San Marcos City Council
July 23, 2024

Appendix B1
Air Quality and Greenhouse Gas Emissions Technical
Memorandum for the Reduced Development Footprint
Alternative – Vernal Pool Minimization

MEMORANDUM
To: City of San Marcos
From: Adam Poll, Dudek
Subject: Air Quality and Greenhouse Gas Emissions Technical Memorandum for the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization Date: February 13, 2024
cc: Vanessa Scheidel, Dudek
Attachments: A – CalEEMod Output Files
B – Construction HRA Output Files
C – CAP Consistency Worksheet

The purpose of this technical memorandum is to assess the potential air quality and greenhouse gas (GHG) emissions impacts associated with construction and operation of the Reduced Development Footprint Alternative – Vernal Pool Impact Minimization (vernal pool alternative) . This analysis uses the significance thresholds in Appendix G of the California Environmental Quality Act (CEQA) Guidelines (14 CCR 15000 et seq.) and the emissions-based significance thresholds recommended by the San Diego Air Pollution Control District (SDAPCD) and other applicable thresholds of significance. This analysis compares the potential impacts of the vernal pool alternative to that which was evaluated in the Air Quality and Greenhouse Gas Emissions Technical Report for the Pacific Project (Dudek report), dated February 6, 2023 (Dudek 2023) (original project).

Section 1, Project Description, discusses the details of the project design. Section 2, Approach and Methodology, discusses the approach to estimating emissions of criteria air pollutants and GHG emissions during construction and operation of the project. Section 3, Air Quality, describes the thresholds of significance and presents an air quality impact analysis per Appendix G of the CEQA Guidelines. Section 4, Greenhouse Gas Emissions, describes the GHG emissions– related thresholds of significance and presents a GHG emissions impact analysis per Appendix G of the CEQA Guidelines.

Section 5, Conclusions, summarizes the findings of the analysis. Section 6, References Cited, includes a list of the references cited in this technical report.
1 Project Description
The approximately 33-acre project site is located in the western portion of the City, at the northwest corner of Las Posas Road and Linda Vista Drive. The 33.2-acre project site is an infill site located in the western portion of the City of San Marcos (City), at the northwest corner of S. Las Posas Road and Linda Vista Drive, comprised of Assessor’s Parcel Numbers 219-222-01, 219-222-02, 219-222-03, and 219-222-04. La Mirada Drive abuts the site’s northern boundary, while South Pacific Street abuts the pro perty’s western boundary. The Grand Plaza shopping center is located directly across Las Posas Road to the east. Light industrial uses are adjacent to the site’s

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northern, southern, and western boundary, and Bradley Park is located across from the site’s southwestern corner.

Single- and multi-family residential uses are located to the west and south of Bradley Park.

The vernal pool alternative consists of 228 residential units, including a mix of rowhomes and villas on approximately 9.7 acres of the 33.2 -acre project site. The vernal pool alternative includes a total of 532 parking spaces and 82,311 square feet of common open space area. The vernal pool alternative also includes landscaping, bio -retention areas, and circulation improvements. The remaining approximately 23.5 acres of the 33.2 -acre project site would be preserved and restored as open space and habitat area. The vernal pool alternative would have a density of approximately 6.86 dwelling units per acre, including the open space and habitat area. Figure 1 shows the location of the reduced project and Figure 2 provides a site plan.

The project proposes a General Plan Amendment, Rezone, Specific Plan, Tentative Map, and Multi -Family Site Development Plan. The General Plan Amendment and Rezone would change the General Plan designation and Zoning from Industrial (I) to Specific Plan Are a (SPA).

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Chula Vista
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8 Project Site

FIGURE 1
Project Location
Reduced Development Footprint Alternative – Vernal Pool Impact Minimization

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FIGURE 2
Reduced Development Footprint Alternative - Vernal Pool Impact Minimization Pacific Project

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2 Approach and Methodology

2.1 Construction
Construction assumptions, including timing, phasing, and equipment type and quantity, as well as worker and vendor truck trips, were based on information provided by the applicant. Default values provided by the California Emissions Estimator Model (CalEEMod) were used where detailed project information was not available. For purposes of estimating project GHG emissions, it is assumed that construction of the vernal pool alternative would commence in June 20261 and would end in July 2027. Construction of the vernal pool alternative is anticipated to occur in five phases. Accordingly, five phases consisting of site preparation, grading, building construction, paving, and architectural coating were assumed. The analysis contained herein is based on the following assumptions (the duration of phases is approximate):
▪ Site Preparation: 10 days (June 2026)
▪ Grading: 2 months (June 2026 – July 2026)
▪ Building Construction: 11 months (July 2026 – May 2027) ▪ Paving: 1 month (May 2027 – June 2027)
▪ Architectural Coating: 1 month (June 2027 – July 2027) The construction equipment mix used for estimating construction emissions of the vernal pool alternative is based on CalEEMod defaults and is shown in Table 1, Construction Scenario Assumptions. For worker and vendor truck trips, the default CalEEMod assumptions for one-way trips were rounded up to the nearest even number to account for whole round trips. For this analysis, it was generally assumed that heavy construction equipment would operate 5 days a week (22 days per month) during project construction. Grading activities were anticipated to be minimal for the project; therefore, no haul trucks would be required to import or export material. VOC off-gassing emissions result from evaporation of solvents contained in surface coatings, such as in paints and primers used during the architectural coating phase. The VOC emission s factor is based on the VOC content of the surface coatings .

SDAPCD’s Rule 67.0.1 (Architectural Coatings) governs the VOC content for interior and exterior coatings (SDAPCD 2015): internal reapplication architectural coatings would have a VOC content of 50 grams per liter (g/L), and exterior architectural coatings would have a VOC content of 100 g/L.

Table 1. Construction Scenario Assumptions – Vernal Pool Alternative Construction
Phase
One -Way Trips
Equipment Quantity
Hours
Per Day
Daily
Workers
Daily
Vendor
Trucks
Total
Haul
Trucks
Site Preparation 18 4 0 Rubber-Tired Dozers 3 8

1 The analysis assumes a construction start date of June 2026, which represents the earliest date construction would initiate (although unlikely). Assuming the earliest start date for construction represents the worst -case scenario for criteria air pollutant emissions because equipment and vehicle emission factors for later years would be slightly less due to more stringent standards for in-use off-road equipment and heavy -duty trucks, as well as fleet turnover replacing older equipment and vehicles in later years.

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SUBJECT: AIR QUALITY AND GREENHOUSE GAS EMISSIONS TECHNICAL MEMORANDUM FOR THE REDUCED DEVELOPMENT FOOTPRINT ALTERNATIVE – VERNAL POOL IMPACT MINIMIZATION

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Table 1. Construction Scenario Assumptions – Vernal Pool Alternative Construction
Phase
One -Way Trips
Equipment Quantity
Hours
Per Day
Daily
Workers
Daily
Vendor
Trucks
Total
Haul
Trucks
Tractors/Loaders/
Backhoes 4 8
Grading 16 4 0 Excavators 2 8
Graders 1 8
Rubber-Tired Dozers 1 8
Tractors/Loaders/
Backhoes 2 8
Building Construction 254 60 0 Cranes 1 7
Forklifts 3 8
Generator Sets 1 8
Tractors/Loaders/
Backhoes 3 7
Welders 1 8
Paving 16 4 0 Pavers 2 8
Paving Equipment 2 8
Rollers 2 8
Architectural Coating 52 4 0 Air Compressors 1 6
Notes: See Appendix A.

The vernal pool alternative would implement dust control strategies. To reflect implementation of proposed dust control strategies, the following was assumed in CalEEMod in accordance with SDAPCD Rule 55:
▪ Water exposed area two times per day (55% reduction in PM10 and PM2.5). ▪ Limit unpaved road travel to 15 miles per hour.

Health Risk Assessment
As a precautionary measure, a health risk assessment (HRA) was performed to assess the impact of construction on sensitive receptors proximate to the project . This report includes an HRA associated with emissions from construction of the project based on the methodologies prescribed in the Office of Environmental Health Hazard Assessment (OEHHA) Air Toxics Hot Spots Program Risk Assessment Guidelines – Guidance Manual for Preparation of Health Risk Assessments (OEHHA 2015). To implement the OEHHA Guidelines based on Project information, the SDAPCD has developed a three-tiered approach where each successive tier is progressively more refined, with fewer conservative assumptions. The SDAPCD Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program Health Risk Assessments provides guidance with which to perform HRAs within the SDAB (SDAPCD 2022).

Health effects from carcinogenic air toxics are usually described in terms of cancer risk. The SDAPCD recommends a carcinogenic (cancer) risk threshold of 10 in a million. Additionally, some TACs increase non-cancer health risk due to long -term (chronic) exposures. The Chronic Hazard Index is the sum of the individual substance chronic

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hazard indices for all TACs affecting the same target organ system. The SDAPCD recommends a Chronic Hazard Index significance threshold of 1.0 (project increment). The exhaust from di esel engines is a complex mixture of gases, vapors, and particles, many of which are known human carcinogens. DPM has established cancer risk factors and relative exposure values for long -term chronic health hazard impacts. No short -term, acute relative exposure level has been established for DPM; therefore, acute impacts of DP M are not addressed in this assessment. This HRA evaluated the risk to future residents from diesel emissions from exhaust from onsite construction equipment and diesel haul and vendor trucks.

The dispersion modeling of DPM was performed using the American Meteorological Society/EPA Regulatory Model (AERMOD), which is the model SDAPCD requires for atmospheric dispersion of emissions. AERMOD is a steady - state Gaussian plume model that incorporates air dispersion based on planetary boundary layer turbulence structure and scaling concepts, including treatment of surface and elevated sources, building downwash, and simple and complex terrain (EPA 2015). For the Project, AERMOD was run with all sources emitting unit emissions (1 gram per second) to obtain the “Χ/Q” values. Χ/Q is a dispersion factor that is the average effluent concentration normalized by source strength and is used as a way to simplify the representation of emissions from many sources.

The Χ/Q values of ground-level concentrations were determined for construction emissions using AERMOD and the maximum concentrations determined for the 1 -hour and Period averaging periods . Principal parameters of this modeling are presented in Table 2.

Table 2. AERMOD Principal Parameters – Vernal Pool Alternative Parameter Details
Meteorological Data The latest 3-year meteorological data (2010–2012) for the Escondido Station (Station ID 3177) from SDAPCD were downloaded and then input to AERMOD. For cancer or chronic noncancer risk assessments, the average cancer risk of all years modeled was used.

Urban versus Rural
Option
Urban areas typically have more surface roughness, as well as structures and low- albedo surfaces that absorb more sunlight—and thus more heat—relative to rural areas. However, based on the SDAPCD guidelines, the rural dispersion option was selected due to the project’s proximity to the ocean.

Terrain
Characteristics
The terrain in the vicinity of the modeled project site is generally flat. The elevation of the modeled site is about 545 feet above sea level. Digital elevation model files were imported into AERMOD so that complex terrain features were evaluated as appropriate.

Elevation Data Digital elevation data were imported into AERMOD, and elevations were assigned to the emission sources and receptors. Digital elevation data were obtained through AERMOD View in the United States Geological Survey’s National Elevation Dataset format with a 30-meter resolution.

Emission Sources
and Release
Parameters
Air dispersion modeling of DPM from construction equipment was conducted using emissions estimated using the CalEEMod, assuming emissions would occur 8 hours per day, 5 days per week. The project area was modeled as a series of volume sources.

Source Release
Characterizations
Based on EPA methodology, the modeled line volume sources would result in a release height of 3.4 meters, a plume height of 6.8 meters, and a plume width of

8.6 meters for off-road equipment and diesel trucks (EPA 2015).

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SUBJECT: AIR QUALITY AND GREENHOUSE GAS EMISSIONS TECHNICAL MEMORANDUM FOR THE REDUCED DEVELOPMENT FOOTPRINT ALTERNATIVE – VERNAL POOL IMPACT MINIMIZATION

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Table 2. AERMOD Principal Parameters – Vernal Pool Alternative Parameter Details
Discrete Receptors A uniform Cartesian grid overlaying residential receptors in close proximity to the project with 20-meter resolution was placed. Additional discrete receptors were placed over residences not within the uniform Cartesian grid.

Note: See Appendix B.

Dispersion model plotfiles from AERMOD were then imported into CARB’s Hotspots Analysis and Reporting Program Version 2 to determine health risk, which requires peak 1-hour emission rates and annual-averaged emission rates for all pollutants for each modeling source. For the residential health risk, the HRA assumes exposure would start in the third trimester of pregnancy . The results of the HRA are provided in Section 3.2, and detailed results and methodology are provided in Appendix B.

2.2 Operation
Emissions from the operational phase of the vernal pool alternative was estimated using CalEEMod. Operational year 2027 was assumed because it would coincide with completion of construction.

Area Sources
The vernal pool alternative would generate air quality emissions from area sources. Consumer products are chemically formulated products used by household and institutional consumers, including detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care produc ts; home, lawn, and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products. Other paint products, furniture coatings, or architectural coatings are not considered consumer products (CAPCOA 2 021). The CalEEMod default values for consumer products were modeled.

VOC off-gassing emissions result from evaporation of solvents contained in surface coatings, such as in paints and primers used during building maintenance. CalEEMod calculates the VOC evaporative emissions from application of surface coatings based on the VOC emissions factor, the building square footage, the assumed fraction of surface area, and the reapplication rate. The VOC emission s factor is based on the VOC content of the surface coatings, and SDAPCD’s Rule 67.0.1 (Architectural Coatings) governs th e VOC content for interior and exterior coatings (SDAPCD 2015). The model default reapplication rate of 10% of area per year is assumed. Consistent with CalEEMod defaults, it was assumed that the surface area for painting equals 2.7 times the floor square footage, with 75% assumed for interior coating and 25% assumed for exterior surface coating (CAPCOA 2021). Consistent with the architectural coatings used during the construction phase, the applicant would use architectural coatings with a VOC content of 50 g/L for internal reapplication, and a VOC content of 100 g/L for exterior architectural coatings for any reapplication during operation.

Landscape maintenance includes fuel combustion emissions from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chainsaws, and hedge trimmers. Emissions from landscape equipment use are estimated based on CalEEMod default values for emission factors (grams per square foot of nonresidential building space per day) and number of summer days (when landscape maintenance would generally be performed)

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and winter days. Emissions associated with potential landscape maintenance equipment were included to conservatively capture potential project operational emission sources.

No woodstoves or wood burning fireplaces would be included in the project design; therefore, they were not included in the CalEEMod analysis. The vernal pool alternative would include natural gas fireplaces and are included in the CalEEMod analysis.

Energy Sources
As represented in CalEEMod, energy sources would include emissions associated with building electricity and natural gas usage. Electricity use would contribute indirectly to criteria air pollutant emissions; however, the emissions from electricity use are only quantified for GHGs in CalEEMod, since criteria pollutant emissions occur at the site of the power plant, which is typically off site.

Operational criteria air pollutant emissions from energy sources include natural gas combustion for appliances and space and water heating. The current Title 24, Part 6 standards, referred to as the 2019 Title 24 Building Energy Efficiency Standards, became effective on January 1, 2020. CalEEMod defaults were assumed for electricity and natural gas.

CalEEMod default energy intensity factors (CO2, CH4, and N2O mass emissions per kilowatt hour) for SDG&E are based on the value for SDG&E’s energy mix in 2021. As explained in Section 3.2.2, SB X1-2 established a target of 33% from renewable energy sources for all electricity providers in California by 2020, and SB 350 calls for further development of renewable energy, with a target of 50% by 2030.

Mobile Sources
The vernal pool alternative would generate air quality emissions from mobile sources (vehicular traffic) as a result of the residents of the project. CalEEMod was used to estimate emissions from proposed vehicular sources (refer to Appendix A). The trip generation rates for the project residential land use were adjusted in CalEEMod to match the overall weekday daily trips based on the Traffic Impact Analysis (LLG 2021). CalEEMod default data, trip modes, trip lengths, fleet mix, and emissions factors were u sed for the model inputs. CalEEMod default vehicle emission factors and vehicle fleet mix for 2027, as based on the CARB EMFAC2017 model, were used to estimate emissions associated with vehicular sources.

Solid Waste
The vernal pool alternative would generate solid waste and therefore would result in CO 2e emissions associated with landfill off -gassing. CalEEMod default values were used to estimate GHG emissions associated with solid waste.

Water and Wastewater
Supply, conveyance, treatment, and distribution of water for the vernal pool alternative would require the use of electricity, which would result in associated indirect GHG emissions. Similarly, wastewater generated by the project would require the use of electricity for conveyance and treatment, along with GHG emissions generated during wastewater

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treatment. Water consumption estimates for both indoor and outdoor water use relied on CalEEMod default assumptions.
3 Air Quality Assessment

3.1 Thresholds of Significance
Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) provides guidance for evaluating whether a development project may result in significant impacts. Based on Appendix G of the CEQA Guidelines, the project would have a significant impact on air quality if the project would:

1. Conflict with or obstruct implementation of the applicable air quality plan.

2. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard.

3. Expose sensitive receptors to substantial pollutant concentrations.

4. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.) indicates that, where available, the significance criteria established by the applicable air quality management district or pollution control district may be relied upon to determine whether the proj ect would have a significant impact on air quality. As part of its air quality permitting process, the SDAPCD has established thresholds in Rule 20.2 requiring the preparation of Air Quality Impact Assessments for permitted stationary sources. The SDAPCD sets forth quantitative emission thresholds below which a stationary source would not have a significant impact on ambient air quality. Project -related air quality impacts estimated in this environmental analysis would be considered significant if any of th e applicable significance thresholds presented in Table 3 are exceeded. For CEQA purposes, these screening criteria can be used as numeric methods to demonstrate that a project’s total emissions would not result in a significant impact to air quality. For nonattainment pollutants, if emissions exceed the thresholds shown in Table 3, the project could have the potential to result in a cumulatively considerable net increase in these pollutants and thus could have a significant impact on ambient air quality. A project that involves a use that would produce objectionable odors would be deemed to have a significant odor impact if it would affect a considerable number of off-site receptors.

Table 3. San Diego Air Pollution Control District Air Quality Significance Thresholds Construction Emissions
Pollutant Total Emissions (Pounds per Day)
Respirable particulate matter (PM10) 100
Fine particulate matter (PM2.5) 55
Oxides of nitrogen (NOx) 250
Sulfur oxides (SOx) 250
Carbon monoxide (CO) 550
Volatile organic compounds (VOC) 137a

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SUBJECT: AIR QUALITY AND GREENHOUSE GAS EMISSIONS TECHNICAL MEMORANDUM FOR THE REDUCED DEVELOPMENT FOOTPRINT ALTERNATIVE – VERNAL POOL IMPACT MINIMIZATION

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Table 3. San Diego Air Pollution Control District Air Quality Significance Thresholds Construction Emissions
Pollutant Total Emissions (Pounds per Day)
Operational Emissions
Pollutant
Total Emissions
Pounds per
Hour
Pounds per
Day Tons per Year
Respirable particulate matter (PM10) — 100 15
Fine particulate matter (PM2.5) — 55 10
Oxides of nitrogen (NOx) 25 250 40
Sulfur oxides (SOx) 25 250 40
Carbon monoxide (CO) 100 550 100
Lead and lead compounds — 3.2 0.6
Volatile organic compounds (VOCs) — 137a 13.7
Source: SDAPCD Rules 1501 and 20.2(d)(2).
a VOC threshold based on South Coast Air Quality Management District (SCAQMD) levels per the SCAQMD and the Monterey Bay Air Pollution Control District, which have similar federal and state attainment status to San Diego.

3.2 Impact Analysis
Threshold 1: Would the project conflict with or obstruct implementation of the applicable air quality plan? The SDAPCD is responsible for developing and implementing the clean air plans for attainment and maintenance of the ambient air quality standards in the SDAB—specifically, the SIP and RAQS. 2 SANDAG is responsible for developing forecasts and data that are used by the SDAPCD in preparing the SIP and RAQS. The federal O 3 maintenance plan, which is part of the SIP, was adopted in 2012. The SIP includes a demonstration that current strategies and tactics will maintain acceptable air quality in the basin based on the NAAQS. The RAQS was initially adopted in 1991 and is updated every 3 years (most recently in 2022). The RAQS outlines SDAPCD’s plans and control measures designed to attain the state air quality standards for O 3. The SIP and RAQS rely on information from CARB and SANDAG, including mobile and area source emissions , as well as information regarding projected growth in the County as a whole and the cities in San Diego County, to project future emissions and determine the strategies necessary for the reduction of emissions through regulatory controls. CARB mobile source emission projections and SANDAG growth projections are based on population, vehicle trends, and land use plans developed by the County and the cities in the County as part of development of their general plans.

