CITY OF ROCKLIN
MEMORANDUM
DATE: April 23, 2024
TO: City Council
FROM: David Mohlenbrok, Community Development Director
Bret Finning, Planning Services Manager
Nathan Anderson, Senior Planner
RE: Whitney Ranch Retail
Item #4C
Additional Project Information/Correspondence
Subsequent to the publication of the 4/23/24 City Council agenda, staff received additional information/correspondence, as follows:
1) The applicant team has provided additional information regarding their request to increase the allowed height of parking lot lighting.
2) On 4/22 /24, staff received public comments challenging the CEQA Ad dendum which was prepared for the project.
3) On 4/23/24, the environmental consultant provided a response to the public comments from 4/22/24.
These three items are attached to this memorandum.
In addition, the applicant and staff are proposing to modify Design Review Condition of Approval #21(d), as shown below. The proposed modifications are shown in red.
COA#21(d). If the City of Rocklin or Placer County do not construct roadway widening and associated street improvements on Whitney Ranch Parkway between the City limit line and the intersection of Whitney Ranch Parkway/University Avenue all as shown in Exhibit B, the developer shall construct the roadway widening and associated street improvements to its ultimate configuration to the City Engineer’s satisfaction and seek later obtain reimbursement from the City of Rocklin for that portion of the roadway wideni ng and street improvements that the County -led Placer Parkway project would have otherwise constructed. Following approval of the Whitney Ranch Retail project by the City Council, City and Developer shall continue to coordinate how the Whitney Ranch Retail project interfaces with planned roadway improvements on Whitney Ranch Parkway. Coordination meet ings shall occur at least monthly. Should the City transition the Whitney Ranch Parkway Widening project to the Developer, the Developer shall complete the design and implement construction of improvements.
City Council Blue Memo
Whitney Ranch Retail
April 23, 2024
The City shall provide a minimum of 30 days advance notice of its intent to transition the Whitney Ranch Parkway Widening project to the Developer.
Frontage improvements on Whitney Ranch Parkway that are contiguous with the developer’s project, including but not limited to, concrete vertical curb, gutter pan, sidewalk, and drainage improvements, and which were never part of the Placer Parkway project shall be constructed and paid for at the developer’s sole expense with no opportunity to seek reimbursement. The developer is hereby made aware that under this scenario, and in order to seek reimbursement using public funds, the developer must adhere to and follow a public bidding process and administer a construction contract in accordance with the California Public Contract Code, including paying the construction contractor the prevailing wage rates as set forth by the California Department of Industrial Relations. Prevailing wage rate work only applies to developer -constructed work in the existing public right -of-way on Whitney Ranch Parkway for which the Developer may seek reimbursement as set forth in this paragraph if, and only if, the City of Rocklin or Placer County do not construct roadway widening and associated street improvements. Developer - constructed work for which the developer will not or cannot seek reimbursement is not subject to prevailing wage rates, including construction of Road A and off -site improvements along University Avenue. (ENGINEERING, PLANNING)
Item 1 – Lighting Request:
Current Design Review COA #8:
All exterior lighting shall be designed and installed to avoid adverse gla re on adjacent properties. Cut -off shoebox type or decorative lighting fixtures, or equivalent, shall be used and mounted such that all light is projected directly toward the ground. Light poles shall be a maximum of 20 feet in height as measured from grad e to the top of the light.
The lighting design plan shall be approved by Community Development Director for compliance with this condition. (PLANNING)
Applicant Request:
Our current shopping center design includes 123 25-foot poles. We request the City allow this current design that includes 25 -foot poles, as opposed to the 20 -foot poles the City generally prefers. The project has been designed to mitigate adverse glare on each of the adjacent properties. The following are several factors that we ask th e City to consider when contemplating acceptance of our proposed design:
1. Along University Avenue, the site sits approximately 5 -feet below street level (please see cross sections 1 and 2 on sheet Sec 2 of the preliminary civil plans).
2. Lights will be dimmed unless activated by motion.
3. If required to reduce the pole height to 20 -feet, the project would need to significantly increase the number of poles. This would be necessary in part to provide adequate lighting within the parking lot and internal walkways as required by most tenants (and as preferred by most law enforcement).
4. The planned layout of the 25 -foot fixtures is designed to avoid glare on adjacent properties. We understand the current layout allows for footcandles to drop to 0. 1 at the property line, avoiding glare on adjacent properties – but at the same time, assuring adequate footcandles in the drive aisles and internal walks.
5. Adjacent to the shopping center, the public street lights that are currently located and are planned to be located along the ROW adjacent to the center -- on Whitney Ranch Parkway and University Avenue (where street level is approximately 5-feet higher than the site) -- are set at 30-feet. This is 5 feet higher than the light poles proposed within the s hopping center, and does not contemplate the lower topography of the site itself. Please see figure below illustrating the 30 -foot street lights in the public ROW:
Comment from project landscape architect, Steve Fuhrman:
With regards to site lighting, and mounting height (MH) used depends upon your perspective and point of view for using it. Our 25’ MH is dependent upon our site-specific lighting needs, the area we are illuminating, while considering the potential for obstruction from trees. The 5’0” higher MH reduces the number of poles needed by approximately 20%, which is favorable for tree locations and quantity needed for parking lot shading.
We have to consider the trade-offs between coverage, intensity, and aesthetics in parking lots and in this case used a slightly higher pole when making this decision. With the site being over 5’0’ lower than the developed edges of the site, the site location adjacent to the freeway and major arterials, not adjacent to single family residential development, and needing to achieve 50% parking tree shading, the optimal height for this project is to use a 25’ MH. The selection of the tree was also considered, and optimally we are using tree forms in the parking lot that are generally considered more upright than spreading, meaning less opportunity to obstruct light intensity in the future as they mature.
Staff Response:
The Citywide Design Guidelines state that smaller scale parking lot lights instead of fewer, overly tal l and large parking lot lights should be installed. The City has utilized the standard 20-foot condition of approval for over 20 years, so it will ultimately be up to the City Council to grant this deviation. Staff recommends the standard language remain as written in the condition of approval.
