CORRESPONDENCES FROM THE PUBLIC
City Council Regular Meeting
April 23, 2024
PUBLIC HEARING - ITEM 4B:
Vacant Property Weed Abatement Protest
Hearing
CORRESPONDENCES FROM THE PUBLIC
Subject: Urgent Protest Against Weed Abatement APN: 376-060-002-000 Date: April 18, 2024
City of Rocklin
Attention: City Clerk
3970 Rocklin Road, Rocklin, CA 95677
Re: APN: 376-060-002-00
Mahone Family Trust (aka Jeffrey and Deborah Henderson Family Trust) Return address: Rocklin Ca. 95765
Dear City of Rocklin Council members,
I am writing to express my strong opposition to the recent weed abatement measures requested in your letter to me dated April 9, 2024. While I understand and agree with the need for maintaining my vacant lot to ensure fire hazard safety, I believe that your current request is detrimental to my lot and the surrounding open space.
Here are my concerns:
Soil Erosion: Weeds play a crucial role in preventing soil erosion. Their roots stabilize the soil, especially in areas prone to erosion. Removing them without considering the consequences could lead to increased erosion, affecting nearby water bodies and landscapes. Below are the civic and environmental challenges for this lot and the remedies I have put in place to control the look and safety until I fully develop the property.
1. Poor design and development of the access street for APN: 376-060-002-00. a. During the rainy season, rain floods the street and pours over the property line and down the sloped lot. The first few years of owning the property I trialed weed abatement throughout the year with chemical use and manual cutting (including the rainy season). The result, massive soil erosion and damage to the Heritage Oak trees on my lot and the adjoining golf course.
2. The fix:
a. Allowing the weeds and planted ground cover to flourish during the rainy season has eliminated all soil erosion and increased the soil integrity.
b. Planting of additional trees, shrubs, and ground cover to restrict high water flows has added additional natural barriers and improved the aesthetic street view.
Lot debris: The letter did not clarify any debris type. However, during this past winter, a golf course tree fell into the lot taking out the fence. The golf course cut-up the tree and chipped the smaller limbs. They left material on the lot, but it is already scheduled to be moved by mid-May.
In summary, I have always gone above and beyond to reduce fire hazard on my property by controlled weed abatement, eliminating ground debris and raising branch height. As evidenced by the above information, I urge you to adopt an abatement clause for my property allowing for no weed abatement measures during the rainy season. My annual plan is to manually cut the landscape growth below 3" between May 15 - 30 or earlier depending on weather conditions.
Let's work together to find solutions that protect our natural heritage while addressing safety concerns.
Thank you for your attention to this matter. I look forward to hearing from you soon.
Sincerely,
Jeff Henderson
From: G. Windgasse
To: City Clerk
Cc: Mike Bouchard; Alex Fong; Eric Feliz
Subject: "Weed Abatement Protest" re APN 010-220-041-000 Date: Saturday, April 20, 2024 12:16:56 PM
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.
From:
Gabriele Windgasse
April 20, 2024
To:
[email protected]
City of Rocklin
Subject: "Weed Abatement Protest" re APN 010-220-041-000 Dear City Clerk - in response to the City's letter that my property on Farron Street is vacant and constitutes a public nuisance due to weeds and rubbish, I want to state the following:
Through my contractor MJB Homes, Rocklin, I applied for a grading permit on 10-9-2023 for my property on Farron Street. After receiving the permit, grading activities have removed the vegetation, and wattles have been placed to prevent runoff. There are no weeds or rubbish on my property. We anticipate submitting a building permit application in the week of April 21, 2024. Please remove my property from the list of "vacant lots" as building activities have started and this property is no longer vacant.
Thank you and let me know if you have any questions.
Sincerely
Gabriele Windgasse
From: Sunny Ghai
Sent: Saturday, April 20, 2024 12:33 PM
To: City Clerk; Reginald Williams; Fire Prevention; Ryan Brayton Cc:
Subject: FW: weed abatement
Attachments: IMG_3980.jpeg; IMG_3974 jpeg; IMG_3975.jpeg; IMG_3976.jpeg; IMG_3977.jpeg; IMG_ 3979.jpeg; Abatement Notice 04.15.24.pdf
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.
With reference to the attached hearing Notice please note that the property in questions has been cleared up as you can see from the pictures.
Can this please be taken off the Calendar for the April 23'd City Council Meeting.
Please note that the area comprises of two parcels and we have abated our parcel which is the corner.
Th other parcel is still owned by the developer Doug and we have forwarded this notice to him but he this does not mention his parcel number.
