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jurisdiction. In addition,the NPDES permit includes hydromodification requirements that projects must include management techniques to reduce the potential for impacts, such as a change in runoff and sediment yield because of land use modifications.To address hydromodification requirements with the County of San Bernardino,the Santa Ana RWQCB developed a Technical Guidance Document for Water Quality Management Plans.46 The Final WQMP would specify the Site Design,Source Control, LID,and Treatment Control BMPs that would be implemented to capture,treat,and reduce pollutants of concern in storm water runoff. Design BMPs are storm water management strategies that emphasize conservation and use of existing site features to reduce the amount of runoff and pollutant loading generated from a site.
Source Control BMPs are preventative measures that are implemented to prevent the introduction of pollutants into storm water. LID BMPs mimic a project site's natural hydrology by using design measures that capture,filter,store,evaporate,detain,and infiltrate runoff rather than allowing runoff to flow directly to piped or impervious storm drains.Treatment Control BMPs are structural BMPs designed to treat and reduce pollutants in storm water runoff prior to releasing it to receiving waters.
Construction.The Project involves the construction of a new 3,698-square-foot SAWCo headquarters and associated improvements including a 4,066-square-foot maintenance building, maintenance yard, driveway, parking,solar cover, landscaping,and utility improvements.
Construction activities would result in the disturbance of 2.8 acres of soil. Pollutants of concern during construction include sediments,trash, petroleum products,concrete waste(dry and wet), sanitary waste,and chemicals. Each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. During construction activities, excavated soil would be exposed,and there would be an increased potential for soil erosion and sedimentation compared to existing conditions. In addition, chemicals, liquid products, petroleum products(e.g., paints,solvents, and fuels), and concrete-related waste may be spilled or leaked, and they have the potential to be transported via storm water runoff into receiving waters.
Because construction of the Project would disturb greater than 1 acre of soil,the Project is subject to the requirements of the CGP,which requires preparation of an SWPPP and implementation of construction BMPs during construction activities. Construction BMPs would include, but are not limited to, Erosion Control and Sediment Control BMPs designed to minimize erosion and retain sediment on site as well as Good Housekeeping BMPs to prevent spills, leaks, and discharge of construction debris and waste into receiving waters.
As detailed in the Report of Geotechnical EvaluationsA7 completed for the Project, no groundwater was encountered within the depth of 3 feet explored and available recorded groundwater well data in the Project vicinity indicates historical groundwater measured at approximately 267 feet below ground.The Project would require excavation to a maximum depth of 6 feet below ground surface.
Therefore, it is not anticipated that dewatering or shoring of groundwater would be required during construction.
46 CDM Smith Inc.2013. Technical Guidance Document Water Quality Management Plans.June 21. 47 Soils Southwest,Inc.2024. Op.cit.
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Adherence with the CGP, including implementation of the required SWPPP and Construction BMPS, would ensure construction impacts related to surface water quality standards,waste discharge requirements,and surface water quality would be less than significant.
Operation. Pollutants of concern from long-term operations include suspended solids/sediment, nutrients, oil and grease, metals, and trash and debris.The Project would include an infiltration basin and an underground storage infiltration system that would be used for stormwater control, treatment, and infiltration.The Project would also be required to prepare a Final WQMP, consistent with the requirement of the City's M54 permit, because the Project consists of significant new development that would create 10,000 square feet or more of impervious surface.The Final WQMP would specify the Site Design,Source Control, LID,and Treatment Control BMPs that would be implemented to capture,treat,and reduce pollutants of concern in storm water runoff.Therefore, compliance with the requirements of the City and the M54 Permit would ensure that operation impacts to water quality would be less than significant.
Overall, because the Project would be required to comply with existing regulations(including the CGP and the MS4 Permit),the Project would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality. Impacts would be less than significant and no mitigation is required. b. Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?(Less Than Significant Impact)
The Project site lies within the Upper Santa Ana Valley—Chino Groundwater Basin."The basin has a surface area of approximately 154,000 acres(240 square miles)and is located in southwestern San Bernardino County.The basin is bounded by the Rialto-Colton fault to the east, impermeable rocks forming the Jurupa Mountains to the southeast, impermeable rocks of the Puente Hills and the Chino Fault to the south,the San Jose Fault on the northwest, and impermeable rocks of the San Gabriel Mountains and the Cucamonga Fault to the north.The water-bearing units in the Chino Subbasin include Holocene and Upper Pleistocene alluvium. Recharge to the basin occurs by direct infiltration or precipitation on the subbasin floor, by infiltration of surface flow,and by underflow of ground water from adjacent basins.There are five recharge facilities in the subbasin including Deer Creek, Day Creek, East Etiwanda,San Sevaine,and Victoria.Groundwater levels declined about 80 feet from historical high marks in the 1920s by 1980. By 2000,water levels had recovered about 20 feet.Total storage within the subbasin is approximately 18,300,000 acre-feet and,as of 2000,total storage is estimated to have been 5,325,000 acre-feet.49 Construction.As detailed in the Report of Geotechnical Evaluations50 completed for the Project, no groundwater was encountered within the depth of 3 feet explored and available recorded 48 California Department of Water Resources(DWR). n.d.Groundwater Basin Boundary Assessment Tool.
Website: https://gis.water.ca.gov/app/bbat/(accessed July 3,2024). 49 California Department of Water Resources(DWR). Division of Water Rights.2006.Upper Santa Ana Valley Groundwater Basin, Chino Subbasin, California's Groundwater Bulletin 118.January 20. sa Soils Southwest, Inc.2024.Op.cit.
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groundwater well data in the Project vicinity indicates historical groundwater measured at approximately 267 feet below ground.The Project would require excavation to a maximum depth of 6 feet below ground surface.Therefore, it is not anticipated that dewatering or shoring of groundwater would be required during construction,and construction activities associated with the Project would not contribute to a substantial depletion of groundwater supplies.
Operation. Development of the Project would increase impervious surface area by approximately
1.1 acres,which would decrease on-site infiltration.As described above,the Project includes BMPs to collect and infiltrate stormwater at the Project site in accordance with the M54 Permit.Therefore, development of the Project would not substantially decrease the amount of stormwater that infiltrates as compared to the existing conditions.
Water service for the Project would be provided by the City of Upland.The City's water supplies include imported water from the Metropolitan Water District of Southern California (MWD) purchased through Inland Empire Utilities Agency(IEUA),groundwater pumped from City owned wells and West End Consolidated Water Company(WECWC),groundwater purchased from SAWCo, surface water purchased from SAWCo and treated by the City,and recycled water purchased from IEUA.Therefore, operation of the Project would likely involve the use of both surface and groundwater sources for potable water.The 2020 Urban Water Management Plan indicates the City has sufficient water supplies to meet water demands through 2045, including during multiple dry years.51 Therefore,the Project's water needs would not contribute to a substantial depletion of groundwater supplies.
For the reasons listed above, impacts related to the decrease of groundwater supplies or interference with groundwater recharge would be less than significant,and no mitigation is required.
c. Would the project substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
I. Result in substantial erosion or siltation on-or off-site;(Less Than Significant Impact) As previously discussed,the Project site is undeveloped and does not contain any existing stormwater infrastructure.Stormwater flows to the southwest to a natural ravine which discharges into an existing ditch along the freeway right-of-way which discharges to a City of Fontana storm drain along Poplar Avenue. During construction activities, more than 1 acre of soil would be disturbed.Soil would be exposed,and drainage patterns temporarily altered during grading and other construction activities,and there would be an increased potential for soil erosion and siltation compared to existing conditions.Additionally,during a storm event,soil erosion and siltation could occur at an accelerated rate.The CGP requires the preparation of an SWPPP to identify construction BMPs to be implemented as part of the Project to reduce impacts on water quality during construction, including those impacts associated with soil erosion and siltation.With compliance 51 City of Upland.2021.City of Upland 2020 Urban Water Management Plan and Water Shortage Contingency Plan.June.
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with the requirements in the CGP and implementation of construction BMPs,construction impacts related to on-or off-site erosion or siltation would be less than significant.
After the completion of Project construction,the Project would not significantly alter the existing drainage pattern of the site. However,operation of the Project would result in an increase in impervious surfaces on the Project site from approximately 0.57 to 1.65 acres, which would result in a net increase in stormwater runoff that could lead to downstream erosion in receiving waters.
However, as discussed above,the infiltration basin and underground storage infiltration system included in the Project's design would be used for stormwater control,treatment,and infiltration in compliance with the requirements of the M54 Permit. Due to the incorporation of LID techniques as required by the MS4 Permit,operational impacts related to on-or off-site erosion or siltation would be less than significant.
ii. Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on-or offsite;(Less Than Significant impact)
Development of the Project would result in an increase in impervious surfaces on the Project site from approximately 0.57 to 1.65 acres,which could have the potential to increase the volume and rate of stormwater runoff discharged from the Project site, However,as previously discussed,an infiltration basin and underground storage infiltration system included in the Project's design would be used for stormwater control,treatment, and infiltration in compliance with the requirements of the M54 Permit.The proposed drainage facilities and BMPs needed to accommodate stormwater runoff would be appropriately sized so that on-site flooding would not occur.Therefore, due to the implementation of LID techniques as required by the MS4 Permit,the Project would not substantially increase the rate or amount of surface runoff in a manner that would result in flooding on-or off site. Impacts would be less than significant, and no mitigation is required.
Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff,• (Less Than Significant impact)
Stormwater Drainage System Capacity. Under existing conditions,stormwater flows to the southwest to a natural ravine which discharges into an existing ditch along the freeway right-of-way which discharges to a City of Fontana storm drain along Poplar Avenue that discharges to the San Sevaine Channel,which flows to the Santa Ana River Reach 3,which drains to the Prado Dam. Prado Dam drains to Santa Ana River Reach 2,which flows to Santa Ana River Reach 1,which discharges to the Pacific Ocean.52 The Project would include an infiltration basin and underground storage infiltration system,which would reduce site discharge to not exceed pre-developed flow rates.The proposed drainage facilities would be designed in compliance with the MS4 Permit.The proposed drainage facilities and BMPs needed to accommodate stormwater runoff would be appropriately sized such that drainage facility capacity would not be exceeded during a design storm.Therefore, the Project would not result in an exceedance of planned or existing stormwater drainage systems, and impacts would be less than significant.
52 Land Development Design Company,LLC.2024.Op.cit.
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Polluted Runoff.As discussed in Section 4.10.a, pollutants of concern during construction include sediments,trash, petroleum products,concrete waste (dry and wet),sanitary waste,and chemicals, and each of these pollutants on its own or in combination with other pollutants can have a detrimental effect on water quality. Drainage patterns would be temporarily altered during grading and other construction activities, and construction-related pollutants could be spilled, leaked,or transported via storm runoff into adjacent drainages and downstream receiving waters. However, as previously discussed,the Project would be required to comply with the requirements set forth by the CGP,including preparation of an SWPPP,which would specify BMPs to be implemented to control the discharge of pollutants in stormwater runoff as a result of construction activities.
Therefore,construction-related impacts would be less than significant,and no mitigation is required.
Expected pollutants of concern from long-term operations include suspended solids/sediment, nutrients,oil and grease, metals,and trash and debris.As previously discussed, compliance with the MS4 Permit,the implementation of LID techniques,and the incorporation of operational BMPs to target pollutants of concern would ensure that the Project would not discharge substantial sources of polluted runoff from the Project site.Operation-related impacts would be less than significant, and no mitigation is required.
iv. Impede or redirect flood flows?(No Impact)
According to the Federal Emergency Management Agency(FEMA) Flood Insurance Rate Map (FIRM) No.06071C7870J,the Project site is located in Zone X,which is identified as an area of minimal flood hazard.53 The Project would not alter the topography of the Project site,which is relatively flat, and would not substantially alter drainage patterns. Because the Project would not place improvements and structures directly within a 100-year floodplain,the Project would not impede or redirect flood flows, and there would be no impact.
d. In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to project inundation?(No Impact)
Flooding.According to FEMA FIRM No. 06071C7870J,the Project site is located in Zone X,which is identified as an area of minimal flood hazard.54 Therefore,the Project would not risk release of pollutants due to Project inundation due to flood hazard.
Tsunami.The Project site is approximately 38 miles northeast of the Pacific Ocean at an elevation over 1,600 feet above mean sea level (amsl). Based on the distance from the Pacific Ocean,the Project site is not located in a tsunami hazard zone and therefore would not be susceptible to impacts associated with a tsunami.
Seiches.Seiches are waves created in an enclosed body of water(e.g.,a bay, lake,or harbor)that go up and down or oscillate and do not progress forward like standard ocean waves. Limited isolated 53 Federal Emergency Management Agency(FEMA).2016.Flood Insurance Rate Map No.06071C7870J.Map Revised September 2,2016.Website: https://msc.fema.gov/portal/search(accessed July 5,2024). 54 Ibid.
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damage to adjacent and down-slope structures has been observed from seiches occurring in swimming pools and in small shallow lakes and ponds.There are no sizeable enclosed bodies of water in the nearby vicinity of the Project site.Therefore,the Project would not risk release of pollutants due to Project inundation due to seiche.
Dam Inundation.The Project site is not located within a mapped dam failure inundation area.' Therefore,the Project site is not at risk of inundation due to dam failure,and no impact would occur.
e. Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?(Less Than Significant Impact) The Project is within the jurisdiction of the Santa Ana RWQCB.The Santa Ana RWQCB adopted a Basin Plan(January 1995,with amendments effective on or before June 2019)that designates beneficial uses for all surface and groundwater within their jurisdiction and establishes the water quality objectives and standards necessary to protect those beneficial uses.As previously discussed, the Project would comply with existing NPDES permit requirements, including the CGP and MS4 Permit,and would implement construction and operational BMPs to reduce pollutants of concern in stormwater runoff.Compliance with these regulatory requirements would ensure that the Project would not degrade or alter water quality,cause the receiving waters to exceed the water quality objectives,or impair the beneficial use of receiving waters.As such,the Project would not result in water quality impacts that would conflict with the Basin Plan.Construction and operational impacts related to a conflict with the Basin Plan would be less than significant.
The Sustainable Groundwater Management Act(SGMA),which was enacted in September 2014, requires governments and water agencies of high-and medium-priority basins to halt overdraft of groundwater basins.The SGMA requires the formation of local Groundwater Sustainability Agencies (GSAs),which are required to adopt Groundwater Sustainability Plans (GSPs)to manage the sustainability of the groundwater basins.The Project site is in the Upper Santa Ana Valley—Chino Groundwater Basin,which the California Department of Water Resources designates as a very low priority basin.'Therefore,development of a GSP is not required for the basin associated with the Project.
As discussed above,the Project would comply with regulatory requirements to treat pollutants in stormwater runoff during construction and operation of the Project. Compliance with these regulatory requirements would ensure that stormwater that may infiltrate during construction or operation of the Project would be treated prior to reaching groundwater.Therefore,the Project would not affect groundwater quality(Upper Santa Ana Valley—Chino Groundwater Basin).As previously stated,development of the Project would increase the impervious surface on the Project site by 1.1 acres. Although,development of the Project would increase the impervious surface area 55 California Department of Water Resources(DWR).2015. Division of Safety of Dams.Dam Breach inundation Map Web Publisher.Website: https://fmds.water.ca.gov/webgis/?appid=dam_prototype_v2 (accessed July 5,2024).
56 California Department of Water Resources.2020.Sustainable Groundwater Management Act 2019 Basin Prioritization Process and Results. May.
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on the Project site and decrease on-site infiltration,the Project would collect and infiltrate stormwater from the Project site.Therefore,the Project would not substantially impact groundwater supplies(Upper Santa Ana Valley—Chino Groundwater Basin). Furthermore,as previously stated,the Project site is located within a very low priority basin and therefore the SGMA provisions do not apply. Impacts related to a conflict with or obstruction of a water quality control plan or sustainable groundwater management plan would be less than significant,and no mitigation is required.
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4.11 LAND USE AND PLANNING
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
Impact Incorporated Impact Impact
Would the project:
a) Physically divide an established community? ❑ ❑ ❑ b) Cause a significant environmental impact due to a conflict with any land use plan,policy,or regulation adopted for the ❑ ❑ ® ❑ purpose of avoiding or mitigating an environmental effect? a. Would the project physically divide an established community?(No Impact) The physical division of an established community typically refers to the construction of a physical feature(e.g.,an interstate highway or railroad tracks)or removal of a means of access(e.g.,a local road or bridge)that would impair mobility within an existing community or between a community and outlying areas. For instance,the construction of an interstate highway through an existing community may constrain travel from one side of the community to another;similarly,such construction may also impair travel to areas outside the community.
The Project would result in the construction of a new 3,698-square-foot SAWCo headquarters and associated improvements including a 4,066-square-foot maintenance building, maintenance yard, driveway, parking, solar cover, landscaping, and utility improvements.The Project site is generally surrounded by a mix of residential,commercial,and industrial uses,and the Project would be consistent with the type and intensity of development in the area.Vehicular access to the Project site would be provided via two new driveways located along the northern and eastern property boundaries.The Project would not require the construction of any new infrastructure that would divide an established community and would not remove any means of access.Therefore,the Project would have no impact related to physically dividing an established community, and no mitigation is required.
b. Would the project cause a significant environmental impact due to a conflict with any land use plan,policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?(Less Than Significant Impact)
The Project would result in the construction of a new 3,698-square-foot SAWCo headquarters and associated improvements including a 4,066-square-foot maintenance building, maintenance yard, driveway, parking,solar cover, landscaping,and utility improvements.The main documents guiding development and regulating land uses in Upland are the City's General Plan and Zoning Code.The proposed use is not currently permitted at the site under the current SFR-L General Plan land use designation and RS-10 zoning.To comply with the City's General Plan and zoning regulations,the Project will require a General Plan amendment and a zone change to Public Utilities (PU) land use designation and Public/Institutional (PB/I)zoning.
The PU designation provides areas for landfills,flood control/recharge facilities and public utilities including gas, electricity,and water.The purpose of the PB/I zone is to allow for public and quasi- 4-52 PA202442O241723_San Antonio Driveway Expansion\PRODUCTS\CEQA\Public Review Draft45an Antonio Water Headquarters ISMND_was 25.docx(08108125)
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public facilities that serve Upland residents and visitors.The PU designation and PB/I zone allow a maximum floor-area ratio(FAR)of 0.5.The Project would have a FAR of 0.07 and is consistent with the allowed uses of the PB/I zone and PU designation.
It should be noted that according to CEQA, policy conflicts do not, in and of themselves, constitute a significant environmental impact. Policy conflicts are considered to be environmental impacts only when they would result in direct physical impacts or where those conflicts relate to avoiding or mitigating environmental impacts.As such,associated physical environmental impacts are discussed in this 15/MND under specific topical sections.The Project would not result in any direct physical impacts that cannot be mitigated to a less than significant level.As a result of the proposed rezone and General Plan amendment,the Project would not conflict with any applicable land use plans, policies,or regulations that were adopted for the purpose of avoiding or mitigating an environmental effect,and this impact would be less than significant.
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4.12 MINERAL RESOURCES
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
Impact Incorporated Impact Impact
Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the ❑ ❑ ❑ state?
b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, ❑ ❑ ❑ specific plan or other land use plan?
a. Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?(No Impart) The Surface Mining and Reclamation Act(SMARA)enacted by the California Legislature in 1975 provides guidelines to assist with the classification and designation of mineral lands.Areas are classified on the basis of geologic factors without regard to existing land uses and ownership.
SMARA categorizes areas into four Mineral Resource Zones(MRZs):
• MRZ-1:An area where adequate information indicates that no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence. • MRZ-2:An area where adequate information indicates that significant mineral deposits are present, or where it is judged that a high likelihood exists for their presence. • MRZ-3:An area containing mineral deposits of which their significance cannot be properly evaluated.
• MR2-4:An area where information is not adequate enough to be able to assign to any other MRZ zone.
The entire City of Upland is classified as MRZ-2. Geologic data indicate that significant PCC-Grade aggregate resources are present within the City,which is attributed to its location below the foothills of the San Gabriel Mountains and atop the San Antonio Creek and Cucamonga Creek alluvial fans.The City's known mineral resources are in the form of aggregate materials located within the San Antonio Creek and Cucamonga Creek drainage areas.57 Despite the mineral resource designations, no mineral resource extraction activities occur at the Project site under existing conditions.The Project site is not designated as a local mineral resource holding and deposit area or a sector designated by the State Mining and Geology Board as 57 City of Upland.2015a.Final Program Environmental impact Report General Plan Update(GPU 08-03), Zoning Code Update(ZCU 08-03), Climate Action Plan,and Cable Airport Land Use Compatibility Plan Update SCH No.2012041006).September 28.
