A list of appropriate Native American Contacts for consultation concerning the project site has been provided and is attached to this letter This comment outlines the steps required to mitigate potential impacts to historical resources.
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
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to determine if the proposed active might impinge on any cultural resources. Lack of surface evidence of archeological resources does not preclude their subsurface existence.
SA1-3 Lead agencies should include in their mitigation plan provisions for the identification and evaluation of accidentally discovered archeological resources, per California Environmental Quality Act (CEQA) §15064.5(f). In areas of identified archaeological sensitivity, a certified archaeologist and a culturally affiliated Native American, with knowledge in cultural resources, should monitor all ground-disturbing activities. Lead agencies should include in their mitigation plan provisions for the disposition of recovered artifacts, in consultation with culturally affiliated Native Americans. Lead agencies should include provisions for discovery of Native American human remains in their mitigation plan. Health and Safety Code §7050.5, CEQA §15064.5(e), and Public Resources Code §5097.98 mandates the process to be followed in the event of an accidental discovery of any human remains in a location other than a dedicated cemetery.
As discussed on page 4.5-21 of the Draft EIR, although there have been previous grounddisturbing activities within the RAAP Plan Area, and it is unlikely that undiscovered archeological resources are located within the site, it is possible that undiscovered archeological resources are present in the RAAP Plan Area. General Plan Policies CONS 2.1, CONS-2.2, CONS-2.4, and CONS-2.5 address this issue. In addition, Section 5097 of the Public Resources Code specifies the procedures to be followed in the event of the unexpected discovery of human remains on nonfederal land, and Section 7050.5 requires that construction or excavation be stopped in the vicinity of discovered human remains until the coroner can determine whether the remains are those of a Native American. If determined to be Native American, the coroner must contact the NAHC.
Central Valley Regional Water Quality Control Board
SA2-1 Pursuant to the State Clearinghouse's 27 March 2013 request, the Central Valley Regional Water Quality Control Board (Central Valley Water Board) has reviewed the Request for Review for the Draft Environmental Impact Report for the Riverbank Army Ammunition Plant Specific Plan Project, located in Stanislaus County.
Our agency is delegated with the responsibility of protecting the quality of surface and groundwaters of the state; therefore our comments will address concerns surrounding those issues.
This comment provides an introduction to the comment letter. No further response is required.
SA2-2 Construction Storm Water General Permit
Dischargers whose project disturb one or more acres of soil or where projects disturb less than one acre but are part of a larger common plan of development that in total disturbs one or more acres, are required to obtain coverage under the General Permit for Storm Water Discharges Associated with Construction Activities (Construction General Permit), Construction General Permit Order No. 2009-009- DWQ. Construction activity subject to this permit includes clearing, grading, grubbing, disturbances to the ground, such as stockpiling, or excavation, but does not include regular maintenance activities perThis comments provides a summary of the requirements of the Construction Storm Water General Permit. Construction-related impacts to hydrology are discussed on pages 4.10-8 through 4.10-10 of the Draft EIR. This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
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formed to restore the original line, grade, or capacity of the facility.
The Construction General Permit requires the development and implementation of a Storm Water Pollution Prevention Plan (SWPPP).
For more information on the Construction General Permit, visit the State Water Resources Control Board website at:
http://www.waterboards.ca.gov/water_issues/programs/stormwater/ constpermits.shtml.
SA2-3 Phase I and II Municipal Separate Storm Sewer System (MS4) Permits The Phase I and II MS4 permits require the Permittees reduce pollutants and runoff flows from new development and redevelopment using Best Management Practices (BMPs) to the maximum extent practicable (MEP). MS4 Permittees have their own development standards, also known as Low Impact Development (LID)/postconstruction standards that include a hydromodification component.
The MS4 permits also require specific design concepts for LID/postconstruction BMPs in the early stages of a project during the entitlement and CEQA process and the development plan review process.
For more information on which Phase I MS4 Permit this project applies to, visit the Central Valley Water Board website at:
http://www.waterboards.ca.gov/centralvalley/water_issues/storm_wa ter/municipal_permits/.
(1) Municipal Permits = The Phase I Municipal Separate Storm Water System (MS4) Permit covers medium sized Municipalities (serving between 100,000 and 250,000 people) and large sized municipalities (serving over 250,000 people). The Phase II MS4 provides coverage for small municipalities, including non-traditional Small MS4s, which include military bases, public campuses, prisons and hospitals.
This comments provides a summary of the requirements of the Phase I and II Municipal Separate Storm Sewer System (MS4) Permits. This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
SA2-4 Industrial Storm Water General Permit
Storm water discharges associated with industrial sites must comply with the regulations contained in the Industrial Storm Water General Permit Order No. 97-03-DWQ.
For more information on the Industrial Storm Water General Permit, visit the Central Valley Water Board website at:
http://www.waterboards.ca.gov/centralvalley/water_issues/storm_wa ter/industrial_general_perm
This comments provides a summary of the requirements of the Industrial Storm Water General Permit. This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
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itslindex.shtml.
SA2-5 Clean Water Act Section 404 Permit
If the project will involve the discharge of dredged or fill material in navigable waters or wetlands, a permit pursuant to Section 404 of the Clean Water Act may be needed from the United States Army Corps of Engineers (USACOE). If a Section 404 permit is required by the USACOE, the Central Valley Water Board will review the permit application to ensure that discharge will not violate water quality standards. If the project requires surface water drainage realignment, the applicant is advised to contact the Department of Fish and Game for information on Streambed Alteration Permit requirements.
If you have any questions regarding the Clean Water Act Section 404 permits, please contact the Regulatory Division of the Sacramento District of USACOE at (916) 557-5250.
This comments provides a summary of the requirements of the Clean Water Act Section 404 Permit. This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
SA2-6 Clean Water Act Section 401 Permit - Water Quality Certification If an USACOE permit, or any other federal permit, is required for this project due to the disturbance of waters of the United States (such as streams and wetlands), then a Water Quality Certification must be obtained from the Central Valley Water Board prior to initiation of project activities. There are no waivers for 401 Water Quality Certifications.
This comments provides a summary of the requirements of the Clean Water Act Section 401 Permit. This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
SA2-7 Waste Discharge Requirements
If USACOE determines that only non-jurisdictional waters of the State (i.e., "non-federal" waters of the State) are present in the proposed project area, the proposed project will require a Waste Discharge Requirement (WDR) permit to be issued by Central Valley Water Board.
Under the California Porter-Cologne Water Quality Control Act, discharges to all waters of the State, including all wetlands and other waters of the State including, but not limited to, isolated wetlands, are subject to State regulation.
For more information on the Water Quality Certification and WDR processes, visit the Central Valley Water Board website at:
http://www.waterboards.ca.gov/centralvalley/help/business_help/per mit2.shtml.
This comments provides a summary of waste discharge requirements. This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
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Department of Transportation
SA3-1 The California Department of Transportation (Department) appreciates the opportunity to review and comment on the DEIR for the for the RAAP Specific Plan which includes 173 acres. This includes 146 acre primary site of which portions are currently underdeveloped and a 27 acre evaporation pond. The Department has the following comments:
This comment acknowledges that the Department of Transportation has reviewed the EIR and introduces ensuing comments, but does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
SA3-2 I. The existing plus approved/pending projects scenario should be included as part of the scenarios being analyzed.
The Draft EIR considered the impacts of the Project on the existing transportation system as well as the future transportation system considering approved, pending and planned developments over the next 20 to 30 years, consistent with CEQA guidelines. As the project is a Specific Plan to guide future development on the site and no specific projects have been proposed, the level of analysis provided in the Draft EIR appropriately identifies the range of impacts that could occur as the site is developed. As Projects are proposed for the site, additional review may be required, but no Existing Plus Approved scenario will be evaluated at this time.
SA3-3 2. Please provide the electronic files that will be used to analyze the traffic study when the traffic study is submitted.
The TIA was included as Appendix E of the Draft EIR. The Synchro files used in the analysis have been forwarded to the commenter.
SA3-4 3. Various intersections along SR-108 do not meet STAA off-tracking requirements for turning movements. The project needs to consider the impact of any potentially generated STAA truck traffic turning movements at intersections due to its development since this would create a safety issue at these intersections.
The Draft EIR acknowledged that the Project could increase truck traffic through intersections on State Route 108 that do not currently meet STAA requirements and a significant impact was identified, as stated on page 4.16-31. The project is required to pay local and regional fees that would fund improvements to the state highway system and the local street network. Potential improvements to these intersections include minor re-striping, intersection modification and/or pavement widening. The StanCOG 2011 RTP identifies some improvements to the SR 108/First Street intersection and available funding is identified for other various intersection improvements, including development fees that each development would be required to pay. However, as the timing of improving SR-108 intersections is unknown, this impact is considered significant and unavoidable. It is also noted that from the Project site, trucks can access the STAA network via Claribel Road (which becomes State Route 219 at McHenry Avenue) with a full interchange to SR 99. Both SR 219 and SR 99 are designated STAA Routes. Additionally, the noted intersections are approximately 2 miles from the Project site and it is beyond the scope of a single project to modify state highways to meet STAA requirements.
SA3-5 Please refer to the letter to the City of Riverbank dated July 19, 2010 regarding related intersections along SR 108 that do not meet STAA. If a copy is needed for reference, please contact the Joshua Swearingen (contact information below).
The letter dated July 19, 2010 identified the intersections of Patterson Road, Santa Fe Street, First Street and Claus Road with SR 108 as intersections that do not meet STAA requirements for one or more turning movements. The intersections of Patterson Road, First Street and Claus Road with SR 108 were included in the impact analysis. Level of service impacts were not identified at these intersections with the addition of traffic from the Project. The intersec-
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tion of Santa Fe Street with SR 108 was not included as the assessment as the project would not add traffic to movements where off-tracking requirements are not met. As noted in the response to comment SA3-4, a significant and unavoidable impact was identified for these intersections for truck movements.
State Clearinghouse
SA4-1 The State Clearinghouse submitted the above named Draft EIR to selected state agencies for review. On the enclosed Document Details Report please note that the Clearinghouse has listed the state agencies that reviewed your document. The review period closed on May 10, 2013, and the comments from the responding agency (ies) is (are) enclosed. If this content package is not in order, please notify the State Clearinghouse immediately. Please refer to the project's ten-digit State Clearinghouse number in future correspondence so that we may respond promptly.
Please note that Section 211 04( c) of the California Public Resources Code states that:
"A responsible or other public agency shall only make substantive. comments regarding those activities involved in a project which are within an area of expertise of the agency or which are required to be carried out or approved by the agency. Those comments shall be supported by specific documentation." These comments are forwarded for use in preparing your final environmental document. Should you need more information or clarification of the enclosed comments, we recommend that you contact the commenting agency directly.
This letter acknowledges that yon have complied with the State Clearinghouse review requirements for draft environmental documents, pursuant to the California Environmental Quality Act. Please contact the State Clearinghouse at (916) 445-0613 if you have any questions regarding the environmental review process.
This comment acknowledges that the Draft EIR was circulated to various State agencies for comment.
Modesto Irrigation District
RA1-1 Thank you for allowing the District to comment on this referral. Following are the recommendations from our Electrical, Irrigation and This comment acknowledges that the Modesto Irrigation District has reviewed the Draft EIR and introduces ensuing comments, but the comments does not state a specific concern or
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Domestic Water Divisions: question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA1-2 Irrigation - Section 4.17 C of the draft EIR discusses increasing storm water discharge flows into the Oakdale Irrigation District (OlD) Riverbank Lateral. The Riverbank Lateral discharges into the Modesto Irrigation District (MID) Main Canal and is subject to a 1942 agreement limiting "irrigation spill, drainage pump discharges and storm and surface water discharges" to maximum total amounts. Any increased discharge from the Riverbank Army Ammunition Plant redevelopment project to OlD's Riverbank Lateral would be subject to the constraints imposed in the 1942 agreement.
The City acknowledges that any increased storm water discharge into the OID lateral is subject to the 1942 agreement. In order to address a potentially significant impact resulting from increased storm water originating on the RAAP site, any new development occurring within the RAAP site would be required to comply with the RAAP Specific Plan as well as the Stormwater Plan prepared for the site. .
RA1-3 Domestic Water - No comments at this time. This comments does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA1-4 Electrical - The Electric Division has no objections at this time. This comments does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA1-5 MID currently has an existing electric facility adjacent to the subject area.
This comments does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA1-6 If MID electric service is desired into the area, the customers should contact the District's Electric Engineering Department to determine the availability of electric service and coordinate service requirements to the proposed project.
The City acknowledges MID's recommendation to potential electrical customers, however this comments does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA1-7 The Modesto Irrigation District reserves its future rights to utilize its property, including its canal and electrical easements and rights-of-way, in a manner it deems necessary for the installation and maintenance of electric, irrigation, agricultural and urban drainage, domestic water and telecommunication facilities. These needs, which have not yet been determined, may consist of poles, crossarms, wires, cables, braces, insulators, transformers, service lines, open channels, pipelines, control structures and any necessary appurtenances, as may, in District's opinion, be necessary or desirable.
The City acknowledges MID's reservation of future rights to utilize property owned by MID, however this comments does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
Oakdale Irrigation District
RA2-1 The Oakdale Irrigation District (OlD) has reviewed the Riverbank Local Redevelopment Authority (RLRA) Riverbank Army Ammunition Plant (RAAP) Environmental Impact Report (EIR) and has the following comments and recommendations regarding the RAAP Specific Plan (project or EIR).
This comment acknowledges that the Oakdale Irrigation District has reviewed the Draft EIR and introduces ensuing comments, but does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
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RA2-2 A letter was sent on March 8, 2011 in response to the February 2, 2011 Notice of Preparation of a Draft EIR in which a request was made that the Riverbank Lateral be fenced. Both the Land Use Concept Figure 3-4) and the Roadway Plan (figure 3-5) of the EIR do not provide alternatives for the Riverbank Lateral as show on Figure 3-7, Potential OlD Realignment. OlD restates the request to fence the Riverbank Lateral.
OID to explore the relocation of the OID canal (Riverbank Lateral) in order to create more viable development parcels on the RAAP site. It is also stated that, while the Specific Plan does not commit the City to implementation of this concept, it does set aside land where the Canal could be relocated in the future. As individual development applications are submitted under the RAAP Specific Plan, the relocation of the OID canal will be discussed, however, the City does not anticipate the installation of fencing adjacent to the Canal location.
RA2-3 The project calls for the City of Riverbank to work with OlD to explore relocating the Riverbank Lateral. Relocation is possible per OlD Policy although no approval has occurred to date. Pre-consultation with OlD is strongly recommended during the planning phase of any specific project.
This comment is correct, and as stated in response to Comment RA2-2, as individual development applications are submitted under the RAAP Specific Plan, the relocation of the OID canal will be discussed. The City acknowledges that pre-construction consultation with the OID is strongly recommended during the planning phases of in individual projects.
RA2-4 The OlD Langstroth Drain is located on the southern edge of parcel 062-031-005. The EIR recommends that the western and southern project frontages along Claribel and Claus Road be widened to their ultimate widths with appropriate turn pockets, bicycle facilities and pedestrian amenities. Expansion of Claribel Road may require the facility be piped. If located underneath Claribel Road, it will become the maintenance responsibility of the City of Riverbank or Stanislaus County.
It is acknowledged that potential expansion of Claribel Road may require the OID Langstroth Drain to be piped, and it will become the maintenance responsibility of the City of Riverbank.
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA2-5 The EIR also discusses 2 existing outlets from the from the north storm drain reservoir that discharge into the Riverbank Lateral and a smaller pump that conveys storm water from the lift station directly to the OlD Riverbank Lateral. You may wish to revise the EIR as these connections were plugged and removed on February 28, 2013 and the capability of RAAP to discharge storm water into the Riverbank Lateral no longer exists.
Text on page 4.17-28 has been amended as follows:
In general, under existing conditions, stormwater runoff is collected in numerous inlets located around the site that connect to a main storm drain line. The main storm drain line carries flows towards the north, opposite the surface grade. At Gate 10, flow is directed through a diversion structure. A valve located at the discharge of the diversion structure remains open allowing stormwater runoff to travel through the diversion structure and down a 36-inch pipe towards a lift station, located adjacent to the north stormwater reservoir. Pumps 1 and 2 of the lift station convey flow into the north reservoir. This reservoir is designed as a detention basin that allows for temporary stormwater runoff to facilitate settling of suspended sediment.
Two outlets, with approximately one foot of elevation difference, are provided in the reservoir to discharge water into the Oakdale Irrigation District (OID) 30-inch diameter line that runs parallel to the north side of the reservoir. Between rain events, some water remains in the reservoir, below the outlets, and either evaporates, infiltrates into the ground, or is used by the vegetation that grows in the basin. The lift station located near the reservoir has a third smaller pump that conveys stormwater from the lift station directly to the OID pipe during periods of excessive rain.
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San Francisco Public Utilities Commission
RA3-1 The San Francisco Public Utilities Commission offers the following comments on the Riverbank Army Ammunition Deport Draft EIR (SCH #2011022015):
This comment acknowledges that the San Francisco Public Utilities Commission has reviewed the EIR and introduces ensuing comments, but does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA3-2 1. The City and County of San Francisco (CCSF), San Francisco Public Utilities Commission (SFPUC) owns a 100-foot-wide right of way (ROW) for the Hetch Hetchy Aqueduct and the San Joaquin Transmission Line, which bisects the Specific Plan area. The Draft EIR acknowledges this ROW and the Specific Plan does not propose development in this area. However, Figure 3-8 in the DEIR identifies the SFPUC ROW as “Buffer/ Greenway/ Open Space”. Please note that any use or development of the ROW, such as for landscaped open space, a pedestrian or bicycle trail, parking, emergency access routes or road crossings, must be reviewed and approved by the SFPUC. Further, CCSF owns the ROW in fee, and SFPUC charges fair market value for its use. In addition, SFPUC places restrictions on use of the ROW in order to protect utility infrastructure and insure that it is accessible for maintenance. SFPUC ROW use requirements are attached (Attachment 1).
As stated on page 3- 14, the Specific Plan does not propose any changes to the Hetch Hetchy Aqueduct, and new development will be outside of the 100-foot-wide parcel. It is acknowledged that any use or development within the Hetch Hetchy Aqueduct, including landscaped open space, pedestrian or bicycle trails, parking, emergency access routes or road crossings, must be reviewed and approved by the SFPUC.
RA3-3 2. In addition, please note that the land use rights associated with the Army’s entry road, which crosses the SFPUC ROW, should be investigated to determine whether this use is covered by an easement. If not, use of this crossing would require review by the SFPUC and, if approved, would be subject to a revocable license from the SFPUC.
It is believed that this comment is referring to the existing rail line that traverses the SFPUC ROW within the RAAP site. The RAAP Specific Plan does not propose construction of any new crossings over the SFPUC property. The existing rail line is within an existing easement, and will remain as a component of the Specific Plan.
RA3-4 3. In 2011 URS, a consultant to SFPUC, reviewed existing environmental documents that addressed the RAAP Superfund site to evaluate any potential impacts to SFPUC's right of way property from activities at the RAAP. As detailed in the attached letter report, "Request for Additional Characterization of the San Francisco Hetch Hetchy Water and Power Division Property Associated with the Riverbank Army Ammunition Plant Superfund Site", which we submit as an element of this comment (Attachment 2), soils in the SFPUC right of way may be contaminated due to the presence of a Transite (asbestos cement) pipe, a past leak in the Transite waste sewer line, leaks in a stormwater line, and overflows from stormwater retention ponds adjacent to the right of way. Additional sampling of soils in the right of way was recommended, and it also was recommended that the Transite pipeline be This comment provides a summary of the URS report that is attached to the comment letter and responded to in the responses to Comments RA3-12 through RA3-23. Please see the response to RA3-14 with regard to the mitigation of potential impacts related to hazardous materials.
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removed rather than abandoned in place. SFPUC is not aware if these actions were ever carried out. If contaminated soils or other hazardous materials are present, this could pose risks to utility workers in the right of way.
RA3-5 San Francisco Public Utilities Commission Pipeline Right of Way Requirements
This comment is the title for the list of requirements that follows.
RA3-6 Utilities
o No utility may be installed along, rather than across, the Right of Way. Only perpendicular crossings are permitted.
o No aerial utility crossing over the Right of Way is permitted except in city streets.
This comment provides the requirements for the installation of utilities in SFPUC pipeline rights of way. The RAAP Specific Plan does not propose the installation of utilities in the SFPUC right of way, and this comment does not question the sufficiency of the analysis or mitigation measures contained in the EIR.
RA3-7 Land Use, Structures, and Accessibility
o Structures on the Right of Way are strictly prohibited. No one shall construct or place any temporary or permanent structure or improvement in, on, under or about the Right of Way. For the SFPUC’s purposes, asphalt, concrete and cementitious concrete driveways, sidewalks and parking areas, and fences are deemed “improvements,” and are subject to SFPUC review and approval.
o No use is permitted that would restrict access to Right of Way at any time by SFPUC staff, construction equipment or vehicles. This means that structures on adjacent property must be setback at least 10 feet from the Right of Way.
o An adjacent property owner or tenant may not use the Right of Way fulfill its open space, setback, emergency access or other development requirements.
o No use that would cause ponding on the Right of Way is permitted. o Any use that cannot effectively be displaced in a timely manner upon the SFPUC's request is disfavored.
o Any use that may contaminate with hazardous materials the soils, water or natural habitat of SFPUC property is prohibited. o Any use where the Right of Way would provide an adjacent owner, tenant or licensee with its sole emergency access to the tenant or licensee’s property is prohibited. o Any use that would increase the SFPUC’s potential liability or diminish its security is disfavored. o Any use inconsistent with any existing or future policies adopted by the SFPUC, as they may be amended or modified from time to time, is disfavored.
This comment provides the requirements for land use, structures, and accessibility in SFPUC pipeline rights of way. This comments does not question the sufficiency of the analysis or mitigation measures contained in the EIR.
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RA3-8 Restoration
The SFPUC is not responsible for restoring or replacing any vegetation or improvement on the Right of Way damaged or demolished so that the SFPUC may access, maintain or repair its pipelines. The SFPUC will restore the ground with soil compacted to SFPUC standards. The vegetation or improvement owner is responsible any additional work or the restoration.
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA3-9 Vegetation
No trees or large shrubs may be planted within the Right of Way. Other vegetation may only be installed with the SFPUC’s prior written consent. For a list of plants that may be permitted in the Right of Way, please refer to SFPUC Integrated Vegetation Management Policy Section 13.005 at http://www.sfwater.org/index.aspx?page=431. The tenant or licensee is responsible for vegetation maintenance and removal.
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA3-10 Right of Way Loading Restrictions
The maximum loading on the Right of Way should not exceed traffic loading HS-20 on the paved surfaces when the pipeline has a minimum four-foot cover. Overburdened or additional live or dead loads such as load-bearing footings, pole foundations, or large boulders within the influence line of the pipe trench is prohibited.
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA3-11 Right of Way Cover Requirements
To prevent damage to the PUC's underground pipelines, an adjacent owner or tenant’s use of vehicles and equipment within twenty feet (20') of each side of the centerline of the PUC's pipelines (measured on the surface) are subject to the restrictions stated in Exhibit B.
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA3-12 URS was tasked with reviewing existing environmental documents to assess potential impacts to the San Francisco Public Utilities Commission (SFPUC) Hetch Hetchy Water and Power Division (HHWP) property, located on the Riverbank Army Ammunition Plant (RBAAP) Superfund Site. The HHWP utility currently bisects the northern portion the RBAAP site. In 1952, the City and County of San Francisco issued a permit to the U.S. Army to occupy and use the HHWP property crossing the RBAAP property.
This comment provides an introduction to a characterization of the SFPUC property located on the RAAP site. This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA3-13 To evaluate any potential impacts to the HHWP property from activities at the RBAAP site, URS reviewed the following documents provided by the SFPUC:
• Site Investigation Report Riverbank Army Ammunition Plant This comment lists the documents that were reviewed in order to evaluate any potential impacts to the SFPUC-owned property. This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
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Riverbank, California, March 2008 (CH2MHill, 2008);
• Environmental Condition of Property Phase I Report Riverbank Army Ammunition Plant, Riverbank, California, November 17, 2006 (CH2MHILL, 2006); and
• Second Five Year Review Report Final Riverbank Army Ammunition Plant, City of Riverbank Stanislaus County California, September 2006 (U.S. Army, 2006).
Based on a review of these documents, three areas of concern were identified associated with the HHWP property where it bisects the RBAAP property:
1. Site RBAAP-04/SWMU-12: A process waste sewer line made of Transite (asbestos cement) material crosses the HHWP property. Historically, there was a break in this line that released untreated process wastewater onto the HHWP property. Additionally, the
Transite pipe material itself is hazardous if disturbed.
2. Site RBAAP-09/SWMU 20: A stormwater line servicing the RBAAP stormwater system crosses HHWP property to connect to the stormwater retention ponds. Leaks in the stormwater line where it crosses HHWP property may have resulted in contamination of soil on HHWP property.
3. Site RBAAP-09/SWMU 20: The stormwater retention ponds located directly adjacent to the HHWP property have historically overflowed. These overflows may have resulted in contamination of soil on the HHWP property.
RA3-14 Site RBAAP-04: Process Waste Sewer Line
In 1972, a break occurred in the effluent sewer line that transported wastewater from the wastewater treatment plant to the facility evaporation percolation ponds, located off site adjacent to the Stanislaus River.
The break was at the intersection of the HHWP property. According to available information, this break was not discovered for 7 days, and an estimated 1 million gallons per day of wastewater were being discharged through the pipe at this time. An unknown volume of wastewater was released, sufficient to cause pooling at the ground surface (CH2MHILL 2006). Additionally, SFPUC understands that the sewer line was video surveyed, and that additional breaks in the line were observed as reported in the Nor Cal Pipeline Services Sewer Report, Project Name: Riverbank Army Ammunition Plant October 2009 (Nor Cal, 2009).
This comment suggests the completion of additional studies to evaluate whether or not contaminants of concern associated with the RAAP site are located within SFPUC-owned land.
As discussed in Chapter 4.9, Hazards and Hazardous Materials, on page 4.9-14, as future development applications for project within the RAAP site are received, the City will require that any hazardous materials issues be fully disclosed, analyzed, and mitigated to ensure against any risk relative to any nearby planned or existing land uses and their users. The recommended remediation activities identified in this comment and further discussed in Comments RA3-15 through RA3-23 would be addressed on a project-by-project basis, in site-specific hazardous waste analyses, and through remedial action plans, where necessary.
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According to the 2006 Phase I Report, an investigation was completed in the vicinity of the pipe leak during the Confirmatory Phase of the Contamination Survey. This investigation included collection of four soil sample cores in the vicinity of the pipe break, and one background sample. Samples were only analyzed for California Title 22 Metals, and results indicated only chromium, copper, and fluoride were present at concentrations close to or greater than three times background (CH2MHILL 2006). Therefore, the Feasibility Study recommended no further action in this area.
Because multiple contaminants of concern (COCs) associated with the RBAAP facility could have been present in the water in the effluent sewer line, it would be appropriate to collect samples for analysis beyond Title 22 Metals. Other contaminants associated with the site include: hexavalent chromium, volatile organic compounds (VOCs), total petroleum hydrocarbons (TPH), cyanide, and polychlorinated biphenyls (PCBs). VOCs would be less likely to persist in shallow soils, because the spill occurred in the 1970s. However, PCBs, TPH, hexavalent chromium, and cyanide could have been present in wastewater, and would be reasonably expected to be present in shallow soil in the vicinity of the break. Some of these COCs were sampled during the Remedial Investigation (RI) at other sewer-related sites at the RBAAP, but not at the sewer line break location.
URS recommends that additional samples be collected at the location of any breaks in the line, and sampled for these COCs. A review of the line video survey should be conducted to identify any breaks on or near the HHWP property. If new breaks on or adjacent to the HHWP property are observed in the video surveys, then additional sampling should be conducted in these areas as well. Additionally, because the Transite pipe represents a hazard to future water utility workers if left in place, the pipe should be removed when it is no longer in use, rather than abandoned in place.
RA3-15 Site RBAAP-09/SWMU 20: Storm Discharge Lines
Although no specific release from a break in the stormwater discharge lines has been documented in the reports reviewed, the discharge line crosses the HHWP to connect to the stormwater retention ponds.
Based on the Nor Cal Pipeline Services Sewer Report, SFPUC understands that this line was video surveyed and that breaks may have been This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR. Please refer to the response to Comment RA3-14 with regard to the mitigation of potential impacts related to hazardous materials.
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observed (Nor Cal, 2009). A review of the line video survey should be conducted to identify any breaks on the HHWP property. If any breaks in this line are present on or adjacent to the HHWP property, soil samples should be collected at and below the depth of the line and analyzed for Title 22 Metals, PCBs, TPH, hexavalent chromium, and cyanide. These contaminants are all COCs at the site, and could be present in any stormwater runoff transferred through this line.
RA3-16 Site RBAAP-09/SWMU 20: Stormwater Retention Ponds The Northwest Storm Reservoir is located adjacent to the Hetch Hetchy aqueduct on the HHWP property. Historically, this reservoir has overflowed in heavy rains. In 1974, the Army Environmental Hygiene Agency reported a sample collected from water in the Storm Reservoir had results showing elevated concentrations of selected heavy metals (CH2MHILL 2006).
During Phase I of the RI at the site, two sediment samples were collected from the reservoir and analyzed for total and hexavalent chromium, total and free cyanide, 1 ,1-dichloroethylene, and the organic persistent and bioaccumulative toxic substances ·listed in California Title 22 California Code of Regulations. The analytical results documented total chromium at levels greater than three times background.
Although it was determined that the reservoir was not a significant source of groundwater contamination, the potential shallow soil contamination was not considered (CH2MHILL 2006).
Because elevated concentrations of heavy metals have been detected in both water and sediment present in the stormwater reservoir, contaminants could potentially have migrated to the HHWP soils during an overflow. Although potential soil contamination from stormwater overflow is not likely to be a source of groundwater contamination, it would result in contaminated soil on the HHWP property. Therefore, samples should be collected on the HHWP property in the vicinity of the stormwater reservoir to confirm that contamination is not present.
Sample analysis should include Title 22 Metals, hexavalent chromium, PCBs, and cyanide.
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR. Please refer to the response to Comment RA3-14 with regard to the mitigation of potential impacts related to hazardous materials.
RA3-17 Regulatory and Guidance Information
The RBAAP site investigation was performed under Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Public Law (PL) 96-510 as amended by Superfund Amendment and This comment provides an introduction to Comments RA3-18 through RA3-22. This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
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Reauthorization Act (SARA) (PL 99-499) and the Community Environmental Response Facilitation Act (CERFA) PL 102-42. Title 40 environmental regulations and U.S. EPA guidance documents guided the environmental investigation, remedy selection, and Record of Decision (ROD). In addition, the 2006 Phase I ESA was a component of the Environmental Baseline Survey (EBS) performed under Department of Defense policy to support a future Finding of Suitability of Transfer (FOST). It appears that the data gaps identified in this letter are covered by the following regulations and guidance:
RA3-18 1) CERCLA Site Investigation: The site investigation generally followed the 1988 U.S. EPA Remedial Investigation I Feasibility Study (RifFS) Guidance (EPA/540/G-89/004); however, it appears that the selection of COCs for sites RBAAP-04 and RBAAP-09 did not include all the known wastes stored and released in those areas as required in the guidance. The liquid wastes released in these areas should have been investigated for all applicable COCs including hexavalent chromium, VOCs, TPH, cyanide, and PCBs. The incomplete COC selection created a data gap that propagated into the risk assessment and remedy selection stages of the CERCLA process.
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR. Please refer to the response to Comment RA3-14 with regard to the mitigation of potential impacts related to hazardous materials.
RA3-19 2) Remedy Selection: The remedy selection and ROD for this site generally followed the 1999 U.S. EPA Guide to Preparing Superfund Proposed Plans, Records Of Decision, And Other Remedy Selection Decision Documents Guidance (EPA 540-R-98-031); however, it appears that the data gap from the missing COCs for sites RBAAP-04 and RBAAP-09 carried through from the site investigation phase to the risk assessment and remedy selection phase. The evaluation of the nine criteria could not take into account the potential COCs at sites RBAAP-04 and RBAAP-09 because no information was available regarding the presence of all the potential COCs. Following U.S. EPA guidance any minor changes to the remedy required by new information could be documented in the Administrative Record and/or a future ROD Amendment.
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR. Please refer to the response to Comment RA3-14 with regard to the mitigation of potential impacts related to hazardous materials.
RA3-20 3) Five-Year Review: The 2006 Second Five Year Review Report Riverbank Army Ammunition Plant prepared by AHTNA generally followed the U.S. EPA 2001 Comprehensive Five-Year Review Guidance (EPA 540-R-01-007); however, the COC data gaps for sites RBAAP-04 and RBAAP-09 were not identified in the review. The U.S.
EPA concurred with the U.S. Army that the remedy was protective of human health and the environment; however, the Five-Year Review This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR. Please refer to the response to Comment RA3-14 with regard to the mitigation of potential impacts related to hazardous materials.
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discussed future implementation of Institutional Controls at the site and continuing RCRA closure for the Industrial Wastewater Collection System. It appears that the COC data gaps for sites RBAAP-04 and RBAAP-09, and the potential presence of utility worker risk from COCs and from the buried Transite pipe should be addressed in the Institutional Controls and RCRA closure that are currently in progress.
If additional data are collected as requested in this letter the results could be appended to the Administrative Record and/or included in a future ROD amendment depending on whether the findings are significant. In addition, the management in place of the buried Transite pipe addressed through Institutional Controls or RCRA closure should be documented in the administrative record and/or in a future ROD amendment, as required.
RA3-21 4) Property Transfer: The potential presence of COCs that were not sampled for at the three locations identified above and the presence of the Transite pipe are covered under CERCLA 120(h) (as amended) which requires that the government certify that "all remedial action necessary to protect human health and the environment with respect to any such substance remaining on the property has been taken before the date of such transfer."
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR. Please refer to the response to Comment RA3-14 with regard to the mitigation of potential impacts related to hazardous materials.
RA3-22 5) Environmental Baseline Survey: The general requirement in CERCLA 120(h) is defined in more detail in DOD policy, in 40 CFR 373, and in ASTM Method D6008-96(2005) "Standard Practice for Conducting Environmental Baseline Surveys." The 2006 Phase I ESA prepared by CH2M Hill generally followed ASTM D6008-96 (2005); however, although this standard explicitly calls for a detailed review of records associated with spills (Section 7.3.1) and contamination from runoff (7.3.19) the COC data gaps for sites RBAAP-04 and RBAAP-09 were not identified. Under the ASTM D6008-96 (2005) standard "if current records are incomplete regarding the nature and extent of contaminant sources, the user or environmental professional will note the strategy for completing relevant records." Since the COC data gaps in RBAAP-04 and RBAAP-09 were not identified or addressed it appears that the 2006 Phase I ESA overlooked the potential COCs in these areas.
This comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR. Please refer to the response to Comment RA3-14 with regard to the mitigation of potential impacts related to hazardous materials.
RA3-23 Recommendations
In summary, URS recommends that additional sampling be conducted in the three areas of concern described above to determine if soil on the HHWP property has been impacted. Additionally, URS recomThis comment provides recommendations with respect to remediating the RAAP site. Please refer to the response to Comment RA3-14 with regard to the mitigation of potential impacts related to hazardous materials.
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mends that the video survey of the wastewater and stormwater lines be reviewed to target sampling around any breaks on-or in the vicinity ofthe HHWP property. Samples should be analyzed for COCs, including Title 22 Metals, hexavalent chromium, PCBs, and cyanide. Lastly, the disposition of the Transite wastewater line after it is no longer in use should be addressed to mitigate risks to future utility workers. The responsibility for addressing the risks from the pipe should be with the U.S. Army, rather than the HHWP.
Stanislaus Consolidated Fire Protection District
RA4-1 Stanislaus Consolidated Fire Protection District (SCFPD} has reviewed the "Draft Environmental Impact Report (EIR} Riverbank Local Redevelopment Authority Specific Plan for Riverbank Army Ammunition Plant" and wishes to have the following comments included:
This comment acknowledges that the Stainslaus Consolidated Fire Protection District has reviewed the EIR and introduces ensuing comments, but does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA4-2 1. The formation of Community Services Districts and an improvement to SCFPD Development Fees needed to fund the anticipated staffing and capital assets is referenced in the Draft EIR but should be included as a mitigation measure with identifiable benchmarks.
The EIR includes Mitigation Measure PUB-1 which requires the City to negotiate with Stanislaus Consolidated Fire Protection District to establish a financing structure that requires development fees from future development resulting from implementation of the RAAP Specific Plan to contribute to the construction of new fire protection facilities. The benchmarks requested in this comment will be agreed upon prior to construction of future development under the RAAP Specific Plan.
RA4-3 2. For ALL mitigation measures, benchmarks shall be identified prior to the adoption of the EIR, which will trigger the implementation of said measures.
This comment requests that benchmarks be included in mitigation measures prior to the certification of the EIR. With respect to benchmarks and safety-related mitigation measures, please see response to Comment RA4-2.
Stanislaus County
RA5-1 The Stanislaus County Environmental Review Committee (ERC) has reviewed the subject project and has determined that it may have a significant effect on the environment.
The following comments/conditions are submitted by the Department of Public Works, Senior Land Development Coordinator:
This comment acknowledges that the Stanislaus County Environmental Review Committee has reviewed the EIR and introduces ensuing comments, but this comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR.
RA5-2 • The County's Public Works Transit Division currently operates transit service in the City of Riverbank and plans to implement Dial-A-Ride (DAR) service in the City of Riverbank beginning August 5, 2013. As a result of the service improvements planned for 2013, the service boundary for the DAR service in the City has been extended from Claus Road to Eleanor Avenue and to Montgomery Rd. The Transit The Specific Plan identifies potential transit stop locations along Claus and Claribel Road.
The final location transit stops along the Project frontage will be coordinated with the Transit Division when final design plans are prepared.
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Division is recommending that any future and potential transit stops to be located along both Claus and Claribel Roads should be coordinated with the Transit Division to ensure it may provide input on the location of these amenities.
RA5-3 • Mitigation measures state that each development shall pay its fair share for both the Claribel at Coffee and Claribel at Roselle intersections for left turn pockets. Developments may require direct mitigation prior to any future widening project, therefore, each development shall be responsible for direct mitigation including, but not limited to, the construction of right turn lanes, additional through lanes, and increased corner radiuses for larger vehicles. These mitigations and fair share contributions should not be limited to the intersections of Claribel at Coffee and Claribel at Roselle intersections.
The intersections of Coffee Road and Roselle Avenue at Claribel Road were identified in the Draft EIR as operating at a deficient level of service in the existing condition, prior to addition of traffic from the Project (LOS F during both peak hours). The addition of traffic from the Project would worsen LOS F conditions at both intersections during the morning and evening peak hours. The recommended mitigation measure is to signalize the Coffee Road and Roselle Avenue at Claribel Road intersections and construct left-turn pocket (Mitigation Measures TRANS-1 and TRANS-2). These improvements are included in the StanCOG RTP in conjunction with other improvements, further described below. Stanislaus County Plans to start construction on the widening on Claribel Road between McHenry Avenue and Oakdale Road to provide two travel lanes in each direction and improvements at the Claribel Road/Coffee Road intersection, including signalization and turn pockets. The planned improvements would result in acceptable operations of the intersection with the addition of Project traffic. Construction is scheduled for 2014. Improvements at the Claribel Road/Roselle Avenue intersection, including signalization, are scheduled for construction in 2015/2016. The Project would be required to pay local and regional fees that would contribute to construction of planned improvements along the corridor.
RA5-4 • The EIR should not consider the North County Corridor in its baseline condition as a route has not yet been adopted. Upon adoption, the Specific Plan should be revised with the updated traffic model.
The North County Corridor (NCC) alignment considered in the Draft EIR is consistent with the alignment identified in the State Route 108 East Route Adoption project as of the time this analysis was conducted. The Draft EIR does recognize that the ultimate alignment of the NCC is still under evaluation and a preferred route has not yet been adopted. One alignment currently under consideration would construct the NCC along Claribel Avenue, which could have Project site access and circulation implications from Claus and Claribel Roads, as it would eliminate the potential for access to be provided from Claribel Road and would restrict the numnber and location of access points from Claus Road. Once the preferred alignment is selected, the Specific Plan and associated technical documents may need to be modified to reflect site access and circulation changes necessary to accommodate the roadway construction.
RA5-5 • Road widening of Claribel Road and Claus Road are mentioned in the summary but not considered in the mitigation measures. Please include this as part of the mitigation measures.
As described in Section 4.16 of the Draft EIR, the Project contributes traffic to the Claribel Road corridor. Two intersection impacts were identified in the Existing Plus Project condition as Project traffic would worsen already deficient conditions at two intersections. Mitigation measures were identified (see response to RA5-3). The Project would also add traffic to the Claus Road corridor. No Project impacts were identified in the Existing Plus Project Scenario. The StanCOG RTP identifies widening of Claribel and Claus Road as Tier I improvements that are expected to be in place by 2025 and there are no Project specific mitigation measures other than to pay applicable fees.
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RA5-6 • Measure Trans-3 states "Future developers within the RAAP area shall contribute their fair share towards improvements at the intersections identified above." Table 4.16-9 shows Claribel at Coffee and Claribel at Roselle intersections while the intent of Trans-3 is for the intersections of Atchison Street (State Route 108) at 1st Street, State Route 108 at Claus Road and State Route 1 08 at Patterson Road. This should be clearly identified in the mitigation measures.
Mitigation Measure TRANS-3 has been amended as follows:
Mitigation Measure TRANS-3: Future developers within the RAAP area shall contribute their fair share towards improvements at the intersections identified above, though the payment of local and regional traffic fees, that improve turning radii for large trucksto provide adequate turning radii in conformance with STAA requirements at intersections on State Route 108, specifically at the intersections of Atchison Street (State Route 108)/1st Street, State Route 108/Claus Road and State Route 108/Patterson Road, though the payment of local and regional traffic fees. No other improvements have been identified for are needed to mitigate project impacts at these intersections.
RA5-7 • In addition, Measure TRANS-5 and Measure TRANS-1 are conflicting measures for the intersection at Claribel and Coffee. Please provide clarifying information to Angie Halverson, Senior Land Development Coordinator with the Department of Public Works.