Although the SDAPCD and City do not provide guidance regarding the analysis of impacts associated with air quality plan conformance, the Cou nty’s Guidelines for Determining Significance and Report and Format and Content Requirements – Air Quality does discuss conformance with the RAQS (County of San Diego 2007). The guidance indicates that, if the project, in conjunction with other projects, contributes to growth projections that would not exceed SANDAG’s growth projections for a c ity, the project would not be in conflict with the RAQS. If a project

2 For the purpose of this discussion, the relevant federal air quality plan is the Ozone Maintenance Plan (SDAPCD 2012). The RAQS is the applicable plan for purposes of state air quality planning. Both plans reflect growth projections in the SDAB.

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includes development that is greater than that anticipated in the local plan and SANDAG’s growth projections, the project might be in conflict with the SIP and RAQS and may contribute to a potentially significant cumulative impact on air quality (County of San Diego 2007). The project’s proposed zoning is compared to the existing land use designation on the site and then the project’s growth inducing impacts are compared to those included in the SANDAG’s growth projections for the City.

The vernal pool alternative site is currently zoned Industrial (I) with a maximum floor-to-area ratio of 0.50. The floor-to- area ratio means the ratio of gross building area of the development, excluding structured parking areas, proposed for the project divided by the net lot area. According to the City of San Marcos Municipal Code, the Industrial (I) land use zone is intended to “provide a setting for the full range of indoor manufacturing, distribution, warehousing, processing, and general service uses that are adequately served by vehicular arterials and utilities. Industries that use hazardous materials, require heavy equipment, and/or that generate sustained noise levels are deemed appropriate for this Zone, and may be permitted according to the standards of this chapter. The I Zone is intended to implement and be consistent with the Industrial land use designation of the General Plan” (City of San Marcos 2020a).

The vernal pool alternative proposes a GPA/Rezone to change the land use from an Industrial (I) to a SPA. This target density would net a maximum of 228 dwelling units. The City projects an increase of 3,170 housing units between 2020 and 2035 (SANDAG 2013), and the vernal pool alternative would only account for 7% of the projected housing units to increase in the City between 2020 and 2035 in the SANDAG Series 13 forecast. The project’s proposed GPA/Rezone would be within the growth projections for the City; thus, the vernal pool alternative would result in regional growth that is accounted for within the RAQS . Furthermore, at a regional level, the growth is consistent with the underlying growth forecasts in the SIP and RAQS. Therefore, implementation of the vernal pool alternative would not conflict with the RAQS or SIP, and potential future development would be consistent with the growth in the region. The project’s proximity to State Route 78 and the Palomar College Sprinter station and bus station make for ideal connectivity to a regional transportation network, employment centers, and shopping and services. In addition, the project would implement applicable measures in the City’s 2020 CAP Consistency Checklist (see Appendix C), which would result in co -benefits to reducing the project’s operational air quality emissions by installing electric vehicle charging stations, installing bicycle infrastructure, implementing a Transportation Demand Management Plan, and reducing parking near transit. These measures would further reduce the project’s emissions from vehicle trips, increase access to transit, and encourage alternative modes of transportation. Consistent with the original project, impacts would be less than significant.

Threshold 2: Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? In analyzing cumulative impacts from a project, the analysis must specifically evaluate a project’s contribution to the cumulative increase in pollutants for which the air basin is designated as nonattainment for the CAAQS and NAAQS. If a project does not exceed thresholds and is determined to have less -than-significant project-specific impacts, it may still contribute to a significant cumulative impact on air quality if the emissions from the project, in combination with the emissions fro m other proposed o r reasonably foreseeable future projects, are in excess of established thresholds. However, a project would only be considered to have a significant cumulative impact if the project’s contribution accounts for a significant proportion of the cumulative total emissions (i.e., it represents a “cumulatively considerable contribution” to the cumulative air quality impact).

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Additionally, for the SDAB, the RAQS serves as the long-term regional air quality planning document for the purpose of assessing cumulative operational emissions to ensure that the SDAB continues to make progress toward NAAQS and CAAQS attainment status. As such, cumulative projects located in the San Diego region would have the potential to result in a cumulative impact to air quality if, in combination, they would conflict with or obstruct implementation of the RAQS. Similarly, individual projects that ar e inconsistent with the regional planning documents upon which the RAQS is based would have the potential to result in cumulative operational impacts if they represent development and population increases beyond regional projections.

The SDAB has been designated as a federal nonattainment area for O 3 and a state nonattainment area for O 3, PM10, and PM 2.5. PM10 and PM2.5 emissions associated with construction generally result in “near-field” impacts.

The nonattainment status is the result of cumulative emissions from all sources of these air pollutants and their precursors within the SDAB. Construction would be short term and temporary, and once construction is completed, construction-related emissions would cease. Operational emissions generated by the vernal pool alternative would not exceed the significance thresholds for VOCs, NOx, CO, SO x, PM10, or PM 2.5, and would not cause a significant impact. As such, the project would result in less -than-significant impacts to air quality relative to operational emissions.

Construction of the vernal pool alternative would result in the temporary addition of pollutants to the local airshed caused by soil disturbance, fugitive dust emissions, and combustion pollutants from on-site construction equipment, as well as from off-site trucks hauling construction materials. Construction emissions can vary substantially from day to day, depending on the level of activity, the specific type of operation, and for dust, the prevailing weather conditions. Therefore, such emissions levels can only be estimated, with a corresponding uncertainty in precise ambient air quality impacts.

Fugitive dust (PM10 and PM2.5) emissions would primarily result from grading and site preparation activities. NOx and CO emissions would primarily result from the use of construction equipment and motor vehicles.

Construction emissions were calculated using CalEEMod for the estimated worst -case day over the construction period associated with each phase and reported as the maximum daily emissions estimated during each year of construction (202 6 and 202 7). Construction schedule assumptions, including phase type, duration, and sequencing, were based on information provided by the applicant and is intended to represent a reasonable scenario based on the best information available. A detailed depiction of th e construction schedule—including information regarding phasing, equipment u sed during each phase, haul trucks, vendor trucks, and worker vehicles—is included in Section 2.1, Construction, of this report. The information contained in Appendix A (CalEEMod Output Files) was used for the CalEEMod inputs.

Implementation of the vernal pool alternative would generate temporary air pollutant emissions from entrained dust, off-road equipment, vehicle emissions, architectural coatings, and asphalt pavement application. Entrained dust results from the exposure of earth surfaces to wind from the direct disturbance and movement of soil, resulting in PM10 and PM2.5 emissions. The project is subject to SDAPCD Rule 55, Fugitive Dust Control. This rule requires that the project take steps to restrict visible emissions o f fugitive dust beyond the property line. Compliance with Rule 55 would limit fugitive dust (PM10 and PM2.5) that may be generated during grading and construction activities.

To account for dust control measures in the calculations, it was assumed that the active sites would be watered at least two times daily, resulting in an approximately 55% reduction of PM. Compliance with Rule 55 would be required as a standard condition of project approval or for issuance of a grading permit.

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Exhaust from internal combustion engines used by construction equipment, hauling trucks (dump trucks), vendor trucks (delivery trucks), and worker vehicles would result in temporary emissions of NO x, VOC, CO, SOx, PM10, and PM2.5. Application of architectural coatings, such as exterior/interior paint and other finishes, would also produce VOC emissions; however, the contractor is required to procure architectural coatings from a supplier in compliance with the requirements of SDAPCD Rule 67.0.1, Architectur al Coatings. This rule requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories (SDAPCD 2015).

The project would comply with SDAPCD Rule 67.0.1 through the incorporation of low -VOC architectural coatings.

The VOC content assumed for the analysis was 50 g/L for interior coatings and 100 g/L for exterior coatings.

Table 4 shows the estimated maximum daily construction emissions associated with the construction of the vernal pool alternative and original project. Details of the emissions calculations are provided in Appendix A of this report.

Table 4. Estimated Maximum Daily Construction Emissions – Unmitigated Year
VOC NO x CO SO x PM 10 PM 2.5
Pounds per Day
Original Project
2023 3.39 34.73 29.46 0.08 10.29 5.76
2024 188.94 19.15 28.57 0.08 5.35 1.88
Maximum daily
emissions
188.94 34.73 29.46 0.08 10.29 5.76
Emission threshold 75 250 550 250 100 55
Threshold exceeded? Yes No No No No No
Vernal Pool Alternative
2026 2.52 25.43 21.98 0.05 10.11 5.59
2027 97.25 15.38 21.70 0.05 3.05 1.19
Maximum daily
emissions

97.25 25.43 21.98 0.05 10.11 5.59
Emission threshold 75 250 550 250 100 55
Threshold exceeded? Yes No No No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate matter with an aerodynamic diameter equal to or less than 10 microns ; PM2.5 = particulate matter with an aerodynamic diameter equal to or less than 2.5 microns.

See Appendix A for output files and modeling details.

The values shown are the maximum summer or winter daily emissions results from CalEEMod and provided in Appendix A. The maximum emissions assumes compliance with SDAPCD Rule 67.0.1, Architectural Coatings, and SDAPCD Rule 55, Fugitive Dust Control.

As shown in Table 4, daily construction emissions would not exceed the significance thresholds for NO x, CO, SOx, PM10, or PM 2.5; however, the vernal pool alternative would exceed the significance threshold for VOC. The vernal pool alternative would result in fewer daily emissions compared to the original project.

Following completion of construction activities, the project would generate VOC, NO x, CO, SO x, PM 10, and PM 2.5 emissions from mobile sources, including vehicular traffic generated by residents of the project; area sources, including the use of landscaping equipment and consumer products; and from architectural coatings.

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Table 5 presents the maximum daily emissions associated with operation of the original project and vernal pool alternative after all construction has been completed. The values shown for motor vehicles and area sources are the maximum summer or winter daily emissions results from CalEEMod.

Table 5. Estimated Project Maximum Daily Operational Emissions – Unmitigated Emission Source
VOC NO x CO SO x PM 10 PM 2.5
Pounds per Day
Original Project
Area 12.77 7.88 40.29 0.05 0.81 0.81
Energy 0.10 0.82 0.35 0.01 0.07 0.07
Mobile 7.76 8.55 71.42 0.15 16.31 4.42
Total 20.63 17.25 112.06 0.21 17.19 5.30
Emission threshold 55 250 550 250 100 55
Threshold
exceeded?
No No No No No No
Vernal Pool Alternative
Area 6.52 4.02 20.55 0.03 0.41 0.41
Energy 0.05 0.42 0.18 0.00 0.03 0.03
Mobile 3.54 3.68 32.50 0.07 8.31 2.25
Total 10.11 8.12 53.23 0.03 8.75 2.69
Emission threshold 55 250 550 250 100 55
Threshold
exceeded?
No No No No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate matter with an aerodynamic diameter equal to or less than 10 microns ; PM2.5 = particulate matter with an aerodynamic diameter equal to or less than 2.5 microns.

See Appendix A for output files and modeling details.

As shown in Table 5, the daily operational emissions from the project would not exceed the significance thresholds for VOC, NOx, CO, SO x, PM10, or PM 2.5. Operational emissions from the vernal pool alternative would be less than those of the original project.

Regarding long-term cumulative operational emissions in relation to consistency with local air quality plans, the SIP and RAQS serve as the primary air quality planning documents for the state and SDAB, respectively. The SIP and RAQS rely on SANDAG growth projections based on population, vehicle trends, and land use plans developed by the cities and the County as part of development of their general plans. Development that is consistent with the growth anticipated by local plans would be consistent with the SIP and RAQS and would result in emissions that are accounted for. Projects that conform to the permitted land use, or result in a less emissions-intensive use, and are therefore accounted for in the SIP and RAQS and would not be considered to result in cumulatively considerable impacts from operational emissions. As stated previously, the project would result in fewer vehicle miles traveled than buildout of the land use built under the existing land use designation that was anticipated by the RAQS, and would be within the housing growth projections assumed in the SIP and RAQS ; therefore, the project would not result in significant regional emissions that are not accounted for within the RAQS.

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However, project construction would exceed the significance threshold for VOC. As a result, the potential for the vernal pool alternative to result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable national or California ambient air quality standard is potentially significant.

Threshold 3: Would the project expose sensitive receptors to substantial pollutant concentrations? Air quality varies as a direct function of the amount of pollutants emitted into the atmosphere, the size and topography of the air basin, and the prevailing meteorological conditions. Air quality problems arise when the rate of pollutant emissions exceeds the rate of dispersion. Reduced visibility, eye irritation, and adverse health impacts on those persons termed “sensitive receptors” are the most serious hazards of existing air quality conditions in the area. Some land uses are considered more sensitive to changes in air quality than others, depending on the population groups and the activities involved. People most likely to be affected by air pollution, as identified by CARB, include children, older adults, athletes, and people with cardiovascular and chronic respiratory diseases; however, for the purposes of this analysis, residents are also considered sensitive receptors. As such, sensitive receptors include residences, schools, playgrounds, childcare centers, athletic facilities, long -term healthcare facilities, rehabilitation centers, convalescent centers, and retirement homes.

Health Impacts of Toxic Air Contaminants
In addition to impacts from criteria pollutants, project impacts may include emissions of pollutants identified by the state and federal government as TACs or hazardous air pollutants. State law has established the framework for California’s TAC identification and control program, which is generally more stringent than the federal program and aimed at TACs that ar e a problem in California. The s tate has formally identified more than 200 substances as TACs, including the federal hazardous air pollutants, and is adopting appropriate control measures for sources of these TACs. The greatest potential for TAC emissions during construction would be diesel particulate emissions from heavy-duty equipment operations and heavy-duty trucks, and the associated health impacts to sensitive receptors.

The following measures are required by state law to reduce diesel particulate emissions:
▪ Fleet owners of mobile construction equipment are subject to the CARB Regulation for In -use Off-road Diesel Vehicles (Title 13 California Code of Regulations, Chapter 9, Section 2449), the purpose of which is to reduce DPM and criteria pollutant emissions from in-use (existing) off-road diesel-fueled vehicles. ▪ All commercial diesel vehicles are subject to Title 13, Section 2485 of the California Code of Regulations, limiting engine idling time. Idling of heavy-duty diesel construction equipment and trucks during loading and unloading shall be limited to 5 minutes; electric auxiliary power units should be used whenever possible.

The greatest potential for TAC emissions during construction would be DPM emissions from heavy-duty equipment operations and heavy-duty trucks during construction of the project and the associated health impacts to sensitive receptors.

However, as a precautionary measure, an HRA was performed to evaluate the risk from diesel exhaust emissions on existing sensitive receptors and future onsite receptors from construction activities. The HRA methodology was described in Section 2.1, and the detailed assessment is provided in Appendix B. Table 6 summarizes the results of the HRA for the original project and vernal pool alternative construction.

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Table 6. Construction Activity Health Risk Assessment Results Impact Parameter Units
Project
Impact
CEQA
Threshold Level of Significance
Original Project
Cancer Risk Per Million 6.4 10.0 Less than Significant
HIC Not Applicable 0.005 1.0 Less than Significant
Vernal Pool Alternative
Cancer Risk Per Million 1.4 10.0 Less than Significant
HIC Not Applicable 0.001 1.0 Less than Significant
Source: Appendix B.

Notes: CEQA = California Environmental Quality Act; HIC = Chronic Hazard Index.

The results of the HRA demonstrate that the TAC exposure from construction diesel exhaust emissions from the previous and vernal pool alternative would result in cancer risk on site below the 10 in 1 million threshold, as well as Chronic Hazard Index less than 1.0. The vernal pool alternative would result in a lower cancer risk than the original project.

Therefore, TAC emissions from construction of the vernal pool alternative would not expose sensitive receptors to substantial pollutant concentrations and would result in a less than significant impact. Upon completion of construction, the project would not generate substantial TAC emissions. As such, impacts would be less than significant during operation.

Health Impacts of Carbon Monoxide
As described previously, exposure to high concentrations of CO can result in dizziness, fatigue, chest pain, headaches, and impairment of central nervous system functions. Mobile-source impacts, including those related to CO, occur essentially on two scales of motion. Regionally, project-related construction travel would add to regional trip generation and increase the vehicle miles traveled within the local airshed and the SDAB. Locally, construction traffic would be added to the roadway system in the vicinity of the project site. Although the SDAB is currently an attainment area for CO, there is a potential for the formation of microscale CO “hotspots” to occur immediately around points of congested traffic. Hotspots can form if such traffic occurs during periods of poor atmospheric ventilation, is composed of a large number of vehicles cold -started and operating at pollution-inefficient speeds, and/or is operating on roadways already crowded with non -project traffic. Because of continued improvement in vehicular emissions at a rate faster than the rate of vehicle growth and/or congestion, the potential for CO hotspots in the SDAB is steadily decreasing.

The Governor’s Office of Planning and Research and the California Natural Resources Agency have issued new CEQA Guidelines for analyzing transportation impacts. By July 1, 2020, all CEQA lead agencies must analyze a project’s transportation impacts using vehicle -miles traveled. Vehicle-miles traveled measures the distances vehicles will travel to and from a project, rather than congestion levels at intersections (LOS, graded on a scale of A–F). To account for this shift from LOS to vehicle-miles traveled, and evaluate the potential for CO hotspots for the project, analysis performed by SCAQMD is leveraged as follows.

The SDAB is a CO maintenance area (western and central part of the SDAB only). As a screening analysis, t he SCAQMD conducted CO modeling for the 2003 Air Quality Management Plan (Appendix V of SCAQMD 2003) for the four worst-case intersections in the South Coast Air Basin: (1) Wilshire Boulevard and Veteran Avenue, (2) Sunset

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Boulevard and Highland Avenue, (3) La Cienega Boulevard and Century Boulevard, and (4) Long Beach Boulevard and Imperial Highway. At the time the 2003 Air Quality Management Plan was prepared, the intersection of Wilshire Boulevard and Veteran Avenue was the most congested intersection in Los Angeles County, with an average daily traffic volume of about 100,000 vehicles per day. Using CO emission factors for 2002, the peak modeled CO 1- hour concentration was estimated to be 4.6 ppm at the intersection of Wilshire Boulevard and Veteran Avenue.

For potential future development associated with approval of the vernal pool alternative, the daily traffic volume of 100,000 vehicles would be conservative compared to the traffic volumes of nearby intersections. When added to the maximum 1-hour CO concentration from 2019 through 2021 at the San Diego – 11403 Rancho Carmel Drive monitoring station, which was 4.1 ppm in 2019, the 1-hour CO would be 8.7 ppm, while the CAAQS is 20 ppm.

The SCAQMD modeled future year 8-hour CO concentrations at the Central Los Angeles monitoring site of 4.6 ppm in 2020. Adding the 4.6 ppm to the maximum 8-hour CO concentration from 2019 through 2021 at the San Diego – 11403 Rancho Carmel Drive monitoring station, which was 2.5 ppm in 2019, the 8-hour CO would be 7.1 ppm, while the CAAQS is 9.0 ppm.

Accordingly, CO concentrations at congested intersections would not exceed the 1-hour or 8-hour CO CAAQS unless projected daily traffic would exceed 100,000 vehicles per day. Potential future development at the vernal pool alternative site would not increase daily traffic volumes at any study intersection to more than 100,000 vehicles per day (LLG 2022).3 Therefore, it is concluded that the project traffic is not anticipated to create a CO hotspot, as emissions would be dispersed rapidly and would not be concentrated, and therefore no CO hotspots would be created. As such, impacts to sensitive receptors with regard to potential CO hotspots resulting from the project’s contribution to cumulative traffic-related air quality impacts would be less than significant.

Health Impacts of Criteria Air Pollutants
Construction of the project would result in emissions that exceed the threshold for VOC without mitigation; however, project construction would not exceed significance thresholds for NO x, CO, SO x, PM10, or PM2.5. Project operation would not exceed significance thresholds for VOC, NOx, CO, SOx, PM10, or PM2.5. VOCs and NOx are precursors to O3, for which the SDAB is designated as nonattainment with respect to the NAAQS and CAAQS (the SDAB is designated by the EPA as an attainment area for the 1 -hour O3 NAAQS standard). The health effects associated with O 3 are generally associated with reduced lung function. The contribution of VOCs and NO x to regional ambient O 3 concentrations is the result of complex photochemistry. The increases in O3 concentrations in the SDAB due to O3 precursor emissions tend to be found downwind from the source location to allow time for the photochemical reactions to occur. However, the potential for exacerbating excessive O3 concentrations also depends on the time of year that the VOC emissions occur because exceedances of the O 3 CAAQS/NAAQS tend to occur between April and October when solar radiation is highest. The holistic effect of a single project’s emissions of O 3 precursors is speculative due to the lack of quantitative methods to assess this impact. Operation of the project would not exceed the significance threshold for NOx; therefore, implementation of the project would contribute minimally to regional O3 concentrations and the associated health effects. Although emission reductions from the following project design features were not quantified, the project would install electric vehicle charging stations, install bicycle infrastructure, implement Transpor tation Demand Management Plan, install electric or solar water heaters that

3 For each study intersection in each scenario evaluated in the Traffic Impact Analysis, all 10 study intersections were estimated to result in less than 100,000 vehicles per day in every scenario evaluated (ranging from 4,649 vehicles to 44,977 vehicles).