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containing regionally significant PCC-grade aggregate resources.58 The Project would develop the Project site with a new SAWCo headquarters and associated improvements,and no mineral resource extraction activities are proposed as part of the Project.As such,the Project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the State,and no impact would occur.
b. Would the project result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan,specific plan or other land use plan?(Na Impact) The City of Upland General Plan Land Use Element does not include a land use designation specifically intended for mineral production or development of natural resources(i.e., rock and gravel production). Thus,there is no locally important mineral resource recovery site delineated on the current General Plan Land Use Map.Given existing and proposed conditions on site, implementation of the Project would not result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan,specific plan,or other land use plan. No impact would occur,and no mitigation is required. 58 City of Upland.2015b.Op.cit.
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4.13 NOISE
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
Impact Incorporated Impact Impact
Would the project result in:
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project ❑ ❑ ® ❑ in excess of standards established in the local general plan or noise ordinance,or applicable standards of other agencies? bj Generation of excessive ground borne vibration or ❑ ❑ ® ❑ groundborne noise levels?
cj For a project located within the vicinity of a private airstrip or an airport land use plan or,where such a plan has not been adopted,within 2 miles of a public airport or public use ❑ ❑ ❑ airport,would the project expose people residing or working in the project area to excessive noise levels?
The following discussion and analyses are based on the findings included in the Noise and Vibration Impact Analysis'completed for the Project,which is included as Appendix F to this IS/MND. a. Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?(Less Than Significant Impact)
The primary existing noise sources in the Project area are transportation facilities, including SR-210 to the south.To assess the existing noise conditions in the area, long-term noise measurements were conducted at the Project site.Two long-term, 24-hour measurements were taken from July 16, 2024,to July 17, 2024.Table 4.13.A provides a summary of the existing noise levels and calculated Community Noise Equivalent Level (CNEL) level from the long-term noise level measurements.As shown in Table 4.13.A,the calculated CNEL levels reached 70.1 decibels NBA)CNEL. Hourly noise levels at surrounding uses are as low as 57.9 dBA equivalent continuous sound level {Leq) during nighttime hours and 59.8 dBA Leg during daytime hours.
Short-Term Construction-Related Impacts. Noise impacts associated with construction activities are regulated by Section 9.40.100(M)of the City's Municipal Code,which limits construction activities to the hours between 7:00 a.m.and 6:00 p.m.on weekdays.6p While the City establishes limits to the hours during which construction activity may take place,it has not established numeric maximum acceptable construction source noise levels at potentially affected receivers,which would allow for a quantified determination of what CEQA constitutes as a substantial temporary or periodic noise increase. 59 LSA.2024e.Noise and Vibration Impact Analysis for the Proposed San Antonio Water Headquarters in Upland,California(LSA Project No. 20241723). November.
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Table 4.13.A: Existing Noise Level Measurements
Location Daytime Noise Evening Nighttime Noise Average Daily Number Location Description Levels' Noise Levels2 Levels3 Noise Levels (dBA Leg] (dBA Leg) (dBA Legg (dBA CNEL)
On a light pole at the end of
20th Street across from the
northeastern corner of the
LT 1 Project site,approximately 490 59.8-67.4 60.6--61.9 57.9-64.9 68.1 feet away from the SR-210
centerline and 355 feet away
from the North Campus Avenue
centerline.
On a light pole across from the
southwestern corner of the
LT-2 Project site,approximately 175 63.4-68.9 63.6-64.4 61.1-65.0 70.1 feet away from the SR-210
centerline.
Source:Compiled by LSA(2024).
' Daytime Noise Levels=noise levels during the hours of 7:00 a.m.to 7:00 p.m. 2 Evening Noise Levels=noise levels during the hours of 7:00 p.m.to 10:00 p.m. 3 Nighttime Noise Levels=noise levels during the hours of 10:00 p.m.to 7:00 a.m.
CNEL=Community Noise Equivalent Level
dBA=A-weighted decibels
ft=foot/feet
=equivalent continuous sound level
Therefore, a numerical construction threshold based on the Federal Transit Administration's(FTA) Transit Noise and Vibration Impact Assessment Manual(FTA Manual)61 is used for analysis of daytime construction impacts.The FTA considers a daytime exterior construction noise level of 80 dBA Leg 1-hour as a reasonable threshold for residential uses,85 dBA Leq 1-hour for commercial uses, and 90 dBA Leg 1-hour for industrial land.
Two types of short-term noise impacts could occur during the construction of the Project. First, construction crew commutes and the transport of construction equipment and materials to the site for the Project would incrementally increase noise levels on access roads leading to the site.
Although there would be a relatively high single-event noise-exposure potential causing intermittent noise nuisance(passing trucks at 50 feet would generate up to 84 dBA Lmax),the effect on longer- term ambient noise levels would be small compared to existing daily traffic volumes on East 20th Street.As detailed in the Noise and Vibration Analysis completed for the Project,the expected traffic noise level increase would be approximately 1.7 dBA.A noise level increase of less than 3 dBA would not be perceptible to the human ear in an outdoor environment.Therefore,short-term, construction-related impacts associated with worker commute and equipment transport to the Project site would be less than significant.
61 Federal Transit Administration(FTA).2018.Transit Noise and Vibration Impact Assessment Manual.Office of Planning and Environment.Report No.0123.September.
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The second type of short-term noise impact is related to noise generated during construction,which includes site preparation,grading, building construction, paving, and architectural coating on the Project site.As detailed in the Noise and Vibration Analysis completed for the Project,the Project construction composite noise levels at a distance of 50 feet(ft)would range from 74 dBA Leq to 86 dBA Leq,with the highest noise levels occurring during the grading phase.Table 4.13.B shows the nearest sensitive uses to the Project site,their distance from the center of construction activities, and composite noise levels expected during construction.These noise level projections do not consider intervening topography or barriers.
Table 4.13.B: Potential Construction Noise Impacts at Nearest Receptor Receptor(Location) Composite Noise Level(dBA LI} Distance(feet) Composite Noise at 50 feetl Level(dBA Leg)
Residential(North) 86 250 72
Residential(West) 405 68
Source:Compiled by LSA(2024).
' The composite construction noise level represents the grading phase which is expected to result in the greatest noise level as compared to other phases.
dBA L,1=average A-weighted hourly noise level
While construction noise will vary, it is expected that composite noise levels during construction at the nearest sensitive residential uses to the north and west would approach 72 dBA Leg and 68 dBA Leq, respectively,during daytime hours.These predicted noise levels would only occur when all construction equipment is operating simultaneously and,therefore,are assumed to be rather conservative in nature. While construction-related short-term noise levels have the potential to be higher than existing ambient noise levels in the Project area under existing conditions,the noise impacts would no longer occur once Project construction is completed.
As stated above,the City's Noise Ordinance regulates noise impacts associated with construction activities.The Project would comply with the construction hours specified in the City's Noise Ordinance,which states that construction activities are allowed between the hours of 7:00 a.m.and 6:00 p.m.on weekdays. As it relates to off-site uses,construction-related noise impacts would remain below the 80 dBA Leq 1-hour construction noise level criteria for daytime construction noise level criteria as established by the FTA for residential land uses.Therefore, impacts would be less than significant and no mitigation is required.
Long-Term Noise Impacts.The Project would generate long-term noise impacts from both traffic and stationary noise sources,as discussed below.The City's noise standards correlate with land use zoning classifications to maintain identified ambient noise levels and to limit, mitigate,or eliminate intrusive noise that exceeds the ambient noise levels within a specified zone.As shown in Table 4.13.C,the City has adopted local guidelines based, in part,on the community noise compatibility guidelines established by the Governor's Office of Planning and Research for use in assessing the compatibility of various land use types with a range of noise levels. 4-58 PA2024420241723_San Antonio Driveway Expansion\PRODUCTS\CEQA\Public Review Oraft45an Antonio Water Headquarters ISM ND_was 25.docx(08108125)
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Table 4.13.C: City of Upland Exterior Noise Compatibility Standards Land Use Type Highest Level of noise Exposure that is Regarded as Normally Acceptable (Lin of CNEL)
Residential—Low Density Single-Family,Duplex,Mobile 60 dBA Homes
Residential—Multi-Family 65 dBA
Mixed-Use 70 dBA
Transient Lodging—Hotels,Motels 65 dBA
Schools,Libraries,Churches,Hospitals,Nursing Homes 70 dBA Auditoriums,Concert Halls,Amphitheaters Mitigation based on site-specific study Sports Arena,Outdoors Spectator Sports Mitigation based on site-specific study Playgrounds,Neighborhood Parks 70 dBA
Golf Course,Riding Stables,Water Recreation,Cemeteries 75 dBA Office Building—Commercial,Office/Professional 70 dBA Industrial,Manufacturing,Utilities,Agriculture 75 dBA Sources:Governor's Office of Planning and Research,State of California General Plan Guidelines 2003,2003,pages 244-254;City of Upland General Plan,Safety Element(City of Upland 2015d).
CNEL=Community Noise Equivalent Level
ld�=Day-Night Noise Level
dBA=A-weighted decibel
The City of Upland Municipal Code Chapter 9.40, Unnecessary Noise, limits the noise level generated on a property that can cross to a neighboring property.The City's noise ordinance limits are presented in terms of a 1-hour average sound level and apply to residential uses only.As prescribed in Section 9.40.040,the exterior noise standards for sensitive residential uses are 55 dBA between 7:00 a.m.and 10:00 p.m. (daytime) and 45 dBA between 10:00 p.m. and 7:00 a.m. (nighttime).
Ordinance limits generally apply to"stationary"sources such as mechanical equipment, manufacturing activities, or vehicles operating on private property.
Traffic Noise Impacts.The guidelines included in the Federal Highway Administration (FHWA) Highway Traffic Noise Prediction Model (FHWA-RD-77 108)were used to evaluate highway traffic- related noise conditions along roadway segments in the Project vicinity.As detailed in the Noise and Vibration Analysis completed for the Project,the increase in Project-related traffic noise would be greater than 3 dBA,which is perceptible to the human ear in an outdoor environment. However,the generated CNEL noise levels would be below 60 dBA CNEL,which is acceptable for low-density residential uses as specified in the City's General Plan.Therefore,traffic noise impacts from Project- related traffic on off-site sensitive receptors would be less than significant, and no mitigation measures are required.
Stationary Noise Impacts.Adjacent off-site land uses would be potentially exposed to stationary- source noise impacts from rooftop heating,ventilation,and air conditioning(HVAC)equipment and proposed truck arrival and departure activities.The potential noise impacts to off-site sensitive land uses from the proposed operations are discussed below.
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(main building and maintenance building)and assumed to operate 24 hours per day.The HVAC equipment could operate 24 hours per day and would generate sound power levels (Lw)of up to 87 dBA Lw or 72 dBA Leg at 5 feet, based on manufacturer data.62 Truck Arrival and Departure Activities. Noise levels generated by delivery trucks would be similar to noise readings from truck loading and unloading activities,which generate a noise level of 75 dBA Leg at 20 feet based on measurements taken by LSA(Operational Noise Impact Analysis for Richmond Wholesale Meat Distribution Center).63 Shorter term noise levels that occur during the docking process taken by LSA for the Operational Noise Impact Analysis for Richmond Wholesale Meat Distribution Center were measured to be 76.3 dBA Leg at 20 feet.
These noise level measures are relevant to the Project because delivery trucks are anticipated during operation of the Project. Delivery trucks would arrive on site and maneuver their trailers so that trailers would be parked within the loading docks. During this process, noise levels are associated with the truck engine noise,air brakes,and back-up alarms while the truck is backing into the dock.These noise levels would occur for a shorter period of time (less than 5 minutes).
After a truck enters the loading dock,the doors would be closed,and the remainder of the truck loading activities would be enclosed and therefore much less perceptible. Consistent with the Traffic Impact Analysis for the San Antonio Water Company Headquarters Project,"it is assumed that truck arrivals and departure activities could occur at 6 parking spaces during peak hour for a period of less than 5 minutes each.
Cumulative Operations Noise Assessment.Tables 4.13.D and 4.13.E below show the combined hourly noise levels generated by HVAC equipment and truck delivery activities at the closest off- site land uses.The results indicated that operational noise levels would be below the daytime hourly noise level standards of 55 dBA Leg for residential uses.Although the operational noise levels may exceed the nighttime hourly noise level standards of 45 dBA Le„ ambient noise levels would not increase by 5 dBA or more.Therefore, operations of the Project would be less than significant and no mitigation is required.
Table 4.13.D: Daytime Exterior Noise Level Impacts
Existing Quietest Project Generated Potential
Receptor Direction Daytime Noise Level Noise Levels Operational Noise (dBA Lam) NBA Lam) Impact71
Residential North 59.8 47.0 No
Residential West 63.4 46.7 No
Source:Compiled by L5A(2024).
' A potential operational noise impact would occur if(1)the quietest daytime ambient hour is less 55 dBA 4q at the nearest residential uses and Project noise impacts are greater 55 dBA Leg at the nearest residential uses,or{2)the quietest daytime ambient hour is greater than 55 dBA Ltq at the nearest residential uses and Project noise impacts are 3 dBA greater than the quietest daytime ambient hour.
dBA Lro=average A-weighted hourly noise level
62 Trane. n.d.Fan Performance-Product Specifications RT-PRCO23AU-EN. 63 LSA.2016.Operational Noise Impact Analysis for Richmond Wholesale Meat Distribution Center. 64 LSA.2024b. Traffic Impact Analysis San Antonio Water Headquarters Project. November. 4-60 P:\2U24420241723_San Antonio Driveway Expansion\PRODUCTS\CEQA\Public Review Oraft45an Antonio Water Headquarters ISMND_48.0825.docx(08108125)
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Table 4.13.E: Nighttime Exterior Noise Level Impacts
Existing Quietest Project Generated Potential
Receptor Direction Nighttime Noise Noise Levels Operational Noise Level(dBA Ley) {dBA Leg) Impact?1
Residential North 57.9 47.0 No
Residential West 61.1 46.7 No
Source:Compiled by LSA(2024).
A potential operational noise impact would occur if(1)the quietest nighttime ambient hour is less 45 dBA Lcy at the nearest residential uses and Project noise impacts are greater than 45 dBA Ley at the nearest residential uses,or(2)the quietest nighttime ambient hour is greater than 45 dBA Lea at the nearest residential uses and Project noise impacts are 3 dBA greater than the quietest nighttime ambient hour.
dBA Ley=average A-weighted hourly noise level
b. Would the project result in generation of excessive groundborne vibration or groundborne noise levels?(Less Than Significant impact)
Vibration standards included in the FTA Manual are used in this analysis for ground-borne vibration impacts on human annoyance.Table 4.13.F provides the criteria for assessing the potential for interference or annoyance from vibration levels in a building.
Table 4.13.F: Criteria for Potential Vibration Annoyance Land Use Max Lv 1Vd8j1 Description of Use
Workshop 90 Distinctly feelable vibration.Appropriate to workshops and non-sensitive areas.
Office 84 Feelable vibration.Appropriate to offices and non-sensitive areas.
Residential Day 78 Feelable vibration.Appropriate for computer equipment and low-power optical microscopes(up to 20X).
Residential Night and Vibration not feelable,but ground-borne noise may be audible inside quiet Operating Rooms 72 rooms.Suitable for medium-power microscopes(100X)and other equipment of law sensitivity.
Source:Transit Noise and Vibration impact Assessment Manual(FTA 2018).
As measured in 1/3-octave bands of frequency over the frequency range S to 80 Hz.
FTA=Federal Transit Administration Max=maximum
Hz=hertz VdB=vibration velocity decibels
Lv=velocity in decibels
The criteria for environmental impacts resulting from ground-borne vibration and noise are based on the maximum levels for a single event.The City's Municipal Code does not include specific criteria for assessing vibration impacts associated with damage.Therefore,for the purpose of determining the significance of vibration impacts experienced at sensitive uses surrounding the Project site,the guidelines within the 2018 FTA Manual have been used to determine vibration impacts.The FTA Manual guidelines show that a vibration level of up to 0.2 inches per second (in/sec)in peak particle velocity(PPV) is considered safe for non-engineered timber and masonry buildings and would not result in any construction vibration damage.Therefore, in order to be conservative,the 0.2 in/sec in the PPV threshold has been used when evaluating vibration impacts at the nearest structures to the site.
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Construction-Period Impacts.Ground-borne noise and vibration from construction activity would be mostly low.The closest structures,which are associated with the residential uses to the west,are approximately 60 feet from the western Project construction boundary.As detailed in the Noise and Vibration Impact Analysis completed for the Project,it is expected that vibration levels generated by dump trucks and other large equipment would generate ground-borne vibration levels of up to
0.024 PPV(in/sec)at the closest structure to the Project site.This vibration level would not exceed the 0.2 in/sec PPV threshold considered safe for non-engineered timber and masonry buildings.
Therefore,construction would not result in any vibration damage. Impacts would be less than significant, and no mitigation is required.
Long-Term Noise Impacts.The Project would not generate noticeable vibration levels related to on- site operations.Trucks traveling to and from the Project site as well as loading and unloading activities may generate vibration levels. However,the closest off-site uses are greater than 25 feet away and vibration levels generated from trucks would not be perceptible. In addition,vibration levels generated from Project-related traffic on the adjacent roadways are unusual for on-road vehicles because the rubber tires and suspension systems of on-road vehicles provide vibration isolation. Based on a reference vibration level of 0.089 in/sec PPV, structures greater than 25 feet from the roadways that contain Project trips would experience vibration levels below the most conservative standard of 0.12 in/sec PPV;therefore,vibration levels generated from Project-related traffic on the adjacent roadways would be less than significant, and no mitigation measures are required.
c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within 2 miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?(No Impact)
The nearest airport to the Project site is the Cable Airport, located approximately 2.6 miles northeast of the Project site.The Project site and surrounding sensitive uses are located well outside of the 60 dBA CNEL contour.Therefore,the Project would not be adversely affected by airport/ airfield noise. No impact would occur,and no mitigation is required. 4-62 P.\2O24\2O241723_San Antonio Driveway Eva nsion\PRODUCTS\CEQA\Public Review Oraft\5an Antonio Water Headquarters ISMND_48.0825.docx(02/08f25)
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4.14 POPULATION AND HOUSING
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
impact Incorporated Impact Impact
Would the project:
a) Induce substantial unplanned population growth in an area, either directly(for example,by proposing new homes and ❑ ❑ ® ❑ businesses)or indirectly(for example,through extension of roads or other infrastructure)?
b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing ❑ ❑ ❑ elsewhere?
a. Would the project induce substantial unplanned population growth in an area, either directly(for example, by proposing new homes and businesses)or indirectly(for example, through extension of roads or other infrastructure)?(Less Than Significant impact) State CEQA Guidelines Section 15126.2[d] identifies a project as growth inducing if it fosters economic or population growth, or the construction of additional housing either directly or indirectly in the surrounding environment. New employees from commercial or industrial development and new population from residential development represent direct forms of growth, which have a secondary effect of expanding the size of local markets and inducing additional economic activity in the area.
Under CEQA,growth inducement is not considered necessarily detrimental, beneficial,or of little significance to the environment.Typically,the growth-inducing potential of a project would be considered substantial if it fosters growth or a concentration of population in excess of what is assumed in pertinent master plans, land use plans,or in projections made by regional planning agencies.
The Project includes the construction of a new 3,698-square-foot SAWCo headquarters and associated improvements including a 4,066-square-foot maintenance building, maintenance yard, driveway, parking,solar cover, landscaping,and utility improvements. It is anticipated that approximately 10 people would be employed on the Project site,an increase of 5 people compared to the 5 people that are currently employed on the Project site under existing conditions.
Construction of the Project would provide short-term construction jobs over an approximately 20- month period. Many of the construction jobs would be temporary and would be specific to the variety of construction activities.The workforce would include a variety of construction trade workers(e.g.,cement finishers, ironworkers,welders, carpenters, electricians, painters,and laborers).Generally,construction workers are only at a job site for the time frame in which their specific skills are needed to complete that phase of construction.Although the Project would increase the number of employees at the Project site during construction activities, it is expected that local and regional construction workers would be available to serve the Project's construction P:12024\20241723 SanAntonia Driveway Expansion\PRODUCTS\CECIMPublit ReviewOraft\5an Antonio Water Headquarters ISMND_4A.DR,25.decx(08102125) 4-63
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needs.Therefore,construction of the Project would not directly or indirectly induce population growth by drawing workers from outside the area on a permanent basis.
The Project would not result in direct population growth as the use proposed is not residential and would not contribute to permanent residency on site.Although the Project would result in 5 additional employees at the Project site, it is unlikely that a substantial number of employees would relocate from outside the region to meet the need for employees resulting from implementation of the Project. Furthermore,the Project would be located within a developed area of Upland that is already served by all utilities.The existing regional infrastructure and the established roadway network would be utilized by employees accessing the Project site.The Project would not require the construction of new infrastructure,such as roads or utilities,that would indirectly induce population or growth. Furthermore,after the City's General Plan amendment and zone change,the Project would be consistent with the General Plan land use designation and zoning designation for the site and would not generate growth beyond that anticipated in the General Plan.Therefore,the Project would not directly or indirectly induce population growth, and this impact would be considered less than significant. No mitigation is required. b. Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?(No Impact) The Project includes the construction of a new 3,698-square-foot SAWCo headquarters and associated improvements including a 4,066-square-foot maintenance building, maintenance yard, driveway, parking, solar cover, landscaping,and utility improvements. Under existing conditions,the Project site does not contain any residential uses and construction of the Project would not displace existing residents within the nearby residential areas.Therefore,the Project would not result in the displacement of people or housing and would not require the construction of replacement housing elsewhere, and there would be no impact.