Sunny Ghai
President
Ghai Management Services, Inc
(Franchisees for Burger King, Taco Bell)
(Dealers for Chevron, BP/ARCO, Phillips 76)
Livermore CA 94551
Off:
Fax:
Cell:
From:
Sent: Saturday, April 20, 2024 11:58 AM
To:
Subject: Re: weed abatement
See photos
Our parcel cleaned out
Thanks
1 LOOKIN DIL
City of Rocklin Fire Prevention
Fire Department Division
DSPARTMIEIN
PLEASE READ THE FOLLOWING IMPORTANT INFORMATION
ABOUT THE CITY OF ROCKLIN'S WEED ABATEMENT PROGRAM
LIVERMORE CA 94551
Dear LLC,
APN(S): 364-090-024-000
Records on file with the Placer County Assessor's Office indicate that you are the owner of vacant property located in the City of Rocklin. This certified letter is to inform you that on April gth, 2024, the Rocklin City Council declared all vacant parcels in the City of Rocklin a public nuisance and ordered the nuisance to be abated by June 1st, 2024. The City's "Annual Weed Abatement Program for Maintaining Vacant Parcels" requires the reduction of any fire hazard and/or public nuisance in the City. As part of this program, each property owner is required to take appropriate action to maintain their property throughout the year in accordance with the enclosed Vegetation Maintenance Standards.
THE CITY DOES NOT OFFER THE OPTION TO HAVE A CONTRACTOR MAINTAIN PRIVATE VACANT PARCELS FOR YOU. IT IS THE PROPERTY OWNER'S RESPONSIBILITY TO COMPLY WITH THE VEGETATION MAINTENANCE STANDARDS.
To ensure fire hazards and/or a public nuisance does not exist on vacant parcels, the City's inspector will be inspecting parcels between May 15th and June 1, If the City's inspectorduring that 2-week period deems parcels non-compliant or partially compliant with the Vegetation Maintenance Standards, the City has the right to abate the public nuisance beginning June 1st.
All costs incurred from performing this work, including direct costs and expenses, any applicable fines, and administrative charges and postage, will be charged to the property owner. In the event that parcels are found to be non-compliant more than once in the same calendar year, no further abatement proceedings are required and the City may proceed directly to abate the public nuisance and collect all associated costs. If such costs are not paid as required, those unpaid costs will constitute a lien and will be recorded against the property until paid. (See Gov.
Code 5§39560-39588; RMC Chapter 8.12 Weeds and Rubbish.) If you have completed the required abatement and your property currently meets the enclosed Standards, please be advised any re-growth throughout the season must also be abated and maintained at a maximum of 4" inches in height.
The enclosed NOTICE TO DESTROY WEEDS AND REMOVE
RUBBISH sets forth your opportunity to object to the City Council's declaration that your property is a public nuisance at a meeting of the Rocklin City Council on April 23, 2024, at 6:00 p.m.
Pursuant to Government Code section 39570, the decision of the City Council regarding any protest is final.
If you have questions or need any additional information, please contact us at (916) 625-5500.
Sincerely,
Rick Lawrence Ryan Brayton
Public Works Manager/Project Manager Deputy Chief-Fire Marshall
NOTICE TO DESTROY WEEDS
AND REMOVE RUBBISH
Notice is hereby given that on the 9th day of April, 2024, the City Council of the City of Rocklin passed a resolution declaring that noxious or dangerous weeds were growing upon the property, and that rubbish, refuse, and dirt were upon the property, in the City of Rocklin, as is more particularly described in the resolution, and that they constitute a public nuisance which must be abated by the removal of the weeds, rubbish, refuse, and dirt. Otherwise, they will be removed and the nuisance abated by the City and the costs of removal assessed upon the land from which the weeds, rubbish, refuse, and dirt are removed and will constitute a lien upon such land until paid. Reference is hereby made to the resolution for further particulars. A copy of said resolution is on file in the office of the City Clerk.
All property owners having any objections to the proposed removal of the weeds, rubbish, refuse, and dirt are hereby notified to attend a meeting of the City Council of the City of Rocklin to be held on April 23, 2024, at 6:00 p.m., when their objections will be heard and given due consideration.
Written protests may also be sent in writing to the City Clerk on or prior to April 23, 2024, at 5:00 p.m. Protests must be mailed to: The City of Rocklin, 3970 Rocklin Road, Rocklin, CA, Attention: City Clerk; or emailed to [email protected] with "Weed Abatement Protest" in the email subject line. Written protests will be read aloud by the City Clerk and given due consideration at the April 23, 2024, City Council meeting. Pursuant to Government Code section 39570, the decision of the City Council regarding any protest is final.
Dated this 10th day of April, 2024.