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would result in co -benefits of reducing the project’s operational emissions of VOC and NO x. However, due to exceedances in construction -generated emissions of VOC, the project could result in potential health effects associated with VOCs.

Operation of the project would not contribute to exceedances of the NAAQS or CAAQS for NO2. As discussed above, the project would implement required CAP Checklist items that would result in co-benefits of reducing the project’s operational emissions of VOC and NO x. Health effects that result from NO 2 and NOx include respiratory irritation, which could be experienced by nearby receptors during the periods of heaviest use of off -road construction equipment. However, project construction would be relatively sh ort term, and off -road construction equipment would be operating at various portions of the site and would not be concentrated in one portion of the site at any one time. In addition, existing NO 2 concentrations in the area are well below the NAAQS and CAAQS standards.

Because project-generated NOx emissions would not exceed the significance threshold, the project would not result in potential health effects associated with NO2 and NOx.

CO tends to be a localized impact associated with congested intersections. The associated potential for CO hotspots are discussed above and were determined to be a less -than-significant impact. Furthermore, the existing CO concentrations in the area are well below the NAAQS and CAAQS standards. Thus, the project’s CO emissions would not contribute to significant health effects associated with this pollutant.

Construction and operation of the project would also not exceed thresholds for PM 10 or PM 2.5, and would not contribute to exceedances of the NAAQS or CAAQS for PM or obstruct the SDAB from coming into attainment for these pollutants. The project would also not result in substantial DPM emissions during construction or operation, and therefore, would not result in significant health effects related to DPM exposure. Additionally, the project would implement dust control strategies and be required to comply with SDAPCD Rule 55, Fugitive Dust, which limits the amount of fugitive dust generated during construction. Due to the minimal contribution of PM during construction and operation, the project is not anticipated to result in health effects associated with PM10 or PM2.5.

In summary, because operation of the project would not result in exceedances of the SDAPCD significance thresholds, the potential health effects associated with criteria air pollutants would be less than significant.

Furthermore, there are numerous scientific and technological complexities associated with correlating criteria air pollutant emissions from an individual project to specific health effects or potential additional nonattainment days, and there are currently no modeling tools that could provide r eliable and meaningful additional information regarding health effects from criteria air pollutants generated by individual projects within the SDAPCD ’s jurisdiction.

The California Supreme Court’s Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502 decision (referred to herein as the Friant Ranch decision) (issued on December 24, 2018) addresses the need to correlate mass emission values for criteria air pollutants to specific health consequences, and contains the following direction from the California Supreme Court: “The Environmental Impact Report (EIR) must provide an adequate analysis to inform the public how its bare numbers translate to create potential adverse impacts or it must explain what the agency does know and why, given existing scientific constraints, it cannot translate potential health impacts further” (italics original). Currently, the SDAPCD, CARB, and EPA have not approved a quantitative method to reliably, meaningfully, and consistently translate the mass emission s estimates for the criteria air pollutants resulting from a project to specific health effects. In addition, there are numerous scientific and technological complexities associated with

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correlating criteria air pollutant emissions from an individual project to specific health effects or potential additional nonattainment days.

In connection with the judicial proceedings culminating in issuance of the Friant Ranch decision, the South Coast Air Quality Management District (SCAQMD) and San Joaquin Valley Air Pollution Control District (SJVAPCD) filed amicus briefs attesting to the extreme difficulty of correlating an individual project’s criteria air pollutant emissions to specific health impacts. Both SJVAPCD and SCAQMD have among the most sophisticated air quality modeling and health impact evaluation capabilities of the air distr icts in California. The key, relevant points from SCAQMD and SJVAPCD briefs are summarized below.

In requiring a health impact type of analysis for criteria air pollutants, it is important to understand how O3 and PM are formed, dispersed, and regulated. The formation of O 3 and PM in the atmosphere, as secondary pollutants, 4 involves complex chemical and physical interactions of multiple pollutants from natural and anthropogenic sources.

The O 3 reaction is self -perpetuating (or catalytic) in the presence of sunlight because NO 2 is photochemically reformed from nitric oxide (NO). In this way, O3 is controlled by both NOx and VOC emissions. The complexity of these interacting cycles of pollutants means that incremental decreases in one emission may not result in proportional decreases in O3 (NRC 2005). Although these reactions and interactions are well understood, variability in emission source operations and meteorology creates uncertainty in the modeled O 3 concentrations to which downwind populations may be exposed (NRC 2005). Once formed, O3 can be transported long distances by wind, and due to atmospheric transport, contributions of precursors from the surrounding region can also be important (EPA 2008).

Because of the complexity of O3 formation, a specific tonnage of VOCs or NOX emitted in a particular area does not equate to a particular concentration of O 3 in that area (SJVAPCD 2015). PM can be divided into two categories:
directly emitted PM and secondary PM. Secondary PM, like O 3, is formed via complex chemical reactions in the atmosphere between precursor chemicals such as SO x and NO x. Because of the complexity of secondary PM formation, including the potential to be transported long distances by wind, the tonnage of PM -forming precursor emissions in an area does not necessarily result in an equivalent concentration of secondary PM in that area (SJVAPCD 2015). This is especially true for individual projects, where project -generated criteria air pollutant emissions are not derived from a single “point source ” but from construction equipment and mobile sources (passenger cars and trucks) driving to, from, and around the project site.

Another important technical nuance is that health effects from air pollutants are related to the concentration of the air pollutant that an individual is exposed to, not necessarily the individual mass quantity of emissions associated with an individual project. For example, health effects from O3 are correlated with increases in the ambient level of O3 in the air a person breathes (SCAQMD 2015). However, it takes a large amount of additional precursor emissions to cause a modeled increase in ambient O3 levels over an entire region (SCAQMD 2015). The lack of link between the tonnage of precursor pollutants and the concentration of O 3 and PM2.5 formed is important because it is not necessarily the tonnage of precursor pollutants that causes human health effects; rather, it is the concentration of resulting O 3 that causes these effects (SJVAPCD 2015). Indeed, the ambient air quality standards, which are statutorily required to be set by the EPA at levels that are requisite to protect the public health, are established as concentrations of O3 and PM2.5 and not as tonnages of their precursor pollutants (EPA 2018a). Because the ambient air quality standards are focused on achieving a particular concentration region -wide, the tools and plans for attaining the ambient air quality standards are regional in nature. For CEQA analyses, project-generated emissions are typically estimated in pounds per day or tons per year and compared to mass daily or annual emission

4 Air pollutants formed through chemical reactions in the atmosphere are referred to as secondary pollutants.

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thresholds. Although CEQA thresholds are established at levels that the air basin can accommodate without affecting the attainment date for the Ambient Air Quality Standards , even if a project exceeds established CEQA significance thresholds, this does not mean that the concentration of O 3 or PM that will be created at or near the project site on a particular day or month of the year, or what specific health impacts will occur , can easily be determined (SJVAPCD 2015).

In regard to regional concentrations and air basin attainment, the SJVAPCD emphasized that attempting to identify a change in background pollutant concentrations that can be attributed to a single project, even one as large as the entire Friant Ranch Specific Plan, is a theoretical exercise. The SJVAPCD brief noted that it “would be extremely difficult to model the impact on NAAQS attainment that the emissions from the Friant Ranch project may have” (SJVAPCD 2015). The situation is further complicated by th e fact that background concentrations of regional pollutants are not uniform either temporally or geographically throughout an air basin, but are constantly fluctuating based on meteorology and other environmental factors. The SJVAPCD noted that the currently available modeling tools are equipped to model the impact of all emission sources in the San Joaquin Valley Air Basin on attainment (SJVAPCD 2015). The SJVAPCD brief then indicated that, “Running the photochemical grid model used for predicting O3 attainment with the emissions solely from the Friant Ranch project (which equate to less than one-tenth of one percent of the total NOx and VOC in the Valley) is not likely to yield valid information given the relative scale involved” (SJVAPCD 2015).

The SCAQMD and SJVAPCD have indicated that it is not feasible to quantify project -level health impacts based on existing modeling (SCAQMD 2015; SJVAPCD 2015). Even if a metric could be calculated, it would not be reliable because the models are equipped to mod el the impact of all emission sources in an air basin on attainment and would likely not yield valid information or a measurable increase in O 3 concentrations sufficient to accurately quantify O3-related health impacts from an individual project.

Nonetheless, following the Supreme Court’s Friant Ranch decision, some Environmental Impact Reports where estimated criteria air pollutant emissions exceeded applicable air district thresholds have included a quantitative analysis of potential project-generated health effects using a combination of a regional photochemical grid model (PGM)5 and the EPA’s Benefits Mapping and Analysis Program (BenMAP or BenMAP–Community Edition [CE]).6 The publicly available health impact assessments (HIAs) typically present results in terms of an increase in health incidences and/or the increase in background health incidence for various health outcomes resulting from a project’s estimated increase in concentrations of O3 and PM2.5.7 The five publicly available HIAs have concluded

5 The first step in the publicly available health impact assessment is running a regional photochemical grid model (PGM), such as the Community Multiscale Air Quality (CMAQ) model or the Comprehensive Air Quality Model with extensions (CAMx) , to estimate the increase in concentrations of O3 and PM2.5 as a result of project-generated emissions of criteria and precursor pollutants. Air districts, such as the SCAQMD, use photochemical air quality models for regional air quality planning. These photochemical models are large-scale air quality models that simulate the changes of pollutant concentrations in the atmosphere using a set of mathematical equations characterizing the chemical and physical processes in the atmosphere (EPA 2017). 6 After estimating the increase in concentrations of O3 and PM2.5, the second step in the five examples is use of BenMAP or BenMAP- CE to estimate the resulting associated health effects. BenMAP estimates the number of health incidences resulting from changes in air pollution concentrations (EPA 2018b). The health impact function in BenMAP -CE incorporates four key sources of data:
modeled or monitored air quality changes, population, baseline incidence rates, and an effect estimate. All of the five example health impact assessments focused on O3 and PM2.5.
7 The following CEQA documents included a quantitative health impact assessment to address Friant Ranch: California State University Dominguez Hills 2018 Campus Master Plan EIR (CSU Dominguez Hills 2019), March Joint Powers Association K4 Warehouse and Cactus Channel Improvements EIR (March JPA 2019), Mineta San Jose Airport Amendment to the Airport Master Plan EIR (City of San Jose 2019), City of Inglewood Basketball and Entertainment Center Project EIR (City of Inglewood 2019), and San Diego State University Mission Valley Campus Master Plan EIR (SDSU 2019).

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that the evaluated project’s health effects associated with the estimated project -generated increase in concentrations of O3 and PM2.5 represent a small increase in incidences and a very small percent of the number of background incidences, indicating that these health impacts are negligible and potentially within the model ’s margin of error. In addition, the results of the five HIAs conclude d that project emissions would not result in a substantial increase in health incidences, and the estimated emissions and assumed toxicity were also conservatively inputted into the HIA and, thus, overestimated health incidences, particularly for PM2.5.

As explained in the SJVAPCD brief (SJVAPCD 2015) and noted previously, running the PGM used for predicting O 3 attainment with the emissions solely from an individual project , like the Friant Ranch project or the vernal pool alternative, is not likely to yield valid information given the relative scale involved. The five examples reviewed support the SJVAPCD’s brief contention that consistent, reliable, and meaningful results may not be provided by methods applied at this time. Accordingl y, additional work in the industry , and more importantly, air district participation, is needed to develop a more meaningful analysis to correlate project-level mass criteria air pollutant emissions and health effects for decision makers and the public. Fu rthermore, at the time of writing, no HIA has concluded that health effects estimated using the PGM and BenMAP approach are substantial , provided that the estimated project-generated incidences represent a very small percent of the number of background incidences, potentially within the model’s margin of error.

In summary, because construction of the vernal pool alternative could result in exceedances of the significance thresholds for VOC, the potential health effects associated with criteria air pollutants, specifically O 3, would be potentially significant . Notably, there are numerous scientific and technological complexities associated with correlating criteria air pollutant emissions from an individual project to specific health effects or potential additional nonattainment days, and there are currently no modeling tools that could provide reliable and meaningful additional information regarding health effects from criteria air pollutants generated by individual projects.

Valley Fever Exposure
Valley Fever is not highly endemic to San Diego County, and within San Diego County, the incidence rate in the project area is below the County and statewide average. Construction of the project would comply with SDAPCD Rule 55, which limits the amount of fugitive dust generated during construction. Strategies the project would implement to comply with SDAPCD Rule 55 and control dust include watering two times per day and limiting speed on unpaved roads to 15 miles per hour.

Based on the low incidence rate of Coccidioidomycosis in San Diego County and the project’s implementation of dust control strategies, it is not anticipated that earth-moving activities during project construction would result in exposure of nearby sensitive receptors to Valley Fever. Therefore, the vernal pool alternative would have a less than significant impact with respect to Valley Fever exposure for sensitive receptors.

Threshold 4: Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Odors would be generated from vehicle and equipment exhaust emissions during construction of the project. Odors produced during construction would be attributable to concentrations of unburned hydrocarbons from tailpipes of construction equipment and from architectural coatings. Such odors would disperse rapidly from the project site

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and generally occur at magnitudes that would not affect substantial numbers of people. Therefore, impacts associated with odors during construction of the vernal pool alternative would be less than significant.

Land uses and industrial operations associated with odor complaints include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding (CARB 2005). The project would not engage in any of these activities. Moreover, typical odors generated from operation of the project would primarily inc lude vehicle exhaust generated by residents and through the periodic use of landscaping and maintenance equipment. Therefore, the vernal pool alternative would result in an odor impact that is less than significant.

3.3 Mitigation Measures
Mitigation Measure (MM-)AQ-1 would be implemented to reduce VOC emissions generated during construction of the project.

MM-AQ-1 Architectural Coatings. The project shall u se low volatile organic compound (VOC) architectural coatings for interior application that do not exceed VOC content of 10 grams per liter , for exterior application that do not exceed VOC content of 50 grams per liter , and for parking application do not exceed VOC content of 100 grams per liter.

For Threshold 2 ( Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard), Table 7 shows the estimated maximum daily construction emissions associated with construction of the original project and vernal pool alternative with implementation of MM-AQ-1.

Table 7. Estimated Maximum Daily Construction Emissions – Mitigated Year
VOC NO x CO SO x PM 10 PM 2.5
Pounds per Day
Original Project
2023 3.39 34.73 29.46 0.08 10.29 5.76
2024 61.80 19.15 28.57 0.08 5.35 1.88
Maximum Daily
Emissions

61.80 34.73 29.46 0.08 10.29 5.76
Emission Threshold 75 250 550 250 100 55
Threshold Exceeded? No No No No No No
Vernal Pool Alternative
2026 2.52 25.42 21.98 0.06 10.11 5.59
2027 31.91 15.38 21.70 0.05 3.05 1.19
Maximum Daily
Emissions

31.91 25.42 21.98 0.06 10.11 5.59
Emission Threshold 75 250 550 250 100 55
Threshold Exceeded? No No No No No No
Notes: VOC = volatile organic compound; NOx = oxides of nitrogen; CO = carbon monoxide; SOx = sulfur oxides; PM10 = particulate matter with an aerodynamic diameter equal to or less than 10 microns ; PM2.5 = particulate matter with an aerodynamic diameter equal to or

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less than 2.5 microns.

See Appendix A for output files and modeling details.

The values shown are the maximum summer or winter daily emissions results from CalEEMod and provided in Appendix A. The maximum emissions assumes compliance with SDAPCD Rule 55, Fugitive Dust Control and implementation of MM -AQ-1, use of low- VOC architectural coatings.

As shown in Table 7, daily construction emissions of the original project or vernal pool alternative would not exceed the significance thresholds for VOC, NOx, CO, SOx, PM10, or PM2.5. The vernal pool alternative would result in fewer emissions during construction compared to the original project . Therefore, the potential for the vernal pool alternative to result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable national o r California ambient air quality standard , and health effects of criteria air pollutants would be reduced to a less than significant impact with mitigation. 4 Greenhouse Gas Emissions Assessment

4.1 Thresholds of Significance
California has developed guidelines to address the significance of GHG emissions impacts that are contained in Appendix G of the CEQA Guidelines (14 CCR 15000 et seq.). Appendix G provides that a project would have a significant environmental impact if it would:

1. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment

2. Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

The Appendix G thresholds for GHGs do not prescribe specific methodologies for performing an assessment, do not establish specific thresholds of significance, and do not mandate specific mitigation measures. Rather, the CEQA Guidelines emphasize the lead agency’s discretion to determine the appropriate methodologies and thresholds of significance consistent with the manner in which other impact areas are handled in CEQA (CNRA 2009). Additional guidance regarding assessment of GHGs is discussed below.

City of San Marcos CAP Checklist
The City adopted the Final CAP on December 8, 2020. The CAP relies on a screening threshold based on land use size and a CAP Consistency Checklist to determine whether a project’s emissions would be consistent with GHG emissions estimated within the City’s CAP. The CAP Consistency Checklist is used to determine significance in accordance with CEQA Guidelines Section 15183.5; therefore, the CAP Consistency Checklist was used to evaluate the vernal pool alternative’s significance with respect to GHG emissions.

4.2 Impact Analysis
This section evaluates the GHG emissions impacts associated with the project. The significance criteria described in Section 4.1, Thresholds of Significance, were used to evaluate impacts associated with the construction and operation of the project.

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Threshold 1: Would the project generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Threshold 2: Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
City of San Marcos’ Climate Action Plan Consistency
This section evaluates the project’s impacts to GHG in accordance with the City’s 2020 CAP Consistency Checklist. A completed CAP Checklist is included as Appendix C. The first step in this section evaluates a project’s GHG emissions consistent with the City’s Guidance to Demonstrating Consistency with the City of San Marcos Climate Action Plan: For Discretionary Projects Subject to CEQA (City’s Guidance Document) (City of San Marcos 2020c). New discretionary development projects subject to CEQA review that emit less than 500 MT CO 2e annually would not contribute considerably to cumulative climate change impacts, as stated in the City’s Guidance Document, and therefore, would be considered consistent with the CAP and associated emissions projections.

For projects that are subject to CAP consistency review, the next step in determining consistency is to assess the project’s consistency with the growth projections used in development of the CAP. This section allows the City to determine a project’s consistency with the land use assumptions used in the CAP.

Step 1
Question 1
Step 1 of the CAP Checklist determines land use consistency. Question 1 of Step 1 asks if a project is less than a certain size. It is deemed consistent with the City’s CAP by emitting fewer than 500 MT CO2e per year and would be less than significant. The vernal pool alternative is larger than the screening size (55 multi-family residential units) and therefore would answer Yes to this question and must proceed to Question 2 of Step 1.

Question 2
Question 2 of Step 1 asks if the project is consistent with the existing General Plan land use designation. The project proposes residential use, but the General Plan currently designates the site as Industrial (I). Therefore, the project would answer No to this question and would proceed to Question 3 of Step 1.

Question 3
Question 3 of Step 1 asks if the project would generate GHG emissions equal to or less than estimated GHG emissions generated under the land use built under the existing land use designation . The following section discusses the results of the construction and emissions analysis based on the methodologies described in Section

3.3.2.1, Construction, and Section 3.3.2.2, Operation, (in the Air Quality and Greenhouse Gas Emissions Technical Report for the Pacific Project , dated February 6, 2023 (Dudek 2023)) for the existing land use designation and original project.

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Existing Land Use Designation
As shown in Table 14 of the Dudek report (Dudek 2023), estimated annual GHG emissions from the existing land use designation would be approximately 5,619 MT CO 2e per year. With amortized construction emissions, the annual operational emissions would be 5,655 MT CO2e per year.

Vernal Pool Alternative
Construction Emissions
Construction of potential future development at the vernal pool alternative site would result in GHG emissions that are primarily associated with use of off-road construction equipment, on-road vendor trucks, and worker vehicles.

CalEEMod was used to calculate the annual GHG emissions based on the construction scenario described in Section 2.1, Construction, and Appendix A. Construction of potential residential development at the vernal pool alternative site is anticipated to commence in June 2026, lasting approximately 18 months. On-site sources of GHG emissions include off-road equipment and off-site sources include on-road vehicles (haul trucks, vendor trucks, and worker vehicles). Table 8 presents construction emissions for the vernal pool alternative from on-site and off-site emission sources.

Table 8. Estimated Annual Construction GHG Emissions – Vernal Pool Alternative Year
CO 2 CH 4 N2O CO 2e
Metric Tons
2026 350.19 0.05 0.01 355.29
2027 284.92 0.04 0.01 289.11
Total 644.40
Emissions amortized over 30 years 21.48
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent.

See Appendix A for complete results.