TRANS-1 identifies improvements that would need to be constructed in the near-term at the Claribel Road/Coffee Road intersection to provide acceptable operations, including signalization and provision of left-turn pockets on all approaches. TRANS-5 identifies long-term improvements, beyond those already planned for, that would need to be constructed at this intersection to accommodate planned development in the area over the next 20 to 30 years.
The cumulative impact at this intersection was identified as significant and unavoidable due to the uncertainty in the timing of constructing the long-term improvements.
San Joaquin Valley Air Pollution Control District
RA6-1 The San Joaquin Valley Unified Air Pollution Control District (District) has reviewed the Specific Plan and Draft Environmental Impact Report (EIR) for the Riverbank Army Ammunition Plant (RAAP) project. The project includes the development of a 146-acre project site with up to 119,058 sf new commercial/retail space, 1,411,542 sf of industrial space (673,625 sf existing, 737,917 sf new), and 116,637 sf of new office/research and development space.
As discussed in the EIR, the Specific Plan is a program level project and should include a discussion of policies, which when implemented, will reduce or mitigate impacts on air quality at the individual project level. To aid the City of Riverbank in addressing project specific issues at the program level and review the feasibility of all potential mitigation measures, the District offers the following comments and recommendations.
This comment acknowledges that the San Joaquin Valley Air Pollution Control District has reviewed the EIR and introduces ensuing comments, but this comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR. No response is required.
RA6-2 Criteria Pollutant Emissions
1. Mitigation Measures AQ-1a and AQ-2 have been incorporated into the project to reduce potential impacts from construction and operational activities associated with the buildout of the Specific Plan. The discussions in the EIR and the mitigation measures indicate that all Mitigation Measure AQ-1a has been amended as follows:
Mitigation Measure AQ-1a: Each individual project component of the Specific Plan, including those projects allowed by right, shall be analyzed for significant construction period air quality impacts. For each project-level analysis, a construction emissions estimate will be made by SJVAPCD using the latest SJVAPCD accepted methodology and will be compared
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future projects within the RAAP will require additional emissions analysis and will be mitigated in accordance with District Rule 9510 (Indirect Source Review). However, the mitigation measures as written are unclear as to whether they are meant to: (1) ensure that future development project will be compliant with CEQA requirements, (2) ensure that all future development projects would comply with District Rule 9510 (Indirect Source Review) requirements, or (3) ensure compliance with both CEQA and District Rule 9510. The District recommends that discussions in the EIR and Mitigation Measure AQ-1a and AQ-2 be amended, or new measures added, to clarify the intent of each measure and to identify how the measures will be made enforceable by the City of Riverbank. The District offers the following recommendations:
to accepted thresholds of significance. Means of mitigating construction period impacts to a less-than-significant level include, but are not limited to, Mitigation Measures AQ-1a through AQ-1d.
Since approval of the RAAP Specific Plan may constitute the final discretionary approval by the City of Riverbank, each individual project component, including those projects allowed by right, shall be required to demonstrate to the SJVAPCD compliance with construction period requirements of Rule 9510 prior to issuance of the first building and/or grading permits as a condition of project approval. The applicant shall document, to the City’s reasonable satisfaction, its compliance with this mitigation measure.
Mitigation Measure AQ-2 has been amended as follows:
Mitigation Measure AQ-2: Each individual project component of the Specific Plan, including those projects allowed by right, shall be analyzed for significant construction period air quality impacts. For each project-level analysis, an operational emissions estimate will be made by SJVAPCD using the latest SJVAPCD accepted methodology and will be compared to accepted thresholds of significance. Means of mitigating operational period impacts to a less-thansignificant level include, but are not limited to, improving transportation and transit design (e.g., improved bikeways, transit infrastructure, and pedestrian enhancements); contributing a project’s fair share to the Air Quality Mitigation Fee Fund; and contributing a project’s fair share towards Transportation Control Measures implementation programs. For each individual project, the applicant shall document, to the City’s reasonable satisfaction, its compliance with this mitigation measure.
Since approval of the RAAP Specific Plan may constitute the final discretionary approval by the City of Riverbank, each individual project component, including those projects allowed by right, shall be required to demonstrate to the SJVAPCD compliance with operational period requirements of Rule 9510 prior to issuance of the first building and/or grading permits as a condition of project approval. For each individual project, the applicant shall document, to the City’s reasonable satisfaction, its compliance with this mitigation measure.
Each individual project, including those projects allowed by right, that introduce significant sources of air pollutant emissions or stationary sources of TACs shall complete separate ambient air quality analysis and health risks assessments to ensure that violations of ambient air quality standards do not occur, including an analysis of cumulative emissions from the RAAP Specific Plan. For each individual project, the applicant shall document, to the City’s reasonable satisfaction, its compliance with this mitigation measure.
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RA6-3 1 a) If the intent of the mitigation measure is to ensure compliance with CEQA requirements: Table 5-1 of the Specific Plan identifies allowed uses within the various development districts within the RAAP plan area. Some of these uses appear to be allowed by right (ministerial approvals only), while others would require additional conditions or the issuance of a use permit (discretionary approvals). As CCR§ 15268 exempts ministerial projects from CEQA requirements, it is unclear whether the City will require additional analysis of construction and operational emissions for all projects within the RAAP plan area, or whether these requirement will be only for projects requiring additional conditions or use permits. It is also unclear whether the City will require project-level developments to mitigate impacts on air quality to less than significant. The District recommends that the discussions on construction and operational related impacts and Mitigation Measure AQ-1 a and AQ-2 be amended to clarify: which projects, if any, would be considered ministerial approvals and which would require additional review; whether projects must mitigate to less-than-significant; and the actions the City will take to enforce the required mitigation.
Please refer to response RA6-2 above.
RA6-4 1 b) If the intent of the mitigation measure is to ensure compliance with District Rule 9510: As previously discussed, Table 5-1 identifies allowed uses within the various development districts within the RAAP plan area, some of which appear to be allowed uses by right with no further CEQA analysis required. As such, approval of the RAAP Specific Plan may constitute the final discretionary approval by the City of Riverbank for some uses identified in Table 5-1. The District recommends that the mitigation measures be amended to include a requirement for all applicants within the RAAP plan area, including those projects allowed by right, to demonstrate to the City compliance with Rule 9510 prior to issuance of the first building and/or grading permits as a condition of project approval.
Please refer to response RA6-2 above.
RA6-5 1 c) If the intent of the mitigation measures are to ensure compliance with both CEQA and District Rule 9510 requirements: The District recommends that the measures be amended to include all District recommendations discussed above.
Please refer to response RA6-2 above.
RA6-6 For project emissions that would be significant and unavoidable, the District recommends the environmental document be revised to inThe emissions from the RAAP Specific Plan are considered significant, because they are compared to the District’s recommended significance thresholds that apply to projects. As a re-
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clude a discussion of the feasibility of implementing a voluntary emission reduction agreement (VERA) to mitigate project specific impacts to less than significant levels. A VERA is a mitigation measure by which the project propoent provides pound-for-pound mitigation of emissions increases through a process that develops, funds, and implements emission reduction projects, with the District serving a role of administrator of the em1ss1ons reduction projects and verifier of the successful mitigation effort. To implement a VERA, the project proponent and the District enter into a contractual agreement in which the project proponent agrees to mitigate project specific emissions by providing funds for the District's Emission Reduction Incentive Program (ERIP). The funds are disbursed by ERIP in the form of grants for projects that achieve emission reductions. Thus, project specific impacts on air quality can be fully mitigated. Types of emission reduction projects that have been funded in the past include electrification of stationary internal combustion engines (such as agricultural irrigation pumps), replacing old heavy-duty trucks with new, cleaner, more efficient heavy-duty trucks, and replacement of old farm tractors.
The District has been developing and implementing VERA contracts with project developers to mitigate project specific emissions since 2005. It is the District's experience that implementation of a VERA is a feasible mitigation measure, and effectively achieves the emission reductions required by a lead agency, by mitigating project related impacts on air quality to a net zero level by supplying real and contemporaneous emissions reductions. To assist the Lead Agency and project proponent in ensuring that the environmental document is compliant with CEQA, the District recommends the environmental document be amended to include an assessment of the feasibility of implementing a VERA.
Additional information on implementing a VERA can be obtained by contacting District CEQA staff at (559) 230-6000.
sult, emissions from the plan are higher than those that would occur from any one project.
Land use developments constructed as part of this project would be subject to the requirements of the District’s Indirect Source Review Rule (ISR), SJVAPCD Rule 9510. As discussed on pages 4.3-11 of the Draft EIR, ISR would require substantial reductions of construction and operational period emissions from the land use activities. This is in addition to SJVAPCD requirements to control emissions from construction activities (Rule 8021 which enforces Regulation VIII described on page 4.3-12 of the Draft EIR), requirements to reduce worker commute emissions (Rule 9410, described on page 4.3-12 of the Draft EIR), SJVAPCD rules and regulations regarding new sources of air pollutants emissions (i.e., those that apply to SJVAPCD regulated sources), and CARB requirements that apply to construction equipment fleets, truck fleets and portable equipment. As a result, projects developed under the RAAP would be required to reduce emissions at a level probably greater than other similar projects in the State or perhaps the country. The large quantity of the emissions predicted in the Draft EIR is related to the type and size of the plan that would consist of numerous projects. The RAAP is actually an accumulation of projects that have been envisioned in the planning process conducted by the City (i.e., beginning with the General Plan Update).
Smaller land use projects that, together, make up the entire project could be proposed. This would certainly result in much lower, and perhaps, insignificant emissions at a project-level analysis. However, the Draft EIR provided emissions estimates for the entire RAAP so that mitigation measures to reduce all environmental impacts can be consistently applied to fairly and effectively reduce significant impacts. The City would anticipate that SJVAPCD and CARB requirements would effectively reduce project air pollutant emissions to the extent feasible.
RA6-7 Health Risks
3. The DEIR includes a health risk assessment (HRA); however, it does not include an ambient air quality analysis (AAQA). The District offers the following comments and recommendations regarding the health risk discussion and analysis presented in the EIR:
Violations of ambient air quality standards were assessed by modeling the emissions from anticipated land uses constructed as part of the entire RAAP Specific Plan and comparing those to District emission thresholds. Emissions exceeding the thresholds were assumed to cause or contribute to violations of ambient air quality standards and were identified as significant. Because this is a Specific Plan, there is not enough detail to model on-site emissions from individual land uses that could be built out as part of the RAAP Specific Plan. Individu-
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al projects and their emissions are required to be analyzed and compared to appropriate threshold per SJVAPCD significance thresholds.
RA6-8 3a) The discussion on exposure of sensitive receptors to substantial pollutant concentrations did not provide adequate information regarding the details of the HRA, nor were the details provided in the appendices to the EIR. Furthermore, the actual modeling files were not submitted to the District for review. As such, the District cannot make a determination as to the level of compliance with District policies and methodologies for performing HRA analyses.
The HRA was updated to include the health risks associated with onsite activity associated with the RAAP Specific Plan build-out in accordance with District modeling guidance. The Draft EIR now addresses health risks from both on-site and off-site sources. On-site sources would be diesel particulate matter emitted by truck travel at slow speeds within the Specific Plan. Stationary sources of contaminant emissions (e.g., diesel generators, fueling stations or dry cleaners) have not been identified. These types of sources could be included as part of projects proposed under the RAAP Specific Plan. These types of sources would be subject to State and District rules and regulations to minimize the emissions and associated health risks.
Maximum excess lifetime cancer risk from on-site sources would be 4.3 per million. An analysis of off-site sources, although not recommended by the District, is included in the analysis.
Section 4.3, Air Quality, of the Draft EIR has been revised to include both Clause Road traffic and emissions from the Specific Plan area, where the cumulative excess lifetime cancer risk would be 9.0 per million. Appendix B of the Draft EIR has been updated to include the additional modeling information. AERMOD modeling input and output files are available from the City.
RA6-9 3b) The only emissions modeled in the HRA were diesel particulate emission (DPM) increases on Claus Road. The District's methodology for completing an HRA for development projects is to predict risk only for emissions of toxics within the boundaries of the project site excluding emissions from public highways. Because Claus Road is a public highway outside of the project area boundaries, any increase in DPM from traffic generated by the Specific Plan would not be considered as producing a risk associated with the project.
Please refer to response RA6-8 above.
RA6-10 3c) Buildout of the Specific Plan will result in emissions generated by diesel truck traffic from retail and industrial land uses, stationary sources used in manufacturing, and from commercial uses such as restaurants, fuel dispensing operations, and dry cleaning. (It should be noted that most future dry cleaning operations will not emit perchloroethylene; however, some perchloroethylene replacements may be or may contain toxic air contaminants.) Stationary source emissions from individual developments within the Northern and Southern Caps may be subject to District permitting regulations, in which case the District would perform a Risk Management Review (RMR) and AAQA as appropriate. However, please note that the District's analyses include only those emissions that the District has statutory authority and will not include emissions generated by mobile sources. As such, more Please refer to response RA6-8 above.
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Number Comment Response
detailed analyses is needed to comply with CEQA requirements.
RA6-11 3d) An AAQA should be performed to ensure that Federal and State ambient air quality standards for all criteria pollutants, including nitrogen dioxide, will not be violated. Concentration predictions need to be made for receptors surrounding the project that are in ambient air and not just residential or worker sites.
At the plan stage, there is not enough detail to model individual air pollutant sources. Emissions from the plan build-out, which could occur over many years was modeled and those levels were compared to emission thresholds contained in the District's Guide for Assessing and Mitigating Air Quality Impacts, adopted 1998 and revised in 2002 and 2004. Project details necessary to model ambient air quality concentrat5ions from the project site are not available. Appropriate analysis of ambient air quality standards would require sufficient detail of anticipated on-site activities that cause emissions and the corresponding project-specific traffic activity and type. That project information is not available at this time. The outcome of such a study may find that project contributions to localized concentrations of ozone and particulate matter (i.e., PM10 and PM2.5), like carbon monoxide, would be less than significant.
Given the lack of specific project information, the Draft EIR is not able to provide a reasonable prediction of localized nitrogen dioxide, PM10 and PM2.5 concentrations. Unlike the health risk assessment that addresses impacts at existing or locations of future sensitive receptors, these predictions are made at locations where any member of the public may be exposed.
Therefore, these types of analysis require inputs that reasonably reflect on-site and off-site activities with respect to potential receptors so that relatively accurate predictions of air pollutant levels can be made. Because traffic is the primary source of project carbon monoxide concentrations and the Draft EIR provides a reasonable worst-case forecast of traffic, carbon monoxide concentrations were predicted at receptors along roadways. This cannot be conducted for receptors on site and adjacent to different land uses within the project site or adjacent to the project boundaries.
RA6-12 3e) The HRA presented in the EIR is not adequate to make a determination of the significance of potential health impacts resulting from implementation of the Specific Plan and should not be considered to be a programmatic HRA. The District recommends that a program level HRA and AAQA be prepared. The District strongly recommends that the City or its consultants contact the District for more information regarding the appropriate modeling approach. More information on HRAs can be obtained by:
• Contacting District Technical Services staff by phone at 9559) 230- 6000;
• E-mailing inquiries to: [email protected]; or
• Visiting the District's website at:
http://www.valleyair.org/busind/pto/Tox_Resources/AirQualityMon itoring.htm.
The Draft EIR HRA analyzes the primary source of contaminant emissions that would be emitted from the RAAP Specific Plan, which is traffic. The HRA was modified to include estimates of on-site traffic activity, including the use of plan-specific truck traffic forecasts.
Because this analysis is conducted at the plan level, it does not include stationary sources of emissions that are not currently envisioned. As indicated under Response to Comment RA6-3 through RA6-5, project-level air quality analysis would be required as part of Mitigation Measure AQ-2.
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RA6-13 3f) Accurate quantification of health risks and operational em1ss1ons requires detailed site specific information, e.g. type of emission source, proximity of the source to sensitive receptors, and trip generation information. The required level of detail is typically not available until project specific approvals are being granted. As discussed above, it appears that allowed uses that do not require additional conditions or use permits may be exempt from additional CEQA analysis. However, some of these allowed uses may lead to increased health risks resulting from increases in diesel particulate matter and other emissions from mobile and stationary sources. Therefore, the District recommends the inclusion of a mitigation measure requiring a separate HRA and AAQA be completed for each new development project within the RAAP area, including those that would otherwise appear to be exempt from CEQA (such as those uses allowed by right as). These future analyses should include all mobile and stationary source emissions from each development. As new projects are constructed, the District recommends a cumulative analysis should be prepared to determine the total risk from the sources within the Specific Plan.
See Response to Comment RA6-3 through RA6-5, project-level air quality analysis would be required as part of Mitigation Measure AQ-2.
RA6-14 District Rules and Regulations
4. As discussed in the EIR, individual development projects within the scope of the RAAP Specific Plan would be subject to District Rule 9510 (Indirect Source Review) if upon full build-out of new developments, or the expansion of any existing building, the project would include or exceed any one of the following:
• 50 dwelling units
• 2,000 square feet of commercial space;
• 25,000 square feet of light industrial space;
• 1 00,000 square feet of heavy industrial space;
• 20,000 square feet of medical office space;
• 39,000 square feet of general office space; or
• 9,000 square feet of educational space; or
• 10,000 square feet of government space; or
• 20,000 square feet of recreational space; or
• 9,000 square feet of space not identified above; or
It is important to note that all projects within the scope of the EIR exceeding the thresholds identified above will be subject to Rule 9510.
As previously discussed, the adoption of the Specific Plan may constitute the final discretionary approval by the City for those allowed uses identified in Table 5-1. As such, the District strongly recommends the SJVAPCD requests that demonstration of compliance with SJVAPCD Rule 9510, Indirect Source Review, be made a condition of Project approval. Mitigation Measure AQ-2 requires applicants for individual, site-specific developments under the Specific Plan to comply with SJVAPCD’s Rule. Furthermore, mitigation measures identified in this EIR are included in the Mitigation Monitoring and Reporting Plan and are identified as Conditions of Approval.
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Number Comment Response
City contact the District's ISR staff to discuss the application process and how to adequately complete an Air Impact Assessment (AlA) Application. District ISR staff is available to meet with the City and/or its consultants to further discuss the requirements of Rule 9510. More information on District Rule 9510 can be obtained by:
• Calling the District's ISR staff at (559) 230-6000;
• E-mailing inquiries to: [email protected]; or
• Visiting the District's website at: http
://www.valleyair.org/ISRIISRHome.htm.
RA6-15 5. Individual development projects within the scope of the RAAP Specific Plan may also be subject to the following District rules and regulations: Regulation VIII, (Fugitive PM10 Prohibitions), Rule 2010 (Permits Required), Rule 2201 (New and Modified Stationary Source Review), Rule 4002 (National Emission Standards for Hazardous Air Pollutants), Rule 4102 (Nuisance), Rule 4601 (Architectural Coatings), and Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations).
The above list of rules is neither exhaustive nor exclusive. To identify other District rules or regulations that apply to individual projects or to obtain information about District permit requirements, project proponents are strongly encouraged to contact the District's Small Business Assistance Office at (209) 557-6446 prior to the start of construction activities. A complete list of current District rules can be found on the District's website at: www.valleyair.org/rules/1ruleslist.htm.
This comment has been noted. Future developments may be subject to SJVAPCD rules and regulations.
RA6-16 General Comments
6. The District recommends the discussions regarding the State and Federal Ambient Air Quality Standards (AAQS) and the District's current attainment plans be updated to reflect the most current information as follows:
This comment provides an introduction to Comments RA6-17 and RA6-18.
RA6-17 6a) The 2013 Federal Ambient Air Quality Standard for fine particulate matter (PM2.5) has been reduced from 15 µg/m3 to 12 µg/m3. The District recommends that Table 4.3-2 on page 4.3-15 in the EIR be amended to reflect the current PM2.5 AAQS. Current attainment status and AAQS can be found on the District's website at:
http://www.valleyair.org/aqinfo/attainment.htm.
This comment has been noted. As shown in Chapter 3 of this Final EIR, Table 4.3-2 of the Draft EIR has been amended to reflect this new standard.
RA6-18 6b) The District recommends that Table 4.3-2 on page 4.3-15 in the EIR be amended to reflect the current PM2.5 AAQS. Current attainment status and AAQS can be found on the District's website at:
This comment has been noted. As shown in Chapter 3 of this Final EIR, page 4.3-21 of the Draft EIR has been amended to reflect this new standard.
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Number Comment Response
http://www.valleyair.org/aqinfo/attainment.htm. The District approved the 2012 PM2.5 Plan on December 20, 2012. The plan was then approved by the California Air Resources Board (ARB) on January 24, 2013. This plan assures the San Joaquin Valley Air Basin will comply with the Environmental Protection Agency (EPA) 2006 PM2.5 standard by the 2019 deadline. The District recommends that the discussion on page 4.3-21 in the EIR be amended to reflect the current status of the District's PM2.5 attainment plan. A copy of the District's 2012 PM2.5 Plan can be found on the District's website at:
http://www.valleyair.org/Air_Quality_Pians/PM25Pians2012.htm.
RA6-19 7. Referral documents for future development projects with the scope of the RAAP Specific Plan should include a project summary detailing, at a minimum, the land use designation, project size, and proximity to sensitive receptors and existing emission sources, and should identify the project as being with the scope of the RAAP Specific Plan.
Future development applications under the RAAP Specific Plan would be required to adhere to the Mitigation Measures within the RAAP Specific Plan EIR. Subsequent environmental review would be required for future discretionary approvals. As part of the future environmental review, subsequent projects would be required to evaluate air quality and GHG emissions impacts and be required to consider proximity to sensitive receptors City of Modesto
LA1-1 Thank you for providing the City of Modesto the opportunity to review the Army Ammunition Plant Specific Plan and Draft EIR. The City of Modesto offers the following comments:
This comment acknowledges that the City of Modesto has reviewed the EIR and introduces ensuing comments, but this comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the EIR. No response is required.
LA1-2 1. The intersections of Claus / Sylvan and Claus / Plainview should be added to the set of traffic study intersections. Significant projectrelated traffic volumes can be expected to occur south of the project, along Claus Road; and,
The intersection of Claus Road and Plainview Road was not selected for inclusion in the study due to the local nature of Plainview Road. Plainview Road is approximately 1-mile in length, connecting Roselle Avenue in the west to Claus Road in the east, providing access to active agricultural uses. The project is not expected to increase traffic volumes on Plainview Road, although it would add through trips to the intersection. Based on changes in traffic volumes along the Claus Road corridor between Terminal Avenue and Claribel Road, very few vehicles turn to/from Plainview Road and the addition of Project traffic through the corridor is not expected to appreciably increase delay for vehicles turning from Plainview Road to Claus Road. The intersection of Claus Road and Sylvan Avenue was recently signalized and additional capacity provided with the construction of turn-pockets. Recent studies indicate that this intersection operates at acceptable service levels with the improvements and the addition of Project traffic is not expected to degrade intersection operations in the near-term, including studies for Village One and Marketplace. The StanCOG RTP identifies widening of Claus Road from Briggsmore Avenue to Claribel Road from two lanes to six lanes, including intersection improvements at the Sylvan Avenue/Claus Road intersection. The improvement is identified as a Tier I Project fully funded project that is planned to be constructed by 2025.
Widening of Sylvan Avenue from two lanes to four lanes from Claus Road to Roselle Avenue
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Number Comment Response
is also identified as a Tier I RTP project. With these planned improvements in place, project traffic is expected to represent less than 2 percent of the overall intersection capacity and would not appreciably change the overall planned intersection design. Therefore, the intersections of Claus Road at Plainview and Sylvan Roads were not added to the analysis.
LA1-3 2. The trip distribution of 13% of AM trips from the east on Claribel seems high, relative to the 19% of AM trips from the south on Claus.
This data should be confirmed.
Project trip distribution percentages were developed based on a review if existing travel patterns in the area, the location of existing and planned land uses within the region, and a select zone analysis using the Stanislaus Council of Governments (StanCOG) travel demand model.
Project trip distribution percentages as presented in the Draft EIR were reviewed and no changes were made to the analysis.
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........................................................................................................................
A PPENDIX B
A IR Q UALITY
........................................................................................................................
CalEEMod Version: CalEEMod.2011.1.1 Date: 3/27/2012
RAAP Specific Plan - 2030 Buildout
Stanislaus County, Annual
1.0 Project Characteristics
1.1 Land Usage
Land Uses Size Metric
Office Park 116 1000sqft
Industrial Park 1412 1000sqft
Strip Mall 119 1000sqft
1.2 Other Project Characteristics
Urbanization Rural Wind Speed (m/s) Utility Company Pacific Gas & Electric CompanyClimate Zone 3 2.2 Precipitation Freq (Days)
1.3 User Entered Comments 46
Project Characteristics - CO2 Intensity updated based on California Public Utilities Commission GHG Calculator, version 3c.Land Use - *Trips and VMT - Demolition - Vehicle Trips - Trip rates based on traffic report (Fehr & Peers, 2011).Energy Use - * 1 of 50
Land Use Change -
Sequestration - Energy Mitigation - Area Coating - *
2.0 Emissions Summary
2.1 Overall Construction
Unmitigated Construction
ROG NOx CO PM2.5
Total
SO2 Fugitive Bio- CO2
PM10
Exhaust
PM10
PM10 Total CO2e
Year tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
2011 1.92 12.70 11.32 0.02 1.33 0.63 1.96 0.32 0.63 0.95 0.00 1,671.04 1,671.04 0.15 0.00 1,674.142012 2.27 11.88 16.20 0.03 1.76 0.57 2.33 0.09 0.57 0.66 0.00 2,466.49 2,466.49 0.17 0.00 2,469.962013 2.07 10.89 14.89 0.03 1.76 0.51 2.28 0.09 0.51 0.60 0.00 2,438.78 2,438.78 0.15 0.00 2,441.942014 12.45 5.30 6.93 0.01 0.84 0.28 1.12 0.04 0.28 0.33 0.00 1,176.15 1,176.15 0.08 0.00 1,177.73 Total 18.71 40.77 49.34 0.54 1.99 2.54 0.00 7,752.46 0.55 0.00 SO2 Fugitive
PM10
Exhaust
PM10
0.09 5.69 1.99 7.69 7,752.46
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
7,763.77
Mitigated Construction
ROG NOx CO N2O CO2e
Year tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
2011 1.92 12.70 11.32 0.02 0.63 0.63 1.26 0.32 0.63 0.95 0.00 1,671.04 1,671.04 0.15 0.00 1,674.142012 2.27 11.88 16.20 0.03 0.09 0.57 0.66 0.09 0.57 0.66 0.00 2,466.49 2,466.49 0.17 0.00 2,469.96 2 of 50
2013 2.07 10.89 14.89 0.03 0.09 0.51 0.60 0.09 0.51 0.60 0.00 2,438.78 2,438.78 0.15 0.00 2,441.94 2014 12.45 5.30 6.93 0.01 0.04 0.28 0.33 0.04 0.28 0.33 0.00 1,176.15 1,176.15 0.08 0.00 1,177.73 Total 18.71 40.77 49.34 0.54 1.99 2.54 0.00 7,752.46 0.55 0.00 SO2 Fugitive
PM10
Exhaust
PM10
0.09 0.85 1.99 2.85 7,752.46
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
7,763.77
2.2 Overall Operational
Unmitigated Operational
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Area 8.34 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Energy 0.13 1.15 0.97 0.01 0.00 0.09 0.00 0.09 0.00 3,446.88 3,446.88 0.25 0.11 3,485.27 Mobile 5.84 20.04 42.31 0.15 13.63 0.67 14.30 0.24 0.61 0.85 0.00 12,183.35 12,183.35 0.32 0.00 12,190.16 Waste 0.00 0.00 0.00 0.00 3,574.93 0.00 3,574.93 211.27 0.00 8,011.65 Water 0.00 0.00 0.00 0.00 0.00 4,990.81 4,990.81 213.32 5.47 11,165.10 Total 14.31 21.19 43.28 0.16 13.63 0.67 14.39 0.24 0.61 0.94 3,574.93 20,621.04 5.58 34,852.18 Exhaust
PM10
PM10 Total
24,195.97 425.16
PM2.5
Total
Bio- CO2
Mitigated Operational
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Area 8.34 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Energy 0.13 1.15 0.97 0.01 0.00 0.09 0.00 0.09 0.00 3,446.88 3,446.88 0.25 0.11 3,485.27 Mobile 5.84 20.04 42.31 0.15 13.63 0.67 14.30 0.24 0.61 0.85 0.00 12,183.35 12,183.35 0.32 0.00 12,190.16 3 of 50
Waste 0.00 0.00 0.00 0.00 3,574.93 0.00 3,574.93 211.27 0.00 8,011.65 Water 0.00 0.00 0.00 0.00 0.00 4,990.81 4,990.81 213.32 5.47 11,165.10 Total 14.31 21.19 43.28 0.16 13.63 0.67 14.39 0.24 0.61 0.94 3,574.93 20,621.04 24,195.97 425.16 5.58 34,852.18 SO2 Fugitive
PM10
Exhaust
PM10
3.0 Construction Detail
3.1 Mitigation Measures Construction
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
3.2 Demolition - 2011
Unmitigated Construction On-Site
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Off-Road 0.25 2.00 1.15 0.00 0.10 0.10 0.10 0.10 0.00 170.30 170.30 0.02 0.00 170.72 4 of 50
Total 0.25 2.00 1.15 0.00 0.10 0.10 0.10 0.10 0.00 170.30 0.00 170.72 Exhaust
PM10
PM10 Total
170.30 0.02
PM2.5
Total
Bio- CO2
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.00 0.00 0.05 0.00 0.01 0.00 0.01 0.00 0.00 0.00 0.00 5.19 5.19 0.00 0.00 5.20 Total 0.00 0.00 0.05 0.00 0.01 0.00 0.01 0.00 0.00 0.00 0.00 5.19 0.00 5.20 Exhaust
PM10
PM10 Total
5.19 0.00
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Off-Road 0.25 2.00 1.15 0.00 0.10 0.10 0.10 0.10 0.00 170.30 170.30 0.02 0.00 170.72 Total 0.25 2.00 1.15 0.00 0.10 0.10 0.10 0.10 0.00 170.30 0.00 170.72 Exhaust
PM10
PM10 Total
170.30 0.02
PM2.5
Total
Bio- CO2
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
5 of 50
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.00 0.00 0.05 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 5.19 5.19 0.00 0.00 5.20 Total 0.00 0.00 0.05 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 5.19 0.00 5.20 Exhaust
PM10
PM10 Total
5.19 0.00
PM2.5
Total
Bio- CO2
3.3 Site Preparation - 2011
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Fugitive Dust 0.27 0.00 0.27 0.15 0.00 0.15 0.00 0.00 0.00 0.00 0.00 0.00 Off-Road 0.16 1.35 0.76 0.00 0.07 0.07 0.07 0.07 0.00 108.80 108.80 0.01 0.00 109.08 Total 0.16 1.35 0.76 0.15 0.07 0.22 0.00 108.80 0.01 0.00 SO2 Fugitive
PM10
Exhaust
PM10
0.00 0.27 0.07 0.34 108.80
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
109.08
Unmitigated Construction Off-Site
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.00 0.00 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.74 3.74 0.00 0.00 3.74 Total 0.00 0.00 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.74 3.74 0.00 0.00 3.74 Mitigated Construction On-Site
6 of 50
Exhaust
PM10
PM10 Total PM2.5
Total
ROG NOx CO SO2 Fugitive Bio- CO2
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Fugitive Dust 0.27 0.00 0.27 0.15 0.00 0.15 0.00 0.00 0.00 0.00 0.00 0.00 Off-Road 0.16 1.35 0.76 0.00 0.07 0.07 0.07 0.07 0.00 108.80 108.80 0.01 0.00 109.08 Total 0.16 1.35 0.76 0.15 0.07 0.22 0.00 108.80 0.01 0.00 SO2 Fugitive
PM10
Exhaust
PM10
0.00 0.27 0.07 0.34 108.80
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
109.08
Mitigated Construction Off-Site
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.00 0.00 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.74 3.74 0.00 0.00 3.74 Total 0.00 0.00 0.03 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.74 0.00 3.74 Exhaust
PM10
PM10 Total
3.74 0.00
PM2.5
Total
Bio- CO2
3.4 Grading - 2011
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Fugitive Dust 0.33 0.00 0.33 0.13 0.00 0.13 0.00 0.00 0.00 0.00 0.00 0.00 Off-Road 0.49 4.15 2.16 0.00 0.20 0.20 0.20 0.20 0.00 369.24 369.24 0.04 0.00 370.08 Total 0.49 4.15 2.16 0.00 0.33 0.20 0.53 0.13 0.20 0.33 0.00 369.24 369.24 0.04 0.00 370.08 7 of 50
SO2 Fugitive
PM10
Exhaust
PM10
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Unmitigated Construction Off-Site
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.01 0.01 0.09 0.00 0.01 0.00 0.01 0.00 0.00 0.00 0.00 10.38 10.38 0.00 0.00 10.40 Total 0.01 0.01 0.09 0.00 0.01 0.00 0.01 0.00 0.00 0.00 0.00 10.38 0.00 10.40 Exhaust
PM10
PM10 Total
10.38 0.00
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Fugitive Dust 0.33 0.00 0.33 0.13 0.00 0.13 0.00 0.00 0.00 0.00 0.00 0.00 Off-Road 0.49 4.15 2.16 0.00 0.20 0.20 0.20 0.20 0.00 369.24 369.24 0.04 0.00 370.08 Total 0.49 4.15 2.16 0.13 0.20 0.33 0.00 369.24 0.04 0.00 SO2 Fugitive
PM10
Exhaust
PM10
0.00 0.33 0.20 0.53 369.24
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
370.08
Mitigated Construction Off-Site
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 8 of 50
Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.01 0.01 0.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 10.38 10.38 0.00 0.00 10.40 Total 0.01 0.01 0.09 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 10.38 0.00 10.40 Exhaust
PM10
PM10 Total
10.38 0.00
PM2.5
Total
Bio- CO2
3.5 Building Construction - 2011
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Off-Road 0.32 2.11 1.26 0.00 0.15 0.15 0.15 0.15 0.00 192.39 192.39 0.03 0.00 192.94 Total 0.32 2.11 1.26 0.00 0.15 0.15 0.15 0.15 0.00 192.39 0.00 192.94 Exhaust
PM10
PM10 Total
192.39 0.03
PM2.5
Total
Bio- CO2
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.24 2.65 1.49 0.00 0.10 0.08 0.18 0.01 0.08 0.09 0.00 325.47 325.47 0.01 0.00 325.68 Worker 0.44 0.43 4.32 0.01 0.61 0.02 0.63 0.03 0.02 0.05 0.00 485.53 485.53 0.04 0.00 486.30 Total 0.68 3.08 5.81 0.01 0.71 0.10 0.81 0.04 0.10 0.14 0.00 811.00 811.00 0.05 0.00 811.98 Mitigated Construction On-Site
9 of 50
Exhaust
PM10
PM10 Total PM2.5
Total
ROG NOx CO SO2 Fugitive Bio- CO2
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Off-Road 0.32 2.11 1.26 0.00 0.15 0.15 0.15 0.15 0.00 192.39 192.39 0.03 0.00 192.94 Total 0.32 2.11 1.26 0.00 0.15 0.15 0.15 0.15 0.00 192.39 0.00 192.94 Exhaust
PM10
PM10 Total
192.39 0.03
PM2.5
Total
Bio- CO2
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.24 2.65 1.49 0.00 0.01 0.08 0.09 0.01 0.08 0.09 0.00 325.47 325.47 0.01 0.00 325.68 Worker 0.44 0.43 4.32 0.01 0.03 0.02 0.05 0.03 0.02 0.05 0.00 485.53 485.53 0.04 0.00 486.30 Total 0.68 3.08 5.81 0.01 0.04 0.10 0.14 0.04 0.10 0.14 0.00 811.00 0.00 811.98 Exhaust