City Clerk ROCKLIN
CALIFORNIA
City of Rocklin
VEGETATION MAINTENANCE STANDARD
Scope:
This guideline provides the requirements for open space land and all parcels within the City of Rocklin to reduce the impact of wildland fire. For the purpose of this guideline, certain terms are defined as follows:
Definitions:
Defensible Space. Defensible space is the buffer you create on your property between a structure and/or property line and the grass, trees, shrubs, or any wildland area that surround it. This space is needed to slow or stop the spread of wildfire and it helps protect your home from catching fire-either from embers, direct flame contact or radiant heat.
Wildland Urban Interface. The WUI is the zone of transition between unoccupied land and human development. It is the line, area or zone where structures and other human development meet or intermingle with undeveloped wildland or vegetative fuels.
References:
Rocklin Municipal Code Chapter 8.10 - Fire Safe Vegetation and Debris Management
Rocklin Municipal Code Chapter 8.12 - Weeds and Rubbish Operational Standards for ALL Parcels:
Zone 1 (Within 30 feet of the property line or structures):
• Cut, mow, graze annual grass down to a maximum height of 4 inches. • Create horizontal space between shrubs and trees. (See diagram) • Create vertical space between grass, shrubs and trees. (See diagram) • Remove branches that hang over property line.
• Trim trees regularly to keep branches a minimum of 10 feet from other trees. • Create a separation between trees, shrubs.
Zone 2 (Extends from 30 feet to 100 feet from structures):
Cut, mow, graze annual grass down to a maximum height of 4 inches.
Create horizontal space between shrubs and trees. (See diagram) Create vertical space between grass, shrubs and trees. (See diagram) Operational Standards for VACANT Parcels:
• The required maintenance for vacant properties is based on the size of the parcels as listed below.
Five (5) acres or smaller shall be totally disced or mowed Larger than five (5) acres and smaller than twenty-five 25) acres require fire breaks consistent with Zone 1, or one hundred (100) feet off closest structure, whichever is greater. The remainder of the parcel will require the appropriate number of thirty (30) foot fire breaks to segment (checkerboard) the land into four (4) acre +/ - sections.
C. Larger than twenty-five (25) acres require fire breaks of thirty (30) feet off property line or one hundred 100) feet off closest structure, whichever is greater. The remainder of the parcel will require the appropriate number of thirty (30) foot firebreaks to segment (checkerboard) the land into five (5) acre + /- sections.
EXCEPTION: An approved fire access road plan may be substituted in lieu of five (5) acre segments.
• Parcels under agricultural or pasture land use require fire breaks of (30) feet adjacent to all developed areas, fences, or structures. The remainder of the property must be mowed or disced at time of harvest or have sufficient animals present to maintain height of combustible growth of six (6) inches. • Fire breaks may be constructed by discing, mowing, or the use of a blade. The maximum height of combustible growth within a firebreak is four (4) inches. If a blade is used, the side boundaries of the break shall be leveled. Windrows are not permitted.
• Parcels may be maintained to allow reasonable access for firefighting operations.
Rubbish and/or debris must be removed prior to any work on the property.
Discing - Discing shall include rototilling or cultivating. Discs shall be set at an angle sufficient to cut and bury the growth existing at the time.
Mowing - If this is used, the mowing shall be done each time the combustible growth exceeds four (4) inches.
DEFENSIBLE SPACE ZONES
TO FEL
ZONE 2
30-100 FEET
30 FEET
ROAD ZONE 1
NEIGHBORING
PROPERTY
TWO ZONES MAKE UP THE REQUIRED
100 FEET OF DEFENSIBLE SPACE:
ZONE 1: 30 feet of Lean, Clean & Green
• FEET ME
Remove all dead plants, grass and weeds. LEARANC
2 Remove dead or dry leaves and pine needles
from your yard, roof and rain gutters.
3 Keep tree branches 10 feet away from VERTICAL SPACING your chimney and other trees.
Large trees do not have to be cut and removed
ZONE 2: 30-100 feet of Reduced Fuel as long as all of the plants beneath them are removed. This eliminates a vertical "fire ladder."
Cut or mow annual grass down to
a maximum height of 4 inches.
Create horizontal spacing between
shrubs and trees.
Create vertical spacing between
grass, shrubs and trees.
30 FEET REDUCED FUEL ZONE 70 FEET
Use Equipment Properly to
Keep from Sparking a Wildfire
HORIZONTAL SPACING
Mow before 10 a.m., and never on
a hot or windy day. String trimmers Create horizontal and vertical spacing between are a safer option (vs. lawnmowers) plants, the amount of spacing will depend on for clearing vegetation. how steep the slope is and the size of the plants.
FILL OUT AND RETURN ONLY IF YOU NO LONGER OWN PARCEL(S) Name_
Previous Owner/Business
APN(s).