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4.15 PUBLIC SERVICES
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
impact Incorporated Impact Impact
Would the project:
a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities,need for new or physically altered governmental facilities,the construction of which could cause significant environmental impacts,in order to maintain acceptable
service ratios,response times or other performance
objectives for any of the public services:
i. Fire protection?
ii. Police protection? 111 El
iii. Schools?
iv. Parks?
v. Other public facilities? [] ® ❑
a. Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
i. Fire protection?(Less Than Significant Impact)
The San Bernardino County Fire Protection District(SBCFPD)provides fire protection and emergency medical response services throughout the City. SBCFPD's service area includes over 2 million residents within a 278 square mile region through 50 fire stations with 1,166 employees.65 There are five fire stations in Upland,with the closest fire station to the Project site being Fire Station 164 located at 1825 North Campus Avenue,approximately 0.35 mile south of the Project site.
The Project includes the construction of a new 3,698-square-foot SAWCo headquarters and associated improvements including a 4,066-square-foot maintenance building, maintenance yard, driveway, parking,solar cover, landscaping,and utility improvements.The Project could result in an incremental increase in demand for fire protection service due to the increase in daytime population at the Project site as a result of additional employees at the Project site. However,the Project would be required to comply with all applicable codes for fire safety and emergency access and the Project Applicant would be required to submit plans to SBCFPD for review and approval prior to the issuance of building permits to ensure the Project would conform to applicable building and fire codes.Additionally,the Project Applicant would be required to pay a fire development impact fee 65 San Bernardino County Fire Protection District.2024.San Bernardino County Fire Statistics,Fiscal Year 2022-23.Website: https://sbcfire.org/statisticsl#statistics-total-anchor(accessed July 10,2024).
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which would be directed towards maintaining adequate service levels,ensuring that any impact to fire protection services that could result from the Project would be offset by development fees.
The SBCFPD would continue providing services to the Project site and would not require additional firefighters to serve the Project.The construction of a new or expanded fire station would not be required.The Project would not result in a significant impact on the physical environment due to the incremental increase in demand for fire protection and life safety services.The incremental increase in demand for services is not expected to adversely affect existing response times to the site or within the City.Therefore, construction and operation of the Project would have a less than significant impact on fire protection and safety services and facilities. ii. Police protection?(Less Than Significant impact)
The Upland Police Department(UPD) provides police protection services to the City and Project site.
The UPD headquarters are located at 1499 West 13th Street,approximately 2.4 miles southwest of the Project site. UPD's service area includes approximately 79,000 residents within a 15.3-square- mile region. UPD includes an Operations Division,Administrative Division,Special Services and Events Division, and Traffic Division.The UPD is currently meeting its target response time of 5 minutes for Priority 1 calls which consist of in-progress emergencies where there is an immediate threat to life or an immediate need for assistance.66
The Project includes the construction of a new 3,698-square-foot SAWCo headquarters and associated improvements including a 4,066-square-foot maintenance building, maintenance yard, driveway, parking, solar cover, landscaping, and utility improvements.The Project could result in an incremental increase in demand for police protection service due to the increase in daytime population at the Project site as a result of additional employees at the Project site. However,the Project would be required to implement Crime Prevention Through Environmental Design principles, and the Project Applicant would be required to pay a police development impact fee that would be directed towards maintaining adequate service levels,ensuring that any impact to police protection services that could result from the Project would be offset by development fees.
The UPD would continue providing services to the Project site and would not require additional police officers to serve the Project.The construction of a new or expanded police station would not be required.The Project would not result in a significant impact on the physical environment due to the incremental increase in demand for police protection services.The incremental increase in demand for services is not expected to adversely affect existing responses times to the site or within the City.Therefore, construction and operation of the Project would have a less than significant impact on police protection services and facilities.
GE City of Upland.2015a.Final Program Environmental impact Report General Plan Update(GPU 08-03), Zoning Code Update(ZCU 08-03), Climate Action Plan,and Cable Airport Land Use Compatibility Plan Update SCH No.2012041006).September 28.
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iii. Schools?(Less Than Significant Impact)
The Upland Unified School District(UUSD),which provides kindergarten through high school education,serves the educational needs in the City of Upland.The UUSD had a 2022-2023 enrollment of 10,079 students and includes 9 elementary schools, 1 TK-8th school, 2 middle schools, and 2 high schools.'
The Project does not include any residential uses,and therefore would not directly affect student population. It is anticipated that approximately 10 people would be employed on the Project site, an increase of 5 people compared to the 5 people that are currently employed on the Project site under existing conditions.A fraction of new employees hired as a result of implementation of the Project may move to the City. However,this growth would be minimal and result in an incremental increase in student population and would be spread amongst the whole school district,depending upon place of residence.Therefore,the Project would not result in a substantial increase in the number of school-age children in the area,and this impact would be less than significant. iv. Parks?(Less Than Significant Impact)
The Project does not include any residential uses and would not generate a direct need for additional park space. Park uses associated with the Project would be minimal and may include local park visits from Project employees during work shifts or on breaks.As noted above,a fraction of employees of the Project may move to the City. However,this growth would only result in an incremental increase in demand for parks,and would be spread throughout the City,depending on place of residence.Therefore,the Project would have a less than significant impact related to parks. v. Other public facilities?(Less Than Significant Impact) Development of the Project would not increase demand for other public service including libraries, community centers,and public health care facilities.As previously discussed,the Project does not include development of residential uses and would therefore not result in an increased demand for public facilities,and this impact would be less than significant. 67 National Center for Education Statistics.2024.Search for Public School Districts;District Name:Upland Unified.Website: https://nces.ed.gov/ccdidistrictsearchidistrict_detail.asp?Search=2&ID2=0600016& DistrictlD=0600016&details=1(accessed July 10,2024).
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4.16 RECREATION
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
Impact Incorporated Impact Impact
a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that ❑ ❑ ® ❑ substantial physical deterioration of the facility would occur or be accelerated?
b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which ❑ ❑ ❑ might have an adverse physical effect on the environment? a. Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?(Less Than Significant impact)
The Project includes the construction of a new 3,698-square-foot SAWCo headquarters and associated improvements including a 4,066-square-foot maintenance building, maintenance yard, driveway, parking, solar cover, landscaping, and utility improvements.The Project would not involve the addition of any housing units that would permanently increase the City of Upland's population.
Although the 10 employees associated with the Project could elect to utilize the City's park facilities during lunch breaks or after-work hours, it is unlikely that the use of parks by Project employees would increase the use of those parks to a level that would contribute to substantial physical deterioration of those facilities. Therefore, development of the Project would not create a significant increase in the use of existing neighborhood, regional parks, or other recreational facilities. Impacts would be less than significant,and mitigation is not required. b. Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?(No Impact)
The Project includes the construction of a new 3,698-square-foot SAWCo headquarters and associated improvements including a 4,056-square-foot maintenance building, maintenance yard, driveway, parking,solar cover, landscaping,and utility improvements.The Project does not include recreational facilities as part of its design, nor does it include the expansion of existing recreational facilities.Although the 10 employees associated with the Project site may use nearby recreational facilities,construction of the proposed SAWCo headquarters and associated improvements would not result in a substantial increase in the use of parks or other recreational facilities,and the Project would not require the construction or expansion of existing recreational facilities.There would be no impact, and mitigation is not required.
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4.17 TRANSPORTATION
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
impact Incorporated Impact Impact
Would the project:
a) Conflict with a program,plan,ordinance or policy addressing the circulation system,including transit,roadway,bicycle ❑ ❑ ® ❑ and pedestrian facilities?
b) Conflict or be inconsistent with CECW Guidelines§15064.3, ❑ ❑ subdivision(b)?
c) Substantially increase hazards due to a geometric design feature(e.g.,sharp curves or dangerous intersections)or ❑ ❑ ® ❑ incompatible uses(e.g.,farm equipment)?
d) Result in inadequate emergency access? ❑ ❑ ® ❑ The following discussion and analyses are based on the findings included in the Traffic Impact Analysis(TIA)ss completed for the Project,which is included as Appendix G to this IS/MND. a. Would the project conflict with a program plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities?(Less Than Significant impact)
The following includes an evaluation of the Project's potential to conflict with applicable programs, plans,ordinances, and policies addressing the circulation system, including the City of Upland's Traffic Impact Analysis(TIA) Guidelines69(TIA Guidelines)and the Circulation Chapter of the City's General Plan.
Based on the City's TIA Guidelines,at a minimum,the study area must include all freeway links with 100 or more two-way peak-hour project trips and other Congestion Management Plan (CMP) roadways with 50 or more two-way peak-hour project trips within 5 miles of the Project site.The Project is not anticipated to add 100 or more two-way peak-hour trips to any freeway segment.
Therefore, no freeway links were analyzed as part of this analysis.The analysis intersections were approved by the City as part of the scoping process and include the following:
1. Winston Court-Project Driveway/20th Street;
2. Campus Avenue/Project Driveway 3-20t"Street.
Trip Generation.The trip generation for the Project was developed using rates from the Institute of Transportation Engineers' (lTE) Trip Generation Manual(11th Edition)for Land Use 712—"Small Office Building".As further detailed in the TIA,the Project is estimated to generate 91 total net daily passenger car equivalent(PCE)trips,with 25 net PCE trips occurring during the a.m. peak hour and 27 net PCE trips occurring during the p.m. peak hour.
es LSA.2024b.Traffic Impact Analysis San Antonio Water Headquarters Project.November. 69 Fehr and Peers.2020.City of Upland Traffic Impact Analysis Guidelines.July.
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Level of Service and Queuing Analysis.The City uses Level of Service (LOS) D as its minimum level of service criterion for all intersections.As detailed in the TIA,all study intersections are forecast to operate at a satisfactory LOS under all scenarios analyzed including opening year(2027) both with and without the Project and horizon year(2050) both with and without the Project.Therefore,the Project is not forecast to cause any LOS or queuing deficiencies at the study intersections and implementation of the Project would not conflict with plans, programs,and policies regarding roadway facilities or decrease the performance of such facilities.
Transit,Roadway,Bicycle,and Pedestrian Facilities.According to the City's TIA Guidelines,a significant impact occurs when a project conflicts with adopted plans, policies,or programs regarding active transportation or public transit facilities, or otherwise decreases the performance or safety of such facilities.
Based on the City's Bikeway Network, Class III bike routes exist on both directions of Campus Avenue north of SR-210 within the Project vicinity.The Project would not modify the existing bike routes along Campus Avenue.As such,the Project would not decrease the performance or safety of any existing or proposed bicycle facility.
According to the City's General Plan,the Project area on Campus Avenue has been identified as an area that needs sidewalks.The Project would not modify any existing sidewalks.As such,the Project would not decrease the performance or safety of any existing or proposed pedestrian facility.
Omnitrans provides both local and regional transit services throughout the region,with 30 fixed routes and 5 OmniGo routes using 178 vehicles.There are no Omnitrans bus routes that operate within the Project vicinity.The Project would not modify or affect any public transit access within the study area.
Therefore, implementation of the Project would not conflict with plans, programs,and policies regarding transit, bicycle,or pedestrian facilities or decrease the performance of such facilities.
Overall,the Project would not conflict with a program plan,ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. Impacts would be less than significant,and no mitigation is required.
b. Would the project conflict or be inconsistent with CEQA Guidelines§15054.3,subdivision (b)? (Less Than Significant impact)
On December 28,2018,the California Office of Administrative Law cleared the revised State CEQA Guidelines for use.Among the changes to the guidelines was the removal of vehicle delay and LOS as the sole basis of determining CEQA impacts.With the implementation of the adopted guidelines, transportation impacts are to be evaluated based on a project's effect on vehicle miles traveled (VMT).The City's TIA Guidelines include screening criteria,VMT analysis methodology,VMT impact thresholds,and VMT mitigation measures for projects within the City of Upland. 4-70 P:\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\CEQA\Public Review Oraft45an Antonio Water Headquarters ISMNO_48.'s25.docx maws)
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The City's TIA Guidelines establish a presumption of less than significant VMT impacts related to qualifying land use projects.A project only needs to meet one of three screening criteria to"screen out" of a detailed VMT analysis:
1) Transit Priority Area(TPA)Screening: Based on the City's TIA Guidelines, projects located within a TPA may be presumed to have a less than significant impact absent substantial evidence to the contrary.
2) Low-VMT-Area Screening: Based on the City's TIA Guidelines, residential and office projects located within a low-VMT-generating area may be presumed to have a less than significant impact absent substantial evidence to the contrary.
3) Project Type Screening:The TIA Guidelines recommend that project land uses and development intensities can be presumed to have a less than significant impact absent substantial evidence to the contrary for various local serving projects, including projects that generate less than 250 daily vehicle trips.
The Project site is not located within a TPA, and therefore does not meet the TPA Screening Criteria.
The Project is not a residential or office project,and therefore does not meet the Low-VMT-Area Screening Criteria.As discussed under Threshold 4.17.a above,the Project is anticipated to generate 91 daily trips,which is below the City's daily trip threshold of 250 daily trips.Therefore, based on the City's TIA Guidelines,the Project can be screened out from a detailed VMT analysis and is anticipated to have a less than significant VMT impact.Therefore,the Project would not conflict or be inconsistent with State CEQA Guidelines Section 15064.3, subdivision (b). Impacts would be less than significant,and no mitigation is required.
c. Would the project substantially increase hazards due to a geometric design feature(e.g., sharp curves or dangerous intersections)or incompatible uses(e.g.,farm equipment)?(Less Than Significant impact)
The design of the Project does not include any geometric design features or incompatible uses that could substantially increase circulation/traffic hazards.The Project would result in the construction of a new 3,698-square-foot SAWCo headquarters and associated improvements including a 4,066- square-foot maintenance building, maintenance yard, driveway, parking,solar cover, landscaping, and utility improvements. Vehicular access to the Project site would be provided via two paved driveways with gates for security.Two new driveways would be located along the northern and eastern property boundaries.One new 26-foot-wide driveway would be constructed off of East 20th Street along the northern property boundary that would access the visitor and customer parking area.An additional 26-foot-wide driveway would enter the Project site at the northeastern corner and would connect to the intersection of Campus Avenue and East 20th Street approximately 275 feet east of the Project site.This driveway would enter the Project site at the northeastern corner and run south along the eastern property line to access the covered employee parking area, maintenance building, and covered truck parking area.This driveway would serve as a SAWCo maintenance vehicle private access road and would be secured by a 20-foot-wide,6-foot-tall steel gate located just west of the Campus Avenue and East 20th Street intersection that would be open during business hours.The types of traffic generated during operation of the Project(i.e., passenger P:12024\2O241723Son Antonia Driveway Expansion\PRODUCTS\CEOA Publit Review❑raft\5an Antonio Water Headquarters ISMND_4A.D8.25.decx(CRIU2/25) 4-71
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cars and trucks)would be compatible with the type of traffic observed along study area roadways under existing conditions.
As detailed in the TIA,a sight distance analysis for stopping and corner sight distance was conducted at the Project driveways along 20th Street and Campus Avenue to evaluate safe access in and out of the Project site.Sight distance is the length of the visible roadway a driver can see approaching vehicles before their line of sight is blocked by any object.As detailed in the TIA, all driveways would provide adequate sight distance for left-turn maneuvers.
The Project would be required to design,construct, and maintain structures, roadways,and facilities in accordance with applicable standards governing vehicular access. Impacts would be less than significant, and no mitigation is required.
d. Would the project result in inadequate emergency access?(Less Than Significant impact) Construction. During short-term construction activities,the Project would not require temporary lane or road closures and therefore would not cause any substantial traffic queuing along 20th Street or Campus Avenue.Therefore, construction of the Project would not physically impair or otherwise interfere with emergency access in the Project vicinity. Impacts related to emergency access in the Project vicinity during Project construction would be less than significant,and no mitigation is required.
Operation.As previously discussed,access to the Project site would be provided via two driveways located along the northern and eastern property boundaries.Two new driveways would be located along the northern and eastern property boundaries.One new 26-foot-wide driveway would be constructed off of East 20th Street along the northern property boundary that would access the visitor and customer parking area.An additional 26-foot-wide driveway would enter the Project site at the northeastern corner and would connect to the intersection of Campus Avenue and East 20th Street approximately 275 feet east of the Project site.The Project would not modify the existing roadway network such that it would result in a change in the access for emergency vehicles adjacent to the Project site. In accordance with the California Fire Code,the Project Applicant is required to design,construct, and maintain structures, roadways,and facilities to maintain appropriate emergency/evacuation access to and from the Project site.All site access points and driveway aprons would be designed and constructed to adequate widths for public safety pursuant to the San Bernardino County Fire Protection District(SBCFPD).Site design and compliance with standard and emergency SBCFPD and City requirements,such as the size and location of fire access routes and fire truck turning radii,would allow for proper site evacuation, if necessary,during Project operations.
Therefore,the Project would not result in inadequate emergency access during Project operation.
Impacts would be less than significant,and no mitigation is required. 4-72 P:\2O24\20241723_San Antonio Driveway Eva nsion\PRODUCTS\CEQA\Public Review Draft45an Antonio Water Headquarters ISMND_08.0825.docx(02/08I25)
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4.18 TRIBAL CULTURAL RESOURCES
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
impact Incorporated Impact Impact
Would the project:
a) Cause a substantial adverse change in the significance of a tribal cultural resource,defined in Public Resources Code Section 21074 as either a site,feature,place,cultural
landscape that is geographically defined in terms of the size and scope of the landscape,sacred place,or object with
cultural value to a California Native American tribe,and that is:
i. Listed or eligible for listing in the California Register of Historical Resources,or in a local register of historical 0 El
resources as defined in Public Resources Code Section
5020.1(k)?Or
ii. A resource determined by the lead agency,in its
discretion and supported by substantial evidence,to be
significant pursuant to criteria set forth in subdivision (c)of Public Resources Code Section 5024.1?In applying
the criteria set forth in subdivision(c)of Public
Resource Code Section 5024.1,the lead agency shall
consider the significance of the resource to a California Native American tribe.
a. Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code Section 21074 as either a site,feature, place,cultural landscape that is geographically defined in terms of the size and scope of the landscape,sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k)?(Less than Significant with Mitigation Incorporated)
As detailed in Section 4.5,Cultural Resources,the following tasks were completed to identify potential historical resources on the Project site: (1)a records search was conducted at the South Central Coastal Information Center(SCCIC) at California State University, Fullerton and the Sacred Lands File(SLF)from the Native American Heritage Commission (NAHC) (2)archival research; and (3) field surveys were conducted on the site on July 8,2024,and August 6,2024.
The only historic-period (50 years of age or older) resource that was identified in the Project site is a mostly subterranean, concrete water reservoir that was built in 1930 as part of the irrigation system for nearby citrus groves.The reservoir was evaluated for historical significance using the criteria for listing in the California Register of Historical Resources and designation as a City Cultural Resource and it did not meet any of the State or local criteria and therefore is not considered a historical resource pursuant to Section 15064.5 of the State CEQ4 Guidelines. No archaeological resources are documented within a 0.5 mile of the Project site, and none were identified during the archaeological P:12024\20241723 SanAntonia Driveway Expansion\PRODUCTS\CECIMPublit ReviewOraft\5an Antonio Water Headquarters ISMND_48.D8.25.decx(08102125) 4-73
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survey. Despite the lack of surface visibility,the parcel has been severely disturbed and the sensitivity for subsurface resources is low.
Native American consultation was conducted by the City in compliance with AB 52 and SB18. As part of the consultation process,a review of the SLF by the NAHC indicated that the results of the file search were positive and NAHC identified methodologies and contacts for conducting the required AB 52 and SB 18 tribal consultation.The NAHC recommended that 25 Native American individuals representing the Agua Caliente,Cahuila,Gabrieleno,Gabrielino Tongva, Morongo,Quechan,San Manuel,Santa Rosa,Serrano, and Soboba groups be contacted for information regarding cultural resources that could be affected by the Project.The City provided notice of the Project via certified mail on March 5,2025,to Native American tribal contacts provided by the NAHC as well as local Native American tribal representatives that previously requested to be notified of future projects proposed by the City in compliance with AB 52 and 5618.7°The City received two letter responses one from the Yuhaaviatam of San Manuel Nation (San Manuel Nation) and one from the Gabrieleno Band of Mission Indians—Kizh Nation (Kizh Nation).
The City completed the tribal consultation process with both the Kizh Nation and the San Manuel Nation in accordance with Assembly Bill (AB) 52 and Senate Bill (SB) 18.As a result of this consultation and based on previously established measures by the City, Mitigation Measures(MM) TCR-1 through TCR-S were developed to minimize potential impacts related to the unanticipated discovery of tribal cultural resources. No specific information regarding known tribal cultural resources on the Project site was provided to the City during the consultation process.