April 22, 2024
By Email
Mayor Greg Janda
Members of the City Council
c/o City Clerk
City of Rocklin
3970 Rocklin Road
Rocklin, CA. 95677
Email: [email protected]
Re: Whitney Ranch Retail / General Development Plan Amendment, PDG2024-0001; Conditional Use Permit, U2023-0003; Design Review, DR2023-0001; Tentative Parcel Map, DL2024-0001 and Environmental, ENV2024-0001
Dear Mayor Janda and Councilmembers:
Please accept and consider the following comments and concerns, submitted on behalf of Stop the Rocklin Expansion, an unincorporated association of Rocklin citizens, environmental groups, members of the United Food and Commercial Workers Union Local 8 and Rocklin residents Mark Stewart, Doug McDowell, and Erik Steinkamp. As explained below, the Whitney Ranch Retail Project (“Project”) cannot be lawfully approved based on only an Addendum to the 2002 Final EIR for the Northwest Rocklin Annexation (Sunset Ranchos) (“2002 EIR”). In the 22 years that have lapsed since that time, substantial changes have occurred with respect to the Project itself, and to the circumstances under which it is being developed, such that the Project may and likely will have new significant impacts that have not been disclosed, evaluated, or mitigated previously. For this reason, CEQA requires the City to prepare and circulate a supplemental or subsequent EIR for public review and comment before it may take action to approve the development entitlements sought. The City Council should therefore DECLINE to approve the Project at this time.
The Addendum Fails to Include a Health Risk Assessment for Diesel Exhaust Omissions During the Project’s Operational Phase
Item 2
Rocklin City Council
In 1998, the California Air Resources Board (“CARB”) identified DPM as a toxic air contaminant (“TAC”) based on published evidence of a relationship between diesel exhaust exposure and lung cancer and other adverse health effects. In 2012, additional studies on the cancer-causing potential of diesel exhaust published since CARB’s determination led the International Agency for Research on Cancer to list diesel engine exhaust as “carcinogenic to humans.” This determination was based primarily on evidence from occupational studies that show a link between exposure to DPM and lung cancer induction, as well as death from lung cancer. Because it is part of PM2.5, DPM also contributes to the same non-cancer health effects as PM2.5 exposure. These effects include premature death, hospitalizations, and emergency department visits for exacerbated chronic heart and lung disease, including asthma, increased respiratory symptoms, and decreased lung function in children. Several studies suggest that exposure to DPM may also facilitate development of new allergies.
Those most vulnerable to non-cancer health effects are children whose lungs are still developing and the elderly who often have chronic health problems. (See CARB (2021) Overview: Diesel Exhaust and Health; excerpt attached as Attachment 1.)
Although the 2002 EIR analyzed air quality impacts from construction and operation of the Sunset Ranchos proposal, its analysis focused on impacts from smog-causing criteria pollutant emissions, which was standard practice at the time. The analysis did not include a quantitative assessment of health risks to nearby residents stemming from exposure to diesel particulate matter (“DPM”) emissions from the heavy-duty diesel delivery trucks, individually or cumulatively. An earlier addendum to the 2002 EIR for “Whitney Ranch Phase II” likewise did not evaluate health impacts from DPM emissions.
The current Addendum’s Air Quality and Greenhouse Gas Impact Analysis (“AQA”) affirms that DPM is a carcinogenic TAC, and acknowledges that “[i]mplementation of the proposed project would result in emissions of TACs related to project construction, operations of the proposed [gasoline station], an increase in heavy truck traffic, or being located on a site which includes natural asbestos.” (AQA, p. 13, underline added.) The AQA also discloses that “[o]perations of the proposed project would involve heavy-duty truck trips to and from the project site associated with transporting goods to the proposed retail uses.” (AQA, p. 15.) The AQA then concludes, with no quantitative analysis whatsoever, that because the Project would allegedly draw fewer than 100 diesel truck deliveries per day, and because those trucks would be subject to idling limitations, “the Project would not expose sensitive receptors to substantial pollutant concentrations associated with heavy-duty trucks during operations.” (Id.)
Rocklin City Council
Such perfunctory discussion of potential impacts to sensitive receptor populations in the residential areas adjacent to the Project site is inadequate under CEQA. Not only does the Addendum fail to include a quantitative health risk assessment (“HRA”) it completely ignores cumulative health effects resulting from the addition of Project-caused DPM and TAC emissions to existing DPM/TAC concentrations in the vicinity. There is no defensible reason why the Addendum or AQA could not include a standard risk assessment that evaluates the Project’s diesel trucks’ incremental contribution to the existing health effects impacting residents near the Project and Highway 65. As explained below, the methodology for doing so is straightforward, and the necessary data are publicly available.
Caltrans publishes daily truck traffic data for all State highways, including Highway 65 in Rocklin. These data are available at https://dot.ca.gov/programs/traffic- operations/census. The most recent data show over 11,000 trucks traveling each day on Highway 65 at the junction with I-80 north of the Project site. Although neither the Addendum nor the AQA report the number of daily diesel truck deliveries to the proposed Project (itself a serious information deficiency), these numbers can be deduced from data included in the Addendum’s Transportation Impact Analysis (“TIA”) and Environmental Noise Assessment (“ENA”). The TIA states: “the proposed project is anticipated to generate 15,725 daily external trips, with 1,289 trips in the a.m. peak hour and 1,408 trips in the p.m. peak hour.” (TIA, p. 18.) The ENA, meanwhile, states: “[t]he commercial component of the project is projected to generate 1,285 trips in the afternoon peak hour (KD Anderson & Associates) [;] Saxelby Acoustics assumed that 2% of these trips could be trucks.” (ENA, p. 10.) Thus, it is reasonable to assume that the Project will generate at least 306 daily truck trips.
With this information in-hand, it becomes a routine exercise to model DPM emissions and resulting health risks using the CARB’s publicly available EMFAC model, 1 the AERMOD dispersion model, and the Office of Environmental Health Hazard Assessment (OEHHA)’s HARP risk model.2 Indeed, OEHHA’s CalEnviroScreen mapping tool3) shows that DPM concentrations in Rocklin near the Project site are already above average, situated between the 50th and 60th percentile Statewide. See below and Attachment 2. This suggests there is already an existing significant cumulative air quality impact with respect to DPM
1 Available at: https://arb.ca.gov/emfac/2017/
2 Available at: https://oehha.ca.gov/air/crnr/notice-adoption-air-toxics-hot-spots-program- guidance-manual-preparation-health-risk-0
3 Available at: https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 Rocklin City Council
emissions affecting the health of residents living near the Project and within 1,000 feet of Highway 65, even without the Project.
Attached as Attachment 3 is a report from Raman Kapahi, a specialist in air quality and health risk assessment in the CEQA context, having prepared numerous HRAs for development projects in California. Using the data methodology described above, Mr.
Kapahi calculated the Project’s individual and cumulative cancer risk scores to be well in excess of the applicable significance thresholds for TAC-related health risks. This is a new significant impact that was never disclosed, evaluated, or mitigated in the 2002 EIR or in either of its Addenda. As discussed below, CEQA requires preparation of a subsequent or supplemental EIR under these circumstances.