List
CHECK THE BOX, SIGN, AND RETURN ONLY IF PROPERTY HAS BEEN SOLD • I no longer own this property.
THE PROPERTY WAS SOLD ON:
to:
Month Day Year Buyer's Name (please print)
Buyer's Address
Buyer's (Area Code) Phone Number
Previous Owner Information Please Return This Form To
U.S Mail:
Name (please print) City of Rocklin
Public Works Department
4081 Alvis Court
Signature Rocklin, CA 95677
Fax (916) 625-5501
Your Address E-Mail to: [email protected] Phone Number
E-mail
Diane S. Petty
Nevada City, CA 95959
Tuesday, April 23, 2024
City of Rocklin
FREE EREET
City Clerk, Avinta Singh
3970 Rocklin Road
Rocklin, CA 95677
RE: Protest Response to Vegetation Maintenance Standards 12152
Dear Avinta,
I spoke with Janie this morning concerning the Rocklin City Council meeting this evening. I have a class this evening and will not be able to attend. She suggested I write to you in regards to the Rocklin City Council meeting to share my concerns and make a written Weed Abatement Protest for my vacant land on Parcel #046-020-070-000 2.7 acres. I'm protesting because I do not have legal access to the property.
I have a total of 5.9 acres in Placer County which does not have any legal access. There are 3.2 acres on Parcel #046-020-069-000 in Roseville and 2.7 acres on Parcel # 046-020-070-000 in Rocklin. The parcels are on the east side of Interstate 80 and Highway 65 exchange going north to Auburn. The property goes along the Caltrans fence to the center of Secret Ravine Creek I have been trying to meet your standards by spraying the weeds twice annually. I have been going through the Caltrans fence located below where Highway 65 comes into Interstate 80 going east to Auburn. The fence has been down for the past 20 years. There is no legal access to the property.
Both the Rocklin and Roseville police departments have had to use the open fence to access the property for keeping the homeless and trespassers from being on the property. There is also no legal access to fight a fire should there ever be one.
Thank you for your help and any suggestions. Please call me if you have any questions at any time.
Sincerely,
Diane S. Petty
cc: Mayor Greg Janda, Vice Mayor Jill Gayaldo,
City Council Members David Bass, Bill Halldin, Ken Broadway PUBLIC HEARING - ITEM 4C:
Whitney Ranch Retail
CORRESPONDENCES FROM THE PUBLIC
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]
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
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,' the AERMOD dispersion model, and the Office of Environmental Health Hazard Assessment (ОЕННА)'s HARP risk model. Indeed, OEHHA's CalEnviroScreen mapping tool?) 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 Available at: https://arb.ca.gov/emfac/2017/
Available at: https://oehha.ca.gov/air/crnr/notice-adoption-air-toxics-hot-spots-program- quidance-manual-preparation-health-risk-0
Available at: https://ochha.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.
CalEnviroScreen 4.0 Indicator Maps Results Map
Legend
Diese PM Percentile
> 90-100
What is diesel particulate matter? > 80-90
> 70 - 80
Exhaust from trucks, buses, trains, ships and other
cauipment with diesel enaines contains a mixture of
> 60-70
gases and solid particles. These solid particles are known > 50 - 60
contains hundreds of different chemicals. Many of these > 40 - 50 are harmtulto health. the honest levels or diese PM are near ports, rail yards and freeways.
The particles in diesel PM can reach deep into the lung. where they can contribute to health problems including
eye, throat and nose irritation, heart and lung disease, and lung cancer. Children and the elderly are most sensitive tol the effects of diesel PM.
More information can be found in the Diesel PM Si Mande R- chapter in the CalEnviroScreen 4.0 report and the Diesel PM indicator page
Rocklin
Röcklin Rd
Cavitt Stallman Ko Hidden Valley
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 S 21166; CEQA Guidelines, S 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.
(65)
Whitney Del Oro High Schor
WHITNEY
RANCH
N Foothills Bivd Jessup
Whitney Oaks Golf Club
Ave University King Rd
dustrial Loomis
Park Dr
W Sunset Blvd S Save Mart Sera College Bid
65 Sunset Bla
Stanford Ranch Rd
Hardwood Palace Crest Dr
W Oaks Blvd
Brac
Safeway Trader Joe's
Supermarket standby Specialty grocer with
Grocery Outlet for groceries & more Midas A ve housebrand items Source for discount
groceries & more Bel Air
Nugget Markets Nugget Markets
Groceries, baked Groceries, baked
goods & deli fare goods & deli fare Safeway
Jersey Mike's Subs Whitney Blvd Supermarket standby
Rocklin for groceries & more
Walmart Supercenter A Rocklin Rd
Reliance SuperMart Walmart
Neighborhood...