As shown in Table 8, the estimated total GHG emissions during construction of potential development at the vernal pool alternative site would be approximately 644 MT CO 2e. Construction GHG emissions of the potential development at the vernal pool alternative site amortized over 30 years would be 21 MT CO2e per year. Amortized construction emissions are added to operational emissions to be compared to development allowed under the existing land use designation.

Operational Emissions
Operation of potential future residential development at the vernal pool alternative site would generate GHG emissions through area sources; motor vehicle trips to and from the project site; energy use (natural gas and generation of electricity consumed by the project); solid waste disposal; and generation of electricity associated with water s upply, treatment, and distribution and wastewater treatment. CalEEMod was used to calculate the annual GHG emissions based on the operational assumptions described in Section 2.2, Operation. The estimated operational emissions of potential residential development at the vernal pool alternative site are presented in Table 9.

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Table 9. Estimated Annual Operational GHG Emissions – Vernal Pool Alternative Emission Source
CO 2 CH 4 N2O CO 2e
Metric Tons
Area 183.16 0.01 0.00 184.30
Energy 329.93 0.02 0.00 331.35
Mobile 1,156.39 0.08 0.05 1,174.02
Waste 21.38 1.26 0.00 52.98
Water 77.91 0.49 0.01 93.76
Total 1,836.41
Amortized construction emissions 21.48
Total with amortized construction emissions 1,857.89
Notes: CO2 = carbon dioxide; CH4 = methane; N2O = nitrous oxide; CO2e = carbon dioxide equivalent; <0.01 = reported value less than 0.01.

See Appendix A for complete results.

As shown in Table 9, estimated annual GHG emissions from potential residential development at the vernal pool alternative site would be approximately 1,836 MT CO2e per year. With amortized construction emissions, the annual operational emissions would be 1,858 MT CO2e per year. Estimated annual GHG emissions from development of the site under the existing land use designation would be 5,655 MT CO 2e per year. Therefore, potential future development associated with the approval of the vernal pool alternative would generate less GHG emissions when compared to the existing land use designation. The vernal pool alternative also resulted in fewer GHG emissions compared to the original project (3,866 MT CO2e per year) (Dudek 2023). The project would answer Yes to Question 3 of Step 1 and can proceed to Step 2 of the Checklist.

Step 2
The second step of CAP consistency review is to evaluate a project’s consistency with the applicable strategies and measures of the CAP. Each checklist item is associated with a specific GHG reduction measure in the City’s CAP.

Not applicable (“N/A”) should only be checked based on the direction provided in each checklist item question. All projects for which the measure is applicable must demonstrate that the project would implement measures consistent with the checklist item, or fully substantiate how the item would be infeasible for project implementation. “N/A” responses are subject to Planning Division review and approval. If “No” is provided as a response to a question, the project would be determined to be inconsistent with the CAP and would result in a significant GHG impact.

Checklist Item 1. Electric Vehicle Charging Stations (Measure T -2) This checklist item applies to multi -family residential and non-residential projects. It asks if the project will install electric vehicle charging stations (Level 2 or better) in at least 5% of the total parking spaces provided on site.

The vernal pool alternative would comply with this checklist item. The vernal pool alternative consists of development of 228 residential units, and a GPA/Rezone to convert the existing Industrial (I) land use and zoning designations to a Specific Plan Area designation to allow for residential development . The vernal pool alternative

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would include 532 total parking spaces, 27 of which would include EV charging stations. The project would answer Yes to this question.

Checklist Item 2. Bicycle Infrastructure (Measure T -8) This checklist item applies to residential and non -residential projects. It asks if the following conditions are met, would the project pay its fair-share contribution to bicycle infrastructure improvements of the following:
▪ Intersection or roadway segment improvements are proposed as part of the project. ▪ The City ’s General Plan Mobility Element identifies bicycle infrastructure improvements at any intersection(s) or roadway segment(s) that would be improved as part of the project.

The vernal pool alternative would comply with this checklist item. T he vernal pool alternative will include the following roadway and bicycle improvements:

Active Transportation Improvements

1. Construct sidewalks to close sidewalk gaps on the site frontage on La Mirada Drive, Pacific Street, and Linda Vista Drive.

2. Construct or preserve space for the portions of proposed bicycle facilities on Linda Vista Drive from Pacific Street to Las Posas Road immediately adjacent to the site.

3. Provide transit stop amenities including, at a minimum, bench, shelter, and trash can at the southbound stop at the intersection of Las Posas Road / Linda Vista Drive located on the southwest corner of the intersection.

Accordingly, the vernal pool alternative would answer “Yes” to this question.

Checklist Item 3. Transportation Demand Management (Measure T -9) This checklist item applies to residential and non -residential projects. Will the project develop and implement a Transportation Demand Management (TDM) Plan that includes, at a minimum, all of the TDM strategies listed below? ▪ Provide discounted monthly transit pass or provide at least 25 percent transit fare subsidy to residents/employees.
▪ Provide designated car-share, carpool, vanpool, and/or park-and-ride parking spaces. ▪ Provide pedestrian connections between all internal uses and to all existing or planned external streets around the project site(s).
▪ Provide secure bicycle parking spaces or bicycle racks, showers, and clothes lockers. ▪ Encourage telecommuting for employees (allow one telecommute day per week or compressed work weeks) or provide a telecommute work center with common office space and equipment available to residents.

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-or
▪ Would the project implement and monitor for four (4) years a TDM program that demonstrates an alternative transportation (i.e. carpool, public transit, bicycle, walk, telecommute) mode share of at least 29 percent for all residents?
The vernal pool alternative would comply with this checklist item. The vernal pool alternative would develop and implement a TDM plan that incorporates the required TDM strategies listed in this measure. The vernal pool alternative would answer Yes to this checklist question.

Checklist Item 4. Reduce Parking Near Transit (Measure T -12) This checklist item applies to multi-family residential projects. If located within one-half mile of a major transit stop, would the project provide at least 27 % fewer parking spaces than required for the same use based on the City’s municipal code parking requirements?
The vernal pool alternative is not located within ½ mile of a major transit stop defined as a bus or light-rail station with fixed service and 10 -minute minimum headways during peak hours. Therefore, the vernal pool alternative would answer “N/A” to this question.

Checklist Item 5. Water Heaters (Measure E -1)
This checklist item applies to residential projects and asks if the project would install one of, or a combination of, the following water heater types in place of natural gas water heaters:
▪ Electric heat pump water heater
▪ Instantaneous electric water heater
▪ Electric tank
▪ Solar water heater with heat pump water heater backup ▪ Solar water heater with electric tank backup
The vernal pool alternative would comply with this checklist item. The vernal pool alternative would install non - natural gas water heaters that would meet the requirements of this checklist item. The project would answer Yes to this checklist question.

Checklist Item 6. Photovoltaic Installation (Measure E -2) This checklist item applies to non-residential projects. Therefore, the vernal pool alternative would answer “N/A” to this checklist item.

Checklist Item 7. Landscaping Water Use (Measure W -1)
This checklist item applies to residential and non-residential projects and asks if the project would comply with the City’s Water Efficient Landscape Ordinance.

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The vernal pool alternative would comply with this checklist item. The vernal pool alternative's landscaping would meet the requirements within the City's Water Efficient Landscape Ordinance. As prescribed in Section 4.3.1 of the specific plan, The selected plants are well suited to the local soils and have proven to flourish within the project area’s climate and are consistent with AB 1881 requirements and the City of San Marcos Water Efficient Landscape Ordinance (WELO) and Municipal Code, Title 20. The vernal pool alternative will include composting, climate adapted plants, mulch, minimal use of turf, and smart water -efficient irrigation systems to minimize water use.

Accordingly, the vernal pool alternative would answer “Yes” to this question.

Checklist Item 8. Urban Tree Canopy (Measure C -2)
This checklist item applies to residential and non-residential projects and asks if the project is providing more than 10 parking spaces, will the project plant at least one tree per five parking spaces provided? The vernal pool alternative would comply with this checklist item. The vernal pool alternative is providing 532 parking spaces and will plant at least 107 trees to satisfy this checklist requirement. Accordingly, the vernal pool alternative would answer “Yes” to this question.

Summary
The vernal pool alternative requires a General Plan Amendment because it is proposing a residential development on a site zoned as Industrial (I). Therefore, a GHG analysis was performed to analyze the emissions of the existing zoned site and the vernal pool alternative. The vernal pool alternative was shown to result in fewer GHG emissions than the existing land use designation, and would implement all applicable checklist items within the City’s 2020 CAP. Therefore, the vernal pool alternative would be co nsistent with the City’s 2020 CAP and impacts to GHG emissions would be less than significant consistent with the original project.

Consistency with Statewide Greenhouse Gas Reduction Strategies The vernal pool alternative’s consistency with statewide GHG reduction strategies is summarized in detail in Table 10 through consideration of the project’s various construction and operational components and their relationship to specified laws and regulations designed to reduce GHG emissions from such components.

Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project Building Components/Facility Operations
Roofs/Ceilings/Insulation CALGreen Code
(Title 24, Part 11)
California Energy
Code (Title 24,
Part 6)
The vernal pool alternative must comply with efficiency standards regarding roofing, ceilings, and insulation.

For example:

Roofs/Ceilings: New construction must reduce roof
heat island effects per CALGreen Code Section
106.11.2, which requires use of roofing materials
having a minimum aged solar reflectance, thermal
emittance complying with Section A5.106.11.2.2 and

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project A5.106.11.2.3 or a minimum aged Solar Reflectance
Index as specified in Tables A5.106.11.2.2, or
A5.106.11.2.3. Roofing materials must also meet solar
reflectance and thermal emittance standards
contained in Title 20 Standards.

Roof/Ceiling Insulation: There are also requirements for the installation of roofing and ceiling insulation (see Title 24, Part 6 Compliance Manual at Section 3.2.2).

Flooring CALGreen Code The vernal pool alternative must comply with efficiency standards regarding flooring materials. For example, for 80% of floor area receiving “resilient flooring,” the
flooring must meet applicable installation and material requirements contained in CALGreen Code Section

5.504.4.6.

Window and Doors
(Fenestration)
California Energy
Code
The vernal pool alternative must comply with
fenestration efficiency requirements. For example, the
choice of windows, glazed doors, and any skylights for
the project must conform to energy consumption
requirements affecting size, orientation, and types of
fenestration products used (see Title 24, Part 6
Compliance Manual, Section 3.3).

Building Walls/Insulation CALGreen Code
California Energy
Code
The vernal pool alternative must comply with efficiency requirements for building walls and insulation.

Exterior Walls: Must meet requirements in the current
edition of California Energy Code, and comply with
Sections A5.106.7.1 or A5.106.7.2 of CALGreen Code
for wall surfaces, as well as Section 5.407.1, which
required weather-resistant exterior wall and foundation envelope as required by California Building Code
Section 1403.2. Construction must also meet
requirements contained in Title 24, Part 6, which vary
by material of the exterior walls (see Title 24, Part 6 Compliance Manual, Part 3.2.3).

Demising (Interior) Walls: Mandatory insulation
requirements for demising walls (which separate
conditioned from non-conditions space) differ by the
type of wall material used (see Title 24, Part 6
Compliance Manual, Part 3.2.4).

Door Insulation: There are mandatory requirements for
air infiltration rates to improve insulation efficiency; they differ according to the type of door (see Title 24, Part 6 Compliance Manual, Part 3.2.5).

Flooring Insulation: There are mandatory requirements
for insulation that depend on the material and location

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project of the flooring (see Title 24, Part 6 Compliance Manual, Part 3.2.6).

Finish Materials CALGreen Code The vernal pool alternative must comply with pollutant control requirements for finish materials. For example, materials including adhesives, sealants, caulks, paints and coatings, carpet systems, and composite wood
products must meet requirements in CALGreen Code to
ensure pollutant control (CALGreen Code Section

5.504.4).

Wet Appliances
(Toilets/Faucets/Urinals,
Dishwasher/Clothes Washer,
Spa and Pool/Water Heater)
CALGreen Code
California Energy
Code
Appliance
Efficiency
Regulations (Title
20 Standards)
Wet appliances associated with the vernal pool
alternative must meet various efficiency requirements.

For example:

Toilets/Faucets/Urinals: Use associated with the
project is subject to new maximum rates for toilets,
urinals, and faucets effective January 1, 2016 (Title 20 Standards, Sections 1605.1(h),(i) 1065.3(h),(i)):
▪ Showerheads maximum flow rate 2.5 gpm at 80
psi
▪ Wash fountains 2.2 x (rim space in inches/20) gpm
at 60 psi
▪ Metering faucets 0.25 gallons/cycle
▪ Lavatory faucets and aerators 1.2 gpm at 60 psi
▪ Kitchen faucets and aerators 1.8 gpm with optional
temporary flow of 2.2 gpm at 60 psi
▪ Public lavatory faucets 0.5 gpm at 60 psi
▪ Trough-type urinals 16 inches length
▪ Wall mounted urinals 0.125 gallons per flush
▪ Other urinals 0.5 gallons per flush
Water Heaters: Use associated with the project is
subject to appliance efficiency requirements for water
heaters (Title 20 Standards, Sections 1605.1(f),
1605.3(f)).

Dishwasher/Clothes Washer: Use associated with the
project is subject to appliance efficiency requirements for dishwashers and clothes washers (Title 20
Standards, Sections 1605.1(o),(p),(q),
1605.3(o),(p),(q)).

Dry Appliances
(Refrigerator/Freezer,
Heater/Air Conditioner, Clothes
Dryer)
Title 20
Standards
CALGreen Code
Dry appliances associated with the vernal pool
alternative must meet various efficiency requirements.

For example the following:

Refrigerator/Freezer: Use associated with the project is subject to appliance efficiency requirements for

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project refrigerators and freezers (Title 20 Standards, Sections 1605.1(a), 1605.3(a)).

Heater/Air Conditioner: Use associated with the project is subject to appliance efficiency requirements for
heaters and air conditioners (Title 20 Standards,
Sections 1605.1(b),(c),(d),(e), 1605.3(b),(c),(d),(e) as applicable).

Clothes Dryer: Use associated with the project is
subject to appliance efficiency requirements for clothes dryers (Title 20 Standards, Section 1605.1(q)).

CALGreen Code Installations of HVAC, refrigeration, and fire suppression equipment must comply with CALGreen
Code Sections 5.508.1.1 and 508.1.2, which prohibits
CFCs, halons, and certain HCFCs and HFCs.

Lighting Title 20
Standards
Lighting associated with the vernal pool alternative will be subject to energy efficiency requirements contained
in Title 20 Standards.

General Lighting: Indoor and outdoor lighting
associated with the project must comply with
applicable appliance efficiency regulations (Title 20
Standards, Sections 1605.1(j),(k),(n), 1605.3(j),(k),(n)).

Emergency Lighting and Self-Contained Lighting: The
project must also comply with applicable appliance
efficiency regulations (Title 20 Standards, Sections
1605.1(l), 1605.3(l)).

Traffic Signal Lighting: For any necessary project
improvements involving traffic lighting, traffic signal modules, and traffic signal lamps will need to comply
with applicable appliance efficiency regulations (Title 20 Standards, Sections 1605.1(m), 1605.3(m)).

California Energy
Code
Lighting associated with the vernal pool alternative will also be subject to energy efficiency requirements
contained in Title 24, Part 6, which contains energy
standards for non-residential indoor lighting and
outdoor lighting (see Title 24 Part 6 Compliance
Manual, at Sections 5, 6).

Mandatory lighting controls for indoor lighting include, for example, regulations for automatic shut-off,
automatic daytime controls, demand responsive
controls, and certificates of installation (Title 24 Part 6 Compliance Manual at Section 5). Regulations for
outdoor lighting include, for example, creation of
lighting zones, lighting power requirements, a

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project hardscape lighting power allowance, requirements for
outdoor incandescent and luminaire lighting, and
lighting control functionality (Title 24 Part 6 Compliance Manual at Section 6).

AB 1109 Lighting associated with the vernal pool alternative will be subject to energy efficiency requirements adopted
pursuant to AB 1109. Enacted in 2007, AB 1109
required the CEC to adopt minimum energy efficiency
standards for general purpose lighting, to reduce
electricity consumption 50% for indoor residential
lighting and 25% for indoor commercial lighting.

Bicycle and Vehicle Parking CALGreen Code The vernal pool alternative will be required to provide compliant bicycle parking, fuel-efficient vehicle parking, and electric vehicle charging spaces (CALGreen Code
Sections 5.106.4, 5.106.5.1, 5.106.5.3).

California Energy
Code
The vernal pool alternative is also subject to parking
requirements contained in Title 24, Party 6. For
example, parking capacity is to meet but not exceed
minimum local zoning requirements, and the project
should employ approved strategies to reduce parking
capacity (Title 24, Part 6, Section 106.6).

Landscaping CALGreen Code The CALGreen Code requires and has further voluntary provisions for the following:
▪ A water budget for landscape irrigation use.
▪ For new water service, separate meters or
submeters must be installed for indoor and outdoor
potable water use for landscaped areas of 1,000 to
5,000 square feet.
▪ Provide water-efficient landscape design that
reduces use of potable water beyond initial
requirements for plant installation and
establishment.

Model Water
Efficient
Landscaping
Ordinance
The model ordinance promotes efficient landscaping in
new developments and establishes an outdoor water
budget for new and renovated landscaped areas that
are 500 square feet or larger (CCR, Title 23, Division 2, Chapter 2.7).

Cap-and-Trade
Program
Transportation fuels used in landscape maintenance
equipment (e.g., gasoline) would be subject to the Cap- and-Trade Program (see “Energy Use,” below).

Refrigerants CARB
Management of
High GWP
Refrigerants for
Any refrigerants associated with the vernal pool
alternative will be subject to CARB standards. CARB’s
Regulation for the Management of High GWP
Refrigerants for Stationary Sources (1) reduces
emissions of high-GWP refrigerants from leaky

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project Stationary
Sources
stationary, non-residential refrigeration equipment; (2) reduces emissions resulting from the installation and
servicing of stationary refrigeration and air conditioning appliances using high-GWP refrigerants; and (3)
requires verification GHG emission reductions (CCR,
Title 17, Division 3, Chapter 1, Subchapter 10, Article 4, Subarticle 5.1, Section 95380 et seq.).

Consumer Products CARB High GWP
GHGs in
Consumer
Products
All consumer products associated with the project will
be subject to CARB standards. CARB’s consumer
products regulations set VOC limits for numerous
categories of consumer products, and limits the
reactivity of the ingredients used in numerous
categories of aerosol coating products (CCR, Title 17,
Division 3, Chapter 1, Subchapter 8.5).

Construction
Use of Off-Road Diesel Engines,
Vehicles, and Equipment
CARB In-Use Off-
Road Diesel
Vehicle
Regulation
Any relevant vehicle or machine use associated with
the vernal pool alternative will be subject to CARB
standards.

The CARB In-Use-Off-Road Diesel Vehicle Regulation
applies to certain off-road diesel engines, vehicles, or equipment greater than 25 horsepower. The regulation
(1) imposes limits on idling, requires a written idling policy, and requires a disclosure when selling vehicles; (2) requires all vehicles to be reported to CARB (using the Diesel Off-Road Online Reporting System) and
labeled; (3) restricts the adding of older vehicles into fleets starting on January 1, 2014; and (4) requires
fleets to reduce their emissions by retiring, replacing, or repowering older engines, or installing Verified Diesel Emission Control Strategies (i.e., exhaust retrofits).

The requirements and compliance dates of the Off-
Road regulation vary by fleet size, as defined by the
regulation.

Cap-and-Trade
Program
Transportation fuels (e.g., gasoline) used in equipment operation would be subject to the Cap-and-Trade
Program (see “Energy Use,” below).

Greening New Construction CALGreen Code All new construction, including the project, must comply with CALGreen Code, as discussed in more detail
throughout this table.

Adoption of the mandatory CALGreen Code standards
for construction has been essential for improving the
overall environmental performance of new buildings; it
also sets voluntary targets for builders to exceed the
mandatory requirements.

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project Construction Waste CALGreen Code The vernal pool alternative will be subject to CALGreen Code requirements for construction waste reduction,
disposal, and recycling, such as a requirement to
recycle and/or salvage for reuse a minimum of 50% of
the non-hazardous construction waste in accordance
with Section 5.408.1.1, 5.408.1.2, or 5.408.1.3; or
meet a local construction and demolition waste
management ordinance, whichever is more stringent.

Solid Waste
Solid Waste Management Landfill Methane
Control Measure
Waste associated with the vernal pool alternative will
be disposed per state requirements for landfills,
material recovery facilities, and transfer stations. Per the statewide GHG emissions inventory, the largest
emissions from waste management sectors come from
landfills, and are in the form of CH4.

In 2010, CARB adopted a regulation that reduces
emissions from CH4 in landfills, primarily by requiring owners and operators of certain uncontrolled municipal
solid waste landfills to install gas collection and control systems, and requires existing and newly installed gas
and control systems to operate in an optimal manner.

