified as nonattainment areas. The Riverside County portion of the SCAB is designated as a nonattainment area for the federal O 3 and PM2.5 standards and is also a nonattainment area for the state standards for O 3, PM10, and PM2.5.
Sensitive Receptor Locations
Some people are especially sensitive to air pollution and are given special consideration when evaluating air quality impacts from projects. These groups of people include children, the elderly, and individuals with pre-existing respiratory or cardiovascular illness. Structures that house these persons or places where they gather are defined as “sensitive receptors”. These structures typically include uses such as residences, hotels, and hospitals where an individual can remain for 24 hours. Consistent with the LST Methodology, the nearest land use where an individual could remain for 24 hours to the Project site has been used to determine construction and operational air quality impacts for emissions of PM 10 and PM2.5, since PM10 and PM2.5 thresholds are based on a 24-hour averaging time.
Receptors in the Project study area are described below. All distances are measured from the Project site boundary to the outdoor living areas (e.g., backyards) or at the building façade, whichever is closer to the Project site. Receptors in the Project study area are shown on Exhibit 2 under the Localized Construction Emissions section later in the report. • Receptor R1 represents the existing residence at 35960 Lindstrand Avenue , approximately 130 feet west of the Project site . Receptor R1 is placed near the private outdoor living area (backyard) adjacent to Whitewood Road facing the Project site. • Receptor R2 represents the residence at 35842 Meadowlark Lane, approximately 59 feet north of the Project site . Receptor R2 is placed near the private outdoor living area (backyard).
• Receptor R3 represents the existing residence at 35815 Arendt Lane , approximately 64 feet north of the Project site. Receptor R3 is placed near the private outdoor living area (backyard) facing the Project site.
• Receptor R4 represents the existing residence at 35820 Arendt Lane, approximately 114 feet northeast of the Project site . Receptor R4 is placed near the private outdoor living area (backyard) facing the Project site.
• Receptor R5 represents the existing residence at 35960 Arendt Lane, approximately 122 feet east of the Project site. Receptor R5 is placed near the private outdoor living area (backyard) facing the Project site.
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• Receptor R6 represents th e Vista Murrieta High School at 28251 Clinton Keith Road , approximately 551 feet southwest of the Project site. Since there are no private outdoor living areas (backyards) facing the Project site, receptor R6 is placed at the building façade.
REGULATORY BACKGROUND
FEDERAL REGULATIONS
The EPA is responsible for setting and enforcing the national ambient air quality standards (NAAQS) for O 3, CO, NO X, SO 2, PM 10, and lead (Pb) (5). The EPA has jurisdiction over emissions sources that are under the authority of the federal government including aircraft, locomotives, and emissions sources outside state waters (Outer Continental Shelf). The EPA also establishes emission standards for vehicles sold in states other than California. Automobiles sold in California must meet the stricter emission requirements of CARB.
The Federal Clean Air Act (CAA) was first enacted in 1955 and has been amended numerous times in subsequent years (1963, 1965, 1967, 1970, 1977, and 1990). The CAA establishes the federal air quality standards, the NAAQS, and specifies future dates for achieving compliance (6). The CAA also mandates that each state submit and implement state implementation plans (SIPs) for local areas not meeting these standards. These plans must include pollut ion control measures that demonstrate how the standards will be met.
The 1990 amendments to the CAA that identify specific emission reduction goals for areas not meeting the NAAQS require a demonstration of reasonable further progress toward attainment and incorporate additional sanctions for failure to attain or to meet interim milestones. The sections of the CAA most directly applicable to the development of the Project site include Title I (Non-Attainment Provisions) and Title II (Mobile Source Provision s) (7) (8). Title I provisions were established with the goal of attaining the NAAQS for the following criteria pollutants O3, NO2, SO2, PM10, CO, PM2.5, and Pb. The NAAQS were amended in July 1997 to include an additional standard for O3 and to adopt a NAAQS for PM2.5.
Mobile source emissions are regulated in accordance with Title II provisions. These provisions require the use of cleaner burning gasoline and other cleaner burning fuels such as methanol and natural gas. Automobile manufacturers are also r equired to reduce tailpipe emissions of hydrocarbons and NOX. NOX is a collective term that includes all forms of NO X which are emitted as byproducts of the combustion process.
CALIFORNIA REGULATIONS
CARB
The CARB, which became part of the California EPA ( CalEPA) in 1991, is responsible for ensuring implementation of the California Clean Air Act (AB 2595), responding to the federal CAA, and for regulating emissions from consumer products and motor vehicles. AB 2595 mandates achievement of the maximum degree of emissions reductions possible from vehicular and other mobile sources in order to attain the state ambient air quality standards by the earliest practical date. The CARB established the California ambient air quality standards (CAAQS) for all pollutants for which the federal government has NAAQS and, in addition, establishes standards for SO 4, Jennifer Dorgan, Allen Matkins
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visibility, hydrogen sulfide (H2S), and vinyl chloride (C2H3Cl). However, at this time, H2S and C2H3Cl are not measured at any monitoring stations in the S CAB because they are not considered to be a regional air quality problem. Generally, the CAAQS are more stringent than the NAAQS (1) (2).
Local air quality management districts, such as the SCAQMD, regulate air emissions from stationary sources such as commercial and industrial facilities. All air pollution control districts have been formally designated as attainment or non-attainment for each CAAQS.
Serious non-attainment areas are required to prepare Air Quality Management Plans (AQMP) that include specified emission reduction strategies in an effort to meet clean air goals. These plans are required to include:
• Application of Best Available Retrofit Control Technology to existing sources; • Developing control programs for area sources (e.g., architectural coatings and solvents) and indirect sources (e.g. motor vehicle use generated by residential and commercial development);
• A District permitting system designed to allow no net increase in emissions from any new or modified permitted sources of emissions;
• Implementing reasonably available transportation control measures and assuring a substantial reduction in growth rate of vehicle trips and miles traveled; • Significant use of low emissions vehicles by fleet operators; • Sufficient control strategies to achieve a 5% or more annual reduction in emissions or 15% or more in a period of three years for ROGs, NOX, CO and PM10. However, air basins may use alternative emission reduction strategy that achieves a reduction of less than 5% per year under certain circumstances.
AQMP
Currently, the NAAQS and CAAQS are exceeded in most parts of the SCAB. In response, the SCAQMD has adopted a series of AQMP to meet the state and federal ambient air quality standards (10). AQMPs are updated regularly in order to more effectively reduce emissions, accommodate growth, and to minimize any negative fiscal impacts of air pollution control on the economy.
APPLICABLE REGULATORY REQUIRMENTS
SCAQMD Rules that are currently applicable during construction activity for this Project include but are not limited to Rule 403 (Fugitive Dust), Rule 445 (Wood Burning Devices), and Rule 1113 (Architectural Coatings) (3) (4) (5).
SCAQMD Rule 403
This rule is intended to reduce the amount of particulate matter entrained in the ambient air as a result of anthropogenic (human -made) fugitive dust sources by requiring actions to prevent and reduce fugitive dust emissions. Rule 403 applies to any activity or human -made condition capable of generating fugitive dust and requires best available control measures to be applied to earth moving and grading activities. This rule is intended to reduce P M10 emissions from any Jennifer Dorgan, Allen Matkins
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transportation, handling, construction, or storage activity that has the potential to generate fugitive dust. PM10 suppression techniques are summarized below. • Portions of a construction site to remain inactive longer than a period o f three months will be seeded and watered until grass cover is grown or otherwise stabilized. • All onsite roads will be paved as soon as feasible or watered periodically or chemically stabilized.