65 Foothills Blvd
Safeway
Supermarket standby
for groceries & more
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, S 15002(a).) Public participation "is an essential part of the CEQA process." (Guidelines, SS 15002(i), 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 eo 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
attachments
ATTACHMENT 1
ATTACHMENT 1
ATTACHMENT 1
ATTACHMENT 1
ATTACHMENT 1
ATTACHMENT 1
Overview: Diesel Exhaust & Health I California Air Resources Board https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health Overview: Diesel Exhaust & Health
CATEGORIES
Topics Health, Air Pollution, Cars & Trucks, Construction & Earthmoving Equipment, Environmental Justice, Oceangoing Vessels & Harbor Craft, Freight & Goods Movement, Trains & Railyards, Transit, VW Diesel Vehicles Programs 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 Type Information
CONTACT
Research Division
Email
Phone
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 um in diameter (about 1/70th 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 all contains gaseous pollutants, including volatile organic compounds and oxides of nitrog. (NOx). NOx 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 1 of 8 3/9/21, 2:11 PM
Overview: Diesel Exhaust & Health I California Air Resources Board https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health 2 of 8 3/9/21, 2:11 PM
Overview: Diesel Exhaust & Health I California Air Resources Board https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health 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 3 of 8 3/9/21, 2:11 PM
Overview: Diesel Exhaust & Health I California Air Resources Board https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health 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.
Estimated Annual Number of
Health Effect Cases*
Cardiopulmonary Death 730(570 - 890)
Hospitalizations (Cardiovascular and 160(20 - 290)
Respiratory)
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.
4 of 8 3/9/21, 2:11 PM
Overview: Diesel Exhaust & Health I California Air Resources Board https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health Statewide DPM Ambient Concentration
2.0 1.8
HDV
Engine STD
1.6 Port rule
1.4 ug/m3 1.2
Ambient
0.6 0.4
Reformulated PSIP USLD
0.2 Diesel Transit Bus
Program HDV - Off road
0.0 1990 1995 2000 2005 2010
Year
**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), 5 of 8 3/9/21, 2:11 PM
Overview: Diesel Exhaust & Health I California Air Resources Board https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health California Population, Gross State Product (GSP),
Diesel Cancer Risk, Diesel Vehicle-Miles-Traveled (VT)
100%
Diesel VMT
GSP
Population
% change from 1990 0%
Diesel Cancer Risk
-100%
1990 1995 2000 2005 2010
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 W 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 6 of 8 3/9/21, 2:11 PM
Overview: Diesel Exhaust & Health I California Air Resources Board https://ww2.arb.ca.gov/resources/overview-diesel-exhaust-and-health 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 Public Workshop SNAPS Lost Hills
Notice on March 16, Notice on March 16, Newsletter - Februa i 2021 - Espanol 2021 2021
7 of 8 3/9/21,2:11 PM
ATTACHMENT 2
ATTACHMENT 2
ATTACHMENT 2
ATTACHMENT 2
CalEnviroScreen 4.0 Indicator Maps Results Map
ollege Bivd Clover Valley
Lincoln Hills Butler Ra
Golf Club 423 f Ca mino
Catta
Verdera:
Country стартот Legend A X
CluE
Diesel PM Percentile
Orchard Creek Tweive Bridges Dr
Ave
> 90 - 100
Delmar Ave Humphrey Rd
What is diesel particulate matter? Aubum i
Rancheria
Athens Ave i park o,
Exhaust from trucks, buses, trains, ships and other > 70 - 80 High
equipment with diesel engines contains a mixture of School whitney > 60 - 70
gases and solid particles. These solid particles are known Park Whitney Dake Antelope Creek
as diesel particulate matter (diesel PM). Diesel PM PO 1 Golf > 50 - 60 Club Coldwater Ds