The regulation allows local air districts to voluntarily enter into a memorandum of understanding with CARB
to implement and enforce the regulation and to assess
fees to cover costs of implementation.

Mandatory
Commercial
Recycling (AB
341)
AB 341 will require the vernal pool alternative, if it
generates 4 cubic yards or more of commercial solid
waste per week, to arrange for recycling services, using one of the following: self-haul; subscribe to a hauler(s); arranging for pickup of recyclable materials;
subscribing to a recycling service that may include
mixed waste processing that yields diversion results
comparable to source separation. The project will also
be subject to local commercial solid waste recycling
program required to be implemented by each
jurisdiction under AB 341.

CALGreen Code The vernal pool alternative will be subject to CALGreen Code requirement to provide areas that serve the entire building and are identified for the depositing, storage, and collection of nonhazardous materials for recycling
(CALGreen Code Section 5.410.1).

Energy Use
Electricity/Natural Gas
Generation
Cap-and-Trade
Program
Electricity and natural gas usage associated with the
project will be subject to the Cap-and-Trade Program.

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project The rules came into effect on January 1, 2013, applying to large electric power plants and large industrial
plants. In 2015, importers and distributors of fossil
fuels were added to the Cap-and-Trade Program in the
second phase.

Specifically, on January 1, 2015, cap-and-trade
compliance obligations were phased in for suppliers of
natural gas, reformulated gasoline blendstock for
oxygenate blending (RBOB), distillate fuel oils, and
liquefied petroleum gas that meet or exceed specified
emissions thresholds. The threshold that triggers a cap- and-trade compliance obligation for a fuel supplier is
25,000 metric tons or more of CO2e annually from the
GHG emissions that would result from full combustion
or oxidation of quantities of fuels (including natural gas, RBOB, distillate fuel oil, liquefied petroleum gas, and blended fuels that contain these fuels) imported and/or delivered to California.

Renewable Energy California RPS (SB
X1-2, SB 350, and
SB 100)
Energy providers associated with the vernal pool
alternative will be required to comply with RPS set by
SB X1 2, SB 350, and SB 100.

SB X1 2 requires investor-owned utilities, publicly
owned utilities, and electric service providers to
increase purchases of renewable energy such that at
least 33% of retail sales are procured from renewable
energy resources by December 31, 2020. In the
interim, each entity was required to procure an average of 20% of renewable energy for the period of January 1, 2011 through December 31, 2013; and will be
required to procure an average of 25% by December
31, 2016, and 33% by 2020.

SB 350 requires retail sellers and publicly owned
utilities to procure 50% of their electricity from eligible renewable energy resources by 2030.

SB 100 increased the standards set forth in SB 350
establishing that 44% of the total electricity sold to
retail customers in California per year by December 31, 2024, 52% by December 31, 2027, and 60% by
December 31, 2030, be secured from qualifying
renewable energy sources. SB 100 states that it is the
policy of the state that eligible renewable energy
resources and zero-carbon resources supply 100% of
the retail sales of electricity to California by 2045.

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project Million Solar
Roofs Program
(SB 1)
The vernal pool alternative will indirectly participate in California’s energy market by pre-wiring roofs for future installation of solar, which is affected by
implementation of the Million Solar Roofs Program. As
part of Governor Schwarzenegger's Million Solar Roofs
Program, California has set a goal to install 3,000
megawatts of new, solar capacity through 2016. The
Million Solar Roofs Program is a ratepayer-financed
incentive program aimed at transforming the market
for rooftop solar systems by driving down costs over
time.

California Solar
Initiative- Thermal
Program
The vernal pool alternative will participate in
California’s energy market, which is affected by
implementation of the California Solar Initiative -
Thermal Program. The program offers cash rebates of
up to $4,366 on solar water heating systems for single- family residential customers. Multi-family and
Commercial properties qualify for rebates of up to
$800,000 on solar water heating systems and eligible
solar pool heating systems qualify for rebates of up to $500,000. Funding for the California Solar Initiative-
Thermal program comes from ratepayers of Pacific Gas
& Electric, Southern California Edison, Southern
California Gas Company, and San Diego Gas & Electric.

The rebate program is overseen by the CPUC as part of
the California Solar Initiative.

Waste Heat and
Carbon Emissions
Reduction Act (AB
1613, AB 2791)
The vernal pool alternative will participate in
California’s energy market, which is affected by
implementation of the Waste Heat and Carbon
Emissions Reduction Act. Originally enacted in 2007
and amended in 2008, this act directed the CEC, CPUC,
and CARB to implement a program that would
encourage the development of new combined heat and
power systems in California with a generating capacity
of not more than 20 megawatts, to increase combined
heat and power use by 30,000 gigawatt-hour. The
CPUC publicly owned electric utilities, and CEC duly
established policies and procedures for the purchase of electricity from eligible combined heat and power
systems.

CEC guidelines require combined heat and power
systems to be designed to reduce waste energy; have a
minimum efficiency of 60%; have NOx emissions of no
more than 0.07 pounds per megawatt-hour; be sized to
meet eligible customer generation thermal load;
operate continuously in a manner that meets expected

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project thermal load and optimizes efficient use of waste heat; and be cost effective, technologically feasible, and
environmentally beneficial.

Vehicular/Mobile Sources
General SB 375 and

SANDAG RTP/SCS
The vernal pool alternative complies with, and is
subject to, the SANDAG adopted RTP/SCS, which CARB
approved as meeting its regional GHG targets in 2016.

Fuel Low Carbon Fuel
Standard (LCFS)/
EO S-01-07
Auto trips associated with the vernal pool alternative
will be subject to the LCFS (EO S-01-07), which requires a 20% or greater reduction in the average fuel carbon
intensity by 2030 with a 2010 baseline for
transportation fuels in California regulated by CARB.

The program establishes a strong framework to
promote the low carbon fuel adoption necessary to
achieve statewide GHG reduction goals.

Cap-and-Trade
Program
Use of gasoline associated with the vernal pool
alternative will be subject to the Cap-and-Trade
Program.

The rules came into effect on January 1, 2013, applying to large electric power plants and large industrial
plants. In 2015, importers and distributors of fossil
fuels were added to the Cap-and-Trade Program in the
second phase.

Specifically, on January 1, 2015, cap-and-trade
compliance obligations were phased in for suppliers of
natural gas, RBOB, distillate fuel oils, and liquefied
petroleum gas that meet or exceed specified emissions
thresholds. The threshold that triggers a cap-and-trade compliance obligation for a fuel supplier is 25,000 MT
or more of CO2e annually from the GHG emissions that
would result from full combustion or oxidation of
quantities of fuels (including natural gas, RBOB,
distillate fuel oil, liquefied petroleum gas, and blended fuels that contain these fuels) imported and/or
delivered to California.

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project Light-Duty Vehicles AB 1493 (or the
Pavley Standard)
Cars that drive to and from the vernal pool alternative will be subject to AB 1493, which directed CARB to
adopt a regulation requiring the maximum feasible and
cost effective reduction of GHG emissions from new
passenger vehicles.

Pursuant to AB 1493, CARB adopted regulations that
establish a declining fleet average standard for CO2,
CH4, N2O, and HFCs (air conditioner refrigerants) in new passenger vehicles and light-duty trucks beginning with the 2009 model year and phased-in through the 2016
model year. These standards are divided into those
applicable to lighter and those applicable to heavier
portions of the passenger vehicle fleet.

The regulations will reduce “upstream” smog-forming
emissions from refining, marketing, and distribution of fuel.

Advanced Clean
Car and ZEV
Programs
Cars that drive to and from the project will be subject to the Advanced Clean Car and ZEV Programs.

In January 2012, CARB approved a new emissions-
control program for model years 2017 through 2025.

The program combines the control of smog, soot, and
global warming gases and requirements for greater
numbers of zero-emission vehicles into a single
package of standards called Advanced Clean Cars. By
2025, new automobiles will emit 34% fewer global
warming gases and 75% fewer smog-forming
emissions.

The ZEV program will act as the focused technology of
the Advanced Clean Cars program by requiring
manufacturers to produce increasing numbers of ZEVs
and plug-in hybrid electric vehicles in the 2018–2025
model years.

Tire Inflation
Regulation
Cars that drive to and from the vernal pool alternative will be subject to the CARB Tire Inflation Regulation,
which took effect on September 1, 2010, and applies
to vehicles with a gross vehicle weight rating of 10,000 pounds or less.

Under this regulation, automotive service providers
must check and inflate each vehicle’s tires to the
recommended tire pressure rating, with air or nitrogen, as appropriate, at the time of performing any
automotive maintenance or repair service, and to keep
a copy of the service invoice for a minimum of three
years, and make the vehicle service invoice available to

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project the CARB, or its authorized representative upon
request.

EPA and NHTSA
GHG and CAFE
standards.

Mobile sources that travel to and from the vernal pool
alternative would be subject to EPA and NHTSA GHG
and CAFE standards for passenger cars, light-duty
trucks, and medium-duty passenger vehicles (75 FR
25324–25728 and 77 FR 62624–63200).

Water Use
Water Use Efficiency Emergency State
Water Board
Regulations
Water use associated with the vernal pool alternative
will be subject to emergency regulations. On May 18,
2016, partially in response to EO B-27-16, the State
Water Board adopted emergency water use regulations
(CCR, title 23, Section 864.5 and amended and re-
adopted Sections 863, 864, 865, and 866). The
regulation directs the State Water Board, Department
of Water Resources, and CPUC to implement rates and
pricing structures to incentivize water conservation,
and calls upon water suppliers, homeowner’s
associations, California businesses, landlords and
tenants, and wholesale water agencies to take stronger
conservation measures.

EO B-37-16 Water use associated with the vernal pool alternative will be subject to Emergency EO B-37-16, issued May 9,
2016, which directs the State Water Resources Control
Board to adjust emergency water conservation
regulations through the end of January, 2017 to reflect differing water supply conditions across the state.

The Water Board must also develop a proposal to
achieve a mandatory reduction of potable urban water
usage that builds off the mandatory 25% reduction
called for in EO B-29-15. The Water Board and
Department of Water Resources will develop new,
permanent water use targets to which the project will
be subject.

The Water Board will permanently prohibit water-
wasting practices such as hosing off sidewalks,
driveways, and other hardscapes; washing automobiles
with hoses not equipped with a shut-off nozzle; using
non-recirculated water in a fountain or other decorative water feature; watering lawns in a manner that causes
runoff, or within 48 hours after measurable
precipitation; and irrigating ornamental turf on public street medians.

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Table 10. Relevant Greenhouse Gas-Related Laws and Regulations Project Component
Applicable
Laws/
Regulations GHG Reduction Measures Required for Project EO B-40-17 EO B-40-17 lifted the drought emergency in all California counties except Fresno, Kings, Tulare, and
Tuolumne. It also rescinds EO B-29-15, but expressly
states that EO B-37-16 remains in effect and directs
the State Water Resources Control Board to continue
development of permanent prohibitions on wasteful
water use to which the project will be subject.

SB X7-7 Water provided to the vernal pool alternative will be affected by SB X7-7’s requirements for water suppliers.

SB X7-7, or the Water Conservation Act of 2009,
requires all water suppliers to increase water use
efficiency. It also requires, among other things, that the Department of Water Resources, in consultation with
other state agencies, develop a single standardized
water use reporting form, which would be used by both
urban and agricultural water agencies.

CALGreen Code The vernal pool alternative is subject to CALGreen Code’s water efficiency standards, including a required 20% mandatory reduction in indoor water use
(CALGreen Code, Division 4.3).

California Water
Code, Division 6,
Part 2.10, Sections
10910–10915.

Development and approval of the vernal pool
alternative requires the development of a project-
specific Water Supply Assessment.

Cap-and-Trade
Program
Electricity usage associated with water and wastewater
supply, treatment and distribution would be subject to
the Cap-and-Trade Program.

California RPS (SB
X1-2, SB 350, SB
100)
Electricity usage associated with water and wastewater
supply, treatment and distribution associated with the
vernal pool alternative will be required to comply with RPS set by SB X1-2, SB 350, and SB 100.

Notes: AB = Assembly Bill; CARB = California Air Resources Board; CEC = California Energy Commission; CFC = chlorofluorocarbon; CH4 = methane; CO 2 = carbon dioxide; CO 2e = carbon dioxide equivalent; CPUC = California Public Utilities Commission; EO = Executive Order; EPA = Environmental Protection Agency; GHG = greenhouse gas; GWP = global warming potential; HCFC = hydrochlorofluorocarbon; HFC = hydrofluorocarbon; gpm = gallons per minute; MT = metric tons; N2O = nitrous oxide; NHTSA = National Highway Traf fic Safety Administration; PM = particulate matter; RPS = Renewable Portfolio Standard; RTP/SCS = Regional Transportation Plan/Sustainable Communities Strategy; SB = Senate Bill; SANDAG = San Diego Association of Governments; VOC = volatile organic compound; ZEV = zero emission vehicle
As shown, the vernal pool alternative would be consistent with and would not conflict with the applicable GHG - reducing strategies of the state that apply to the project’s construction and operational components.

In addition, CARB notes in the First Update that “California is on track to meet the near-term 2020 GHG limit and is well positioned to maintain and continue reductions beyond 2020 as required by AB 32” (CARB 2014). The project would help support achieveme nt of the near -term 2020 goal (as codified in AB 32), the interim 2030 goal (as

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codified in SB 32) , and the long -term, carbon neutrality 2045 goal (as set forth in EO B -55-18) by being infill development with access to multi -modal transportation options and incorporating design features such as installation of smart meters, installation of programmable thermostats, implementation of a parking management plan, walkability and bicycle access throughout the project site, walking access to the nearby Sprinter station, and drought-tolerant landscaping.8
Consistency with SANDAG’s RTP/SCS
At the regional level, SANDAG’s RTP/SCS has been adopted for the purpose of reducing GHG emissions attributable to passenger vehicles in the San Diego region. In October 2015, SANDAG adopted its RTP/SCS, which meets CARB’s 2020 and 2035 reduction targets for the region. The RTP/SCS does not regulate land use or supersede the exercise of land use authority by SANDAG’s member jurisdictions, but it is a relevant regional reference document for purposes of evaluating the intersection of land use and transportation patterns and the corresponding GHG emissions. CARB has recognized that the approved RTP/SCS is consistent with SB 375 (CARB 2015).

For purposes of the RTP/SCS consistency evaluation, the vernal pool alternative would increase access to transit because it is located approximately 0.6 miles from the Palomar College Sprinter station and a bus station is located in front of the project site. 9 The vernal pool alternative would provide connectivity by extending the sidewalk to neighboring communities, the shopping center across South Las Posas Road, the bus station, and the Sprinter station. The vernal pool alternative’s proximity to State Route 78 further allows for easy regional connectivity to employment centers, shopping areas, and recreation opportunities. Furthermore, the vernal pool alternative would implement applicable measures in the City’s 2020 CAP Consistency Checklist (see Appendix C), installing electric vehicle charging stations, installing bicycle infrastructure, implementing a Transporta tion Demand Management plan, and reducing parking near transit. These measures would further reduce the project’s GHG emissions from vehicle trips, increase access to transit, and encourage alternative modes of transportation. The vernal pool alternative’s density , land use type, and location are consistent with SANDAG’s RTP/SCS, which provides for increased access to transit and promotes regional connectivity to employment centers, shopping areas, and recreation opportunities. The features mentioned above would help facilitate alternative transit usage and reduce the overall vehicle trips, thereby reducing the vernal pool alternative’s regional GHG emissions.

Based on the considerations outlined above, the vernal pool alternative would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs, and potential impacts would be less than significant. No mitigation measures are required.

8 GHG emission reductions from the listed design features were not quantified. 9 The City uses the North County Transit District (NCTD) for Coaster rail service, Sprinter light rail service, and Breeze bus service for connections throughout the County of San Diego. Sprinter service operates between Escondido and Oceanside with connections to Interstate 5 and the Coaster rail service operating out of the City of Oceanside. The NCTD operates the Palomar College Sprinter, which is within a short walk from the project area. In addition, a bus stop is located in front of the project site. Connections to Orange County can be made via the Metrolink in the City of Oceanside. Similarly, connections to Riverside Transit Authority buses can be made via the transit station in Oceanside and Escondido. Both the Metrolink connection in Oceanside and the Riverside Transit Authority Bus connection in Oceanside and Escondido are accessible through Sprinter light rail service. These public transit options will offer residents of the project area quick access to a variety of alternative modes of transportation.

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4.3 Mitigation Measures
The project would not result in significant impacts; therefore, no mitigation is required. 5 Conclusions
Criteria air pollutant emissions generated during construction and operation of the vernal pool alternative would not exceed SDAPCD’s significance thresholds or result in a cumulatively considerable net increase in emissions.

The vernal pool alternative would result in fewer emissions of criteria air pollutants during operation and construction compared to the original project. Similarly, the vernal pool alternative would not create a CO hotspot or expose sensitive receptors to substantial concentrations of TACs. Therefore, the vernal pool alternative would result in a less than significant impact.

Estimated total GHG emissions generated during operation, including amortized construction emissions, would be below the existing land use designation for the site. The vernal pool alternative would be consistent with the City’s CAP. Furthermore, the vernal pool alternative would result in fewer GHGs compared to the original project. The vernal pool alternative would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs because there are curren tly no mandatory GHG regulations or finalized agency guidelines that would apply to implementation of this project. Accordingly, potential cumulative GHG impacts would be less than significant.

As such, the vernal pool alternative would not result in significant impacts to air quality or GHG emissions. 6 References
CAPCOA (California Air Pollution Control Officers Association). 2021. California Emissions Estimator Model (CalEEMod) User’s Guide, Version 2020.4.0. Prepared by BREEZE Software, A Division of Trinity Consultants, in collaboration with South Coast Air Quality Management District and the California Air Districts. September. Accessed November 2021. http://caleemod.com/.

CARB (California Air Resources Board). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. April 2005. http://www.arb.ca.gov/ch/landuse.htm.

CARB. 2014. First Update to the AB 32 Scoping Plan. May 2014. http://www.arb.ca.gov/cc/scopingplan/ document/updatedscopingplan2013.htm.

CARB. 2015. Executive Order G-15-075. San Diego Association of Governments (SANDAG), Sustainable Communities Strategy (SCS). CARB Acceptance of GHG Quantification Determination. December 2015.

City of San Marcos. 2013. City of San Marcos General Plan. Adopted February 14, 2012. http://www.san-marcos.net/work/economic-development/general-plan.

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City of San Marcos. 2020a. San Marcos Code of Ordinances, Title 20, Chapter 20.230 – Industrial Zones. January

14. Accessed October 2020. https://library.municode.com/ca/san_marcos/codes/code_of_ordinances? nodeId=TIT20ZO_CH20.230INZO.

City of San Marcos. 2020b. City of San Marcos Final Climate Action Plan. Adopted December 2020. Accessed March 2021. https://www.san-marcos.net/home/showpublisheddocument?id=25084.

City of San Marcos. 2020c. City’s Guidance to Demonstrating Consistency with the City of San Marcos Climate Action Plan: For Discretionary Projects Subject to CEQA.

CNRA (California Natural Resources Agency). 2009. Final Statement of Reasons for Regulatory Action:

Amendments to the State CEQA Guidelines Addressing Analysis and Mitigation of Greenhouse Gas Emissions Pursuant to SB 97. December 2009.

County of San Diego. 2007. Guidelines for Determining Significance and Report and Format and Content Requirements – Air Quality. Land Use and Environment Group. Department of Planning and Land Use.

Department of Public Works. March 19, 2007.

Dudek. 2023. Air Quality and Greenhouse Gas Emissions Technical Report for the Pacific Project. February 6.

EPA (Environmental Protection Agency). 2008. Final Ozone NAAQS Regulatory Impact Analysis. March 2008. https://www3.epa.gov/ttnecas1/regdata/RIAs/452_R_08_003.pdf.

EPA. 2017. Support Center for Regulatory Atmospheric Modeling (SCRAM) – Photochemical Air Quality Modeling. https://www.epa.gov/scram/photochemical-air-quality-modeling.

EPA. 2018a. Table of Ozone National Ambient Air Quality Standards. https://www.epa.gov/ground-level-ozone- pollution/table-historical-ozone-national-ambient-air-quality-standards-naaqs.

EPA. 2018b. Environmental Benefits Mapping and Analysis Program – Community Edition User’s Manual. July 2018. https://www.epa.gov/sites/production/files/2015-04/documents/benmap-ce_user_ manual_march_2015.pdf.

EPA and NHTSA (U.S. Environmental Protection Agency and Department of Transportation’s National Highway Traffic Safety Administration). 2016. EPA and NHTSA Adopt Standards to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles for Model Year 2018 and Beyond. August 2016. https://nepis.epa.gov/Exe/ZyPDF.cgi/P100P7NL.PDF?Dockey=P100P7NL.PDF.