• All material transported offsite will be either sufficiently watered or securely covered to prevent excessive amounts of dust.
• The area disturbed by clearing, grading, earthmoving, or excavation operations will be minimized at all times.
• Where vehicles leave a construction site and enter adjacent public streets, the streets will be swept daily or washed down at the end of the workday to remove soil tracked onto the paved surface.
SCAQMD Rule 445
This rule is intended to reduce the emission of particulate matter from wood -burning devices.
The Project is required to comply with SCAQMD Rule 445, which prohibits the use of wood burning stoves and fireplaces in new development.
SCAQMD Rule 1113
This rule serves to limit the volatile organic compound (VOC) content of architectural coatings used on projects in the SCAQMD. Any person who supplies, sells, offers for sale, or manufactures any architectural coating for use on projects in the SCAQMD must comply with the current VOC standards set in this rule.
METHODOLOGY
In May 2022, the California Air Pollution Cont rol Officers Association (CAPCOA) in conjunction with other California air districts, including SCAQMD, released the latest version of the CalEEMod Version 2022.1. The purpose of this model is to calculate construction -source and operational - source criteria pollutant (VOCs, NO X, SOX, CO, PM 10, and PM 2.5) and GHG emissions from direct and indirect sources; and quantify applicable air quality and GHG reductions achieved from mitigation measures (6). Accordingly, the latest v ersion of CalEEMod has been used for this Project to determine construction and operational air quality and greenhouse gas emissions.
Standards of Significance
The criteria used to determine the significance of potential Project-related air quality impacts are taken from the California Environmental Quality Act Guidelines (CEQA Guidelines ) (14 CCR §§15000, et seq.). Based on these thresholds, a project would result in a significant impact related to air quality if it would (7):
• Threshold 1: Conflict with or obstruct implementation of the applicable air quality plan. • Threshold 2: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non -attainment under an applicable federal or state ambient air quality standard.
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• Threshold 3: Expose sensitive receptors to substantial pollutant concentrations. • Threshold 4: Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.
AIR QUALITY REGIONAL EMISSIONS THRESHOLDS
The SCAQMD has developed regional significance thresholds for criteria pollutants, as summarized at Table 1 (8). The SCAQMD’s CEQA Air Quality Significance Thresholds ( April 2019) indicate that any projects in the South Coast Air Basin (SCAB) with daily emissions that exceed any of the indicated thresholds should be considered as having an individually and cumulatively significant air quality impact.
TABLE 1: MAXIMUM DAILY REGIONAL EMISSIONS THRESHOLDS
Pollutant Construction Operations
NOX 100 lbs/day 55 lbs/day
VOC 75 lbs/day 55 lbs/day
PM10 150 lbs/day 150 lbs/day
PM2.5 55 lbs/day 55 lbs/day
SOX 150 lbs/day 150 lbs/day
CO 550 lbs/day 550 lbs/day
lbs/day – Pounds Per Day
AIR QUALITY LOCALIZED EMISSIONS THRESHOLDS
For this Project, the appropriate SRA for the LST analysis is the SCAQMD Pomona monitoring station (SRA 10). LSTs apply to CO, NO 2, PM10, and PM 2.5. The SCAQMD produced look -up tables for projects less than or equal to 5 acres in size . T he SCAQMD’s screeni ng look-up tables are utilized in determining localized impacts. It should be noted that since the look-up tables identify thresholds at only 1 acre, 2 acres, and 5 acres, linear regression has been utilized to determine localized significance thresholds. Consistent with SCAQMD guidance, the thresholds presented in Table 2 were calculated by interpolating the threshold values for the Project’s disturbed acreage.
The acres disturbed is based on the equipment list and days in the site preparation and grading phase according to the anticipated maximum number of acres a given piece of equipment can pass over in an 8 -hour workday. The equipment-specific grading rates are summarized in the CalEEMod user’s guide, Appendix A: Calculation Details for CalEEMod (9). It should be noted that the disturbed area per day is representative of a piece of equipment making multiple passes over the same land area. In other words, one Rubber Tired Dozer can make multiple passes over the same land area totaling 0.5 acres in a given 8-hour day. Appendix A of the CalEEMod User Manual only identifies equipment -specific gradi ng rates for Crawler Tractors, Graders, Rubber Tired Dozers, and Scrapers; therefore, Tractors/Loaders/Backhoes equipment that was included in the site preparation phase was replaced with crawler tractors. For analytical purposes, emissions associated with site preparation activities are considered for purposes of localized significance Jennifer Dorgan, Allen Matkins
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thresholds (LSTs) since this phase represents the maximum localized emissions that would occur.
The Project’s construction activities could disturb a maximum of approximately 3.5 acres per day for site preparation activities. Any other construction phases of development would result in lesser emissions and consequently lesser impacts than what is disclosed herein. As such, Table 2 presents thresholds for localized construction and operational emissions.
TABLE 2: MAXIMUM DAILY LOCALIZED EMISSIONS THRESHOLDS
Activity
Emissions (lbs/day)
NOX CO PM10 PM2.5
Construction 193 lbs/day 1,226 lbs/day 9 lbs/day 6 lbs/day Operation 236 lbs/day 1,566 lbs/day 3 lbs/day 2 lbs/day
CONSTRUCTION ACTIVITIES
Construction activities associated with the Project would result in emissions of VOCs, NO X, SOX, CO, PM10, and PM2.5.
CONSTRUCTION DURATION
For purposes of analysis, construction of Project is expected to commence in October 2024 and would last through December 2024. The construction schedule utilized in the analysis, as shown in Table 3, represents a “worst-case” analysis scenario should cons truction 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 1. The duration of construction activity and associated e quipment represents a reasonable approximation of the expected construction fleet as required per CEQA Guidelines (10).
1 As shown in the CalEEMod User’s Guide Version 2022.1.1.25, Section 4.3 “Off-Road 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.
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TABLE 3: CONSTRUCTION DURATION
Construction Activity Start Date End Date Number of
Days
Site Preparation 10/1/2024 11/4/2024 25
Paving 11/5/2024 12/9/2024 25
CONSTRUCTION EQUIPMENT
Consistent with industry standards and typical construction practices, each piece of equipment listed in Table 4 would operate up to a total of eight (8) hours per day, or more than two -thirds of the period during which construction activities are allowed pursuant to the City Code.
TABLE 4: CONSTRUCTION EQUIPMENT
Construction Activity Equipment Amount Hours
Per Day
Site Preparation
Rubber Tired Dozers 3 8
Crawler Tractors 4 8
Paving
Pavers 2 8
Paving Equipment 2 8
Rollers 2 8
REGIONAL CONSTRUCTION EMISSIONS SUMMARY
The estimated maximum daily construction emissions without mitigation are summarized in Table 5. Detailed construction model outputs are presented in Attachment A. Under the assumed scenarios, emissions resulting from the Project construction will not exce ed thresholds established by the SCAQMD for emissions of any criteria pollutant and no mitigation is required.