contains hundreds of different chemicals. Many of these * Harold+T Biz > 40 - 50
are harmful to health. The highest levels of diesel PM are near ports, rail yards and freeways. illiam Jessup
University Park Dr. Loomis
The particles in diesel PM can reach deep into the lung, Rawhide Ro Valley Taylor Rd where they can contribute to health problems including Saword Ranch RabaSa Sierra College eye, throat and nose irritation, heart and lung disease, and BINd Crest Dr High
WOaks Bivd School Clover
lung cancer. Children and the elderly are most sensitive to the effects of diesel PM. Argonaut A ve DelmariAve RAVİN More information can be found in the Diesel PM Sunset Val Verde Ro chapter in the CalEnviroScreen 4.0 report and the Diesel Whitney PM indicator page. Recreation
Midas Ave Area Granite Dr
Sorr
Bivd ningview Rocklin
Sierra College
penio Slay Pines Golf Blue Quarr Rocklin Rd
lamily Course Oaks. Parl
Park 105°
Complex Wells Ave
Timber
cimbe Creek Golf
Stanford
Course Ranch
Woodcreek Rose vile PkNy
Golf
-iddyment-Ro Westfield
Galleria at Coltege Biva-
Roseville
Diamond Oaks Auburn Fo
S BING Golf Course
Mahany
secret R Cavitt Stallman Rd Hidden Valley
Woodcreek Regional Kaseberg Creek Sierra View
Park
West eria. Blvd
Clut
farmin, INCREMENT P. USGS, METINASA, NGA, ERA, USDA
ATTACHMENT 3
ATTACHMENT 3
ATTACHMENT 3
ATTACHMENT 3
EPS
ENVIRONMENTAL PERMITTING SPECIALISTS
Air Quality • Permitting • OHSA • RMP/PSM
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:
E-Mail:
https://www.epsconsulting.orq/
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:
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. These data indicate that 11,325 trucks per day travel on SR 65 near the intersection of 1-80 (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 1-80 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
2 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.- 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)
O to 100 O 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)
O to 100 Oto 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)
O 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. 3 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
ОЕННА (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)
Figure 1
Project Vicinity Map
Source: Whitney Ranch Retail project
Addendum to a Certified EIR
Undeveloped
Land
0.6 mile segment
of SR 65 modeled
Muld Family"
Wake Dead COD
Reaidences
Project Site
Distribution
Conte
Undeveloped Single Family
Land
Table 1
CalTrans 2022 Data on Truck Volume
RTE RTE_SFX PM_PFX POSTMLE PM SEX DESCRIPTION ESTIVER COUC
0.085 A TAHOE CITY, JCT. RTE. 89 3.61
450 LARDIN WAY 4.21
KINGS BEACH, JCT. RTE, 267 NORTH 11400
KINGS BEACH, JCT. RTE, 267 NORTH
<<m
AUBURN. JCT. RTE. 80
AUBURN, JCT.RTE. BO mm
LUTHER ROAD
LUTHER ROAD
DRY CREEK ROAD m<<m
LORENSEN RD
ROSEVILLE. JCT. RTE. 80
-...... reggessaggsgesgggsesssgagggess. ROSEVILLE, RIVERSIDE DRIVE 00003000000000-3
ROSEVILLE, ATLANTIC STREET
1615
1616
ROCKLIN, SIERRA COLLEGE BOULEVARD
12420 HALLBOM ROAD UC
17.541 AUBURN, JCT. RTE. 49
17 641 83378
AUBURN RAVINE ROAD
AUBURN RAVINE ROAD <m m
23.429
COLFAX, JCT. RTE. 174 NORTH
33.131 COLFAX, JCT. RTE. 174 NORTH
5.812 WARD CREEK BRIDGE 18884 1mmm
8.569
TAND CITY AT ATE FAS
Table 2
EMFAC Emission Factors for CY 2024
G J K L M N
Source: EMFAC2021 (v1.0.2) Emission Rates
2 Region Type: Statewide
Region: California
4 Calendar Year: 2024
5 Season: Annual
6 Vehicle Classification: EMFAC2007 Categories
7 Units: miles/day for CVMT and EVMT, trips/day for Trips, g/mile for RUNEX, PMBW and PMTW, g/trip for STREX, HOTSOAK and RUNLOSS, g/vehicle/day for IDLEX & Table 3
Calculation of Current and Project DPM Emissions
A C D E F G
1 EXISTING TRUCK EMISSIONS
2 Total Truck ADT 11,325
3 Length of Roadway 0.6 miles
6 DPM Emissions from HD Trucks
Emission Factor (EF) for HD Trucks (Table 2) 0.0288 grams/mile ADT 11,325 veh/day
Emissions 195.6 grams/day
0.431 Ibs/day
157.2 Ibs/yr
12 Calculation of Emissions = Length of Roadway × EF × ADT 15 16 FUTURE TRUCK EMISSIONS