CEQA Requirements for Preparing Subsequent or Supplemental EIRs
Where a project for which an EIR has been certified is later modified, or the circumstances under which it is to be carried out change, the lead agency must determine whether to: (a) prepare a subsequent or supplemental EIR; (b) prepare an addendum to the Rocklin City Council
previously certified EIR, or (c) treat the modification as a new project and perform a new, independent environmental review under CEQA. (Save Our Neighborhood v. Lishman (2006) 140 Cal.App.4th 1288, 1295-1297.) The lead agency must prepare a subsequent or supplemental EIR and circulate it for public review and comment prior to approving any post-certification modification to a project if one or more of the following events occurs:
“(a) Substantial changes are proposed in the project which will require major revisions of the [EIR].
“(b) Substantial changes occur with respect to the circumstances under which the project is being undertaken which will require major revisions in the [EIR].
“(c) New information, which was not known and could not have been known at the time the [EIR] was certified as complete, becomes available.” Pub. Resources Code § 21166; CEQA Guidelines, § 15162.
If, however, only “minor technical changes or additions” are necessary, or none of the conditions described above calling for preparation of a subsequent EIR have occurred, then the agency may prepare an addendum to the original EIR, which notably it need not circulate for public review and comment. (Guidelines, § 15164.)
Here, the Addendum and AQA simply fail to undertake any assessment of potential cumulative health risks result from exposure to the Project’s DPM emissions in combination with existing emissions from truck traffic on Highway 65. Meanwhile, Mr. Kapahi’s analysis shows new significant cumulative health impacts resulting from the Project. This information and analysis constitute new information of substantial importance showing that that substantial changes have occurred with respect to the circumstances under which the Project is being undertaken which will require major revisions in the 2002 EIR. CEQA therefore requires the City to prepare a subsequent or subsequent EIR that includes a health risk assessment before taking action to approve the Project.
The Addendum Also Fails to Consider Potential Urban Decay Impacts
In 2004, after the 2002 EIR was certified, the Court of Appeal publishes its opinion in Bakersfield Citizens v. City of Bakersfield (2004) 124 Cal.App.4th 1184. This case affirmed that CEQA requires public agencies considering larger-scale retail developments to consider potential impacts relating to urban decay. The Court recognized two pertinent questions to Rocklin City Council
be asked regarding the potential urban decay-related effects of a proposed project: 1) would the proposed new retail uses result in sales losses that are sufficiently large at existing retail establishments to force some to close; and 2) would the affected closed stores stay idle long enough to create physical changes that could be defined as urban decay?
Because supermarkets often anchor larger retail centers or neighborhood strips, their closure and subsequent loss of significant customer traffic (supermarkets typically generate far more daily shopping trips than other forms of retail) can produce a domino effect leading to closures of other retailers and resulting urban decay. Given the existing supply of grocery stores in Rocklin (see map, below), the addition of yet another Nugget Market as part of the Project here creates the potential for an existing store to close, giving rise to urban decay effects. A meaningful analysis of the potential for this Project to cause or contribute to the closure of other nearby markets is therefore critical.
Because the duty to consider urban decay effects under CEQA did not solidify until after the 2002 EIR was certified, the foregoing also constitutes new information showing a significant change in circumstances requiring major changes to the 2002 EIR. It would thus be improper for the City to approve the Project in reliance on a mere addendum to that EIR.
Therefore, the City should prepare and circulate a subsequent EIR that adequately evaluates the Project’s potential urban decay impacts.
Rocklin City Council
Finally, we note that the practical consequence of the City’s reliance on an Addendum to the 2002 EIR is that the City has not subjected the new studies appended to it, or any other newly generated information, to formal public and agency scrutiny during a designated comment period. CEQA establishes mandatory information disclosure and public participation procedures to ensure that decision-makers and the public are informed of a project’s impacts, and that the public can evaluate and respond to the proposed actions of their elected representatives before those actions are taken. (CEQA Guidelines, § 15002(a).) Public participation “is an essential part of the CEQA process.” (Guidelines, §§ 15002(j), 15201. “Public review provides the dual purpose of bolstering the public’s confidence in the agency’s decision and providing the agency with information from a variety of experts and sources.” Schoen v. Cal. Dept. of Forestry & Fire Prot. (1997) 58 Cal.App.4th 556, 574.)
For all these reasons, we respectfully urge the City Council to DECLINE to approve the Project at this time, and instead to direct staff to prepare and publicly circulate a subsequent or supplemental EIR that adequately evaluates the Project’s individual and cumulative impacts on human health and urban decay.
Thank you for your consideration of these concerns.
Sincerely,
Stop the Rocklin Expansion
Stop the Rocklin Expansion
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CATEGORIES
Health, Air Pollution, Cars & Trucks, Construction & Earthmoving Equipment, Environmental Justice, Oceangoing Vessels & Harbor Craft, Freight & Goods Movement, Trains & Railyards, Transit, VW Diesel Vehicles Exposure, Community Air Protection Program , Community Health, Zero-Emission Powertrain Certification, Alternative Diesel Fuels, In-Use Off-Road Diesel-Fueled Fleets Regulation, Study of Neighborhood Air near Petroleum Sources, School Buses Information
CONTACT
Research Division
[email protected]
(916) 445-0753
Overview: Diesel Exhaust & Health
Background
Diesel engines emit a complex mixture of air pollutants, including both gaseous and solid material. The solid material in diesel exhaust is known as diesel particulate matter (DPM).
More than 90% of DPM is less than 1 µm in diameter (about 1/70 the diameter of a human hair), and thus is a subset of particulate matter less than 2.5 microns in diameter (PM2.5). Most PM2.5 derives from combustion, such as use of gasoline and diesel fuels by motor vehicles, burning of natural gas to generate electricity, and wood burning. PM2.5 is the size of ambient particulate matter air pollution most associated with adverse health effects of the air pollutants that have ambient air quality standards. These health effects include cardiovascular and respiratory hospitalizations, and premature death. As a California statewide average, DPM comprises about 8% of PM2.5 in outdoor air, although DPM levels vary regionally due to the non-uniform distribution of sources throughout the state.
DPM is typically composed of carbon particles (“soot” , also called black carbon, or BC) and numerous organic compounds, including over 40 known cancer-causing organic substances. Examples of these chemicals include polycyclic aromatic hydrocarbons, benzene, formaldehyde, acetaldehyde, acrolein, and 1,3-butadiene. Diesel exhaust also contains gaseous pollutants, including volatile organic compounds and oxides of nitrogen (NO ). NO emissions from diesel engines are important because they can undergo chemical reactions in the atmosphere leading to formation of PM2.5 and ozone.