TABLE 5: REGIONAL CONSTRUCTION EMISSIONS SUMMARY
Source
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Maximum Emissions (2024) 4.57 42.60 36.40 0.05 8.14 4.81 Maximum Daily Emissions 4.57 42.60 36.40 0.05 8.14 4.81 SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? NO NO NO NO NO NO
1PM10 and PM2.5 source emissions reflect 3x daily watering per SCAQMD Rule 403 for fugitive dust.
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REGIONAL OPERATIONAL EMISSIONS SUMMARY
Operational activities associated with the Project would result in emissions of CO, VOCs, NOX, SOX, PM10, and PM2.5. Operational related emissions are expected from the following primary sources:
mobile source emissions, area source emissions, energy source emissions, stationary source emissions, and operational off-road equipment emissions.
The Project related operat ional air quality impacts derive primarily from vehicle trips generated by the Project. Trip characteristics available from the 1313 East Phillips Road Vehicle Miles Traveled (VMT) Screening Evaluation were utilized in this analysis (11). It should be noted that the Project traffic study evaluated two options, as described in the Project Overview. This analysis conservatively evaluates the emissions associated with Option 2, as this scenario would result in more daily passenger vehicle and truck trips, and thus increased emissions compared to Option
1. The estimated operation-source emissions from the Project are summarized on Table 6. Detailed operation model outputs are presented in Attachment B. As shown on Table 6, operation al- source emissions would not exceed the applicable SCAQMD regional thresholds for emissions of any criteria pollutant and no mitigation is required.
TABLE 6: REGIONAL OPERATIONAL EMISSIONS SUMMARY
Source
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Summer
Mobile Source 0.33 0.97 3.66 0.01 0.87 0.23
Area Source 1.29 0.01 1.72 <0.005 <0.005 <0.005
Energy Source 0.01 0.20 0.17 <0.005 0.02 0.02
Winter
Mobile 0.33 1.02 3.37 0.01 0.87 0.23
Area Source 1.50 0.00 0.00 0.00 0.00 0.00
Energy Source 0.02 0.31 0.26 <0.005 0.02 0.02
Maximum Daily Emissions 1.63 1.22 5.55 0.01 0.89 0.25
SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? NO NO NO NO NO NO
SENSITIVE RECEPTORS
The analysis uses the methodology included in the SCAQMD Final Localized Significance Threshold Methodology (LST Methodology) (12). The SCAQMD has established that impacts to air quality are significant if there is a potential to contribute or cause localized exceedances of the federal and/or state ambient air quality standards (NAAQS/CAAQS). Collectively, these are referred to as Localized Significance Thresholds (L STs). The SCAQMD established LSTs in response to the Jennifer Dorgan, Allen Matkins
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SCAQMD Governing Board’s Environmental Justice Initiative I -42. LSTs represent the maximum emissions from a project that will not cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard at the sensitive receptor. The SCAQMD states that lead agencies can use the LSTs as another indicator of significance in its air quality impact analyses. It should be noted that SCAQMD also states th at projects that are statutorily or categorically exempt under CEQA would not be subject to LST analyses. Projects exempt from CEQA also include infill projects that meet the H&S Code provisions. As such, although not required for this Project, LST analysis is presented to further underscore that there are in fact no significant impacts associated with the Project.
The SCAQMD recommends that the nearest sensitive receptor be considered when determining the Project’s potential to cause an individual or cumulatively significant impact. The nearest land use where an individual could remain for 24 hours to the Project site has been used to determine localized construction and operational air quality impacts for emissions of PM 10 and PM2.5 (since PM10 and PM2.5 thresholds are based on a 24-hour averaging time). The nearest receptor used for evaluation of localized impacts of PM 10 and PM2.5 is located approximately 25 meters east of the Project site. As such, for evaluation of localized NOX, CO, PM10 and PM2.5, a 25-meter distance will be used.
It should be noted that the LST Methodology explicitly states that “ It is possible that a project may have receptors closer than 25 meters. Projects with boundaries located closer than 25 meters to the nearest receptor should use the LSTs for receptors located at 25 meters (12).” As such, for evaluation of localized PM10, PM2.5, NOX, and CO, a 25-meter distance will be used.
LOCALIZED CONSTRUCTION EMISSIONS
Table 7 identifies the localized impacts at the nearest receptor location in the vicinity of the Project. Outputs from the model runs for construction LSTs are provided in Attachment A. For analytical purposes, emissions associated with peak site preparation activities are considered for purposes of LSTs since this phase represents the maximum localized emissions that would occur.
Any other construction phases of development that overlap would result in lesser emissions and consequently lesser impacts than what is disclosed here in. As shown in Table 7, emissions resulting from the construction will not exceed the numerical thresholds of significance established by the SCAQMD for any criteria pollutant . Thus, a less than significant impact would occur for localized Project-related construction-source emissions and no mitigation is required.
2 The purpose of SCAQMD’s Environmental Justice program is to ensure that everyone has the right to equal protection from air pollution and fair access to the decision-making process that works to improve the quality of air within their communities. Further, the SCAQMD defines Environmental Justice as “…equitable environmental policymaking and enforcement to protect the health of all residents, regardless of age, culture, ethnicity, gender, race, socioeconomic status, or geographic location, from the health effects of air pollution.” Jennifer Dorgan, Allen Matkins
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TABLE 7: PROJECT LOCALIZED CONSTRUCTION IMPACTS
On-Site Emissions
Emissions (lbs/day)
NOX CO PM10 PM2.5
Site Preparation
Maximum Daily Emissions 42.50 35.30 7.91 4.76
SCAQMD Localized Threshold 193 1,226 9 6
Threshold Exceeded? NO NO NO NO
LOCALIZED OPERATIONAL EMISSIONS
Table 8 identifies the localized impacts at the nearest receptor location in the vicinity of the Project. Outputs from the model runs for operational LSTs are provided in Attachment C and assume an on -site travel distance of 0. 25 mile. As shown in Table 8, emissions resulting from Project operational activities will not exceed the numerical thresholds of significance established by the SCAQMD for any criteria pollutant . Thus, a less than significant impact would occur for localized Project-related operation-source emissions and no mitigation is required.
TABLE 8: PROJECT LOCALIZED OPERATIONAL IMPACTS
On-Site Emissions
Emissions (lbs/day)
NOX CO PM10 PM2.5
Maximum Daily Emissions 0.45 2.65 0.04 0.03
SCAQMD Localized Threshold 209 1,545 3 2
Threshold Exceeded? NO NO NO NO
AIR QUALITY IMPACTS – CONSISTENCY WITH THRESHOLD NO. 1
Would the Project conflict with or obstruct implementation of the applicable air quality plan? The Project site is located within the SCAB, which is characterized by relatively poor air quality.
The SCAQMD has jurisdiction over an approximately 10,743 square -mile area consisting of the four-county Basin and the Los Angeles County and Riverside County portions of what use to be referred to as the South east Desert Air Basin. In these areas, the SCAQMD is principally responsible for air pollution control, and works directly with the Southern California Association of Governments (SCAG), county transportation commissions, local governments, as well as stat e and federal agencies to reduce emissions from stationary, mobile, and indirect sources to meet state and federal ambient air quality standards.
Currently, these state and federal air quality standards are exceeded in most parts of the SCAB.
In response, the SCAQMD has adopted a series of AQMPs to meet the state and federal ambient air quality standards. AQMPs are updated regularly in order to more effectively reduce emissions, accommodate growth, and to minimize any negative fiscal impacts of air pollution control on the economy.