Tribal responses included MM's to address unanticipated tribal resources finds. MM TCR-1, MM TCR-2,MM TCR-3, MM TCR-4,and MM TCR-5 were developed based on the tribal consultation process and previously agreed upon measures developed by the City to minimize potential impacts related to the unanticipated discovery of tribal cultural resources. MM TCR-1 requires Native American tribal monitoring of ground-disturbing activities,if requested. MM TCR-2,MM TCR-3,and MM TCR-4 outline the procedures to be followed if unanticipated tribal cultural resources are discovered during ground disturbing activities. In the event that human remains or funerary/ceremonial objects are encountered, during construction, MM TCR-5 requires compliance with PRC 5097 and the State's Health and Safety Code Section 7050.5 for the proper treatment and handling of such remains or objects.
TCR-1 Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities.
A. The City shall contact interested tribes to determine if a Native American Monitor is requested prior to the commencement of any"ground-disturbing activity"for the subject Project at all Project locations(i.e., both on-site and any off-site locations that are included in the Project description/definition and/or required in connection with the Project,such as public improvement work). 70 Winter,Joshua,City of Upland.2025.Senate Bill 18 Consultation Letters for San Antonio Water Company Headquarters Project(GPA-24-0004)and Assembly Bill 52 Consultation Letters for the San Antonio Water Company Headquarters Project.March 5.
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"Ground-disturbing activity"shall include, but is not limited to,demolition, pavement removal, potholing,auguring,grubbing,tree removal, boring, grading,excavation,drilling, and trenching.
B. A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.
C. If monitoring is required,the monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities,the type of construction activities performed, locations of ground-disturbing activities,soil types,cultural-related materials, and any other facts,conditions, materials, or discoveries of significance to the Tribe. Monitor logs will identify and describe any discovered TCRs, including but not limited to, Native American cultural and historical artifacts, remains, places of significance,etc., (collectively,tribal cultural resources,or"TCR"),as well as any discovered Native American (ancestral)human remains and burial goods.Copies of monitor logs will be provided to the Project applicant/lead agency upon written request to the Tribe.
D. On-site tribal monitoring shall conclude upon the latter of the following(1) written confirmation to the tribal representative from a designated point of contact for the Project applicant/lead agency that all ground-disturbing activities and phases that may involve ground-disturbing activities on the Project site or in connection with the Project are complete;or(2)a determination and written notification by the tribal representative to the Project applicant/lead agency that no future, planned construction activity and/or development/construction phase at the Project site possesses the potential to impact TCRs.
TCR-2 Unanticipated Discovery of Tribal Cultural Resource Objects(Non-Funeral/Non- Ceremonial).
The San Manuel Nation Cultural Resources Department shall be contacted of any pre-contact and/or historic-era cultural resources discovered during project implementation and be provided information regarding the nature of the find so as to provide tribal input with regards to significance and treatment. In the event the material is determined to be significant, Mitigation Measure TCR-4 shall apply.
TCR-3 Unanticipated Discovery of Tribal Cultural Resource Objects(Non-Funeral/Non- Ceremonial). Upon discovery of any TCRs, all construction activities in the immediate vicinity of the discovery shall cease (i.e., not less than the surrounding 50 feet)and shall not resume until the discovered TCR has been fully assessed by the Kizh monitor and/or Kizh archaeologist. In the event the material is determined to be significant, Mitigation Measure TCR-4 shall apply.
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TCR-4 Monitoring and Treatment Plan. In the event of any inadvertent discovery of any tribal cultural material, or pre-contact/historic-era resource determined to be significant,the City shall require the preparation of a Monitoring and Treatment Plan.The monitoring and treatment plan shall be prepared by a qualified archeologist in consultation with and subject to the approval of the City and the consulting Native American tribes.The City and consulting Native American tribes shall engage in mutual good faith efforts to develop the Monitoring and Treatment Plan.The monitoring and treatment plan shall identify the manner and process in which any suspected tribal cultural material is evaluated, recorded, removed,or curated, including the final disposition of any such material.
If the manner and process of evaluation, recording, removing,and/or disposing of tribal cultural material cannot be resolved between consulting Native American parties,the City shall, in good faith, determine and approve the appropriate actions to be included in the Monitoring and Treatment Plan.
TCR-5 Unanticipated Discovery of Human Remains and Associated Funerary or Ceremonial Objects.
A. Native American human remains are defined in PRC 5097.98(d)(1)as an inhumation or cremation, and in any state of decomposition or skeletal completeness. Funerary objects,called associated grave goods in Public Resources Code Section 5097.98, are also to be treated according to this statute.
B. If Native American human remains and/or grave goods are discovered or recognized on the Project site,then Public Resource Code 5097.9 as well as Health and Safety Code Section 7050.5 shall be followed.
C. Human remains and grave/burial goods shall be treated alike per California Public Resources Code section 5097.98(d)(1)and (2).
D. Preservation in place(i.e., avoidance) is the preferred manner of treatment for discovered human remains and/or burial goods.
E. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
Based on the findings of the Cultural Resources Assessment completed for the Project and AB 52/SB 18 consultation, no known tribal cultural resources listed or eligible for listing in the California Register of Historical Resources(California Register)or in a local register exist within the Project site, and there are no known tribal cultural resources on the Project site.Therefore,the Project would not cause a substantial adverse change in the significance of a tribal cultural resource defined as a site,feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape,sacred place,or object with cultural value to a California Native American Tribe, and that is listed or eligible for listing in the California Register or in a local register of historical 4-76 P:\2024420241723_San Antonio Driveway Expansion\PRODUCTS\CEQA\Public Review Draft\5an Antonio Water Headquarters ISMNO_48.'s25.docx maws) w2s)
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resources as defined in PRC Section 5020.1(k). Nevertheless, implementation of MM TCR-1,MM TCR-2, MM TCR-3,MM TCR-4,and MM TCR-5,are required to address the potential impacts to unanticipated tribal cultural resources, human remains,and associated funerary or ceremonial objects,the implementation of which would reduce impacts to less than significant with mitigation incorporated.
ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision(c)of Public Resources Code Section 5024.1?In applying the criteria set forth in subdivision(c)of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe. (Less than Significant with Mitigation Incorporated) As noted above,a cultural resources record search,an SLF search through the NAHC,and AB 52 and SB18 Native American consultation were conducted for the Project.The purpose of these efforts was to identify known tribal cultural resources on or near the Project site. No on-site cultural resources were identified as part of the records search.The City conducted tribal consultation with the and San Manuel Nation and the Kizh Nation and MM TCR.-1, MM TCR-2, MM TCR-3,MM TCR-4, and MM TCR-5 were developed based on the tribal consultation process and previously agreed upon measures developed by the City to minimize potential impacts related to the discovery of unanticipated tribal cultural resources, human remains,and associated funerary or ceremonial objects.
Archaeological pedestrian field surveys of the Project site were conducted on July 8,2024,and August 6,2024,as part of the Cultural Resources Assessment completed for the Project.No cultural resources, including tribal cultural resources, were discovered within the Project site during the field survey.
Furthermore, the parcel has been severely disturbed and the sensitivity for subsurface resources is low. Therefore, encountering unknown buried cultural resources, including tribal cultural resources, during Project construction is unlikely.However,in the unlikely event that unanticipated tribal cultural resources are discovered during construction of the Project, MM TCR-2, MM TCR-3, and MM TCR-4 would be implemented, which require adherence to procedures for the treatment of unanticipated tribal cultural resources if discovered during construction. With implementation of MM TCR-2, MM TCR-3, and MM TCR-4 potential impacts to previously unanticipated tribal cultural resources would be less than significant.
No human remains are documented/known to be on the Project site. Furthermore, the parcel has been severely disturbed and the sensitivity for subsurface resources is low.Therefore,the likelihood of discovering unknown human remains during construction of the Project is extremely low. However, in the unlikely event that human remains or funerary/ceremonial objects are discovered during construction of the Project and are of Native American origin,the Construction Contractor would be required to implement MM TCR-5, which requires compliance with PRC 5097 and the State's Health and Safety Code Section 7050.5 for the treatment of human remains or funerary/ceremonial objects.
If human remains are Native American in origin, the remains may be considered a tribal cultural resource.
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At the completion of Project construction,the Project would not result in further disturbance of native soils on the Project site and, therefore, Project operations would have no potential to impact previously undiscovered tribal cultural resources or human remains.
With implementation of MM TCR-1, MM TCR-2, MM TCR-3, MM TCR-4, and MM TCR-5,the Project would not cause a substantial adverse change in the significance of a tribal cultural resource defined as a site,feature,place,cultural landscape that is geographically defined in terms of the size and scope of the landscape,sacred place,or object with cultural value to a California Native American tribe that is determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1.
Impacts would be less than significant with mitigation incorporated. 4-78 P:\2O24\2O241723_San Antonio Driveway Expansion\PRODUCTS\CEQA\Public Review Oraft\5an Antonio Water Headquarters ISMND_48.D825.docx(OS/25)
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4.19 UTILITIES AND SERVICE SYSTEMS
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
impact Incorporated Impact Impact
Would the project:
a) Require or result in the relocation or construction of new or expanded water,wastewater treatment or stormwater
drainage,electric power,natural gas,or telecommunications ❑ ❑ ® ❑ facilities,the construction or relocation of which could cause significant environmental effects?
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during ❑ ❑ ® ❑ normal,dry and multiple dry years?
c) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has ❑ ❑ ® ❑ adequate capacity to serve the project's projected demand in addition to the provider's existing commitments?
d) Generate solid waste in excess of State or local standards,or in excess of the capacity of local infrastructure,or otherwise ❑ ❑ ® ❑ impair the attainment of solid waste reduction goals?
e) Comply with federal,state,and local management and ❑ ❑ ® ❑ reduction statutes and regulations related to solid waste? a. Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage,electric power,natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?(Less Than Significant impact)
The City of Upland owns and operates the local sewer lines within the City, and wastewater treatment is provided at reclamation facilities primarily owned and maintained by the Inland Empire Utilities Agency(IEUA). Except for areas within the southwestern-most portion of the City,the Upland community sewer system is a gravity-flow system,and therefore there are no public wastewater lift stations in the City. There are approximately 270 miles of wastewater conduits within the City of Upland. The major trunk lines,varying in size from 12 inches to 21 inches, are predominantly situated along the southern parts of the City. Laterals,generally 8-inch to 10-inch diameter,compose the remainder of the system.71 The Project would include new on-site sanitary sewer lines that would be constructed and connected to existing nearby sanitary sewer main lines in conformance with City standards,and the Project's construction would not cause significant environmental effects.
The City of Upland owns and operates its own water distribution system and provides water service to almost all of the residential,commercial, and industrial users within the incorporated City limits, including the Project site.The City serves potable water to a population of 78,383 people through 71 City of Upland.2015a.Final Program Environmental impact Report General Plan Update(GPU 08-03), Zoning Code Update(ZCU 08-03), Climate Action Plan,and Cable Airport Land Use Compatibility Plan Update SCH No.2012041006).September 28.
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19,487 connections.The City's water supplies include imported water from Metropolitan Water District of Southern California(MWD) purchased through IEUA,groundwater pumped from City owned wells and West End Consolidated Water Company(WECWC),groundwater purchased from SAWCo,surface water purchased from SAWCo and treated by the City,and recycled water purchased from IEUA.The City updated its Urban Water Management Plan (UWMP) in 2020 and adopted the UWMP in 2021.72 According to the UWMP,the annual water use in 2020 was 18,431 acre-feet.As discussed in Section 4.19.b,the Project would not substantially increase demand for water and would therefore not exceed the capacity of existing water treatment facilities.The Project would not require the construction of new water treatment facilities, or the expansion of existing facilities,other than those already planned.The Project would include new on-site water lines that would be constructed and connected to existing nearby water main lines in conformance with City standards,which have sufficient capacity to accommodate the Project.Therefore,the impact of the Project on water infrastructure would be less than significant.
The proposed storm drainage infrastructure would include new stormwater drains and catch basins that would be installed throughout the site,connecting to an infiltration basin and an underground storage infiltration system that would be used for stormwater control,treatment, and infiltration.
On-site drainage would be designed in compliance with the requirements of the MS4 Permit as detailed in Section 4.10, Hydrology and Water Quality.Therefore,the impact of the Project on stormwater infrastructure would be less than significant.
Electrical power is provided to the Project site and surrounding area by the Southern California Edison company.The Project would connect to existing overhead electricity lines along East 20th Street.There would be no changes to the existing telecommunications facilities.
The City does not allow the use of natural gas;therefore, natural gas is not proposed as part of the Project.
Therefore, because the Project would connect to existing utility services within or adjacent to the Project site and there is sufficient excess capacity within those systems to accommodate Project demands,the relocation or reconstruction of new or expanded water,wastewater treatment or stormwater drainage, electric power,or telecommunications facilities would not be required,and this impact would be less than significant.
b. Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?(Less Than Significant impact)
As noted above,the City provides water service to the Project site.As previously discussed,the City's potable water supply is sourced from imported water from MWD purchased through IEUA, groundwater pumped from City wells and WEWC,and groundwater and surface water purchased from SAWCo.The City's 2020 UWMP describes the existing and planned sources of water available 72 City of Upland.2021.City of Upland 2020 Urban Water Management Plan and Water Shortage Contingency Plan.June.
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in the water system service area over the next 20 years, in 5-year increments.The 2020 UWMP indicates the City has sufficient water supplies to meet water demands through 2045, including during multiple dry years.The UWMP,which identifies water system improvements necessary to meet future water demand,did not identify any deficiencies in the vicinity of the Project site.The existing water system infrastructure has adequate capacity to serve the Project and the anticipated water use of the Project would not be significantly higher than the water demand of the Project site under existing conditions. In addition,the Project would be required to coordinate with the San Bernardino County Fire Protection District(SBCFPD)to assess fire flow requirements and comply with them as part of the Project. Based on the above,the City would have sufficient water supply to support the Project during normal, dry,and multiple dry years,and implementation of the Project would not require new or expanded entitlements for water supplies, and impacts related to water supply would be less than significant.
c. Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments?(Less Than Significant Impact) As discussed above,wastewater treatment is provided at reclamation facilities primarily owned and maintained by the IEUA.Wastewater from the Project site would be treated at the IEUA Regional Water Reclamation Facility 1(RP-1). RP-1 is located in the City of Ontario and was originally commissioned in 1948.The plant has undergone several expansions to increase the design wastewater treatment capacity to the current 44 million gallons per day(mgd).This facility serves the cities of Chino,Ontario, Rancho Cucamonga, Upland, Montclair, Fontana and an unincorporated area of San Bernardino County.The plant treats an average influent wastewater flow of approximately 28 million gallons per day,which is approximately 64 percent of its 44 mgd capacity.73
Sinks and toilets that would serve the employees at the Project site would generate domestic wastewater, which would be treated by IEUA's RP-1. However, considering the treatment plant only treats an average of approximately 64 percent of its capacity on a daily basis, it would be able to adequately accommodate wastewater generated by the Project.Therefore,wastewater generated from the Project would not cause the IEUA to violate any wastewater treatment requirements, and this impact would be less than significant.
d. Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?(Less Than Significant Impact)
Burrtec Waste Industries, Inc. provides solid waste collection to the City of Upland for residential, commercial and industrial waste services, recycling services,and composting.Solid waste from the City is transferred to the West Valley Transfer Station/Material Recovery Facility in Fontana before being distributed to various landfills within San Bernardino County.The majority of waste from Upland is disposed of at the Mid-Valley Sanitary Landfill, Badlands Sanitary Landfill,and El Sobrante 73 IEUA.2024.Regional Water Recycling Plant No. 1.Website:https:il www.ieua.org/regional-water- recycling-plant-n❑-1/(accessed July 10,2024).
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Landfill.74 The Mid-Valley Sanitary Landfill has a maximum permitted daily disposal rate of 7,500 tons of solid waste,a remaining capacity of 54,219,377 cubic yards,and an anticipated closure date of 2045.75 The Badlands Sanitary Landfill has a maximum permitted daily disposal rate of 5,000 tons of solid waste,a remaining capacity of 7,800,000 cubic yards, and an anticipated closure date of 2059.76 The El Sobrante Landfill has a maximum permitted daily disposal rate of 16,054 tons of solid waste,a remaining capacity of 209,910,000 cubic yards, and an anticipated closure date of 2051.77 Based on a generation rate of 1.24 pounds per employee per day,'$the Project would generate approximately 12.4 pounds of solid waste per day.As noted above,the Mid-Valley Sanitary Landfill, Badlands Sanitary Landfill,and El Sobrante Landfill have adequate capacity to serve the Project.As such,the Project would be served by a landfill with sufficient capacity to accommodate the Projects waste disposal needs. Furthermore,the Project would comply local and State west reduction strategies.Therefore, impacts associated with the disposition of solid waste would be less than significant.
e. Would the project comply with federal,state, and local management and reduction statutes and regulations related to solid waste?(Less Than Significant Impact) The Project would comply with all federal,State,and local solid waste statutes and/or regulations related to solid waste and, as noted above,the Mid-Valley Sanitary Landfill, Badlands Sanitary Landfill,and El Sobrante Landfill have adequate capacity to serve the Project.Therefore,the Project would result in a less than significant impact related to solid waste regulations. 74 City of Upland.2015a.Final Program Environmental Impact Report General Plan Update(GPU 08-03), Zoning Code Update(ZCU 08-03), Climate Action Plan,and Cable Airport Land Use Compatibility Plan Update SCH No.2012041006).September 28.
75 California Department of Resources Recycling and Recovery(CalRecycle).2019a.SWIS Facility/Site Activity Details,Mid-Valley Sanitary Landfill(36-AA-0055).Website: https://www2.calrecycle.ca.gov/Solid Waste/SiteActivity/Details/1880?sitelD=2662(accessed July 10,2024). 76 CalRecycle.2019b.SWIS Facility/Site Activity Details, Badlands Sanitary Landfill(33 AA-0006). Website:
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2245?sitelD=2367(accessed July 10, 2024).
" CalRecycle.2019c.SWIS Facility/Site Activity Details,El Sobrante Landfill(33-AA-0217).Website:
https://www2.calrecycle.ca.gov/SalidWaste/SiteActivity/Details/2280?sitelD=2402(accessed July 10, 2024).
78 CalRecycle. n.d. Estimated Solid Waste Generation Rates. Website: https://www2.calrecycle.ca.gov/ wastecharacterization/general/rates(accessed July 10,2024). 4-82 P:1,2024\2O241723_5an Antonio Driveway Expansion\PRODUCTS\CEQA\Public Review Oraft\5an Antonio Water Headquarters ISMNO_48.0s25.docx(08108125)
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4.20 WILDFIRE
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
impact Incorporated Impact Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones,would the project:
a) Substantially impair an adopted emergency response plan or ❑ ❑ ® ❑ emergency evacuation plan?
b) Due to slope,prevailing winds,and other factors,exacerbate wildfire risks,and thereby expose project occupants to ❑ ❑ ® ❑ pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of associated infrastructure(such as roads,fuel breaks,emergency water sources,power lines or other utilities)that may exacerbate ❑ ❑ ® ❑ fire risk or that may result in temporary or ongoing impacts to the environment?
d) Expose people or structures to significant risks,including downsiope or downstream flooding or landslides,as a result ❑ ❑ ® ❑ of runoff,post-fire slope instability,or drainage changes? a. Would the project substantially impair an adopted emergency response plan or emergency evacuation plan?(Less Than Significant Impact)
The Project site is not located within or near a State Responsibility Area (SRA)for fire service and is not located in a Very High Fire Hazard Severity Zone (VHFHSZ).79 An SRA VHFHSZ is located approximately 1.5 miles north the Project site.The Project would be designed to provide adequate access to the site for fire/police/emergency medical service personnel in the event of an emergency at the Project site.The improvements that would occur as part of the Project are site-specific and do not include any public right-of-way improvements to off-site areas(e.g., roadway improvements, intersection improvements).The Project would not reduce the number of traffic lanes on any adjacent streets and would not alter the existing street grid, and;therefore, it would not alter or obstruct emergency evacuation routes or response plan. The Project site would be accessible to emergency vehicles in the event a hazardous event occurs on the site.Overall,the Project does not include any features that would impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan;therefore,this impact would be less than significant.
79 Office of the State Fire Marshal.2024 Fire Hazard Severity Zones.Website: https://osfm.fire.ca.gov/what- we-do/community-wildfire-preparedness-and-mitigation/fire-hazard-severity-zones(accessed April 22, 2025).