PM10
PM10 Total
811.00 0.05
PM2.5
Total
Bio- CO2
3.5 Building Construction - 2012
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Off-Road 0.73 4.87 3.10 0.01 0.33 0.33 0.33 0.33 0.00 478.23 478.23 0.06 0.00 479.48 Total 0.73 4.87 3.10 0.01 0.33 0.33 0.33 0.33 0.00 478.23 478.23 0.06 0.00 479.48 10 of 50
Exhaust
PM10
PM10 Total PM2.5
Total
Bio- CO2
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.54 6.05 3.39 0.01 0.25 0.18 0.44 0.02 0.18 0.21 0.00 808.87 808.87 0.02 0.00 809.35 Worker 0.99 0.96 9.72 0.01 1.51 0.05 1.56 0.07 0.05 0.12 0.00 1,179.39 1,179.39 0.08 0.00 1,181.12 Total 1.53 7.01 13.11 0.02 1.76 0.23 2.00 0.09 0.23 0.33 0.00 1,988.26 0.00 1,990.47 Exhaust
PM10
PM10 Total
1,988.26 0.10
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Off-Road 0.73 4.87 3.10 0.01 0.33 0.33 0.33 0.33 0.00 478.23 478.23 0.06 0.00 479.48 Total 0.73 4.87 3.10 0.01 0.33 0.33 0.33 0.33 0.00 478.23 0.00 479.48 Exhaust
PM10
PM10 Total
478.23 0.06
PM2.5
Total
Bio- CO2
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.54 6.05 3.39 0.01 0.02 0.18 0.21 0.02 0.18 0.21 0.00 808.87 808.87 0.02 0.00 809.35 Worker 0.99 0.96 9.72 0.01 0.07 0.05 0.12 0.07 0.05 0.12 0.00 1,179.39 1,179.39 0.08 0.00 1,181.12 11 of 50
Total 1.53 7.01 13.11 0.02 0.09 0.23 0.33 0.09 0.23 0.33 0.00 1,988.26 0.00 1,990.47 Exhaust
PM10
PM10 Total
1,988.26 0.10
PM2.5
Total
Bio- CO2
3.5 Building Construction - 2013
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Off-Road 0.67 4.52 3.06 0.01 0.30 0.30 0.30 0.30 0.00 478.23 478.23 0.05 0.00 479.38 Total 0.67 4.52 3.06 0.01 0.30 0.30 0.30 0.30 0.00 478.23 0.00 479.38 Exhaust
PM10
PM10 Total
478.23 0.05
PM2.5
Total
Bio- CO2
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.49 5.51 3.07 0.01 0.25 0.16 0.42 0.02 0.16 0.19 0.00 808.85 808.85 0.02 0.00 809.28 Worker 0.90 0.86 8.76 0.01 1.51 0.05 1.56 0.07 0.05 0.12 0.00 1,151.71 1,151.71 0.08 0.00 1,153.28 Total 1.39 6.37 11.83 0.02 1.76 0.21 1.98 0.09 0.21 0.31 0.00 1,960.56 0.00 1,962.56 Exhaust
PM10
PM10 Total
1,960.56 0.10
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
12 of 50
Off-Road 0.67 4.52 3.06 0.01 0.30 0.30 0.30 0.30 0.00 478.23 478.23 0.05 0.00 479.38 Total 0.67 4.52 3.06 0.01 0.30 0.30 0.30 0.30 0.00 478.23 0.00 479.38 Exhaust
PM10
PM10 Total
478.23 0.05
PM2.5
Total
Bio- CO2
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.49 5.51 3.07 0.01 0.02 0.16 0.19 0.02 0.16 0.19 0.00 808.85 808.85 0.02 0.00 809.28 Worker 0.90 0.86 8.76 0.01 0.07 0.05 0.12 0.07 0.05 0.12 0.00 1,151.71 1,151.71 0.08 0.00 1,153.28 Total 1.39 6.37 11.83 0.02 0.09 0.21 0.31 0.09 0.21 0.31 0.00 1,960.56 0.00 1,962.56 Exhaust
PM10
PM10 Total
1,960.56 0.10
PM2.5
Total
Bio- CO2
3.5 Building Construction - 2014
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Off-Road 0.27 1.81 1.31 0.00 0.11 0.11 0.11 0.11 0.00 207.05 207.05 0.02 0.00 207.50 Total 0.27 1.81 1.31 0.00 0.11 0.11 0.11 0.11 0.00 207.05 0.00 207.50 Exhaust
PM10
PM10 Total
207.05 0.02
PM2.5
Total
Bio- CO2
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Fugitive NBio- CO2 Total CO2 CH4 N2O CO2e
PM2.5
Exhaust
PM2.5
13 of 50
Category tons/yr MT/yr
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.19 2.17 1.22 0.00 0.11 0.06 0.17 0.01 0.06 0.07 0.00 349.97 349.97 0.01 0.00 350.14 Worker 0.36 0.33 3.40 0.01 0.65 0.02 0.68 0.03 0.02 0.05 0.00 486.53 486.53 0.03 0.00 487.15 Total 0.55 2.50 4.62 0.01 0.76 0.08 0.85 0.04 0.08 0.12 0.00 836.50 0.00 837.29 Exhaust
PM10
PM10 Total
836.50 0.04
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Off-Road 0.27 1.81 1.31 0.00 0.11 0.11 0.11 0.11 0.00 207.05 207.05 0.02 0.00 207.50 Total 0.27 1.81 1.31 0.00 0.11 0.11 0.11 0.11 0.00 207.05 0.00 207.50 Exhaust
PM10
PM10 Total
207.05 0.02
PM2.5
Total
Bio- CO2
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.19 2.17 1.22 0.00 0.01 0.06 0.07 0.01 0.06 0.07 0.00 349.97 349.97 0.01 0.00 350.14 Worker 0.36 0.33 3.40 0.01 0.03 0.02 0.05 0.03 0.02 0.05 0.00 486.53 486.53 0.03 0.00 487.15 Total 0.55 2.50 4.62 0.01 0.04 0.08 0.12 0.04 0.08 0.12 0.00 836.50 836.50 0.04 0.00 837.29
3.6 Paving - 2014
14 of 50
Exhaust
PM10
PM10 Total PM2.5
Total
Bio- CO2
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Off-Road 0.14 0.88 0.57 0.00 0.08 0.08 0.08 0.08 0.00 72.77 72.77 0.01 0.00 73.01 Paving 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 0.14 0.88 0.57 0.08 0.08 0.00 72.77 0.01 0.00
SO2 Fugitive
PM10
Exhaust
PM10
0.00 0.08 0.08 72.77
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
73.01 Unmitigated Construction Off-Site
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.00 0.00 0.04 0.00 0.01 0.00 0.01 0.00 0.00 0.00 0.00 5.32 5.32 0.00 0.00 5.32 Total 0.00 0.00 0.04 0.00 0.01 0.00 0.01 0.00 0.00 0.00 0.00 5.32 0.00 5.32 Exhaust
PM10
PM10 Total
5.32 0.00
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Off-Road 0.14 0.88 0.57 0.00 0.08 0.08 0.08 0.08 0.00 72.77 72.77 0.01 0.00 73.01 Paving 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 15 of 50
Total 0.14 0.88 0.57 0.08 0.08 0.00 72.77 0.01 0.00
SO2 Fugitive
PM10
Exhaust
PM10
0.00 0.08 0.08 72.77
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
73.01 Mitigated Construction Off-Site
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.00 0.00 0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 5.32 5.32 0.00 0.00 5.32 Total 0.00 0.00 0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 5.32 0.00 5.32 Exhaust
PM10
PM10 Total
5.32 0.00
PM2.5
Total
Bio- CO2
3.7 Architectural Coating - 2014
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Archit. Coating 11.44 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Off-Road 0.01 0.08 0.05 0.00 0.01 0.01 0.01 0.01 0.00 7.01 7.01 0.00 0.00 7.03 Total 11.45 0.08 0.05 0.01 0.01 0.00 7.01 0.00 0.00
SO2 Fugitive
PM10
Exhaust
PM10
0.00 0.01 0.01 7.01
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
7.03 Unmitigated Construction Off-Site
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
16 of 50
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.03 0.03 0.33 0.00 0.06 0.00 0.07 0.00 0.00 0.00 0.00 47.50 47.50 0.00 0.00 47.56 Total 0.03 0.03 0.33 0.00 0.06 0.00 0.07 0.00 0.00 0.00 0.00 47.50 0.00 47.56 Exhaust
PM10
PM10 Total
47.50 0.00
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Archit. Coating 11.44 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Off-Road 0.01 0.08 0.05 0.00 0.01 0.01 0.01 0.01 0.00 7.01 7.01 0.00 0.00 7.03 Total 11.45 0.08 0.05 0.01 0.01 0.00 7.01 0.00 0.00
SO2 Fugitive
PM10
Exhaust
PM10
0.00 0.01 0.01 7.01
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
7.03 Mitigated Construction Off-Site
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Worker 0.03 0.03 0.33 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 47.50 47.50 0.00 0.00 47.56 Total 0.03 0.03 0.33 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 47.50 47.50 0.00 0.00 47.56 17 of 50
SO2 Fugitive
PM10
Exhaust
PM10
4.0 Mobile Detail
4.1 Mitigation Measures Mobile
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
ROG NOx CO N2O CO2e
Category tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Mitigated 5.84 20.04 42.31 0.15 13.63 0.67 14.30 0.24 0.61 0.85 0.00 12,183.35 12,183.35 0.32 0.00 12,190.16 Unmitigated 5.84 20.04 42.31 0.15 13.63 0.67 14.30 0.24 0.61 0.85 0.00 12,183.35 12,183.35 0.32 0.00 12,190.16 Total NA NA NA NA NA NA NA NA NA NA NA NA
4.2 Trip Summary Information
Average Daily Trip Rate Unmitigated Mitigated
NA NA NA NA
Land Use Weekday Saturday Sunday
Industrial Park 4,829.04 4,829.04 4829.04
939.60 939.60
Annual VMT Annual VMT
16,754,915 16,754,915
2,720,587 2,720,587
Strip Mall 4,339.93 4,339.93 4339.93 6,926,393 6,926,393 Office Park 939.60
26,401,895 26,401,895
4.3 Trip Type Information
Miles Trip %
Total 10,108.57 10,108.57 10,108.57
18 of 50
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Industrial Park 14.70 6.60 6.60 59.00 28.00 13.00
Office Park 14.70 6.60 6.60 33.00 48.00 19.00
Strip Mall 14.70 6.60 6.60 16.60 64.40 19.00
Exhaust
PM10
PM10 Total
5.0 Energy Detail
5.1 Mitigation Measures Energy
PM2.5
Total
ROG NOx CO SO2 Fugitive Bio- CO2
PM10
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Electricity Mitigated 0.00 0.00 0.00 0.00 0.00 2,194.15 2,194.15 0.22 0.08 2,224.92 Electricity
Unmitigated
0.00 0.00 0.00 0.00 0.00 2,194.15 2,194.15 0.22 0.08 2,224.92 NaturalGas
Mitigated
0.13 1.15 0.97 0.01 0.00 0.09 0.00 0.09 0.00 1,252.74 1,252.74 0.02 0.02 1,260.36 NaturalGas
Unmitigated
0.13 1.15 0.97 0.01 0.00 0.09 0.00 0.09 0.00 1,252.74 1,252.74 0.02 0.02 1,260.36 Total NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA
5.2 Energy by Land Use - NaturalGas
Unmitigated
NaturalGas Use ROG NOx CO SO2 Fugitive
PM10
Exhaust Total CO2
PM10
PM10 Total Fugitive
PM2.5
Exhaust
PM2.5
CH4 N2O CO2e
Land Use kBTU tons/yr MT/yr
PM2.5
Total
Bio- CO2 NBio- CO2
19 of 50
Industrial Park 1.93726e+007 0.10 0.95 0.80 0.01 0.00 0.07 0.00 0.07 0.00 1,033.80 1,033.80 0.02 0.02 1,040.0 Office Park 2.77588e+006 0.01 0.14 0.11 0.00 0.00 0.01 0.00 0.01 0.00 148.13 148.13 0.00 0.00 149.03 Strip Mall 1.32685e+006 0.01 0.07 0.05 0.00 0.00 0.00 0.00 0.00 Total 0.12 1.16 0.96 0.01 0.00 0.00 0.08
0.00 70.81 70.81 0.00 0.00 71.24
0.02 1,260.3
Mitigated
0.08 0.00 1,252.74 1,252.74 0.02
NaturalGas Use ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
N2O CO2e
Land Use kBTU tons/yr MT/yr
Bio- CO2 NBio- CO2 Total CO2 CH4
Industrial Park 1.93726e+007 0.10 0.95 0.80 0.01 0.00 0.07 0.00 0.07 0.00 1,033.80 1,033.80 0.02 0.02 1,040.0 Office Park 2.77588e+006 0.01 0.14 0.11 0.00 0.00 0.01 0.00 0.01 0.00 148.13 148.13 0.00 0.00 149.03 Strip Mall 1.32685e+006 0.01 0.07 0.05 0.00 0.00 0.00 0.00 0.00 Total 0.12 1.16 0.96 0.01 0.00 0.00 0.08
0.00 70.81 70.81 0.00 0.00 71.24
0.02 1,260.3
5.3 Energy by Land Use - Electricity
Unmitigated
0.08 0.00 1,252.74 1,252.74 0.02
Electricity Use ROG NOx N2O CO2e
Land Use kWh tons/yr MT/yr
CO SO2 Total CO2 CH4
Industrial Park 1.42894e+007 1,857.62 0.19 0.07 1,883.67 Office Park 1.5022e+006 195.29 0.02 0.01 198.02
Strip Mall 1.08647e+006 141.24 0.01 0.01 143.22
Total 2,194.15 0.22 0.09 2,224.91
20 of 50
Mitigated
Electricity Use ROG NOx N2O CO2e
Land Use kWh tons/yr MT/yr
CO SO2 Total CO2 CH4
Industrial Park 1.42894e+007 1,857.62 0.19 0.07 1,883.67 Office Park 1.5022e+006 195.29 0.02 0.01 198.02
Strip Mall 1.08647e+006 141.24 0.01 0.01 143.22
Total 2,194.15 0.22 0.09 2,224.91
6.0 Area Detail
6.1 Mitigation Measures Area
ROG NOx CO PM2.5
Total
SO2 Fugitive Bio- CO2
PM10
Exhaust
PM10
PM10 Total CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Mitigated 8.34 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Unmitigated 8.34 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA
6.2 Area by SubCategory
Unmitigated
21 of 50
SO2 Fugitive
PM10
Exhaust
PM10
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
ROG NOx CO N2O CO2e
SubCategory tons/yr MT/yr
PM10 Total Bio- CO2 NBio- CO2 Total CO2 CH4
Architectural
Coating
1.91 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Consumer Products 6.43 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Landscaping 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 8.34 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Exhaust
PM10
PM10 Total
0.00 0.00
PM2.5
Total
Bio- CO2
Mitigated
ROG NOx CO SO2 Fugitive
PM10
CO2e
SubCategory tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
Architectural
Coating
1.91 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Consumer Products 6.43 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Landscaping 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Total 8.34 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
7.0 Water Detail
7.1 Mitigation Measures Water
22 of 50
ROG NOx CO SO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 4,990.81 213.32 5.47 11,165.10
Unmitigated 4,990.81 213.32 5.47 11,165.10
Total NA NA NA NA NA NA NA NA
7.2 Water by Land Use
Unmitigated
Indoor/Outdoor
Use
ROG NOx CO SO2 Total CO2 CH4 N2O CO2e
Land Use Mgal tons/yr MT/yr
Industrial Park 6942.72 / 0 4,961.57 212.42 5.44 11,109.68 Office Park 20.6171 /
12.6363
20.48 0.63 0.02 38.82
Strip Mall 8.81463 /
5.40252
8.76 0.27 0.01 16.60
Total 4,990.81 213.32 5.47 11,165.10
Mitigated
Indoor/Outdoor
Use
ROG NOx N2O CO2e
Land Use Mgal tons/yr MT/yr
CO SO2 Total CO2 CH4
Industrial Park 6942.72 / 0 4,961.57 212.42 5.44 11,109.68 Office Park 20.6171 /
12.6363
20.48 0.63 0.02 38.82
Strip Mall 8.81463 /
5.40252
8.76 0.27 0.01 16.60
23 of 50
Total 4,990.81 213.32 5.47 11,165.10
8.0 Waste Detail
NOx CO
8.1 Mitigation Measures Waste
Category/Year
CO2e
tons/yr MT/yr
ROG SO2 Total CO2 CH4 N2O
Mitigated 3,574.93 211.27 0.00 8,011.65
Unmitigated 3,574.93 211.27 0.00 8,011.65
Total NA NA NA NA NA NA NA NA
8.2 Waste by Land Use
Unmitigated
Waste Disposed ROG NOx CO SO2 Total CO2 CH4 N2O CO2e
Land Use tons tons/yr MT/yr
Industrial Park 17378.5 3,527.67 208.48 0.00 7,905.74
Office Park 107.88 21.90 1.29 0.00 49.08
Strip Mall 124.95 25.36 1.50 0.00 56.84
Total 3,574.93 211.27 0.00 8,011.66
24 of 50
Mitigated
Waste Disposed ROG NOx N2O CO2e
Land Use tons tons/yr MT/yr
CO SO2 Total CO2 CH4
Industrial Park 17378.5 3,527.67 208.48 0.00 7,905.74
Office Park 107.88 21.90 1.29 0.00 49.08
Strip Mall 124.95 25.36 1.50 0.00 56.84
Total 3,574.93 211.27 0.00 8,011.66
9.0 Vegetation
25 of 50
2.1 Overall Construction
Vehicle Trips - Trip rates based on traffic report (Fehr & Peers, 2011).Energy Use - *Area Coating -
2.0 Emissions Summary
1.3 User Entered Comments 46
Project Characteristics - CO2 Intensity based on California Public Utilities Commission GHG Calculator version 3c.Land Use - * Climate Zone 3 2.2
Precipitation Freq (Days)
Urbanization Rural Wind Speed (m/s) Pacific Gas & Electric Company Industrial Park 674 1000sqft
1.2 Other Project Characteristics
Utility Company
1.0 Project Characteristics
1.1 Land Usage
Land Uses Size Metric
CalEEMod Version: CalEEMod.2011.1.1 Date: 3/26/2012
RAAP Existing
Stanislaus County, Annual
1 of 42
0.00 0.03 0.00 2,130.45 2,130.45 0.10 0.04 2,145.89
0.00 Energy 0.05 0.45 0.38 0.00 0.00 0.03
Area 3.41 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
1,813.46
2.2 Overall Operational
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
Total 6.79 12.70 12.29 0.02 0.26 0.71 0.97 0.14 0.71 0.85 0.00 1,810.07 1,810.07 0.17 0.00
0.20 0.21 0.00 539.68 539.68 0.05 0.00 540.64
1,272.82
2012 5.28 3.36 3.60 0.01 0.01 0.20 0.21 0.01
2011 1.51 9.34 8.69 0.01 0.25 0.51 0.76 0.13 0.51 0.64 0.00 1,270.39 1,270.39 0.12 0.00 N2O CO2e
Year tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
1,813.46
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
Total 6.79 12.70 12.29 0.02 1.10 0.71 1.81 0.14 0.71 0.85 0.00 1,810.07 1,810.07 0.17 0.00
0.20 0.21 0.00 539.68 539.68 0.05 0.00 540.64
1,272.82
2012 5.28 3.36 3.60 0.01 0.30 0.20 0.50 0.01
2011 1.51 9.34 8.69 0.01 0.80 0.51 1.31 0.13 0.51 0.64 0.00 1,270.39 1,270.39 0.12 0.00 N2O CO2e
Year tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
2 of 42
0.17 0.26 1,683.89 7,948.43 9,632.32 201.09 2.64 14,674.11 7,275.53
Total 4.98 5.95 13.50 0.01 1.29 0.17 1.50 0.06
Water 0.00 0.00 0.00 0.00 0.00 4,340.81 4,340.81 101.39 2.60
0.00 0.00 1,683.89 0.00 1,683.89 99.51 0.00 3,773.70
1,478.99
Waste 0.00 0.00
Mobile 1.52 5.50 13.12 0.01 1.29 0.17 1.47 0.06 0.17 0.23 0.00 1,477.17 1,477.17 0.09 0.00
0.00 0.03 0.00 2,130.45 2,130.45 0.10 0.04 2,145.89
0.00 Energy 0.05 0.45 0.38 0.00 0.00 0.03
Area 3.41 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.17 0.26 1,683.89 7,948.43 9,632.32 201.09 2.64 14,674.11 7,275.53
Total 4.98 5.95 13.50 0.01 1.29 0.17 1.50 0.06
Water 0.00 0.00 0.00 0.00 0.00 4,340.81 4,340.81 101.39 2.60
0.00 0.00 1,683.89 0.00 1,683.89 99.51 0.00 3,773.70
1,478.99
Waste 0.00 0.00
Mobile 1.52 5.50 13.12 0.01 1.29 0.17 1.47 0.06 0.17 0.23 0.00 1,477.17 1,477.17 0.09 0.00 3 of 42
0.00 0.00 0.00 2.08 2.08 0.00 0.00 2.08
2.08 Total 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00
Worker 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2.08 2.08 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.04 0.04 0.00 68.12 68.12 0.01 0.00 68.29
68.29 Total 0.10 0.80 0.46 0.00 0.04 0.04
Off-Road 0.10 0.80 0.46 0.00 0.04 0.04 0.04 0.04 0.00 68.12 68.12 0.01 0.00 N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
3.2 Demolition - 2011
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
3.0 Construction Detail
3.1 Mitigation Measures Construction
4 of 42
Total 0.05 0.45 0.25 0.00 0.09 0.02 0.11 0.05 0.02 0.07 0.00 36.27 36.27 0.00 0.00 36.36
0.02 0.02 0.00 36.27 36.27 0.00 0.00 36.36
0.00 Off-Road 0.05 0.45 0.25 0.00 0.02 0.02
Fugitive Dust 0.09 0.00 0.09 0.05 0.00 0.05 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
3.3 Site Preparation - 2011
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.00 0.00 0.00 2.08 2.08 0.00 0.00 2.08
2.08 Total 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00
Worker 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2.08 2.08 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.04 0.04 0.00 68.12 68.12 0.01 0.00 68.29
68.29 Total 0.10 0.80 0.46 0.00 0.04 0.04
Off-Road 0.10 0.80 0.46 0.00 0.04 0.04 0.04 0.04 0.00 68.12 68.12 0.01 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
5 of 42
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
36.36 Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
Total 0.05 0.45 0.25 0.00 0.09 0.02 0.11 0.05 0.02 0.07 0.00 36.27 36.27 0.00 0.00
0.02 0.02 0.00 36.27 36.27 0.00 0.00 36.36
0.00 Off-Road 0.05 0.45 0.25 0.00 0.02 0.02
Fugitive Dust 0.09 0.00 0.09 0.05 0.00 0.05 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.00 0.00 0.00 1.25 1.25 0.00 0.00 1.25
1.25 Total 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00
Worker 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.25 1.25 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
6 of 42
Mitigated Construction On-Site
0.00 0.00 0.00 4.15 4.15 0.00 0.00 4.16
4.16 Total 0.00 0.00 0.04 0.00 0.01 0.00 0.01 0.00
Worker 0.00 0.00 0.04 0.00 0.01 0.00 0.01 0.00 0.00 0.00 0.00 4.15 4.15 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
148.03
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
Total 0.20 1.66 0.87 0.00 0.13 0.08 0.21 0.05 0.08 0.13 0.00 147.69 147.69 0.02 0.00
0.08 0.08 0.00 147.69 147.69 0.02 0.00 148.03
0.00 Off-Road 0.20 1.66 0.87 0.00 0.08 0.08
Fugitive Dust 0.13 0.00 0.13 0.05 0.00 0.05 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
3.4 Grading - 2011
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.00 0.00 0.00 1.25 1.25 0.00 0.00 1.25
1.25 Total 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00
Worker 0.00 0.00 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.25 1.25 0.00 0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 7 of 42
0.28 0.28 0.00 366.46 366.46 0.05 0.00 367.50
367.50
Total 0.61 4.02 2.40 0.00 0.28 0.28
Off-Road 0.61 4.02 2.40 0.00 0.28 0.28 0.28 0.28 0.00 366.46 366.46 0.05 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
3.5 Building Construction - 2011
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.00 0.00 0.00 4.15 4.15 0.00 0.00 4.16
4.16 Total 0.00 0.00 0.04 0.00 0.00 0.00 0.00 0.00
Worker 0.00 0.00 0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 4.15 4.15 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
148.03
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
Total 0.20 1.66 0.87 0.00 0.13 0.08 0.21 0.05 0.08 0.13 0.00 147.69 147.69 0.02 0.00
0.08 0.08 0.00 147.69 147.69 0.02 0.00 148.03
0.00 Off-Road 0.20 1.66 0.87 0.00 0.08 0.08
Fugitive Dust 0.13 0.00 0.13 0.05 0.00 0.05 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
ROG NOx CO SO2 Fugitive Bio- CO2
PM10
Exhaust
PM10
PM10 Total
8 of 42
Worker 0.35 0.35 3.49 0.00 0.02 0.02 0.04 0.02 0.02 0.04 0.00 391.81 391.81 0.03 0.00 392.42
0.06 0.07 0.00 252.57 252.57 0.01 0.00 252.73
0.00 Vendor 0.19 2.06 1.16 0.00 0.01 0.06 0.07 0.01
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.28 0.28 0.00 366.46 366.46 0.05 0.00 367.50
367.50
Total 0.61 4.02 2.40 0.00 0.28 0.28
Off-Road 0.61 4.02 2.40 0.00 0.28 0.28 0.28 0.28 0.00 366.46 366.46 0.05 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.08 0.11 0.00 644.38 644.38 0.04 0.00 645.15
392.42
Total 0.54 2.41 4.65 0.00 0.57 0.08 0.65 0.03
Worker 0.35 0.35 3.49 0.00 0.49 0.02 0.51 0.02 0.02 0.04 0.00 391.81 391.81 0.03 0.00
0.06 0.07 0.00 252.57 252.57 0.01 0.00 252.73
0.00 Vendor 0.19 2.06 1.16 0.00 0.08 0.06 0.14 0.01
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
9 of 42
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.04 0.05 0.00 317.70 317.70 0.01 0.00 318.06
191.72
Total 0.24 1.10 2.11 0.00 0.29 0.04 0.32 0.01
Worker 0.16 0.16 1.58 0.00 0.25 0.01 0.25 0.01 0.01 0.02 0.00 191.44 191.44 0.01 0.00
0.03 0.03 0.00 126.26 126.26 0.00 0.00 126.34
0.00 Vendor 0.08 0.94 0.53 0.00 0.04 0.03 0.07 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.13 0.13 0.00 183.23 183.23 0.02 0.00 183.71
183.71
Total 0.28 1.87 1.19 0.00 0.13 0.13
Off-Road 0.28 1.87 1.19 0.00 0.13 0.13 0.13 0.13 0.00 183.23 183.23 0.02 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
3.5 Building Construction - 2012
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
Total 0.54 2.41 4.65 0.00 0.03 0.08 0.11 0.03 0.08 0.11 0.00 644.38 644.38 0.04 0.00 645.15 10 of 42
26.56 Unmitigated Construction Off-Site
Total 0.06 0.36 0.21 0.00 0.03 0.03 0.03 0.03 0.00 26.46 26.46 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
26.56 Paving 0.00 0.00 0.00
Off-Road 0.06 0.36 0.21 0.00 0.03 0.03 0.03 0.03 0.00 26.46 26.46 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
3.6 Paving - 2012
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.04 0.05 0.00 317.70 317.70 0.01 0.00 318.06
191.72
Total 0.24 1.10 2.11 0.00 0.01 0.04 0.05 0.01
Worker 0.16 0.16 1.58 0.00 0.01 0.01 0.02 0.01 0.01 0.02 0.00 191.44 191.44 0.01 0.00
0.03 0.03 0.00 126.26 126.26 0.00 0.00 126.34
0.00 Vendor 0.08 0.94 0.53 0.00 0.00 0.03 0.03 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.13 0.13 0.00 183.23 183.23 0.02 0.00 183.71
183.71
Total 0.28 1.87 1.19 0.00 0.13 0.13
Off-Road 0.28 1.87 1.19 0.00 0.13 0.13 0.13 0.13 0.00 183.23 183.23 0.02 0.00 11 of 42
0.00 0.00 0.00 2.03 2.03 0.00 0.00 2.03
2.03 Total 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00
Worker 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2.03 2.03 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
26.56 Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
Total 0.06 0.36 0.21 0.00 0.03 0.03 0.03 0.03 0.00 26.46 26.46 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
26.56 Paving 0.00 0.00 0.00
Off-Road 0.06 0.36 0.21 0.00 0.03 0.03 0.03 0.03 0.00 26.46 26.46 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.00 0.00 0.00 2.03 2.03 0.00 0.00 2.03
2.03 Total 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00
Worker 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2.03 2.03 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
12 of 42
Archit. Coating 4.68 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.00 0.00 0.00 7.71 7.71 0.00 0.00 7.72
7.72 Total 0.01 0.01 0.06 0.00 0.01 0.00 0.01 0.00
Worker 0.01 0.01 0.06 0.00 0.01 0.00 0.01 0.00 0.00 0.00 0.00 7.71 7.71 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
2.56 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
Total 4.69 0.03 0.02 0.00 0.00 0.00 0.00 0.00 0.00 2.55 2.55 0.00 0.00
0.00 0.00 0.00 2.55 2.55 0.00 0.00 2.56
0.00 Off-Road 0.01 0.03 0.02 0.00 0.00 0.00
Archit. Coating 4.68 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
3.7 Architectural Coating - 2012
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
13 of 42
N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
4.0 Mobile Detail
4.1 Mitigation Measures Mobile
0.00 0.00 0.00 7.71 7.71 0.00 0.00 7.72
7.72 Total 0.01 0.01 0.06 0.00 0.00 0.00 0.00 0.00
Worker 0.01 0.01 0.06 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 7.71 7.71 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 N2O CO2e
Category tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
2.56 Mitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
Total 4.69 0.03 0.02 0.00 0.00 0.00 0.00 0.00 0.00 2.55 2.55 0.00 0.00 Off-Road 0.01 0.03 0.02 0.00 0.00 0.00 0.00 0.00 0.00 2.55 2.55 0.00 0.00 2.56 14 of 42
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
ROG NOx CO SO2 Fugitive Bio- CO2
PM10
Exhaust
PM10
PM10 Total
5.0 Energy Detail
5.1 Mitigation Measures Energy
H-W or C-W H-S or C-C H-O or C-NW
Industrial Park 14.70 6.60 6.60 59.00 28.00 13.00
Land Use H-W or C-W H-S or C-C H-O or C-NW
2,502,218 2,502,218
4.3 Trip Type Information
Miles Trip %
Total 721.18 721.18 721.18
Annual VMT Annual VMT
Industrial Park 721.18 721.18 721.18 2,502,218 2,502,218 Land Use Weekday Saturday Sunday
NA
4.2 Trip Summary Information
Average Daily Trip Rate Unmitigated Mitigated
Total NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA
0.17 0.23 0.00 1,477.17 1,477.17 0.09 0.00 1,478.99
1,478.99
Unmitigated 1.52 5.50 13.12 0.01 1.29 0.17 1.47 0.06
Mitigated 1.52 5.50 13.12 0.01 1.29 0.17 1.47 0.06 0.17 0.23 0.00 1,477.17 1,477.17 0.09 0.00 15 of 42
0.01 496.47
5.3 Energy by Land Use - Electricity
Unmitigated
0.03 0.00 0.03 0.00 493.47 493.47 0.01
0.01 496.47
Total 0.05 0.45 0.38 0.00 0.00
Industrial Park 9.24728e+006 0.05 0.45 0.38 0.00 0.00 0.03 0.00 0.03 0.00 493.47 493.47 0.01 N2O CO2e
Land Use kBTU tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
CO SO2 Fugitive
PM10
Exhaust
PM10
NaturalGas Use ROG NOx
0.01 496.47
Mitigated
0.03 0.00 0.03 0.00 493.47 493.47 0.01
0.01 496.47
Total 0.05 0.45 0.38 0.00 0.00
Industrial Park 9.24728e+006 0.05 0.45 0.38 0.00 0.00 0.03 0.00 0.03 0.00 493.47 493.47 0.01 CH4 N2O CO2e
Land Use kBTU tons/yr MT/yr
PM2.5
Total
Exhaust Bio- CO2 NBio- CO2 Total CO2
PM10
PM10 Total Fugitive
PM2.5
Exhaust
PM2.5
NA
5.2 Energy by Land Use - NaturalGas
Unmitigated
NaturalGas Use ROG NOx CO SO2 Fugitive
PM10
Total NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA
0.00 0.03 0.00 493.47 493.47 0.01 0.01 496.47
496.47
NaturalGas
Unmitigated
0.05 0.45 0.38 0.00 0.00 0.03
NaturalGas 0.00 0.00 0.03 0.00 0.03 0.00 493.47 493.47 0.01 0.01 Mitigated
0.05 0.45 0.38
0.00 0.00 0.00 1,636.98 1,636.98 0.09 0.03 1,649.42
1,649.42
Electricity
Unmitigated
0.00 0.00
Electricity Mitigated 0.00 0.00 0.00 0.00 0.00 1,636.98 1,636.98 0.09 0.03 16 of 42
CO2e
Category tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
SO2 Fugitive Bio- CO2
PM10
Exhaust
PM10
ROG NOx CO PM10 Total
6.1 Mitigation Measures Area
0.03 1,649.42
6.0 Area Detail
0.03 1,649.42
Total 1,636.98 0.09
Industrial Park 6.82088e+006 1,636.98 0.09
N2O CO2e
Land Use kWh tons/yr MT/yr
Electricity Use ROG NOx CO SO2 Total CO2 CH4
0.03 1,649.42
Mitigated
0.03 1,649.42
Total 1,636.98 0.09
Industrial Park 6.82088e+006 1,636.98 0.09
N2O CO2e
Land Use kWh tons/yr MT/yr
Electricity Use ROG NOx CO SO2 Total CO2 CH4
17 of 42
7.0 Water Detail
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Total 3.41 0.00 0.00 0.00 0.00 0.00
Landscaping 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Consumer Products 2.63 0.00 0.00
Architectural 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Coating
0.78 CO2e
SubCategory tons/yr MT/yr
Fugitive NBio- CO2 Total CO2 CH4 N2O
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
Mitigated
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10 Total
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Total 3.41 0.00 0.00 0.00 0.00 0.00
Landscaping 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Consumer Products 2.63 0.00 0.00
Architectural 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Coating
0.78 N2O CO2e
SubCategory tons/yr MT/yr
PM10 Total Fugitive Bio- CO2 NBio- CO2 Total CO2 CH4
PM2.5
Exhaust
PM2.5
PM2.5
Total
NA
6.2 Area by SubCategory
Unmitigated
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
Total NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
0.00 Unmitigated 3.41 0.00 0.00 0.00 0.00 0.00
Mitigated 3.41 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 18 of 42
Indoor/Outdoor CO SO2 Total CO2 CH4 N2O CO2e
Use
ROG NOx
2.60 7,275.53
Mitigated
2.60 7,275.53
Total 4,340.81 101.39
Industrial Park 3314.02 / 0 4,340.81 101.39
CH4 N2O CO2e
Land Use Mgal tons/yr MT/yr
NA
7.2 Water by Land Use
Unmitigated
Indoor/Outdoor
Use
ROG NOx CO SO2 Total CO2
Total NA NA NA NA NA NA NA
7,275.53
Unmitigated 4,340.81 101.39 2.60 7,275.53
Mitigated 4,340.81 101.39 2.60
CO2e
Category tons/yr MT/yr
ROG NOx CO SO2 Total CO2 CH4 N2O
7.1 Mitigation Measures Water
19 of 42
Industrial Park 8295.38 1,683.89 99.51 0.00 3,773.70
CH4 N2O CO2e
Land Use tons tons/yr MT/yr
NA
8.2 Waste by Land Use
Unmitigated
Waste Disposed ROG NOx CO SO2 Total CO2
Total NA NA NA NA NA NA NA
3,773.70
Unmitigated 1,683.89 99.51 0.00 3,773.70
Mitigated 1,683.89 99.51 0.00
CO2e
tons/yr MT/yr
ROG NOx CO SO2 Total CO2 CH4 N2O
8.1 Mitigation Measures Waste
Category/Year
2.60 7,275.53
8.0 Waste Detail
2.60 7,275.53
Total 4,340.81 101.39
Industrial Park 3314.02 / 0 4,340.81 101.39
Land Use Mgal tons/yr MT/yr
20 of 42
0.00 3,773.70
9.0 Vegetation
0.00 3,773.70
Total 1,683.89 99.51
Industrial Park 8295.38 1,683.89 99.51
N2O CO2e
Land Use tons tons/yr MT/yr
Waste Disposed ROG NOx CO SO2 Total CO2 CH4
0.00 3,773.70
Mitigated
Total 1,683.89 99.51
21 of 42
Riverbank Project - Modesto, Ca
Claus Road Traffic Data and PM2.5 - 45 mph
North of Project Site
Analysis Year = 2020
Emission Factors
2020 Caltrans 2020 Number Diesel All Vehicles
Number Number 2020 Diesel Vehicle Vehicles Exhaust
Vehicle Vehicles Vehicles Percent Vehicles Speed DPM PM2.5 Type (veh/day) (veh/day) Diesel (veh/day) (mph) (g/VMT) (g/VMT) LDA 3,259 3,259 0.33% 11 45 0.0086 0.0012
LDT 1,698 1,698 0.08% 1 45 0.0128 0.0015
MDT 0 0 12.61% 0 45 0.0205 0.0028
HDT 502 502 92.55% 465 45 0.0625 0.0592
Total 5,459 5,459 - 477 45 - -
Mix Avg Emission Factor 0.06113 0.00664
1.00 Vehicles/Direction 2,730 238
Avg Vehicles/Hour/Direction 114 9.9
Traffic Data Year = 2020
Total Truck by Axle
Total Truck 2 3 4 5
Claus Rd - North of Project Site 5,459 502 0 167 167 167 Increase From 2020
Riverbank Project - Modesto, Ca
Claus Road Traffic Data and PM2.5 - 45 mph
South of Project Site
Analysis Year = 2020
Emission Factors
2020 Caltrans 2020 Number Diesel All Vehicles
Number Number 2020 Diesel Vehicle Vehicles Exhaust
Vehicle Vehicles Vehicles Percent Vehicles Speed DPM PM2.5 Type (veh/day) (veh/day) Diesel (veh/day) (mph) (g/VMT) (g/VMT) LDA 2,777 2,777 0.33% 9 45 0.0086 0.0012
LDT 1,446 1,446 0.08% 1 45 0.0128 0.0015
MDT 0 0 12.61% 0 45 0.0205 0.0028
HDT 428 428 92.55% 396 45 0.0625 0.0592
Total 4,651 4,651 - 406 45 - -
Mix Avg Emission Factor 0.06113 0.00664
1.00 Vehicles/Direction 2,326 203
Avg Vehicles/Hour/Direction 97 8.5
Traffic Data Year = 2020
Total Truck by Axle
Total Truck 2 3 4 5
Claus Rd - South of Project Site 4,651 428 0 143 143 143 Increase From 2020
Riverbank Project - Modesto, Ca
Claus RoadDPM Modeling - Roadway Links, Traffic Volumes, and DPM EmissionsYear = 2020 Average VPH Diesel Vehicles Composite
Group Link Description Direction
No.
Lanes
Link
Length
(m)
Link
Width
(ft)
Link
Width
(m)
Release
Height
( m)
Diesel
ADT
Average
Speed
(mph)
Average
Vehicles
per Hour LDA LDT
LDA
&
LDT MDT HDT
Average
Emissions
(g/mi)
NB_N_Claus Northbound Claus Rd North of Site N 1 1161 12 3.7 1.8 238 45 9.9 0.2 0.0 0.3 0.0 9.7 0.06113 SB_N_Claus Southbound Claus Rd North of Site S1 1159 12 3.7 1.8 238 45 9.9 0.2 0.0 0 0.0 9.7 0.06113 NB_S_Claus Northbound Claus Rd South of Site N 1 1555 12 3.7 1.8 203 45 8.5 0.2 0.0 0.2 0.0 8.3 0.06113 SB_S_Claus Southbound Claus Rd South of Site S1 1555 12 3.7 1.8 203 45 8.5 0.2 0.0 0 0.0 8.3 0.06113 Riverbank Project, Modesto, CA
AERMOD DPM Risk Modeling Parameters and Maximum Cancer Risk From Claus Rd, Modesto DPM Cancer Risks from DPM Emissions in 2020 for 70 Years Receptor Information
Number of Receptors 65
Receptor Height = ground level
Receptor distances = variable
Meteorological Conditions
Modesto Airport - Hourly Met Data 2005 - 2009
Land Use Classification Rural
Cancer Risk Calculation Method
Inhalation Dose = Cair x DBR x A x EF x ED x 10-6 / AT
Where: Cair = concentration in air (μg/m3
)
DBR = daily breathing rate (L/kg body weight-day)
A = Inhalation absorption factor
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
AT = Averaging time period over which exposure is averaged. 10-6 = Conversion factor
Inhalation Dose Factors
Value1
DBR A Exposure EF ED AT
Exposure Type (L/kg BW-day) (-) (hr/day) (days/yr) (Years) (days) Residential (70-Year) 393 1 24 350 70 25,550
1 Default values recommended by OEHHA& Bay Area Air Quality Management District Cancer Risk (per million) = CPF x Inhalation Dose x 1.0E6 = URF x Cair
Where: CPF = Cancer potency factor (mg/kg-day)-1
URF =Unit risk factor (cancer risk per μg/m3)
Diesel Particulate Matter Unit Risk Factors
CPF URF
Exposure Type (mg/kg-day)-1 (Risk/million/μg/m 3 )
Residential (70-Yr Exposure) 1.10E+00 414.5
MEI Cancer Risk Calculation from Claus Rd DPM emissions Maximum Modeled Annual
Meteorological DPM Concentration (ug/m3
)
Data Years 2020
2005 - 2009 0.0158
70-yr Maximum Riska 6.5
Notes:
Maximum concentrations occur at UTM 683,228.5 m east, 4,175,260.6 m north. a Maximum cancer risk (per million) calculated assuming constant exposure over a 70-year period to 2020 DPM Concentration Figure 1. Project Site, Roadway Links for Dispersion Modeling, and Receptor Locations Riverbank - On-Site Truck Distribution Methods and Assumptions The distribution of truck travel within the project area was based on trip data from the traffic report and initial information on the location, size, and types of land uses for the project development areas. The project would include areas for research and development (R&D) and industrial uses at the northern and southern portions of the site, retail development adjacent to Claus road near the central and southern portions of the site, and realignment of existing parking areas in the central portion of the site near Claus road. These areas are identified in Figures 1. Also shown on the figures are potential truck routes within each area that were used for modeling.
Based on the traffic report the total daily trips for all vehicles will be 10,110, with 930 daily truck trips (see trip generation table below), or 9.2% trucks. The truck trips were calculated for industrial land use only. There were no truck trips calculated for the other land uses (e.g., R&D and retail). The 10,110/ 930 vehicle/truck trips include trips from existing uses at the site. That is they include both existing and proposed trips. Presumably, some of the existing trips were for trucks, although the breakdown of vehicle type for the existing trips was not provided. New project trips were reported as 9,390 daily trips for all vehicles. Assuming 9.2% trucks, the number of existing truck trips was estimated as 67.
In order to distribute the truck trips to the different development areas, it was assumed that 863 trips (930-67) were distributed between the new R&D/industrial areas bases on the estimated sizes of the areas. The remaining 67 trips were distributed between the two retail areas and to the main road into the existing industrial area (which would include some new industrial uses). 50 trips were assigned to the main road, 11 trips to the central retail area, and 6 trips to the southern retail area. The truck trip distribution calculations are shown in the table below.
Figure 1 shows the number of daily trucks assigned to each development area. There would be 2 trips per daily truck.
2 Trip Distribution Ca
Area/Roads
North R & D and Industr
North Road A
North Road B
Central R & D and Indus
Central Road
South R & D and Industr
South Road A
South Road B
Central Retail Area
South Retail Area
Main Road
Total
3 Figure 1. Project Site, Development Areas, On-Site Truck Routes, and Daily Truck Traffic
Attachment
Riverbank On-Site Operation Truck DPM Emissions 2020
Idle PM2.5 Annual DPM Average
Line Daily Total Travel Emission Emission Operation4 Emissions Hourly Source Vehicle Number Annual Speed Factor3 Factor3 Schedule Travel Distance (lb/year) Emissions Truck Route Name Type1 Trucks Trucks2 (mph) (g/hr) (g/mi) (hrs/day) (feet) (miles) Travel Idle5 (lb/hr) On-Site Truck Travel
North R & D and Industrial Area
North Road A A_N_RDI HHDT 96 35,040 15 0.1227 0.0675 24 2,383 0.45 2.35 1.58 4.49E-04 North Road B B_N_RDI HHDT 96 35,040 15 0.1227 0.0675 24 3,161 0.60 3.12 1.58 5.37E-04 Central R & D and Industrial Area
Central Road R_C_RDI HHDT 155 56,575 15 0.1227 0.0675 24 3,409 0.65 5.44 2.55 9.12E-04 South R & D and Industrial Area
South Road A A_S_RDI HHDT 42 15,330 15 0.1227 0.0675 24 1,211 0.23 0.52 0.69 1.39E-04 South Road B B_S_RDI HHDT 42 15,330 15 0.1227 0.0675 24 1,171 0.22 0.51 0.69 1.37E-04 Central Retail Area R_C_RTL HHDT 6 2,190 15 0.1227 0.0675 24 1,208 0.23 0.07 0.10 1.98E-05 South Retail Area R_S_RTL HHDT 3 1,095 15 0.1227 0.0675 24 777 0.15 0.02 0.05 8.38E-06 Main Road R-MAIN HHDT 25 9,125 15 0.1227 0.0675 24 2,679 0.51 0.69 0.41 1.26E-04 1 HHDT = heavy heavy duty truck
2 Annual trips - Based on 365 days of operation
3 Emission factors from EMFAC2011 for San Joaquin Valley for operation in 2020 and assumes all trucks are diesel. 4 Operation hours assumed to be 24 hours per day, 365 days per year 5 Assumes 5 minutes idle per trip (10 minutes total per truck) Riverbank Project, Modesto, CA
AERMOD DPM Risk Modeling Parameters and Maximum Cancer Risk From On-Site Truck Travel DPM Cancer Risks from DPM Emissions in 2020 for 70 Years Receptor Information
Number of Receptors 72
Receptor Height = 1.5 meters
Receptor distances = variable
Meteorological Conditions
Modesto Airport - Hourly Met Data 2005 - 2009
Land Use Classification Rural
Cancer Risk Calculation Method
Inhalation Dose = Cair x DBR x A x EF x ED x 10-6 / AT
Where: Cair = concentration in air (μg/m3
)
DBR = daily breathing rate (L/kg body weight-day)
A = Inhalation absorption factor
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
AT = Averaging time period over which exposure is averaged. 10-6 = Conversion factor
Inhalation Dose Factors
Value1
DBR A Exposure EF ED AT
Exposure Type (L/kg BW-day) (-) (hr/day) (days/yr) (Years) (days) Residential (70-Year) 393 1 24 350 70 25,550
1 Default values recommended by OEHHA& Bay Area Air Quality Management District Cancer Risk (per million) = CPF x Inhalation Dose x 1.0E6 = URF x Cair
Where: CPF = Cancer potency factor (mg/kg-day)-1
URF =Unit risk factor (cancer risk per μg/m3)
Diesel Particulate Matter Unit Risk Factors
CPF URF
Exposure Type (mg/kg-day)-1 (Risk/million/μg/m 3 )
Residential (70-Yr Exposure) 1.10E+00 414.5
MEI Cancer Risk Calculation from Claus Rd DPM emissions Maximum Modeled Annual
Meteorological DPM Concentration (ug/m3
)
Data Years 2020
2005 - 2009 0.0103
70-yr Maximum Riska 4.3
Notes:
Maximum concentrations occur at UTM 683,107.9 m east, 4,176,965.0 m north. a Maximum cancer risk (per million) calculated assuming constant exposure over a 70-year period to 2020 DPM Concentration 4 Riverbank Project, Modesto, CA
AERMOD DPM Risk Modeling Parameters and Maximum Cancer Risk Cumulative Cancer Risk from On-Site & Off-Site Truck Travel DPM Cancer Risks from DPM Emissions in 2020 for 70 Years Receptor Information
Number of Receptors 72
Receptor Height = 1.5 meters
Receptor distances = variable
Meteorological Conditions
Modesto Airport - Hourly Met Data 2005 - 2009
Land Use Classification Rural
Cancer Risk Calculation Method
Inhalation Dose = Cair x DBR x A x EF x ED x 10-6 / AT
Where: Cair = concentration in air (μg/m3
)
DBR = daily breathing rate (L/kg body weight-day)
A = Inhalation absorption factor
EF = Exposure frequency (days/year)
ED = Exposure duration (years)
AT = Averaging time period over which exposure is averaged. 10-6 = Conversion factor
Inhalation Dose Factors
Value1
DBR A Exposure EF ED AT
Exposure Type (L/kg BW-day) (-) (hr/day) (days/yr) (Years) (days) Residential (70-Year) 393 1 24 350 70 25,550
1 Default values recommended by OEHHA& Bay Area Air Quality Management District Cancer Risk (per million) = CPF x Inhalation Dose x 1.0E6 = URF x Cair
Where: CPF = Cancer potency factor (mg/kg-day)-1
URF =Unit risk factor (cancer risk per μg/m3
)
Diesel Particulate Matter Unit Risk Factors
CPF URF
Exposure Type (mg/kg-day)-1 (Risk/million/μg/m 3 )
Residential (70-Yr Exposure) 1.10E+00 414.5
MEI Cancer Risk Calculation from Claus Rd DPM emissions Maximum Modeled Annual
Meteorological DPM Concentration (ug/m3
)
Data Years 2020
2005 - 2009 0.0217
70-yr Maximum Riska 9.0
Notes:
Maximum concentrations occur at UTM 683,107.9 m east, 4,176,965.0 m north. a Maximum cancer risk (per million) calculated assuming constant exposure over a 70-year period to 2020 DPM Concentration ........................................................................................................................