In December 2022 , the SCAQMD released the Final 20 22 AQMP (2022 AQMP). The 2022 AQMP continues to evaluate current integrated strategies and control measures to meet the CAAQS, as Jennifer Dorgan, Allen Matkins
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well as explore new and innovative methods to reach its goals. Some of these approaches include utilizing incentive programs, recognizing existing co -benefit programs from other sectors, and developing a strategy with fair-share reductions at the federal, state, and local levels (13). Similar to the 201 6 AQMP, the 2022 AQMP incorporates scientific and technological information and planning assumptions, including the 2020-2045 RTP/SCS, a planning document that supports the integration of land use and transportation to help the region meet the federal CAA requirements (14). The Project’s consist ency with the AQMP will be determined using the 2022 AQMP as discussed below.
SCAG adopted the 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (2020- 2045 RTP/SCS), a planning document that supports the integration of land use and transportation to help the region meet the federal metropolitan planning organization (MPO) requirements under the Sustainable communities and Climate Protection Act . The proposed Project would be developed in accordance with all applicable rules and regulations contained in those plans.
Criteria for determining consistency with the AQMP are defined in Chapter 12, Section 12.2 and Section 12.3 of the 1993 CEQA Handbook (15). These indicators are discussed below.
The proposed Project will not result in an increase in the frequency or severity of existing air quality violations or cause or contribute to new violations or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMP.
The violations under this criterion refer to the CAAQS and NAAQS. CAAQS and NAAQS violations would occur if regional or localized significance thresholds were exceeded.
CAAQS and NAAQS violations would occur if regional or localized significanc e thresholds were exceeded. As evaluated, the Project’s regional and localized construction and operational-source emissions would not exceed applicable regional significance thresholds. As such, a less than significant impact is expected.
On the basis of the preceding discussion, the Project is determined to be consistent with the first criterion.
The Project will not exceed the assumptions in the AQMP based on the years of Project build - out phase.
The 2022 AQMP demonstrates that the applicable ambient air quality standards can be achieved within the timeframes required under federal law. Growth projections from local general plans adopted by cities in the district are provided to the SCAG, which develops regional growth forecasts, which are then used to develop future air quality forecasts for the AQMP. Development consistent with the growth projections in City of Pomona General Plan is considered to be consistent with the AQMP.
Peak day emissions generated by construction activities are largely independe nt of land use assignments, but rather are a function of development scope and maximum area of disturbance.
Irrespective of the site’s land use designation, development of the site to its maximum potential would likely occur, with disturbance of the enti re site occurring during construction activities. As such, when considering that no emissions thresholds will be exceeded, a less than significant impact would result.
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The City of Pomona General Plan designates the Project site as “Workplace District” land uses and “M-1 Light Industrial ” zoning uses. The Project’s proposed uses and density are consistent with the site’s land use designations, and a general plan amendment will not be required.
On the basis of the preceding discussion, the Project is determin ed to be consistent with the second criterion.
As the proposed Project is consistent with site’s land use designation, would not exceed any applicable regional or local thresholds, and would not result in or cause NAAQS or CAAQS violations, the Project is therefore considered to be consistent with the AQMP and would not have impacts beyond what was studied in the City of Pomona General Plan EIR, as such, a less than significant impact is expected.
AIR QUALITY IMPACTS – CONSISTENCY WITH THRESHOLD NO. 2
Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard?
The CAAQS designates the region in which the Project site is located as nonattainment for O 3, PM10, and PM2.5 while the NAAQS designates the Project site’s region as nonattainment for O3 and PM2.5.
The SCAQMD has published a report on how to address cumulative impacts from air pollution:
White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution (16). In this report the SCAQMD clearly states (Page D-3):
“…the SCAQMD uses the same significance thresholds for project specific and cumulative impacts for all environmental topics analyzed in an Environmental Assessment or EIR. The only case where the significance thresholds for project specific and cumulative impacts differ is the Hazard Index (HI) significance threshold for TAC emiss ions. The project specific (project increment) significance threshold is HI > 1.0 while the cumulative (facility -wide) is HI > 3.0. It should be noted that the HI is only one of three TAC emission significance thresholds considered (when applicable) in a C EQA analysis. The other two are the maximum individual cancer risk (MICR) and the cancer burden, both of which use the same significance thresholds (MICR of 10 in 1 million and cancer burden of 0.5) for project specific and cumulative impacts.
Projects that exceed the project-specific significance thresholds are considered by the SCAQMD to be cumulatively considerable. This is the reason project-specific and cumulative significance thresholds are the same. Conversely, projects that do not exceed the project-specific thresholds are generally not considered to be cumulatively significant.” Therefore, this analysis assumes that individual projects that do not generate operational or construction emissions that exceed the SCAQMD’s recommended daily thresholds f or project- specific impacts would also not cause a cumulatively considerable increase in emissions for those pollutants for which SCAB is in nonattainment, and, therefore, would not be considered to have a significant, adverse air quality impact. Alternatively, individual project-related construction and operational emissions that exceed SCAQMD thresholds for project -specific impacts would be considered cumulatively considerable.
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Construction Impacts
The Project ‐specific evaluation of emissions presented in the preceding analysis demonstrates that proposed Project construction -source air pollutant emissions would not result in exceedances of regional thresholds. Therefore, the proposed Project construction -source emissions would be considered less than significant on a project-specific and cumulative basis.
Operational Impacts
The Project ‐specific evaluation of emissions presented in the preceding analysis demonstrates that proposed Project operational-source air pollutant emissions would not result in exceedances of regional thresholds. Therefore, the proposed Project operational-source emissions would be considered less than significant on a project-specific and cumulative basis.
AIR QUALITY IMPACTS – CONSISTENCY WITH THRESHOLD NO. 3
Would the Project expose sensitive receptors to substantial pollutant concentrations? The potential impact of Project-generated air pollutant emissions at sensitive receptors has also been considered. Results of the LST analysis indicate that the Project will not exceed the SCAQMD localized significance thresholds during construction. The refore, sensitive receptors would not be exposed to substantial pollutant concentrations during Project construction.
Additionally, the Project will not exceed the SCAQMD localized significance thresholds during operational activity. Therefore, sensitive receptors would not be exposed to substantial pollutant concentrations as the result of Project operations.
CO “HOT SPOT” ANALYSIS
As discussed below, the Project would not result in potentially adverse CO concentrations or “hot spots.” An adverse CO concentration, known as a “hot spot”, would occur if an exceedance of the state one-hour standard of 20 ppm or the eight-hour standard of 9 ppm were to occur.
It has long been recognized that CO hotspots are caused by vehicular emissions, primarily when idling at congested intersections. In response, vehicle emissions standards have become increasingly stringent in the last twenty years. Currently, the allowable CO emissions standard in California is a maximum of 3.4 grams/mile for passenger cars (there are requirements for certain vehicles that are more stringent). With the turnover of older vehicles, introduction of cleaner fuels, and implementation of increasingly sophisticated and efficient emissions control technologies, CO concentration in the SCAB is now designated as attainment.
To establish a more accurate record of baseline CO concentrations affecting the SCAB, a CO “hot spot” analysis was conducted in 2003 for four busy intersections in Los Angeles at the peak morning and afternoon time periods3. This “hot spot” analysis did not predict any exceedance of the 1-hour (20.0 ppm) or 8-hour (9.0 ppm) CO standards, as shown on Table 9.