Most major sources of diesel emissions, such as ships, trains, and trucks operate in and th
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around ports, rail yards, and heavily traveled roadways. These areas are often located near highly populated areas. Because of this, elevated DPM levels are mainly an urban problem, with large numbers of people exposed to higher DPM concentrations, resulting in greater health consequences compared to rural areas. A large fraction of personal exposure to DPM occurs during travel on roadways. Although Californians spend a relatively small proportion of their time in enclosed vehicles (about 7% for adults and teenagers, and 4% for children under 12), 30 to 55% of total daily DPM exposure typically occurs during the time people spend in motor vehicles.
Diesel Particulate Matter and Health
The majority of DPM is small enough to be inhaled into the lungs. Most inhaled particles are subsequently exhaled, but some deposit on the lung surface. Although particles the size of DPM can deposit throughout the lung, the largest fraction deposits in the deepest regions of the lungs where the lung is most susceptible to injury.
In 1998, CARB identified DPM as a toxic air contaminant based on published evidence of a relationship between diesel exhaust exposure and lung cancer and other adverse health effects. In 2012, additional studies on the cancer-causing potential of diesel exhaust published since CARB’s determination led the International Agency for Research on Cancer (IARC, a division of the World Health Organization) to list diesel engine exhaust as “carcinogenic to humans” . This determination is based primarily on evidence from occupational studies that show a link between exposure to DPM and lung cancer induction, as well as death from lung cancer. Download the IARC report (external site).
Because it is part of PM2.5, DPM also contributes to the same non-cancer health effects as PM2.5 exposure. These effects include premature death, hospitalizations and emergency department visits for exacerbated chronic heart and lung disease, including asthma, increased respiratory symptoms, and decreased lung function in children. Several studies suggest that exposure to DPM may also facilitate development of new allergies. Those most vulnerable to non-cancer health effects are children whose lungs are still developing and the elderly who often have chronic health problems.
Estimated Health Effects of DPM in California
DPM has a significant impact on California’s population. It is estimated that about 70% of total known cancer risk related to air toxics in California is attributable to DPM. Based on 2012 estimates of statewide exposure, DPM is estimated to increase statewide cancer risk ! "#$%&'()*+,
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by 520 cancers per million residents exposed over a lifetime. Non-cancer health effects associated with exposure to DPM (based on 2014 - 2016 air quality data) are shown in the table below.
Health Effect
Estimated Annual Number of
Cases*
Cardiopulmonary Death 730 (570 – 890)
Hospitalizations (Cardiovascular and
Respiratory)
160 (20 – 290)
Emergency Room Visits for Asthma 370 (240 – 510)
*Values in parenthesis indicate 95% confidence interval.
More Information
Trends in Outdoor Levels of DPM
The figure below shows the trend in ambient DPM. CARB regulations** of diesel engines and fuels have had a dramatic effect on DPM concentrations. Since 1990, DPM levels have decreased by 68%. The figure also shows which regulations have had the greatest impact on DPM.
DPM levels are expected to continue declining as additional controls are adopted, and the number of new technology diesel vehicles increases.
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**Abbreviations of CARB regulations used in table: HDV Engine STD = Heavy-duty diesel truck engine standard; HDV - Off road = Heavy-duty off-road diesel engines; Port rule = Port (drayage) trucks; PSIP = Periodic self-inspection program; Transit bus = Urban transit buses; ULSD = Clean diesel fuel
The figure below shows that despite the increased number of vehicle miles traveled by diesel vehicles (VMT , red line), and despite increases in statewide population (green line) and gross state product (GSP , a measure of growth in the state’s economy, light blue line), CARB’s regulatory programs still led to a decline in statewide cancer risk (dark blue line). ! "#$%&'()*+,
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Additional Information
CARB’s diesel programs
CARB’s diesel mobile vehicles and equipment activities
CARB’s freight transport, ports and rail programs
California's diesel fuel program
Other diesel-related programs
Selected references on diesel-related health effects
Environmental Effects of Diesel Exhaust
In addition to its health effects, diesel exhaust significantly contributes to haze that reduces visibility by obscuring outdoor views and decreasing the distance over which one can distinguish features across the landscape. Researchers have reported that in the San Joaquin Valley and in southern California, diesel engines contribute to a reduction in visibility. This decrease in visibility is caused by scattering and absorption of sunlight by particles and gases present in diesel emissions.
DPM also plays an important role in climate change. A large proportion of DPM is composed of BC. Recent studies cited in the Intergovernmental Panel on Climate Change ! "#$%&'()*+,
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report estimate that emissions of BC are the second largest contributor to global warming, after carbon dioxide emissions. Warming occurs when BC particles absorb sunlight, convert it into infrared (heat) radiation, and emit that radiation to the surrounding air. A recent California-specific study showed that the darkening of snow and ice by BC deposition is a major factor in the rapid disappearance of the Sierra Nevada snow packs. Melting of the snow pack of the Sierra Nevada earlier in the spring is one of the contributing factors to the serious decline in California’s water supply. As additional DPM controls are adopted, and the number of new technology diesel vehicles increases, BC emissions will continue to decline.
Conclusions
Although progress has been made over the past decade in reducing exposure to diesel exhaust, diesel exhaust still poses substantial risks to public health and the environment.
Efforts to reduce DPM exposure through use of cleaner-burning diesel fuel, retrofitting engines with particle-trapping filters, introduction of new, advanced technologies that reduce particle emissions, and use of alternative fuels are approaches that are being explored and implemented. CARB anticipates that newly adopted diesel exhaust control measures will reduce population exposure even further, and that as the sustainable freight program expands, population exposure to diesel exhaust pollution will decrease even further. It is estimated that emissions of DPM in 2035 will be less than half those in 2010, further reducing statewide cancer risk and non-cancer health effects.
RELATED RESOURCES
Public Workshop
Notice on March 16,
2021 - Espanol
Public Workshop
Notice on March 16,
2021
SNAPS Lost Hills
Newsletter - February
2021 ! "#$%&'()*+,
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TECHNICAL MEMORANDUM
To: Mark R. Wolfe Date: April 21, 2024 Attorney at Law
M. R. Wolfe & Associates, PC
San Francisco, CA 94104
From: Ray Kapahi RK
Tel: 916-687-8352
E-Mail: [email protected]
https://www.epsconsulting.org/
Subject: Screening Level Cancer Risks Adjacent to State Route 65 Placer County, CA
INTRODUCTION
We have completed our analysis of existing and cumulative cancer risks in the vicinity of State Route (SR) 65 in Placer County. The analysis is related to the development of the Whitney Ranch Retail Project to be located East of SR 65 and South of Whitney Ranch Road. As described in the 2024 Addendum to the 2002 final environmental impact report (EIR) for the Northwest Rocklin Annexation, the project includes development of a new shopping center with 10 buildings totaling 94,500 square feet (sf) of retail building space and a total of 665 parking stalls.