EPA and NHTSA. 2018. The Safer Affordable Fuel-Efficient ‘SAFE’ Vehicles Rule for Model Years 2021–2026 Passenger Vehicles and Light Trucks. Proposed Rule August 2018. Accessed May 2019. https://www.govinfo.gov/content/pkg/FR-2018-08-24/pdf/2018-16820.pdf.

LLG (Linscott, Law & Greenspan). 2022. Pacific General Plan Amendment/Rezone Traffic Impact Analysis.

MEMORANDUM
SUBJECT: AIR QUALITY AND GREENHOUSE GAS EMISSIONS TECHNICAL MEMORANDUM FOR THE REDUCED DEVELOPMENT FOOTPRINT ALTERNATIVE – VERNAL POOL IMPACT MINIMIZATION

13170 46 FEBRUARY 2024

NRC (National Research Council). 2005. Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants. Washington, DC: The National Academies Press. https://doi.org/10.17226/11208.

SANDAG (San Diego Association of Governments). 2013. Series 13 Regional Growth Forecast City of San Marcos. http://datasurfer.sandag.org/download/
sandag_forecast_13_jurisdiction_san-marcos.pdf.

SCAQMD (South Coast Air Quality Management District). 2003. Final 2003 AQMP Appendix V: Modeling and Attainment Demonstrations. August 2003. Accessed March 2021. https://www.aqmd.gov/docs/default- source/clean-air-plans/air-quality-management-plans/2003-air-quality-management-plan/2003-aqmp- appendix-v.pdf?sfvrsn=2.

SCAQMD. 2015. Brief of Amicus Curiae in Support of Neither Party, Sierra Club v. County of Fresno, Case No.

S219783 (filed Apr. 13, 2015). https://www.courts.ca.gov/ documents/9-s219783-ac-south-coast-air-quality-mgt-dist-041315.pdf.

SDAPCD (San Diego Air Pollution Control District). 2012. Redesignation Request and Maintenance Plan for the 1997 National Ozone Standard for San Diego County. Adopted December 5, 2012. San Diego, California:

SDAPCD. http://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF/Air%20Quality%20Planning/ 8_Hour_O3_Maint-Plan.pdf.

SDAPCD. 2015. Regulation IV: Prohibitions; Rule 67.0.1: Architectural Coatings. Adopted June 24, 2015. Effective January 1, 2016. Accessed December 12, 2016. http://www.sdapcd.org/content/dam/sdc/ apcd/PDF/Rules_and_Regulations/Prohibitions/APCD_R67-0-1.pdf.

SDAPCD. 2016. 2008 Eight-Hour Ozone Attainment Plan for San Diego County. Final. December 2016. San Diego, California: SDAPCD. http://www.sandiegocounty.gov/content/dam/sdc/apcd/PDF/ Air%20Quality%20Planning/8-Hr-O3%20Attain%20Plan-08%20Std.pdf.

SJVAPCD (San Joaquin Valley Air Pollution Control District). 2015. Brief of Amicus Curiae in Support of Defendant and Respondent, County of Fresno, and Real Party In Interest and Respondent, Friant Ranch, L.P., Sierra Club v. County of Fresno, Case No. S219783 (filed Apr. 13, 2015). https://www.courts.ca.gov/ documents/7-s219783-ac-san-joaquin-valley-unified-air-pollution-control-dist-041315.pdf.

Attachment A
CalEEMod Output Files

Table of Contents
Annual Reduced Development 2
Summer Reduced Development 36
Winter Reduced Development 64
Annual Reduced Development South Mitigated 92
Summer Reduced Development South Mitigated 126
Winter Reduced Development South Mitigated 154
PVWatts Calculator 182
Revised Reduced Development Footprint Alternative- South Plan San Diego County APCD Air District, Annual
Project Characteristics -
Land Use - Based on site plan.

Construction Phase - CalEEMod defaults.

Off-road Equipment - CalEEMod defaults.

Off-road Equipment - CalEEMod defaults.

Off-road Equipment - CalEEMod defaults.

Off-road Equipment - CalEEMod defaults.

1.1 Land Usage
Land Uses
Size
Metric
Lot Acreage
Floor Surface Area
Population
Parking Lot
532.00
Space

4.79 212,800.00
0 Apartments Mid Rise
113.00
Dwelling Unit

2.97 113,000.00
323
Condo/Townhouse High Rise
116.00
Dwelling Unit

1.81 116,000.00
332

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
13 Wind Speed (m/s)
Precipitation Freq (Days)

2.6 40

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company
San Diego Gas & Electric
2027
Operational Year
CO2 Intensity
(lb/MWhr)
539.98

0.033
CH4 Intensity
(lb/MWhr)

0.004
N2O Intensity
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Off-road Equipment - CalEEMod defaults.

Trips and VMT - CalEEMod defaults. Odd trips were rounded up to account for whole round trips.

On-road Fugitive Dust - CalEEMod defaults.

Grading - CalEEMod defaults.

Architectural Coating - In accordance with SDAPCD Rule 67.0.1.

Vehicle Trips - Based on TIA.

Woodstoves - Natural gas fireplaces in all units.

Consumer Products - CalEEMod defaults.

Area Coating - In accordance with SDAPCD Rule 67.0.1.

Landscape Equipment - CalEEMod defaults.

Energy Use - CalEEMod defaults.

Water And Wastewater - CalEEMod defaults.

Solid Waste - CalEEMod defaults.

Construction Off-road Equipment Mitigation - In accordance with SDAPCD Rule 55.

Area Mitigation - In accordance with SDAPCD Rule 67.0.1. No wood burning fireplaces.

Energy Mitigation -
Table Name
Column Name
Default Value
New Value
tblArchitecturalCoating
EF_Residential_Exterior
250.00
100.00
tblArchitecturalCoating
EF_Residential_Interior
250.00

50.00 tblAreaCoating
Area_EF_Residential_Exterior
250
100
tblAreaCoating
Area_EF_Residential_Interior
250
50 tblAreaMitigation
UseLowVOCPaintResidentialExteriorValu
e
250
100
tblAreaMitigation
UseLowVOCPaintResidentialInteriorValu
e
250
50 tblConstDustMitigation
WaterUnpavedRoadVehicleSpeed
0 15
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

tblFireplaces
FireplaceWoodMass
3,078.40

0.00 tblFireplaces
FireplaceWoodMass
3,078.40

0.00 tblFireplaces
NumberGas

62.15 113.00
tblFireplaces
NumberGas

63.80 116.00
tblFireplaces
NumberNoFireplace

11.30 0.00
tblFireplaces
NumberNoFireplace

11.60 0.00
tblFireplaces
NumberWood

39.55 0.00
tblFireplaces
NumberWood

40.60 0.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
VendorTripNumber

59.00 60.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
WorkerTripNumber

15.00 16.00
tblTripsAndVMT
WorkerTripNumber

15.00 16.00
tblTripsAndVMT
WorkerTripNumber

51.00 52.00
tblVehicleTrips
ST_TR

4.91 6.00
tblVehicleTrips
ST_TR

4.91 6.00
tblVehicleTrips
SU_TR

4.09 6.00
tblVehicleTrips
SU_TR

4.09 6.00
tblVehicleTrips
WD_TR

5.44 6.00
tblVehicleTrips
WD_TR

5.44 6.00
tblWoodstoves
NumberCatalytic

5.65 0.00
tblWoodstoves
NumberCatalytic

5.80 0.00
tblWoodstoves
NumberNoncatalytic

5.65 0.00
tblWoodstoves
NumberNoncatalytic

5.80 0.00
tblWoodstoves
WoodstoveDayYear

82.00 0.00
tblWoodstoves
WoodstoveDayYear

82.00 0.00
tblWoodstoves
WoodstoveWoodMass
3,019.20

0.00 CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.0 Emissions Summary
tblWoodstoves
WoodstoveWoodMass
3,019.20

0.00 CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.1 Overall Construction
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Year
tons/yr
MT/yr
2026

0.1526

1.2379

1.5894

3.8900e-
003

0.3225

0.0460

0.3685

0.1261

0.0430

0.1691

0.0000
350.1906
350.1906

0.0524

0.0127
355.2931
2027

1.0928

0.9155

1.3164

3.1600e-
003

0.1351

0.0340

0.1691

0.0364

0.0319

0.0683

0.0000
284.9180
284.9180

0.0395

0.0107
289.1063
Maximum

1.0928

1.2379

1.5894

3.8900e-
003

0.3225

0.0460

0.3685

0.1261

0.0430

0.1691

0.0000
350.1906
350.1906

0.0524

0.0127
355.2931
Unmitigated Construction
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Year
tons/yr
MT/yr
2026

0.1526

1.2379

1.5893

3.8900e-
003

0.2295

0.0460

0.2755

0.0795

0.0430

0.1225

0.0000
350.1904
350.1904

0.0524

0.0127
355.2929
2027

1.0928

0.9155

1.3164

3.1600e-
003

0.1351

0.0340

0.1691

0.0364

0.0319

0.0683

0.0000
284.9178
284.9178

0.0395

0.0107
289.1061
Maximum

1.0928

1.2379

1.5893

3.8900e-
003

0.2295

0.0460

0.2755

0.0795

0.0430

0.1225

0.0000
350.1904
350.1904

0.0524

0.0127
355.2929
Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction

0.00 0.00

0.00 0.00

20.33 0.00

17.30 28.69

0.00 19.64

0.00 0.00

0.00 0.00

0.00 0.00
Quarter
Start Date
End Date
Maximum Unmitigated ROG + NOX (tons/quarter)
Maximum Mitigated ROG + NOX (tons/quarter)
1 6-1-2026
8-31-2026

0.6118

0.6118
2 9-1-2026
11-30-2026

0.5667

0.5667
3 12-1-2026
2-28-2027

0.5606

0.5606
4 3-1-2027
5-31-2027

0.5605

0.5605
5 6-1-2027
8-31-2027

1.0785

1.0785
Highest

1.0785

1.0785

2.2 Overall Operational
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Area

1.0748

0.1754

1.7699

1.0800e-
003

0.0220

0.0220

0.0220

0.0220

0.0000
183.1588
183.1588

6.1400e-
003

3.3100e-
003
184.2978
Energy

8.9800e-
003

0.0768

0.0327

4.9000e-
004

6.2100e-
003

6.2100e-
003

6.2100e-
003

6.2100e-
003

0.0000
329.9257
329.9257

0.0164

3.4200e-
003
331.3543
Mobile

0.6164

0.6637

5.7941

0.0125

1.4674

9.3700e-
003

1.4768

0.3916

8.7400e-
003

0.4004

0.0000
1,156.389
6 1,156.389
6 0.0824

0.0523
1,174.019
2 Waste

0.0000

0.0000

0.0000

0.0000

21.3831

0.0000

21.3831

1.2637

0.0000

52.9757
Water

0.0000

0.0000

0.0000

0.0000

4.7335

73.1805

77.9140

0.4907

0.0120

93.7628
Total

1.7002

0.9158

7.5967

0.0141

1.4674

0.0376

1.5051

0.3916

0.0370

0.4286

26.1166
1,742.654
7 1,768.771
2 1.8593

0.0710
1,836.409
7 Unmitigated Operational
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.2 Overall Operational
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Area

1.0748

0.1754

1.7699

1.0800e-
003

0.0220

0.0220

0.0220

0.0220

0.0000
183.1588
183.1588

6.1400e-
003

3.3100e-
003
184.2978
Energy

8.9800e-
003

0.0768

0.0327

4.9000e-
004

6.2100e-
003

6.2100e-
003

6.2100e-
003

6.2100e-
003

0.0000
329.9257
329.9257

0.0164

3.4200e-
003
331.3543
Mobile

0.6164

0.6637

5.7941

0.0125

1.4674

9.3700e-
003

1.4768

0.3916

8.7400e-
003

0.4004

0.0000
1,156.389
6 1,156.389
6 0.0824

0.0523
1,174.019
2 Waste

0.0000

0.0000

0.0000

0.0000

21.3831

0.0000

21.3831

1.2637

0.0000

52.9757
Water

0.0000

0.0000

0.0000

0.0000

4.7335

73.1805

77.9140

0.4907

0.0120

93.7628
Total

1.7002

0.9158

7.5967

0.0141

1.4674

0.0376

1.5051

0.3916

0.0370

0.4286

26.1166
1,742.654
7 1,768.771
2 1.8593

0.0710
1,836.409
7 Mitigated Operational

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name
Phase Type
Start Date
End Date
Num Days
Week
Num Days
Phase Description
1 Site Preparation
Site Preparation
6/1/2026
6/12/2026
5 10
2 Grading
Grading
6/13/2026
7/10/2026
5 20
3 Building Construction
Building Construction
7/11/2026
5/28/2027
5 230
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

4 Paving
Paving
5/29/2027
6/25/2027
5 20
5 Architectural Coating
Architectural Coating
6/26/2027
7/23/2027
5 20
OffRoad Equipment
Phase Name
Offroad Equipment Type
Amount
Usage Hours
Horse Power
Load Factor
Site Preparation
Rubber Tired Dozers
3 8.00
247

0.40 Site Preparation
Tractors/Loaders/Backhoes
4 8.00
97 0.37
Grading
Excavators
1 8.00
158

0.38 Grading
Graders
1 8.00
187

0.41 Grading
Rubber Tired Dozers
1 8.00
247

0.40 Grading
Tractors/Loaders/Backhoes
3 8.00
97 0.37
Building Construction
Cranes
1 7.00
231

0.29 Building Construction
Forklifts
3 8.00
89 0.20
Building Construction
Generator Sets
1 8.00
84 0.74
Building Construction
Tractors/Loaders/Backhoes
3 7.00
97 0.37
Building Construction
Welders
1 8.00
46 0.45
Paving
Pavers
2 8.00
130

0.42 Paving
Paving Equipment
2 8.00
132

0.36 Paving
Rollers
2 8.00
80 0.38
Architectural Coating
Air Compressors
1 6.00
78 0.48
Trips and VMT
Residential Indoor: 463,725; Residential Outdoor: 154,575; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area:
12,768 (Architectural Coating
–
sqft)
Acres of Grading (Site Preparation Phase): 15
Acres of Grading (Grading Phase): 20
Acres of Paving: 4.79
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.2 Site Preparation - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust

0.0983

0.0000

0.0983

0.0505

0.0000

0.0505

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

0.0124

0.1262

0.0896

1.9000e-
004

5.4300e-
003

5.4300e-
003

5.0000e-
003

5.0000e-
003

0.0000

16.7335

16.7335

5.4100e-
003

0.0000

16.8688
Total

0.0124

0.1262

0.0896

1.9000e-
004

0.0983

5.4300e-
003

0.1037

0.0505

5.0000e-
003

0.0555

0.0000

16.7335

16.7335

5.4100e-
003

0.0000

16.8688
Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Water Exposed Area
Reduce Vehicle Speed on Unpaved Roads
Phase Name
Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Site Preparation
7 18.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Grading
6 16.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Building Construction
9 254.00

60.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Paving
6 16.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Architectural Coating
1 52.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.2 Site Preparation - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

2.0000e-
005

8.6000e-
004

3.0000e-
004

0.0000

1.3000e-
004

1.0000e-
005

1.4000e-
004

4.0000e-
005

0.0000

4.0000e-
005

0.0000

0.3794

0.3794

1.0000e-
005

5.0000e-
005

0.3961
Worker

2.0000e-
004

1.3000e-
004

1.6900e-
003

1.0000e-
005

7.2000e-
004

0.0000

7.3000e-
004

1.9000e-
004

0.0000

1.9000e-
004

0.0000

0.5169

0.5169

1.0000e-
005

1.0000e-
005

0.5212
Total

2.2000e-
004

9.9000e-
004

1.9900e-
003

1.0000e-
005

8.5000e-
004

1.0000e-
005

8.7000e-
004

2.3000e-
004

0.0000

2.3000e-
004

0.0000

0.8964

0.8964

2.0000e-
005

6.0000e-
005

0.9173
Unmitigated Construction Off-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust

0.0442

0.0000

0.0442

0.0227

0.0000

0.0227

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

0.0124

0.1262

0.0896

1.9000e-
004

5.4300e-
003

5.4300e-
003

5.0000e-
003

5.0000e-
003

0.0000

16.7335

16.7335

5.4100e-
003

0.0000

16.8688
Total

0.0124

0.1262

0.0896

1.9000e-
004

0.0442

5.4300e-
003

0.0497

0.0227

5.0000e-
003

0.0277

0.0000

16.7335

16.7335

5.4100e-
003

0.0000

16.8688
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.2 Site Preparation - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

2.0000e-
005

8.6000e-
004

3.0000e-
004

0.0000

1.3000e-
004

1.0000e-
005

1.4000e-
004

4.0000e-
005

0.0000

4.0000e-
005

0.0000

0.3794

0.3794

1.0000e-
005

5.0000e-
005

0.3961
Worker

2.0000e-
004

1.3000e-
004

1.6900e-
003

1.0000e-
005

7.2000e-
004

0.0000

7.3000e-
004

1.9000e-
004

0.0000

1.9000e-
004

0.0000

0.5169

0.5169

1.0000e-
005

1.0000e-
005

0.5212
Total

2.2000e-
004

9.9000e-
004

1.9900e-
003

1.0000e-
005

8.5000e-
004

1.0000e-
005

8.7000e-
004

2.3000e-
004

0.0000

2.3000e-
004

0.0000

0.8964

0.8964

2.0000e-
005

6.0000e-
005

0.9173
Mitigated Construction Off-Site

3.3 Grading - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust

0.0708

0.0000

0.0708

0.0343

0.0000

0.0343

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

0.0152

0.1532

0.1454

3.0000e-
004

6.2400e-
003

6.2400e-
003

5.7400e-
003

5.7400e-
003

0.0000

26.0698

26.0698

8.4300e-
003

0.0000

26.2806
Total

0.0152

0.1532

0.1454

3.0000e-
004

0.0708

6.2400e-
003

0.0771

0.0343

5.7400e-
003

0.0400

0.0000

26.0698

26.0698

8.4300e-
003

0.0000

26.2806
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Grading - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

4.0000e-
005

1.7300e-
003

5.9000e-
004

1.0000e-
005

2.7000e-
004

1.0000e-
005

2.8000e-
004

8.0000e-
005

1.0000e-
005

9.0000e-
005

0.0000

0.7588

0.7588

3.0000e-
005

1.1000e-
004

0.7922
Worker

3.6000e-
004

2.2000e-
004

3.0100e-
003

1.0000e-
005

1.2800e-
003

1.0000e-
005

1.2900e-
003

3.4000e-
004

1.0000e-
005

3.5000e-
004

0.0000

0.9190

0.9190

2.0000e-
005

2.0000e-
005

0.9266
Total

4.0000e-
004

1.9500e-
003

3.6000e-
003

2.0000e-
005

1.5500e-
003

2.0000e-
005

1.5700e-
003

4.2000e-
004

2.0000e-
005

4.4000e-
004

0.0000

1.6778

1.6778

5.0000e-
005

1.3000e-
004

1.7188
Unmitigated Construction Off-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust

0.0319

0.0000

0.0319

0.0154

0.0000

0.0154

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

0.0152

0.1532

0.1454

3.0000e-
004

6.2400e-
003

6.2400e-
003

5.7400e-
003

5.7400e-
003

0.0000

26.0698

26.0698

8.4300e-
003

0.0000

26.2806
Total

0.0152

0.1532

0.1454

3.0000e-
004

0.0319

6.2400e-
003

0.0381

0.0154

5.7400e-
003

0.0212

0.0000

26.0698

26.0698

8.4300e-
003

0.0000

26.2806
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Grading - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

4.0000e-
005

1.7300e-
003

5.9000e-
004

1.0000e-
005

2.7000e-
004

1.0000e-
005

2.8000e-
004

8.0000e-
005

1.0000e-
005

9.0000e-
005

0.0000

0.7588

0.7588

3.0000e-
005

1.1000e-
004

0.7922
Worker

3.6000e-
004

2.2000e-
004

3.0100e-
003

1.0000e-
005

1.2800e-
003

1.0000e-
005

1.2900e-
003

3.4000e-
004

1.0000e-
005

3.5000e-
004

0.0000

0.9190

0.9190

2.0000e-
005

2.0000e-
005

0.9266
Total

4.0000e-
004

1.9500e-
003

3.6000e-
003

2.0000e-
005

1.5500e-
003

2.0000e-
005

1.5700e-
003

4.2000e-
004

2.0000e-
005

4.4000e-
004

0.0000

1.6778

1.6778

5.0000e-
005

1.3000e-
004

1.7188
Mitigated Construction Off-Site

3.4 Building Construction - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Off-Road

0.0848

0.7731

0.9973

1.6700e-
003

0.0327

0.0327

0.0308

0.0308

0.0000
143.7901
143.7901

0.0338

0.0000
144.6351
Total

0.0848

0.7731

0.9973

1.6700e-
003

0.0327

0.0327

0.0308

0.0308

0.0000
143.7901
143.7901

0.0338

0.0000
144.6351
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Building Construction - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