3 The CO “hot spot” analysis conducted in 2003 is the most current study used for CO “hot spot” analysis in the SCAB.
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TABLE 9: CO MODEL RESULTS
Intersection Location
CO Concentrations (ppm)
Morning 1-hour Afternoon 1-hour 8-hour
Wilshire Boulevard/Veteran Avenue 4.6 3.5 3.7
Sunset Boulevard/Highland Avenue 4 4.5 3.5
La Cienega Boulevard/Century Boulevard 3.7 3.1 5.2
Long Beach Boulevard/Imperial Highway 3 3.1 8.4
Notes: Federal 1-hour standard is 35 ppm and the deferral 8-hour standard is 9.0 ppm.
Based on the SCAQMD's 2003 AQMP and the 1992 Federal Attainment Plan for Carbon Monoxide (1992 CO Plan ), peak carbon monoxide concentrations in the SCAB were a result of unusual meteorological and topographical conditions and not a result of traffic volumes and congestion at a particular intersection. As evidence of this, for example, of the 8.4 ppm 8-hr CO concentration measured at the Long Beach Blvd. and Imperial Hwy. intersection (i.e., the highest CO generating intersection within the “hot spot” analysis), only 0.7 ppm was attributable to the traffic volumes and congestion at this intersection; the remaining 7.7 ppm were due to the ambient air measurements at the time the 2003 AQMP was prepared (17). In contrast, an adverse CO concentration, known as a “hot spot”, would occur if an exceedance of the state one -hour standard of 20 parts per million (ppm) or the eight-hour standard of 9 ppm were to occur.
Similar considerations are also employed by other Air Districts when evaluating potential CO concentration impacts. More specifically, the Bay Area Air Quality Management District (BAAQMD) concludes that under existing and future vehicle emission rates, a given project would have to increase traffic volumes at a single intersection by more than 44,000 vehicles per hour (vph)—or 24,000 vph where vertical and/or horizontal air does not mix —in order to generate a significant CO impact (18). Traffic volumes generating the CO concentrations for the “hot spot” analysis is shown on Table 10. The busiest intersection evaluated was that at Wilshire Boulevard and Veteran Avenue, which has a daily traffic volume of approximately 100,000 vph and AM/PM traffic volumes of 8,062 vph and 7,719 vph respectively (17). The 2003 AQMP estimated that the 1-hour concentration for this intersection was 4.6 ppm; this indicates that, should the daily traffic volume increase four times to 400,000 vehicles per day, CO concentrations (4.6 ppm x 4= 18.4 ppm) would still not likely exceed the most stringent 1-hour CO standard (20.0 ppm)4
4 Based on the ratio of the CO standard (20.0 ppm) and the modeled value (4.6 ppm) Jennifer Dorgan, Allen Matkins
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TABLE 10: TRAFFIC VOLUMES
Intersection Location
Peak Traffic Volumes (vph)
Eastbound
(AM/PM)
Westbound
(AM/PM)
Southbound
(AM/PM)
Northbound
(AM/PM)
Total
(AM/PM)
Wilshire Boulevard/Veteran Avenue 4,954/2,069 1,830/3,317 721/1,400 560/933 8,062/7,719 Sunset Boulevard/Highland Avenue 1,417/1,764 1,342/1,540 2,304/1,832 1,551/2,238 6,614/5,374 La Cienega Boulevard/Century Boulevard 2,540/2,243 1,890/2,728 1,384/2,029 821/1,674 6,634/8,674 Long Beach Boulevard/Imperial Highway 1,217/2,020 1,760/1,400 479/944 756/1,150 4,212/5,514 AIR QUALITY IMPACTS – CONSISTENCY WITH THRESHOLD NO. 4
Would the Project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The potential for the Project to generate objectionable odors has also been considered. Land uses generally associated with odor complaints include:
• Agricultural uses (livestock and farming)
• Wastewater treatment plants
• Food processing plants
• Chemical plants
• Composting operations
• Refineries
• Landfills
• Dairies
• Fiberglass molding facilities
The Project does not contain land uses typically associated with emitting objectionable odors.
Potential odor sou rces associated with the proposed Project may result from construction equipment exhaust and the application of asphalt and architectural coatings during construction activities and the temporary storage of typical solid waste (refuse) associated with the proposed Project’s (long-term operational) uses. Standard construction requirements would minimize odor impacts from construction. The construction odor emissions would be temporary, short -term, and intermittent in nature and would cease upon completion of the respective phase of construction and is thus considered less than significant. It is expected that Project -generated refuse would be stored in covered containers and removed at regular intervals in compliance with the solid waste regulations. The prop osed Project would also be required to comply with SCAQMD Rule 402 to prevent occurrences of public nuisances. Therefore, odors associated with the proposed Project construction and operations would be less than significant and no mitigation is required (19).
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PROJECT GHG ANALYSIS
CLIMATE CHANGE SETTING
Global climate change (GCC) is the change in average meteorological conditions on the earth with respect to temperature, precipitation, and storms. The majority of scientists believe that the climate shift taking place since the Industrial Revolution is o ccurring at a quicker rate and magnitude than in the past. Scientific evidence suggests that GCC is the result of increased concentrations of GHGs in the earth’s atmosphere, including carbon dioxide (CO 2), methane (CH4), nitrous oxide (N 2O), and fluorinate d gases. The majority of scientists believe that this increased rate of climate change is the result of GHGs resulting from human activity and industrialization over the past 200 years.
An individual project like the proposed Project evaluated in this mem o cannot generate enough GHG emissions to affect a discernible change in global climate. However, the proposed Project may participate in the potential for GCC by its incremental contribution of GHGs combined with the cumulative increase of all other sour ces of GHGs, which when taken together constitute potential influences on GCC. Because these changes may have serious environmental consequences, this memo will evaluate the potential for the proposed Project to have a significant effect upon the environment as a result of its potential contribution to the greenhouse effect.
GCC refers to the change in average meteorological conditions on the earth with respect to temperature, wind patterns, precipitation and storms. Global temperatures are regulated by naturally occurring atmospheric gases such as water vapor, CO 2, N2O, CH4, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF 6). These particular gases are important due to their residence time (duration they stay) in the atmosphere, which ranges from 10 years to more than 100 years. These gases allow solar radiation into the earth’s atmosphere, but prevent radiative heat from escaping, thus warming the earth’s atmosphere. GCC can occur naturally as it has in the past with the previous ice ages.
Gases that trap heat in the atmosphere are often referred to as GHGs. GHGs are released into the atmosphere by both natural and anthropogenic activity. Without the natural GHG effect, the earth’s average temperature would be approximately 61 degrees Fahrenheit (°F) cooler than it is currently. The cumulative accumulation of these gases in the earth’s atmosphere is considered to be the cause for the observed increase in the earth’s temperature.
For the purposes of this analysis, emissions of CO2, CH4, and N2O were evaluated because these gases are the primary contributors to GCC from development projects. Although there are other substances such as fluorinated gases that also contribute to GCC, these fluorinated gases were not evaluated as their sources are not well-defined and do not contain accepted emissions factors or methodology to accurately calculate these gases.
