Serving Monterey, San Benito, and Santa Cruz Counties 24580 Silver Cloud Court Monterey, CA 93940
PHONE: (831) 647-9411 • FAX: (831) 647-8501
Richard A. Stedman, Air Pollution Control Officer
February 9th, 2024
City of Salinas: Community Development Department
Attn: Thomas Wiles, Senior Planner
65 W. Alisal St.
Salinas, CA 93901
Re: St. George’s Senior Apartments
Dear Mr. Wiles
Thank you for providing the Monterey Bay Air Resources District (MBARD) with the opportunity to comment on the Mitigated Negative Declaration and Initial Study for the St. George’s Senior Apartments Project. MBARD has reviewed the MND/IS and has the following comments:
Air Quality
o Emission Quantification
▪ Emission estimates must be supported with substantial evidence. Please include quantification of the proposed project’s construction and operational emissions, as indicated on pages 6-7 of the initial study, with a comparison to the MBARD’s CEQA thresholds to evaluate the significance of the proposed project’s impact on air quality.
The use of the California Emissions Estimator Model (CalEEMOD) is recommended as a tool to evaluate the project’s emissions.
o Fugitive Dust Control
▪ Given the proximity to sensitive receptors, fugitive dust should be mitigated during the construction phase of the project. Compliance with MBARD Rule 402 (Nuisance) and CEQA Guidelines, Section 8.2 can be maintained by implementing the following Best Management Practices as applicable:
• Water all active construction areas at least twice daily. Frequency should be based on the type of operation, soil, and wind exposure. • Prohibit all grading activities during periods of high wind (over 15 mph). • Cover all trucks hauling dirt, sand, or loose materials. • Cover inactive storage piles.
• Maintain at least 2’0” of freeboard in haul trucks.
• Apply chemical soil stabilizers on inactive construction areas (disturbed lands within construction projects that are unused for at least four consecutive days).
Stationary/Mobile Equipment Emissions
o Required Permits
▪ If a generator, boiler, or other stationary sources of air pollutants are needed to support the construction process or will be installed for use in the operation of the project, a
Richard A. Stedman, Air Pollution Control Officer
permit may be required. Any stationary piston-type internal combustion engine of greater than or equal to 50 brake horsepower (bhp) requires a permit. Please contact MBARD’s Engineering Division if there are any questions regarding the permitting process.
o Construction Equipment
▪ To further reduce construction emissions, MBARD recommends using cleaner than required equipment that conforms to the California Air Resources Board’s (CARB) Tier 3 or Tier 4 emission standards. We further recommend that whenever feasible, construction equipment use alternative fuels such as compressed natural gas (CNG), propane, electricity, or biodiesel. This would have the added benefit of reducing diesel exhaust emissions.
Hazardous Materials
o Asbestos Piping
▪ The Air District wants to ensure that if older underground asbestos (Transite) piping is encountered during grading, trenching, or other land disturbing actions during construction, the requirements of MBARD Rule 424 National Emissions Standards for Hazardous Air Pollutants (NESHAP) could be triggered. Please contact MBARD’s Compliance Division at (831) 647-9411 for more information regarding this rule.
Greenhouse Gases
o EV Charging Stations
▪ With the growing use of electric vehicles (EV), please consider making public EV charging stations available in the facility’s parking areas. For information about potential electric infrastructure grant funding opportunities, please contact MBARD’s Planning Division at (831) 647-9411.
I appreciate the opportunity to comment on the MND/IS for the St. George’s Senior Apartments Project.
Please let me know if you have any questions. I may be reached at (831) 718-8030 or [email protected].
Regards,
Edward Ballaron
Air Quality Planner I
cc: Rich Stedman, Air Pollution Control Officer
David Frisbey, Planning and Air Monitoring Manager
Shawn Boyle, Planning and Air Monitoring Supervisor