Our analysis focused on a 0.6 mile segment of SR 65 West of the project site (Figure 1). Truck emissions along this segment of the highway were calculated to determine future health impacts to nearby residents as a result of the proposed development. The objective of this analysis is to determine if existing and future residents and workers at the Whitney Ranch Retail project would be exposed to significant cancer risks from exposure to current and future truck emissions.
The following steps were used to calculate cancer risk from truck emissions along SR 65:
2 1. Determine current (baseline) and incremental daily truck volumes
2. Calculate diesel particulate matter (DPM) emissions from trucks. DPM is regulated as a carcinogen by the State of California
3. Calculate the cancer risk scores from exposure to truck emissions
These steps are discussed in this Memo. Supporting data and calculations are attached.
ESTIMATE OF ANNUAL TRUCK TRAFFIC AND EMISSIONS
For current truck volumes, we relied on traffic data along SR 65 collected by the California Department of Transportation (Caltrans). The most recent data available is for 2022. 1 These data indicate that 11,325 trucks per day travel on SR 65 near the intersection of I- 80 (Table 1).
This is 3.5 miles from the project site and is considered a reasonable approximation of traffic volume near the project location, as SR 65 is a main artery connecting I-80 and SR 99 at Yuba City.
To estimate future truck volumes associated with the project, we reviewed the Addendum to the Final Environmental Impact Report, the Transportation Impact Analysis (TIA) and Environmental Noise Assessment (ENA) and Traffic Impact Analysis. The TIA states that the project is anticipated to generate 15,725 daily external trips, with 1,289 trips in the a.m. peak hour and 1,408 trips in the p.m. peak hour. (TIA, p. 18.) The ENA states that commercial component of the project is projected to generate 1,285 trips in the afternoon peak hour (KD Anderson & Associates), while assuming that 2% of these trips could be trucks.” (ENA, p. 10.) Thus, it is reasonable to assume that the Project will generate 306 daily truck trips.
We next relied on truck emissions data compiled by the California Air Resources Board (CARB) to calculate annual emissions of DPM. These data provide emission rates of DPM in terms of grams per mile, We used emissions data for heavy duty diesel trucks calendar year 2024. An excerpt of the emissions data generated using the EMFAC emissions model, are provided in Table 2.
On the basis of the 11,325 trucks per day, it is estimated the annual emission rate of DPM is 157.2 pounds per year and an incremental increase in 9.8 pounds per year. The detailed calculations are provided in Table 3.
CALCULATION OF CANCER RISK SCORE
A screening level health risk analysis was prepared to determine health risks to future residents from exposure to DPM. A screening level health risk analysis is a simplified calculation to determine if a project is likely to cause significant health risks to residents living near the
1 Caltrans ’ data are available on its website: https://dot.ca.gov/programs/traffic- operations/census
3 project site. By its nature, a screening level HRA is a conservative estimate of actual risks. If the screening level HRA indicates significant health risks, then a refined risk assessment is prepared.
A cancer risk score above 10 indicates significant health risk.2
We calculated the existing and project related cancer risk score based on DPM toxicity factor recommended by the Office of Environmental Health Hazard Assessment (OEHHA 2015) and procedures recommended under AB-2588. Detailed calculations are provided in Tables 4 and 5 and are summarized below.
Summary of Existing Cancer Risk Score
Distance Cancer Risk Score
(Meters) (Feet)
0 to 100 0 to 328 363
100 to 250 328 to 820 90.8
250 to 500 820 to 1,640 14.5
500 to 1000 1,640 to 3,280 3.99
Summary of Incremental Cancer Risk Score
Distance Cancer Risk Score
(Meters) (Feet)
0 to 100 0 to 328 22.6
100 to 250 328 to 820 5.66
250 to 500 820 to 1,640 0.906
500 to 1000 1,640 to 3,280 0.249
Summary of Cumulative Cancer Risk Score
Distance Cancer Risk Score
(Meters) (Feet)
0 to 100 0 to 328 385.6
100 to 250 328 to 820 96.46
250 to 500 820 to 1,640 15.406
500 to 1000 1,640 to 3,280 4.239
These results indicate that there is high potential for exposing future residents to excessive risks from exposure to emissions from diesel trucks travelling along SR 65. Since truck traffic will increase in future years, the risk scores summarized above will increase. In addition, our analysis did not include emissions from transport refrigeration units (TRUs). Adding these emissions would also increase the cancer risk scores.
2 Placer County Air Pollution Control District (2017) CEQA Handbook, Appendix G:
Preparing a Health Risk Assessment for Land Use Projects.
4 REFERENCES
CalTrans (2022): Traffic Census Program. Information Available at:
https://dot.ca.gov/programs/traffic-operations/census
CARB (2021): EMFAC 2021 Emissions Model. Information available at:
https://ww2.arb.ca.gov/msei-modeling-tools
OEHHA (2015): Risk Assessment Guidelines February 2015. Available at:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf
City of Rocklin (2024): Whitney Ranch Retail Project, Addendum to a Certified Environmental Impact Report.
- Appendix A: Air Quality and Greenhouse Gas Impact Analysis (prepared by Raney, Jan. 2024)
- Appendix D: Environmental Noise Assessment (prepared by Saxelby Acoustics, Jan. 2024)
- Appendix E: Transportation Impact Analysis for Placer Creek Retail Center (prepared by K.D. Anderson & Associates, December 2022)
5 Figure 1
Project Vicinity Map
Source: Whitney Ranch Retail project
Addendum to a Certified EIR
6 Table 1
CalTrans 2022 Data on Truck Volume
7 Table 2
EMFAC Emission Factors for CY 2024
8 Table 3
Calculation of Current and Project DPM Emissions
9 Table 4
Calculation of Baseline Cancer Risk Score
10 Table 5
Calculation of Incremental Cancer Risk Score
Ray Kapahi
Senior Air Quality
Consulting Engineer
Office: 916.687.8352
Mobile: 916.806.8333
Practice Areas
Air Quality Permitting
Odor Investigation and Control
Health Risk Assessment
Computational Fluid Dynamics
Greenhouse Gas Analysis
Atmospheric Dispersion Modeling
Industries
Solid Waste
Energy Production
Construction and Mining
Food Industries
Oil and Gas Production
Education and Training
BSc. Physics (1972)
MEng. Chemical Engineering (1975)
CARB Accredited Green House Gas
(GHG) Lead Verifier with Specialization
in Process Emissions and Electricity
Transactions (2009)
News
Presentation “Numerical Modeling of
Landfill Gas and Odors” 33rd International
Conference on Solid Waste Technology and
Management. March 11 to 14, 2018, Annapolis,
MD.