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b. Would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?(Less Than Significant Impact) As described above,the Project is not located in a VHFHSZ or in an SRA.Additionally,as noted in Chapter 2.0, Project Description,the Project site is generally level and is primarily surrounded by existing development. Furthermore,the Project would not include any design features that would increase the potential for a wildfire.Therefore,the Project would not exacerbate wildfire risks and thereby expose Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire,and this impact would be less than significant. c. Would the project require the installation or maintenance of associated infrastructure(such as roads,fuel breaks, emergency water sources,power lines or other utilities)that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?(Less Than Significant Impact)
As described above,the Project is not located in a VHFHSZ or in an SRA.The Project includes the construction of a new 3,598-square-foot SAWCo headquarters and associated improvements including a 4,056-square-foot maintenance building, maintenance yard,driveway, parking,solar cover, landscaping,and utility improvements. In the absence of any significant potential for on-site or adjacent wildfire hazard,the Project would not need to incorporate fire protection infrastructure (such as roads,fuel breaks,emergency water sources, power lines,or other non-existing utilities) that may themselves exacerbate fire risk. Installation of all Project-related utility improvements would be implemented in an urbanized setting in accordance with the current California Building Code,California Fire Code,and applicable local ordinances.Therefore, impacts related to the installation or maintenance of infrastructure that may exacerbate fire risk or result in temporary or ongoing impacts would be less than significant.
d. Would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff,post fire slope instability, or drainage changes?(Less Than Significant impact)
Landslides. Landslides and other forms of mass wasting, including mud flows,debris flows, and soil slips,occur as soil moves downslope under the influence of gravity. Landslides are frequently triggered by intense rainfall or seismic shaking but can also occur as a result of erosion and downslope runoff caused by rain following a fire.As previously discussed in Section 4.7.a.iv,the Project site is not located in an area at risk of landslide. Further,as stated previously,the Project site is not located in a VHFHSZ,or in or near an SRA. In the unlikely event that a wildfire should spread to the Project site, it would not expose any on-site slopes to erosion and potential failure because the Project site does not contain any steep slopes that are prone to landslide.The Project would not expose people or structures to significant risks, including downslope landslides, as a result of runoff, post-fire slope instability,or drainage changes.There would be no impact to Project occupants or nearby residents or workers related to post-wildfire landslide risks,and no mitigation would be required.
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Flooding.According to the Federal Emergency Management Agency(FEMA) Flood Insurance Rate Map (FIRM) No.06071C7870J,the Project site is located in Zone X,which is identified as an area of minimal flood hazard.8°In the unlikely event that a wildfire should spread to the Project site, it is not expected that the Project would contribute any additional runoff or sedimentation downstream drainages.This is due to the lack of steep slopes that are prone to landslide or erosion on the Project site and the fact that the Project's drainage improvements would manage the rate and volume on- site runoff and reduce the potential for flooding conditions in downstream storm drain facilities.
Therefore, downslope or downstream flooding as a result of runoff, post-fire slope instability,or drainage changes are unlikely to expose occupants or structures to significant risks. Impacts to Project occupants related to post-wildfire flooding risks would be less than significant, and no mitigation is required.
FEMA.2016.Flood Insurance Rate Map No.06071C7870J. Map Revised September 2,2016.Website:
https://msc.fema.gov/portal/search(accessed July 5,2024).
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4.21 MANDATORY FINDINGS OF SIGNIFICANCE
Less Than
Potentially Significant with Less Than
Significant Mitigation Significant No
Impact Incorporated Impact Impact
Would the project:
a) Have the potential to substantially degrade the quality of the environment,substantially reduce the habitat of a fish or wildlife species,cause a fish or wildlife population to drop below self-sustaining levels,threaten to eliminate a plant or ❑ ® ❑ ❑ animal community,substantially reduce the number or
restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of
California history or prehistory?
b) Have impacts that are individually limited,but cumulatively considerable?("Cumulatively considerable"means that the incremental effects of a project are considerable when ❑ ® ❑ ❑ viewed in connection with the effects of past projects,the effects of other current projects,and the effects of probable future projects.)
c} Have environmental effects which will cause substantial adverse effects on human beings,either directly or ❑ ® ❑ ❑ indirectly?
a. Would the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?(Less Than Significant with Mitigation incorporated)
The Project site does not contain suitable habitat for any federal or State-listed plant,animal,or aquatic species.Additionally,the Project site does not contain any sensitive habitats, including any United States Fish and Wildlife Service(USFWS)designated Critical Habitat for any federally-listed species,or California Department of Fish and Wildlife(CDFW)special-status natural communities.
However,burrowing owls,a non-listed State species of special concern, have a low to moderate probability of occurrence within the Project site.To avoid impacts to burrowing owls,Mitigation Measure(MM)B10-1 would be required,which entails the completion of burrowing owl clearance surveys.Additionally,there are trees adjacent to and within the Project site that could provide nesting habitat for common birds and raptors protected under the Migratory Bird Treaty Act(MBTA)and the California Fish and Game Code.To comply with the MBTA and the California Fish and Game Code and avoid impacts to nesting birds from implementation of the Project,a pre-construction nesting bird survey would be required prior to construction activities and vegetation removal,as detailed in MM BIO-2.With implementation of MM 810-1 and MM B10-2, potential impacts to biological resources would be less than significant.
Based on the results of the cultural records search,the only historic-period(50 years of age or older) resource that was identified in the Project area is a concrete water reservoir that was built in 1930 4-86 P.\2024\2O241723_5an Antonio Driveway Expansion\PRODUCTS\CEQA\Public Review Oraft\5an Antonio Water Headquarters ISMND_was 25.docx(08108125)
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as part of the irrigation system for nearby citrus groves.The reservoir was evaluated for historical significance using the criteria for listing in the California Register of Historical Resources and designation as a City Cultural Resource and did not meet any of the State or local criteria.Therefore, it is not considered a historical resource pursuant to Section 15064.5 of the State CEQA Guidelines, and implementation of the Project would not result in impacts to historical resources.Although no archaeological resources were found on the Project site,ground-disturbing activities have the potential to reveal unknown buried deposits. In the unlikely event that unanticipated archaeological resources are discovered at any time during Project construction, impacts to these resources could be potentially significant.Therefore, MM CUL-1 would be implemented,which requires that a qualified archaeologist be retained on-call to respond to inadvertent discoveries during Project construction and that all construction work occurring within 50 feet of any find shall immediately stop until a qualified archaeologist, meeting the Secretary of the Interior's Qualification Standards for Archaeology,can evaluate the significance of the find.Although no human remains are known to be on the Project site or are anticipated to be discovered during Project construction,there is always a possibility of encountering unanticipated cultural resources, including human remains, during construction activities. In the event that human remains are discovered during construction activities, MM CUL-2 would be implemented,which requires compliance with the State's Health and Safety Code for the treatment of human remains.Additionally, in the unlikely event that fossils of any sort are discovered during grading/earthmoving activities, MM GEO-1 would be implemented to reduce potential impacts to paleontological resources.With implementation of MMs CUL-1,CUL-2, and GEO-1, potential impacts associated with important examples of the major periods of California history or prehistory would be less than significant with mitigation incorporated.
With incorporation of MMs BIO-1,BIO-2,CUL-1,CUL-2,and GEO-1,the Project would not substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species,cause a fish or wildlife population to drop below self-sustaining levels,threaten to eliminate a plant or animal community,substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory,and impacts would be less than significant with mitigation incorporated.
b. Would the project have impacts that are individually limited, but cumulatively considerable? (''Cumulatively considerable"means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)?(Less Than Significant with Mitigation incorporated)
Based on the analysis provided throughout this IS/MND,the Project would have either no impact,a less than significant impact,or a less than significant impact with mitigation incorporated with respect to all environmental issues pursuant to CEQA. Furthermore,due to the limited scope of direct physical impacts to the environment associated with the Project,the Project's impacts are primarily Project-specific in nature.
Implementation of the Project has the potential to result in effects to the environment that are individually limited and may be cumulatively considerable in the following areas: Biological Resources,Cultural Resources, Geology and Soils, and Tribal Cultural Resources.As shown in the P:12024\2O241723 SanAntonia Driveway Expansion\PRODUCTS\CEOMPublit ReviewDraft\5an Antonio Water Headquarters ISMND_4A.D8.25.dacx(CRIU2/25) 4-87
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discussion above,environmental effects associated with the Project can be reduced to less than significant levels through implementation of Project-specific mitigation measures or existing regulations.Therefore,with incorporation of the mitigation measures and existing regulations discussed throughout this IS/MND,the Project would not contribute to environmental effects that are individually limited, but cumulatively considerable. Impacts would be less than significant with mitigation incorporated.
c. Would the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?(Less Than Significant with Mitigation incorporated) Based on the analysis provided throughout this Is/MND,with incorporation of mitigation measures and regulatory compliance measures,the Project would not result in any environmental effects that would cause substantial adverse effects on human beings,either directly or indirectly. Potential impacts on human beings would be less than significant with mitigation incorporated. 4-88 P:\2O24\2O241723_San Antonio Driveway Expansion\PRODUCTS\CEQA\Public Review Oraft45an Antonio Water Headquarters ISMND_was 25.docx(08108125)
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5.0 LIST OF PREPARERS
LSA Associates, Inc.
3210 El Camino Real,Suite 100
Irvine,CA 92602
Amanda Durgen, Principal Environmental Planner
Dena Giacomini, Project Manager
Ashley Honer, Environmental Planner
Ronald Brugger,Senior Air Quality Specialist
Amber Hazelrigg, Greenhouse Gas/Climate Change Analyst
Jessica Coria,Associate/Director of Air Quality and Climate Change Mohammad Abushanab, Mechanical Noise Engineer
Casey Tibbet,Associate Architectural Historian
Rory Goodwin,Associate Archaeologist
Cassidy Sharp,Archaeologist
Chrissy Kent, Biologist
Jenna Wedworth,Assistant Biologist
Ambarish Mukherjee, Mobility Principal
Kimberly Cervantes,Transportation Engineer
Kenneth Tan,Senior Transportation Engineer
Vyshnavi Shetty,Transportation Planner/Engineer
Jessie Quigley, GIS Specialist/Programmer
Meredith Canterbury,Associate GIS Specialist
Jason Thomas, Graphics Specialist
Matt Phillips, Graphics and Production
Lauren Johnson,Senior Technical Editor
Chantik Virgil,Senior Word Processor
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6.0 REFERENCES
California Air Resources Board (CARE). 2017. California's 2017 Climate Change Scoping Plan.
November.
. 2021. EMFAC 2021 Web Database(v1.0.0).June 2021.Website: https://arb.ca.gov/emfac/ emissions-inventory(accessed September 4, 2024).
. 2022.2022 Scoping Plan for Achieving Carbon Neutrality. December.Website:ww2.arb.ca. gov/sites/default/files/2023-04/2022-sp.pdf(accessed November 2024).
California Department of Conservation (DOC)California Geologic Survey(CGS). 2021.Earthquake Zones of Required Investigation. Website: https://maps.conservation.ca.gov/cgs/EQ2App/ app/(accessed July 2, 2024).
. 2022. California Important Farmland Finder(map).Website: maps.conservation.ca.gov/ dlrp/tiff/(accessed June 20, 2024).
California Department of Resources Recycling and Recovery(CalRecycle). 2019a.SWIS Facility/Site Activity Details, Mid-Valley Sanitary Landfill(36-AA-0055). Website: https://www2.cal recycle.ca.gov/SalidWaste/SiteActivity/Details/1880?sitelD=2662(accessed July 10, 2024). 2019b.SWIS Facility/Site Activity Details, Badlands Sanitary Landfill(33AA-0006).Website:
https://www2.ca l recycle.ca.gov/So!id W a ste/SiteActivity/Details/2245?sitelD=2367 (accessed July 10, 2024).
. 2019c.SWIS Facility/Site Activity Details, El Sobrante Landfill(33-AA-0217).Website:
https://www2.ca l recycle.ca.gov/Sal id W a ste/SiteActivity/beta i ls/2280?site!D=2402 (accessed July 10, 2024).
. n.d.Estimated Solid Waste Generation Rates.Website: https://www2.calrecycle.ca.gov/ wastecharacterization/general/rates(accessed July 10, 2024), California Department of Toxic Substances Control (DISC). 2021.Facilities from the California Environmental Reporting Systems(CERS).Website: https://siteportal.calepa.ca.gov/nsite/ site/427484(accessed July 2,2024).
California Department of Transportation (Caitrans). 2018.California State Scenic Highway System Map.Website: https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465 dfd3d807c46cc8e8057116f1aacaa (accessed June 20, 2024).
California Department of Water Resources (DWR). 2006. Division of Water Rights. Upper Santa Ana Valley Groundwater Basin, Chino Subbasin, California's Groundwater Bulletin 118.January
20. p:\2024\2O241723 San Antonia Driveway Expansion\PRODUCTS\CEOA Publit Review❑raft\5an Antonio Water Headquarters ISMND_48.08.25.dacx(08102125) 6_1
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. 2015. Division of Safety of Dams.Dam Breach Inundation Map Web Publisher.Website:
https://fmds.water.ca.gov/webgis/?appid=dam_prototype_v2(accessed July 5, 2024). . 2020.Sustainable Groundwater Management Act 2019 Basin Prioritization Process and Results. May.
. n.d. Groundwater Basin BoundaryAssessment Tool.Website: https://gis.water.ca.gov/app/ bbat/(accessed July 3, 2024).
California Energy Commission (CEC).2022 Total System Electric Generation.Website: https://www . energy.ca.gov/data-reports/energy-almanac/ca liforn i a-e lectricity-data/2022-tota l-system- electric-generation (accessed September 4,2024).
California Environmental Protection Agency(CalEPA).2024. Cortese List Data Resources. Website:
https://calepa.ca.gov/sitecleanup/corteselist/(accessed July 2, 2024).
California State Mining and Geology Board. 2014.Surface Mining Reclamation Act Regulations.
California Code of Regulations,Title 14, Division 2,Chapter 8,Subchapter 1.
CDM Smith Inc.2013. Technical Guidance Document Water Quality Management Plans.June 21.
City of Upland. 2015a.City of Upland General Plan Update, Figure LU-1 General Plan Land Use.
September 14.
. 2015b.Final Program Environmental Impact Report General Plan Update(GPU 08-03), Zoning Code Update(ZCU 08-03), Climate Action Plan,and Cable Airport Land Use Compatibility Plan Update SCH No.2012041006).September 28. . 2015c.Cable Airport Land Use Compatibility Plan. Map 3A Compatibility Policy Map.
September 14.
2015d. Municipal Code, Noise Ordinances. March 13.
. 2015e. General Plan, Safety Element.
. 2021. City of Upland 2020 Urban Water Management Plan and Water Shortage Contingency Plan.June.
. City of Upland. Code of Ordinances,Title 12 Streets,Sidewalks and Public Places,Chapter
12.24 Parkways, Parking Strips,Section 12.24.100 Tree Removal—Permit. . City of Upland. Municipal Code,Title 8, Chapter 15.32. . City of Upland.Zoning Code,Title 17 Zoning Ordinance, Part 3 General Regulations, Chapter
17.14 Outdoor Lighting.
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Federal Emergency Management Agency(FEMA). 2016. Flood Insurance Rate Map No. 06071C7870J. Map Revised September 2, 2016.Website: htttps://msc.fema.gov/portal/ search (accessed July 5, 2024).
Federal Transit Administration (FTA).2018. Transit Noise and Vibration Impact Assessment Manual.
Office of Planning and Environment. Report No. 0123.September.
Fehr and Peers.2020. City of Upland Traffic Impact Analysis Guidelines.July.
IEUA.2024. Regional Water Recycling Plant No. 1.Website: https://www.ieua.org/regional-water- recycling-plant-no-1/(accessed July 10,2024).
Institute of Transportation Engineers(ITE). Trip Generation Manual(11th Edition).
Land Development Design Company, LLC. 2024. Preliminary Water Quality Management Plan For:
San Antonio Water Company.September 7.
LSA Associates, Inc(LSA). 2016. Operational Noise Impact Analysis for Richmond Wholesale Meat Distribution Center.
. 2024a.Air Quality and Greenhouse Gas Technical Memorandum for the Proposed San Antonio Water Headquarters in Upland, California(LSA Project No. 20241723). November
19. . 2024b. Traffic Impact Analysis San Antonio Water Headquarters Project. November. . 2024c.Biological Resources Assessment, San Antonio Water Company Headquarters, Upland,San Bernardino County, California(APN 1044-091-22).September. . 2024d. Cultural Resources Assessment,San Antonio Water Company Headquarters Project, City of Upland,San Bernardino County, California.September. . 2024e.Noise and Vibration Impact Analysis for the Proposed San Antonio Water Headquarters in Upland, California(LSA Project No. 20241723). November.
National Center for Education Statistics. 2024.Search for Public School Districts; District Name:
Upland Unified.Website: https://nces.ed.gov/ccd/districtsearch/district_detail.asp ? Search=2&ID2=0600016&DistrictlD=0600016&details=1(accessed July 10, 2024).
Office of the State Fire Marshal.2024 Fire Hazard Severity Zones.Website: https://osfm.fire.ca.gov/ what-we-do/community-wildfire-preparedness-and-mitigation/fire-hazard-severity-zones (accessed April 22, 2025).
San Bernardino County Fire Protection District. 2024.San Bernardino County Fire Statistics, Fiscal Year 2022-23. Website: https://sbcfire.org/statistics/#statistics-total-anchor(accessed July 10, 2024).
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LC SAN AN,ONIO WATER COMPANY HEADQUARTERS PROJECT INITIAL STUDY/MITIGATED NEGATIVE DECLARATION _.1/ UPLAND,CALIFORNIA AuGusr 202S
Southern California Association of Governments(SLAG). 2008.Final 2008 Regional Comprehensive Plan.Website: scag.ca.gov/sites/main/files/file-attachments/f2008rcp_complete.pdf? 1604263359 (accessed November 2024).
. 2020. Connect SoCal:The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments.Website: scag.ca.gov/sites/ main/files/file-attachments/0903fconnectsocal-plan_0.pdf?1606001176 (accessed November 2024).
South Coast Air Quality Management District(SCAQMD). 1993. CEQA Air Quality Handbook.
Website: www.aqmd.gov/home/rules-compliance/cega/air-quality-analysis-handbook/ cega-air-quality-handbook-(1993)(accessed November 2024). . 2012.Final 2012 Air Quality Management Plan. Website: https://www.agmd.gov/home/air- qual ity/a i r-q u a lity-ma nageme nt-p la ns/a i r-q ua l ity-mgt-pla n/fi na I-2012-air-q ua l ity- management-plan(accessed November 2024).
. 2015.Amicus Curiae Brief of South Coast Air Quality Management District.April. Website:
www.cou rts.ca.gov/docu me nts/9-s219783-a c-south-coast-air-quality-mgt-d ist-041315.pdf (accessed November 2024).
. 2022.2022 Air Quality Management Plan. Website: www.agmd.gov/does/default-source/ cl ea n-a i t-pla ns/a i t-q u a l ity-m a n agement-pla ns/2022-ai r-q ua l ity-ma nage ment-plan/fi na l- 2022-agmp/final-2022-agmp.pdf?sfvrsn=16(accessed November 2024). . 2024a.NAAQS and CAAQS Attainment Status for South Coast Air Basin. Website:
www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/naags- caags-feb2016.pdf(accessed November 2024).
. 2024b.South Coast AQMD Rule Book.Website: www.agmd.gov/home/rules-compliance/ rules(accessed November 2024).
Soils Southwest, Inc.2024.Report of Geotechnical Evaluations and Soils Infiltration Testing for WQMP-BMP Stormwater Disposal Design, Planned New San Antonio Water District Headquarters Office and Maintenance Facility.August 28.
State Water Resources Control Board (SWRCB).2023.2020-2022 California Integrated Report(Clean Water Act Section 303(d)List and 305(b)Report).Website: https://www.waterboards.ca . gov/water_issues/programs/water_quality_assessment/2020_2022_i ntegrated_report.htm I (accessed September 17, 2024).
. 2024.GeoTracker. Website: https://geotracker.waterboards.ca.gov/map/?myaddress= California&from=header&cgid=4806317985 (accessed July 2,2024).
Trane. n.d. Fan Performance- Product Specifications RT-PRCO23AU-EN. 6-4 P:\2024420241723_San Antonio Driveway Expansion\PRODUCTS\CEQA\Public Review Oraft\5an Antonio Water Headquarters ISMND_48.0825.docx(08108125)
INITIAL STUDYJNIITISATEo NEGATIVE DECLARATION SAN ANTONI❑WATER COMPANY HEADQUARTERS PRolECT ` S A AUGUST 2025 UPLAND,CALIFORNIA L r`.
United States Department of Transportation(USDOT). "Table 4-23:Average Fuel Efficiency of U.S.
Light Duty Vehicles."Website: https://www.bts.gov/contentlaverage-fuel-efficiency-us- light-duty-vehicles(accessed September 4, 2024).
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MITIGATION MONITORING AND REPORTING PROGRAM SAN ANTONIO WATER COMPANY HEADQUARTERS PROJECT L SA AUGUST 2025 UPLAND,CALIFORNIA
MITIGATION MONITORING AND REPORTING PROGRAM
This Mitigation Monitoring and Reporting Program (MMRP) is formulated based upon the findings of the Initial Study/Mitigated Negative Declaration (IS/MND) prepared for the San Antonio Water Company(SAWCo) Headquarters Project(Project).The MMRP, which is found in Table 1, lists mitigation measures recommended in the IS/MND prepared for the Project and identifies mitigation monitoring requirements.The Final MMRP must be adopted when the City of Upland (City) makes a final decision on the Project.