A PPENDIX H
C OMMENTS R ECEIVED ON THE
D RAFT EIR
........................................................................................................................
COMMENT LETTER # SA1
SA1-1
SA1-2
SA1-3
COMMENT LETTER # SA2
SA2-1
SA2-2
SA2-3
SA2-4
SA2-5
SA2-6
SA2-7
COMMENT LETTER # SA3
SA3-1
SA3-2
SA3-3
SA3-4
SA3-5
COMMENT LETTER # SA4
SA4-1
COMMENT LETTER # RA1
RA1-1
RA1-2
RA1-3
RA1-4
RA1-5
RA1-6
RA1-7
COMMENT LETTER # RA2
RA2-1
RA2-2
RA2-3
RA2-4
RA2-5
Services of the San Francisco Public Utilities Commission Bureau of Environmental Management
525 Golden Gate Avenue, 6th Floor
San Francisco, CA 94102
T (415) 934-5700
F (415) 934-5750
May 13, 2013
Debbie Olson, Executive Director
Riverbank Local Redevelopment Authority
5300 Claus Road
Riverbank, CA 95367
Re: SFPUC Comments on Riverbank Army Ammunition Plant Draft EIR (SCH #2011022015)
Dear Ms. Olsen:
The San Francisco Public Utilities Commission offers the following comments on the Riverbank Army Ammunition Deport Draft EIR (SCH #2011022015):
1. The City and County of San Francisco (CCSF), San Francisco Public Utilities Commission (SFPUC) owns a 100-foot-wide right of way (ROW) for the Hetch Hetchy Aqueduct and the San Joaquin Transmission Line, which bisects the Specific Plan area. The Draft EIR acknowledges this ROW and the Specific Plan does not propose development in this area. However, Figure 3-8 in the DEIR identifies the SFPUC ROW as “Buffer/ Greenway/ Open Space”. Please note that any use or development of the ROW, such as for landscaped open space, a pedestrian or bicycle trail, parking, emergency access routes or road crossings, must be reviewed and approved by the SFPUC.
Further, CCSF owns the ROW in fee, and SFPUC charges fair market value for its use. In addition, SFPUC places restrictions on use of the ROW in order to protect utility infrastructure and insure that it is accessible for maintenance. SFPUC ROW use requirements are attached (Attachment 1).
2. In addition, please note that the land use rights associated with the Army’s entry road, which crosses the SFPUC ROW, should be investigated to determine whether this use is covered by an easement.
If not, use of this crossing would require review by the SFPUC and, if approved, would be subject to a revocable license from the SFPUC.
COMMENT LETTER # RA3
RA3-1
RA3-2
RA3-3
Debbie Olson, Executive Director
Riverbank Local Redevelopment Authority
SFPUC Comments on Riverbank Army Ammunition Deport Draft EIR
3. In URS, a consultant to SFPUC, reviewed existing
environmental documents that addressed the RAA P Superfund site to evaluate any potential impacts to SFPUC's right of way property from activities at the RAAP. As detailed in the attached letter report, "Request for Additional Characterization of the San Francisco Hetch Hetchy Water and Power Division Property Associated with the Riverbank Army Ammunition Plant Superfund Site", which we submit as an element of this comment (Attachment 2), soils in the SFPUC right of way may be contaminated due to the presence of a Transite (asbestos cement) pipe, a past leak in the Transite waste sewer line, leaks in a stormwater line, and overflows from retention ponds to the right of way. Additional sampling of soils in the right of way was recommended, and it also was recommended that the Transite pipeline be removed rather than abandoned in place. SFPUC is not aware if these actions were ever carried out. If contaminated soils or other hazardous materials are present, this could pose risks to utility workers in the right of way.
Thank you for providing SFPUC with the opportunity to comment.
Attachments:
SFPUC Pipeline Right of Way Requirements
2) Request for Additional Characterization the San Francisco Hetch Hetchy Water and Power Division Property Associated with the Riverbank Army Ammunition Plant Superfund Site. Prepared by URS Corporation for SFPUC. October 5, 2011.
Rosanna Russell, Real Estate, SFPUC
Tim Ramirez, Natural Resources Land Management Division, SFPUC Sarah Jones, CCSF Planning Dept., Environmental Planning Division RA3-4
San Francisco Public Utilities Commission
Pipeline Right of Way Requirements
• Utilities
o No utility may be installed along, rather than across, the Right of Way. Only perpendicular crossings are permitted.
o No aerial utility crossing over the Right of Way is permitted except in city streets.
• Land Use, Structures, and Accessibility
o Structures on the Right of Way are strictly prohibited. No one shall construct or place any temporary or permanent structure or improvement in, on, under or about the Right of Way. For the SFPUC’s purposes, asphalt, concrete and cementitious
concrete driveways, sidewalks and parking areas, and fences are deemed “improvements,” and are subject to SFPUC review and approval.
o No use is permitted that would restrict access to Right of Way at any time by SFPUC staff, construction equipment or vehicles.
This means that structures on adjacent property must be setback at least 10 feet from the Right of Way.
o An adjacent property owner or tenant may not use the Right of Way fulfill its open space, setback, emergency access or other development requirements.
o Any use where the Right of Way would provide an adjacent owner, tenant or licensee with its sole emergency access to the tenant or licensee’s property is prohibited.
o No use that would cause ponding on the Right of Way is permitted.
o Any use that cannot effectively be displaced in a timely manner upon the SFPUC's request is disfavored.
o Any use that may contaminate with hazardous materials the soils, water or natural habitat of SFPUC property is prohibited.
RA3-5
RA3-6
RA3-7
o Any use that would increase the SFPUC’s potential liability or diminish its security is disfavored.
o Any use inconsistent with any existing or future policies adopted by the SFPUC, as they may be amended or modified from time to time, is disfavored.
• Restoration
The SFPUC is not responsible for restoring or replacing any vegetation or improvement on the Right of Way damaged or demolished so that the SFPUC may access, maintain or repair its pipelines. The SFPUC will restore the ground with soil compacted to SFPUC standards. The vegetation or improvement owner is responsible any additional work or the restoration.
• Vegetation
No trees or large shrubs may be planted within the Right of Way. Other vegetation may only be installed with the SFPUC’s prior written consent. For a list of plants that may be permitted in the Right of Way, please refer to SFPUC Integrated Vegetation Management Policy Section 13.005 at http://www.sfwater.org/index.aspx?page=431. The tenant or licensee is responsible for vegetation maintenance and removal.
• Right of Way Loading Restrictions
The maximum loading on the Right of Way should not exceed traffic loading HS-20 on the paved surfaces when the pipeline has a minimum four-foot cover. Overburdened or additional live or dead loads such as load-bearing footings, pole foundations, or large boulders within the influence line of the pipe trench is prohibited.
• Right of Way Cover Requirements
To prevent damage to the PUC's underground pipelines, an adjacent owner or tenant’s use of vehicles and equipment within twenty feet (20') of each side of the centerline of the PUC's pipelines (measured on the surface) are subject to the restrictions stated in Exhibit B.
RA3-7
cont.
RA3-8
RA3-9
RA3-10
RA3-11
RA3-12
RA3-13
RA3-13
cont.
RA3-14
RA3-14
cont.
RA3-15
RA3-16
RA3-16
cont.
RA3-17
RA3-18
RA3-19
RA3-19
cont.
RA3-20
RA3-21
RA3-22
RA3-22
cont.
RA3-23
RA3-24
COMMENT LETTER # RA4
RA4-1
RA4-2
RA4-3
COMMENT LETTER # RA5
RA5-1
RA5-2
RA5-3
RA5-3
cont.
RA5-4
RA5-5
RA5-6
RA5-7
COMMENT LETTER # RA6
RA6-1
RA6-2
RA6-2
cont.
RA6-3
RA6-4
RA6-5
RA6-6
RA6-6
cont.
RA6-7
RA6-8
RA6-9
RA6-10
RA6-10
cont.
RA6-11
RA6-12
RA6-13
RA6-14
RA6-15
RA6-15
cont.
RA6-16
RA6-17
RA6-18
RA6-19
RA6-20
COMMENT LETTER # LA1
LA1-1
LA1-2
LA1-3
ATTACHMENT 2
(Specific Plan)
ATTACHMENT 2
(CONTINUED)
5300 Claus Road #5
Aemetis Advanced Products Riverbank, Inc. Modesto, CA 95357 www.aemetis.com 209‐863‐0959
Riverbank Army Ammunition Plant Specific Plan
Addendum to the
Final Environmental Impact Report
State Clearinghouse #2011022015
Aemetis Advanced Products Riverbank, Inc.
Carbon Zero 1 Project
Riverbank Industrial Complex
Riverbank, CA
CEQA Lead Agency
City of Riverbank
6707 Third Street
Riverbank CA 95367
Prepared By
Trinity Consultants, Inc.
20 Corporate Drive, Suite 285
Irvine CA 92606
May 9, 2023
ATTACHMENT 3
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project i May 2023
TABLE OF CONTENTS
1. EXECUTIVE SUMMARY 1
2. PROJECT DESCRIPTION 2
2.1 Introduction................................................................................................................. 2
2.2 Project Location........................................................................................................... 2
2.3 Facility and Process Description.................................................................................. 5
2.3.1 Block Flow Diagram.................................................................................................... 6
2.3.2 Feedstock Receiving................................................................................................... 6
2.3.3 Feedstock Blending and Pretreatment .......................................................................... 6
2.3.4 HydroFlex™ Unit (RD and SAF Production) ................................................................... 7
2.3.5 Hydrogen Production Unit........................................................................................... 7
2.4 Inputs and Outputs...................................................................................................... 8
2.4.1 Inputs....................................................................................................................... 8
2.4.2 Storage Tanks ........................................................................................................... 9
2.4.3 Outputs................................................................................................................... 10
2.4.4 Utilities ................................................................................................................... 10
2.5 Site Plan and Operations............................................................................................ 13
2.5.1 Site Plan ................................................................................................................. 13
2.5.2 Construction............................................................................................................ 15
2.5.3 Hours of Operation................................................................................................... 15
2.5.4 Employees............................................................................................................... 15
2.5.5 Fencing and Design.................................................................................................. 16
2.5.6 Traffic Summary ...................................................................................................... 16
2.6 Riverbank Industrial Complex Zoning........................................................................ 17
2.7 Permits and Regulatory Programs ............................................................................. 18
3. CEQA PROCESS 20
3.1 History of the RAAP Site............................................................................................. 20
3.2 The Specific Plan EIR ................................................................................................. 20
3.3 CEQA Standard........................................................................................................... 20
3.4 Checklist Analysis ...................................................................................................... 21
4. ENVIRONMENTAL REVIEW 22
4.1 CEQA Guidelines Appendix G Updates........................................................................ 22
4.2 CEQA Addendum Evaluation Questions ...................................................................... 24
4.3 Environmental Analysis.............................................................................................. 26 I. Aesthetics ............................................................................................................... 26 II. Agriculture and Forestry Resources............................................................................ 28 III. Air Quality ............................................................................................................... 31 IV. Biological Resources................................................................................................. 35 V. Cultural Resources ................................................................................................... 39 VI. Energy .................................................................................................................... 41 VII. Geology and Soils .................................................................................................... 47 VIII. Greenhouse Gas Emissions........................................................................................ 51 IX. Hazards & Hazardous Materials ................................................................................. 53 X. Hydrology / Water Quality......................................................................................... 57 XI. Land Use / Planning ................................................................................................. 60 Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project ii May 2023
XII. Mineral Resources.................................................................................................... 62 XIII. Noise ...................................................................................................................... 63 XIV. Population / Housing ................................................................................................ 66 XV. Public Services......................................................................................................... 67 XVI. Recreation............................................................................................................... 69 XVII. Transportation/Traffic............................................................................................... 70 XVIII. Tribal Cultural Resources .......................................................................................... 74 XIX. Utilities / Service Systems ......................................................................................... 76 XX. Wildfire ................................................................................................................... 80
5. ACRONYMS 83
6. REFERENCES 85
EXHIBIT 1 – FACILITY SITE PLAN E1-1
EXHIBIT 2 – FACILITY PLOT PLAN E2-1
APPENDIX A – AIR QUALITY TECHNICAL REPORT A-1
APPENDIX B – GREENHOUSE GAS TECHNICAL REPORT B-1
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project iii May 2023
TABLES AND FIGURES
Table 1 Input Materials 8
Table 2 Outputs 10
Table 3 Utility Inputs and Outputs 10
Table 4 Facility Operations Traffic Activity Assuming All Truck 17 Table 5 Facility Operations Traffic Activity Assuming Rail & Truck 17 Table 6 Zoning and Land Use 17
Table 7 EIR Scope Comparison with 2019 CEQA Environmental Checklist Updates 22 Table 8 Operations Worst-Case Vehicle Annual Fuel Usage – All Trucks 44 Table 9 Operations Rail and Truck Annual Fuel Usage 45
Table 10 Operations Gas and Electricity Usage 45
Table 11 Table of Acronym Definitions 83
Figure 1 RIC Parcel Map 2
Figure 2 Regional Location 3
Figure 3 Facility Location Within RIC 4
Figure 4 Facility Location 5
Figure 5 Facility Block Flow Diagram 6
Figure 6 Site Plan 14
Figure 7 Rendering of Street Level View along Claus Road 15 Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 1 May 2023
1. EXECUTIVE SUMMARY
Aemetis Advanced Products Riverbank, Inc. (“Aemetis”) plans to build a sustainable aviation fuel (SAF) and renewable diesel (RD) production plant, referred to as the “Carbon Zero 1 Project” (the “Facility”) at the Riverbank Industrial Complex (“RIC”). Designed to be a “green business,” the Facility will produce 120 million gallons per year of low carbon intensity SAF and RD from 475,000 gallons per day of vegetable oils and animal fats. The production of low-carbon fuels produced from renewable sources will help reduce total carbon emissions to the atmosphere.
The RIC is a 140 acre site of a former U.S. Army ammunition production plant referred to as the Riverbank Army Ammunition Plant (“RAAP”). It is in the process of being converted to private use under management by the City of Riverbank, California (the “City”) and Aemetis Properties Riverbank, Inc. as master developer.
About one-half of the RIC is a heavily industrialized area that was used by the Army. The other half of the RIC is undeveloped open land that the City’s applicable re-use plan expects to be completely built out with new industrial/business park uses. Aemetis’ Facility would be located on approximately 29 acres of the RIC in the open space between the existing industrialized area and the Hetch Hetchy power lines.
The City prepared and certified an Environmental Impact Report (“Specific Plan EIR” or “EIR”) under the California Environmental Quality Act (“CEQA”) when it adopted a Specific Plan that modified the zoning for the RIC and described the City’s plan for reuse and development. The EIR analyzes the impacts of the zoning changes at the RAAP Site and also analyzes the impacts of the individual projects expected to be built as part of the reuse of the site, including projects in both the existing industrial area and in the undeveloped open space. The EIR applies to Aemetis’ Facility, which would be built within the area subject to the Specific Plan.
The purpose of this Addendum is to describe the facility and its impacts and to analyze them in the context of the Specific Plan EIR. As a general matter, once an EIR has been certified for proposed project, “no subsequent EIR shall be prepared” unless specific criteria in Section 15162 of the CEQA Guidelines are met. (CEQA Guidelines Section 15162(a).) Those criteria would require additional CEQA analysis only if (i) there are substantial changes to a project or circumstances, or substantial new information, and (ii) those changes require major revisions to the EIR, due to (iii) new significant adverse impacts caused by the change that were not previously analyzed.
This Addendum applies the Section 15162 standard to each significance threshold that is normally included within a CEQA checklist. Based on the analysis provided below and in the Specific Plan EIR, the Facility does not include changes from the Specific Plan that would require major changes to the existing EIR due to new significant adverse environmental effects over those determined by the City in the Specific Plan EIR. Based on this, CEQA states the ”lead agency or responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions [to the EIR] are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.” CEQA Guidelines Section 15164(a).
In additions, “[t]he decision-making body shall consider the addendum with the final EIR or adopted negative declaration prior to making a decision on the project.” CEQA Guidelines Section 15164(d).
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 2 May 2023
2. PROJECT DESCRIPTION
2.1 Introduction
Aemetis plans to build a sustainable aviation fuel (SAF) and renewable diesel (RD) production plant, referred to as the “Carbon Zero 1 Project,” or the “Facility.” The Facility will be located at 5300 Claus Road, Riverbank, California 95357, at the Riverbank Industrial Complex (RIC) (the former RAAP site). It will produce 120 million gallons per year of low carbon intensity SAF and RD from 475,000 gallons per day of vegetable oils and animal fats. The Carbon Zero 1 Project has the following key objectives:
► Produce low carbon fuel. The SAF and RD produced by the Facility will have a low “carbon intensity” under California’s Low Carbon Fuel Standard, which will reduce greenhouse gas emissions from transportation fuels used in the state.
► Support the implementation of the federal Renewable Fuels Standard (RFS). The SAF and RD produced by the Facility will be considered an advanced biofuel under the federal RFS and help achieve the RFS mandates for production of renewable fuels.
► Economic Development. The Facility will support economic redevelopment and job growth at the former army base in the City of Riverbank.
2.2 Project Location
Aemetis’ Carbon Zero 1 Project will be located on approximately 29 acres within a mostly undeveloped portion of the RIC. Figure 1 shows the RIC parcel designations. Figure 2 shows the regional and site location. Figures 3 and 4 show the location of the Aemetis’ Facility within the RIC. The Facility will be primarily located south of the Hetch Hetchy aqueduct and power lines, north of the former army base developed industrial area with entrances along Claus Road.
Figure 1 RIC Parcel Map
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 3 May 2023
Figure 2 Regional Location
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 4 May 2023
Figure 3 Facility Location Within RIC
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 5 May 2023
Figure 4 Facility Location
As shown in these figures, the Facility will primarily be located on parcels 2 and 2A of the RIC, with a small portion on the north edges of the main parcel A, use of a few existing buildings within parcel A, and a small portion of the Facility on the south edge of parcel B east of the existing stormwater ponds for a new stormwater pond.
2.3 Facility and Process Description
Aemetis process will hydrotreat renewable oils to produce SAF and RD.
Project
Site
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 6 May 2023
2.3.1 Block Flow Diagram
Figure 5 is a Block Flow Diagram of the major production processes at the Facility. Exhibit 1 to this Addendum includes another copy of the same diagram in larger format.
Figure 5 Facility Block Flow Diagram
2.3.2 Feedstock Receiving
The facility will receive on average 11,300 barrels (bbl) per day of vegetable oil and/or animal fats (oil feedstock) that will be used as feedstock to produce renewable fuels.
Oil feedstock will be received by rail tanker, tank trucks, or trucked iso-containers. Each rail tanker holds 30,000 gallons, tank trucks hold 7,000 gallons, and iso containers hold 5,500 gallons. The feedstock will be unloaded from the shipping vehicle or tank and pumped to feed storage tanks. Rail tankers will be unloaded in 60 minutes and iso-containers in 45 minutes.
2.3.3 Feedstock Blending and Pretreatment
The feedstock oils will be blended and then pumped to a Pretreatment Unit to remove impurities prior to hydro-processing. The feed pretreatment system consists of:
► Mixing – Feedstock will be mixed in a day tank (8,950 bbl) to maintain consistent oil composition. ► Drying and crude filtration – Removes polyethylene, food waste, metal, and protein. ► Ultra-degumming via pH adjustment – Removes metal ions and convert hydrophilic proteins. ► Water washing – Removes trace impurities such as chlorides and reduce the load to bleaching.
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 7 May 2023
► Double-pass bleaching – Removes trace impurities, metals, and other compounds.
Waste oil from pretreatment will be recovered and processed through the pretreatment unit again. Gums generated will be kept in a storage tank and trucked to wastewater treatment or sold. The gums (also called soapstock) can be also sold for animal feed. Spent clay generated during pretreatment will be stored in dumpsters and removed from the facility by truck.
2.3.4 HydroFlex™ Unit (RD and SAF Production)
The HydroFlex Unit (HFU) will use a hydro-treating process licensed from Topsoe to convert the feedstock oils to SAF and RD. The HFU includes the following primary processes:
► Hydrogenation – Pretreated oil feed stock will be heated in the presence of hydrogen and catalyst to hydrogenate the oils and remove oxygen and impurities. The hydrocarbons from the reactor will contain varying length hydrocarbon chains, hydrogen, and other by-products. A series of processing steps will separate the hydrogen, hydrogen sulfide, and light end hydrocarbons from the heavier hydrocarbon stream. Separated hydrogen and light ends will be re-used in the process. ► Dewaxing Reactor and Separation – The heavier hydrocarbons (which contain the final products) will be processed in a dewaxing reactor to improve the cold flow properties of the products. Another series of separation steps will remove hydrogen, hydrogen sulfide, ammonia, light ends and light naphtha from the hydrocarbon liquid, and then split the heavy hydrocarbon stream into heavy naphtha, SAF and RD. ► Reuse of Byproducts – Recovered hydrogen gas, light ends, and light naphtha will be reused in the production process. The light and heavy naphtha will be stabilized via a fractionation process to remove light components prior to storage and use in the Reformer to produce hydrogen.
2.3.5 Hydrogen Production Unit
The Hydrogen Production Unit (HPU) will convert naphtha and offgas (outputs of the HydroFlex unit) into hydrogen using Topsoe Convection Reformer technology. The Facility is expected to produce enough naphtha and offgas to meet its normal hydrogen requirements. The HPU will consist of a series of reactors:
► Sour Gas Treatment -- Removes hydrogen sulfide from the offgas stream generated in the HFU so the gas can be used as feed in the Reformer.
► Hydrotreater – Converts organic sulfur compounds in the reformer feed into hydrogen sulfide and converts olefins to saturated hydrocarbons using a Co-Mo catalyst. ► Desulfurization Absorber – Removes the hydrogen sulfide from the process gases using a zinc oxide catalyst.
► Pre-Reformer – Converts long-chain hydrocarbons in naphtha to methane using a zinc catalyst. ► Reformer – Converts methane and naphtha to CO and H2 using a zinc catalyst. ► High Temperature Shift Converter – Converts CO to H2 and CO2 using steam and an iron-chromium catalyst.
► Pressure Swing Adsorber (PSA) – Removes impurities to produce pure hydrogen (99+%) at a flow rate of 26 MMSCFD. The H2 is used as an input to the HydroFlex Unit. The removed streams will be used as fuel in the Reformer.
These reactors will be fixed beds and have non-regenerable catalysts. The catalysts will be replaced every two years for the hydrotreater and desulfurization reactors and every 10 years for the other reactors.
The reformer will be heated using off gases from the PSA as fuel, with natural gas used during startup and for supplemental energy. Heat will be recovered from the flue gas to generate steam used throughout the facility. The exhaust from the heaters will flow through an SCR prior to venting to atmosphere.
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 8 May 2023
2.4 Inputs and Outputs
2.4.1 Inputs
Table 1 lists the types and quantities of feedstock and other materials that will be used by the facility.
Table 1 Input Materials
Input Quantity Used Transportation
Mode Number of Deliveries
Feedstock
Vegetable Oil and
Animal Fat (tallow)
475,000 gal/day (11,300 BPD) Feedstock may be
received by rail car,
tanker truck or isocontainer truck
16 rail cars/day
or
86 iso-container
trucks/day
or
68 tanker trucks/day
(or combination)
Pretreatment
Citric Acid (50%) 54,750 gal/yr 1,000 gal trucks 55 trucks/yr Sodium Hydroxide
(50%)
82,125 gal/yr 1,000 gal trucks 83 trucks/yr
Bleaching Earth 7,200 tons/yr 24 ton trucks 300 trucks/yr Filter Aid 4,344 tons/yr 24 ton trucks 181 trucks/yr
HydroFlex Unit
SulfrZol 54 38,500 gal/yr 1,000 gal trucks 39 trucks/yr MDEA 15,200 gal/yr 1,000 gal trucks 16 trucks/yr
Boiler
Oxygen Scavenger 4,380 gal/yr Tote 11 totes/yr
Amine 2,190 gal/yr Tote 6 totes/yr
Phosphate 2,190 gal/yr Tote 6 totes/yr
Cooling Water
Sodium Hydroxide
(50%)
13,000 gal/yr 1,000 gal trucks 13 trucks/yr
Sodium
Hypochlorite
13,000 gal/yr 1,000 gal trucks 13 trucks/yr
Corrosion Inhibitor 4,800 gal/yr Tote 12 totes/yr
Dispersant 13,000 gal/yr 1,000 gal trucks 13 trucks/yr
Demin Water
Anti-Scalant 8,760 gal/yr Tote 22 totes/yr
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Input Quantity Used Transportation
Mode Number of Deliveries
Bisulfite 8,760 gal/yr Tote 22 totes/yr
Sodium Hydroxide
(50%)
19,710 gal/yr 1,000 gal trucks 20 trucks/yr
Wastewater Treatment
Sodium Hydroxide
(50%)
4,380 gal/yr Tote 11 totes/yr
HCl Acid 4,380 gal/yr Tote 11 totes/yr
Polymer 8,760 gal/yr Tote 22 totes/yr
Coagulant/Nutrient 8,760 gal/yr Tote 22 totes/yr
SCRs:
19% Aqueous
Ammonia
HFU – 6,800 gal/yr
Boiler – 13,500 gal/yr
Hydrogen – 40,200 gal/yr
6,400 gal trucks, 19%
aqueous ammonia will
be stored centrally and
pumped to the two
SCR locations.
10 trucks/yr
2.4.2 Storage Tanks
The facility will include onsite tanks to store finished products and liquid additives used in the processes. The storage tanks will include:
► Oil and Tallow Feedstock Storage – 4 tanks, 38,750 barrels each, cone roof ► Feedstock Blending Tanks – 2 tanks, 8,950 barrels each, cone roof ► Buffer Tanks – 2 tanks, 7,150 barrels each, cone roof ► RD/SAF – 4 tanks, 24,100 barrels each, internal floating roof ► Naphtha – 2 tanks, 4,850 barrels each, internal floating roof ► Slop/Off-spec – 1 tank, 3,650 barrels, internal floating roof ► Slop/Off-spec – 1 tank, 7,150 barrels, internal floating roof ► Untreated Oil (Soapstock) – 1 tank, 930 barrels, ASME Sec VIII construction ► Oil Pretreatment Slop – 1 tank, 500 barrels, cone roof ► Fire Water/Utility Water – 1 tank, 24,100 barrels, cone roof ► Demineralized Water – 1 tank, 3,000 barrels, cone roof Tanks with floating roofs will include double seals to prevent release of fugitives and odors. Tanks with fixed roofs will include a vapor capture system and carbon filters to trap and prevent odors. Tanks containing feedstocks and refined products will be contained with berms, with foam systems for fire suppression.
RD and SAF will be moved from storage tanks and loaded onto trucks using loading arms at an effective rate of 400 gpm per truck, approximately 20 minutes per truck or approximately 30-45 minutes per rail car. The loading arms will have vapor recovery.
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2.4.3 Outputs
Table 2 summarizes the facility’s output streams.
Table 2 Outputs
Output Production Quantity Transportation Mode Shipment Quantity RD, SAF 120 mln gal/yr of
combined RD and SAF
Rail or tanker truck 65 trucks or 15 rail cars
per day (or combination)
Naphtha 940 BPSD Rail or tanker truck 6 trucks or 2 rail cars per day (or combination)
Wastewater
Sludge
4.8 TPD Removed in dumpsters –
landfilled
One dumpster removed
every two days
Salt Cake from
Wastewater
Treatment
2.8 TPD Removed in dumpsters –
landfilled
One dumpster removed
daily
Spent Clay from
Pretreatment
12.9 TPD Removed in dumpsters. Spent
bleaching earth can be
blended into animal feed due
to the high oil content.
One dumpster removed
daily
Waste Oil
(Gums)
9,750 gallons/day gums
produced when processing
vegetable oils in the
Pretreatment Unit
Small volumes may be sent to
wastewater treatment; large
volumes removed via truck.
Another name for these gums
is soapstock and it can be sold
for animal feed.
2 trucks daily
2.4.4 Utilities
Table 3 lists utility inputs and outputs, including the quantity and source.
Table 3 Utility Inputs and Outputs
Utility Flow Rate Source Annual Flow Rate
Water Supply 240 gpm RIC wells; potential backup
supply from City water
126,144,000 gallons
Cooling Water 10,100 gpm Produced onsite Recirculating
Steam 92,000 lb/hr Produced onsite Recirculating
Natural Gas 3.29 MMSCFD PG&E 1,200 MMSCF
Electricity 15 MW SFPUC and PG&E 15 MW
Instrument air 1,400 SCFM Produced onsite 735,840,000 SCF Nitrogen 10,000 SCFH Produced onsite or delivered 87,600,000 SCF Wastewater 145 gpm Recycled in onsite WWTP and
reused; backup connection to
City sewer
Recycled onsite
Sanitary Wastewater Tbd City sewer Tbd
Stormwater varies Retention ponds Varies
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2.4.4.1 Water Supply and Uses
Water used in the facility will be supplied by the onsite wastewater treatment plant and RIC wells. The facility will require 300 gpm of water supply, with approximately 60 gpm to be supplied by treated wastewater and the balance of 240 gpm from RIC wells. The Facility will also treat collected stormwater to provide additional water supply. The Facility will also potentially connect to the City water supply if needed:
► Cooling Water - Several plant processes will use non-contact cooling water produced by an evaporative cooling tower that includes a cooling water basin, tower, two pumps, chemical treatment, and distribution circuits to deliver and receive back the cooling water. The cooling water will recirculate back to the cooling tower for reuse where additional water will be supplied to offset evaporation from the tower. ► Fire Water - Fire water will be stored in a 24,100 bbl tank. Half of the total capacity is dedicated to firewater and the balance will be available for use as utility water for the plant. ► Process Water - Plant process water will be supplied from the fire water storage tank. ► Steam - A deaerator will provide boiler feed water for steam production. Most steam will be produced using energy from the reformer flue gases. An auxiliary boiler will produce additional steam using natural gas as fuel. A header system will distribute steam at different pressures throughout the facility. High pressure steam produced by the reformer will be de-superheated with boiler feed water to reduce the pressure. Steam condensate will be collected and returned as boiler feed water to reduce water make-up requirements.
► Employee Washrooms/Breakroom – An onsite employee washroom and breakroom will be supplied with potable water from existing RIC wells or from City water.
2.4.4.2 Natural Gas
Natural gas will be used as fuel in heaters and the boiler. The natural gas can also be used as a backup feedstock to the reformer, but this is not expected to be necessary during regular operation. Natural gas will be supplied by Pacific Gas & Electric from its existing pipelines at the RIC.
2.4.4.3 Electricity
Electricity will be supplied by San Francisco PUC and Pacific Gas & Electric, both of which have on site connection points.
2.4.4.4 Instrument Air
The instrument air system will provide 110 pounds per square inch gauge (psig) compressed air to operate instruments and controls, and for general utility service inside the plant. The instrument air system includes:
► Instrument air compressor package – Compresses air with electric motor-driven compressors, and includes air intake filter, two-stage rotary screw water-cooled air compressor, intercooling, water separation, aftercooling, aftercooler separation, lubrication, and control system ► Wet air receiver – Stores the wet air from the compressor package ► Instrument air dryer package – Dries the compressed air using pre-filtration, two-stage desiccant air drying, and post-filtration
► Instrument air receiver – Provides steady pressure to system and serves as a reservoir in case of heavy demand
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2.4.4.5 Nitrogen
Nitrogen will be produced on site via air compression and pressure swing adsorption. Nitrogen will be used for compressor seals, blanket gas to tank, purging at unloading/loading equipment, and as a backup for inert purge gas for flare system. Additional N2 may also be purchased and delivered by truck.
2.4.4.6 Wastewater Treatment
The facility will treat process wastewater on site to create clean water for process use. The wastewater treatment plant (WWTP) includes:
► Process wastewater sump – Collects process wastewater to be pumped to the Equalization tank ► Equalization tank – Removes oil via steam sparging and oil skimming ► pH neutralization system – Neutralizes pH using 50% sulfuric acid or 25% caustic soda ► Coalescing plate unit – Removes free oil globules larger than 150 microns and solids ► Dissolved gas flotation (DAF) – Recirculates clean effluent through pressurization of plant air to remove solids and skim oil
► Anaerobic treatment system – Converts biological oxygen demand (BOD) and chemical oxygen demand (COD) into biogas via anaerobic microorganisms
► Anchor channel biotreater tank – Clarifies and removes sludge from anaerobic treatment ► Gravity filter – Removes suspended solids to meet requirements for water reclamation ► Aerobic Digester Tank – Separates solids and liquids from sludge using plant air. Gases from the digester will go to a thermal oxidizer.
► Filter Press – Concentrates sludge from aerobic digester tank into a cake that will be trucked offsite for disposal.
► Recycle System – Treated and neutralized wastewater, filter backwash water and cooling tower blowdown are collected, equalized, softened and processed through a reverse osmosis system for reuse. ► Crystallizer – Reject from the reverse osmosis system is sent to the Zero Liquid Discharge system comprised of a forced circulation crystallizer unit.
The Facility will produce approximately 100 gpm of wastewater that will be processed onsite on a continuous basis. Intermittently, there will be about 45 gpm of additional wastewater from filter backwash and clean-inplace streams that will also be processed in the WWTP. WWTP will be designed to treat any hydrocarbons or contaminants that may be contained in the stormwater being managed onsite. The WWTP will include storage for seven days of wastewater generation in case the WWTP is inoperable. If the WWTP is down longer than 7 days, then the facility will scale down operations to align with available wastewater capacities. The Facility is also expected to include a separate permitted connection to the City sewer to be used for backup.
The RIC currently connects to the City sewer system for disposal of sanitary wastewater. Aemetis’ Facility will also connect to this system for wastewater from lunchroom, employee showers, sinks, toilets, and similar sources. This is expected to be a small quantity in the context of the RIC total flows.
2.4.4.7 Stormwater
Stormwater run-off will flow through open site ditches and underground pipes that drain to a retention pond with a capacity of 52,400 cu ft. The retention pond will be located east of the current stormwater retention ponds on Parcel B of the RIC, sized approximately at 125 ft by 125 ft. Process areas that have potential to contaminate storm water with hydrocarbons or other unwanted chemicals will be curbed to prevent runoff from draining to the storm water system. Potentially contaminated water will be directed to a sump and pumped to the Wastewater Treatment Unit for treatment. The Facility will also be able to pump collected Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 13 May 2023
stormwater from the retention pond for filtering and re-use as process water to reduce the facility’s raw water consumption.
2.4.4.8 Thermal Oxidizers
Two 7.6 million British thermal unit (mmBTU) thermal oxidizers will be used to combust exhaust gases prior to emission to the atmosphere. The loading and unloading racks for both trucks and rail will include a vapor recovery system that will capture vapors and route them to the thermal oxidizers to prevent odors.
2.4.4.9 Flare
A standby flare will combust gases vented during a process upset prior to emission to the atmosphere. The flare has small natural gas pilot light, but it will combust gases only during unplanned venting and not during normal operations.
2.4.4.10 Fire Protection
The Facility will be designed with its own onsite fire protection equipment and systems in accordance with the California Fire Code and applicable NFPA guidelines. This design is currently expected to include:
► Firefighting water storage tank (combined with the freshwater supply tank described above) ► New firewater loop with hydrants around the site
► Targeted firewater monitors for tanks and critical equipment ► Cooling water spray on critical tanks for cooling
► Foam stations for monitors at the fuel storage tanks
► Firewater pumps (electric with diesel for emergency backup) ► Firewater jockey pumps (electric and diesel)
Aemetis final fire protection design and full requirements will be subject to review and approval by the City of Riverbank and fire officials when Aemetis seeks approval of building permits.
2.5 Site Plan and Operations
2.5.1 Site Plan
Figure 6 below and Exhibit 2 to this Addendum show the Facility’s plot plan, including the general layout of equipment, buildings, and traffic flow of the facility. There will be two access points on Claus Road; the north entrance will be for entering truck traffic and the south entrance will be for exiting truck traffic as well as normal site traffic. The Facility will have its own truck scales for incoming and exiting vehicles.
The Facility will include the following buildings:
► Administration Building (existing 2,819 sf site building) ► Warehouse (existing 9,600 sf site building)
► Control Room
► Analytical Lab
► Truck Operator Shelter
► Rail Operator Shelter
► Guard Shacks (2)
► Truck Canopy
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► Rail Canopy
► Compressor Shelter
► Demin Water Equipment Shelter
► Pretreatment Shelter
► Wastewater Treatment Shelter
Employee facilities include a lunchroom, lockers, and showers in the Control Room building.
Figure 6 Site Plan
Figure 7 shows a rendering of the street level view looking northeast from Claus Road, including expected fencing and landscaping.
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Aemetis Carbon Zero 1 Project 15 May 2023
Figure 7 Rendering of Street Level View along Claus Road
2.5.2 Construction
Construction will start when all permits are obtained and financing is closed. Construction will be managed in one phase and is anticipated to take 24 months with 700 people, primarily contractors and subcontractors.
When it was owned and operated by the Army, the RAAP facility discharged hazardous substances that contaminated the soil and groundwater under portions of the RIC. The Army has assumed responsibility for the environmental clean-up and is closely coordinating with the City of Riverbank, Aemetis, and the applicable federal and state regulatory agencies. The Facility’s construction and other ground disturbing activities will be subject to review and approval by these regulatory agencies to ensure it is conducted in a manner that protects against exposure to any existing hazardous substances.
2.5.3 Hours of Operation
The facility will operate 24 hours per day, 365 days per year. Equipment may shut down periodically for planned and unplanned maintenance, but employees will be on site at all times. Deliveries will be scheduled primarily during normal business hours.
2.5.4 Employees
Once operating, the facility will employ approximately 50 people with the job functions listed below. The plant will operate with multiple shifts so not all employees will be on site at the same time, although more will be on site during daytime operations than during off-shifts. ► Plant Manager (1)
► Safety/Quality Engineer (1)
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► Admin/Accounting/Procurement (3)
► Operations Supervisors (4)
► Loading/Unloading Operators (6)
► Plant Operators (12)
► Maintenance Manager (1)
► I&E Maintenance (2)
► Mechanical Maintenance (2)
► General Maintenance (2)
► Lab Supervisors (4)
► Lab Techs (4)
► Security Guards (8)
The site plan includes parking near the administrative building and control room. Racks will be provided for employees who commute by bike. While at work, employees will travel around the interior of the facility using e-bikes provided by the facility.
2.5.5 Fencing and Design
The site will be secured by a chain link fence with guard stations controlling ingress and egress. Along Claus Road the chain link will include privacy slats to provide visual shielding in addition to vegetation and trees.
The fencing along Claus Road will be set back to allow for drainage, power lines, and sidewalks (where appropriate).
2.5.6 Traffic Summary
Materials will be shipped to and from the Facility by both truck and rail. To address this range of transportation activity during operations, this project description describes two scenarios: all truck operations (with no rail shipments, so it has the highest number of truck trips), and use of rail for feedstock and finished product deliveries. Actual operations will use a mix of truck and rail deliveries of feedstock, other additives and finished products. Shipping and receiving could occur six days per week for 12 hours per day. However, to conservatively estimate the maximum number of trips at one time, descriptions below assume shipping and delivery activities are concentrated into a shorter period of eight hours per day and five days per week.
The Facility will have two entrances, one at the main gate to the RIC and a second farther north on Claus Road. The area around the main gate, including the primary traffic route to the gate, will be widened and improved as part of the County Corridor project. Aemetis will continue to monitor and coordinate with the planners of that project on those improvements.
Table 4 shows the all-truck scenario and includes daily traffic activity levels as well as daily and annual vehicle miles travelled (VMT) assuming all receiving and delivery activities would be by truck. Table 5 shows the mixed rail and truck scenario, which assumes inbound oil feedstock and outbound finished RD and SAF are shipped by rail with are some truck deliveries for other materials. The Facility could include up to 16 daily inbound feedstock railcars (and 1 locomotive per string of railcars) and up to 17 outbound RD/SAF and Naphtha outbound railcar deliveries (and 1 locomotive per string of railcars). Sierra Northern Railway currently has a long-term lease to operate the rail spurs at the RIC and maintains Tier 3 rail power genset locomotives onsite for managing railcar movements. All rail movement on the property will be under Sierra Northern Railway’s operating rules and will comply with California Public Utility Commission and Federal Railroad Administration regulations.
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Table 4 Facility Operations Traffic Activity Assuming All Truck Daily One Way Daily Annual
Activity Round Trips Trip Length 1,2 VMT VMT
Inbound Truck Trips 89 86 15,308 3,980,080
Outbound Truck Trips 75 96 14,400 3,744,000
Employee Trips 50 16.8 1,680 613,200
VMT Summary 31,388 8,337,280
Notes:(1) CalEEMod Version 2020.4.0 Appendix D, Table 4.2 for employee trip length. (2) Measured using Google maps actual rail travel distance onsite and actual travel distance between Riverbank and SFO (outbound) and Port of Oakland (inbound).