REGULATORY SETTING
Executive Order S-3-05
Former California Governor Arnold Schwarzenegger announced on June 1, 2005, throug h Executive Order S-3-05, the following reduction targets for GHG emissions:
• By 2010, reduce GHG emissions to 2000 levels.
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• By 2020, reduce GHG emissions to 1990 levels.
• By 2050, reduce GHG emissions to 80% below 1990 levels.
The 2050 reduction goal represents what some scientists believe is necessary to reach levels that will stabilize the climate. The 2020 goal was established to be a mid-term target. Because this is an executive order, the goals are not legally enforceable for local governments or the private sector.
Assembly Bill (AB) 32
The California State Legislature enacted AB 32, which requires that GHGs emitted in California be reduced to 1990 levels by the ye ar 2020. “GHGs” as defined under AB 32 include CO 2, CH4, N2O, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Since AB 32 was enacted, a seventh chemical, nitrogen trifluoride, has also been added to the list of GHGs.
CARB is the state agency charged with monitoring and regulating sources of GHGs. Pursuant to AB 32, CARB adopted regulations to achieve the maximum technologically feasible and cost - effective GHG emission reductions. AB 32 states the following:
“Global warming poses a serious threat to the economic well -being, public health, natural resources, and the environment of California. The potential adverse impacts of global warming include the exacerbation of air quality problems, a reduction in the quali ty and supply of water to the state from the Sierra snowpack, a rise in sea levels resulting in the displacement of thousands of coastal businesses and residences, damage to marine ecosystems and the natural environment, and an increase in the incidences of infectious diseases, asthma, and other human health-related problems.”
CARB approved the 1990 GHG emissions level of 427 million metric ton of CO 2 equivalent per year (MMTCO2e) on December 6, 2007 (20). Therefore, emissions generated in California in 2020 are required to be equal to or less than 427 MMTCO2e. Emissions in 2020 in a “business as usual” (BAU) scenario were estimated to be 596 MMTCO 2e, which do not account for reductions from AB 32 regulations (21). At that level, a 28.4% reduction was required to achieve the 427 MMTCO2e 1990 inventory. In October 2010, CARB prepared an updated BAU 2020 forecast to account for the recession and slower forecasted growth. The forecasted inventory wit hout the benefits of adopted regulation is now estimated at 545 MMTCO2e. Therefore, under the updated forecast, a
21.7% reduction from BAU is required to achieve 1990 levels (22).
Progress in Achieving AB 32 Targets and Remaining Reductions Required The State has made steady progress in implementing AB 32 and achieving targets included in Executive Order S -3-05. The progress is shown in updated emission inventories prepared by CARB for 2000 through 2012 (23). The State has achieved the Executive Order S -3-05 target for 2010 of reducing GHG emissions to 2000 levels. As shown below, the 2010 emission inventory achieved this target.
• 1990: 427 MMTCO2e (AB 32 2020 target)
• 2000: 463 MMTCO2e (an average 8% reduction needed to achieve 1990 base) • 2010: 450 MMTCO2e (an average 5% reduction needed to achieve 1990 base) Jennifer Dorgan, Allen Matkins
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CARB has also made substantial progress in achieving its goal of achieving 1990 emissions levels by 2020. As described earlier in this section, CARB revised the 2020 BAU inventory forecast to account for new lower growth projections, which resulted in a new lower reduction from BAU to achieve the 1990 base. The previous reduction from 2020 BAU needed to achieve 1990 levels was 28.4% and the latest reduction from 2020 BAU is 21.7%. • 2020: 545 MMTCO2e BAU (an average 21.7% reduction from BAU needed to achieve 1990 base)
Senate Bill (SB) 32
On September 8, 2016, Governor Jerry Brown signed the SB 32 and its companion bill, AB 197. SB 32 requires the state to reduce statewide GHG emissions to 40% below 1990 levels by 2030, a reduction target that was first introduced in Executive Order B -30-15. The new legislation builds upon the AB 32 goal of 1990 levels by 2020 and provides an intermediate goal to achieving S -3- 05, which sets a statewide GHG reduction target of 80% below 1990 levels by 2050. AB 197 creates a legislative committee to oversee r egulators to ensure that CARB not only responds to the Governor, but also the Legislature (24).
AB 197
A condition of approval for SB 32 was the passage of AB 197. AB 197 requires that CARB consider the social costs of GHG em issions and prioritize direct reductions in GHG emissions at mobile sources and large stationary sources. AB 197 also gives the California legislature more oversight over CARB through the addition of two legislatively appointed members to the CARB Board an d the establishment a legislative committee to make recommendations about CARB programs to the legislature.
Executive Order B-55-18 and SB 100
Executive Order B -55-18 and SB 100. SB 100 and Executive Order B -55-18 were signed by Governor Brown on September 10, 2018. Under the existing RPS, 25% of retail sales are required to be from renewable sources by December 31, 2016, 33% by December 31, 2020, 40% by December 31, 2024, 45% by December 31, 2027, and 50% by December 31, 2030. SB 100 raises California’s RPS requirement to 50% renewable resources target by December 31, 2026, and to achieve a 60% target by December 31, 2030. SB 100 also requires that retail sellers and local publicly owned electric utilities procure a minimum quantity of electricity products from eligible renewable energy resources so that the total kilowatt hours of those products sold to their retail end-use customers achieve 44% of retail sales by December 31, 2024, 52% by December 31, 2027, and 60% by December 31, 2030. In addition to targets under AB 32 and SB 32, Executive Order B- 55-18 establishes a carbon neutrality goal for the state of California by 2045; and sets a goal to maintain net negative emissions thereafter. The Executive Order directs the California Natural Resources Agency (CNRA), California Environmental Protection Agency (CalEPA), the Department of Food and Agriculture (CDFA), and CARB to include sequestration targets in the Natural and Working Lands Climate Change Implementation Plan consistent with the carbon neutrality goal.
Title 24 California Code of Regulations (CCR)
California Code of Regulations (CCR) Title 24 Part 6: The California Energy Code was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption.
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The standards are updated periodically to allow consideration and possible incorporation of new energy efficient technologies and methods. CCR, Title 24, Part 11: California Green Building Standards Code (CALGreen) is a comprehensive and uniform regulatory code for all residential, commercial, and school buildings that went in effect on August 1, 2009, and is administered by the California Building Standards Commission.
CALGreen is updated on a regular basis, with the most recent approved update consisting of the 2022 California Green Building Code Standards that became effective on January 1, 20235. As construction of the Project is anticipated to be completed in 2028, it is presumed that the Project would be required to comply with the Title 24 standards in place at that time.
SCAQMD
SCAQMD is the agency responsible for air quality planning and regulation in the S CAB. The SCAQMD addresses the impacts to climate change of projects subject to SCAQMD permit as a lead agency if they are the only agency having discretionary approval for the project and acts as a responsible agency when a land use agency must also approve discretionary permits for the project. The SCAQMD acts as an expert commenting agency for impacts to air quality. This expertise carries over to GHG emissions, so the agency helps local land use agencies through the development of models and emission thresholds that can be used to address GHG emissions.