This MMRP has been prepared to comply with the requirements of State law (Public Resources Code Section 21081.6). State law requires the Lead Agency to adopt an MMRP when mitigation measures are required to avoid significant impacts.The MMRP is intended to ensure compliance with the mitigation measures identified in the IS/MND during implementation of the Project.
The MMRP is organized in a matrix format.The first two columns identify the potential impacts and corresponding mitigation measures.The third column, entitled "Timeframe for Implementation," refers to when monitoring will occur to ensure that the mitigating action is completed.The fourth column, entitled "Responsibility for Implementation," refers to the party responsible for implementing the mitigation measure. The fifth column, entitled, "Oversight of Implementation," refers to the party responsible for oversight or ensuring that the mitigation measure is implemented.
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MITIGATION MONITORING AND REPORTING PROGRAM SAN ANTONIO WATER COMPANY HEADQUARTERS PROJECT L r`■L S A AUGUST 2025 UPLAND,CALIFORNIA
Mitigation Monitoring and Reporting Program
Timeframe for Responsibility Oversight of
Impact Mitigation Measures for
Implementation Implementation
Implementation
4.4 Biological Resources
MM BIO-1:Burrowing Owl Clearance Survey.Fourteen days prior to the commencement of Project activities,a qualified biologist will conduct a Fourteen days Presence/Absence survey of suitable habitat on the Project site as well as prior to the
survey for signs of scat/burrow usage.If burrowing owls/active burrows are The Project could have a commencement City of Upland directly observed within the Project site during the preconstruction survey,a substantial adverse effect, of Project Project Director of suitable buffer will be placed around the active burrow as determined by a either directly or through activities Proponent/ Planning habitat modifications,on qualified biologist and avoided until the individuals leave of their own accord. Qualified Biologist Services,or burrowing owls. Additionally,if burrowing owl is found during the preconstruction survey,the Prior to designee Project proponent will need to inform the California Department of Fish and initiating ground Wildlife(CDFW)and the United States Fish and Wildlife Service(USFWS)and disturbance prepare a Burrowing Owl Protection and Relocation Plan for approval by these agencies prior to initiating ground disturbance. _ MM BIO-2:Nesting Bird Clearance Survey.The Project's construction activities will occur,if feasible,between September 16 and January 31(outside of nesting bird season)in an effort to avoid impacts to nesting birds. If activities must occur within nesting bird season(February 1 to September 15),a qualified biologist will conduct a pre-construction survey no more than 3 days(72 hours) Prior to any The Project could have a prior to any construction activities and vegetation removal.Should nesting construction Project
substantial adverse effect, birds be found,an exclusionary buffer will be established by the qualified activities and City of Upland either directly or through biologist.The buffer will be clearly marked in the field by construction vegetation Proponent/ Director of habitat modifications,on personnel under guidance of the qualified biologist. No construction activities removal Qualified Planning native birds protected will be allowed within this zone until the qualified biologist determines that the Biologist/ Services,or under the Migratory Bird young have fledged,or the nest is no longer active. During Construction designee Treaty Act. construction
Contractor
To the greatest extent feasible,tree trimming/removal activities will be activities performed outside of the nesting season for birds(February 1—September 15).
If trimming or removal of trees during the nesting bird season cannot be avoided,a qualified biologist will monitor tree trimming and removal activities, if nests are found present during the pre-construction survey.
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4.5 Cultural Resources
MM CUL-1:Unknown Archaeological Resources.In the event that archaeological resources are discovered during excavation,grading,or construction activities,work shall cease within 50 feet of the find until a qualified archaeologist from the San Bernardino County List of Qualified The Project could cause a During
Archaeologists has evaluated the find in accordance with federal,State,and Project substantial adverse change local guidelines to determine whether the find constitutes a"unique excavation, Proponent/ City of Upland in the significance of an grading,or Director of unidentified archaeological archaeological resource,"as defined in Section 21083.2(g)of the California ground Qualified Planning Public Resources Code(PRC).Personnel of the Project shall not collect or move Archaeologist/ resource if such resources disturbing Services,or any archaeological materials and associated materials.Construction activity Construction are encountered during construction designee may continue unimpeded on other portions of the Project site.The found Contractor construction. activities
deposits shall be treated in accordance with federal,State,and local guidelines, including those set forth in PRC Section 21083.2.Prior to issuance of a grading permit,the Director of Planning Services,or designee,shall ensure that this mitigation measure is documented on the grading plans.
MM CUL-2:Human Remains.If human remains are encountered,State Health and Safety Code Section 7050.5 states that no further disturbance shall occur until the County Coroner has made a determination of origin and disposition pursuant to State Public Resources Code(PRC)Section 5097.98.The County Coroner must be notified of the find immediately.If the remains are determined to be Native American,the County Coroner would notify the Native American Heritage Commission(NAHC),which would determine and notify a During The Project could disturb
Most Likely Descendant(MLD).With the permission of the landowner or excavation, Project City of Upland human remains if such his/her authorized representative,the MLD may inspect the site of the grading,or Proponent/ Director of resources are encountered discovery.The MLD shall complete the inspection and make recommendations ground- County Coroner/ Planning during construction. or preferences for treatment within 48 hours of being granted access to the disturbing Construction Services,or site.The MLD recommendations may include scientific removal and construction Contractor designee nondestructive analysis of human remains and items associated with Native activities American burials,preservation of Native American human remains and associated grave goods in place,relinquishment of Native American human remains and associated items to the descendants for treatment,or any other culturally appropriate treatment.Prior to issuance of a grading permit,the Director of Planning Services or designee shall ensure that this mitigation measure is documented on the grading plans.
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MITIGATION MONITORING AND REPORTING PROGRAM SAN ANTONIO WATER COMPANY HEADQUARTERS PROJECT L r`■L S A AUGUST 2025 UPLAND,CALIFORNIA
Mitigation Monitoring and Reporting Program
Timeframe for Responsibility Oversight of
Impact Mitigation Measures for
Implementation Implementation
Implementation
4.7 Geology and Soils
MM GEO-1:Paleontological Resources Impact Mitigation Program.Should paleontological resources be encountered during Project subsurface construction activities,all ground-disturbing activities within 25 feet shall be redirected and a qualified paleontologist contacted to assess the situation, consult with agencies as appropriate,and make recommendations for the treatment of the discovery.For purposes of this mitigation,a"qualified paleontologist"shall be an individual with the following qualifications:(1)a graduate degree in paleontology or geology and/or a person with a demonstrated publication record in peer-reviewed paleontological journals;(2) at least two years of professional experience related to paleontology;(3) During The Project could directly or Project
proficiency in recognizing fossils in the field and determining their significance; excavation, City of Upland indirectly destroy a unique Proponent/
(4)expertise in local geology,stratigraphy,and biostratigraphy;and(5) I grading,or Director of paleontological resource or Qualified
experience collecting vertebrate fossils in the field. If the paleontological ground- Planning site or unique geologic resources are found to be significant and Project activities cannot avoid them, disturbing Paleontologist/ Services,or feature if encountered Construction
measures shall be implemented to ensure that the Project does not cause a construction designee during construction. Contractor
substantial adverse change in the significance of the paleontological resource. activities Measures may include monitoring,recording the fossil locality,data recovery and analysis,a final report,and accessioning the fossil material and technical report to a paleontological repository.Upon completion of the assessment,a report documenting methods,findings,and recommendations shall be prepared and submitted to the City of Upland for review.If paleontological materials are recovered,this report also shall be submitted to a paleontological repository such as the University of California Museum of Paleontology,along with significant paleontological materials. Public educational outreach may also be appropriate. _
4.18 Tribal Cultural Resources
MM TCR-1:Retain a Native American Monitor Prior to Commencement of Ground-Disturbing Activities. During
The Project could disturb I excavation, City of Upland tribal cultural resources if A. The City shall contact interested tribes to determine if a Native American grading,or Project Director of such resources are Monitor is requested prior to the commencement of any"ground- ground- Proponent/ Planning disturbingactivit 'for the subject Project at all Project locations i e.,both Native American encountered during Y 1 1 1 ( disturbing Services,or construction. on-site and any off-site locations that are included in the Project construction Monitor designee description/definition and/or required in connection with the Project,such activities as public improvement work)."Ground-disturbing activity"shall include, P:\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\CEQA\San Antonio Water Headquarters MMRP.docx(08/08/25) 5
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but is not limited to,demolition,pavement removal,potholing,auguring, grubbing,tree removal,boring,grading,excavation,drilling,and trenching.
B. A copy of the executed monitoring agreement shall be submitted to the lead agency prior to the commencement of any ground-disturbing activity, or the issuance of any permit necessary to commence a ground-disturbing activity.
C. If monitoring is required,the monitor will complete daily monitoring logs that will provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed,locations of ground- disturbing activities,soil types,cultural-related materials,and any other facts,conditions,materials,or discoveries of significance to the Tribe.
Monitor logs will identify and describe any discovered TCRs,including but not limited to,Native American cultural and historical artifacts,remains, places of significance,etc.,(collectively,tribal cultural resources,or"TCR"), as well as any discovered Native American(ancestral)human remains and burial goods.Copies of monitor logs will be provided to the Project applicant/lead agency upon written request to the Tribe.
D. On-site tribal monitoring shall conclude upon the latter of the following(1) written confirmation to the tribal representative from a designated point of contact for the Project applicant/lead agency that all ground-disturbing activities and phases that may involve ground-disturbing activities on the Project site or in connection with the Project are complete;or(2)a determination and written notification by the tribal representative to the Project applicant/lead agency that no future,planned construction activity and/or development/construction phase at the Project site possesses the potential to impact TCRs. _
MM TCR-2:Unanticipated Discovery of Tribal Cultural Resource Objects(Non- During The Project could disturb Project
Funeral/Non-Ceremonial).The San Manuel Nation Cultural Resources i excavation, City of Upland non-funeral/non-ceremonial Proponent/ Department shall be contacted of any pre-contact and/or historic-era cultural grading,or Director of tribal cultural resources if Native American resources discovered during project implementation and be provided ground- Planning such resources are information regarding the nature of the find so as to provide tribal input with disturbing Monitor/ Services,or encountered during Construction
regards to significance and treatment.In the event the material is determined construction designee construction. to be significant,Mitigation Measure TCR-4 shall apply. activities Contractor 6 P:\2024\20241723_5an Antonio Driveway Expansion\PRODUCTS\CEOA\San Antonio Water Headquarters MMRP.docx(08/08/25)
MITIGATION MONITORING AND REPORTING PROGRAM SAN ANTONIO WATER COMPANY HEADQUARTERS PROJECT L Sr`■L A AUGUST 2025 UPLAND,CALIFORNIA
Mitigation Monitoring and Reporting Program
Timeframe for Responsibility Oversight of
Impact Mitigation Measures for
Implementation Implementation
Implementation
MM TCR-3:Unanticipated Discovery of Tribal Cultural Resource Objects(Non- During The Project could disturb Project
Funeral/Non-Ceremonial).Upon discovery of any TCRs,all construction excavation, City of Upland non-funeral/non-ceremonial Proponent/ activities in the immediate vicinity of the discovery shall cease(i.e.,not less grading,or Director of tribal cultural resources if Native American than the surrounding 50 feet)and shall not resume until the discovered TCR has ground- Planning such resources are Monitor/
been fully assessed by the Kizh monitor and/or Kizh archaeologist.In the event disturbing Services,or encountered during Construction
the material is determined to be significant,Mitigation Measure TCR-4 shall construction designee construction. Contractor
apply. activities
MM TCR-4:Monitoring and Treatment Plan.In the event of any inadvertent discovery of any tribal cultural material,or pre-contact/historic-era resource determined to be significant,the City shall require the preparation of a Monitoring and Treatment Plan.The monitoring and treatment plan shall be prepared by a qualified archeologist in consultation with and subject to the During approval of the City and the consulting Native American tribes.The City and Project The Project could disturb excavation, City of Upland tribal cultural resources if consulting Native American tribes shall engage in mutual good faith efforts to grading,or Proponent/ Director of such resources are develop the Monitoring and Treatment Plan.The monitoring and treatment ground- Qualified Planning encountered during plan shall identify the manner and process in which any suspected tribal disturbing Archeologist/ Services,or construction. cultural material is evaluated,recorded,removed,or curated,including the construction Consulting Native designee final disposition of any such material. American Tribes activities
If the manner and process of evaluation,recording,removing,and/or disposing of tribal cultural material cannot be resolved between consulting Native American parties,the City shall,in good faith,determine and approve the appropriate actions to be included in the Monitoring and Treatment Plan.
MM TCR-5:Unanticipated Discovery of Human Remains and Associated I
Funerary or Ceremonial Objects.
A. Native American human remains are defined in PRC 5097.98(d)(1)as an During The Project could disturb inhumation or cremation,and in any state of decomposition or skeletal Project excavation,
City of Upland
tribal human remains and completeness.Funerary objects,called associated grave goods in Public Proponent/ grading,or Director of
associated funerary or Resources Code Section 5097.98,are also to be treated according to this ground- Native American Planning ceremonial objects if such statute. disturbing Monitor/ Services,or resources are encountered Construction B. If Native American human remains and/orgravegoods are discovered or construction designee during construction. Contractor
recognized on the Project site,then Public Resource Code 5097.9 as well as activities Health and Safety Code Section 7050.5 shall be followed.
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Public Resources Code section 5097.98(d)(1)and(2).
D. Preservation in place(i.e.,avoidance)is the preferred manner of treatment for discovered human remains and/or burial goods.
E. Any discovery of human remains/burial goods shall be kept confidential to prevent further disturbance.
Source:LSA 2025.
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INITIAL STUDY/MITIGATED NEGATIVE DECLARATION SAN ANTONI❑WATER COMPANY HEADQUARTERS PROJECT M ■ AUGUST 2025 UPLAND,CALIFORNIA
APPENDIX A
AIR QUALITY AND GREENHOUSE GAS
TECHNICAL MEMORANDUM
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CARLSBAD
L SA CLOVIS
IRVINE
LOS ANGELES
PALM SPRINGS
POINT RICHMOND
RIVERSIDE
ROSEVILLE
SAN LUIS OBISPO
MEMORANDUM
DATE: November 19, 2024
To: Brian Lee, General Manager, San Antonio Water Company FROM: Ronald Brugger, Senior Air Quality Specialist, LSA Associates, Inc.
SUBJECT: Air Quality and Greenhouse Gas Technical Memorandum for the Proposed San Antonio Water Headquarters in Upland, California (LSA Project No. 20241723)
INTRODUCTION
LSA has prepared this Air Quality and Greenhouse Gas Technical Memorandum to evaluate the impacts associated with the construction and operation of the San Antonio Water Company (SAWCO) Headquarters Project (project) in Upland, California.This analysis was prepared using methods and assumptions recommended in the air quality impact assessment guidelines of the South Coast Air Quality Management District (SCAQMD) in its CEQA Air Quality Handbook and associated updates.'This analysis includes an assessment of criteria pollutant emissions and an assessment of the project's greenhouse gas (GHG) emissions.
PROJECT LOCATION
The approximately 4.92-acre project site is located at 400 East 20th Street in Upland, San Bernardino County(Assessor's Parcel Number 1044-091-22).The project site is located in northwest Upland in an area primarily consisting of residential, commercial, and industrial uses.The project site is bound by East 20th Street to the north, undeveloped open space to the east, State Route 210 (SR 210)to the south, and Flower Court to the west.The project location is shown on Figure 1 (all figures are provided in Attachment A).
PROJECT DESCRIPTION
The project would result in the construction of a new 3,698-square-foot SAWCO headquarters and associated improvements, including a 4,066-square-foot maintenance building, maintenance yard, driveway, parking, solar cover, landscaping, and utility improvements, as shown on Figure 2.The headquarters building would feature office space, meeting and conference rooms, a lobby, an archive room, a break room,two Americans with Disabilities Act (ADA) restrooms, a quiet room, a copy room, and a work area.The maintenance building would include storage space, an outdoor 1 South Coast Air Quality Management District(SCAQMD). 1993. CEQA Air Quality Handbook. Website:
www.agmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/ceqa-air-quality-handbook- (1993)(accessed November 2024).
3210 El Camino Real,Suite 100,Irvine,California 92602 949.553.0666 www.lsa.net
LSA
welding area, a motor repair room, electrical rooms, an ADA restroom, a locker room, and a maintenance office/break room.The buildings would not use any natural gas (all electric), be a maximum height of 23 feet, and have a Floor Area Ratio of 0.7. It is anticipated that approximately 10 people would be employed on the project site.
The project would include a citrus grove buffer along the eastern half of the northern property line, along with various trees and shrubs around the parking areas and the main headquarters building.
Approximately 46,077 square feet of landscaped area would be provided. Up to two of the existing street trees would be removed to accommodate the driveway off East 20th Street, and various shrubs and associated grassland would be removed to accommodate the driveway off Campus Avenue and East 20th Street.The three existing trees at the southwestern corner of the project site would remain in place, and 51 new ornamental trees and 64 new citrus trees would be planted as part of the project's landscape design.
The visitor and customer parking lot would be located south of the citrus grove and north of the main headquarters building and would provide 14 surface parking spaces, including two ADA compliant parking spots.The employee parking area would be located east of the main headquarters building, would be covered by photovoltaic panels, and would include 14 surface parking spaces, including 2 ADA compliant parking spots.The project would also provide 8 covered truck parking spots west of the maintenance building.
Existing developments include a 1-million-gallon water storage tank located at the northwestern corner of the parcel, a pump station located at the southwestern corner of the parcel, and a signal building and tower located at the southeastern corner of the parcel.Approximately five SAWCO employees within the Operations Department use the project site on a daily basis for equipment and material storage.The existing water storage tank, pump station, and signal buildings and tower would remain in place.
The proposed use is not currently consistent with the existing Single-Family Residential Low (SFR-L) General Plan land use designation and RS-10 zoning.To comply with the City of Upland's (City) General Plan and zoning regulations,the project will require a General Plan amendment, and a zone change to Public Utilities (PU) land use designation and Public/Institutional (PB/I) zoning.The PU designation accommodates landfills,flood control/recharge facilities, and public utilities, including gas, electricity, and water.The purpose of the PB/I zone is to allow for public and quasi-public facilities that serve Upland residents and visitors.The PU designation and PB/I zone permit a maximum Floor Area Ratio of 0.5.
Construction of the project is anticipated to begin in Spring 2025 and be completed by the end of 2026.The proposed project would require approximately 1,700 tons of roadway debris to be removed from the site and approximately 900 cubic yards of soil to be imported to the site. No natural gas would be used during construction.
EXISTING LAND USES IN THE PROJECT AREA
As shown in Figure 3, the project site is generally surrounded by a mix of residential, commercial, and industrial uses.To the north, the project site is bound by East 20th Street, across which are 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 2 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
LSA
single-family residential uses.The project site is immediately bound to the east by undeveloped open space owned by Southern California Edison Company. Further east are commercial and industrial uses, including a concrete supplier and gravel mine.To the south, the project site is bound by SR 210, across which are two large water storage tanks, single-family residential uses, and commercial uses.To the west,the project site is bound by Flower Court, across which are single- family residential uses.
For the purposes of this analysis, sensitive receptors are areas of population that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include residences, schools, daycare centers, hospitals, parks, and similar uses which are sensitive to air quality. Impacts on sensitive receptors are of particular concern because they are the population most vulnerable to the effects of air pollution.
The nearest sensitive receptors are the existing single-family residences to the west approximately 90 feet from the proposed project boundary.Although the majority of the construction activities would occur in the eastern half of the proposed project site much further from these residences, this analysis assumes that at some point construction equipment could operate along the western boundary of the project site. As the proposed project's operational emissions would occur in the eastern portion of the project site around the proposed buildings, the closest sensitive receptors to these emissions are the existing single-family residences to the north approximately 300 feet from the centroid of the operational area.Table A summarizes the distance of sensitive receptors to the proposed project by impact categories.
Table A: Summary of Analysis Distances by Impact Category Distance
Activity Nearest Sensitive Receptor Points of Analysis (feet) Construction' Single-family homes along Flower Court Perimeter of construction activities to 90 centroid of nearest residence.
Operations Single-family homes along East 20th Emissions sources on site generalized at the 300 Street centroid of the project site to centroid of nearest residence.
Source:Compiled by LSA(2024).
1 Distance for construction air quality impact potential includes the assumption that heavy construction equipment would operate adjacent to the proposed project boundary,which is approximately 90 feet from the center of the nearest off-site structures where a person would live.
ENVIRONMENTAL SETTING
Air Quality Background
Air quality is primarily a function of local climate, local sources of air pollution, and regional pollution transport. The amount of a given pollutant in the atmosphere is determined by the amount of the pollutant released and the atmosphere's ability to transport and dilute the pollutant.