Table 5 Facility Operations Traffic Activity Assuming Rail & Truck Daily One Way Daily Annual
Activity Round Trips 1 Trip Length 2, 3 VMT VMT
Inbound Truck Trips 3 86 516 134,160
Outbound Truck Trips 4 96 768 199,680
Employee Trips 50 16.8 1,680 613,200
Rail onsite 2 0.5 1 260
Inbound Rail off-site 1 86 86 22,360
Outbound Rail off-site 1 96 96 24,960
VMT Summary 3,147 994,620
Notes: (1) Rail activities represent locomotives needed per day to move the railcar deliveries. (2) CalEEMod Version 2020.4.0 Appendix D, Table 4.2 for employee trip length. (3) Measured using Google maps actual rail travel distance onsite and actual travel distance between Riverbank and SFO (outbound) and Port of Oakland (inbound).
2.6 Riverbank Industrial Complex (RIC) Zoning
The Facility will primarily be located on Parcel 2 within the RIC parcel map as shown in Figure 1 above.
Portions will also be located on Parcel A (Main Parcel), Parcel 2, and Parcel B. The zoning for the RIC is established by a Specific Plan. Table 6 summarizes the applicable zoning designations from the RIC Specific Plan:
Table 6 Zoning and Land Use
Parcel RIC
Zoning
Areas
Carbon Zero 1 Project Activity Permitted or Conditional Use A RAAP-2
General
Industrial
Entrance drive, scales, guard
shack, railroad spur, truck rack,
control room, parking, existing
buildings for administration and
warehouse
Permitted
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B RAAP-1
Industrial/
R&D
Stormwater pond Permitted
2 RAAP-1
Industrial/
R&D
SAF/RD production equipment
and supporting utilities
“Light” and “General” Manufacturing and
Processing are Permitted uses.
“Heavy” Manufacturing and Processing
are allowed with Use Permit
2A RAAP-R
Retail
Tanks and truck loading racks “Manufacturing and Processing-Light” activities are allowed with a Use Permit
Notes:
1) From Table 5-1, Allowed Uses in RAAP Areas, from RAAP Specific Plan (Riverbank Local Redevelopment Authority, 2013), pp. 65-66
Based on these zoning designations a City of Riverbank Use Permit would be required for the following:
► To allow heavy industry activities in the RAAP-1 zone ► To allow light industry activities in the RAAP-R zone
2.7 Permits and Regulatory Programs
The Facility will be subject to or potentially subject to the following permit requirements and regulatory programs:
► City of Riverbank: Use Permit
► City of Riverbank: Building Permits (including mechanical, electrical, grading, fire review, etc.) ► City of Riverbank: Lead Agency for CEQA
► City of Riverbank: Business License
► City of Riverbank: Tree Ordinance (where applicable)
► City of Riverbank: Connections to City water supply and City sewer line ► Stanislaus County or City of Riverbank: Encroachment permit for street access and any necessary offsite improvements (if applicable)
► Stanislaus County, Department of Environmental Resources, Environmental Health Services: Hazardous Materials Business Plan, Emergency Action Plan, SPCC plan (as applicable) ► Stanislaus County, Department of Agriculture & Weights and Measures: Scale Permit ► Fire Department: California Fire Code
► San Joaquin Valley Air Pollution Control District (SJVAPCD): Air emissions permits (authorities to construct and permits to operate)
► San Francisco Public Utility Commission (SFPUC): Application for Land or Right-of-Way Access Permit for new pipes (if needed)
► California Air Resources Board (CARB): Low Carbon Fuel Standard (LCFS), Pathway Certification ► Central Valley Regional Water Quality Control Board (Central Valley RWQCB): Stormwater Pollution Prevention Plans (construction and operation), Waters of the State permit (wetlands disturbance if applicable), Wastewater discharge permits (if applicable) ► CalOSHA: Construction permits for structures and pits; operating permits for pressure vessels; compliance with design standards and regulatory programs ► California Department of Toxic Substances Control (DTSC): California Accidental Release Program (CalARP) and Federal Risk Management Program (RMP) CalARP/RMP plan (if applicable) Riverbank Industrial Complex CEQA Addendum
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► California Energy Commission: Award of grant funds (if applicable) ► U.S. Environmental Protection Agency: Renewable Fuels Standard Facility Registration; Fuel Registrations; Low Carbon Renewable Fuel Pathway Approval (if applicable) ► U.S. Environmental Protection Agency (US EPA): Hazardous Waste Generator ID ► U.S. EPA, DTSC, RWQCB, U.S. Army: Soils Management Plan ► U.S. Army: Compliance with lease provisions, including approval of physical modifications Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 20 May 2023
3. CEQA PROCESS
3.1 History of the RAAP Site
The U.S. Army used the RAAP Site primarily to produce ammunition from World War II until 2010. In 2005, the federal government designated the RAAP Site for closure and reuse under the federal Defense Base Closure and Realignment Act of 1990.
In 2007 and 2008, the City of Riverbank prepared a Base Reuse Plan and held several public hearings on the plan. In 2009, the City adopted its current General Plan and certified an associated EIR that anticipated the transfer of the RAAP Site to the City of Riverbank. The General Plan designates the RAAP Site as “Industrial/Business Park,” and designates land adjacent to the RAAP Site to the east and west of the southern half of the RAAP Site as the same Industrial/Business Park category.
The City began leasing the RAAP Site from the U.S. Army in 2010, and entered several subleases with various tenants to begin reuse of the Site. The City is also in the process of acquiring actual title to portions of the RAAP Site land from the U.S. Army. In 2021, the City leased portions of the RAAP Site to Aemetis Properties Riverbank, Inc. as Master Developer. Pursuant to that lease, Aemetis took over operations of the built-up portions of the facility and is developing the open portions. The lease to Aemetis also includes agreements for the City to sell the property to Aemetis after the facility transfers from the U.S. Army.
3.2 The Specific Plan EIR
On March 28, 2013, the City issued a draft EIR (“DEIR”) for the development of the RAAP Site pursuant to a Specific Plan, and accepted public comments on the documents. The City prepared a final EIR (“FEIR”) in November 2013. Pursuant to CEQA, the full EIR for the Specific Plan includes both the draft EIR and the final EIR. On February 10, 2014, the Riverbank City Council certified the EIR, adopted the Specific Plan for the RAAP Site, made findings pursuant to CEQA related to the impacts of the project, and adopted a Mitigation Monitoring and Reporting Plan (“MMRP”) that contains final mitigation measures for significant impacts. The purpose of the Specific Plan was to change the city zoning applicable to the RAAP Site to allow for private use. The EIR for the Specific Plan analyzes the effects of the rezoning and the effects of building out the RAAP Site in accordance with the planned private uses under the rezoning. It was anticipated that individual projects built at the Riverbank Industrial Complex (RIC) could rely on the certified EIR, subject to the appropriate CEQA standards to determine if additional analysis would be necessary and the appropriate type of analysis. (Specific Plan Page 117.)
3.3 CEQA Standard
The legal standard for the appropriate CEQA review of a specific project after adoption of an EIR is provided in CEQA Guidelines Sections 15168 and 15162. In order to promote efficient development, those sections require agencies to rely on existing environmental documentation unless a proposed activity includes substantial changes from the project described in the EIR (including changes to the project, circumstance or new information), and those changes require major revisions to the EIR due to new or substantially worse significant adverse effects on the environment. If that standard is met, the activity would require additional environmental documentation such as a supplemental EIR, subsequent EIR, or mitigated negative declaration.
In each case, such documentation would be focused on just those new substantial changes. If the new Riverbank Industrial Complex CEQA Addendum
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activity does not include substantial changes to the previously described project, or if there are changes that do not cause new significant adverse impacts to the environment, CEQA states the ”lead agency or responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.” CEQA Guidelines Section 15164(a).
3.4 Checklist Analysis
Section 4 below compares the Aemetis Facility to the project described in the Specific Plan EIR using the same checklist questions and significance thresholds typically used in an Initial Study and an EIR. Specifically, the analysis includes a section for each of the 20 environmental resource areas typically discussed in a CEQA analysis. For each resource area, the analysis describes the scope of the project described in the EIR and conclusions of the EIR, and compares Aemetis’ Facility to the project that is analyzed in the EIR with respect to each significance threshold listed in the EIR.
Based on this Checklist review, pursuant to CEQA Guidelines Section 15168 and 15162, the Facility does not include substantial changes to the project described in the Specific Plan EIR that would meet the requirements of Section 15162 for performing additional environmental review. As a result, this Addendum can be placed in the record with the existing EIR to (i) be reviewed in conjunction with decisions about the Facility, and (ii) document the City’s determination that a subsequent EIR is not required.
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4. ENVIRONMENTAL REVIEW
4.1 CEQA Guidelines Appendix G Updates
Since the City’s certification of the EIR in 2014, the CEQA Guidelines Appendix G, Environmental Checklist, has been revised, with revisions made to some existing checklist questions, the addition of some new checklist questions, and the addition of new resource areas for energy, greenhouse gases, tribal cultural resources, and wildfire. Table 7 compares the scope of the EIR and subsequent changes to the CEQA environmental checklist. The modifications to the checklist questions are reviewed in the discussion for each resource area below.
Table 7 EIR Scope Comparison with 2019 CEQA Environmental Checklist Updates CEQA
Environmental
Checklist
Impact Areas
Was the
Resource Area
included in the
Specific Plan EIR
Analysis?
2019 CEQA
Environmental
Checklist
Updates
Changes?
Summary of Changes to EIR Findings
Aesthetics Yes Yes New/modified checklist question(s) are addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Agriculture and
Forestry
Resources
Yes No No change
Air Quality Yes Yes New/modified checklist question(s) are addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Biological
Resources
Yes Yes New/modified checklist question(s) are
addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Cultural
Resources
Yes Yes New/modified checklist question(s) are
addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Energy No Yes. New
Resource area
New checklist question(s) are addressed in CEQA
Environmental Checklist below with no change in
findings described in the EIR as a result of the
Facility.
Geology and Soils Yes Yes New/modified checklist question(s) are addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Greenhouse Gas
Emissions
Yes Yes New/modified checklist question(s) are
addressed in Environmental Checklist below with
no change in findings described in the EIR as a
result of the Facility.
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CEQA
Environmental
Checklist
Impact Areas
Was the
Resource Area
included in the
Specific Plan EIR
Analysis?
2019 CEQA
Environmental
Checklist
Updates
Changes?
Summary of Changes to EIR Findings
Hazards and
Hazardous
Materials
Yes Yes New/modified checklist question(s) are
addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Hydrology and
Water Quality
Yes Yes New/modified checklist question(s) are
addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Land Use
Planning
Yes Yes New/modified checklist question(s) are
addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Mineral
Resources
Yes No No change
Noise Yes Yes New/modified checklist question(s) are
addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Population and
Housing
Yes Yes New/modified checklist question(s) are
addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Public Services Yes Yes New/modified checklist question(s) are addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Recreation Yes Yes New/modified checklist question(s) are addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Transportation Yes Yes New/modified checklist question(s) are addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
Tribal Cultural
Resources
Yes. This is now a
descrete resource
area but the
checklist question
was previously
included in Cultural
Resources.
Yes New/modified checklist question(s) are
addressed in CEQA Environmental Checklist
below with no change in findings of the project
described in the EIR as a result of the Facility.
Comment letter on NOP IS of the EIR documents
that tribal representatives were contacted and
they did not request consultation at that time.
Utilities / Service
Systems
Yes Yes New/modified checklist question(s) are
addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
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Aemetis Carbon Zero 1 Project 24 May 2023
CEQA
Environmental
Checklist
Impact Areas
Was the
Resource Area
included in the
Specific Plan EIR
Analysis?
2019 CEQA
Environmental
Checklist
Updates
Changes?
Summary of Changes to EIR Findings
Wildfire Not a discrete
resource area, but
it was partially
assessed in
Hazards analysis
previously
Yes New/modified checklist question(s) are
addressed in CEQA Environmental Checklist
below with no change in findings described in
the EIR as a result of the Facility.
4.2 CEQA Addendum Evaluation Questions
Pursuant to California Public Resources Code (PRC) Section 21166 and CEQA Guidelines Section 15162, when an environmental impact report (EIR) has been certified or a negative declaration adopted for a project, no subsequent EIR or negative declaration shall be prepared for the project unless the lead agency determines that one or more of the following conditions are met:
Are there Substantial Changes to the Project, and, If So, Do They Involve New Significant Impacts or Substantially More Severe Impacts?
Pursuant to Section 15162(a)(1) of the CEQA Guidelines, this column in the tables below indicate whether there are substantial changes to the project that would require major revisions to the certified Environmental Impact Report due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.
Are there Substantial Changes in the Circumstances for the Project, and, If So, Do They Involve New Significant Impacts or Substantially More Severe Impacts Pursuant to Section 15162(a)(2) of the CEQA Guidelines, this column indicates whether there have been substantial changes in the circumstances under which the project is undertaken that have occurred subsequent to the certified Environmental Impact Report, which would require major revision to an Environmental Impact Report due to the involvement of new significant environmental impacts that were not considered in the existing environmental document or a substantial increases in the severity of previously identified significant impacts.
Is there New Information of Substantial Importance, and, If So, Does it Identify New Significant Effects Pursuant to Section 15162(a)(3)(A-D) of the CEQA Guidelines, this column indicates whether new information of substantial importance which was not known and could not have been known with the exercise of reasonable diligence at the time the environmental documents were certified as complete (or adopted) is available, requiring an update to the analysis of the environmental documents to verify that the environmental conclusions and mitigation measures remain valid. If the new information shows that: (A) the project will have one or more significant effects not discussed in the environmental documents; or (B) significant effects previously examined will be substantially more severe than shown in the environmental documents; or (C) mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects or the project, but the project proponents decline to adopt the mitigation measure or alternative; or (D) mitigation measures or alternatives which are considerably different from those analyzed in the environmental documents would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative, the question would be answered ‘Yes’ requiring the preparation of an Environmental Impact Report.
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Aemetis Carbon Zero 1 Project 25 May 2023
However, if the additional analysis completed as part of this Environmental Checklist review finds that the conclusions of the certified Environmental Impact Report remain the same and no new significant impacts are identified, or identified significant environmental impacts are not found to be substantially more severe, the question would be answered ‘No’ and no additional documentation would be required Section 4.3 below, Environmental Analysis, contains a summary table for each environmental resource area recommended by the CEQA Guidelines that addresses the above questions for each resource area, followed by a comparison of the Facility to the project described and evaluated in the Specific Plan EIR. The table at the beginning of each section also identifies mitigation measures adopted for each resource area when the City of Riverbank certified the EIR.
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 26 May 2023
4.3 Environmental Analysis
I. Aesthetics
Aesthetics Checklist Questions
I. Aesthetics.
Would the project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Have a substantial
adverse effect on a
scenic vista?
DEIR pp. 4.1-1
to 4.1-12
No No No No
b) Substantially
damage scenic
resources, including,
but not limited to,
trees, rock
outcroppings, and
historic buildings
within a state scenic
highway?
DEIR pp. 4.1-1
to 4.1-12
No No No No
c) Substantially
degrade the existing
visual character or
quality of the site
and its surroundings?
DEIR pp. 4.1-1
to 4.1-12
No No No No
d) Create a new
source of substantial
light or glare which
would adversely
affect day or
nighttime views in
the area?
DEIR pp. 4.1-1
to 4.1-12
No No No No
Checklist question Ia: The EIR identifies the only scenic vista in Riverbank’s General Plan as the scenery along the Stanislaus River, which is approximately one mile from the RAAP Site. The EIR states that “the General Plan emphasizes the importance of scenic views along the Stanislaus River, but no other scenic views are identified in the Riverbank General Plan. Implementation of the Specific Plan would not impact scenic views along the Stanislaus River, and therefore, the Specific Plan would cause no impact on General-Plandesignated scenic views” (DEIR 4.1-9). The EIR analysis also applies to individual projects implementing the Specific Plan since they are located on the same land, including the Facility. Therefore, the Facility does not change the project described in the EIR with respect to this threshold.
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Aemetis Carbon Zero 1 Project 27 May 2023
Checklist question Ib: The EIR determines that the Specific Plan area “is located approximately 20 miles to the east of Interstate 5, an Officially Designated State Scenic Highway” (DEIR 4.1-9) and determines that the Specific Plan would have “no impact on views from a scenic highway” (DEIR 4.1-10). This conclusion also applies to individual projects located within the Specific Plan area, including the Facility. Therefore, the Facility does not change the project described in the EIR with respect to this threshold.
Checklist question Ic: As stated in the Specific Plan and referenced in the EIR, “the existing visual character of the site is predominantly industrial” (DEIR 4.1-10). The Facility includes the installation of large industrial equipment, which is consistent with the existing visual character. The closest side of the Facility will be more than 30 feet from the edge of Claus Road; this industrial equipment will be visible from the street and other areas outside of the RAAP area. Because there is a buffer between the edge of the Facility and the street (Claus Road), there will be adequate space for the installation of additional aesthetic design features prescribed in the Specific Plan (e.g., fence with privacy slats, landscaping, etc.) between the Facility and the street as described in the Project Description. Given that the existing visual character of the site is predominantly industrial and due to the planned landscaping improvements along the site’s boundaries with Claus Road, the EIR determines that the implementation of the Specific Plan will be an overall beneficial impact to the “existing visual character or quality of the site and its surroundings” (DEIR 4.1-10). The Facility will be part of the build out of the Specific Plan and is consistent with the existing visual character of the RAAP Specific Plan, as shown in Figure 2-9, the rendering of street views, and therefore the Facility does not represent a substantial change from the project described in the EIR.
Checklist question Id: The EIR states that the development and improvements described in the Specific Plan could contribute to light and glare during both daytime and nighttime (DEIR 4.1-11). The EIR also describes many existing sources of glare already existing in the industrialized portion of the RAAP Site. The EIR states that “the Riverbank General Plan contains policies which would mitigate these potential impacts” (DEIR 4.1-11). Based on policies DESIGN-17.2 and CONS-7.6 (DEIR 4.1-11), the EIR then determines that the additional light and glare created by the implementation of the Specific Plan and controlled by the existing development policies will be less than significant. The Facility is part of the build out of the RAAP site discussed in the Specific Plan and will adhere to all applicable pre-existing guidelines as described in the EIR (DEIR 4.1- 2 to 4, 11). Therefore, the Facility does not change the project described in the EIR with respect to this threshold.
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Aemetis Carbon Zero 1 Project 28 May 2023
II. Agriculture and Forestry Resources
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland.
In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.
Agriculture and Forestry Resources Checklist Questions
II. Agriculture
and Forestry
Resources.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Convert Prime
Farmland, Unique
Farmland, or
Farmland of
Statewide
Importance
(Farmland), as
shown on the
maps prepared
pursuant to the
Farmland Mapping
and Monitoring
Program of the
California
Resources Agency,
to non-agricultural
use?
DEIR pp. 4.2-1
– 4.2-14
No No No No
b) Conflict with
existing zoning for
agricultural use, or
a Williamson Act
contract?
DEIR pp. 4.2-1
– 4.2-14
No No No No
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Aemetis Carbon Zero 1 Project 29 May 2023
II. Agriculture
and Forestry
Resources.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
c) Conflict with
existing zoning for,
or cause rezoning
of, forest land (as
defined in Public
Resources Code
section 12220(g)),
timberland (as
defined by Public
Resources Code
section 4526), or
timberland zoned
Timberland
Production (as
defined by
Government Code
section 51104(g))?
DEIR pp. 4.2-1
– 4.2-14
No No No No
d) Result in the
loss of forest land
or conversion of
forest land to nonforest use?
DEIR pp. 4.2-1
– 4.2-14
No No No No
e) Involve other
changes in the
existing
environment
which, due to their
location or nature,
could result in
conversion of
Farmland, to nonagricultural use or
conversion of
forest land to nonforest use?
DEIR pp. 4.2-1
– 4.2-14
No No No No
Checklist question IIa: According to the EIR, The RAAP site “does not contain any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance” (DEIR 4.2-10). The land on the RAAP site that is designated as Farmland of Local Significance under the Farmland Mapping & Monitoring Program (FMMP) is “not considered farmland of concern under CEQA” (4.2-10). Therefore, the EIR determines that there a no impacts Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 30 May 2023
to this resource area. Since the Facility will be located on the same land analyzed in the EIR, the Facility does not change the project described in the EIR with respect to this threshold.
Checklist question IIb: The primary purpose of the Specific Plan is to create new zoning designations for the RAAP Site (RAAP Specific Plan, page 7). There are no agriculturally-zoned areas within the RAAP Site; therefore, the EIR determines that the Specific Plan “would not conflict with existing agricultural zoning or Williamson Act contracts and there would be no impact” (DEIR 4.2-10). The Facility will be built on the same land analyzed in the EIR. Therefore, the Facility does not change the project described in the EIR with respect to this threshold.
Checklist question IIc: The EIR determines that there are no timber resources in the City of Riverbank (DEIR, section 4.2), so the implementation of the Specific Plan would have no impact on forest resources.
The Facility will be built on the same land analyzed in the EIR. Therefore, the Facility does not change the project described in the EIR with respect to this threshold.
Checklist question IId: The EIR determines that no forest land exists at the RAAP site, and the Specific Plan therefore creates no risk of conversion due to this project, so there are no impacts. The Facility will be built on the same land analyzed in the EIR. Therefore, the Facility does not change the project described in the EIR with respect to this threshold.
Checklist question IIe: The EIR states that “approximately 20 acres of the [RAAP] site is designated as Farmland of Local Importance under the FMMP” (DEIR 4.2-11). This land is currently undeveloped. The EIR’s discussion includes a study conducted to determine whether the conversion of this land for and industrial/business park would result in a significant environmental impact using a detailed Land Evaluation/Site Assessment (LESA) model pursuant to pursuant to CEQA Appendix G and the City of Riverbank Draft Sustainable Agricultural Committee Report of January 2010. The LESA model determined that the impact of conversion of the 20 acres of grazing to an industrial and business park would be less than significant. This conclusion also applies to all projects built within the RAAP Site. Therefore, the Facility does not change the project described in the EIR with respect to this threshold.
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 31 May 2023
III. Air Quality
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.
Air Quality Checklist Questions
III. Air Quality.
Would the project:
Where
Impact
Is
Analyzed
in
Existing
Environ
mental
Docume
nts
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Conflict with or
obstruct
implementation of the
applicable air quality
plan?
DEIR pp.
4.3-1 to
4.3-42
No No No No
b) Violate any air
quality standard or
contribute
substantially to an
existing or projected
air quality violation?
DEIR pp.
4.3-1 to
4.3-42
No No No DEIR Mitigation
Measures AQ-1a
through AQ-1e
and AQ-2 (DEIR
4.3-39 to 4.3-
40; MMRP pp. 1
to 5)
c) Result in a
cumulatively
considerable net
increase of any
criteria pollutant for
which the project
region is nonattainment under an
applicable federal or
state ambient air
quality standard
(including releasing
emissions which
exceed quantitative
thresholds for ozone
precursors)?
DEIR pp.
4.3-1 to
4.3-42
No No No DEIR Mitigation
Measures AQ-1a
through AQ-1e
and AQ-2 (DEIR
4.3-39 to 4.3-
40; MMRP pp. 1
to 5)
d) Expose sensitive
receptors to
substantial pollutant
concentrations?
DEIR pp.
4.3-1 to
4.3-42,
and FEIR
pp. 3-1 to
3-11
No No No No
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 32 May 2023
III. Air Quality.
Would the project:
Where
Impact
Is
Analyzed
in
Existing
Environ
mental
Docume
nts
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
e) Result in other
emissions (such as
those leading to
odors) adversely
affecting a substantial
number of people?
DEIR pp.
4.3-1 to
4.3-42
No No No No
Appendix A includes an air quality technical memo prepared by GeoSyntec that describes the Facility’s criteria air pollutant emissions estimates for construction and operations.
Construction Phase Impacts
The Facility will occupy 960,319 square feet, including 77,076 square-feet for a new rail spur area.
Construction of buildings, improvements to roads, and installation of equipment would occur over an approximately two-year period. Estimates of air pollutant emissions associated with the construction are based on Aemetis’ preliminary phasing schedule, which includes grading, excavation and site work, building construction, and paving.
Estimated unmitigated construction-related emissions associated with the Facility are shown in Tables 1 and 2 of Appendix A. The existing EIR Mitigation Measure AQ-1e applies to construction emissions. That measure states:
Mitigation Measure AQ-1e: Implement measures to mitigate emissions from construction equipment exhaust. The project [as described in the EIR] will implement additional emissions control measures will include utilizing construction equipment with engines that either meet or exceed USEPA Tier 4 offroad emission standards in at least ninety percent of diesel-powered off-road construction equipment rated greater than 25 horsepower.
With implementation of EIR Mitigation Measure AQ-1e, NOX emissions associated with construction of the Facility would not exceed the SJVAPCD regional significance threshold, as shown in Table 2 of Appendix A, Carbon Zero 1 Project Construction Emissions – Mitigated.
Operations Phase Impacts
The Facility’s operational emissions are described in Appendix A. Operations would also result in 50 employee vehicle round-trips daily, and from 164 heavy-duty haul truck round-trips per day and no rail (all trucks case) to 7 daily truck round trips and 2 daily locomotives delivering and receiving through railcar deliveries. Total criteria pollutant emissions resulting from Facility operations are summarized in Table 3 (Rail & Truck Scenario) and Table 5 (All Truck Scenario) of Appendix A.
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Aemetis Carbon Zero 1 Project 33 May 2023
As shown in Table 3 and Table 4 of Appendix A, the Facility’s long-term annual criteria pollutant emissions that would not individually exceed SJVAPCD’s significance thresholds.
Checklist question IIIa: The EIR analyzes the growth associated with the overall Specific Plan project and states that “the proposed Plan would not result in a substantial and unplanned level of growth and associated air quality impacts would therefore be consistent with population and vehicle related emissions projections contained in regional clean air planning efforts and would not conflict with achievement of the control plans aimed at reducing these projected emissions” (DEIR 4.3-26). The EIR estimates that the Specific Plan would create between 827 and 1,654 new jobs. The Facility will create approximately 50 new jobs and is well within this amount. The City’s general plan anticipates 2,000,000 square feet of new industrial space that is accounted for in the RAAP Specific Plan and other regional plans. The Facility is well within the regional growth projections used for air quality planning as well as analyzed in the EIR, and therefore does not constitute a change to the project described in the EIR with respect to this threshold.
Checklist question IIIb: The EIR calculates the estimated emissions from traffic associated with substantial increase in daily trips from the overall buildout of the Specific Plan. The EIR also summarizes SJVAPCD significance thresholds for air emissions. The SJVAPCD reviewed the City’s analysis contained in the Draft EIR and provided comments to the City on the RAAP Specific Plan Draft EIR that the SJVAPCD believed necessary to ensure that emissions from specific projects built to implement the Specific Plan would not cause significant impacts that are not accounted for the EIR. In response to SJVAPCD’s comments, the City adopted SJVAPCD’s suggestions and imposed more stringent mitigation measures that are designed to address both the construction and operation emissions of all projects that implement the Specific Plan (FEIR 5-20 to 5-21). The mitigation measures are intended to ensure compliance with both CEQA and SJVAPCD rules and require a project specific air analysis to be performed for both ministerial and discretionary projects prior to the City’s issuance of building permits. Since the EIR already determines that emissions from individual projects might be significant and imposes mitigation measures on the individual projects to ensure they are not significant, the Facility is therefore consistent with the project analyzed in the EIR and does not constitute a change.
Checklist question IIIc: The EIR summarizes the SJVAPCD significance thresholds and determines that the impact of emissions from the implementation of the Specific Plan would be significant and unavoidable with respect to traffic and significant with mitigation with respect to operations. In response to comments provided to the City by SJVAPCD, the City imposed more stringent mitigation measures on all projects designed to address both the construction and operation emissions of projects that implement the Specific Plan (FEIR 5- 20 to 5-21). The mitigation measures are intended to ensure compliance with both CEQA and SJVAPCD rules and require a project specific analysis to be performed for both ministerial and discretionary projects prior to the City’s issuance of building permits. The Facility will be required to comply with any these EIR mitigation measures that are applicable, so it does not represent a change from the project analyzed in the EIR.
Furthermore, the Facility will be required to obtain and comply with SJVAPCD’s air permitting rules and regulations, which will ensure that the Facility operations comply with all relevant rules and plans, and that it does not increase emissions beyond the SJVAPCD’s levels of significance. The EIR’s mitigation measures are intended to apply to all projects, whether or not they require an SJVAPCD permit and whether or not they are ministerial or discretionary. Individual projects such as the Facility that require a permit to construct from SJVAPCD will automatically be required to comply with those mitigation measures and all SJVAPCD rules and regulations through the air permitting process, which provides assurance that such projects will not have significant emissions. Therefore, the Facility does not represent a change to the project analyzed in the EIR and there are no revisions to the EIR necessary or new significant air quality effects with respect to this threshold.
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Aemetis Carbon Zero 1 Project 34 May 2023
Checklist question IIId: The EIR analyzes the potential risks to sensitive receptors from additional pollution (DEIR 4.3-33 through 4.3-37). The EIR defines the threshold for a significant impact to sensitive receptors as “an incremental cancer risk of ten excess cases per million at the Maximally Exposed Individual (MEI)” (DEIR
4.3-36). The EIR found that “maximum increased MEI cancer risk for a 70-year exposure was 6.5 in a million” (DEIR 4.3-36), which is less than the threshold of significance so the EIR determined that the potential risk to sensitive receptors would be a less than significant impact. The EIR based its conclusion on an estimated 9,390 new daily vehicle trips associated with implementation of the Specific Plan (DEIR 4.16-24). As detailed above in Table 4 of the Project Description, the worst-case traffic generated by the Facility is approximately 50 new daily employee round trips in and out of the site and 164 daily truck round trips for deliveries of feed stock and other additives as well as distribution of finished product. The Facility’s trip generation is only a fraction of the Specific Plan’s anticipated traffic. Therefore, the Facility does not represent a change to the project analyzed in the EIR.
Checklist question IIIe: The EIR states that odor complaints could be associated with either new activities or with placing new activities next to existing odor sources (DEIR 4.3-37). It concludes that there are no existing odor sources that could generate complaints and did not expect the build out of the Specific Plan to create objectionable odors. The Facility’s feedstock includes vegetable oils and animal fats that could have a potential for odors. As indicated in the Project Description, the Facility will include carbon filters on the vents for tanks holding oils and animal fats. These carbon filters are industry standard for managing potential odors and therefore the Facility is not expected to have objectionable odors based on the planned processes. The build out of the Specific Plan anticipated the construction of many types of industrial facilities, so the Facility is consistent with the project described in the EIR and does not represent a change to the project analyzed in the EIR.
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Aemetis Carbon Zero 1 Project 35 May 2023
IV. Biological Resources
Biological Resources Checklist Questions
IV. Biological
Resources.
Would the
project:
Where
Impact Is
Analyzed in
Existing
Environmen
tal
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstance
s Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Informatio
n Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Have a
substantial adverse
effect, either
directly or through
habitat
modifications, on
any species
identified as a
candidate,
sensitive, or special
status species in
local or regional
plans, policies, or
regulations, or by
the California
Department of Fish
and Game or U.S.
Fish and Wildlife
Service?
DEIR pp. 4.4-
1 to 4.4-28
No No No BIO-1 (FEIR 2-8
to 2-10; MMRP
pp. 5 to 7)
b) Have a
substantial adverse
effect on any
riparian habitat or
other sensitive
natural community
identified in local
or regional plans,
policies,
regulations or by
the California
Department of Fish
and Game or US
Fish and Wildlife
Service?
DEIR pp. 4.4-
1 to 4.4-28
No No No No
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 36 May 2023
IV. Biological
Resources.
Would the
project:
Where
Impact Is
Analyzed in
Existing
Environmen
tal
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstance
s Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Informatio
n Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
c) Have a
substantial adverse
effect on federally
protected wetlands
as defined by
Section 404 of the
Clean Water Act
(including, but not
limited to, marsh,
vernal pool,
coastal, etc.)
through direct
removal, filling,
hydrological
interruption, or
other means?
DEIR pp. 4.4-
1 to 4.4-28
No No No No
d) Interfere
substantially with
the movement of
any native resident
or migratory fish or
wildlife species or
with established
native resident or
migratory wildlife
corridors, or
impede the use of
native wildlife
nursery sites?
DEIR pp. 4.4-
1 to 4.4-28
No No No BIO-1 (FEIR 2-8
to 2-10; MMRP
pp. 5 to 7)
e) Conflict with any
local policies or
ordinances
protecting
biological
resources, such as
a tree preservation
policy or
ordinance?
DEIR pp. 4.4-
1 to 4.4-28
No No No
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Aemetis Carbon Zero 1 Project 37 May 2023
IV. Biological
Resources.
Would the
project:
Where
Impact Is
Analyzed in
Existing
Environmen
tal
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstance
s Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Informatio
n Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
f) Conflict with the
provisions of an
adopted Habitat
Conservation Plan,
Natural Community
Conservation Plan,
or other approved
local, regional, or
state habitat
conservation plan?
DEIR PP. 4.4-
1 to 4.4-28
No No No No
Checklist question IVa: The EIR determines that while special-status plant and animal species are known to occur within the general vicinity of the RAAP site, existing site conditions make the RAAP site unsuitable for these species. None of the eleven special-status animal species or ten special-status plant species found in the region are known to occupy the site (DEIR 4.4-22). However, the EIR does identify one potentially significant impact in this category related to potential habitat disturbance of one special-status animal species, the Townsend’s western big-eared bat. Abandoned buildings on the RAAP site could offer roosting habitat for Townsend’s big-eared bats that could be affected by demolition activities. Because of this, the EIR determines that this impact is “potentially significant” (DEIR 4.4-24) and the City adopted a mitigation measure (BIO-1) to reduce the effect of abandoned building demolition if the Townsend’s big-eared bat is found onsite during breeding or hibernacula season. This mitigation measure, described in the Final EIR (FEIR 2-9), requires conducting surveys no more than two weeks in advance of any demolition or construction activity involving concrete breaking or similarly noisy or intrusive activities that would commence during the pup-rearing season (April 15 through August 31) or winter hibernacula season (October 15 through March 1, depending on weather conditions). If these surveys, which must be conducted by a “qualified bat biologist”, find bat roosts in the vicinity of the planned activity, certain described steps must be undertaken to protect the bats from disturbance. The City’s EIR findings conclude that the impact is less than significant with these mitigation measures. Because the EIR specifically analyzed the potential future build-out of the site, including possible demolition of existing buildings, the Facility does not include any changes from the project described in the EIR. To the extent building demolition is required for the Facility (although not currently part of the plant design), the Facility will be required to comply with the identified BIO-1 mitigation measure.
Checklist question IVb: The EIR determines that the Specific Plan area does not contain riparian habitat, and as such development on the site will have a less than significant impact on “riparian habitat and sensitive natural community types” (DEIR 4.4-24). This same conclusion applies to all individual projects, including the Facility. Therefore, there are no changes to the project described in the EIR.
Checklist question IVc: The EIR determines that the 1.3 acres of wetlands that exist within the RAAP Site “appear to be isolated depressions as they are not tributary to a ‘navigable waters of the US’” and potentially Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 38 May 2023
exempt from Section 404 of the Clean Water Act (CWA) (DEIR 4.4-24). The EIR determines that the impact of the Specific Plan on these areas would be less than significant. This conclusion applies to individual projects implementing the Specific Plan, including the Facility. The Facility will not be located within the 1.3 acres identified as potential wetlands. Therefore, there are no changes to the project described in the EIR.
Checklist question IVd: The EIR reviews the potential build out of the RAAP site, and states that the stormwater retention ponds onsite will remain in place and the implementation of the Specific Plan would involve development of currently undeveloped ruderal grassland and emergent marsh. The EIR concludes that the overall impact of the implementation of the Specific Plan will be less than significant (DEIR 4.4-24,25). As described in the Project Description, the Facility will include a new stormwater retention pond approximately adjacent to the existing stormwater retention ponds to the east. Therefore, the Facility does not represent a change from the project described in the EIR.
Checklist question IVe: The EIR identified General Plan Policy CONS-5.4 regarding protection of wetlands and CONS-5.7 regarding loss of Swainson’s hawk foraging habitat as relevant to this impact category (DEIR
4.4-25). The EIR states that because projects developed on the RAAP Site will be required to comply with applicable General Plan policies, including Riverbank GP policies CONS-5.4 and CONS-5.7 (DEIR 4.4-25), impacts to this resource area will be less than significant. Furthermore, the Facility will be built in a vacant portion with no trees or potential bird habitat, and not within the area where Swainson’s hawks would be present. Since the EIR analyzes the build-out of the entire RAAP site, the Facility does not change the project analyzed in the EIR.
Checklist question IVf: The EIR analyzes whether the implementation of the Specific Plan would conflict with the Recovery Plan for Upland Species of San Joaquin Valley (RPUSSJV) (DEIR 4.4-25). The species in the region that are protected under the RPUSSJV include the San Joaquin kit fox, Riparian (San Joaquin Valley) woodrat, and Riparian brush rabbit, but none of these species are known to be present at the RAAP site (DEIR
4.4-25). Current industrial activities on the site make their presence very unlikely. The EIR determines that the Specific Plan would have no impacts on any conservation plan. This conclusion also applies generally to all projects implementing the Specific Plan, including the Facility. Therefore, there are no changes to the project described in the EIR.
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 39 May 2023
V. Cultural Resources
Cultural Resources Checklist Questions
V. Cultural
Resources.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Cause a
substantial adverse
change in the
significance of a
historical resource
as defined in §
15064.5?
DEIR pp. 4.5-1
to 4.5-24
No No No CUL-1 (MMRP p.
7).
b) Cause a
substantial adverse
change in the
significance of an
archaeological
resource pursuant
to § 15064.5?
DEIR pp. 4.5-1
to 4.5-24
No No No No
c) Disturb any
human remains,
including those
interred outside of
dedicated
cemeteries?
DEIR pp. 4.5-1
to 4.5-24
No No No No
Checklist question Va: The RAAP Site is not located within or on any of the sites on the National Register of Historic Places (DEIR 4.5-20). However, the EIR states that parts of the RAAP Site could be eligible for inclusion on the California Register of Historic Resources (CRHR) because it is historically significant at a local level for its role in the area’s industrial past. Demolition of buildings at the RAAP Site might have a potentially significant impact on the local historical character of Riverbank. However, the site’s complex and inconsistent history make it less likely to be considered a historic resource, as discussed on page 4.5-14 of the EIR as follows: “In summary, the property may be eligible to the CRHR for its association with munitions manufacturing, but its association with three wars, change of use, and growth by accretion significantly complicate any such determination. California housed extensive arms manufacturing plants over the same period, making it likely that this plant would be significant only at the local level, if at all.” The EIR includes a mitigation measure (CUL-1) which would be undertaken if buildings are modified or demolished for the Facility. The mitigation measure is described as follows on page 2-10 of the FEIR: “Prior to the demolition of buildings and structures comprising the eligible district, an Historic American Building Survey/Historic American Engineering Record (HABS/HAER) recordation shall be conducted for the affected Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 40 May 2023
structures. HABS/HAER recordation could include archiving of original plans, undertaking archival research for preparation of a report, making measured drawings, and completing a photographic study of the structures.” The EIR determines that the impact due to the loss of buildings that are currently eligible for inclusion on the CRHR is significant and unavoidable, however, no building demolition will be required for the Facility, and it does not change the project described in the EIR.
Checklist question Vb: The Specific Plan describes existing General Plan policies protecting archeological resources (Riverbank GP policies CONS-2.1, CONS-2.2, CONS-2.4, and CONS-2.5, DEIR 4.5-21), and determines that “there are no known archaeological resources in the RAAP Plan Area and a records search of files at the Central California Information Center (CCIC) indicated there are no recorded prehistoric cultural resources in Riverbank” (DEIR 4.5-21). The EIR determines that the impact of the Specific Plan on this category is less than significant. Because the Facility will be located on the land which was included in the Specific Plan evaluation, it does not change the project described in the EIR.
Checklist question Vc: The Specific Plan describes existing General Plan policies protecting prehistoric human remains (Riverbank GP policy CONS-2.5, DEIR 4.5-22), and determines that there are no known prehistoric human remains in the vicinity of Riverbank, although it is possible that there are undiscovered remains in the RAAP site area (DEIR 4.5-22). Given that no remains have been discovered at the site, there are no predicted impacts under this threshold, and the existing EIR determines that impacts to this category are less than significant. If remains were to be discovered during development of the property, the developer would be required to comply with the California Health and Safety Code and any other relevant regulations described in the EIR (DEIR 4.5-22-23). As the Facility will be located on the same land analyzed in the EIR, the Facility does not change the project described in the EIR.
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 41 May 2023
VI. Energy
Energy Checklist Questions
VI. Energy.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Result in
potentially
significant
environmental
impact due to
wasteful,
inefficient, or
unnecessary
consumption of
energy
resources,
during project
construction or
operation?
NA No No No No
b) Conflict with
or obstruct a
state or local
plan for
renewable
energy or
energy
efficiency?
NA No No No No
Energy is a new CEQA Environmental Checklist resource area established in 2019 so this resource area was not previously part of the EIR. Each local land use agency determines its own significance thresholds, and the City of Riverbank has yet to establish specific numeric criteria related to energy resources. As such, the CEQA Guidelines Appendix G Environmental Checklist Form is a primary resource in determining significance to be used for projects within the City’s jurisdiction. The following section presents other applicable federal, state and local regulations and agency guidance connected to energy resources.
Federal Regulations
Corporate Average Fuel Standards
First enacted by the U.S. Congress in 1975, the Corporate Average Fuel Economy (CAFE) standards reduce energy consumption by increasing the fuel economy of cars and light trucks. The National Highway Traffic Safety Administration (NHTSA) and United States Environmental Protection Agency (USEPA) jointly administer the CAFE standards. The U.S. Congress has specified that CAFE standards must be set at the “maximum Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 42 May 2023
feasible level” with consideration given for: 1) technological feasibility; 2) economic practicality; 3) effect of other standards on fuel economy; and 4) need for the nation to conserve energy.
Fuel efficiency standards for medium- and heavy-duty trucks have been jointly developed by USEPA and NHTSA. The Phase 1 heavy-duty truck standards apply to combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles for model years 2014 through 2018, and result in a reduction in fuel consumption from 6 to 23 percent over the 2010 baseline, depending on the vehicle type. USEPA and NHTSA have also adopted the Phase 2 heavy-duty truck standards, which cover model years 2021 through 2027 and require the phase-in of a 5 to 25 percent reduction in fuel consumption over the 2017 baseline depending on the compliance year and vehicle type (USEPA and NHTSA, 2016).