Presentation “Integrated Approach to
Effective Odor Control at Landfills and
Composting Facilities” Wastecon 2016,
Indianapolis, IN.
EXPERIENCE
Over 30 years of experience in analyzing air quality and odor impacts, permitting of stationary sources, and preparation of environmental impact documents. Mr. Kapahi works with a broad range of clients and assists them to identify and meet their regulatory obligations.
The scope of his experience includes siting of new landfills, waste to energy plants, obtaining conditional use permits from City and County Governments for new projects or expansion of existing projects. Specific experience and skills include preparation of emission inventories, analysis and measurements of odors, dispersion modeling, oversight of air quality monitoring, analysis of impacts to public health, responding to public comments, and appearing before City and County Planning Boards and Commissions as an expert witness on behalf of clients.
Following approvals for new facilities or expansion of existing facilities, Mr. Kapahi continues to work with clients to ensure on- going compliance.
REPRESENTATIVE PROJECTS
Air Quality Modeling and Permitting
Permitting of a Powdered Milk Plant (Turlock, CA)
Evaluate emissions of various air pollutants from the proposed 30 million gallons per year mild processing/drying facility. Demonstrate compliance with local and state air quality regulations, including regulation of toxic air pollutants.
Permit Revisions for an Existing Fruit Dehydration
Facility (Yuba City, CA)
Assisted a major food processor in revising their operating permits to allow for additional steam production. Worked cooperatively with the local air district to ensure timely issuance of the revised permits.
Permitting of a Waste to Energy Plant (Fort Irwin, CA) Quantify emissions from a proposed 34 tons per day solid waste to energy project. Analyze emissions associated with pyrolysis and subsequent utilization of synthetic gas to generate 1.5 MW of electric power. Prepare the necessary permit applications and supporting documentation.
Permitting of a Portable Biomass to Energy Unit
(Berkeley, CA)
Prepare permit application and supporting documents for an Authority to Construct and Permit to Operate an on-demand 25 kw biomass powered electric gensets. The unit includes a gasification and biochar recovery modules. The scope of work included a demonstration of compliance with best available control technology.
Publications and Presentations
Presentation “Use of Advanced Models to
Control Fugitive Odors from Composting Sites”.
US Compost Council Annual Meeting, January
2015, Austin, TX.
“Air Emissions from Landfills and Transfer Stations
– Do they Increase Public Health Risks?”
Presented at Quad State Environmental
Conference, Pigeon Forge TN, Sept 2015.
“Risks of Carbon Credit Invalidation Under
California’s Cap-and-Trade Program”, Presented
at the 2014 Air and Waste Management
Association Annual Conference. June 24-27,
2014. Long Beach, CA
“Estimate of VOC Emissions from Sludge Drying”,
Presented at the 1995 SWANA Conference.
November 1995, Baltimore, MD.
“Use of Biofilters to Control VOCs”, Biocycle,
February 1995.
“Impacts of the 1990 Clean Air Act
Amendments”, San Jose Business Journal, March
24, 1994.
“Modeling Fine Particulates” in Municipal Waste
Incineration Risk Assessment, Edited by Curtis
Travis, Plenum Press, 1990.
Specialized Training
Accidental Release Modeling Workshop. Trinity
Consultants. Dallas, TX November 1-2, 2018.
HARP2 (Risk Assessment Model) Training at
California Air Resources Board. Redding, CA April
2016.
Hearing Board Variance Training – California Air
Resources Board (1995)
Air Emissions and Odors from Wastewater –
University of Texas, Austin (1994)
Professional Affiliations
Air and Waste Management Association
(Board Member)
American Institute of Chemical Engineers
(Member)
Dust and Odor Mitigation
Ventilation System for Odor Control (Anaheim, CA)
Advanced computational fluid mechanics (CFD) models were used to predict the air flow and building pressure to identify the location, size and number of exhaust fans required to remove odors from the transfer station building.
Migration of Odors and Aerosol from Leachate
Evaporation Pond (Bi-County Landfill, Montgomery
County, TN)
Analyze the movement of odors and aerosols from leachate evaporators.
Demonstrate that evaporators were ineffective in reducing volume of leachate, but would release odors and VOCs to nearby homes.
Analysis and Control of Fugitive Dust and Odors from a Soil Blending Facility (Stockton, CA)
Advanced computational fluid mechanics (CFD) models were used to predict the air flow and movement of fugitive dust at a soil blending facility. With this information, the client was able to install appropriate mitigation services to mitigate off-site migration of fugitive dust. View how the movement of dust and odors occur at:
https://www.youtube.com/watch?v=wXEX6IT-54U
Review of Odor Control Systems for Cannabis Cultivation and Distribution Facilities (Palm Springs, CA)
EPS evaluated the odor control system for over 15 different odor cultivation and distribution facilities in Palm Springs. The effectiveness of the proposed system was evaluated and recommendations were made to the City of Palm Springs.
Analysis of Public Health Risks
Analysis of Public Health Risks Associated with
Composting Operations (Napa County, CA)
Estimate the types and amounts of toxic air contaminants (TAC) released from green waste and food waste composting. An air dispersion model was used with local wind data to determine the concentration of each TAC.
The concentration estimates were supplemented with toxicity data to quantify public health risks from exposure to the various toxic pollutants.
Analysis of Public Health Risks from Proposed Asphalt Plant (Kern County, California)
Analyze emissions of any toxic air pollutants from a proposed 250 tons per day asphalt plant. Emissions from aggregate drying, propane combustion and asphalt oil were quantified. Acute and chronic public health risks from exposure to various toxic pollutants were calculated and compared with regulatory thresholds of significance.
Ap
ril 23, 2024
To: Nat
han Anderson, Senior Planner
City of Rocklin Planning Division
3970 Rocklin Road
Rocklin, CA 95677
Subject: Response to Comments on the Whitney Ranch Retail Project Addendum
Mr. A
nderson:
Raney
has prepared the following memorandum in response to the comments provided by Stop the Rocklin Expansion in their comment letter dated April 22, 2024 regarding the Whitney Ranch Retail Addendum.