3.9600e-
003

0.1607

0.0553

7.2000e-
004

0.0247

9.7000e-
004

0.0257

7.1300e-
003

9.3000e-
004

8.0600e-
003

0.0000

70.5703

70.5703

2.4300e-
003

0.0102

73.6748
Worker

0.0356

0.0219

0.2963

9.9000e-
004

0.1263

6.0000e-
004

0.1269

0.0336

5.5000e-
004

0.0341

0.0000

90.4527

90.4527

2.2600e-
003

2.3100e-
003

91.1978
Total

0.0396

0.1825

0.3515

1.7100e-
003

0.1510

1.5700e-
003

0.1526

0.0407

1.4800e-
003

0.0422

0.0000
161.0231
161.0231

4.6900e-
003

0.0125
164.8725
Unmitigated Construction Off-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Off-Road

0.0848

0.7731

0.9973

1.6700e-
003

0.0327

0.0327

0.0308

0.0308

0.0000
143.7899
143.7899

0.0338

0.0000
144.6349
Total

0.0848

0.7731

0.9973

1.6700e-
003

0.0327

0.0327

0.0308

0.0308

0.0000
143.7899
143.7899

0.0338

0.0000
144.6349
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Building Construction - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

3.9600e-
003

0.1607

0.0553

7.2000e-
004

0.0247

9.7000e-
004

0.0257

7.1300e-
003

9.3000e-
004

8.0600e-
003

0.0000

70.5703

70.5703

2.4300e-
003

0.0102

73.6748
Worker

0.0356

0.0219

0.2963

9.9000e-
004

0.1263

6.0000e-
004

0.1269

0.0336

5.5000e-
004

0.0341

0.0000

90.4527

90.4527

2.2600e-
003

2.3100e-
003

91.1978
Total

0.0396

0.1825

0.3515

1.7100e-
003

0.1510

1.5700e-
003

0.1526

0.0407

1.4800e-
003

0.0422

0.0000
161.0231
161.0231

4.6900e-
003

0.0125
164.8725
Mitigated Construction Off-Site

3.4 Building Construction - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Off-Road

0.0725

0.6609

0.8525

1.4300e-
003

0.0280

0.0280

0.0263

0.0263

0.0000
122.9173
122.9173

0.0289

0.0000
123.6397
Total

0.0725

0.6609

0.8525

1.4300e-
003

0.0280

0.0280

0.0263

0.0263

0.0000
122.9173
122.9173

0.0289

0.0000
123.6397
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Building Construction - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

3.3000e-
003

0.1359

0.0468

6.0000e-
004

0.0211

8.2000e-
004

0.0219

6.1000e-
003

7.8000e-
004

6.8800e-
003

0.0000

59.0790

59.0790

2.1200e-
003

8.5500e-
003

61.6797
Worker

0.0288

0.0172

0.2400

8.2000e-
004

0.1080

4.8000e-
004

0.1084

0.0287

4.4000e-
004

0.0291

0.0000

75.0709

75.0709

1.7700e-
003

1.8800e-
003

75.6749
Total

0.0321

0.1530

0.2868

1.4200e-
003

0.1291

1.3000e-
003

0.1304

0.0348

1.2200e-
003

0.0360

0.0000
134.1499
134.1499

3.8900e-
003

0.0104
137.3545
Unmitigated Construction Off-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Off-Road

0.0725

0.6609

0.8525

1.4300e-
003

0.0280

0.0280

0.0263

0.0263

0.0000
122.9172
122.9172

0.0289

0.0000
123.6395
Total

0.0725

0.6609

0.8525

1.4300e-
003

0.0280

0.0280

0.0263

0.0263

0.0000
122.9172
122.9172

0.0289

0.0000
123.6395
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Building Construction - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

3.3000e-
003

0.1359

0.0468

6.0000e-
004

0.0211

8.2000e-
004

0.0219

6.1000e-
003

7.8000e-
004

6.8800e-
003

0.0000

59.0790

59.0790

2.1200e-
003

8.5500e-
003

61.6797
Worker

0.0288

0.0172

0.2400

8.2000e-
004

0.1080

4.8000e-
004

0.1084

0.0287

4.4000e-
004

0.0291

0.0000

75.0709

75.0709

1.7700e-
003

1.8800e-
003

75.6749
Total

0.0321

0.1530

0.2868

1.4200e-
003

0.1291

1.3000e-
003

0.1304

0.0348

1.2200e-
003

0.0360

0.0000
134.1499
134.1499

3.8900e-
003

0.0104
137.3545
Mitigated Construction Off-Site

3.5 Paving - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Off-Road

9.1500e-
003

0.0858

0.1458

2.3000e-
004

4.1900e-
003

4.1900e-
003

3.8500e-
003

3.8500e-
003

0.0000

20.0193

20.0193

6.4700e-
003

0.0000

20.1811
Paving

6.2700e-
003

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Total

0.0154

0.0858

0.1458

2.3000e-
004

4.1900e-
003

4.1900e-
003

3.8500e-
003

3.8500e-
003

0.0000

20.0193

20.0193

6.4700e-
003

0.0000

20.1811
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.5 Paving - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

4.0000e-
005

1.7100e-
003

5.9000e-
004

1.0000e-
005

2.7000e-
004

1.0000e-
005

2.8000e-
004

8.0000e-
005

1.0000e-
005

9.0000e-
005

0.0000

0.7431

0.7431

3.0000e-
005

1.1000e-
004

0.7758
Worker

3.4000e-
004

2.0000e-
004

2.8500e-
003

1.0000e-
005

1.2800e-
003

1.0000e-
005

1.2900e-
003

3.4000e-
004

1.0000e-
005

3.5000e-
004

0.0000

0.8922

0.8922

2.0000e-
005

2.0000e-
005

0.8994
Total

3.8000e-
004

1.9100e-
003

3.4400e-
003

2.0000e-
005

1.5500e-
003

2.0000e-
005

1.5700e-
003

4.2000e-
004

2.0000e-
005

4.4000e-
004

0.0000

1.6354

1.6354

5.0000e-
005

1.3000e-
004

1.6753
Unmitigated Construction Off-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Off-Road

9.1500e-
003

0.0858

0.1458

2.3000e-
004

4.1900e-
003

4.1900e-
003

3.8500e-
003

3.8500e-
003

0.0000

20.0192

20.0192

6.4700e-
003

0.0000

20.1811
Paving

6.2700e-
003

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Total

0.0154

0.0858

0.1458

2.3000e-
004

4.1900e-
003

4.1900e-
003

3.8500e-
003

3.8500e-
003

0.0000

20.0192

20.0192

6.4700e-
003

0.0000

20.1811
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.5 Paving - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

4.0000e-
005

1.7100e-
003

5.9000e-
004

1.0000e-
005

2.7000e-
004

1.0000e-
005

2.8000e-
004

8.0000e-
005

1.0000e-
005

9.0000e-
005

0.0000

0.7431

0.7431

3.0000e-
005

1.1000e-
004

0.7758
Worker

3.4000e-
004

2.0000e-
004

2.8500e-
003

1.0000e-
005

1.2800e-
003

1.0000e-
005

1.2900e-
003

3.4000e-
004

1.0000e-
005

3.5000e-
004

0.0000

0.8922

0.8922

2.0000e-
005

2.0000e-
005

0.8994
Total

3.8000e-
004

1.9100e-
003

3.4400e-
003

2.0000e-
005

1.5500e-
003

2.0000e-
005

1.5700e-
003

4.2000e-
004

2.0000e-
005

4.4000e-
004

0.0000

1.6354

1.6354

5.0000e-
005

1.3000e-
004

1.6753
Mitigated Construction Off-Site

3.6 Architectural Coating - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Archit. Coating

0.9695

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

1.7100e-
003

0.0115

0.0181

3.0000e-
005

5.2000e-
004

5.2000e-
004

5.2000e-
004

5.2000e-
004

0.0000

2.5533

2.5533

1.4000e-
004

0.0000

2.5567
Total

0.9713

0.0115

0.0181

3.0000e-
005

5.2000e-
004

5.2000e-
004

5.2000e-
004

5.2000e-
004

0.0000

2.5533

2.5533

1.4000e-
004

0.0000

2.5567
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.6 Architectural Coating - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

4.0000e-
005

1.7100e-
003

5.9000e-
004

1.0000e-
005

2.7000e-
004

1.0000e-
005

2.8000e-
004

8.0000e-
005

1.0000e-
005

9.0000e-
005

0.0000

0.7431

0.7431

3.0000e-
005

1.1000e-
004

0.7758
Worker

1.1100e-
003

6.6000e-
004

9.2700e-
003

3.0000e-
005

4.1700e-
003

2.0000e-
005

4.1900e-
003

1.1100e-
003

2.0000e-
005

1.1300e-
003

0.0000

2.8998

2.8998

7.0000e-
005

7.0000e-
005

2.9231
Total

1.1500e-
003

2.3700e-
003

9.8600e-
003

4.0000e-
005

4.4400e-
003

3.0000e-
005

4.4700e-
003

1.1900e-
003

3.0000e-
005

1.2200e-
003

0.0000

3.6429

3.6429

1.0000e-
004

1.8000e-
004

3.6990
Unmitigated Construction Off-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Archit. Coating

0.9695

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Off-Road

1.7100e-
003

0.0115

0.0181

3.0000e-
005

5.2000e-
004

5.2000e-
004

5.2000e-
004

5.2000e-
004

0.0000

2.5533

2.5533

1.4000e-
004

0.0000

2.5567
Total

0.9713

0.0115

0.0181

3.0000e-
005

5.2000e-
004

5.2000e-
004

5.2000e-
004

5.2000e-
004

0.0000

2.5533

2.5533

1.4000e-
004

0.0000

2.5567
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.6 Architectural Coating - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

4.0000e-
005

1.7100e-
003

5.9000e-
004

1.0000e-
005

2.7000e-
004

1.0000e-
005

2.8000e-
004

8.0000e-
005

1.0000e-
005

9.0000e-
005

0.0000

0.7431

0.7431

3.0000e-
005

1.1000e-
004

0.7758
Worker

1.1100e-
003

6.6000e-
004

9.2700e-
003

3.0000e-
005

4.1700e-
003

2.0000e-
005

4.1900e-
003

1.1100e-
003

2.0000e-
005

1.1300e-
003

0.0000

2.8998

2.8998

7.0000e-
005

7.0000e-
005

2.9231
Total

1.1500e-
003

2.3700e-
003

9.8600e-
003

4.0000e-
005

4.4400e-
003

3.0000e-
005

4.4700e-
003

1.1900e-
003

3.0000e-
005

1.2200e-
003

0.0000

3.6429

3.6429

1.0000e-
004

1.8000e-
004

3.6990
Mitigated Construction Off-Site

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Mitigated

0.6164

0.6637

5.7941

0.0125

1.4674

9.3700e-
003

1.4768

0.3916

8.7400e-
003

0.4004

0.0000
1,156.389
6 1,156.389
6 0.0824

0.0523
1,174.019
2 Unmitigated

0.6164

0.6637

5.7941

0.0125

1.4674

9.3700e-
003

1.4768

0.3916

8.7400e-
003

0.4004

0.0000
1,156.389
6 1,156.389
6 0.0824

0.0523
1,174.019
2 4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate
Unmitigated
Mitigated
Land Use
Weekday
Saturday
Sunday
Annual VMT
Annual VMT
Apartments Mid Rise
678.00
678.00
678.00
1,935,896
1,935,896
Condo/Townhouse High Rise
696.00
696.00
696.00
1,987,291
1,987,291
Parking Lot

0.00 0.00

0.00 Total
1,374.00
1,374.00
1,374.00
3,923,187
3,923,187
Miles
Trip %
Trip Purpose %
Land Use
H-W or C-W
H-S or C-C
H-O or C-NW
H-W or C-W
H-S or C-C
H-O or C-NW
Primary
Diverted
Pass-by
Apartments Mid Rise

10.80 7.30

7.50 41.60

18.80 39.60
86 11
3 Condo/Townhouse High Rise

10.80 7.30

7.50 41.60

18.80 39.60
86 11
3 Parking Lot

9.50 7.30

7.30 0.00

0.00 0.00
0 0
0 4.4 Fleet Mix
Land Use
LDA
LDT1
LDT2
MDV
LHD1
LHD2
MHD
HHD
OBUS
UBUS
MCY
SBUS
MH
Apartments Mid Rise

0.568480

0.062094

0.174123

0.115064

0.023357

0.006399

0.009361

0.006325

0.000693

0.000596

0.028205

0.000919

0.004383
Condo/Townhouse High Rise

0.568480

0.062094

0.174123

0.115064

0.023357

0.006399

0.009361

0.006325

0.000693

0.000596

0.028205

0.000919

0.004383
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Parking Lot

0.568480

0.062094

0.174123

0.115064

0.023357

0.006399

0.009361

0.006325

0.000693

0.000596

0.028205

0.000919

0.004383

5.0 Energy Detail
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Electricity
Mitigated

0.0000

0.0000

0.0000

0.0000

0.0000
241.0101
241.0101

0.0147

1.7900e-
003
241.9104
Electricity
Unmitigated

0.0000

0.0000

0.0000

0.0000

0.0000
241.0101
241.0101

0.0147

1.7900e-
003
241.9104
NaturalGas
Mitigated

8.9800e-
003

0.0768

0.0327

4.9000e-
004

6.2100e-
003

6.2100e-
003

6.2100e-
003

6.2100e-
003

0.0000

88.9156

88.9156

1.7000e-
003

1.6300e-
003

89.4440
NaturalGas
Unmitigated

8.9800e-
003

0.0768

0.0327

4.9000e-
004

6.2100e-
003

6.2100e-
003

6.2100e-
003

6.2100e-
003

0.0000

88.9156

88.9156

1.7000e-
003

1.6300e-
003

89.4440

5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Land Use
kBTU/yr
tons/yr
MT/yr
Apartments Mid
Rise
822194

4.4300e-
003

0.0379

0.0161

2.4000e-
004

3.0600e-
003

3.0600e-
003

3.0600e-
003

3.0600e-
003

0.0000

43.8754

43.8754

8.4000e-
004

8.0000e-
004

44.1361
Condo/Townhous
e High Rise
844022

4.5500e-
003

0.0389

0.0166

2.5000e-
004

3.1400e-
003

3.1400e-
003

3.1400e-
003

3.1400e-
003

0.0000

45.0402

45.0402

8.6000e-
004

8.3000e-
004

45.3079
Parking Lot
0 0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Total

8.9800e-
003

0.0768

0.0327

4.9000e-
004

6.2000e-
003

6.2000e-
003

6.2000e-
003

6.2000e-
003

0.0000

88.9156

88.9156

1.7000e-
003

1.6300e-
003

89.4440
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Land Use
kBTU/yr
tons/yr
MT/yr
Apartments Mid
Rise
822194

4.4300e-
003

0.0379

0.0161

2.4000e-
004

3.0600e-
003

3.0600e-
003

3.0600e-
003

3.0600e-
003

0.0000

43.8754

43.8754

8.4000e-
004

8.0000e-
004

44.1361
Condo/Townhous
e High Rise
844022

4.5500e-
003

0.0389

0.0166

2.5000e-
004

3.1400e-
003

3.1400e-
003

3.1400e-
003

3.1400e-
003

0.0000

45.0402

45.0402

8.6000e-
004

8.3000e-
004

45.3079
Parking Lot
0 0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Total

8.9800e-
003

0.0768

0.0327

4.9000e-
004

6.2000e-
003

6.2000e-
003

6.2000e-
003

6.2000e-
003

0.0000

88.9156

88.9156

1.7000e-
003

1.6300e-
003

89.4440
Mitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2
CH4
N2O
CO2e
Land Use
kWh/yr
MT/yr
Apartments Mid
Rise
433936
106.2843

6.5000e-
003

7.9000e-
004
106.6813
Condo/Townhous
e High Rise
475577
116.4834

7.1200e-
003

8.6000e-
004
116.9185
Parking Lot
74480

18.2425

1.1100e-
003

1.4000e-
004

18.3106
Total
241.0101

0.0147

1.7900e-
003
241.9104
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Use Low VOC Paint - Residential Interior
Use Low VOC Paint - Residential Exterior
Use only Natural Gas Hearths

6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2
CH4
N2O
CO2e
Land Use
kWh/yr
MT/yr
Apartments Mid
Rise
433936
106.2843

6.5000e-
003

7.9000e-
004
106.6813
Condo/Townhous
e High Rise
475577
116.4834

7.1200e-
003

8.6000e-
004
116.9185
Parking Lot
74480

18.2425

1.1100e-
003

1.4000e-
004

18.3106
Total
241.0101

0.0147

1.7900e-
003
241.9104
Mitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Mitigated

1.0748

0.1754

1.7699

1.0800e-
003

0.0220

0.0220

0.0220

0.0220

0.0000
183.1588
183.1588

6.1400e-
003

3.3100e-
003
184.2978
Unmitigated

1.0748

0.1754

1.7699

1.0800e-
003

0.0220

0.0220

0.0220

0.0220

0.0000
183.1588
183.1588

6.1400e-
003

3.3100e-
003
184.2978

6.2 Area by SubCategory
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
SubCategory
tons/yr
MT/yr
Architectural
Coating

0.0970

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Consumer
Products

0.9081

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Hearth

0.0182

0.1558

0.0663

9.9000e-
004

0.0126

0.0126

0.0126

0.0126

0.0000
180.3718
180.3718

3.4600e-
003

3.3100e-
003
181.4437
Landscaping

0.0515

0.0196

1.7036

9.0000e-
005

9.4400e-
003

9.4400e-
003

9.4400e-
003

9.4400e-
003

0.0000

2.7870

2.7870

2.6800e-
003

0.0000

2.8541
Total

1.0748

0.1754

1.7699

1.0800e-
003

0.0220

0.0220

0.0220

0.0220

0.0000
183.1588
183.1588

6.1400e-
003

3.3100e-
003
184.2978
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

7.1 Mitigation Measures Water

7.0 Water Detail

6.2 Area by SubCategory
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
SubCategory
tons/yr
MT/yr
Architectural
Coating

0.0970

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Consumer
Products

0.9081

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Hearth

0.0182

0.1558

0.0663

9.9000e-
004

0.0126

0.0126

0.0126

0.0126

0.0000
180.3718
180.3718

3.4600e-
003

3.3100e-
003
181.4437
Landscaping

0.0515

0.0196

1.7036

9.0000e-
005

9.4400e-
003

9.4400e-
003

9.4400e-
003

9.4400e-
003

0.0000

2.7870

2.7870

2.6800e-
003

0.0000

2.8541
Total

1.0748

0.1754

1.7699

1.0800e-
003

0.0220

0.0220

0.0220

0.0220

0.0000
183.1588
183.1588

6.1400e-
003

3.3100e-
003
184.2978
Mitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Total CO2
CH4
N2O
CO2e
Category
MT/yr
Mitigated

77.9140

0.4907

0.0120

93.7628
Unmitigated

77.9140

0.4907

0.0120

93.7628

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2
CH4
N2O
CO2e
Land Use
Mgal
MT/yr
Apartments Mid
Rise

7.3624 /

4.64152

38.4467

0.2421

5.9300e-
003

46.2672
Condo/Townhous
e High Rise

7.55787 /

4.76474

39.4674

0.2485

6.0900e-
003

47.4956
Parking Lot
0 / 0

0.0000

0.0000

0.0000

0.0000
Total

77.9140

0.4907

0.0120

93.7628
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2
CH4
N2O
CO2e
Land Use
Mgal
MT/yr
Apartments Mid
Rise

7.3624 /

4.64152

38.4467

0.2421

5.9300e-
003

46.2672
Condo/Townhous
e High Rise

7.55787 /

4.76474

39.4674

0.2485

6.0900e-
003

47.4956
Parking Lot
0 / 0

0.0000

0.0000

0.0000

0.0000
Total

77.9140

0.4907

0.0120

93.7628
Mitigated

8.1 Mitigation Measures Waste

8.0 Waste Detail
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Total CO2
CH4
N2O
CO2e
MT/yr
Mitigated

21.3831

1.2637

0.0000

52.9757
Unmitigated

21.3831

1.2637

0.0000

52.9757
Category/Year

8.2 Waste by Land Use
Waste
Disposed
Total CO2
CH4
N2O
CO2e
Land Use
tons
MT/yr
Apartments Mid
Rise

51.98 10.5515

0.6236

0.0000

26.1408
Condo/Townhous
e High Rise

53.36 10.8316

0.6401

0.0000

26.8348
Parking Lot
0 0.0000

0.0000

0.0000

0.0000
Total

21.3831

1.2637

0.0000

52.9757
Unmitigated
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

8.2 Waste by Land Use
Waste
Disposed
Total CO2
CH4
N2O
CO2e
Land Use
tons
MT/yr
Apartments Mid
Rise

51.98 10.5515

0.6236

0.0000

26.1408
Condo/Townhous
e High Rise

53.36 10.8316

0.6401

0.0000

26.8348
Parking Lot
0 0.0000

0.0000

0.0000

0.0000
Total

21.3831

1.2637

0.0000

52.9757
Mitigated

9.0 Operational Offroad
Equipment Type
Number
Hours/Day
Days/Year
Horse Power
Load Factor
Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type
Number
Hours/Day
Hours/Year
Horse Power
Load Factor
Fuel Type
Boilers
Equipment Type
Number
Heat Input/Day
Heat Input/Year
Boiler Rating
Fuel Type
User Defined Equipment
Equipment Type
Number
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

11.0 Vegetation
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:34 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Annual EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Revised Reduced Development Footprint Alternative- South Plan San Diego County APCD Air District, Summer
Project Characteristics -
Land Use - Based on site plan.