Energy Policy Act of 2005
The Energy Policy Act of 2005 addresses energy efficiency; renewable energy requirements; oil, natural gas and coal; alternative-fuel use; tribal energy, nuclear security; vehicles and vehicle fuels; hydropower and geothermal energy; and climate change technology. The act provides revised annual energy reduction goals (two percent per year beginning in 2006), revised renewable energy purchase goals, federal procurement of Energy Star or Federal Energy Management Program designated products, federal green building standards, and fuel cell vehicle and hydrogen energy system research and demonstration.
State Regulations
Assembly Bill 1575 (AB 1575)
In 1975, largely in response to the oil crisis of the 1970s, the California State Legislature adopted Assembly Bill (AB) 1575, which created the California Energy Commission (CEC). The statutory mission of the CEC is to forecast future energy needs, license thermal power plants of 50 megawatts or larger, develop energy technologies and renewable energy resources, plan for and direct state responses to energy emergencies, and, perhaps most importantly, promote energy efficiency through the adoption and enforcement of appliance and building energy efficiency standards. AB 1575 also amended Public Resources Code Section 21100(b)(3) to require Environmental Impact Reports (EIRs) to consider the wasteful, inefficient, and unnecessary consumption of energy resources caused by a project. Since the passage of AB 1575, the California Natural Resources Agency finalized updates to the CEQA Guidelines in December 2018. New CEQA Guidelines Section 15126.2(b) treats “wasteful, inefficient, or unnecessary” energy consumption as a significant environmental impact. As a result, the following energy thresholds have been incorporated into Appendix G of the CEQA Guidelines:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation? b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? As discussed above, this section has been prepared to assess energy impacts in accordance with the CEQA Appendix G of criteria specific to energy resources.
Senate Bill 1389
Senate Bill (SB) 1389 (Public Resources Code Sections 25300–25323; SB 1389) requires the CEC to prepare a biennial integrated energy policy report that assesses major energy trends and issues facing the state’s electricity, natural gas, and transportation fuel sectors and provides policy recommendations to conserve resources; protect the environment; ensure reliable, secure, and diverse energy supplies; enhance the state’s economy; and protect public health and safety (Public Resources Code Section 25301[a]). The most recent 2020 Integrated Energy Policy Report (the 2021 Report remains in draft form pending finalization by the CEC) provides the results of the CEC’s assessments of a variety of energy issues facing California, including energy Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 43 May 2023
efficiency, California’s transition to zero-emission vehicles (ZEVs), transportation, microgrids, and repercussions of several recent events including the COVID-19 pandemic, electricity outages, and statewide wildfires. The 2020 Report also provides updates on trends in California’s sources of crude oil, update on California’s nuclear plants, and other energy issues.
Senate Bill 350
SB 350 was approved on October 7, 2015. SB 350 will: 1) increase the standards of the California Renewables Portfolio Standard (RPS) program by requiring that the amount of electricity generated and sold to retail customers per year from eligible renewable energy resources be increased to 50 percent by December 31, 2030; 2) require the State Energy Resources Conservation and Development Commission to establish annual targets for statewide energy efficiency savings and demand reduction that will achieve a cumulative doubling of statewide energy efficiency savings in electricity and natural gas final end uses of retail customers by January 1, 2030; 3) provide for the evolution of the Independent System Operator into a regional organization; and 4) require the state to reimburse local agencies and school districts for certain costs mandated by the state through procedures established by statutory provisions. Among other objectives, the State legislature intends to double the energy efficiency savings in electricity and natural gas final end uses of retail customers through energy efficiency and conservation.
Local Regulations
City of Riverbank General Plan
The City of Riverbank’s General Plan (April 2009) addresses energy in its design, conservation and open space, public services & facilities, and air quality sections. While the majority of the General Plan policies related to energy are general in nature and not specific, the following goals and policies are potentially applicable to the project:
► Goal DESIGN-18: Renewable Resource Use and Energy-Efficiency In Site and Architectural Design • Policy DESIGN-18.2: The City will encourage passive and natural lighting systems in architectural design to conserve electricity.
► Goal CONS-8: Minimize the Use of Energy through Sustainable Development Patterns, Construction Practices, and Construction Materials
• Policy CONS-8.2: The City will encourage material and energy-efficient building design, including strategies certified by the U.S. Green Building Council’s Leadership in Energy and Environmental Design (LEED) Program.
• Policy CONS-8.3: The City will encourage the incorporation of energy conservation features in the design of all new construction and the installation of conservation devices in existing development. ► Goal PUBLIC-6: Adequate Public Utilities, Including Gas, Electric, Telecommunications and Other Utility Services
• Policy PUBLIC-6.3: The City will require the demonstration of adequate energy supply through a willserve letter from the appropriate energy service provider prior to approval of new or expanded structures that have the potential for significant energy use. • Policy PUBLIC-6.4: The City will require that gas, electrical, and communications lines be installed underground as a part of new development, wherever possible. • Policy PUBLIC-6.5: New development projects shall include landscaping methods, materials, and design to conserve energy and water.
► Goal AIR-2: Construction Practices and Materials Used in Riverbank Minimize Direct and Indirect Air Pollutant Emissions
• Policy AIR-2.5: The City of Riverbank will require new residential, commercial, and industrial development to reduce air quality impacts from area sources and from energy consumption.
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 44 May 2023
Facility Operations Energy Consumption
The Facility’s energy consumption is evaluated based on the following three (3) sources: fuel use from associated diesel and gasoline vehicle activity (i.e., transportation sources), natural gas usage, and electricity consumption. As discussed, operations of the Carbon Zero 1 Project Facility’s will consume energy resources that are quantified and evaluated in this section.
The primary sources of the Facility operations’ fuel energy consumption (diesel and gasoline) would come from on-road vehicular traffic (i.e., delivery trucks, rail, passenger vehicles) during operations, and equipment used during fuel production (e.g., boilers, heaters). Construction is not included in the energy consumption analysis as the construction activities will be temporarily occurring over a short period of time. Within the CalEEMod model run, which forms the basis of this energy analysis, default values were used to quantify the associated trip lengths for the various trip types, among other parameters described in the appendices of the CalEEMod User Guide.
The operations on‐road operational vehicle trip fuel usage is calculated using the default vehicle trip distance/distribution from the CalEEMod model run for each trip type. Using this data, along with the fleet average miles per gallon rates, Table 8 presents the annual fuel usage resulting from on-road vehicles activity during the operations of the Facility. The truck trip lengths are from the actual travel distances between Riverbank and the Port of Oakland for inbound truck trips delivering feed stock and other materials, and between Riverbank and San Francisco Airport (SFO) for outbound truck trips distributing RD and SAF finished products.
Table 8 Operations Worst-Case Vehicle Annual Fuel Usage – All Trucks Activity Daily Round
Trips
One Way Trip
Length (mi)
Daily VMT Annual
VMT
Annual Fuel
Usage (gal)
Inbound Truck
Trips
Outbound
Truck Trips
89 75
86 96
15,308
14,400
3,980,080
3,744,000
612,320
576,000
Employee Trips 50 16.8 1,680 613,200 27,873
Total Summary 28,160 7,498,076 1,216,193
a. Truck average miles per gallon rates from “A Survey of Fuel Economy and Fuel Usage by Heavy Duty Truck Fleets” by Schoettle et. al (2016).
b. Passenger vehicle miles per gallon rates from US Bureau of Transportation Statistics (2019).
As discussed in the Project Description, Traffic Summary, Facility operations could also include use of rail for receiving feed stock and distributing the finished product. This would reduce the number of truck trips and therefore the annual VMT and annual fuel usage. Table 9 presents the annual fuel usage resulting from a mix of rail and trucks activity during the Facility’s operations phase using this data, along with the average miles per gallon rates for rail.
The Facility’s rail operational fuel usage is based on the off-site distance and onsite circulation distance of 33 rail cars per day split between 16 inbound rail cars (with one locomotive) delivering feed stock and 17 outbound rail cars (with one locomotive) distributing finished product to SFO. The off-site rail trip lengths are from the actual travel distances between Riverbank and the Port of Oakland for inbound rail cars delivering feed stock, and between Riverbank and SFO for outbound rail car trips distributing RD and SAF finished products to SFO. Although there are 16 to 17 rail cars per delivery, each delivery represents one locomotive Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 45 May 2023
and therefore fuel usage estimates are based on the number of locomotives. The onsite circulation distance is estimated to be 0.5 miles.
Table 9 Operations Rail and Truck Annual Fuel Usage
Activity Daily Round
Trips
One Way Trip
Length (mi)
Daily VMT Annual VMT Annual Fuel
Usage (gal)
Inbound Truck
Trips
2 86 384 99,916 15,372
Outbound
Truck Trips
4 96 768 199,680 30,720
Employee Trips 50 16.8 1,680 613,200 27,873
Onsite Rail
Circulation
2 0.5 1 260 1,857
Inbound Rail
Off-site
1 86 86 22,360 159,714
Outbound Rail
Off-site
1 96 96 24,960 178,286
Total Summary 3,015 960,376 413,821
a. Rail miles per gallon rates from US Bureau of Transportation Statistics (2019). The fuel consumption rate for off-site travel and onsite circulation was assumed to be the same.
Additional sources of energy consumption include electricity and natural gas, as presented in Table 10. The natural gas and electricity usage for fuel production are estimated based on the Facility’s engineering design data.
Table 10 Operations Gas and Electricity Usage
Utility Usage Source Annual Usage Estimates
Natural Gas 3.29 mmscf/day PG&E 1,200mmscf
Electricity 15 MW SFPUC and PG&E 131,400 MWh
a. Natural gas and electricity usage from administrative buildings, sanitary systems, parking lots, and warehouses is assumed to be de minimis.
Checklist question VIa: As discussed above, energy use associated with the Facility would be consumed in the form of fuel (diesel and gasoline), electricity, and natural gas.
The equipment and vehicles used by workers and vendors would be subject to increasingly stringent federal and state fuel efficiency standards, which would minimize the potential for inefficient fuel usage. The Facility would be required to comply with the provisions of 13 CCR Sections 2449 and 2485, which prohibit dieselfueled commercial motor vehicles and off-road diesel vehicles from idling for more than five minutes. Heavy equipment would also be subject to the USEPA Construction Equipment Fuel Efficiency Standard (40 Code of Federal Regulations Parts 1039, 1065, and 1068) and CARB’s Assembly Bill (AB) 1493 (i.e., Pavley) regulations, which would also minimize inefficient fuel consumption and ensure that the fuel efficiency of equipment and vehicles operating on- and off-site would continue to improve over time. The Facility will also be constructed consistent with applicable CALGreen Building Code and Title 24 which would also reduce consumption from area and energy sources. Compliance with applicable state and local requirements as described above will Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 46 May 2023
ensure that the Facility does not result in wasteful, inefficient, or unnecessary consumption of energy resources.
Compliance with local, state, and federal regulations would reduce short-term energy demand during the Facility construction to the extent feasible, and therefore, construction would not result in a wasteful or inefficient use of energy. The Facility operations will also use energy resources and for on-road vehicles. As shown in Table 9, the Facility’s operational worst-case fuel resource consumption is estimated to be 27,873 gallons per year of gasoline for employee vehicles and 1,188,320 gallons of diesel for truck deliveries. The CEC’s Retail Fuel Outlet Annual Reporting (A-15) Results show that approximately 39 million gallons of diesel and 197 million gallons of gasoline was sold in Stanislaus County in 2020. The Facility operations would represent 3 percent of total annual diesel fuel consumption and 0.014 percent of total annual gasoline fuel consumption from 2020 within the County.
Similarly, as shown in Table 10, the Facility operational electricity and natural gas consumption is estimated to be 131,400 MWh and 1,200.85 mmscf per year respectively. Per the CEC’s most recent energy report, specifically the most recent “Electricity Consumption by County” and “Natural Gas Consumption by County” 2020 data sets for Stanislaus, non-residential sector operations consumed an estimated 3 billion kWh and 136 million therms (approximately 13,000 mmscf) total in 2020. Compared to the CEC’s 2020 County-wide data set, the Facility’s estimated increase in electricity and natural gas consumption would constitute approximate
4.3 percent and 9.08 percent, respectively, of total annual 2020 consumption within the County. Because the Facility is creating new supplies of RD and SAF, these activities would not have a substantial effect on the local and regional fuel energy supplies and availability. Furthermore, General Plan policies PUBLIC-6.3 and PUBLIC-6.5 would ensure that the Facility has adequate energy supply and implements energy efficient design as applicable. As discussed in the Project Description, Aemetis has obtained a will-serve letter from Pacific Gas & Electric per Policy PUBLIC-6.3 to ensure adequate fuel supplies and availability.
For these reasons, the construction and operation of Facility will not result in wasteful, inefficient, or unnecessary consumption of energy resources and therefore, the potential impacts to energy resources will be less than significant. Section 6 of the EIR acknowledges that development of the Plan will require nonrenewable resources and states that commitment of nonrenewable resources such as electric and gas service would not be large due to inclusion of energy-conserving Plan features, compliance with applicable standards and regulations, and implementation of mitigation measures.
Checklist question VIb: As discussed above, the City of Riverbank has not yet set a specific threshold of significance for energy impacts. At this time, other than the generalized policies found within the General Plan, the City has not adopted local programs or policies that support energy efficiency and/or sustainability that would apply to the Facility. In accordance with the City’s General Plan goals and policies, the Facility would implement energy efficiency and conservation measures as applicable.
The State of California’s Energy Efficiency Strategic Plan (adopted 2008, updated January 2011) outlines specific goals and strategies to help promote energy efficiency in California’s industrial sector in three (3) areas: 1) Support industry adoption of energy efficiency by integrating energy efficiency savings with achievement of GHG goals; 2) Build market value of and demand for energy efficiency; and 3) Provide technical and public policy guidance for resource efficiency. The Energy Efficiency Strategic Plan promotes reductions in energy consumption through compliance with greenhouse gas (GHG) emission reductions, water conservation, and proper waste disposal.
The anticipated mobile equipment and vehicles would comply with federal, state, and regional efficiency requirements where applicable. Specifically, the USEPA and the NHTSA have adopted fuel efficiency standards Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 47 May 2023
for medium- and heavy-duty trucks which apply to truck fleet operators, such as the applicant. CARB has also adopted cleaner technology and fuel standards pursuant to AB 1493. While Phase 1 and Phase 2 regulation published by both the USEPA/NHTSA and CARB primarily apply to manufacturers of on-road vehicles and not the end user, the Facility operator and off-site vendors will ensure engines purchased are certified in accordance with the appropriate state and federal regulations. Due to federal and state standards, energy efficiency of mobile equipment and vehicles will continue to improve over time through compliance with increasingly stringent standards adopted by regulatory agencies.
The primary purpose of the Facility is to produce low carbon RD and SAF. This will advance local and state plans for increasing renewable energy and energy efficiency. The Facility’s construction and operations activities would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
Therefore, the proposed Facility’s impacts are less than significant.
VII. Geology and Soils
Geology and Soils Checklist Questions
VII. Geology and
Soils.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Directly or
indirectly cause
potential
substantial adverse
effects, including
the risk of loss,
injury or death
involving:
DEIR pp. 4.6-1
to 4.6-20
No No No No
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Aemetis Carbon Zero 1 Project 48 May 2023
VII. Geology and
Soils.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
i) Rupture of a
known earthquake
fault, as delineated
on the most recent
Alquist-Priolo
Earthquake Fault
Zoning Map issued
by the State
Geologist for the
area or based on
other substantial
evidence of a
known fault? Refer
to Division of Mines
and Geology
Special
Publication 42.
DEIR pp. 4.6-1
to 4.6-20
No No No No
ii) Strong seismic
ground shaking?
DEIR pp. 4.6-1
to 4.6-20
No No No No
iii) Seismic-related
ground failure,
including
liquefaction?
DEIR pp. 4.6-1
to 4.6-20
No No No No
iv) Landslides? DEIR pp. 4.6-1
to 4.6-20
No No No No
b) Result in
substantial soil
erosion or the loss
of topsoil?
DEIR pp. 4.6-1
to 4.6-20
No No No No
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Aemetis Carbon Zero 1 Project 49 May 2023
VII. Geology and
Soils.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
c) Be located on a
geologic unit or soil
that is unstable, or
that would become
unstable as a result
of the project, and
potentially result in
on- or off-site
landslide, lateral
spreading,
subsidence,
liquefaction or
collapse?
DEIR pp. 4.6-1
to 4.6-20
No No No No
d) Be located on
expansive soil, as
defined in Table
18-1-B of the
Uniform Building
Code (1994),
creating substantial
risks to life or
property?
DEIR pp. 4.6-1
to 4.6-20
No No No No
e) Have soils
incapable of
adequately
supporting the use
of septic tanks or
alternative
wastewater
disposal systems
where sewers are
not available for
the disposal of
waste water?
DEIR pp. 4.6-1
to 4.6-20
No No No No
f) Directly or
indirectly destroy a
unique
paleontological
resource or site or
unique geologic
feature?
DEIR pp. 4.5-1
to 4.5-24 and
pp. 4.6-1 to 4.6-
20 No No No No
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 50 May 2023
Checklist question VIIa:
(i) Rupture of a Known Earthquake Fault - As stated in the EIR, “the RAAP is not located within an AlquistPriolo Earthquake Fault Zone and is not located on an active fault as designated by the California Geological Survey (CGS). The Specific Plan Area is located more than 70 miles to the east of both the San Andreas and Hayward Faults, the two most prominent fault lines in the region, and approximately 37 miles northeast of the Ortigalita Fault. Therefore, the Specific Plan area is not considered susceptible to the risk of loss, damage, or death involving fault rupture. Associated potential impacts would be less than significant” (DEIR 4.6-16).
Because the Facility will be located on the same land, the same determination applies and there are no changes to the project described in the EIR.
(ii) Strong Seismic Ground Shaking - The Specific Plan determines that impacts to seismic ground shaking are less than significant. Seismic ground shaking is possible at the site in the event of a major earthquake, but the Facility will be required to comply with the guidelines of the California Building Code and the Riverbank Municipal Code that pertain to building safety, as described in the EIR. The Facility will be located on the same land; therefore, there are no changes to the project described in the EIR. (iii) Liquefaction - As stated in the Specific Plan, “Alluvial soils in the Plan Area can potentially become saturated when the groundwater table is high, which increases their susceptibility to liquefaction during a seismic event. However, the California Building Code, applicable in Riverbank pursuant to General Plan Policy SAFE-1.2, establishes standards for seismic design, foundations, and drainage. Continued implementation of this policy and compliance with State of California uniform codes would ensure that the risk of loss, damage, or death from seismic related ground failure is less than significant” (DEIR 4.6-17). The Facility will comply with these existing standards described in the Specific Plan that pertain to seismic-related ground failure, including liquefaction. Because the Facility will be located on the land analyzed in the EIR, there is no change to the project described in the EIR.
(iv) Landslide - As stated in the Specific Plan, “The terrain of the Plan Area slopes to the southwest at a rate of 25 feet per mile, and given this relatively flat topography, there would be no impact associated with landslides and slope instability” (DEIR 4.6-17). Because the Facility will be located on the same land analyzed in the EIR, there is no change to the project described in the EIR.
Checklist question VIIb: The Specific Plan discusses the effect that building activity on the site could have on erosion; however, all construction activities must be compliant with Building Code Provisions in order to minimize erosion. The Specific Plan also discusses construction activities creating new impervious areas, which may increase stormwater runoff, and therefore erosion. The Specific Plan also described General Plan Policy PUB-23 (Riverbank GP policy PUB-23, DEIR 4.6-18) which is intended to promote “green” infrastructure where possible. The EIR determines that, with these standards in mind, the impact on this category is less than significant. The Facility is located on the same land and is located in an area of the Specific Plan already designated for construction and evaluated as if covered with hard surfaces in the EIR. Therefore, the Facility does not change the project described in the EIR.
Checklist question VIIc: As stated in the DEIR, “Land subsidence is not characteristic of soils in Riverbank and the Plan Area.” (DEIR 4.6-18). The EIR concludes development on the RAAP site would have a less-thansignificant impact related to geologically unstable soils. The Facility is located on the same property analyzed in the EIR so will result in no changes to the project described in the EIR.
Checklist question VIId: The EIR determines there will be a less than significant impacts due to expansive soils because of the city’s preexisting regulations. Although there are soils onsite with expansive Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 51 May 2023
characteristics, there are rules and regulations in place (Title XV, Chapter 155 in the Riverbank Municipal Code and General Plan Policies SAFE-1.2, SAFE-1.11, and SAFE-1.12) that apply to development at the RAAP site on site throughout construction. Since the Facility is located on the same land analyzed in the EIR and the Facility will be subject to the City’s Municipal Code and General Plan policies, there is no change to the project described in the EIR.
Checklist question VIIe: Because “the site is served by the City of Riverbank Public Works Department Sewer Division and its wastewater facilities” (DEIR 4.6-19), the EIR determines there will be no impact to soils from sanitary waste disposal caused by development of the RAAP site. The Facility will also use the existing sanitary sewer as well as manage its own industrial wastewater onsite, so it does not change the project described in the EIR.
Checklist question VIIf: The Specific Plan describes existing General Plan policies protecting paleontological resources (Riverbank GP policy CONS-2.1, DEIR 4.5-22), and determines that “there are no known paleontological resources in the RAAP Site and a records search of files at the CCIC indicated there are no recorded prehistoric cultural resources in Riverbank” (DEIR 4.5-22). For this reason, the EIR determines that the Specific Plan would have a less than significant impact on paleontological resources or geologic features.
This analysis was conducted for the same land on which the Facility will be located; therefore, the Facility does not change the project analyzed in the EIR.
VIII. Greenhouse Gas Emissions
Greenhouse Gas Emissions Checklist Questions
VIII.
Greenhouse
Gas
Emissions.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Generate
greenhouse gas
emissions,
either directly
or indirectly,
that may have
a significant
impact on the
environment?
DEIR pp. 4.7-1
to 4.7-18
No No No FEIR Mitigation
Measure GHG-1
(FEIR 2-10;
MMRP p. 8)
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 52 May 2023
VIII.
Greenhouse
Gas
Emissions.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
b) Conflict with
an applicable
plan, policy or
regulation
adopted for the
purpose of
reducing the
emissions of
greenhouse
gases?
DEIR pp. 4.7-1
to 4.7-18
No No No No
Appendix B includes a Greenhouse Gas (GHG) technical memo prepared by GeoSyntec which presents GHG emissions estimates for construction and operations for the Facility.
Checklist question VIIIa: The EIR states that emissions of greenhouse gases would be considered significant if the projects implementing the Specific Plan do not adhere to Best Performance Standards (BPS) established by the San Joaquin Valley Air Pollution Control District or, if this is not possible, do not achieve a 29% GHG emission reduction compared to Business as Usual (BAU) (based on the GHG emission reduction targets established in the California Air Resources Board’s AB 32 Scoping Plan). The EIR determines that greenhouse gas emissions from implementing the Specific Plan will be significant and unavoidable, either because they could not be accurately predicted at the time of the EIR, or because they do not reflect sufficient reductions from BAU. Due to this finding of significance, the City adopted mitigation measure GHG-1 to require individual projects to “document, to the City’s reasonable satisfaction, its compliance with this mitigation measure” (FEIR 2-10) requiring implementation of BPS or a 29% reduction in GHGs compared to BAU “prior to issuance of building permits” for the project (see MMRP, p.8).
The EIR determines that individual projects could increase emissions of GHG that would be significant without mitigation, and subjects them to a mitigation measure to be implemented when the city issues building permits. Therefore, any individual project at the RAAP site that would have increased GHG emissions is consistent with the project described in the EIR and does not represent a change or a new impact.
More importantly, the Facility is designed for the purpose of producing a transportation fuel with a low carbon intensity that will help California meet its Low Carbon Fuel Standard (LCFS) for transportation fuels and meet greenhouse gas emission reduction targets, including the 29% reduction target. As discussed above, the LCFS program calculates the average CI of all transportation fuels used in the State and requires the average CI to achieve a certain reduction below baseline fuels. Fuels with a CI lower than the state requirement level help the state meet it CI target. The CI of a fuel is calculated based on “lifecycle” emissions, which include all GHG emissions associated with a fuel, including emissions from feedstock production, transportation, the plant production process, and the use of the fuel. Therefore, a fuel with a low CI necessarily reduces overall Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 53 May 2023
greenhouse gas emissions. Therefore, the Facility does not represent a change from the project described in the EIR.
Checklist question VIIIb: All future projects, including the Facility, in the Specific Plan Area are “subject to any new requirements under rule making developed at the State and local level regarding GHG emissions and will be subject to local policies that may affect emissions of GHGs” (DEIR 4.7-17). The Facility does not represent a change in the project described in the EIR with respect to this standard.
IX. Hazards & Hazardous Materials
Hazards & Hazardous Materials Checklist Questions
IX. Hazards &
Hazardous
Materials.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Create a
significant hazard
to the public or the
environment
through the routine
transport, use, or
disposal of
hazardous
materials?
DEIR pp. 4.9-1
to 4.9-18
No No No No
b) Create a
significant hazard
to the public or the
environment
through reasonably
foreseeable upset
and accident
conditions
involving the
release of
hazardous
materials into the
environment?
DEIR pp. 4.9-1
to 4.9-18
No No No No
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 54 May 2023
IX. Hazards &
Hazardous
Materials.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
c) Emit hazardous
emissions or
handle hazardous
or acutely
hazardous
materials,
substances, or
waste within onequarter mile of an
existing or
proposed school?
DEIR pp. 4.9-1
to 4.9-18
No No No No
d) Be located on a
site which is
included on a list
of hazardous
materials sites
compiled pursuant
to Government
Code Section
65962.5 and, as a
result, would it
create a significant
hazard to the
public or the
environment?
DEIR pp. 4.9-1
to 4.9-18
No No No No
e) For a project
located within an
airport land use
plan or, where
such a plan has not
been adopted,
within two miles of
a public airport or
public use airport,
would the project
result in a safety
hazard for people
residing or working
in the project area?
DEIR pp. 4.9-1
to 4.9-18
No No No No
Riverbank Industrial Complex CEQA Addendum
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IX. Hazards &
Hazardous
Materials.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
f) Impair
implementation of
or physically
interfere with an
adopted
emergency
response plan or
emergency
evacuation plan?
DEIR pp. 4.9-1
to 4.9-18
No No No No
g) Expose people
or structures to a
significant risk of
loss, injury or
death involving
wildland fires?
DEIR pp. 4.9-1
to 4.9-18
No No No No
The Facility will use hazardous materials to support the production of RD and SAF, such as sodium hydroxide, sulfiding agent, hydrochloric acid, and ammonia (refer to Project Description). The Facility will also produce wastes that may be hazardous such as sludge from wastewater treatment, spent clay, and waste oils.
Hazardous materials and hazardous wastes will be transported, managed, and stored according to the applicable regulations and General Plan policies. The management of these hazardous materials as inputs or as hazardous wastes are governed by the Certified Unified Program Agency (CUPA) program, the California Accidental Release Prevention Program, and the Spill Prevention, Control, and Countermeasure (SPCC) Program.
Checklist question IXa: The EIR states that development of the RAAP site will increase the use of hazardous materials used and wastes generated at the RAAP set (DEIR 4.9-13). The EIR describes existing guidelines that ensure safe handling according to local, state, and federal safety standards of hazardous materials that will apply to all projects onsite and describes existing General Plan Policies that contain additional safety standards (Riverbank GP policy SAFE-1.8 and SAFE-1.10, DEIR 4.9-14). The EIR determines that the impact of RAAP site development that increases the presence of hazardous materials that is in compliance with applicable safety standards will be less than significant. The Facility is consistent with the project and activities in the Specific Plan and therefore does not represent a change.
Checklist question IXb: The EIR states that development in the Specific Plan area could increase the amount of accidents involving hazardous materials (DEIR 4.9-14). It also states that existing and future projects on the RAAP site would be required to comply with federal, State, and local regulations regarding the handling, disposal, and clean-up of hazardous materials” (DEIR 4.9-14) as well as General Plan Policies CONS6.2, SAFE-1.8, SAFE-1.9, and SAFE-1.10 (Riverbank GP policy CONS-6.2, SAFE-1.8, 1.9 and 1.10, DEIR 4.9- Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 56 May 2023
14), and determines that the impacts of the anticipated industrial development under this standard will be less than significant. The Facility is consistent with the project analyzed in the EIR.
Checklist question IXc: The EIR states that there are no existing or proposed schools within one-quarter mile of the RAAP site (DEIR 4.9-15), so there is no impact under this standard. The Facility will be located within the same land analyzed in the EIR, so it does not change the project analyzed in the EIR.
Checklist question IXd: The RAAP site contains known hazardous materials sites that “are either monitored and/or under active remediation by government agencies, or remediation activities have been completed” (DEIR 4.9-15). The EIR also analyzes hazardous materials such as asbestos in existing buildings at the RAAP.
The EIR states that the Specific Plan includes a stipulation that any such materials will be “fully disclosed, analyzed, and mitigated” (DEIR 4.9-16) according to General Plan policy SAFE-1.10, which requires the City to review all development plans on a project-by project basis and set appropriate restrictions pertaining to hazardous materials. After a full analysis of the existing conditions and the planned development, the EIR determines that impacts under this standard are less than significant. Because the Facility would be consistent with the development and standards reviewed in the EIR, it does not represent a change from the project described in the EIR.
Checklist question IXe: As stated in the DEIR, “the RAAP site is located approximately 1.2 miles from the Peterson Airport, a privately owned airport located at 5800 Langworth Road. The RAAP site is not located within an established land use plan for an airport, nor is it located within close proximity to the runway. As result, the conflicts between aircraft and people and structures on the ground would not result in safety hazards” (DEIR 4.9-17). The EIR determines the impact under this standard to be less than significant. As the Facility will be located on this same land, it does not represent a change from the project described in the EIR.
Checklist question IXf: The DEIR identifies the emergency plan for the failure of the New Melones Dam as the only emergency response/evacuation plan relevant to the RAAP site. This plan includes the following: “If failure of the New Melones Dam were to occur, the City of Riverbank evacuation routes would be to the southeast toward higher ground, with the primary evacuation routes along Terminal/Santa Fe and Claus Road towards Empire and Waterford. Although the RAAP Specific Plan proposes to modify the visual character of Claus Road, vehicle travel would not be hindered or obstructed, and would not impair implementation of or physically interfere with the Stanislaus County Multi-Jurisdictional Hazard Mitigation Plan (MJHMP). As a result, a less-than-significant impact would occur” (DEIR 4.9-17). The Facility will not alter or obstruct vehicle traffic on Claus Road, so it does not represent a change to the project described in the EIR.
Checklist question IXg: The DEIR states that no areas within the site are defined as “Very High Fire Hazard Severity” (DEIR 4.9-18) for wildland fires, and all new development would comply as required by law with California Building Code, California Fire Code, and any other applicable state and local fire safety requirements.
Because of these factors, the EIR determines that impact of buildout of the Specific Plan under this standard is less than significant. The Facility is located within the plan area evaluated for development and does not represent a change to the project described in the EIR.
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 57 May 2023
X. Hydrology / Water Quality
Hydrology / Water Quality Checklist Questions
X. Hydrology /
Water Quality.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Violate any
water quality
standards or waste
discharge
requirements or
otherwise
substantially
degrade surface or
groundwater
quality?
DEIR pp. 4.10-1
to 4.10-14
No No No No
b) Substantially
decrease
groundwater
supplies or
interfere
substantially with
groundwater
recharge such that
the project may
impede sustainable
groundwater
management of
the basin?
DEIR pp. 4.10-1
to 4.10-14
No No No No
c) Substantially
alter the existing
drainage pattern of
the site or area,
including through
the alteration of
the course of a
stream or river or
through the
addition of
impervious
surfaces, in a
manner which
would:
DEIR pp. 4.10-1
to 4.10-14
No No No No
Riverbank Industrial Complex CEQA Addendum
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X. Hydrology /
Water Quality.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
i) result in
substantial erosion
or siltation on- or
off-site;
DEIR pp. 4.10-1
to 4.10-14
No No No No
ii) substantially
increase the rate
or amount of
surface runoff in a
manner which
would result in
flooding on- or
offsite;
DEIR pp. 4.10-1
to 4.10-14
No No No No
iii) create or
contribute runoff
water which would
exceed the
capacity of existing
or planned
stormwater
drainage systems
or provide
substantial
additional sources
of polluted runoff;
or
DEIR pp. 4.10-1
to 4.10-14
No No No No
iv) impede or
redirect flood
flows?
DEIR pp. 4.10-1
to 4.10-14
No No No No
d) In flood hazard,
tsunami, or seiche
zones, risk release
of pollutants due to
project inundation?
DEIR pp. 4.10-1
to 4.10-14
No No No No
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 59 May 2023
X. Hydrology /
Water Quality.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
e) Conflict with or
obstruct
implementation of
a water quality
control plan or
sustainable
groundwater
management plan?
DEIR pp. 4.17-
12-4.17-25
No No No No
As described in the Project Description, the Facility includes a wastewater treatment system designed for zeroliquid discharge. All wastewater will be treated onsite and reused as process water. Any additional water needs will be supplied by onsite wells. The Facility will require 300 gpm of water supply, and approximately 60 gpm estimated to be supplied by treated wastewater. The Facility’s stormwater will be retained in a new stormwater retention pond located to the east of the existing stormwater ponds located on Parcel B of the RAAP site and will be recycled for reuse onsite.
Checklist question Xa: As stated in the EIR, “for all future projects in the Plan Area before the approval of grading permits, a project applicant would be required to consult with the City, the State Water Resources Control Board (SWRCB), and the Central Valley Regional Water Quality Control Board (RWQCB) to acquire the appropriate regulatory approvals that may be necessary to obtain Section 401 water quality certification, an SWRCB statewide NPDES stormwater permit for general construction activity, and any other necessary sitespecific Waste Discharge Requirements (WDRs) or waivers under the Porter-Cologne Act” (DEIR 4.10-9). The impact under this standard is determined to be less than significant in the EIR. The Facility will not include any direct discharges to water bodies, as stormwater and process wastewater will be retained and treated onsite, and sanitary wastewater will be discharged to the City sewer system. In addition, the Facility would be required to comply with applicable water quality standards and/or waste discharge requirements, if any are applicable, and so it does not represent any changes to the project described in the EIR.
Checklist question Xb: A water survey conducted for the EIR determines that there is sufficient groundwater to serve future development at the RIC, which is expected to continue sourcing its water from onsite wells. Additionally, the DEIR states that “the Urban Water Management Plan (UWMP) determined that sufficient groundwater supply is available to supply future growth within the City, including the Plan Area”.
The UWMP did not evaluate the use of RIC wells, but growth in the Plan Area was assumed when evaluating projected water demand. As described in the EIR, all future developments will rely on onsite wells and on the City of Riverbank’s Water Division for its water needs. If a development proposal were to exceed the capacity of the RIC wells, the UWMP states that the City will be able to supply enough water in the Plan Area. The City of Riverbank’s water is supplied from wells located throughout the City. These wells are monitored and maintained by the City. The EIR determines the impact to groundwater resources due to the City’s availability of groundwater supply and availability of water from onsite wells to be less than significant. Because the Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 60 May 2023
Facility will source its water from RIC wells as described in the EIR and will be required to follow city water use policies, it does not change the project described in the EIR.
Checklist question Xc: The RAAP Site is generally level and does not contain river or stream beds. The EIR determines that impacts under this standard generally from build out of the entire Specific Plan, including both the open areas and the currently industrialized areas, will be less than significant, principally due to the topography of the site as well as existing regulatory standards and approval requirements applicable to all development imposed by the City, the SWRCB, and the Central Valley RWQCB. The Facility will include the construction of a new stormwater retention pond to capture all stormwater onsite. The Facility will be located within the area already analyzed in the EIR, so it does not represent a change to the project described in the EIR. There would be no change in on- or offsite erosion, surface runoff, exceed the capacity of (existing and proposed) stormwater drainage systems, or in flood flows from the project evaluated in the EIR.
Checklist question Xd: According to the EIR, “the RAAP site is not located within the 100-year floodplain” (DEIR 4.10-12) and is therefore very unlikely to be impacted by a flood. The EIR also analyzes the potential failure of the New Melones Dam, stating that it “would result in the inundation of the City of Riverbank [and] property damage”, but concludes that the risk of a dam failure is small. The EIR also analyzes risk of tsunamis or seiche stating that “the RAAP site is not located adjacent to a large body of water that would result in a risk of tsunamis or seiche. Furthermore, given the RAAP site’s flat topography, mudflows could not occur” (DEIR 4.10-13). Therefore, the EIR determines that the impact under this standard is less than significant. As the Facility will be located on this same land, it does not change the project described in the EIR.
Checklist question Xe: As stated in the EIR on pages 4.17-12 through 4.17-251 and described above, all projects implemented at the RAAP site, including the Facility, will be required to comply with rules of various regulatory agencies that require valid grading and water discharge permits. Additionally, the Facility will include the construction of an additional stormwater retention pond to meet the necessary stormwater retention capacity. Therefore, the EIR determines that impacts under this standard will be less than significant.
The Facility does not represent a change from the project described in the EIR.
XI. Land Use / Planning
Land Use / Planning Checklist Questions
XI. Land Use /
Planning.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Physically
divide an
established
community?
DEIR pp. 4.11-1
to 4.11-12
No No No No
Riverbank Industrial Complex CEQA Addendum
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XI. Land Use /
Planning.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
b) Cause a
significant
environmental
impact due to a
conflict with any
land use plan,
policy, or
regulation
adopted for the
purpose of
avoiding or
mitigating an
environmental
effect?
DEIR pp. 4.11-1
to 4.11-12
No No No No
Checklist question XIa: As stated in the EIR, “the proposed Plan would involve the redevelopment of the Plan Area entirely within its current boundaries. Therefore, buildout of the Plan would not divide an established community and impacts would be less than significant” (DEIR 4.11-8). As the Facility will be located on this same area of land, it creates no changes to the project analyzed in EIR.
Checklist question XIb: The RAAP Specific Plan describes the zoning designations within the RAAP. The RAAP Specific Plan states that the zoning designations in the Specific Plan supersede the zoning designations in the General Plan and the City of Riverbank Zoning Ordinance (SP page 7). For these reasons, the EIR anticipates a less than significant impact under this standard for projects consistent with the zoning.
As stated in the EIR, “the industrial uses currently on the RAAP site contrast markedly with the surrounding residential and semi-agricultural uses. While buildout of the Plan would generally represent a continuation of existing uses, the contrast of industrial activity with surrounding uses would remain” (DEIR 4.11-11). The EIR further says that “the implementation of design features” like landscaped buffers would help to create a transition between the industrial nature of the site and the uses surrounding it. For these reasons, the EIR determines that the impacts under this standard are less than significant.
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Aemetis Carbon Zero 1 Project 62 May 2023
XII. Mineral Resources
Mineral Resources Checklist Questions
XII. Mineral
Resources.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Result in the
loss of availability
of a known
mineral resource
that would be of
value to the
region and the
residents of the
state?
DEIR pp. 4.8-1
to 4.8-7
No No No No
b) Result in the
loss of availability
of a locallyimportant mineral
resource recovery
site delineated on
a local general
plan, specific plan
or other land use
plan?
DEIR pp. 4.8-1
to 4.8-7
No No No No
Checklist question XIIa: The EIR states that the RAAP site “is already largely developed and surrounded by land uses incompatible with mining activities” (DEIR 4.8-5). Given the limited mineral resources that exist at the site and in the surrounding region, it is very unlikely that any future mineral extraction would occur.
The EIR determines that the impact from buildout of project onsite is less than significant. Since the Facility will be part of the buildout described in the EIR and located on the same land, it does not represent a change to the project described in the EIR.
Checklist question XIIb: According to the EIR, there are no mines in the RAAP Site, and the site is “largely incompatible with mining activities” (DEIR 4.8-6), making any mineral extraction unlikely. Therefore, the EIR determines that the impact from development of any project onsite would be less than significant. The Facility is part of the buildout described in the Specific Plan and will be located in an area of the RAAP site that was previously evaluated for industrial/R&D development. Therefore, the Facility does not represent a change to the project described in the EIR.
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XIII. Noise
Noise Checklist Questions
XIII. Noise.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Generation of
a substantial
temporary or
permanent
increase in
ambient noise
levels in the
vicinity of the
project in excess
of standards
established in the
local general plan
or noise
ordinance, or
applicable
standards of
other agencies?
DEIR pp. 4.12-1
to 4.12-37
No No No Mitigation
Measure NOISE1 (FEIR pp 2-11
to 2-13; MMRP
pp. 8 to 9)
b) Generation of
excessive
groundborne
vibration or
groundborne
noise levels?
DEIR pp. 4.12-1
to 4.12-37
No No No No
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 64 May 2023
XIII. Noise.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
c) For a project
located within the
vicinity of a
private airstrip or
an airport land
use plan or,
where such a
plan has not
been adopted,
within two miles
of a public airport
or public use
airport, would the
project expose
people residing
or working in the
project area to
excessive noise
levels?
DEIR pp. 4.12-1
to 4.12-37
No No No Mitigation
Measures
NOISE-2, and
NOISE-4 (FEIR
pp 2-11 to 2-13;
MMRP pp. 9,
11)
Checklist question XIIIa: The EIR finds a significant impact from added noise due to site development, stating that: “The nearest residential land uses are 110 feet west of the plan area, across Claus Road. Noise levels resulting from onsite activities may exceed City standards for stationary noise sources at nearby residential receivers if the noise generated by such uses are not regulated or adequately mitigated” (DEIR
4.12-23). This represents a significant impact before mitigation. In order to mitigate this impact, the EIR includes mitigation measure NOISE-1 (RAAP Specific Plan DEIR 4.12-32), which includes measures intended to limit noise pollution at residential receptors. The Facility will be subject to these mitigation measures, and therefore does not represent a change from the project described in the EIR.
The EIR (pages 4.12-26-27) analyzes the expected increase in ambient noise from increased traffic created by the development of the RAAP site and determines that the impact would be significant. The EIR therefore includes mitigation measure NOISE-2 to require design strategies to be implemented on a project-by-project basis to address noise from transportation. Mitigation measure NOISE-4, which has the same conditions as NOISE-2, is targeted at the impact of increased traffic from development in the Specific Plan area and other parts of the City of Riverbank. Even with these mitigation measures in place, the City determined that the impacts are anticipated to be significant and unavoidable because “it may not be reasonable or feasible to reduce project-generated traffic noise at all receivers” in all areas experiencing development (DEIR 4.12-35).