The major determinants of transport and dilution are wind, atmospheric stability, terrain, and,for photochemical pollutants, sunshine.
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A region's topographic features have a direct correlation with air pollution flow and therefore are used to determine the boundary of air basins.The proposed project is in Upland, San Bernardino County, and is within the jurisdiction of SCAQMD,which regulates air quality in the South Coast Air Basin (Basin).
The Basin comprises approximately 10,000 square miles and covers all of Orange County and the urban parts of Los Angeles, Riverside, and San Bernardino Counties.The Basin is on a coastal plain with connecting broad valleys and low hills to the east. Regionally,the Basin is bounded by the Pacific Ocean to the southwest and high mountains to the east,forming the inland perimeter.
Both State and federal governments have established health-based ambient air quality standards for six criteria air pollutants: carbon monoxide (CO), ozone (03), nitrogen dioxide (NO2), sulfur dioxide (SO2), lead (Pb), and suspended particulate matter. In addition,the State has set standards for sulfates, hydrogen sulfide,vinyl chloride, and visibility-reducing particles.These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety.Two criteria pollutants, 03 and NO2, are considered regional pollutants because they(or their precursors) affect air quality on a regional scale. Pollutants such as CO, SO2, and Pb are considered local pollutants that tend to accumulate in the air locally.
Air quality monitoring stations are located throughout the nation and are maintained by the local air districts and State air quality regulating agencies. Data collected at permanent monitoring stations are used by the United States Environmental Protection Agency(USEPA)to identify regions as "attainment" or"nonattainment" depending on whether the regions meet the requirements stated in the applicable National Ambient Air Quality Standards (NAAQS). Nonattainment areas are imposed with additional restrictions as required by the USEPA. In addition, different classifications of attainment(e.g., marginal, moderate, serious, severe, and extreme) are used to classify each air basin in the State on a pollutant-by-pollutant basis.The classifications are used as a foundation to create air quality management strategies to improve air quality and to comply with the NAAQS. As shown in Table B,the Basin is designated as nonattainment by the federal standards for 03 and particulate matter less than 2.5 microns in diameter(PM2.5) and nonattainment by the State standards for 03, particulate matter less than 10 microns in diameter(PM1o), and PM2.5. 03 levels, as measured by peak concentrations and the number of days over the State 1-hour standard, have declined substantially as a result of aggressive programs by SCAQMD and other regional, State, and federal agencies.The reduction of peak concentrations represents progress in improving public health; however,the Basin still exceeds the State standard for 1-hour and 8-hour 03 levels.The USEPA lowered the 1997 0.80 parts per million (ppm)federal 8-hour ozone standard to 0.75 ppm in 2008 and then to 0.70 ppm on October 1, 2015.The Basin is classified nonattainment for the 1-hour and 8-hour ozone standards at the State and federal level. 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 4 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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Table B: Attainment Status of Criteria Pollutants in the South Coast Air Basin
Pollutant State Federal
03 1-hour _ Nonattainment N/A
03 8-hour Nonattainment Extreme Nonattainment
PM2o Nonattainment Attainment/Maintenance
PM2.5 Nonattainment Nonattainment
CO Attainment Attainment/Maintenance
NO2 Attainment Unclassified/Attainment(1-hour) Attainment/Maintenance(Annual)
SO2 Unclassifiable/Attainment Unclassifiable/Attainment Lead Attainment' Unclassified/Attainment'
All Others Attainment/Unclassified Attainment/Unclassified Source:NAAQS and CAAQS Attainment Status for South Coast Air Basin(SCAQMD 2024).Website: www.aqmd.gov/docs/ default-source/clean-air-plans/air-quality-management-plans/naaqs-caaqs-feb2016.pdf(accessed November 2024). ' PM2.5 federal attainment status shown is based on the 2012 12.0 µg/m3 NAAQS,status based on the 2024 9.0 µg/m3 NAAQS is pending.
2 Only the Los Angeles County portion of the South Coast Air Basin is in nonattainment for lead.
CAAQS=California Ambient Air Quality Standards 03=ozone CO=carbon monoxide PMx,=particulate matter less than 10 microns in diameter EPA=United States Environmental Protection Agency PM2.s=particulate matter less than 2.5 microns in diameter N/A=not applicable SCAQMD=South Coast Air Quality Management District NAAQS=National Ambient Air Quality Standards SO2=sulfur dioxide NO2=nitrogen dioxide
From 2021 to 2023,the Fontana-Arrow Highway Air Monitoring Station located at 14360 Arrow Boulevard in the City of Fontana (the closest monitoring station to the project limits) recorded the following exceedances of the State and federal 1-hour and 8-hour 03 standards (full data included in Attachment C):2
• The State and federal 8-hour 03 standard (which are the same) had 81 exceedances in 2021, 68 in 2022, and 74 in 2023.
• The State 1-hour 03 standard had 44 exceedances in 2021, 4 in 2022, and 56 in 2023.
National and State standards have also been established for PM2.5 over 24-hour and yearly averaging periods. PM2.5, because of the small size of individual particles, can be especially harmful to human health. PM2.5 is emitted by common combustion sources such as cars, trucks, buses, and power plants, in addition to ground-disturbing activities. On December 17, 2006,the USEPA strengthened the 24-hour PM2.5 NAAQS from 65 micrograms per cubic meter(µg/m3)to 35 µg/m3, and the Basin was subsequently designated "moderate" nonattainment for the 2006 24-hour PM2.5 NAAQS on December 14, 2009. On February 7, 2024,the USEPA strengthened the NAAQS for PM2.5 by revising the primary(health-based) annual standard from 12.0 µg/m3 to 9.0 µg/m3; however, a new attainment designation has not been issued.The Basin is also considered a nonattainment area for 2 California Air Resources Board (CARB).2024. iADAM Air Quality Data Statistics.Website: www.arb . ca.gov/adam/topfour/topfourl.php(accessed November 2024). 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 5 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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the PM2.5 standard at the State level. From 2021 to 2023,the Fontana-Arrow Highway Monitoring Station recorded the following exceedances of the federal 24-hour PM2.5. • The federal 24-hour PM2.5 standard had 2 exceedances in 2021 with 1 in 2022 and 2023.
The Basin is classified as a PM13 nonattainment area at the State level and was redesignated from serious nonattainment to attainment of the federal PM10 standard on July 26, 2013. Because the Basin was redesignated from nonattainment to attainment, a PM10 maintenance plan was adopted in 2013 and is required to be updated every 10 years. From 2021 to 2023,the 1630 Fontana-Arrow Highway Air Monitoring Station recorded the following exceedances of the State and federal 24- hour PM10 standards:
• The State 24-hour PM10 standard had 3 exceedances in 2021, 6 exceedances in 2022, and 8 in 2023.
• The federal 24-hour PM10 standard had no exceedances in 2021, 2022, or 2023.
All areas of the Basin have continued to remain below the federal CO standards (35 ppm 1-hour and 9 ppm 8-hour) since 2003.The USEPA redesignated the Basin to attainment of the federal CO standards, effective June 11, 2017.The Basin is also well below the State CO standards (20 ppm 1-hour CO and 9 ppm 8-hour CO). From 2021 to 2023,the 1630 Fontana-Arrow Highway Air Monitoring Station recorded no exceedances of the State and federal 1-hour and 8-hour CO standards.
Greenhouse Gas Background
GHGs are present in the atmosphere naturally, are released by natural sources, or form from secondary reactions taking place in the atmosphere. Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the atmosphere.These extra emissions are increasing GHG concentrations in the atmosphere and enhancing the natural greenhouse effect, which is believed to be causing global warming. Although manmade GHGs include naturally occurring GHGs such as carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O), some gases like hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), nitrogen trifluoride (NF3), and sulfur hexafluoride (SF6) are completely new to the atmosphere.
Certain gases, such as water vapor, are short-lived in the atmosphere. Others remain in the atmosphere for significant periods of time, contributing to climate change in the long term. Water vapor is excluded from the list of GHGs above because it is short-lived in the atmosphere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation.
These gases vary considerably in terms of global warming potential (GWP),which is a concept developed to compare the ability of each GHG to trap heat in the atmosphere relative to another gas.The GWP is based on several factors, including the relative effectiveness of a gas in absorbing infrared radiation and the length of time that the gas remains in the atmosphere (atmospheric lifetime). The GWP of each gas is measured relative to CO2,the most abundant GHG; the definition 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 6 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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of GWP for a particular GHG is the ratio of heat trapped by one unit mass of the GHG to the ratio of heat trapped by one unit mass of CO2 over a specified time period. GHG emissions are typically measured in terms of pounds or tons of CO2 equivalents (CO2e).
REGULATORY SETTING
Air Quality
This section provides regulatory background information for air quality at the federal, State, and local levels.
Federal Regulations
The 1970 Federal Clean Air Act (CAA) authorized the establishment of national health-based air quality standards and set deadlines for their attainment.The CAA Amendments of 1990 changed deadlines for attaining national standards as well as the remedial actions required for areas of the nation that exceed the standards. Under the CAA, State and local agencies in areas that exceed the national standards are required to develop State Implementation Plans to demonstrate how they will achieve the national standards by specified dates.
State Regulations
In 1988,the California Clean Air Act (CCAA) required that all air districts in the State endeavor to achieve and maintain California Ambient Air Quality Standards (CAAQS)for CO, 03, SO2, and NO2 by the earliest practical date.The CCAA provides districts with the authority to regulate indirect sources and mandates that air quality districts focus particular attention on reducing emissions from transportation and area-wide emission sources. Each nonattainment district is required to adopt a plan to achieve a 5 percent annual reduction, averaged over consecutive 3-year periods, in district- wide emissions of each nonattainment pollutant or its precursors. A Clean Air Plan shows how a district would reduce emissions to achieve air quality standards. Generally,the State standards for these pollutants are more stringent than the national standards.
The California Air Resources Board (CARB) is the State's "clean air agency." CARB's goals are to attain and maintain healthy air quality, protect the public from exposure to toxic air contaminants, and oversee compliance with air pollution rules and regulations.
Regional Regulations
The proposed project would be required to comply with regional rules that assist in reducing short- term air pollutant emissions. SCAQMD Rule 403 requires that fugitive dust be controlled with best available control measures so that the presence of such dust does not remain visible in the atmosphere beyond the property line of the emissions source. In addition, SCAQMD Rule 403 requires implementation of dust suppression techniques to prevent fugitive dust from creating a nuisance off site. SCAQMD Rule 1113 limits the volatile organic compound (VOC) content of architectural coatings. Applicable dust suppression techniques from SCAQMD Rule 403 and low VOC content in paints under SCAQMD Rule 1113 are summarized below. Implementation of these dust 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 7 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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suppression techniques can reduce the fugitive dust generation (and thus the PM10 component).
Compliance with these rules would reduce impacts on nearby sensitive receptors.' South Coast Air Quality Management District Rule 403 Measures. • Water active sites at least two times daily (locations where grading is to occur will be thoroughly watered prior to earthmoving).
• All trucks hauling dirt,sand, soil,or other loose materials are to be covered or should maintain at least 2 feet of freeboard in accordance with the requirements of California Vehicle Code Section 23114(freeboard means vertical space between the top of the load and top of the trailer). • Traffic speeds on all unpaved roads shall be reduced to 15 miles per hour or less.
South Coast Air Quality Management District Rule 1113 Measures. SCAQMD Rule 1113 governs the sale, use, and manufacture of architectural coating and limits the VOC content in paints and paint solvents.This rule regulates the VOC content of paints available during construction and operation of the proposed project.Therefore, all paints and solvents used during construction and operation of the proposed project must comply with SCAQMD Rule 1113.
Local Regulations
City of Upland General Plan 2010. The City of Upland addresses air quality in the Open Space and Conservation and Circulation Element of the City of Upland General Plan 2015.4 The General Plan contains goals and policies that work to protect air, water, and energy resources from pollution and overuse.The following policies are applicable to the proposed project:
• Cooperate with the South Coast Air Quality Management District (SCAQMD) and other regional agencies to implement and enforce regional air quality management plans. • Support alternative transportation modes, alternative technologies, and bicycle-and pedestrian- friendly neighborhoods to reduce emissions related to vehicular travel. • Encourage development that incorporates pedestrian-and transit-oriented design and landscape elements.
Greenhouse Gas Emissions
This section describes regulations related to global climate change at the federal, State, and local levels.
• SCAQMD. 2024.South Coast AQMD Rule Book.Website: www.aqmd.gov/home/rules-compliance/rules (accessed November 2024).
4 City of Upland. 2015. Upland General Plan,Open Space and Conservation and Circulation Element.
Website: www.uplandca.gov/general-plan-map(accessed November 2024). 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 8 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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Federal Regulations
The United States has historically had a voluntary approach to reducing GHG emissions. However, on April 2, 2007, the United States Supreme Court ruled that the USEPA has the authority to regulate CO2 emissions under the CAA.
Although there currently are no adopted federal regulations for the control or reduction of GHG emissions, the USEPA commenced several actions in 2009 to implement a regulatory approach to global climate change, including the 2009 USEPA final rule for mandatory reporting of GHGs from large GHG emission sources in the United States.Additionally,the USEPA Administrator signed an endangerment finding action in 2009 under the CAA,finding that seven GHGs (CO2, CH4, N20, HFCs, NF3, PFCs, and SF6) constitute a threat to public health and welfare, and that the combined emissions from motor vehicles cause and contribute to global climate change, leading to national GHG emission standards.
State Regulations
CARB is the lead agency for implementing climate change regulations in the State. Since its formation, CARB has worked with the public,the business sector, and local governments to find solutions to California's air pollution problems. Key efforts by the State are described below.
Assembly Bill 32(2006),California Global Warming Solutions Act. California's major initiative for reducing GHG emissions is Assembly Bill (AB) 32, passed by the State Legislature on August 31, 2006.
This effort set a target to reduce GHG emissions to 1990 levels by 2020. CARB has established the level of GHG emissions in 1990 at 427 million metric tons (MMT) of CO2e.The emissions target of 427 MMT CO2e requires the reduction of 169 MMT CO2e from the State's projected business-as- usual 2020 emissions of 596 MMT CO2e.AB 32 requires CARB to prepare a Scoping Plan that outlines the main State strategies for meeting the 2020 deadline and to reduce GHGs that contribute to global climate change. CARB approved the Scoping Plan on December 11, 2008, which contains the main strategies California will implement to achieve the reduction goals and includes CARB-recommended GHG reductions for each emissions sector of the State's GHG inventory.
The CARB approved the First Update to the Climate Change Scoping Plan on May 22, 2014. The First Update identifies opportunities to leverage existing and new funds to further drive GHG emission reductions through strategic planning and targeted low carbon investments.The First Update defines CARB climate change priorities until 2020 and sets the groundwork to reach long-term goals set forth in Executive Orders (EOs) S-3-05 and B-16-2012.The First Update highlights California's progress toward meeting the "near-term" 2020 GHG emission reduction goals as defined in the initial Scoping Plan. It also evaluates how to align the State's "longer-term" GHG reduction strategies with other State policy priorities for water, waste, natural resources, clean energy,transportation, and land use.The CARB released a second update to the Scoping Plan,the 2017 Scoping Plans to reflect the 2030 target that was set by EO B-30-15 and codified by Senate Bill (SB) 32. 5 CARB. 2017. California's 2017 Climate Change Scoping Plan. November. 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 9 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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The 2022 Scoping Plan'was approved in December 2022 and assesses progress toward the statutory 2030 target while laying out a path to achieving carbon neutrality no later than 2045.The 2022 Scoping Plan Update focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State's long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.
The 2022 Scoping Plan focuses on building clean energy production and distribution infrastructure for a carbon-neutral future, including transitioning existing energy production and transmission infrastructure to produce zero-carbon electricity and hydrogen and utilizing biogas resulting from wildfire management or landfill and dairy operations, among other substitutes.The 2022 Scoping Plan states that in almost all sectors, electrification will play an important role.The 2022 Scoping Plan evaluates clean energy and technology options and the transition away from fossil fuels, including adding four times the solar and wind capacity by 2045 and about 1,700 times the amount of current hydrogen supply. As discussed in the 2022 Scoping Plan, EO N-79-20 requires that all new passenger vehicles sold in California be zero-emission by 2035 and that all other fleets transition to zero-emission as fully as possible by 2045, which will reduce the percentage of fossil fuel combustion vehicles.'
Senate Bill 375 (2008). Signed into law on October 1, 2008, SB 375 supplements GHG reductions from new vehicle technology and fuel standards with reductions from more efficient land use patterns and improved transportation. Under the law, CARB-approved GHG reduction targets in February 2011 for California's 18 federally designated regional planning bodies, known as Metropolitan Planning Organizations (MPOs). CARB may update the targets every 4 years and must update them every 8 years. MPOs, in turn, must demonstrate how their plans, policies, and transportation investments meet the targets set by CARB through Sustainable Community Strategies (SCSs).The SCSs are included with the Regional Transportation Plan (RTP), a report required by State law. However, if an MPO finds that its SCS will not meet the GHG reduction targets, it may prepare an Alternative Planning Strategy.The Alternative Planning Strategy identifies the impediments to achieving the targets.
Executive Order B-30-15 (2015). Governor Jerry Brown signed EO B-30-15 on April 29, 2015, which added the immediate target of:
• GHG emissions reduced to 40 percent below 1990 levels by 2030.
All State agencies with jurisdiction over sources of GHG emissions were directed to implement measures to achieve reductions of GHG emissions to meet the 2030 and 2050 targets. CARB was directed to update the AB 32 Scoping Plan to reflect the 2030 target and,therefore, is moving forward with the update process.The mid-term target is critical to help frame the suite of policy 6 CARB. 2022.2022 Scoping Plan Update. May 10.Website:ww2.arb.ca.gov/sites/default/files/2022- 12/2022-sp.pdf(accessed November 2024).
Ibid.
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measures, regulations, planning efforts, and investments in clean technologies and infrastructure needed to continue reducing emissions.
Senate Bill 350(2015)Clean Energy and Pollution Reduction Act. SB 350, signed by Governor Jerry Brown on October 7, 2015, updates and enhances AB 32 by introducing the following set of objectives in clean energy, clean air, and pollution reduction for 2030:
• Raise California's renewable portfolio standard from 33 percent to 50 percent. • Increase energy efficiency in buildings by 50 percent by the year 2030.
The 50 percent renewable energy standard will be implemented by the California Public Utilities Commission for private utilities and by the California Energy Commission for municipal utilities. Each utility must submit a procurement plan showing it will purchase clean energy to displace other nonrenewable resources.The 50 percent increase in energy efficiency in buildings must be achieved through the use of existing energy efficiency retrofit funding and regulatory tools already available to State energy agencies under existing law.The addition made by this legislation requires State energy agencies to plan for and implement those programs in a manner that achieves the energy efficiency target.
Senate Bill 32,California Global Warming Solutions Act of 2016, and Assembly Bill 197. In summer 2016,the Legislature passed, and the Governor signed, SB 32 and AB 197. SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emission reduction target of at least 40 percent below 1990 levels by 2030 contained in Governor Brown's April 2015 EO B-30-15. SB 32 builds on AB 32 and keeps us on the path toward achieving the State's 2050 objective of reducing emissions to 80 percent below 1990 levels, consistent with an Intergovernmental Panel on Climate Change analysis of the emission trajectory that would stabilize atmospheric GHG concentrations at 450 ppm CO2e and reduce the likelihood of catastrophic impacts from climate change.
AB 197, the companion bill to SB 32, provides additional direction to CARB related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 meant to provide easier public access to air emissions data that are collected by CARB was posted in December 2016.
Senate Bill 100. On September 10, 2018, Governor Brown signed SB 100, which raises California's renewable portfolio standard requirements to 60 percent by 2030,with interim targets, and 100 percent by 2045.The bill also establishes a State policy that eligible renewable energy resources and zero-carbon resources supply 100 percent of all retail sales of electricity to California end-use customers and 100 percent of electricity procured to serve all State agencies by December 31, 2045.
Under the bill,the State cannot increase carbon emissions elsewhere in the western grid or allow resource shuffling to achieve the 100 percent carbon-free electricity target.
Executive Order B-55-18. EO B-55-18, signed September 10, 2018, sets a goal "to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter." EO B-55-18 directs CARB to work with relevant State agencies to ensure that future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal.The goal of carbon neutrality by 2045 is in addition to other statewide goals, meaning that not only 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 11 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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should emissions be reduced to 80 percent below 1990 levels by 2050, but that, by no later than 2045,the remaining emissions should be offset by equivalent net removals of CO2e from the atmosphere, including through sequestration in forests, soils, and other natural landscapes.
Assembly Bill 1279.AB 1279 was signed in September 2022 and codifies the State goals of achieving net carbon neutrality by 2045 and maintaining net negative GHG emissions thereafter.This bill also requires California to reduce statewide GHG emissions by 85 percent compared to 1990 levels by 2045 and directs CARB to work with relevant State agencies to achieve these goals.