17 Total Truck ADT 11,325
Length of Roadway 0.6 miles
20 21 DPM Emissions from HD Trucks
22 Emission Factor (EF) for HD Trucks (Table 2) 0.0288 grams/mile 23 ADT 704 veh/day
24 Emissions 12.2 grams/day
25 0.027 Ibs/day
26 9.8 Ibs/yr
28 Calculation of Emissions = Length of Roadway × EF x ADT 29 8
Table 4
Calculation of Baseline Cancer Risk Score
A C D E F G
1 Name: Whitney Ranch RocklAir Toxics Hot Spots Facility Prioritization Score Calculatol Applicability Use to provide a Prioritization score for facility emissions according to Toxic Hot Spots quidelines. Entries raguiled in yellow areas, output in gray areas Ray Kapahi April 20, 2024
Whitney Ranch Rocklin
Screening Level Risk Analysis
Baseline Conditions
RK
Stack Height
10 Operating Hours hr/yr 8,760.00 m 46
11 Emissions Potency Method Dispersion Adjustment Method Non- Facility Non- Facility
Receptor Proximity and Proximity Cancer Cancer Cancer
Cancer Ranking Ranking
Factors
13 Score Score Priority Score Score Priority
14 0< R<100 1.000 3.63E+02 5.38E-01 High 6.04E+00 8.97E-03 Medium 15 100≤R<250 0.250 9.08E+01 1.35E-01 High 6.04E+00 8.97E-03 Medium 16 250≤R<500 0.040 1.45E+01 2.15E-02 High 5.43E+00 8.08E-03 Medium 17 500<R<1000 0.011 3.99E+00 5.92E-03 Medium 2.41E+00 3.59E-03 Medium 18 1000<R<1500 0.003 1.09E+00 1.62E-03 Medium 7.85E-01 1.17E-03 Medium 19 1500<R<2000 0.002 7.26E-01 1.08E-03 Low 3.98E-01 3.98E-01 Low 20 2000<R 0.001 3.63E-01 5.38E-04 Low 2.54E-01 2.54E-01 Low 21 22 Height Adjustment <250m <500m <1000m <1500m
23 <20m 0.04 0.011 0.003
24 20m<= <45m 0.22 0.064 0.018
25 =>45m 0.9 0.4 0.13
26 27 Enter the unit's CAS# of the substances emitted and 28 their amounts.
Corrected Corrected
MW Annual Maximum Annual Maximum
Correction Emissions Hourly Emissions Hourly
29 Substance CAS# (Ibs/yr) (Ibs/hr) (Ibs/yr) (Ibs/hr)
Diesel engine exhaust, particulate 1.0000 1.57E+02 1.57E+02 0.00E+00 30 matter (Diesel PM) 9901
0.0000 0.00E+00 | 0.00E+00
31 9
Table 5
Calculation of Incremental Cancer Risk Score
A G
1 Name: Whitney Ranch RocklAir Toxics Hot Spots Facility Prioritization Score Calculato Applicability Use to provide a Prioritization score for facility emissions according to Toxic Hot Spots quidelines. Entries required in yellow areas, output in gray areas. 3 Author or updater Ray Kapahi Last Update April 20, 2024 4 Facility: Whitney Ranch Rocklin
Screening Level Risk Analysis
•Project Incremental Cancer Risk Score
Data Entered by RK
Data Reviewed by:
Location
Stack Height
10 Operating Hours hr/yr 8,760.00 m 46
Emissions Potency Method Dispersion Adjustment Method
Non- Facility Non- Facility
Receptor Proximity and Proximity
Cancer Cancer Ranking Cancer Cancer Ranking
Factors
13 Score Score Priority Score Score Priority
14 0< R<100 1.000 2.26E+01 3.36E-02 High 3.76E-01 5.59E-04 Medium 15 100<R<250 0.250 5.66E+00 8.39E-03 Medium 3.76E-01 5.59E-04 Medium 16 250≤R<500 0.040 9.06E-01 1.34E-03 Low 3.39E-01 5.03E-04 Low 17 500<R<1000 0.011 2.49E-01 3.69E-04 Low 1.51E-01 2.24E-04 Low 18 1000≤R<1500 0.003 6.79E-02 1.01E-04 Low 4.89E-02 7.27E-05 Low 19 1500≤R<2000 0.002 4.53E-02 6.71E-05 Low 2.48E-02 2.48E-02 Low 20 2000<R 0.001 2.26E-02 3.36E-05 Low 1.58E-02 1.58E-02 Low 21 22 Height Adjustment <100m <250m <500m <1000m <1500m 23 <20m 60 0.25 0.04 0.011 0.003
24 20m<= <45m 0.85 0.22 0.064 0.018
Dada
25 =>45m 1 0.9 0.4 0.13
26 27 Enter the unit's CAS# of the substances emitted and 28 their amounts.
Corrected Corrected
MW Annual Maximum Annual Maximum
Correction Emissions Hourly Emissions Hourly
29 Substance CAS# (Ibs/yr) (Ibs/hr) (Ibs/yr) (Ibs/hr)
Diesel engine exhaust, particulate 1.0000 9.80E+00 9.80E+00 0.00E+00 30 matter (Diesel PM) 9901
31 0.00E+00 0.00E+00
10 EXPERIENCE
Ray Kapahi Over 30 years of experience in analyzing air quality and odor Senior Air Quality impacts, permitting of stationary sources, and preparation of Consulting Engineer 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 [email protected] as an expert witness on behalf of clients.