The level of traffic analyzed by the EIR is higher than the volume of traffic that will be generated by the Facility. In addition, the City already determined that the overall impact of traffic from the implementation of the Specific Plan will be significant and imposed appropriate mitigation measures. Therefore, the Facility does not represent a change from the project described in the EIR.
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 65 May 2023
The EIR states that, as would be the case with any industrial construction projects, there will be noise generated during the time of construction. The EIR includes mitigation measure NOISE-3 on page 4.12-36, which outlines the most straightforward methods of reducing construction-related noise-- “limiting the hours when construction can occur to daytime hours” and “controls such as constructing temporary noise barriers and utilizing “quiet” construction equipment”. With this mitigation measure in place, the EIR anticipates a less than significant impact under this standard. The EIR already determines that construction noise could be significant and implements appropriate mitigation measures. Therefore, the Facility does not represent a change from the project described in the EIR.
Checklist question XIIIb: The EIR determines that construction activities can produce perceptible levels of vibration and ground borne noise at the site, stating that: “Construction activities may extend over several construction seasons, but construction vibration would not be substantial for most of this time except during vibration generating activities … Jackhammers typically generate vibration levels of 0.035 in/sec PPV and drilling typically generates vibration levels of 0.09 in/sec PPV at a distance of 25 feet. Vibration levels would vary depending on soil conditions, construction methods, and equipment used. Vibration levels would be expected to be 0.2 in/sec PPV or less, below the 0.3 in/sec PPV significance threshold. Vibration generated by construction activities near the common property line would at times be perceptible, however, would not be expected to result in “architectural” damage to these buildings. In areas where vibration would not be expected to cause structural damage, vibration levels may still be perceptible. However, as with any type of construction, this would be anticipated and it would not be considered significant given the intermittent and short duration of the phases that have the highest potential of producing vibration (demolition and use of jackhammers and other high-power tools). By use of administrative controls such as notifying adjacent commercial shops of scheduled construction activities and scheduling construction activities with the highest potential to produce perceptible vibration to hours with the least potential to affect these uses, perceptible vibration can be kept to a minimum and as such would not result in a significant impact with respect to perception.” Based on this analysis, the EIR determines that this impact would be less than significant. The EIR analysis already included expected typical construction noise, so the Facility does not represent a change to that project described in the EIR.
Checklist question XIIIc: The EIR states, “retail, office, and industrial uses developed at the site would be intermittently exposed to noise levels from aircraft associated with the Peterson private airport located approximately 1.5 miles east of the Specific Plan area. Because of relatively infrequent use of the airstrip and aircraft overflights, onsite noise levels would not substantially increase above those resulting from traffic along the local roadway network or onsite operations. The resulting noise environment from aircraft would be considered compatible with the proposed land uses” (DEIR 4.12-29). The EIR determines that this impact is less than significant. Because the Facility will be located on this same land, it does not represent a change to the project described in the EIR.
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Aemetis Carbon Zero 1 Project 66 May 2023
XIV. Population / Housing
Population / Housing Checklist Questions
XIV. Population
/ Housing.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Induce
substantial
population growth
in an area, either
directly (for
example, by
proposing new
homes and
businesses) or
indirectly (for
example, through
extension of roads
or other
infrastructure)?
DEIR pp. 4.13-1
to 4.13-15
No No No No
b) Displace
substantial
numbers of
existing people or
housing,
necessitating the
construction of
replacement
housing
elsewhere?
DEIR pp. 4.13-1
to 4.13-15
No No No No
Checklist question XIVa: The Specific Plan determines that buildout of the RAAP Specific Plan will not result in a “substantial and unplanned level of growth and associated impacts would be less than significant” (DEIR
4.13-13). The EIR describes an overall much larger scale of growth (described in detail on pages 4.13-12 and
4.12-13 of the DEIR) than would be caused by the approximately 50 employees at the Carbon Zero 1 Project alone, so the Facility does not represent a change to the project described in the EIR. The Facility will create up to 450 construction jobs onsite during the peak of the construction period; this would be temporary and would also not represent a change to the project described in the EIR.
Checklist question XIVb: As stated in the EIR, “the RAAP site does not contain any housing units and the Plan does not propose the demolition or redevelopment of any housing units. As such, implementation of the Plan would not result in the displacement of housing units or require the construction of replacement housing elsewhere. The Facility does not propose the construction or demolition of any housing units and therefore is Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 67 May 2023
not a change from the project described in the EIR. As such, there are no residents of the site who could be displaced with implementation of the Plan, and therefore, the construction of replacement housing elsewhere would not be required. Consequently, there would be no impact with respect to population or housing unit displacement” (DEIR 4.13-13). This determination applies to the Facility, which will be located entirely on land already analyzed for impacts to housing, and therefore the Facility is not a change from the project described in the EIR.Public Services
Public Services Checklist Questions
XV. Public
Services.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Would the
project result in
substantial adverse
physical impacts
associated with the
provision of new or
physically altered
governmental
facilities, need for
new or physically
altered
governmental
facilities, the
construction of
which could cause
significant
environmental
impacts, in order
to maintain
acceptable service
ratios, response
times or other
performance
objectives for any
of the public
services:
DEIR pp. 4.14-1
to 4.14-26
No No No Mitigation
Measure PUB-1
(FEIR pp 2-13;
MMRP p. 11)
Fire protection? DEIR pp. 4.14-1
to 4.14-26
No No No Mitigation
Measure PUB-1
(FEIR pp 2-13;
MMRP p. 11)
Police protection? DEIR pp. 4.14-1
to 4.14-26
No No No No
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 68 May 2023
XV. Public
Services.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
Schools? DEIR pp. 4.14-1
to 4.14-26
No No No No
Parks? DEIR pp. 4.14-1
to 4.14-26
No No No No
Other public
facilities?
DEIR pp. 4.14-1
to 4.14-26
No No No No
Checklist question XVa: The EIR states that “RPS (Riverbank Public Safety) has determined that buildout of the Specific Plan would not exceed the ability of police responders to adequately serve the Plan Area, and thereby would not need additional equipment or staff or require construction of new facilities or modification of existing facilities” (DEIR 4.14-5). The General Plan also includes Policies PUBLIC-8.1, 8.4, and 8.5 that require the RAAP development to have adequate police services. The EIR determines that this impact is less than significant. The Facility, as one portion of the buildout of the Specific Plan, does not represent a change to the project described in the EIR.
The EIR determines that fire protection services will need improvements as the city pursues new development, and states that “Policy PUB-3 of the Specific Plan would require the City to ensure that financing of the new station would occur commensurate with development within the RAAP site” (DEIR 4.14-13). The EIR includes a mitigation measure PUB-1 stipulating that “the city shall coordinate with the Stanislaus Consolidated Fire Protection District to ensure fair share development fees for future development resulting from the implementation of the RAAP Specific Plan” (FEIR 2-13). With this mitigation measure in place, the EIR determines that this impact will be less than significant. As would be the case with any other kind of new development onsite, the Facility would potentially increase the demand for fire protection services. The potential increase is consistent with the project described in the EIR, and the Facility will be subject to the existing Mitigation Measure PUB-1. Therefore, the Facility does not represent a change to the project described in the EIR.
The EIR makes the determination that there will be a less than significant impact to public schools because “buildout of the plan would not result in a substantial population increase, either directly, through the construction of new housing, or indirectly, through the creation of new jobs that would attract new residents to the Riverbank area” (DEIR 4.14-20). The Facility, as one portion of the buildout of the Specific Plan, does not represent a change to the project described in the EIR.
The Specific Plan determines that the buildout of the Specific Plan will not significantly increase local population; therefore, the Specific Plan determines that the Specific Plan’s buildout would not significantly increase the local volume of parks or other public facilities. There is a less than significant impact to this public service anticipated in the EIR. The Facility, as one portion of the buildout of the Specific Plan, does not represent a change to the project described in the EIR.
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Aemetis Carbon Zero 1 Project 69 May 2023
XV. Recreation
Recreation Checklist Questions
XVI.
Recreation.
Would the
project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Information
Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Would the
project increase
the use of
existing
neighborhood
and regional
parks or other
recreational
facilities such
that substantial
physical
deterioration of
the facility would
occur or be
accelerated?
DEIR pp. 4.15-1
to 4.15-8
No No No No
b) Does the
project include
recreational
facilities or
require the
construction or
expansion of
recreational
facilities which
might have an
adverse physical
effect on the
environment?
DEIR pp. 4.15-1
to 4.15-8
No No No No
Checklist question XVIa: The EIR describes the build out of the complete RAAP site with new buildings in both the existing industrialized area and the current open spaces and determines that “buildout of the Plan would not result in increased use of park and recreational facilities due to a substantial increase in the number of users” (DEIR 4.15-7). The EIR states that the implementation of the Plan will result in a less than significant impact to recreation facilities. Therefore, the Facility does not represent a change to the project described in the EIR.
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Aemetis Carbon Zero 1 Project 70 May 2023
Checklist question XVIb: As established in the EIR, there will not be a significant increase in population from buildout of the Specific Plan. Therefore, existing recreational facilities would not require expansion as a result of the Specific Plan’s buildout. Since there will be no expansion in recreation facilities, there is no impact on the environment from an expansion, and therefore, the EIR determines the impact under this threshold to be less than significant. The Facility is consistent with the project described in the EIR and will not create a need for new recreational facilities.
XVI. Transportation/Traffic
Transportation/Traffic Checklist Questions
XVII.
Transportation/
Traffic.
Would the project:
Where Impact
Is Analyzed in
Existing
Environmental
Documents
Do
Substantial
Changes
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Do Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Informatio
n Identify
New
Significant
Impacts?
Environmental
Document
Mitigation
Measures to
Address
Impacts
a) Conflict with a
program, plan,
ordinance or policy
addressing the
circulation system,
including transit,
roadway, bicycle and
pedestrian facilities?
DEIR pp. 4.16-
1 to 4.16-43
No No No (*)
b) Would the project
conflict or be
inconsistent with
CEQA Guidelines
section 15064.3,
subdivision (b)?
DEIR pp. 4.16-
1 to 4.16-43
No No No (*)
c) Substantially
increase hazards due
to a geometric design
feature (e.g., sharp
curves or dangerous
intersections) or
incompatible uses
(e.g., farm
equipment)?
DEIR pp. 4.16-
1 to 4.16-43
No No No (*)
d) Result in
inadequate
emergency access?
DEIR pp. 4.16-
1 to 4.16-43
No No No (*)
(*) Note, as discussed below, the EIR restates the significance thresholds for traffic, determines that traffic impacts from the full build out of the Specific Plan will be significant and unavoidable, and imposes extensive Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 71 May 2023
mitigation measures that address all significance thresholds generally. (See MMRP pp. 12 to 15, discussing mitigation measures TRANS-1, TRANS-2, TRANS-3, TRANS-4, TRANS-5, TRANS-6.) Checklist questions XVIIa, c, d (analyzed together): The EIR extensively analyzes the impacts of the implementation of the Specific Plan. The Specific Plan anticipates that the largely abandoned industrial areas of the RAAP Site would be re-used with new industrial business and that the currently empty portions of the RAAP Site would be built-up with business parks and industrial facilities, essentially filling the entire 140 acre parcel with businesses. The EIR estimates that this buildout would create 9,390 total daily vehicle trips, including 6,050 total truck and passenger vehicle trips to the R&D and retail parcels of the RAAP site. The EIR (Appendix B, Mobile Source HRA inputs) assigned 161 truck trips to Parcels 2 and 2A.
Because of the potential impact associated with nearly 10,000 daily trips from the full build out of the Specific Plan as well as temporary traffic associated with construction, the EIR contains an extremely detailed analysis of traffic, including analyzing the level of use of use on surrounding streets and intersections. The EIR restates the CEQA Checklist questions and significance thresholds based on the City’s experience analyzing traffic impacts to the following:
- The addition of project traffic causes a signalized intersection to deteriorate from an acceptable level to an unacceptable level.
- The addition of project traffic causes the level of service at an unsignalized intersection to degrade from an acceptable to an unacceptable service level or causes an unsignalized intersection to meet peak hour traffic signal warrants
- The project substantially increases hazards or congestion due to a design feature (e.g., sharp curves) or incompatible uses (e.g., farm equipment)
- The project results in inadequate emergency access.
- The project conflicts with adopted transportation policies, plans or programs.
Reviewing the EIR’s detailed traffic analysis under these thresholds, the EIR determines that traffic impacts will be significant and unavoidable. When approving the Specific Plan, the City made findings regarding the traffic, adopted a statement of overriding considerations for the unavoidable impacts, and imposed several mitigation measures to address the impacts. Some of the mitigation measures apply generally to the City and County planning and development processes, and some apply to individual projects.
The Facility’s worst case activity levels are expected to generate up to 164 truck (328 daily one-way trips) and other commercial round trips per day (290 daily one-way trips) and approximately 50 employee roundtrips in passenger vehicles (100 daily one-way trips) for the all truck scenario and seven truck round trips and 2 daily rail round trips for the truck and rail scenario, which is a fraction of trips analyzed by the EIR for these parcels, and therefore, the Facility does not represent a change to the project described in the EIR. In addition, the City already determined that traffic impacts of the full Specific Plan project will be significant and imposed several mitigation measures, and the Facility will be required to comply with those mitigation measures applicable to individual projects.
Checklist questions XVIIb: The EIR did not evaluate this topic because the threshold was added to the CEQA Guidelines after December 31, 2018. Since July 2020, all lead agencies were required to adopt vehicle miles traveled (VMT) as the new measure for identifying transportation impacts for land use projects, replacing automobile delay–based level of service (LOS).
To aid in this transition, the Governor’s Office of Planning and Research released a technical advisory, “Evaluating Transportation Impacts in CEQA” (December 2018). The City of Riverbank has not yet adopted “Vehicle Miles Traveled (VMT) Guidelines”. The VMT analysis utilizes the thresholds developed by OPR in Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 72 May 2023
December 2018 entitled, “Technical Advisory on Evaluating Transportation Impacts in CEQA” (Technical Advisory) for automobile VMT (i.e., light-duty vehicles).
The Technical Advisory suggests that lead agencies may screen out VMT impacts under CEQA based on project size, VMT generation characteristics, transit availability, and provision of affordable housing. The following project types are ˈscreened outˈ as having less-than-significant transportation impacts in the Technical Advisory1:
► Small Projects Generating Less than 110 Daily Trips: OPR suggests a small project that would generate 110 trips per day or less generally may be assumed to cause a less-than- significant transportation impact and thus not warrant further VMT analysis. ► Redevelopment Projects with a Net Decrease in VMT: Where a project replaces existing VMTgenerating land uses, if the replacement leads to a net overall decrease in VMT, the project would lead to a less-than-significant transportation impact. If the project leads to a net overall increase in VMT, then the thresholds developed by the jurisdiction should apply.
► Projects in Low VMT Areas: Residential and office (or other land use) projects that are located in areas with low VMT, and that incorporate similar features (i.e., density, mix of uses, transit accessibility), will tend to exhibit similarly low VMT and thus do not warrant further VMT analysis. ► Projects in Transit Priority Areas (TPAs): A TPA is an area within a half a mile of a major transit stop or a bus transit corridor with service intervals of no longer than 15 minutes during peak commute hours.
A ˈmajor transit stopˈ means “a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.” as defined by Public Resources Code Section 21064.3. OPR suggests that a project in TPA should generally be presumed to have less than significant impacts, but the presumption might not be appropriate if the project:
• Has a Floor Area Ratio (FAR) of less than 0.75
• Includes more parking for use by residents, customers, or employees of the project than required by the jurisdiction (if the jurisdiction requires the project to supply parking) • Is inconsistent with the applicable Sustainable Communities Strategy (SCS) (as determined by the lead agency, with input from the Metropolitan Planning Organization) • Replaces affordable residential units with a smaller number of moderate- or high-income residential units
► Local-Serving Retail Projects under 50,000 Square Feet: Because new retail development typically redistributes shopping trips rather than creates new trips, estimating the total change in VMT (i.e., the difference in total VMT in the area affected with and without the project) is the best way to analyze a retail project’s transportation impacts. By adding retail opportunities into the urban fabric and thereby improving retail destination proximity, local-serving retail development tends to shorten trips and reduce VMT. Thus, lead agencies generally may presume such development creates a less-than-significant transportation impact. Regional serving retail development, on the other hand, which can lead to substitution of longer 1 Governor’s Office of Planning and Research. 2018, December. Technical Advisory on Evaluating Transportation Impacts in CEQA. https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 73 May 2023
trips for shorter ones, may tend to have a significant impact. Where such development decreases VMT, lead agencies should consider the impact to be less-than-significant. The Technical Advisory suggests that retail uses of less than 50,000 square feet might be considered local-serving. ► Affordable Housing Projects: OPR guidance indicates that adding affordable housing to infill locations generally improves jobs-housing match, in turn shortening commutes and reducing VMT. Further, “… lowwage workers in particular would be more likely to choose a residential location close to their workplace, if one is available.” In areas where existing jobs-housing match is closer to optimal, low-income housing nevertheless generates less VMT than market rate housing, therefore, a project consisting of a high percentage of affordable housing may be a basis for the lead agency to find a less-than-significant impact on VMT. Evidence supports a presumption of a less-than-significant impact for a 100 percent affordable residential development (or the residential component of a mixed-use development) in infill locations.
Thresholds for Impacts to Goods Movement
Neither the Technical Advisory nor CEQA Guidelines Section 15064.3(a) directly address how to analyze transportation impacts associated with changes in traffic associated with goods movement, which is largely carried out by heavy-duty trucks. CEQA Guidelines Section 15064.3(a) specifies that the VMT to be analyzed is defined as the amount and distance of automobile travel (emphasis added) attributable to a project. The term ˈautomobileˈ refers to on-road passenger vehicles, specifically cars and light trucks (emphasis added).2 SB 743 does not require the inclusion of heavy-duty truck trips, utility vehicles, or other types of vehicles in the VMT analysis.3 In the case of trucks (other than light trucks), based on CARBˈs 2017 Scoping Plan, the State’s strategy for the goods movement sector is not via VMT reduction, but through advances in technology [zero-emissions (ZE) and near-zero emissions (NZE) control strategies].4 Automobile VMT Impact Assessment
CEQA Guidelines Section 15064.3(a) states that the primary consideration in evaluating a project’s transportation impacts for CEQA purposes is the amount and distance that a project might cause people to drive. This approach captures two measures of transportation impacts: number of automobile trips generated and VMT. The Facility would result in 50 daily employee commute trips by automobile (which are comprised of light-duty passenger vehicles and light-duty trucks). Consequently, for the purpose of quantifying automobile VMT, the Facility is expected to generate less than the 110 trips per day for employee commute trips and is screened out from a more detailed VMT analysis in accordance with OPRˈs guidance for small projects. Thus, the Facility would result in less-than-significant transportation impacts under SB 743 regarding employee trips and would not represent a change to the project described in the EIR. 2 Governorˈs Office of Planning and Research, December 2018, Technical Advisory on Evaluating Transportation Impacts Under CEQA, https://www.opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf accessed January 10, 2021. 3 OPR staff have interpreted that the intent of SB 743 was to address passenger vehicle VMT impact and not freight VMT, as cited under CEQA Guidelines Section 15064.3(a). Therefore, lead agencies could exclude freight VMT from transportation VMT impact analyses under CEQA.
4 California Air Resources Board, 2017, Californiaˈs 2017 Climate Change Scoping Plan: The Strategy for Achieving Californiaˈs 2030 Greenhouse Gas Target, https://www.arb.ca.gov/cc/scopingplan/2030sp_pp_final.pdf accessed on March 18, 2019.
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XVII. Tribal Cultural Resources
Tribal Cultural Resources Checklist Questions
XVIII. Tribal Cultural
Resources.
Where
Impact Is
Analyzed
in Existing
Environm
ental
Document
s
Do
Substantia
l Changes
Involve
New
Significant
Impacts or
Substantia
lly More
Severe
Impacts?
Do
Substantial
Changes in
Circumstanc
es Involve
New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Informatio
n Identify
New
Significant
Impacts?
Environment
al Document
Mitigation
Measures to
Address
Impacts
Would the project cause a
substantial adverse
change in the significance
of a tribal cultural
resource, defined in
Public Resources Code
section 21074 as either
a site, feature, place,
cultural landscape that is
geographically defined in
terms of the size and
scope of the landscape,
sacred place, or object
with cultural value to a
California Native
American tribe, and that
is:
NA No No NA No
a) Listed or eligible for
listing in the California
Register of Historical
Resources, or in a local
register of historical
resources as defined in
Public Resources Code
section 5020.1(k), or
NA No No NA No
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Aemetis Carbon Zero 1 Project 75 May 2023
XVIII. Tribal Cultural
Resources.
Where
Impact Is
Analyzed
in Existing
Environm
ental
Document
s
Do
Substantia
l Changes
Involve
New
Significant
Impacts or
Substantia
lly More
Severe
Impacts?
Do
Substantial
Changes in
Circumstanc
es Involve
New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Informatio
n Identify
New
Significant
Impacts?
Environment
al Document
Mitigation
Measures to
Address
Impacts
b) A resource determined
by the lead agency, in
its discretion and
supported by substantial
evidence, to be
significant pursuant to
criteria set forth in
subdivision (c) of Public
Resources Code Section
5024.1. In applying the
criteria set forth in
subdivision (c) of Public
Resource Code Section
5024.1, the lead agency
shall consider the
significance of the
resource to a California
Native American tribe.
NA No No NA No
At the time of the preparation of the Specific Plan, this checklist section and these questions were not part of the CEQA Guidelines. Since that time, the Appendix G checklist added these questions. As discussed above under Checklist questions related to cultural resources, there are no known cultural resources in the RAAP site. The project described in the EIR includes the full build out of the RAAP site, including build out in both currently undeveloped areas, as well as in the existing industrialized area of the RAAP site, so the Facility does not represent a change to the project described in the EIR with respect to this threshold.
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XVIII. Utilities / Service Systems
Utilities / Service Systems Checklist Questions
XIX. Utilities /
Service Systems.
Would the project:
Where
Impact Is
Analyzed
in Existing
Environme
ntal
Documents
Do
Substantia
l Changes
Involve
New
Significant
Impacts
or
Substantia
lly More
Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Informatio
n Identify
New
Significant
Impacts?
Environmenta
l Document
Mitigation
Measures to
Address
Impacts
a) Require or result in
the relocation or
construction of new
or expanded water,
wastewater treatment
or storm water
drainage, electric
power, natural gas, or
telecommunications
facilities, the
construction or
relocation of which
could cause
significant
environmental
effects?
DEIR pp. pp.
4.10-1 to
4.10-14 and
pp. 4.17-1
to 4.17-42
No No No No
b) Have sufficient
water supplies
available to serve the
project and
reasonably
foreseeable future
development during
normal, dry and
multiple dry years?
DEIR pp.
4.17-1 to
4.17-42
No No No No
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XIX. Utilities /
Service Systems.
Would the project:
Where
Impact Is
Analyzed
in Existing
Environme
ntal
Documents
Do
Substantia
l Changes
Involve
New
Significant
Impacts
or
Substantia
lly More
Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Informatio
n Identify
New
Significant
Impacts?
Environmenta
l Document
Mitigation
Measures to
Address
Impacts
c) Result in a
determination by the
wastewater treatment
provider which serves
or may serve the
project that it has
adequate capacity to
serve the project’s
projected demand in
addition to the
provider’s existing
commitments?
DEIR pp.
4.17-1 to
4.17-42, and
FEIR pp. 3-
13 to 3-17
No No No No
d) Generate solid
waste in excess of
State or local
standards, or in
excess of the capacity
of local infrastructure,
or otherwise impair
the attainment of
solid waste reduction
goals?
DEIR pp.
4.17-1 to
4.17-42
No No No No
e) Comply with
federal, state, and
local management
and reduction
statutes and
regulations related to
solid waste?
DEIR pp.
4.17-1 to
4.17-42
No No No No
Checklist question XIXa: (See also response to checklist question Xb) A water survey conducted for the EIR determines that there is sufficient groundwater to serve future development at the RAAP Site, which is expected to continue sourcing its water from onsite wells. Additionally, the DEIR states that “the Urban Water Management Plan (UWMP) determined that sufficient groundwater supply is available to supply future growth within the City, including the Plan Area”. The Facility will rely on RIC wells and on the City of Riverbank’s Water Division for its water needs, as described in the EIR. The City of Riverbank’s water is supplied from wells located throughout the City. These wells are monitored and maintained by the City. The EIR determines the impact to groundwater resources due to the City’s availability of groundwater supply and availability of water from onsite wells to be less than significant. Because the Facility will source its water from a metered Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 78 May 2023
water tie-in near the site entrance and will be required to follow city water use policies, it does not change the project described in the EIR.
The EIR for the Specific Plan compares the water demands from the implementation of the Specific Plan to the available water supply. The Specific Plan determines that the wells on the RAAP site have a capacity of about 2,600 gallons per minute (“gpm”) and additional water could be available from the City supply, which together is more than adequate to provide the 438 gpm needed for the new business park development and additional amounts needed for industrial uses, so the EIR determines that the impact under this threshold is less than significant (DEIR 4.17-24). The Facility will require a water supply of approximately 240 gpm, which is well within the available capacity described in the Specific Plan. The Facility will reduce its water usage by 60 gpm by recycling wastewater onsite. Additional water supply will be generated from intermittent wastewater treatment of filter backwash and clean in place streams and stormwater reuse. For these reasons, the Facility does not change the project analyzed in the EIR.
The EIR states that wastewater released from the RAAP site is required to comply with the conditions of the site’s Waste Discharge Requirement issued by the State Water Resources Board. Because of these compliance measures, the EIR determines that the impact under this threshold is less than significant. The Facility will treat its process wastewater onsite for reuse, so there is no change from the project described in the EIR regarding wastewater treatment.
The EIR states that development under the Specific Plan could lead to “significant changes to land use that would substantially alter the existing drainage pattern of the RAAP site” (DEIR 4.10-11), but the impact under this standard would be less than significant due to the RAAP Specific Plan requirement for all development on the RAAP Site to comply with National Pollutant Discharge Elimination System (NPDES) regulations regulating storm water runoff volumes and to implement the use of LID, surface runoff volumes would be contained onsite in detention basins (DEIR 4.10-11). The Facility is located within an existing industrialized area of the RAAP Site that is already generally level. For these reasons, the Facility does not represent a change to the project described in the EIR.
The EIR analyzes the complete build out of the RAAP site and states that “all the storm water from the Plan Area would be treated onsite” (FEIR 3-14) and determines that the “Specific Plan would not result in any significant impacts to stormwater, therefore, no mitigation measures are necessary.” (FEIR 3-15). The Facility will be part of the anticipated build out of the RAAP site and will construct an additional stormwater retention pond to retain all stormwater on site. In addition, the Facility will be located on a portion of the RAAP site that either already contains or will be developed with hard surfaces and drains and will not be located in open area without hard surfaces. For these reasons, there are no changes to the project described in the EIR.
Although the EIR did not directly evaluate the potential impacts to electric power, natural gas or telecommunications facilities, the RAAP site was already served with electric power, natural gas, and telecommunications facilities. The Modesto Irrigation District did provide comments on the DEIR (FEIR comment letter RA1). In its comments RA1-4, RA1-5 and RA1-6, the Modesto Irrigation District confirms they have sufficient electricity supplies and can provide electric power to the RAAP area. As discussed in the Project Description, Aemetis has obtained a will-serve letter from Pacific Gas & Electric per Policy PUBLIC-6.3 to ensure adequate fuel supplies and availability. Additionally, the Facility is a producer of RD and SAF. For these reasons, the Facility will not create any new impacts over what was evaluated in the EIR and does not represent a change to the project described in the EIR.
Checklist question XIXb: (See also response to checklist question Xb) A water survey conducted for the EIR determines that there is sufficient groundwater to serve future development at the RAAP Site, which is Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 79 May 2023
expected to continue sourcing its water from onsite wells. Additionally, the DEIR states that “the Urban Water Management Plan (UWMP) determined that sufficient groundwater supply is available to supply future growth within the City, including the Plan Area”. This is aligned with the City of Riverbank’s updated UWMP published in 2020. The Facility will rely on onsite wells for its water needs, as described in the EIR. The EIR determines the impact to groundwater resources due to the City’s availability of groundwater supply and availability of water from onsite wells to be less than significant. Because the Facility will source its water from onsite well(s) and will be required to follow city water use policies, it does not change the project described in the EIR.
Checklist question XIXc: The EIR determines that the impact under this threshold is less than significant because the anticipated wastewater generation resulting from the build-out of the Specific Plan would be within the capacity of the existing City Wastewater Treatment Plant. The Facility will treat, recycle and/or evaporate its process wastewater onsite and discharge sanitary wastewater to the City sewer, creating no need for changes to existing City facilities. For this reason, the Facility will result in no changes to the project analyzed in the EIR.
Checklist question XIXd: As stated in the EIR, “solid waste from the proposed [Specific] Plan site would be transferred to the Forward, Inc. landfill in San Joaquin County, the Fink Road Landfill, and the Covanta Waste-to-Energy Facility in Stanislaus County. Covanta is permitted to receive up to 1,700 tons of waste per day, and the Fink Road Landfill is expected to receive approximately 400 tons per day by 2029 and will add an estimated 10 to 15 years of additional disposal capacity if approved” (DEIR 4.17-40). The EIR uses the estimate that each additional job created sends an additional “16 pounds per job” of waste to local landfills.
The calculation of additional waste from development of the Specific Plan is made assuming that 1,654 jobs will be added onsite and results in an additional volume of between 0.2 and 3.3 percent of the daily capacity of the three landfills mentioned above. Based on this information, the EIR makes the determination that this will be a less than significant impact. The Facility will generate approximately 49-59 TPD of solid waste, consisting of wastewater treatment sludge, salt cake from wastewater treatment, waste oil, and spent clay.
The waste generated by the Facility will be within the 3.3 percent of the daily capacity, and the overall effect impact of the Facility will be to reduce waste generation since the plant will be using vegetable oils and animal fats as feedstock. Furthermore, the waste oils (29-39 TPD) and spent clay (13 TPD) can be sold as animal feed, reducing the amount of waste that is transferred to landfills. Therefore, the Facility does not represent a change to the project analyzed in the EIR.
Checklist question XIXe: The EIR determines that compliance with relevant federal, state, and local statutes that pertain to solid waste (as set forth in the EIR on page 4.17-41), will ensure that the Specific Plan’s impact in this category is less than significant. The Facility will also comply with applicable laws related to the management of solid waste, so there is no change to the project described in the EIR.
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XIX. Wildfire
Wildfire Checklist Questions
XX. Wildfire.
Would the project:
Where
Impact Is
Analyzed
in Existing
Environme
ntal
Documents
Do
Substantia
l Changes
Involve
New
Significant
Impacts
or
Substantia
lly More
Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Informatio
n Identify
New
Significant
Impacts?
Environmenta
l Document
Mitigation
Measures to
Address
Impacts
a) Substantially
impair an adopted
emergency response
plan or emergency
evacuation plan?
DEIR pp.
4.9-1 to 4.9-
18 No No No No
b) Due to slope,
prevailing winds, and
other factors,
exacerbate wildfire
risks, and thereby
expose project
occupants to,
pollutant
concentrations from a
wildfire or the
uncontrolled spread
of a wildfire?
DEIR pp.
4.9-1 to 4.9-
18 No No No No
c) Require the
installation or
maintenance of
associated
infrastructure (such
as roads, fuel breaks,
emergency water
sources, power lines
or other utilities) that
may exacerbate fire
risk or that may result
in temporary or
ongoing impacts to
the environment?
DEIR pp.
4.9-1 to 4.9-
18 No No No No
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XX. Wildfire.
Would the project:
Where
Impact Is
Analyzed
in Existing
Environme
ntal
Documents
Do
Substantia
l Changes
Involve
New
Significant
Impacts
or
Substantia
lly More
Severe
Impacts?
Do
Substantial
Changes in
Circumstances
Involve New
Significant
Impacts or
Substantially
More Severe
Impacts?
Does New
Important
Informatio
n Identify
New
Significant
Impacts?
Environmenta
l Document
Mitigation
Measures to
Address
Impacts
d) Expose people or
structures to
significant risks,
including downslope
or downstream
flooding or landslides,
as a result of runoff,
post-fire slope
instability, or
drainage changes?
DEIR pp.
4.9-1 to 4.9-
18 No No No No
Although this is a new section to CEQA Guidelines Appendix G, the EIR evaluated the potential impacts from wildfires in Question g and h) of Section 4.9. Hazardous and Hazardous Materials of the EIR.
Checklist question XXa and c: As described in Chapter 4.16, Transportation and Traffic of the EIR, development under the Specific Plan would make only minor changes to the existing road network although it would bring more employees to the area and more congestion on existing streets. The North County Corridor Phase 1 will include upgrades to Claribel Road and Claus Road as well as a new signalized intersection at Claus Road and the Facility entrance; all of these improvements will improve emergency evaluation route access. The Stanislaus County Safety Plan and Multi-Jurisdictional Hazardous Mitigation Plan (MJHMP) includes emergency response to various safety hazards including seismic and geologic hazards, dam failure, flood hazards and fire hazards. The City of Riverbank is within the inundation zone of New Melones dam in the event of a failure. The Office of Emergency Services maintains inundation maps for the New Melones and other dams that would affect the county, in the event of earthquake or other causes of failure. If failure of the New Melones Dam were to occur, the City of Riverbank evacuation routes would be to the southeast toward higher ground, with the primary evacuation routes along Terminal/Santa Fe and Claus Road towards Empire and Waterford. Although the RAAP Specific Plan proposes to modify the visual character of Claus Road, vehicle travel would not be hindered or obstructed, and would not impair implementation of or physically interfere with the Stanislaus County MJHMP. For these reasons, the EIR found the potential impact to an adopted emergency response plan or emergency evaluation plan would be less-than-significant. The Facility is located within the RAAP Specific Plan area, will not add any infrastructure that will exacerbate any fire risks, will not impair an adopted emergency response or evacuation plan, will have a facility emergency Preparedness/Contingency Plan, and does not represent a change to the project analyzed in the EIR.
Checklist question XXb and d: The EIR states that the RAAP project has no areas within the site are defined as “Very High Fire Hazard Severity” (DEIR 4.9-18) for wildland fires, and all new development would comply as required by law with California Building Code, California Fire Code, and any other applicable state and local fire safety requirements. Further the slope within RAAP area is flat and there are no features on the Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project 82 May 2023
site that would exacerbate wildfire risks, including downslope or downstream flooding or landslides, as a result of runoff, or any other associated risks with wildfire. Additionally, the EIR found that potential impacts to exposing people or structures to a significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or where residences are intermixed with wildlands were lessthan-significant due to General Plan policies SAFE-1.1, SAFE-1.2, SAFE-1.4, SAFE-1.5, and SAFE-2.2, SAFE2.3, SAFE-2.4 (Section 4.9h). For these reasons, the EIR determines that impact of buildout of the Specific Plan under these standards is less than significant. The Facility is located within the plan area evaluated in the Specific Plan and does not represent a change to the project analyzed in the EIR.
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5. ACRONYMS
Table 11 Table of Acronym Definitions
Acronym Definition
AB Assembly Bill
Army U.S. Army
BAU Business As Usual
bbl barrels
BOD Biological oxygen demand
BPS Best Performance Standards
BRAC base closure and realignment
CAFE Corporate Average Fuel Economy
CalARP California Accidental Release Program
CalEEMod California Emissions Estimator Model
CARB California Air Resources Board
CCIC Central California Information Center
CEC California Energy Commission
CEQA California Environmental Quality Act
CGS California Geological Survey
CI carbon intensity
City City of Riverbank
COD Chemical oxygen demand
CRHR California Register of Historic Resources
CUPA Certified Unified Program Agency
CWA Clean Water Act
DEIR Draft Environmental Impact Report
DTSC California Department of Toxic Substances Control
EIR Environmental Impact Report
FAR floor area ratio
FEIR Final Environmental Impact Report
FMMP Farmland Mapping & Monitoring Program
GHG greenhouse gas
gpm gallon per minute
HABS/HAER Historic American Building Survey/Historic American Engineering Record HFU HydroFlex unit
HPU hydrogen production unit
lb/hr Pound per hour
LCFS Low Carbon Fuel Standard
LEED Leadership in Energy and Environmental Design
LESA Land Evaluation/Site Assessment
LOS level of service
MJHMP Multi-Jurisdictional Hazard Mitigation Plan
mmBTU Million British thermal unit
MMRP Mitigation Monitoring and Reporting Program
MMSCF million standard cubic feet
MW megawatt
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NHTSA National Highway Traffic Safety Administration
NPDES National Pollutant Discharge Elimination System
NZE near zero emission
PRC Public Resources Code
PSA Pressure swing adsorber
psig Pounds per square gauge
RAAP Riverbank Army Ammunition Plant
R&D Office/research and development
RD Renewable diesel
RIC Riverbank Industrial Complex
RMP Risk Management Plan
RPS California Renewables Portfolio Standard
RPUSSJV Recovery Plan for Upland Species of San Joaquin Valley RWQCB Regional Water Quality Control Board
SAF sustainable aviation Fuel
SB Senate Bill
scf standard cubic feet
SCS Sustainable Communities Strategy
SFO San Francisco Airport
SFPUC San Francisco Public Utility Commission
SJVAPCD San Joaquin Valley Air Pollution Control District SPCC Spill Prevention, Control, and Countermeasure
SWRCB State Water Resources Control Board
tbd to be determined
TPA transit priority areas
TPD tons per day
VMT Vehicle miles travelled
US EPA United States Environmental Protection Agency
UWMP Urban Water Management Plan
WDRs Waste Discharge Requirements
WWTP wastewater treatment plant
ZE zero emission
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Aemetis Carbon Zero 1 Project 85 May 2023
6. REFERENCES
California Air Pollution Control Officers Association (CAPCOA), 2022. CalEEMod Version 2020.4.0 Appendix D, Table 4.2
California Air Resources Board, 2017, California’s 2017 Climate Change Scoping Plan: The Strategy for Achieving California’s 2030 Greenhouse Gas Target,
https://www.arb.ca.gov/cc/scopingplan/2030sp_pp_final.pdf accessed on March 18, 2019.
California Energy Commission, 2022a. California Retail Fuel Outlet Annual Reporting (CEC-A15) Results. https://www.energy.ca.gov/data-reports/energy-almanac/transportation-energy/california-retail-fuel-outletannual-reporting California Energy Commission, 2022b. Electricity Consumption by County. http://www.ecdms.energy.ca.gov/elecbycounty.aspx
California Energy Commission, 2022c. Gas Consumption by County. http://www.ecdms.energy.ca.gov/gasbycounty.aspx
California Governor’s Office of Planning and Research. 2018, December. Technical Advisory on Evaluating Transportation Impacts in CEQA. https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf CH2MHILL, 2006. U.S. Army BRAC 2005, Environmental Condition of Property Phase I Report for Riverbank Army Ammunition Plant in Riverbank, California.
CH2MHILL, 2008. Final Site Investigation Report, Riverbank Army Ammunition Plant, Riverbank, California.
Prepared for U.S. Army Corps of Engineers, Louisville District. Contract No. W912QR-04-D-0020, Delivery Order No. 0015. March 2008.
Riverbank, City of, 2013. Riverbank Army Ammunition Plant Specific Plan EIR, State Clearinghouse number:
2011022015. [Final and Draft EIR] Prepared by The Planning Center et. al. -----, 2020. 2020 Urban Water Management Plan. Prepared October 2021. Prepared by Kjeldsen, Sinnock & Neudeck, Inc.
-----, 2021. Water Shortage Contingency Plan. Prepared October 2021. Prepared by Kjeldsen, Sinnock & Neudeck, Inc.
Riverbank Local Redevelopment Authority, 2013. Riverbank Army Ammunition Plan Specific Plan, Revised Public Review, November 2013. Prepared by The Planning Center et. al.
U.S. Environmental Protection Agency, 1994. EPA Superfund Record of Decision: Riverbank Army Ammunition Plant, EPA ID: CA7210020759, OU1, Riverbank California. 03/23/1994 U.S. Department of Transportation, 2022. Bureau of Transportation Statistics, Class I Freight Fuel Consumption and Travel. Class I Rail Freight Fuel Consumption and Travel | Bureau of Transportation Statistics (bts.gov)
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Weston Solutions, Inc. 2018. Final Work Plan Parcel A Soil/Sediment Time-Critical Removal Action, Former Riverbank Army Ammunition Plant, City of Riverbank, Stanislaus County, California. February 2018.
Prepared for Riverbank Local Redevelopment Authority and U.S. Department of the Army, Base Realignment and Closure Division
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project E1-1 May 2023
Exhibit 1 Facility Site Plan
Riverbank Industrial Complex CEQA Addendum
Aemetis Carbon Zero 1 Project E2-1 May 2023
Exhibit 2 Facility Plot Plan
Riverbank Army Ammunition Plant Specific Plan CEQA Addendum to Final EIR Aemetis Carbon Zero 1 Project A-1 May 2023
Appendix A Air Quality Technical Memo
1 Air Quality
Riverbank is located in the northern portion of the San Joaquin Valley Air Basin, which is under the jurisdiction of the San Joaquin Valley Air Pollution Control District (SJVAPCD). SJVAPCD establishes airborne pollutant emissions thresholds to determine whether construction or operations of a proposed project will result in significant impacts, including cumulative impacts, to regional air quality by obstructing the implementation of any applicable air quality plan, contributing to potential air quality violations, or resulting in a cumulatively considerable net increase of any criteria pollutant for which the San Joaquin Air Basin is in nonattainment status.
SJVAPCD’s Guide for Assessing and Mitigating Air Quality Impacts (GAMAQI) provides specific significance thresholds for evaluating airborne emissions of criteria pollutants generated during construction of a proposed project, as well as those from direct and indirect sources associated with its operations (SJVAPCD 2015). Direct sources of operational emissions include stationary sources requiring a Permit to Operate. Indirect sources of operational emissions, which do not require a Permit to Operate, include mobile sources and energy consumption. SJVAPCD considers a proposed project to have a significant impact on regional air quality if, during either construction or operations, criteria pollutant emissions exceed any of the significance thresholds presented in the table below. The operational emissions thresholds apply to permitted equipment/activities and non-permitted equipment/activities separately when making significance determinations, per SJVAPCD’s GAMAQI (SJVAPCD 2015).