In 2008, SCAQMD formed a Working Group to identify GHG emissions threshol ds for land use projects that could be used by local lead agencies in the S CAB. The Working Group developed several different options that are contained in the SCAQMD Draft Guidance Document – Interim CEQA GHG Significance Threshold, that could be applied by lead agencies. The working group has not provided additional guidance since release of the interim guidance in 2008. The SCAQMD Board has not approved the thresholds; however, the Guidance Document provides substantial evidence supporting the approaches to significance of GHG emissions that can be considered by the lead agen cy in adopting its own threshold. The current interim thresholds consist of the following tiered approach:
• Tier 1 consists of evaluating whether or not the project qualifies for any applicable exemption under CEQA.
• Tier 2 consists of determining whether t he project is consistent with a GHG reduction plan. If a project is consistent with a qualifying local GHG reduction plan, it does not have significant GHG emissions.
• Tier 3 consists of screening values, which the lead agency can choose, but must be consistent with all projects within its jurisdiction. A project’s construction emissions are averaged over 30 years and are added to the project’s operational emissions. If a project’s emissions are below one of the following screening thresholds, then the pr oject is less than significant:
o Residential and commercial land use: 3,000 metric ton of CO2 equivalent (MTCO2e/yr)
o Industrial land use: 10,000 MTCO2e/yr
5 The 2022 California Green Building Standard Code will be published July 1, 2022.
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o Based on land use type: residential: 3,500 MTCO 2e/yr; commercial: 1,400 MTCO2e/yr; or mixed use: 3,000 MTCO2e/yr
• Tier 4 has the following options:
o Option 1: Reduce Business-as-Usual (BAU) emissions by a certain percentage; this percentage is currently undefined.
o Option 2: Early implementation of applicable AB 32 Scoping Plan measures o Option 3: 2020 tar get for service populations (SP), which includes residents and employees: 4.8 MTCO 2e per SP per year for projects and 6.6 MTCO 2e per SP per year for plans;
o Option 3, 2035 target: 3.0 MTCO 2e per SP per year for projects and 4.1 MTCO 2e per SP per year for plans.
• Tier 5 involves mitigation offsets to achieve target significance threshold.
The SCAQMD’s interim thresholds used the Executive Order S -3-05-year 2050 goal as the basis for the Tier 3 screening level. Achieving the Executive Order’s objective would contribute to worldwide efforts to cap CO2 concentrations at 450 ppm, thus stabilizing global climate.
SCAQMD only has authority over GHG emissions from development projects that include air quality permits. At this time, it is unknown if the project wou ld include stationary sources of emissions subject to SCAQMD permits. Notwithstanding, if the Project requires a stationary permit, it would be subject to the applicable SCAQMD regulations.
SCAQMD Regulation XXVII, adopted in 2009 includes the following rules:
• Rule 2700 defines terms and post global warming potentials. • Rule 2701, Southern California (SoCal) Climate Solutions Exchange, establishes a voluntary program to encourage, quantify, and certify voluntary, high quality certified GHG emission reductions in the SCAQMD.
• Rule 2702, GHG Reduction Program created a program to produce GHG emission reductions within the SCAQMD. The SCAQMD will fund projects through contracts in response to requests for proposals or purchase reductions from other parties.
SCAQMD is the agency responsible for air quality planning and regulation in the S CAB. The SCAQMD addresses the impacts to climate change of projects subject to SCAQMD permit as a lead agency if they are the only agency having discretionary approval for the p roject and acts as a responsible agency when a land use agency must also approve discretionary permits for the project. The SCAQMD acts as an expert commenting agency for impacts to air quality. This expertise carries over to GHG emissions, so the agency helps local land use agencies through the development of models and emission thresholds that can be used to address GHG emissions.
Standards of Significance
According to the CEQA Guidelines Appendix G thresholds, to determine whether impacts from GHG emissions are significant. Would the project:
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• Threshold 1 : Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
• Threshold 2 : Conflict with an applic able plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs?
EMISSIONS SUMMARY
PROJECT GHG EMISSIONS
The estimated GHG emissions for the Project are summarized on Table 11. As shown on Table 11, the Project would generate a total of approximately 326.74 MTCO2e/yr. Detailed construction and operational model outputs are presented in Attachments A and B, respectively.
TABLE 11: TOTAL PROJECT GHG EMISSIONS
Source
Emission (metric tons per year)
CO2 CH4 N2O Refrigerants Total CO2e
Annual construction-related emissions
amortized over 30 years 2.83 1.67E-04 1.67E-04 3.33E-04 2.84 Mobile Source 156.00 0.01 0.01 0.28 161.00
Area Source 0.8 <0.005 <0.005 0.00 0.80
Energy Source 127.00 0.01 <0.005 0.00 128.00
Water Source 12.90 0.30 0.01 0.00 22.50
Waste Source 3.32 0.33 0.00 0.00 11.60
Total CO2e (All Sources) 326.74
GHG IMPACTS
The criteria used to determine the significance of potential Project-related GHG impacts are taken from the Initial Study Checklist in Appendix G of the State CEQA Guidelines (14 CCR of Regulations §§15000, et seq.). Based on these significance criteria , a project would result in a significant impact related to GHG if it would (2):
• Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
• Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs?
CEQA Guidelines Section 15064.4 recommends that lead agencies quantify GHG emissions of projects and consider several other factors that may be used in the determination of significance of GHG emissions from a project, including the extent to which the project may increase or reduce GHG emissions, whether the project exceeds an applicable significance threshold, and whether the project complies with regulations or requirements adopted to implement a reduction or mitigation of GHGs.
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thresholds, a lead agency may appropriately look to thresholds developed by other public agencies, or suggested by other experts, such as the CAPCOA, as long as any threshold chosen is supported by substantial evidence (see CEQA Guidelines Section 15064.7(c )). The CEQA Guidelines also clarify that the effects of GHG emissions are cumulative and should be analyzed in the context of CEQA’s requirements for cumulative impact analysis (see CEQA Guidelines Section 15130(f)). It is noted that the CEQA Guidelines w ere amended in response to SB 97. In particular, the CEQA Guidelines were amended to specify that compliance with a GHG emissions reduction plan renders a cumulative impact less than significant.
Per CEQA Guidelines Section 15064(h)(3), a project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project would comply with an approved plan or mitigation program that provides specific requirements that would avoid or substantially lessen the cumulative problem within the geographic area of the project. To qualify, such plans or programs 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 plans [and] plans or regulations for the reduction of GHG emissions. In summary, CEQA Guidelines Section 15064(h)(3) allows the lead agency to make a finding of less than significant for GHG emissions if a project complies with adopted programs, plans, policies, and/or other regulatory schemes to reduce GHG emissions.
In the absence of any applicable adopted numeric threshold, the significance of the Project’s GHG emissions is evaluated consistent with CEQA Guidelines Section 15064.4(b) by c onsidering whether the Project is consistent with applicable regulations or requirements adopted to implement a Statewide, regional, or local plan for the reduction or mitigation of GHG emission.
For this Project, as a land use development project, the mos t directly applicable adopted regulatory plan to reduce GHG emissions is the City’s CAP, which is designed to achieve regional GHG reductions from the land use and transportation sectors as required by the State’s long - term climate goals. This analysis als o considers consistency with regulations or requirements adopted by the AB 32 Scoping Plan and subsequent updates, and the 2020–2045 RTP/SCS.