Construction Phase - CalEEMod defaults.

Off-road Equipment - CalEEMod defaults.

Off-road Equipment - CalEEMod defaults.

Off-road Equipment - CalEEMod defaults.

Off-road Equipment - CalEEMod defaults.

1.1 Land Usage
Land Uses
Size
Metric
Lot Acreage
Floor Surface Area
Population
Parking Lot
532.00
Space

4.79 212,800.00
0 Apartments Mid Rise
113.00
Dwelling Unit

2.97 113,000.00
323
Condo/Townhouse High Rise
116.00
Dwelling Unit

1.81 116,000.00
332

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
13 Wind Speed (m/s)
Precipitation Freq (Days)

2.6 40

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company
San Diego Gas & Electric
2027
Operational Year
CO2 Intensity
(lb/MWhr)
539.98

0.033
CH4 Intensity
(lb/MWhr)

0.004
N2O Intensity
(lb/MWhr)
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

Off-road Equipment - CalEEMod defaults.

Trips and VMT - CalEEMod defaults. Odd trips were rounded up to account for whole round trips.

On-road Fugitive Dust - CalEEMod defaults.

Grading - CalEEMod defaults.

Architectural Coating - In accordance with SDAPCD Rule 67.0.1.

Vehicle Trips - Based on TIA.

Woodstoves - Natural gas fireplaces in all units.

Consumer Products - CalEEMod defaults.

Area Coating - In accordance with SDAPCD Rule 67.0.1.

Landscape Equipment - CalEEMod defaults.

Energy Use - CalEEMod defaults.

Water And Wastewater - CalEEMod defaults.

Solid Waste - CalEEMod defaults.

Construction Off-road Equipment Mitigation - In accordance with SDAPCD Rule 55.

Area Mitigation - In accordance with SDAPCD Rule 67.0.1. No wood burning fireplaces.

Energy Mitigation -
Table Name
Column Name
Default Value
New Value
tblArchitecturalCoating
EF_Residential_Exterior
250.00
100.00
tblArchitecturalCoating
EF_Residential_Interior
250.00

50.00 tblAreaCoating
Area_EF_Residential_Exterior
250
100
tblAreaCoating
Area_EF_Residential_Interior
250
50 tblAreaMitigation
UseLowVOCPaintResidentialExteriorValu
e
250
100
tblAreaMitigation
UseLowVOCPaintResidentialInteriorValu
e
250
50 tblConstDustMitigation
WaterUnpavedRoadVehicleSpeed
0 15
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

tblFireplaces
FireplaceWoodMass
3,078.40

0.00 tblFireplaces
FireplaceWoodMass
3,078.40

0.00 tblFireplaces
NumberGas

62.15 113.00
tblFireplaces
NumberGas

63.80 116.00
tblFireplaces
NumberNoFireplace

11.30 0.00
tblFireplaces
NumberNoFireplace

11.60 0.00
tblFireplaces
NumberWood

39.55 0.00
tblFireplaces
NumberWood

40.60 0.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
VendorTripNumber

59.00 60.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
VendorTripNumber

0.00 4.00
tblTripsAndVMT
WorkerTripNumber

15.00 16.00
tblTripsAndVMT
WorkerTripNumber

15.00 16.00
tblTripsAndVMT
WorkerTripNumber

51.00 52.00
tblVehicleTrips
ST_TR

4.91 6.00
tblVehicleTrips
ST_TR

4.91 6.00
tblVehicleTrips
SU_TR

4.09 6.00
tblVehicleTrips
SU_TR

4.09 6.00
tblVehicleTrips
WD_TR

5.44 6.00
tblVehicleTrips
WD_TR

5.44 6.00
tblWoodstoves
NumberCatalytic

5.65 0.00
tblWoodstoves
NumberCatalytic

5.80 0.00
tblWoodstoves
NumberNoncatalytic

5.65 0.00
tblWoodstoves
NumberNoncatalytic

5.80 0.00
tblWoodstoves
WoodstoveDayYear

82.00 0.00
tblWoodstoves
WoodstoveDayYear

82.00 0.00
tblWoodstoves
WoodstoveWoodMass
3,019.20

0.00 CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.0 Emissions Summary
tblWoodstoves
WoodstoveWoodMass
3,019.20

0.00 CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.1 Overall Construction (Maximum Daily Emission)
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Year
lb/day
lb/day
2026

2.5181

25.4234

21.9786

0.0552

19.8320

1.0885

20.9205

10.1495

1.0015

11.1509

0.0000
5,496.650
6 5,496.650
6 1.1987

0.2199
5,579.242
3 2027

97.2416

15.2391

21.7031

0.0545

2.4929

0.5521

3.0450

0.6704

0.5194

1.1898

0.0000
5,421.533
6 5,421.533
6 0.7189

0.2142
5,502.379
6 Maximum

97.2416

25.4234

21.9786

0.0552

19.8320

1.0885

20.9205

10.1495

1.0015

11.1509

0.0000
5,496.650
6 5,496.650
6 1.1987

0.2199
5,579.242
3 Unmitigated Construction
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Year
lb/day
lb/day
2026

2.5181

25.4234

21.9786

0.0552

9.0206

1.0885

10.1091

4.5931

1.0015

5.5946

0.0000
5,496.650
6 5,496.650
6 1.1987

0.2199
5,579.242
3 2027

97.2416

15.2391

21.7031

0.0545

2.4929

0.5521

3.0450

0.6704

0.5194

1.1898

0.0000
5,421.533
6 5,421.533
6 0.7189

0.2142
5,502.379
6 Maximum

97.2416

25.4234

21.9786

0.0552

9.0206

1.0885

10.1091

4.5931

1.0015

5.5946

0.0000
5,496.650
6 5,496.650
6 1.1987

0.2199
5,579.242
3 Mitigated Construction
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction

0.00 0.00

0.00 0.00

48.43 0.00

45.11 51.35

0.00 45.02

0.00 0.00

0.00 0.00

0.00 0.00
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

2.2 Overall Operational
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Area

6.5235

4.0166

20.5455

0.0253

0.4121

0.4121

0.4121

0.4121

0.0000
4,883.546
7 4,883.546
7 0.1258

0.0889
4,913.186
3 Energy

0.0492

0.4207

0.1790

2.6900e-
003

0.0340

0.0340

0.0340

0.0340
537.0558
537.0558

0.0103

9.8500e-
003
540.2472
Mobile

3.5386

3.4057

31.6070

0.0714

8.2580

0.0516

8.3096

2.1997

0.0481

2.2477
7,278.198
3 7,278.198
3 0.4822

0.3040
7,380.833
5 Total

10.1113

7.8430

52.3315

0.0993

8.2580

0.4976

8.7556

2.1997

0.4941

2.6938

0.0000
12,698.80
07 12,698.80
07 0.6183

0.4027
12,834.26
70 Unmitigated Operational
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Area

6.5235

4.0166

20.5455

0.0253

0.4121

0.4121

0.4121

0.4121

0.0000
4,883.546
7 4,883.546
7 0.1258

0.0889
4,913.186
3 Energy

0.0492

0.4207

0.1790

2.6900e-
003

0.0340

0.0340

0.0340

0.0340
537.0558
537.0558

0.0103

9.8500e-
003
540.2472
Mobile

3.5386

3.4057

31.6070

0.0714

8.2580

0.0516

8.3096

2.1997

0.0481

2.2477
7,278.198
3 7,278.198
3 0.4822

0.3040
7,380.833
5 Total

10.1113

7.8430

52.3315

0.0993

8.2580

0.4976

8.7556

2.1997

0.4941

2.6938

0.0000
12,698.80
07 12,698.80
07 0.6183

0.4027
12,834.26
70 Mitigated Operational
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name
Phase Type
Start Date
End Date
Num Days
Week
Num Days
Phase Description
1 Site Preparation
Site Preparation
6/1/2026
6/12/2026
5 10
2 Grading
Grading
6/13/2026
7/10/2026
5 20
3 Building Construction
Building Construction
7/11/2026
5/28/2027
5 230
4 Paving
Paving
5/29/2027
6/25/2027
5 20
5 Architectural Coating
Architectural Coating
6/26/2027
7/23/2027
5 20
OffRoad Equipment
Phase Name
Offroad Equipment Type
Amount
Usage Hours
Horse Power
Load Factor
Site Preparation
Rubber Tired Dozers
3 8.00
247

0.40 Site Preparation
Tractors/Loaders/Backhoes
4 8.00
97 0.37
Grading
Excavators
1 8.00
158

0.38 Grading
Graders
1 8.00
187

0.41 Grading
Rubber Tired Dozers
1 8.00
247

0.40 Grading
Tractors/Loaders/Backhoes
3 8.00
97 0.37
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00

0.00 0.00
Residential Indoor: 463,725; Residential Outdoor: 154,575; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area:
12,768 (Architectural Coating
–
sqft)
Acres of Grading (Site Preparation Phase): 15
Acres of Grading (Grading Phase): 20
Acres of Paving: 4.79
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.1 Mitigation Measures Construction
Water Exposed Area
Reduce Vehicle Speed on Unpaved Roads
Building Construction
Cranes
1 7.00
231

0.29 Building Construction
Forklifts
3 8.00
89 0.20
Building Construction
Generator Sets
1 8.00
84 0.74
Building Construction
Tractors/Loaders/Backhoes
3 7.00
97 0.37
Building Construction
Welders
1 8.00
46 0.45
Paving
Pavers
2 8.00
130

0.42 Paving
Paving Equipment
2 8.00
132

0.36 Paving
Rollers
2 8.00
80 0.38
Architectural Coating
Air Compressors
1 6.00
78 0.48
Trips and VMT
Phase Name
Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Site Preparation
7 18.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Grading
6 16.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Building Construction
9 254.00

60.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Paving
6 16.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
Architectural Coating
1 52.00

4.00 0.00

10.80 7.30

20.00 LD_Mix
HDT_Mix
HHDT
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.2 Site Preparation - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

19.6570

0.0000

19.6570

10.1025

0.0000

10.1025

0.0000

0.0000
Off-Road

2.4727

25.2339

17.9118

0.0381

1.0868

1.0868

0.9999

0.9999
3,689.103
7 3,689.103
7 1.1931
3,718.932
0 Total

2.4727

25.2339

17.9118

0.0381

19.6570

1.0868

20.7438

10.1025

0.9999

11.1023
3,689.103
7 3,689.103
7 1.1931
3,718.932
0 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

4.3400e-
003

0.1668

0.0586

7.7000e-
004

0.0271

1.0400e-
003

0.0281

7.8000e-
003

9.9000e-
004

8.7900e-
003

83.5919

83.5919

2.8800e-
003

0.0121

87.2672
Worker

0.0411

0.0227

0.3554

1.1800e-
003

0.1479

6.9000e-
004

0.1486

0.0392

6.3000e-
004

0.0399
119.5014
119.5014

2.7100e-
003

2.7300e-
003
120.3829
Total

0.0454

0.1895

0.4140

1.9500e-
003

0.1750

1.7300e-
003

0.1767

0.0470

1.6200e-
003

0.0486
203.0933
203.0933

5.5900e-
003

0.0148
207.6501
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.2 Site Preparation - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

8.8457

0.0000

8.8457

4.5461

0.0000

4.5461

0.0000

0.0000
Off-Road

2.4727

25.2339

17.9118

0.0381

1.0868

1.0868

0.9999

0.9999

0.0000
3,689.103
7 3,689.103
7 1.1931
3,718.932
0 Total

2.4727

25.2339

17.9118

0.0381

8.8457

1.0868

9.9324

4.5461

0.9999

5.5460

0.0000
3,689.103
7 3,689.103
7 1.1931
3,718.932
0 Mitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

4.3400e-
003

0.1668

0.0586

7.7000e-
004

0.0271

1.0400e-
003

0.0281

7.8000e-
003

9.9000e-
004

8.7900e-
003

83.5919

83.5919

2.8800e-
003

0.0121

87.2672
Worker

0.0411

0.0227

0.3554

1.1800e-
003

0.1479

6.9000e-
004

0.1486

0.0392

6.3000e-
004

0.0399
119.5014
119.5014

2.7100e-
003

2.7300e-
003
120.3829
Total

0.0454

0.1895

0.4140

1.9500e-
003

0.1750

1.7300e-
003

0.1767

0.0470

1.6200e-
003

0.0486
203.0933
203.0933

5.5900e-
003

0.0148
207.6501
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Grading - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

7.0826

0.0000

7.0826

3.4247

0.0000

3.4247

0.0000

0.0000
Off-Road

1.5227

15.3148

14.5402

0.0297

0.6236

0.6236

0.5737

0.5737
2,873.705
2 2,873.705
2 0.9294
2,896.940
5 Total

1.5227

15.3148

14.5402

0.0297

7.0826

0.6236

7.7062

3.4247

0.5737

3.9984
2,873.705
2 2,873.705
2 0.9294
2,896.940
5 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

4.3400e-
003

0.1668

0.0586

7.7000e-
004

0.0271

1.0400e-
003

0.0281

7.8000e-
003

9.9000e-
004

8.7900e-
003

83.5919

83.5919

2.8800e-
003

0.0121

87.2672
Worker

0.0365

0.0202

0.3159

1.0500e-
003

0.1314

6.1000e-
004

0.1321

0.0349

5.6000e-
004

0.0354
106.2235
106.2235

2.4100e-
003

2.4300e-
003
107.0070
Total

0.0409

0.1870

0.3745

1.8200e-
003

0.1585

1.6500e-
003

0.1602

0.0427

1.5500e-
003

0.0442
189.8154
189.8154

5.2900e-
003

0.0145
194.2742
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.3 Grading - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Fugitive Dust

3.1872

0.0000

3.1872

1.5411

0.0000

1.5411

0.0000

0.0000
Off-Road

1.5227

15.3148

14.5402

0.0297

0.6236

0.6236

0.5737

0.5737

0.0000
2,873.705
2 2,873.705
2 0.9294
2,896.940
5 Total

1.5227

15.3148

14.5402

0.0297

3.1872

0.6236

3.8107

1.5411

0.5737

2.1148

0.0000
2,873.705
2 2,873.705
2 0.9294
2,896.940
5 Mitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

4.3400e-
003

0.1668

0.0586

7.7000e-
004

0.0271

1.0400e-
003

0.0281

7.8000e-
003

9.9000e-
004

8.7900e-
003

83.5919

83.5919

2.8800e-
003

0.0121

87.2672
Worker

0.0365

0.0202

0.3159

1.0500e-
003

0.1314

6.1000e-
004

0.1321

0.0349

5.6000e-
004

0.0354
106.2235
106.2235

2.4100e-
003

2.4300e-
003
107.0070
Total

0.0409

0.1870

0.3745

1.8200e-
003

0.1585

1.6500e-
003

0.1602

0.0427

1.5500e-
003

0.0442
189.8154
189.8154

5.2900e-
003

0.0145
194.2742
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Building Construction - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Off-Road

1.3674

12.4697

16.0847

0.0270

0.5276

0.5276

0.4963

0.4963
2,556.474
4 2,556.474
4 0.6010
2,571.498
1 Total

1.3674

12.4697

16.0847

0.0270

0.5276

0.5276

0.4963

0.4963
2,556.474
4 2,556.474
4 0.6010
2,571.498
1 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

0.0651

2.5022

0.8791

0.0116

0.4064

0.0156

0.4219

0.1170

0.0149

0.1319
1,253.878
1 1,253.878
1 0.0432

0.1814
1,309.007
5 Worker

0.5798

0.3202

5.0148

0.0167

2.0866

9.6700e-
003

2.0962

0.5535

8.9000e-
003

0.5624
1,686.298
1 1,686.298
1 0.0383

0.0385
1,698.736
7 Total

0.6449

2.8224

5.8939

0.0282

2.4929

0.0252

2.5182

0.6704

0.0238

0.6942
2,940.176
2 2,940.176
2 0.0815

0.2199
3,007.744
2 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Building Construction - 2026
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Off-Road

1.3674

12.4697

16.0847

0.0270

0.5276

0.5276

0.4963

0.4963

0.0000
2,556.474
4 2,556.474
4 0.6010
2,571.498
1 Total

1.3674

12.4697

16.0847

0.0270

0.5276

0.5276

0.4963

0.4963

0.0000
2,556.474
4 2,556.474
4 0.6010
2,571.498
1 Mitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

0.0651

2.5022

0.8791

0.0116

0.4064

0.0156

0.4219

0.1170

0.0149

0.1319
1,253.878
1 1,253.878
1 0.0432

0.1814
1,309.007
5 Worker

0.5798

0.3202

5.0148

0.0167

2.0866

9.6700e-
003

2.0962

0.5535

8.9000e-
003

0.5624
1,686.298
1 1,686.298
1 0.0383

0.0385
1,698.736
7 Total

0.6449

2.8224

5.8939

0.0282

2.4929

0.0252

2.5182

0.6704

0.0238

0.6942
2,940.176
2 2,940.176
2 0.0815

0.2199
3,007.744
2 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Building Construction - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Off-Road

1.3674

12.4697

16.0847

0.0270

0.5276

0.5276

0.4963

0.4963
2,556.474
4 2,556.474
4 0.6010
2,571.498
1 Total

1.3674

12.4697

16.0847

0.0270

0.5276

0.5276

0.4963

0.4963
2,556.474
4 2,556.474
4 0.6010
2,571.498
1 Unmitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

0.0636

2.4755

0.8703

0.0113

0.4064

0.0154

0.4218

0.1170

0.0148

0.1318
1,227.939
0 1,227.939
0 0.0442

0.1776
1,281.965
0 Worker

0.5480

0.2939

4.7482

0.0162

2.0866

9.1000e-
003

2.0957

0.5535

8.3700e-
003

0.5618
1,637.120
2 1,637.120
2 0.0352

0.0366
1,648.916
6 Total

0.6116

2.7694

5.6185

0.0275

2.4929

0.0245

2.5175

0.6704

0.0231

0.6936
2,865.059
2 2,865.059
2 0.0794

0.2142
2,930.881
6 Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.4 Building Construction - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Off-Road

1.3674

12.4697

16.0847

0.0270

0.5276

0.5276

0.4963

0.4963

0.0000
2,556.474
4 2,556.474
4 0.6010
2,571.498
1 Total

1.3674

12.4697

16.0847

0.0270

0.5276

0.5276

0.4963

0.4963

0.0000
2,556.474
4 2,556.474
4 0.6010
2,571.498
1 Mitigated Construction On-Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Hauling

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Vendor

0.0636

2.4755

0.8703

0.0113

0.4064

0.0154

0.4218

0.1170

0.0148

0.1318
1,227.939
0 1,227.939
0 0.0442

0.1776
1,281.965
0 Worker

0.5480

0.2939

4.7482

0.0162

2.0866

9.1000e-
003

2.0957

0.5535

8.3700e-
003

0.5618
1,637.120
2 1,637.120
2 0.0352

0.0366
1,648.916
6 Total

0.6116

2.7694

5.6185

0.0275

2.4929

0.0245

2.5175

0.6704

0.0231

0.6936
2,865.059
2 2,865.059
2 0.0794

0.2142
2,930.881
6 Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2020.4.0
Date: 12/11/2023 8:36 AM

Revised Reduced Development Footprint Alternative- South Plan - San Diego County APCD Air District, Summer EMFAC Off-Model Adjustment Factors for Gasoline Light Duty Vehicle to Account for the SAFE Vehicle Rule Not Applied

3.5 Paving - 2027
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
lb/day
lb/day
Off-Road

0.9152

8.5816

14.5780

0.0228

0.4185

0.4185

0.3850

0.3850
2,206.745
2 2,206.745
2 0.7137
2,224.587
8 Paving

0.6275

0.0000

0.0000

0.0000

0.0000

0.0000

0.0000
Total

1.5426

8.5816

14.5780

0.0228