Office: 916.687.8352
Mobile: 916.806.8333 Following approvals for new facilities or expansion of existing facilities, Mr. Kapahi continues to work with clients to ensure on- Practice Areas going compliance.
• Air Quality Permitting
• Odor Investigation and Control
• Health Risk Assessment REPRESENTATIVE PROJECTS
Computational Fluid Dynamics
Greenhouse Gas Analysis Air Quality Modeling and Permitting Atmospheric Dispersion Modeling
Industries • Permitting of a Powdered Milk Plant (Turlock, CA) Evaluate emissions of various air pollutants from the proposed 30 : Solid Waste million gallons per year mild processing/drying facility. Demonstrate Energy Production
Construction and Mining compliance with local and state air quality regulations, including • Food Industries regulation of toxic air pollutants.
• Oil and Gas Production
• Permit Revisions for an Existing Fruit Dehydration
Education and Training
Facility (Yuba City, CA)
BSc. Physics (1972) 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) News 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.
• Presentation "Integrated Approach to • 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.
Dust and Odor Mitigation
Publications and Presentations
• Ventilation System for Odor Control (Anaheim, CA)
Presentation "Use of Advanced Models to Advanced computational fluid mechanics (CFD) models were used to Control Fugitive Odors from Composting Sites". predict the air flow and building pressure to identify the location, size and US Compost Council Annual Meeting, January number of exhaust fans required to remove odors from the transfer 2015, Austin, TX.
station building.
"Air Emissions from Landfills and Transfer Stations
- Do they Increase Public Health Risks?" • Migration of Odors and Aerosol from Leachate Presented at Quad State Environmental Evaporation Pond (Bi-County Landfill, Montgomery Conference, Pigeon Forge TN, Sept 2015.
County, TN)
"Risks of Carbon Credit Invalidation Under Analyze the movement of odors and aerosols from leachate evaporators.
California's Cap-and-Trade Program", Presented Demonstrate that evaporators were ineffective in reducing volume of at the 2014 Air and Waste Management leachate, but would release odors and VOCs to nearby homes.
Association Annual Conference. June 24-27,
2014. Long Beach, CA
• Analysis and Control of Fugitive Dust and Odors from a "Estimate of VOC Emissions from Sludge Drying", Soil Blending Facility (Stockton, CA) Presented at the 1995 SWANA Conference. Advanced computational fluid mechanics (CFD) models were used to November 1995, Baltimore, MD. predict the air flow and movement of fugitive dust at a soil blending "Use of Biofilters to Control VOCs", Biocycle, facility. With this information, the client was able to install appropriate February 1995. mitigation services to mitigate off-site migration of fugitive dust. View how the movement of dust and odors occur at:
"Impacts of the 1990 Clean Air Act https://www.youtube.com/watch?v=wXEX6IT-54U Amendments", San Jose Business Journal, March
24, 1994.
• Review of Odor Control Systems for Cannabis Cultivation "Modeling Fine Particulates" in Municipal Waste and Distribution Facilities (Palm Springs, CA) Incineration Risk Assessment, Edited by Curtis EPS evaluated the odor control system for over 15 different odor Travis, Plenum Press, 1990. cultivation and distribution facilities in Palm Springs. The effectiveness of the proposed system was evaluated and recommendations were made to Specialized Training
the City of Palm Springs.
Accidental Release Modeling Workshop. Trinity
Consultants. Dallas, TX November 1-2, 2018. Analysis of Public Health Risks HARP2 (Risk Assessment Model) Training at • Analysis of Public Health Risks Associated with California Air Resources Board. Redding, CA April Composting Operations (Napa County, CA) 2016.
Estimate the types and amounts of toxic air contaminants (TAC) released Hearing Board Variance Training - California Air from green waste and food waste composting. An air dispersion model Resources Board (1995) was used with local wind data to determine the concentration of each TAC.
The concentration estimates were supplemented with toxicity data to Air Emissions and Odors from Wastewater - quantify public health risks from exposure to the various toxic pollutants.
University of Texas, Austin (1994)
Professional Affiliations
• Analysis of Public Health Risks from Proposed Asphalt Air and Waste Management Association Plant (Kern County, California) (Board Member)
Analyze emissions of any toxic air pollutants from a proposed 250 tons per American Institute of Chemical Engineers day asphalt plant. Emissions from aggregate drying, propane combustion (Member) 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.