For informational purposes, the analysis also calculates the amount of GHG emissions that would be attributable to the Project using recommended air quality models, as described below. The primary purpose of quantifying the Project’s GHG emissions is to satisfy State CEQA Guidelines 15064.4(a), which calls for a good-faith effort to describe and calculate emissions. The estimated emissions inventory is also used to determine if there would be a reduction in the Project’s incremental contribution of GHG emissions because of compliance with regulations and requirements adopted to implement plans for the reduction or mitigation of GHG emissions.
GHG IMPACTS – CONSISTENCY WITH THRESHOLD NO. 1
Would the Project have the p otential to generate direct or indirect GHG emissions that would result in a significant impact on the environment?
A numerical threshold for determining the significance of GHG emissions in the SCAB has not been established by the SCAQMD for projects where it is not the lead agency . As an interim threshold based on guidance provided in the CAPCOA CEQA and Climate Change handbook, the Jennifer Dorgan, Allen Matkins
July 9, 2024
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City has opted to use a non-zero threshold approach based on Approach 2 of the handbook.
Threshold 2.5 (Unit-Based Thresh olds Based on Market Capture) establishes a numerical threshold based on capture of approximately 90% of emissions from future development. The latest threshold developed by SCAQMD using this method is 3,000 MTCO2e/yr for all projects (25).
The Project would result in approximately 326.74 MTCO2e/yr; the proposed Project would not exceed the SCAQMD’s numeric threshold of 3,000 MTCO2e/yr. Thus, the Project would result in a less than significant impact with respect to GHG emissions.
GHG IMPACTS – CONSISTENCY WITH THRESHOLD NO. 2
Would the Project have the potential to conflict with any applicable plan, policy or regulation of an agency adopted for the purpose of reducing the emissions of GHGs ? In November 2022, CARB released the Final 2022 Scoping Plan Update, which identifies the State’s progress towards the statutory 2030 target, while providing a path towards carbon neutrality and reduce greenhouse gases emissions by 85% below 1990 levels by 2045. Recent studies show that the State’s existing and proposed regulatory framework will allow the State to reduce its GHG emissions level to 40% below 1990 levels by 2030 (26). The Project would not conflict with any of the 2022 Scoping Plan elements as any regulations adopted would apply directly or indirectly to the Project.
Finally, the Project is consistent with the general plan land use designation, density, building intensity, and applicable policies specified for the Project area in SCAG's Sustainable Community Strategy/ Regional Transportation Plan, which pursuant to SB 375 calls for the integration of transportation, land -use and housing policies to plan for achievement of the GHG -emissions target for the region. Thus, a less than significant impact related to GHG emissions from Project construction and operation would occur and no mitigation is required.
CONCLUSION
Results of the assessment indicate that the Project is not anticipated to result in any new impacts associated with air quality and greenhouse gas emissions.
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REFERENCES
1. Air Resources Board. California Ambient Air Quality Standards (CAAQS). [Online] 2009. [Cited:
April 16, 2018.] http://www.arb.ca.gov/research/aaqs/caaqs/caaqs.htm.
2. Environmental Protection Agency. National Ambient Air Quality Standards (NAAQS). [Online] 1990. https://www.epa.gov/environmental-topics/air-topics.
3. South Coast Air Quality Management District. RULE 403. FUGITIVE DUST. [Online] https://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-403.pdf?sfvrsn=4.
4. —. RULE 445. Wood-Burning Devices. [Online] http://www.aqmd.gov/docs/default-source/rule- book/rule-iv/rule-445.pdf.
5. —. RULE 1113. Architectural Coatings. [Online] http://www.aqmd.gov/docs/default - source/rule-book/reg-xi/r1113.pdf.
6. California Air Pollution Control Officers Association (CAPCOA). California Emissions Estimator Model (CalEEMod). [Online] May 2022. www.caleemod.com.
7. State of California. 2020 CEQA California Environmental Quality Act. 2020.
8. South Coast Air Quality Management District (SCAQMD). SCAQMD Air Quality Significance Thresholds. [Online] http://www.aqmd.gov/docs/default - source/ceqa/handbook/scaqmd-air-quality-significance-thresholds.pdf?sfvrsn=2.
9. California Air Pollution Control Officers Association (CAPCOA). Appendix A: Calculation Details for CalEEMod. CalEEMod. [Online] http://www.aqmd.gov/docs/default- source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6.
10. State of California. 2023 CEQA California Environmental Quality Act. 2023.
11. Urban Crossroads, Inc. 1313 East Phillips Road Vehicle Miles Traveled (VMT) Screening Evaluation. 2024.
12. South Coast Air Quality Management District. Localized Significance Thresholds Methodology. s.l. : South Coast Air Quality Managment District, 2003.
13. —. Final 2016 Air Quality Management Plan (AQMP). [Online] March 2017. http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management- plans/2016-air-quality-management-plan/final-2016-
aqmp/final2016aqmp.pdf?sfvrsn=11.
14. Southern California Association of G overnments. 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy. [Online] September 2020. https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal- plan_0.pdf?1606001176.
15. South Coast Air Quality Management District. CEQA Air Quality Handbook (1993). 1993.
16. Goss, Tracy A and Kroeger, Amy. White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution. [Online] South Coast Air Quality Management District, 2003. http://www.aqmd.gov/docs/def ault-source/Agendas/Environmental- Justice/cumulative-impacts-working-group/cumulative-impacts-white-paper.pdf.
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17. South Coast Air Quality Management District. 2003 Air Quality Management Plan. [Online] 2003. https://www.aqmd.gov/home/air -quality/clean-air-plans/air-quality-mgt- plan/2003-aqmp.
18. Bay Area Air Quality Management District. [Online] http://www.baaqmd.gov/.
19. South Coast Air Quality Management Di strict. RULE 402 NUISANCE. [Online] http://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-402.pdf.
20. California Air Resources Board. GHG 1990 Emissions Level & 2020 Limit. California Air Resources Board. [Online] https://ww2.arb.ca.gov/ghg-2020-limit.
21. —. Climate Change Draft Scoping Plan. 2008.
22. —. STATUS OF SCOPING PLAN RECOMMENDED MEASURES. [Online] [Cited: September 19, 2019.]
https://calcarbondash.org/cc/scopingplan/sp_measures_implementation_timeline.pdf.
23. —. First Update to the Climate Change Scoping Plan. 2014.
24. California Legislative Information. Senate Bill No. 32. [Online] September 8, 2016. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB32.
25. South Coast Air Quality Management District. Interim CEQA GHG Threshold for Stationary Sources, Rules and Plans. [Online] December 5, 2008.
http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)- ceqa-significance-thresholds/ghgboardsynopsis.pdf.
26. Lawrence Berkeley National Labo ratory. California's Policies Can Significantly Cut Greenhouse Gas Emissions through 2030. Lawrence Berkeley National Laboratory. [Online] January 22, 2015. http://newscenter.lbl.gov/2015/01/22/californias -policies- can-significantly-cut-greenhouse-gas-emissions-2030/.
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ATTACHMENT A
CALEEMOD PROPOSED PROJECT EMISSIONS MODEL OUTPUTS –
CONSTRUCTION
16167-02 AQ & GHG Assessment.docx
ATTACHMENT B
CALEEMOD PROPOSED PROJECT EMISSIONS MODEL OUTPUTS –
OPERATION
16167-02 AQ & GHG Assessment.docx
ATTACHMENT C
CALEEMOD PROPOSED PROJECT EMISSIONS MODEL OUTPUTS –
LOCALIZED OPERATIONS