SJVAPCD Air Quality Thresholds of Significance – Criteria Pollutants Pollutant/Precursor Annual Construction
Emissions (tons/year)
Annual Operational Emissions (tons/year)
Permitted
Equipment/Activities
Non-Permitted
Equipment/Activities
CO 100 100 100
NOX 10 10 10
ROG 10 10 10
SOX 27 27 27
PM10 15 15 15
PM2.5 15 15 15
Source: SJVAPCD’s Air Quality Thresholds of Significance – Criteria Pollutants (SJVAPCD 2015), Section 8.3, Table 2.
Additionally, a proposed project is considered to have a significant impact if it:
• Exposes the public to objectionable odors, and/or
• Results in toxic air contaminant (TAC) emissions that result in a health risk to the Maximally Exposed Individual (MEI) that is equal to or exceeds either of the following thresholds:
- A cancer risk of 10 in one million
- An acute or chronic health risk Hazard Index of 1
2 The thresholds of significance mentioned above are based on SJVAPCD Rule 2201 New Source Review (NSR) offset thresholds. The District has determined that using these NSR offset thresholds in making CEQA significance determinations, as allowed under California Code of Regulations Title 14, Section 15064.7 (14 CCR §15064.7), promotes consistency in the environmental review process.
Significant impacts of an individual proposed project are considered cumulatively significant when modeling shows that the project’s airborne emissions, when combined with those of other existing and planned projects in the area, exceeds a regional air quality standard. A proposed project resulting in a significant air quality impact also results in a significant cumulative air quality impact.
The Carbon Zero 1 Project (also referred to as the “Facility”) is located within the former Riverbank Army Ammunition Plant (RAAP). On February 10, 2014, the Riverbank City Council adopted a Specific Plan for the RAAP Site and certified an EIR for the Specific Plan (City of Riverbank 2013). As part of the 2013 RAAP Specific Plan EIR and related technical evaluations, potentially significant impacts were determined for air quality and as such, the RAAP Specific Plan EIR imposed mitigation measures. This technical report has been prepared to support a California Environmental Quality Act (CEQA) environmental checklist evaluation pursuant to California Public Resources Code (PRC) Section 21166 and CEQA Guidelines Section 15162, to determine whether the proposed project is consistent with the impact analyses and mitigation measures presented in the 2013 RAAP Specific Plan EIR.
Construction Phase Emissions
The Carbon Zero 1 Project (or Facility) consists of a Renewable Diesel (RD) and Sustainable Aviation Fuel (SAF) production plant encompassing a total of 960,319 square-feet, including a new 77,076 square-feet rail spur area, material loading/unloading areas, and unpaved roads within the Facility. Installation of industrial equipment and construction of property improvements, including utilities, a few small on-site structures to be used for utilities and administrative functions, and on-site roads, will occur over a period of approximately two years, and is conservatively expected to commence in early 2023. The actual start date will be after required approvals and permits are received and so will likely be later in 2023. Estimates of air pollutant emissions associated with construction of the project are based on a preliminary phasing schedule provided by the Applicant, which includes grading, excavation, site work, building construction, and paving.
Estimates of the unmitigated construction-related emissions associated with the project are shown in Table 1, Carbon Zero 1 Construction Emissions – Unmitigated, as quantified using the California Emissions Estimator Model (CalEEMod), Version 2020.4.0 (CAPCOA 2020), and mobile source emissions factors from the California Air Resources Board (CARB) EMission FACtors (EMFAC) Model, Version 1.0.2 (CARB 2021). Emissions estimates are based on the preliminary construction schedule and equipment list provided by the Applicant. As shown in Table 1, unmitigated annual NOX emissions associated with construction exceed the annual SJVAPCD significance threshold. 3 Table 1 Carbon Zero 1 Construction Emissions – Unmitigated Construction Phase
Criteria Air Pollutant Emissions 1
ROG NOX CO SO2 PM10 PM2.5
Construction Year 2023
Construction Phase Daily Maximum Emissions (lb/day)
Site Preparation <1 5.8 11 <1 23 12
Grading 1.1 8.2 16 <1 13 7.1
Building Construction 18 126 147 <1 11 6.8
Maximum Daily Construction Emissions 2 19 135 163 <1 24 14 SJVAPCD Daily Significance Threshold N/A N/A N/A N/A N/A N/A Construction Phase Annual Emissions (ton/year)
Site Preparation <1 <1 <1 <1 <1 <1
Grading <1 <1 <1 <1 <1 <1
Building Construction 1.7 12 14 <1 1.1 <1
Total Annual Construction Emissions 3.7 14 16 <3 3.1 <3 SJVAPCD Annual Significance Threshold 3 10 10 100 27 15 15 Any Threshold Exceeded? No Yes No No No No
Construction Year 2024
Construction Phase Daily Maximum Emissions (lb/day)
Building Construction 17 119 144 <1 11 6.2
Paving 1.4 9.2 14.7 <1 <1 <1
Maximum Daily Construction Emissions 2 18 128 159 <1 11 6.7 SJVAPCD Daily Significance Threshold N/A N/A N/A N/A N/A N/A Construction Phase Annual Emissions (ton/year)
Building Construction 1.8 13 16 <1 1.1 <1
Paving <1 <1 <1 <1 <1 <1
Total Annual Construction Emissions 2.8 14 17 <2 2.1 <2 SJVAPCD Annual Significance Threshold 3 10 10 100 27 15 15 Any Threshold Exceeded? No Yes No No No No
Source: CalEEMod Version 2020.4.0 (CAPCOA 2020).
Notes: Totals may not sum to 100 percent due to rounding. 1 Construction phasing is based on the preliminary information provided by the Applicant. Where specific information regarding proposed project-related construction activities was not available, construction assumptions were based on CalEEMod defaults. 2 In 2023, Grading and Building Construction phases overlap; in 2024, Building Construction and Paving phases overlap. 3 SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD 2015), Section 8.3, Table 2. 4 The RAAP Specific Plan EIR includes Mitigation Measure AQ-1e to reduce construction related emissions.
For the Carbon Zero 1 Project, the first mitigation strategy evaluated for reducing criteria pollutant emissions was requiring that at least ninety-percent of diesel-powered off-road construction equipment rated above 25 horsepower meet USEPA Tier 4 off-road emission standards.
Mitigation Measure AQ-1e
The project [as described in the RAAP Specific Plan EIR] will implement measures to mitigate emissions from construction equipment exhaust, including the use of alternative-fueled or catalystequipped diesel construction equipment; minimizing idling time (e.g. 5-minute maximum); limiting the hours of operation of heavy duty equipment and/or the amount of equipment in use at one time; and replacing fossil-fueled equipment with electrically-driven equivalents (provided they are not run via a portable generator set).
Thus, by requiring that at least ninety-percent of the diesel-powered off-road equipment rated greater than 25 horsepower used during construction of the Carbon Zero 1 Project utilize engines that either meet or exceed USEPA Tier 4 off-road emission standards, construction-related NOX emissions will be reduced to levels below SJVAPCD’s threshold of significance.
Table 2, Carbon Zero 1 Construction Emissions – Mitigated, presents the estimated emissions that result from implementing the USEPA Tier 4 off-road equipment requirement in at least ninety-percent of dieselpowered off-road equipment rated greater than 25 horsepower. As can be seen in Table 2, annual NOX emissions associated with construction of the Carbon Zero 1 Project are below the annual SJVAPCD significance threshold when this mitigation measure is applied.
Table 2 Carbon Zero 1 Construction Emissions – Mitigated Construction Phase
Criteria Air Pollutant Emissions 1
ROG NOX CO SO2 PM10 PM2.5
Construction Year 2023
Construction Phase Daily Maximum Emissions (lb/day)
Site Preparation <1 1.6 12 <1 23 12
Grading <1 2.4 18 <1 13 6.9
Building Construction 7.1 49 153 <1 6.8 2.5
Maximum Daily Construction Emissions 2 7.6 51 172 <1 23 12 SJVAPCD Daily Significance Threshold N/A N/A N/A N/A N/A N/A Construction Phase Annual Emissions (ton/year)
Site Preparation <1 <1 <1 <1 <1 <1
Grading <1 <1 <1 <1 <1 <1
Building Construction <1 4.8 15 <1 <1 <1
5 Construction Phase
Criteria Air Pollutant Emissions 1
ROG NOX CO SO2 PM10 PM2.5
Total Annual Construction Emissions <3 6.8 17 <3 <3 <3
SJVAPCD Annual Significance Threshold 3 10 10 100 27 15 15 Any Threshold Exceeded? No No No No No No
Construction Year 2024
Construction Phase Daily Maximum Emissions (lb/day)
Building Construction 6.8 48 152 <1 6.7 2.4
Paving <1 4.4 16 <1 <1 <1
Maximum Daily Construction Emissions 2 7.7 52 168 <1 7.2 2.7 SJVAPCD Daily Significance Threshold N/A N/A N/A N/A N/A N/A Construction Phase Annual Emissions (ton/year)
Building Construction <1 5.3 16 <1 <1 <1
Paving <1 <1 <1 <1 <1 <1
Total Annual Construction Emission <2 6.3 17 <2 <2 <2
SJVAPCD Annual Significance Threshold 3 10 10 100 27 15 15 Any Threshold Exceeded? No No No No No No
Source: CalEEMod Version 2020.4.0 (CAPCOA 2020).
Notes: Totals may not sum to 100 percent due to rounding. 1 Construction phasing is based on the preliminary information provided by the Applicant. Where specific information regarding proposed project-related construction activities was not available, construction assumptions were based on CalEEMod defaults. 2 In 2023, Grading and Building Construction phases overlap; in 2024, Building Construction and Paving phases overlap. 3 SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD 2015), Section 8.3, Table 2.
Operational Phase Emissions
Operational emissions associated with the Carbon Zero 1 Project are described in detail below. Emissions of permitted equipment/activities and non-permitted equipment/activities are considered separately in making significance determinations, as allowed by SJVAPCD (SJVAPCD 2015).
Stationary (Permitted) Sources
The following stationary equipment was considered in estimating the emissions of permitted sources:
• HydroFlexTM Unit (HFU). The HFU uses a hydro-treating process licensed by Haldor Topsøe to convert feedstock oils to sustainable aviation fuel (SAF) and renewable diesel (RD) products. The HFU conversion process consists of hydrogenation of the feedstock oils followed by separation of the hydrogen, hydrogen sulfide, and light end hydrocarbons from the heavier hydrocarbons containing the final products. The heavier hydrocarbons will be further processed by dewaxing and additional separation steps to ultimately yield heavy naphtha, RD, and SAF. 6 • Hydrogen Production Unit (HPU). The HPU will convert lighter naphtha byproducts and sweetened off-gas from the HFU into pure hydrogen using Haldor Topsøe Convection Reformer (HTCR) technology. The HPU will consist of a series of process reactors, including a Hydrotreater, Desulfurization Absorber, Pre-Reformer and Reformer, High Temperature Shift Converter, and a Pressure Swing Adsorber (PSA).
• Sour Gas Treatment Unit. The Sour Gas Treatment Unit consists of fixed-bed vessels arranged in a lead-lag configuration and will be used to remove hydrogen sulfide (H2S) and other sulfides from the off-gas stream generated in the upstream HFU. The solid iron oxide/hydroxide catalyst beds selectively targets sulfur compounds, converting them into iron sulfide and elemental sulfur. The catalyst will be changed every six months. The sweet gas from the reactors containing very little hydrogen sulfide will be compressed up to the Reformer feed gas pressure and will have a maximum sulfur content of less than 10 parts-per-million by volume (ppmv). • Storage Tanks. Storage tanks requiring permitting will be constructed with internal floating roofs for emissions control. Storage tanks handling permit-exempt materials will be constructed as vertical fixed roof tanks. The feedstock holding tanks will have activated carbon filters on the vents to control potential odors. Tanks containing feedstocks or refined products will be contained with berms, and will be equipped with foam systems for fire suppression. Tanks containing nonhazardous items such as water will not have secondary containment. • Auxiliary Boiler. The 59 MMBtu/hr auxiliary boiler, fired on natural gas, will generate additional steam for use by the Facility. A header system will distribute steam at different levels to steam users.
Steam is de-superheated with boiler feed water to meet the required conditions as steam is generated at a high pressure in the reformer and heat recovery steam generator (HRSG). Condensate is collected and returned to reduce make-up requirements. Low pressure condensate enters the LP condensate flash drum where the overhead is condensed.
• Cooling Tower. A cooling tower will receive recirculating cooling water return from various plant uses. The water will be pumped to a distributor at the top of the cooling tower, sprayed over the width of the tower, and allowed to trickle down through baffles. Fresh air drawn through the tower by a fan causes evaporative cooling of the water for distribution back to the plant. The baffles also function as drift eliminators, allowing entrained water droplets to condense and return to the water basin below.
• Wastewater Treatment Plant. The wastewater plant will be designed as a “Zero Liquid Discharge” (ZLD) facility. All wastewater streams from all units at the Facility will be processed in a multi-stage wastewater treatment plant for treatment and recovery. The wastewater plant includes a digester that creates vent digester gas. The digester gas will be routed to the thermal oxidizers during normal operation. Solids from the wastewater treatment plant will be sent to an offsite landfill for disposal. The wastewater treatment plant is an enclosed system, with no emissions points other than fugitive emissions and the thermal oxidizers. • Thermal Oxidizers. The site will include two 7.6 MMBtu/hr thermal oxidizers that will be used to combust the gases generated during plant operations that cannot be combusted in the flare. 7 • Standby Flare. The site will contain an emergency flare to combust process gases produced during process upsets and emergency situations. The flare will have a natural gas pilot, but will combust gases only during unplanned venting and not during normal operations.
Non-Permitted Sources
In addition to the permitted stationary equipment and activities that are part of the Carbon Zero 1 Project, as described above, emissions from non-permitted sources and activities, including area sources, energy consumption, and vehicles, were also considered in estimating operational emissions. Emissions from these non-permitted sources were estimated using refined off-model calculations based on data provided by the Applicant and emissions factors utilized by CalEEMod, such as mobile source emissions factors available in CARB’s EMFAC database. This strategy allowed for the determination of a more accurate emissions profile and refined emissions estimates reflecting the unique industrial parameters of the Facility.
Estimated Carbon Zero 1 Project Operational Emissions
The Carbon Zero 1 Project Description specifies that operations will result in the generation of up to 50 employee vehicle round-trips, and either seven (7) or 164 heavy-duty haul truck round-trips per day for deliveries and shipments, depending on whether railway transport of feedstocks and products supplants a portion of the projected truck trips. Both scenarios are considered in estimating operational mobile source emissions.
Given the Facility could operate under these two transportation scenarios, the estimated Carbon Zero 1 Project operational emissions were estimated for both the Rail & Truck and All Truck Scenarios, separately.
By evaluating the potential emissions for each of the two transportation scenarios, consideration of the worst-case operational emissions scenario for the Carbon Zero 1 Project is possible.
Total criteria pollutant emissions resulting from implementation of the Carbon Zero 1 Project, assuming both railcars and trucks will be used for product shipments and feedstock deliveries, are shown below in Table 3, Carbon Zero 1 Annual Operational Emissions – Rail & Truck Scenario (vehicle trip assumptions for this traffic activity scenario are presented in the Carbon Zero 1 Project Description, Table 5).
Table 3 Carbon Zero 1 Annual Operational Emissions – Rail & Truck Scenario Source
Annual Emissions (ton/year)
ROG NOx CO SO2 PM10 PM2.5
Component
Area 1 0.27 <0.001 0.001 0.0 <0.001 <0.001
Energy 2 — — — — — —
Mobile 3 0.05 0.51 0.66 0.006 0.03 0.03
Locomotive (Haul-Line and Switcher) 0.29 2.9 1.4 1.9 0.05 0.05 Annual Emissions (Non-Permitted Sources) 0.60 3.4 2.1 1.9 0.08 0.08 8 Source
Annual Emissions (ton/year)
ROG NOx CO SO2 PM10 PM2.5
SJVAPCD Threshold (Non-Permitted Sources) 4 10 10 100 27 15 15 Any Threshold Exceeded? No No No No No No
Stationary/Permitted Equipment 5, 6, 7 8.7 8.3 28 12 8.7 8.7 Annual Emissions (Permitted Sources) 8.7 8.3 28 12 8.7 8.7 SJVAPCD Threshold (Permitted Sources) 8 10 10 100 27 15 15 Any Threshold Exceeded? No No No No No No
Source: Geosyntec, 2023.
Note: Totals may not sum to 100 percent due to rounding. 1 Area source emissions were initially calculated in CalEEMod using default emission factors, then modified based on a more granular consumer products profile for industrial projects, as determined by CARB’s 2020 Consumer Product Emission Inventory Categories Update. Emissions were adjusted accordingly to seven percent of the values estimated by CalEEMod using default area source emission factors [CalEEMod Version 2020.4.0 (CAPCOA 2020)]. 2 Emissions resulting from natural gas usage indicated in CalEEMod estimates were not included, as emissions from sources burning natural gas are accounted for in stationary source emissions estimates. 3 Mobile source emissions were estimated using projected vehicle miles traveled (VMT), as detailed in the Project Description, and EMFAC emissions factors deemed applicable to the Project, as assessed by Trinity Consultants (2023). 4 SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD 2015), Section 8.3, Table 2 for Non-Permitted Sources.
5 Calculated using USEPA AP-42 emissions factors and equipment specifications provided by the Applicant. 6 Stationary source ROG emissions presented assume voluntarily compliance with the equipment leak standards of 40 CFR 63, Subpart H.
7 Stationary source NOX emissions presented assume the use of emissions control technology, including selective catalytic reduction (SCR) on the Reformer and Auxiliary Boiler.
8 SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD 2015), Section 8.3, Table 2, for Permitted Sources.
Total criteria pollutant emissions resulting from implementation of the Carbon Zero 1 Project, assuming only trucks will be used for shipments and deliveries (no rail activity), are shown below in Table 4, Carbon Zero 1 Annual Operational Emissions – All Truck Scenario (vehicle trip assumptions for this traffic activity scenario are presented in the Carbon Zero 1 Project Description, Table 4).
Table 4 Carbon Zero 1 Annual Operational Emissions – All Truck Scenario Source
Annual Emissions (ton/year)
ROG NOx CO SO2 PM10 PM2.5
Component
Area 1 0.27 <0.001 0.001 0.0 <0.001 <0.001
Energy 2 — — — — — —
Mobile 3 0.14 6.62 1.15 0.09 0.09 0.09
9 Source
Annual Emissions (ton/year)
ROG NOx CO SO2 PM10 PM2.5
Annual Emissions (Non-Permitted Sources) 0.41 6.62 1.15 0.09 0.09 0.09 SJVAPCD Threshold (Non-Permitted Sources) 4 10 10 100 27 15 15 Any Threshold Exceeded? No No No No No No
Stationary/Permitted Equipment 5, 6, 7 8.7 8.3 28 12 8.7 8.7 Annual Emissions (Permitted Sources) 8.7 8.3 28 12 8.7 8.7 SJVAPCD Threshold (Permitted Sources) 8 10 10 100 27 15 15 Any Threshold Exceeded? No No No No No No
Source: Geosyntec, 2023.
Note: Totals may not sum to 100 percent due to rounding. 1 Area source emissions were initially calculated in CalEEMod using default emission factors, then modified based on a more granular consumer products profile for industrial projects, as determined by CARB’s 2020 Consumer Product Emission Inventory Categories Update. Emissions were adjusted accordingly to seven percent of the values estimated by CalEEMod using default area source emission factors [CalEEMod Version 2020.4.0 (CAPCOA 2020)]. 2 Emissions resulting from natural gas usage indicated in CalEEMod estimates were not included, as emissions from sources burning natural gas are accounted for in stationary source emissions estimates. 3 Mobile source emissions were estimated using projected vehicle miles traveled (VMT), as detailed in the Project Description, and EMFAC emissions factors deemed applicable to the Project, as assessed by Trinity Consultants (2023). 4 SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD 2015), Section 8.3, Table 2 for Non-Permitted Sources.
5 Calculated using USEPA AP-42 emissions factors and equipment specifications provided by the Applicant. 6 Stationary source ROG emissions presented assume voluntarily compliance with the equipment leak standards of 40 CFR 63, Subpart H.
7 Stationary source NOX emissions presented assume the use of emissions control technology, including selective catalytic reduction (SCR) on the Reformer and Auxiliary Boiler.
8 SJVAPCD’s Guidance for Assessing and Mitigating Air Quality Impacts (SJVAPCD 2015), Section 8.3, Table 2, for Permitted Sources.
In summary, Tables 3 and 4 above demonstrate that when implementing either transportation scenario for operations of the Carbon Zero 1 Project, long-term annual criteria pollutant emissions from both permitted and non-permitted sources are both below SJVAPCD’s operational thresholds of significance. 10 References
California Air Pollution Control Officers Association (CAPCOA). 2020. California Emissions Estimator Model (CalEEMod) User’s Guide, Version 2020.4.0. Prepared by Trinity Consultants, South Coast Air Quality Management District, and other California Air Districts. Available:
http://www.caleemod.com/.
California Air Resources Board (CARB). 2021 (January). California EMission FACtors (EMFAC) Model, Version 1.0.2 (EMFAC2021). Available: https://arb.ca.gov/emfac/.
California Code of Regulations, Title 14. 2021 (December). Section 15064.7 - Thresholds of Significance.
Available: https://www.law.cornell.edu/regulations/california/14-CCR-Sec-15064-7.
City of Riverbank. 2013 (November). Riverbank Army Ammunition Plant (RAAP) Specific Plan EIR.
Available: https://www.riverbank.org/DocumentCenter/View/708/LRA-Specific-Plan-Final-EIR-.
SJVAPCD. 2015 (February). Guidance for Assessing and Mitigating Air Quality Impacts. Available:
https://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF.
Riverbank Industrial Complex CEQA Addendum to Final EIR Aemetis Carbon Zero 1 Project B-1 May 2023
Appendix B Greenhouse Gas Technical
Memo
1 Greenhouse Gas Emissions
The California Environmental Quality Act (CEQA) Guidelines do not specify that the Lead Agency responsible for reviewing a project under CEQA must establish numerical thresholds for determining whether the project’s greenhouse gas (GHG) emissions would have a significant impact on climate change, nor is it mandated that specific mitigation measures be implemented if the impacts are found to be significant (AEP 2022). Rather, the CEQA Guidelines rely on the discretion of the Lead Agency in developing appropriate criteria for evaluating the significance of impacts due to a project’s GHG emissions and employing reliable methods of assessment that are consistent with the methodologies used to determine the significance of impacts in other resource areas evaluated under CEQA. The criteria used by the Lead Agency in assessing the significance of a project’s impacts on climate change as a result of its GHG emissions must only follow the general recommendations provided in Appendix G of the CEQA Guidelines.
These recommendations specify that a project would have a significant environmental impact if it would:
1. Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment.
2. Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.
The San Joaquin Valley Air Pollution Control District (SJVAPCD) does not directly regulate GHG emissions through its stationary source permitting process, nor does it enforce specific GHG rules or regulations. However, SJVAPCD has adopted formal guidelines for reviewing a project under CEQA and determining the significance of the impacts on climate change that would result from GHG emissions generated during project construction and/or operations. These guidelines are presented in SJVAPCD’s Guidance for Valley Land-Use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA (SJVAPCD 2009).
In assessing the significance of a project’s GHG-related impacts during CEQA review, whether the project has implemented SJVAPCD’s recommended Best Performance Standards (BPS) for GHG-emitting sources is evaluated. The BPS were developed by SJVAPCD to ensure that a project implementing the BPS appropriate to each source type would have less-than-significant individual and cumulative impacts on climate change. If a project is found to meet the requirements of the applicable BPS, any impact it might have on climate change due to its GHG emissions would be considered less-than-significant.
As described in the SJVAPCD Guidance, BPS were developed for several source categories such that implementing the relevant BPS would result in at least a 29% reduction in GHG emissions compared to the “business-as-usual” (BAU) scenario that would result if the BPS requirements were not met. This was determined to be the minimum GHG reduction necessary to meet the targets of the California Air Resources Board’s AB 32 Scoping Plan, which at the time mandated a statewide reduction of GHG emissions to 1990 levels by 2020.
The SJVAPCD Guidance recommends the following hierarchy for evaluating the impact of a project with respect to its GHG emissions:
• Projects complying with an approved GHG emission reduction plan or GHG mitigation program, which avoids or substantially reduces GHG emissions within the geographic area in which the project is located, would be determined to have a less-than-significant individual and cumulative impact for GHG emissions. Such plans or programs must be specified in law or approved by the lead agency with jurisdiction over the affected resource and supported by a CEQA compliant environmental review 2 document adopted by the lead agency. Projects complying with an approved GHG emission reduction plan or GHG mitigation program would not be required to implement BPS. • Projects implementing BPS would not require quantification of project specific GHG emissions.
Consistent with the CEQA Guidelines, such projects would be determined to have a less-thansignificant individual and cumulative impact for GHG emissions. • Projects not implementing BPS would require quantification of project-specific GHG emissions and demonstration that project-specific GHG emissions reductions of at least 29%, compared to BAU.
Projects achieving at least a 29% GHG emission reduction compared to BAU would be considered to have a less-than-significant individual and cumulative impact for GHG emissions.
The Carbon Zero 1 Project (also referred to as the “Facility”) will be located within the former Riverbank Army Ammunition Plant (RAAP). On February 10, 2014, the Riverbank City Council adopted a Specific Plan for the RAAP Site and certified an EIR for the Specific Plan (City of Riverbank 2013). As part of the 2013 RAAP Specific Plan EIR and related technical evaluations, potentially significant impacts were determined for GHG emissions and as such, the RAAP Specific Plan EIR imposed a mitigation measure (GHG-1) to reduce impacts to less-than-significant. The current GHG Technical Report has been prepared to support a California Environmental Quality Act (CEQA) environmental checklist evaluation pursuant to California Public Resources Code (PRC) Section 21166 and CEQA Guidelines Section 15162.
Given the Facility will implement BPS applicable to the project, the impacts of the project’s GHG emissions on climate change are considered less-than-significant, as discussed above. Estimates of project-related GHG emissions presented in this technical report are thus not required by the Lead Agency or SJVAPCD for use in making significance determinations under CEQA. These data are provided in the spirit of transparency and should only be used for informational purposes.
Construction and Operational Emissions
Annual GHG emissions resulting from construction and operations of the Carbon Zero 1 Project were quantified using California Emissions Estimator Model (CalEEMod), Version 2020.4.0 (CAPCOA 2020), as well as mobile source emissions factors from the California Air Resources Board (CARB) EMission FACtors (EMFAC) Model, Version 1.0.2 (CARB 2021). Based on the most current construction scenario provided by the Applicant, construction of the Facility is anticipated to commence in early 2023, once all required permits and approvals are obtained, and will last approximately two years, reaching completion in late 2024. Sources of GHG emissions during construction include on-site building and site-preparation activities, material movement and storage, off-road equipment and vehicle use, and off-site mobile sources, including haul trucks, vendor trucks, and construction worker vehicles.
The Facility is expected to be operational by early 2025. Sources of operational GHG emissions include stationary sources, as further discussed in the Air Quality Technical Report (Appendix A), employee commutes, energy consumption, and GHGs associated with Facility water, waste, and wastewater streams.
Total GHG emissions resulting from construction and operations of the Carbon Zero 1 Project, assuming the use of both rail cars and trucks for product shipments and feedstock deliveries, are summarized below in Table 1, Carbon Zero 1 Annual GHG Emissions – Assuming Rail & Truck Activity. 3 Table 1 Carbon Zero 1 Project Annual GHG Emissions – Assuming Rail & Truck Activity Category GHG Emissions (Metric Tons per Year)
CO2 CH4 N2O CO2e
Construction Emissions
2023 Construction 2,375 0.37 0.015 2,389
2024 Construction 2,682 0.41 0.016 2,697
Total Construction Emissions 5,057 0.78 0.031 5,086
Operational Emissions
Stationary Biogenic Sources 1
Reformer Process — — — 273,007
Fuel Gas Combustion — — — 144,379
Total Biogenic Emissions — — — 417,386
Stationary Non-Biogenic Sources 1
Natural Gas Combustion — — — 52,887
Diesel Fuel Combustion 56 3.8 1.6 615
Total Non-Biogenic Emissions — — — 53,503
Area Sources 0.022 <0.01 0.0 0.023
Energy Usage 2 10,942 1.8 0.21 11,050
Mobile Sources 3 545 0.002 0.061 563
Solid Waste 4 13 0.74 0.0 31
Water and Wastewater 4 9.5 0.38 <0.01 22
Locomotive (Haul-Line and Switcher) 5 10,184 0.41 0.083 10,219 Total Annual Operational Emissions — — — 492,774
Source: Geosyntec, 2023.
Notes: Totals may not sum to 100 percent due to rounding. 1 Calculated using USEPA AP-42 emissions factors and equipment specifications provided by the Applicant. 2 GHG emissions resulting from natural gas usage were not included, as emissions from all sources burning natural gas (i.e. stationary sources) are accounted for in stationary source emissions estimates. 3 Mobile source emissions were estimated using projected vehicle miles traveled (VMT), as detailed in the Project Description, and EMFAC emissions factors deemed applicable to the Project. 4 CalEEMod Version 2020.4.0.
5 Calculated using a SJVAPCD-approved methodology for estimating locomotive emissions based on CARB emissions profiles and guidance provided to Trinity Consultants, which was incorporated into a proprietary emissions estimation tool developed by Trinity (Trinity 2023).
Total GHG emissions resulting from construction and operations of the Carbon Zero 1 Project, assuming only trucks are used for product shipments and feedstock deliveries, are summarized in Table 2 below, Carbon Zero 1 Project Annual GHG Emissions – Assuming Truck Activity Only. 4 Table 2 Carbon Zero 1 Project Annual GHG Emissions – Assuming Truck Activity Only Category GHG Emissions (Metric Tons per Year)
CO2 CH4 N2O CO2e
Construction Emissions
2023 Construction 2,375 0.37 0.015 2,389
2024 Construction 2,682 0.41 0.016 2,697
Total Construction Emissions 5,057 0.78 0.031 5,086
Operational Emissions
Stationary Biogenic Sources 1
Reformer Process — — — 273,007
Fuel Gas Combustion — — — 144,379
Total Biogenic Emissions — — — 417,386
Stationary Non-Biogenic Sources 1
Natural Gas Combustion — — — 52,887
Diesel Fuel Combustion 56 3.8 1.6 615
Total Non-Biogenic Emissions — — — 53,503
Area Sources 0.022 <0.01 0.0 0.023
Energy Usage 2 10,942 1.8 0.21 11,050
Mobile Sources 3 8,541 0.007 1.3 8,934
Solid Waste 4 13 0.74 0.0 31
Water and Wastewater 4 9.5 0.38 <0.01 22
Total Annual Operational Emissions — — — 490,926
Source: Geosyntec, 2023.
Notes: Totals may not sum to 100 percent due to rounding. 1 Calculated using USEPA AP-42 emissions factors and equipment specifications provided by the Applicant. 2 GHG emissions resulting from natural gas usage were not included, as emissions from all sources burning natural gas (i.e. stationary sources) are accounted for in stationary source emissions estimates. 3 Mobile source emissions were estimated using projected vehicle miles traveled (VMT), as detailed in the Project Description, and EMFAC emissions factors deemed applicable to the Project. 4 CalEEMod Version 2020.4.0.
Approximately 5,086 metric tons of carbon dioxide equivalents (MT-CO2e) will be emitted as a result of the project over its two-year construction period. As with the criteria pollutant emissions described in the Air Quality Technical Report (Appendix A), the generation of GHG emissions during construction of the Facility will be temporary, lasting only for the duration of the two-year construction period, and does not represent a long-term, continuous source of GHGs.
5 The estimated annual operational GHG emissions generated by the Facility are 492,774 MT-CO2e per year, assuming both trucks and locomotive-driven rail cars were used for product shipments and feedstock deliveries, and 490,926 MT-CO2e per year if only trucks were used. In alignment with SJVAPCD’s CEQA Guidance, the Facility will reduce its GHG emissions by implementing BPS, thereby reducing its impact on climate change.
The following Mitigation Measure from the project evaluated in the RAAP Specific Plan EIR is applicable.
Mitigation Measure GHG-1
The project [as described in the RAAP Specific Plan EIR] shall be analyzed for significant GHG impacts. The project will implement appropriate BPS or demonstrate a 29 percent GHG emission reduction compared to a business-as-usual (BAU) scenario. Means of mitigating GHG impacts to a less-than-significant level include, but are not limited to, technological controls for stationary sources (such as for boilers, generators, and process heaters), and GHG emissions reduction strategies (such as energy efficiency, transportation, and site design measures) for development projects listed in the SJVAPCD Climate Change Action Plan (CCAP, SJVAPCD 2008).
Consistent with Mitigation Measure GHG-1 of the RAAP Specific Plan EIR, representative SJVAPCD BPS that are deemed applicable to the Facility, as described below, will be implemented to reduce GHG emissions associated with the Carbon Zero 1 Project, thus aligning the project with California’s statewide GHG reduction goals.
SJVAPCD Best Performance Standards (BPS)
New Industrial Steam Generators (applies to 184 MMBtu/hr Reformer and 59 MMBtu/hr Auxiliary Boiler) • The steam generator shall be either equipped with an economizer system meeting the following design criteria or shall be equipped with an approved alternate heat recovery system which will collectively provide heat recovery from the boiler flue gas which is equivalent. • Equivalent heat recovery systems may utilize recovered heat for purposes other than steam generation provided such uses offset other fuel usage which would otherwise be required. • Except for steam generators subject to the requirements of item below, the economizer system shall be designed at maximum steam generator firing rate to either 1) reduce the temperature of the economizer flue gas outlet to a value no greater than 90°F above the temperature of the boiler feed water or 2) heat the boiler feed water to a temperature which is no less than the saturation temperature of the steam at the pressure of the steam separator, or 3) reduce the final temperature of the boiler’s flue gas to a temperature no greater than 300°F.
• For steam generators with rated capacity in excess of 20 MMBtu/hr which have an average water supply temperature which is equal to or less than 150°F, the steam generator shall be equipped with an economizer designed to reduce the temperature of the flue gas outlet to a value no greater than 90°F above the water supply temperature when the boiler is operating at maximum firing rate. • Electric motors driving combustion air fans or induced draft fans shall meet the National Electrical Manufacturer’s Association (NEMA) standards for “premium efficiency” motors and each one shall be operated with a variable speed control or equivalent for control of flow through the fan. 6 Petroleum Refineries, Gas Liquids Processing Facilities, and Chemical Plants • Minimize fugitive GHG emissions by applying leak standards and I&M requirements to components subject to Rule 4455 (Components at Petroleum Refineries, Gas Liquids Processing Facilities, and Chemical Plants).
Two 7.6 MMBtu/hr Thermal Oxidizers (Contaminated air stream ≤ 32 % LEL) • Direct Fired Thermal Oxidizer: A concentrator is not required for influent contaminated air streams with flow rates of less than 15,000 scfm, humidity levels of 80% or greater, temperatures of over 100 degrees F, air streams with VOCs that will not adsorb at a rate of at least 95% by weight, or air streams with VOCs that would damage or significantly diminish the performance of the adsorption material.
Additionally, the essential purpose of the Facility is to produce renewable diesel (RD) and sustainable aviation fuel (SAF), both of which have a low carbon intensity (CI) as compared to traditional petroleumbased fuels. The CI of a fuel is calculated based on a “lifecycle assessment” (LCA) of the fuel’s GHG emissions, which quantifies all GHG emissions that are associated with the fuel over its lifetime, including GHGs emitted during feedstock production and transportation, plant processes involved in fuel production, and the ultimate combustion of the fuel. Therefore, a fuel with a CI lower than traditional petroleum-based fuels necessarily reduces overall GHG emissions. The average CI for RD, measured in grams of carbon dioxide equivalent per megajoule (gCO2e/MJ), ranges from approximately 10 to 40 gCO2e/MJ (Riazi et al. 2020), while the CI for SAF ranges from approximately 20 to 40 gCO2e/MJ (Prussi, et al. 2021), depending on the specific lifecycle pathway and feedstocks. For reference, the CIs of conventional petroleum-based diesel fuel and jet fuel are roughly 95 gCO2e/MJ and 85-95 gCO2e/MJ, respectively.
Production of low-CI fuels such as RD and SAF as alternates to traditional fossil fuels will ultimately help California meet its Low Carbon Fuel Standard (LCFS) for transportation fuels. The LCFS program calculates the average CI of all transportation fuels used in the State, and sets CI reduction targets relative to the CI values of baseline fuels, which gradually decline each year. Per California Code of Regulations Title 17, Section 95484, Annual Carbon Intensity Benchmarks (17 CCR §95484), the 2025 target CI for SAF and RD is 86.6 gCO2e/MJ. The CI values for ultra-low-sulfur diesel (ULSD) fuel and conventional petroleum-based jet fuel, using 2010 as a base year, are 100.5 gCO2e/MJ and 89.4 gCO2e/MJ, respectively.
Fuels produced with a CI lower than the required benchmark set by the State help it meet the CI target.
The carbon intensities of RD and SAF produced by the Carbon Zero 1 Project are expected to be lower than other liquid fuels produced in the State of California, based on the LCA approach, and thus production of these low-CI fuels will help California in achieving a statewide reduction in GHG emissions as well as meeting its LCFS goals. In addition to supplying low-CI fuels to consumers, The Carbon Zero 1 Project will also implement BPS applicable to the Facility, as discussed above, including BPS for boilers, process heaters, chemical processing facilities, and other applicable equipment, and will thus be in alignment with the goals of the SJVAPCD CCAP and further help California meet its statewide GHG reduction goals. 7 References
Association of Environmental Professions (AEP). 2022. California Environmental Quality Act (CEQA) – Statute & Guidelines. Available:
https://www.califaep.org/docs/2022_CEQA_Statue_and_Guidelines.pdf.
California Air Pollution Control Officers Association (CAPCOA). 2020. California Emissions Estimator Model (CalEEMod) User’s Guide Version 2020.4.0. Prepared by Trinity Consultants, the South Coast Air Quality Management District, and the California Air Districts. Available:
http://www.caleemod.com/.
California Air Resources Board (CARB). 2021 (January). California EMission FACtors (EMFAC) Model, Version 1.0.2 (EMFAC2021). Available: https://arb.ca.gov/emfac/.
California Code of Regulations, Title 17. 2021 (December). Section 95484 - Annual Carbon Intensity Benchmarks. Available: https://www.law.cornell.edu/regulations/california/17-CCR-Sec-95484.
City of Riverbank. 2013 (November). Riverbank Army Ammunition Plant (RAAP) Specific Plan EIR.
Available: https://www.riverbank.org/DocumentCenter/View/708/LRA-Specific-Plan-Final-EIR-.
Prussi, Matteo, et al. 2021. CORSIA: The first internationally adopted approach to calculate life-cycle GHG emissions for aviation fuels. Renewable and Sustainable Energy Reviews 150 (2021):
111398. Available: https://doi.org/10.1016/j.rser.2021.111398.
Riazi, Bahar, et al. 2020. Renewable diesel from oils and animal fat waste: implications of feedstock, technology, co-products and ILUC on life cycle GWP. Resources, Conservation and Recycling 161: 104944. Available: https://doi.org/10.1016/j.resconrec.2020.104944 SJVAPCD. 2008 (November). SJVAPCD Climate Change Action Plan (CCAP). Available:
https://www.valleyair.org/Programs/CCAP/CAPP Staff Report 2008Nov12.pdf.
SJVAPCD. 2009 (December). Guidance for Valley Land-use Agencies in Addressing GHG Emission Impacts for New Projects under CEQA. Available:
https://www.valleyair.org/Programs/CCAP/12-17-09/3 CCAP - FINAL LU Guidance - Dec 17 2009.pdf.
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City of Riverbank
Planning Commission
Resolution No. 2023-010
A Resolution of the Planning Commission of the City of Riverbank Denying Use Permit 01-2023 for Aemetis Advanced Products Riverbank, Inc., Located at 5300 Claus Road, APNs: 062-031-005 & -011
Whereas, the proposed business location for a Sustainable Aviation Fuel/Renewable Diesel Production Plant (the “Facility”) is located within the City of Riverbank at 5300 Claus Road (APNs: 062-031-005 & -011) (the “Property”); and Whereas, the property has a General Plan Land Use Designation of Industrial / Business Park (I/BP); and
Whereas, Industrial / Business Park is the primary land use category for Riverbank to accommodate industrial uses located along major roadways on the periphery of existing and planned neighborhoods during the buildout of the General Plan; and Whereas, the property has a zoning designation of Riverbank Industrial Complex (RIC) Specific Plan RAAP-1, RAAP-2, RAAP-R; and
Whereas, staff had recommended that the Planning Commission find the Aemetis project consistent with the General Plan and specifically, Policies LAND-4.4, LAND-4.5, LAND-6.2, and CIRC-4.1.
Whereas, the Planning Commission reviewed the Riverbank Army Ammunition Plant Specific Plan EIR (State Clearinghouse Number 2011022015), including (a) the March 28, 2013, Public Review Draft EIR, (b) the November 2013, Final EIR, (c) November 2013, RAAP Specific Plan, and (d) the City of Riverbank, City Council Resolution 2014-006, certifying the RAAP Specific Plan EIR, making CEQA findings, and adopting a Mitigation Measures and Monitoring Program; and Whereas, the City of Riverbank is the lead agency pursuant to CEQA for the current project, and the Planning Commission has decision making authority for the City of Riverbank with respect to the project; and
Whereas, the Planning Commission reviewed the CEQA Addendum to the Riverbank Army Ammunition Plant EIR that was prepared for the project; and Whereas, the Planning Commission heard this item at their July 18, 2023 meeting, opened public comment, closed public comment, then continued this item to the August 15, 2023 meeting with a 5-0 vote due to technical difficulties with the posting of the agenda.
Therefore, Be It Resolved that, against staff recommendation to approve it, the Planning Commission hereby denies CUP 01-2023 for Aemetis Advanced Products Riverbank, Inc.
ATTACHMENT 4
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PASSED AND ADOPTED by the Planning Commission of the City of Riverbank at a meeting held on the 15
th of August, 2023; motioned by Commissioner Dinan,
seconded by Chair Basso, and upon roll call was denied by the following vote of 3-2:
AYES: Chair Basso and Commissioner Reuben
NAYS: Commissioners: Dinan, Zamora, Stewart
ABSENT: None
ABSTAIN: None
Attest: Approved:
Donna M. Kenney Natasha Basso
_________________________ __________________________
Donna M. Kenney, Secretary Natasha Basso, Chairperson
Planning and Building Manager Planning Commission