Com
ment 1: The Addendum Fails to Include a Health Risk Assessment for Diesel Exhaust Omissions During the Project’s Operational Phase
Response to Comment 1: The determination that project operations would not result in substantial toxic air contaminant (TAC) emissions related to heavy-duty trucks included in the Air Quality and Greenhouse Gas Analysis prepared for the proposed project was made based on the common sources of TACs included in the California Air Resource Board’s (CARB’s) Air Quality and Land Use Handbook: A Community Health Perspective (Handbook), as well as Raney’s professional judgement regarding typical activities associated with commercial developments
such as the proposed project. The CARB’s
Handbook
includes land uses such as chrome plating facilities, gas dispensing facilities, certain dry cleaners, freeways and high traffic roads, distribution centers, and rail
yards as typical sources of TACs. With the exception of the proposed gas station, which is discussed in detail on page 14 of the Air Quality and Greenhouse Gas Analysis prepared for the proposed project, the proposed commercial uses involve none
of the TAC producing activities that occur in association with the CARB identified TAC emitting land
uses.
In addition, t he commenter is incorrect that operation of the project would involve approximately 306 truck trips per day. As discussed in the Truck Trip Generation Memorandum prepared by T. Kear Transportation Planning & Management (TKTPM) (included as Attachment 1), the original transportation study done by KD Anderson and associates was based on a 134,500 square foot (sf) retail center; however, the project has since been reduced to 94,500 sf. As such, TKTPM prepared an addendum to the KD Anderson report to reflect such changes. The commenter used the outdated estimate of commercial vehicle trips provided by the KD Anderson Report and used a two percent assumption to arrive at an estimate of 3 06 daily truck trips. The two percent assumption is attributed to the Noise Study prepared for the proposed project, which is likely based on the assumption that two percent of traffic on local roadways is attributable to truck traffic, unless traffic counts indicate a higher percentage. The two percent assumption ref ers to the street traffic, rather than the project traffic. Thus, the commenters estimated truck traffic assumption is based on a non- applicable element of the trip generation data Item 3
presented in the reports (total trips as opposed to new trips) and, therefore, applied a default screening assumption out of context. The estimate of 306 daily truck trips is erroneously high. Furthermore, the commenter’s calculation of daily truck trips is incorrect.
Regardless, based on the calculations conducted by TKTPM, included as an attachment to the Truck Trip Generation Memorandum, the anticipated daily truck trip generation for the proposed project is nine truck trips per day, which is well below the 100 trip per day screening criteria established by CARB.
The foregoing consideration of heavy -duty truck trips associated with the project demonstrates that the proposed project would not result in substantial TAC emissions over the lifetime of the project. Therefore, because the project was determined not to result in the substantial release of TACs, the project would not have the potential to result in health risks to nearby receptors, and a detailed health risk assessment is not warrented in order to determine that the project would not exceed the Placer County Air Pollution Control District’s (PCAPCD’s) specific numeric thresholds of significance.
It should further be noted that as discussed on page 5, as well as shown in the graph on page 6, of the attachments to the comment letter, CARB regulations of diesel engines and fuels have had a dramatic effect on DPM concentrations. Since 1990, DPM levels have decreased by 68 percent. In addition, DPM levels are expected to continue declining as additional controls are adopted, and the number of new technology diesel vehicles increases. As such, DPM levels in the project area associated with traffic along State Route (SR) 65 can reasonably be assumed to continue declining due to increasingly stringent regulations and advancements in technology.
Comment 2: CEQA Requirements for Preparing Subsequent or Supplemental EIRs
Response to Comment 2: As discussed on page 2 of the Addendum, t he purpose of the Addendum was to document that no new significant impacts, nor a substantial increase in the severity of previously identified significant impacts, would result from the proposed project as described in the Addendum, relative to the project as analyzed in the 2002 EIR.
As further described on page 4 of the Addendum, none of the conditions identified in State CEQA Guidelines Section 15162(a) would occur with implementation of the proposed project because:
a) The revisions to the Project evaluated in the 2002 EIR, as described in Section
2.0, Project Description, of the Addendum, are relatively minor in nature and would not result in new significant environmental effects or a substantial increase in the severity of previously identified significant effects.
b) While some circumstances and existing conditions surrounding the Project have changed from those described in the 2002 EIR, the changes relate mostly to ongoing implementation of the Northwest Rocklin Annexation Project analyzed in the 2002 EIR. Existing conditions on and surrounding the project site generally remain as described in the 2002 EIR and are not substantially different from those described in that document. Therefore, any changes in circumstances or conditions that have occurred would not res ult in new significant environmental effects or a substantial increase in the severity of previously identified significant effects.
c) There is no new information of substantial importance. There is no information available that indicates that the Project would result in significant effects that were
not addressed in the previous EIR or a substantial increase in the severity of previously identified significant effects; or that mitigation measures or alternatives are available and feasible that would substantially reduce one or more significant effects on the environment.
In addition, as discussed on page 20 of the Addendum, TAC emissions were analyzed within the 2002 EIR. Based on the analysis included therein, t he Northwest Rocklin Annexation Project was determined to result in less than significant impacts related to potentially exposing sensitive receptors to stationary source pollutants and TACs . The project site is located within the boundaries of the 1,871-acre Northwest Rocklin General Development Area, within the portion of the Northwest Rocklin General Development Area designated as Retail Commercial, and is consistent with the site’s zoning and land use designations. Therefore, the analysis included in the Northwest Rocklin General Development Area EIR would remain relevant to the proposed project, and given that the proposed project would represent a small portion of the overall development associated with the Northwest Rocklin Annexation Project , TAC emissions associated with the proposed project would be substantially less than what was anticipated within the 2002 EIR.
Finally, as discussed above, t he foregoing consideration of heavy -duty truck trips associated with the project demonstrates that the proposed project would not result in substantial TAC emissions over the lifetime of the project. Therefore, because the project was determined not to result in the substantial release of TACs, the project would not have the potential to result in health risks to nearby receptors, and a detailed health risk assessment is not warranted.
Comment 3: The Addendum Also Fails to Consider Potential Urban Decay Impacts
Response to Comment 3: Generally speaking, for the purpose of CEQA, urban decay is characterized by physical deterioration to properties or structures that is so prevalent, substantial, and lasting a significant period of time that it impairs the proper utilization of the properties and structures, and the health, safety, and welfare of the surrounding community. The key indicator from a CEQA perspective is impacts on the existing physical environment, which in the context of an urban decay analysis includes the commercial real estate base and other germane real estate conditions, as measured against the current baseline. Characteristics of physical deterioration contributing to urban decay include abandoned buildings, boarded doors and windows, parked trucks and long- term unauthorized use of the properties and parking lots, extensive or offensive graffiti painted on buildings, dumping of refuse or overturned dumpste rs on properties, dead trees and shrubbery, and uncontrolled weed growth.
Urban decay is a compounding effect that can result from extended vacancy, deferred maintenance, and abandonment. The urban decay process generally takes several years to materialize fully and is reinforced by declining economic conditions in the broader market area. Urban Decay is generally not the result of a single property standing vacant for a short time in an otherwise vibrant market.
The commenter does not provide evidence to support the assumption that the proposed project would result in urban decay . In addition, as noted on page 61 of the Addendum, the Traffic Impact Analysis ( TIA) prepared for the proposed project included additional supporting information provided in a market study prepared for the proposed anchor
tenant (i.e., supermarket) of the proposed project. The market study focused on the location of competing supermarkets with a one- to three-mile radius of the site. As shown in Figure 7 of the TIA (see Appendix E to the Addendum), while three existing markets are located roughly two miles from the site, competing supermarkets are not located within a mile of the site. Other supermarkets exist within or near a three-mile radius. The market study noted the existing development and development being constructed to the east of the site in an underserved area roughly bounded by Stanford Ranch Road -Park Drive to the south and the Rocklin City limits to the north would account for nearly 70 percent of the trade area sales. As such, the available data suggests the proposed project would be a “locally serving” use that would provide local residents with more shopping options that are closer to their residence. Furthermore, as discussed above, the project site is located within the portion of the Northwest Rocklin General Development Area designated as Retail Commercial, and is consistent with the site’s zoning and land use designations .
Development of the project site with commercial uses, including the proposed supermarket, has been generally anticipated by the City. Therefore, the proposed project would not result in any impacts related to urban decay.
Finally, in the comment letter’s closing remarks, the commenter states, “CEQA establishes mandatory information disclosure and public participation procedures to ensure that decision- makers and the public are informed of a project’s impacts, and that the public can evaluate and respond to the proposed actions of their elected representatives before those actions are taken.” As stated in Section 15164(c), and reiterated on page 3 of the Addendum, an addendum need not be circulated for public review but can be included in or attached to th e final EIR or adopted negative declaration. The City has complied with all CEQA requirements related to mandatory information disclosure and public participation procedures.
If you have any questions regarding the contents of this document, please do not hesitate to contact me at (916) 372-6100, or via email at [email protected] .
Best Regards,
Rod Stinson
Vice President/Air Quality Specialist
1501 Sports Drive, Suite A
Sacramento, CA 95834
Office: (916) 372-6100
www.raneymanagement.com
Attachments:
Attachment 1 Truck Trip Generation Memorandum
Attachment 1
Truck Trip Generation Memorandum
Memorandum
TO: Rob Cole, UKI Rocklin, LLC
FROM: Tom Kear, PhD, PE
Date: April 22, 2024
RE: Whitney Ranch Retail Project Truck Trip Generation
Introduction Background
This memo is written to inform the response to a comment received from “Stop the Rocklin Expansion” related to truck trip generation estimates for the Whitney Ranch Retail Project (the Project). Using information taken out of context from the Project ’s transportation analysis, “Stop the Rocklin Expansion” anticipated that there will be 306 daily truck trips generated by the Project.
This memorandum describes trip generation estimates in the Project’s transportation analysis, highlights an erroneous assumption made by “Stop the Rocklin Expansion ,” and provides a more appropriate estimate of truck trip generation. In this memo we document that the Project is anticipated to generate nine truck trips per day.
Trip Generation Estimates in the Project’s Transportation Analysis Trip generation estimates were prepared as part of the transportation analysis for the Whitney Ranch Retail Project (the Project). The original transportation study done by KD Anderson and associates was based on a 134.5 ksf (thousand square feet) retail center. Unfortunately, Mr. Anderson passed away shortly after preparing that study. Subsequent to the KD Anderson transportation analysis, the Project was reduced from 134.5 ksf to 94.5 ksf, and the assumed intersection controls at the Whitney Ranch Pkwy/University Ave intersection were revised. An addendum was prepared by T. Kear Transportation Planning and Management (TKTPM) to analyze the reduced Project, account for the updated intersection assumptions, and address comments from city staff.
Both the original KD Anderson transportation report and the TKTPM addendum included anticipated vehicle trip generation estimates for the P roject which ranged between 15,725 – 17,265 total daily vehicle trips. The variation in estimates between the original study and the addendum are attributable to the reduced square footage of the Project and mix of uses. Both studies then reduced the total number of trips to account for pass-by trips (where a trip already on an adjacent street stops, such as for coffee) and reduced the total number of trips to account for internal capture (where a c ustomer stops at multiple business es inside the retail center on a single trip. Accounting for Internal trip capture and pass-by trips reduced the Project trip generation to 6174 to 8647 new daily vehicle trips.
It is also important to define a “trip” as the industry and common definition differ. The transportation industry considers travel in one direction from an origin (such as your home) to a destination (such as a restaurant) to be a single trip. The return journey is considered to be a separate trip. Thus, when we Whitney Ranch Retail Project Truck Trip Generation memorandum April 22, 2024
consider 6174 new daily vehicle trips, it refers to 3087 vehicles traveling on local roads to the Project site on a typical day, and the same number departing.
“Stop the Rocklin Expansion” Estimate
“Stop the Rocklin Expansion” took the outdated high estimate of 17,265 total daily vehicle trips and used a 2% assumption for heavy vehicles to arrive at an estimate of 306 daily truck trips.
The 2% assumption is attributed to the Project noise study, which likely took the assumption from the transportation analysis where 2% truck traffic is often used for traffic on local roads unless traffic counts indicate a higher percentage. That 2% refers to the street traffic, rather than the Project traffic.
Thus “Stop the Rocklin Expansion” estimated truck traffic based on the wrong element of the trip generation data presented in the reports (total trips as apposed to new trips) and took a default screening assumption of 2% trucks out of context. Their estimate of 306 daily truck trips is erroneously high.
Project Truck Trip Generation
Truck trip generation data is available for a limited number of land uses within the Institute of Transportation Engineers (ITE) trip generation manual as shown in the table below. The best match for the Project is ITE Land use 820: Shopping Center, Greater than 150 ksf (though the P roject totals only 94.5 ksf). A calculation sheet is attached documenting that the anticipated daily truck trip generation for the Project is 9 truck trips.
It is not industry standard practice for transportation analysis of most land use projects to consider truck trip generation because the estimates are generally low enough to be screened out as de - minimis, such as in this case. There are exceptions to that standard for freight terminals, bus terminals, port facilities, aggregate mines, and large industrial facilities.
Finding
The anticipated daily truck trip generation for the Project is 9 truck trips.
Whitney Ranch Retail Project Truck Trip Generation memorandum April 22, 2024
Attachment: Project Truck Trip Generation Estimate
Whitney Ranch Retail Project Truck Trip Generation memorandum April 22, 2024