Title 24, Building Efficiencies Standards,and the California Green Building Standards Code. In November 2008,the California Building Standards Commission established the California Green Building Standards Code (CALGreen) (California Code of Regulations Title 24, Part 11), which sets performance standards for residential and nonresidential development to reduce environmental impacts and to encourage sustainable construction practices. CALGreen addresses energy efficiency, water conservation, material conservation, planning and design, and overall environmental quality.
CALGreen is updated every 3 years and was most recently updated in 2022 to include new mandatory measures for residential as well as nonresidential uses;the new measures took effect on January 1, 2023.
Regional Regulations
Southern California Association of Governments.The Southern California Association of Governments (SCAG) is a regional council consisting of the following six counties: Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura. In total,the SCAG region encompasses 191 cities and more than 38,000 square miles within Southern California. SCAG is the MPO serving the region under federal law and serves as the Joint Powers Authority,the Regional Transportation Planning Agency, and the Council of Governments under State law.As the Regional Transportation Planning Agency, SCAG prepares long-range transportation plans for the Southern California region, including the RTP/SCS and the 2008 Regional Comprehensive Plan.8 On April 4, 2024, SCAG adopted Connect SoCal: The 2024-2050 Regional Transportation Plan/Sustainable Communities Strategy(2024-2050 RTP/SCS).9 In general,the SCS outlines a development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, would reduce vehicle miles traveled from automobiles and light-duty trucks and thereby reduce GHG emissions from these sources. For the SCAG region, CARB has set GHG reduction targets at 8 percent below 2005 per-capita emission levels by 2020 and 19 percent below 2005 per capita emission levels by 2035.The RTP/SCS lays out a strategy for the region to meet these targets. Overall,the SCS is meant to provide growth strategies that will achieve the regional GHG emission reduction targets. Land use strategies to achieve the region's targets 8 Southern California Association of Governments(SCAG).2008.Final 2008 Regional Comprehensive Plan.
Website:scag.ca.gov/sites/main/files/file-attachments/f2008rcp_complete.pdf?1604263359(accessed November 2024).
SCAG. 2020.Connect SoCal:The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments.Website:scag.ca.gov/sites/main/files/file- attachments/0903fconnectsocal-plan_0.pdf?1606001176(accessed November 2024). 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 12 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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include planning for new growth around high-quality transit areas and livable corridors and creating neighborhood mobility areas to integrate land use and transportation and plan for more active lifestyles.10 However, the SCS does not require that local General Plans, Specific Plans, or zoning be consistent with the SCS; instead, it provides incentives to governments and developers for consistency.
South Coast Air Quality Management District. In 2008,the SCAQMD formed a GHG CEQA Significance Threshold Working Group (Working Group)to identify GHG emission thresholds for land use projects that could be used by local lead agencies in the SCAQMD.The Working Group developed several different options that are contained in the SCAQMD 2008 draft guidance document titled Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans (2008)that could be applied by lead agencies. On September 28, 2010, SCAQMD Working Group Meeting No. 15 provided further guidance, including a tiered approach for evaluating GHG emissions for development projects where SCAQMD is not the lead agency. SCAQMD has not presented a finalized version of these thresholds to the governing board.
SCAQMD identifies the emission level for which a project would not be expected to substantially conflict with any State legislation adopted to reduce statewide GHG emissions. As such, the utilization of a service population represents the rates of emissions needed to achieve a fair share of the State's mandated emissions reductions. Overall, SCAQMD identifies a GHG efficiency level that, when applied statewide or to a defined geographic area, would meet the 2020 and post-2020 emission targets required by AB 32 and SB 32. If projects are able to achieve targeted rates of emissions per the service population,the State would be able to accommodate expected population growth and achieve economic development objectives while also abiding by AB 32's emission target and future post-2020 targets.The SCAQMD has established a flowchart for evaluating GHG significance and indicates that when a project is exempt from California Environmental Quality Act (CEQA), no further analysis is required.
Local Regulations
City of Upland General Plan 2010.The City's General Plan'contains extensive policies directly related to GHGs and climate change.This includes measures to improve transit efficiency, reduce truck idling, increase ridesharing, promote mixed land uses, and requiring the implementation of Renewable energy systems,water efficient landscaping, and energy efficient, sustainable building standard.The Open Space and Conservation Element also includes greenhouse gas emissions assessments, monitoring, and reduction policies.
10 SCAG. 2020.Connect SoCal:The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments.Website:scag.ca.gov/sites/main/files/file- attachments/0903fconnectsocal-plan_0.pdf?1606001176(accessed November 2024). 11 City of Upland. 2015. Upland General Plan,Open Space and Conservation Element.Website:
www.uplandca.gov/general-plan-map(accessed November 2024). 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 13 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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METHODOLOGY
Construction Emissions
Construction activities can generate a substantial amount of air pollution. Construction activities are considered temporary; however, short-term impacts can contribute to exceedances of air quality standards. Construction activities include site preparation, earthmoving, and general construction.
The emissions generated from these common construction activities include fugitive dust from soil disturbance and fuel combustion by mobile heavy-duty, diesel-and gasoline-powered equipment, portable auxiliary equipment, and worker commute trips.
LSA used the California Emissions Estimator Model version 2022.1 (CalEEMod) computer program to calculate emissions from on-site construction equipment and emissions from worker and vehicle trips to the site.As mentioned in the Project Description section, construction of the proposed project would include site preparation, grading, building construction, paving, and architectural coating activities, which was included in CalEEMod.This analysis assumes that construction would begin in Spring 2025 and be completed by the end of 2026.The proposed project would require approximately 1,700 tons of roadway debris to be removed from the site and approximately 900 cubic yards of soil to be imported to the site,which was included in CalEEMod. This analysis assumes compliance with SCAQMD Rule 403 measures.12 All other construction details are not yet known; therefore, default assumptions (e.g., construction equipment and construction hauling and vendor truck trips and fleet activities)from CalEEMod were used.
Operational Emissions
This air quality analysis includes estimating emissions associated with long-term operation of the project. Indirect emissions of criteria pollutants with regional impacts would be emitted by project- generated vehicle trips. In addition, localized air quality impacts (i.e., higher CO concentrations or "hot-spots") near intersections or roadway segments in the project vicinity would also potentially occur due to project-generated vehicle trips.
Consistent with SCAQMD guidance for estimating emissions associated with land use development projects, the CalEEMod computer program was used to calculate the long-term operational emissions associated with the project.As discussed in the Project Description section,the proposed project would construct two buildings: a 3,698-square-foot SAWCO headquarters and a 4,066- square-foot maintenance building. Additionally, a maintenance yard, driveway, parking lot, solar cover, landscaping, and utility improvements would be constructed.The headquarters building would feature office space, meeting and conference rooms, a copy room, and a work area.The maintenance building would include storage space, an outdoor welding area, a motor repair room, electrical rooms, an ADA restroom, a locker room, and a maintenance office/break room.Therefore, this analysis was conducted using the CalEEMod land use codes for Government Office Building, Automobile Care Center, and Parking Lot.
12 SCAQMD. 2024.South Coast AQMD Rule Book.Website: www.aqmd.gov/home/rules-compliance/rules (accessed November 2024).
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Greenhouse Gas Emissions
GHG emissions associated with the project would occur over the short term from construction activities, consisting primarily of emissions from equipment exhaust.There would also be long-term GHG emissions associated with project operations, including project-related vehicular exhaust and energy consumption. Recognizing that the field of global climate change analysis is rapidly evolving, the approaches advocated most recently indicate that for determining a project's contribution to GHG emissions, lead agencies should calculate, or estimate, emissions from vehicular traffic, energy consumption, water conveyance and treatment,waste generation, construction activities, and any other significant source of emissions within the project area.The CalEEMod results were used to quantify GHG emissions generated by the proposed project.
THRESHOLDS OF SIGNIFICANCE
The State CEQA Guidelines indicate that a project would normally have a significant adverse air quality impact if project-generated pollutant emissions would do any of the following:
• Conflict with or obstruct implementation of the applicable air quality plan; • Result in a cumulatively considerable net increase of any criteria pollutant for which the project is nonattainment under applicable federal or State ambient air quality standards; • Expose sensitive receptors to substantial pollutant concentrations; or • Result in other emissions (such as those leading to odors) affecting a substantial number of people.
Certain air districts (e.g., SCAQMD) have created guidelines and requirements to conduct air quality analysis.The SCAQMD's current guidelines,the CEQA Air Quality Handbook13 with associated updates, were followed in this assessment of air quality impacts for the proposed project.
Regional Emissions Thresholds
SCAQMD has established daily emission thresholds for construction and operation of proposed projects.The emission thresholds were established based on the attainment status of the Basin with regards to air quality standards for specific criteria pollutants. Because the concentration standards were set at a level that protects public health with an adequate margin of safety, these emission thresholds are regarded as conservative and would overstate an individual project's contribution to health risks.Table C lists the CEQA significance thresholds for construction and operational emissions established for the Basin.
13 SCAQMD. 1993. CEQA Air Quality Handbook. Website: www.agmd.gov/home/rules-compliance/ceqa/air- quality-analysis-handbook/cega-air-quality-handbook-(1993) (accessed November 2024). 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 15 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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Table C: Regional Thresholds for Construction and Operational Emissions Pollutant Emissions Threshold(lbs/day)
Emissions Source VOCs NOx CO SOX PM10 PM2.5 Construction 75 100 550 150 150 55
Operations 55 55 550 150 150 55
Source:Air Quality Significance Thresholds(SCAQMD 2024).Website: www.agmd.gov/docs/default- source/ceqa/handbook/south-coast-aqmd-air-quality-significance-thresholds.pdf(accessed November 2024).
CO=carbon monoxide PM1O=particulate matter less than 10 microns in size lbs/day=pounds per day SCAQMD=South Coast Air Quality Management District NOx=nitrogen oxides SOx=sulfur oxides
PM2.s=particulate matter less than 2.5 microns in size VOCs=volatile organic compounds Projects in the SCAQMD with construction-or operations-related emissions that exceed any of their respective emission thresholds would be considered significant under SCAQMD guidelines.These thresholds,which the SCAQMD developed and which apply throughout the SCAQMD, apply as both project and cumulative thresholds. If a project exceeds these standards, it would be considered to have a project-specific and cumulative impact.
Local Microscale Concentration Standards
The significance of localized project impacts under CEQA depends on whether ambient CO levels in the project vicinity are above or below State and federal CO standards. Because ambient CO levels are below the standards throughout the SCAQMD, a project would be considered to have a significant CO impact if project emissions would result in an exceedance of one or more of the 1-hour or 8-hour standards.The following are applicable local emission concentration standards for CO:
• California State 1-hour CO standard of 20 ppm
• California State 8-hour CO standard of 9 ppm
Localized Impacts Analysis
SCAQMD published its Final Localized Significance Threshold Methodology in July 2008, recommending that all air quality analyses include an assessment of air quality impacts to nearby sensitive receptors.14 This guidance was used to analyze potential localized air quality impacts associated with construction of the proposed project. Localized significance thresholds (LSTs) are developed based on the size or total area of the emission source,the ambient air quality in the Source Receptor Area (SRA), and the distance to the project. Sensitive receptors include residences, schools, hospitals, and similar uses that are sensitive to adverse air quality. As described in the Project Description section and in Table A, the nearest sensitive receptors are 90 feet to the west during construction and 300 feet to the north after construction during operations.
LSTs are based on the ambient concentrations of that pollutant within the project SRA and the distance to the nearest sensitive receptor. For the proposed project,the appropriate SRA for the LST is the Northwest San Bernardino Valley area (SRA 32). SCAQMD provides LST screening tables for 14 SCAQMD. 2008. Final Localized Significance Threshold Methodology.July. 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 16 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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25-, 50-, 100-, 200-, and 500-meter source-receptor distances.As identified above, the closest sensitive receptors nearby the project limits include single-family residential uses located approximately 90 feet from the western boundaries of the project limits. it is assumed that the maximum daily disturbed acreage for the proposed project could be 4.92 acres (the entire site).
Table D lists the emissions thresholds that apply during project construction and operation (derived by interpolating the SCAQMD screening tables).
Table D: SCAQMD Localized Significance Thresholds
Pollutant Emissions Threshold(lbs/day)
Emissions Source NOx CO PM10 PM2.5 Construction(4.92-acres,90-foot distance) 270 2,230 18 9 Operations(4.92-acre site,300-foot distance) 361 4,742 18 5 Source:Final Localized Significance Threshold Methodology(SCAQMD 2008).
CO=carbon monoxide PM.=particulate matter less than 10 microns in size lbs/day=pounds per day PM2.5=particulate matter less than 2.5 microns in size NO,=nitrogen oxides SCAQMD=South Coast Air Quality Management District Greenhouse Gas Thresholds
The State CEQA Guidelines indicate that a project would normally have a significant adverse greenhouse gas emissions impact if the project would:
• Generate GHG emissions, either directly or indirectly,that may have a significant impact on the environment; or
• Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.
Section 15064.4 of the State CEQA Guidelines states that: "A lead agency should make a good-faith effort, based to the extent possible on scientific and factual data,to describe, calculate, or estimate the amount of greenhouse gas emissions resulting from a project." In performing that analysis,the lead agency has discretion to determine whether to use a model or methodology to quantify GHG emissions or to rely on a qualitative analysis or performance-based standards. In making a determination as to the significance of potential impacts,the lead agency then considers the extent to which the project may increase or reduce GHG emissions as compared to the existing environmental setting, whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project, and the extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
To provide guidance to local lead agencies on determining significance for GHG emissions in their CEQA documents, SCAQMD has convened a Working Group. Based on the last Working Group meeting held in September 2010(Meeting No. 15), SCAQMD proposed to adopt a tiered approach for evaluating GHG emissions for development projects where SCAQMD is not the lead agency:
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• Tier 1—Exemptions: If a project is exempt from CEQA, project-level and cumulative GHG emissions are less than significant.
• Tier 2—Consistency with a Locally Adopted GHG Reduction Plan: If the project complies with a GHG emissions reduction plan or mitigation program that avoids or substantially reduces GHG emissions in the project's geographic area (i.e., city or county), project-level and cumulative GHG emissions are less than significant.
• Tier 3—Numerical Screening Threshold: If GHG emissions are less than the numerical screening- level threshold, project-level and cumulative GHG emissions are less than significant.
For projects that are not exempt or where no qualifying GHG reduction plans are directly applicable, SCAQMD requires an assessment of GHG emissions. SCAQMD, under Option 1, is proposing a "bright-line" screening-level threshold of 3,000 metric tons (MT) of CO2e (or MT CO2e) per year(or MT CO2e/year)for all land use types or, under Option 2,the following land use-specific thresholds: 1,400 MT CO2e for commercial projects; 3,500 MT CO2e for residential projects, or 3,000 MT CO2e for mixed-use projects.This bright-line threshold is based on a review of the Governor's Office of Planning and Research (OPR) database of CEQA projects.
Based on their review of 711 CEQA projects, 90 percent of CEQA projects would exceed the bright-line thresholds identified above.Therefore, projects that do not exceed the bright-line threshold would have a nominal and therefore less than cumulatively considerable impact on GHG emissions.
• Tier 4—Performance Standards: If emissions exceed the numerical screening threshold, a more detailed review of the project's GHG emissions is warranted.The SCAQMD has proposed an efficiency target for projects that exceed the bright-line threshold.The current recommended approach is per-capita efficiency targets.The SCAQMD is not recommending use of a percentage emissions reduction target. Instead,the SCAQMD proposes proposed a 2020 efficiency target of
4.8 MT CO2e per year per service population for project-level analyses and 6.6 MT CO2e per year per service population for plan-level projects (e.g., program-level projects such as General Plans).
For the purpose of this analysis,the proposed project will be compared to the threshold of 3,000 MT CO2e per year for all land use types.The project is also evaluated for compliance with the CARB Scoping Plan and SCAG's RTP/SCS.
IMPACT ANALYSIS
This section identifies potential air quality and GHG impacts associated with implementation of the proposed project.
Air Quality Impacts
Air pollutant emissions associated with the project would occur over the short term from construction activities and over the long term from project-related vehicular trips and energy consumption.
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Consistency with Applicable Air Quality Plans
A consistency determination plays an essential role in local agency project review by linking local planning and unique individual projects to the air quality plans. A consistency determination fulfills the CEQA goal of fully informing local agency decision makers of the environmental costs of the project under consideration at a stage early enough to ensure that air quality concerns are addressed. Air quality plan strategies are typically based on projections from local General Plans.
The proposed project would develop an existing undeveloped portion of SAWCO land into new SAWCO headquarters. It is anticipated that approximately 10 people would be employed in the new headquarters.The proposed project is not considered a project of statewide, regional, or area-wide significance (e.g., large-scale projects such as airports, electrical generating facilities, petroleum and gas refineries; a residential development of more than 500 dwelling units; or shopping center or business establishment employing more than 1,000 persons or encompassing more than 500,000 square feet of floor space) as defined in the California Code of Regulations (Title 14, Division 6, Chapter 3,Article 13, Section 15206(b)). Because the proposed project would not be defined as a regionally significant project under CEQA, it does not meet the SCAG's Intergovernmental Review criteria.
To comply with the City's General Plan and zoning regulations, the project will require a General Plan amendment and a zone change. Currently,the project site has an SFR-L General Plan designation and is within the Single-Family Residential 76,500 (RS-7.5) zone.The proposed use is not currently permitted at the site. However,the City plans to revise their General Plan and zoning to accommodate this project.
The City of Upland General Plan is consistent with the SCAG Regional Comprehensive Plan Guidelines15 and the SCAQMD Air Quality Management Plan (AQMP).16 The revisions to accommodate this project will not change that. Pursuant to the methodology provided in the SCAQMD CEQA Air Quality Handbook,17 consistency with the Basin AQMP is affirmed when a project (1)would not increase the frequency or severity of an air quality standards violation or cause a new violation, and (2) is consistent with the growth assumptions in the AQMP. Consistency review is presented as follows:
1. The project would result in short-term construction and long-term operational pollutant emissions that are all less than the CEQA significance emissions thresholds established by SCAQMD, as demonstrated below; therefore, the project would not result in an increase in the frequency or severity of an air quality standards violation or cause a new air quality standards violation.
1s SCAG. 2008.Final 2008 Regional Comprehensive Plan.Website:scag.ca.gov/sites/main/files/file- attachments/f2008rcp_complete.pdf?1604263359 (accessed November 2024). 16 SCAQMD. 2022.2022 Air Quality Management Plan.Website: www.agmd.gov/docs/default-source/clean- air-plans/air-quality-management-plans/2022-air-quality-management-plan/final-2022-agmp/final-2022- agmp.pdf?sfvrsn=16(accessed November 2024).
17 SCAQMD. 1993. CEQA Air Quality Handbook. Website: www.agmd.gov/home/rules-compliance/ceqa/air- quality-analysis-handbook/ceqa-air-quality-handbook-(1993) (accessed November 2024). 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 19 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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2. The CEQA Air Quality Handbook indicates that consistency with AQMP growth assumptions must be analyzed for new or amended General Plan elements, Specific Plans, and significant projects.
Significant projects include airports, electrical generating facilities, petroleum and gas refineries, designation of oil drilling districts, water ports, solid waste disposal sites, and offshore drilling facilities;therefore,the proposed project is not defined as significant. According to SCAG's 2024-2050 RTP/SCS,the City of Upland households and jobs are forecast to increase by approximately 5,700 households and 4,900 jobs, respectively, between 2019 and 2050. Based on information provided by the Project Applicant,the proposed project would have approximately 10 employees.The number of new employees generated by the proposed project would fall within the 4,900 projected jobs for the City.Accordingly, the proposed project's labor demand would not be expected to substantially increase population, households, or employment in Upland since the number of employees associated with the proposed project would be a small fraction (approximately 0.2 percent) of the projected job growth for the City.
Therefore, implementation of the proposed project would not interfere with SCAG's ability to implement the regional strategies outlined in the 2024-2050 RTP/SCS.
Based on the consistency analysis presented above, the proposed project would be consistent with the regional AQMP.
Criteria Pollutant Analysis
The Basin is currently designated as nonattainment for the federal and State standards for 03 and PM2.5. In addition,the Basin is in nonattainment for the PM10 standard.The Basin's nonattainment status is attributed to the region's development history. Past, present, and future development projects contribute to the region's adverse air quality impacts on a cumulative basis. By its very nature, air pollution is largely a cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of an ambient air quality standard. Instead, a project's individual emissions contribute to existing cumulatively significant adverse air quality impacts. If a project's contribution to the cumulative impact is considerable,then the project's impact on air quality would be considered significant.
In developing thresholds of significance for air pollutants, SCAQMD considered the emission levels for which a project's individual emissions would be cumulatively considerable. If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region's existing air quality conditions.Therefore, additional analysis to assess cumulative impacts is not necessary.The following analysis assesses the potential project-level air quality impacts associated with construction and operation of the proposed project.
Construction Emissions. During construction, short-term degradation of air quality may occur due to the release of particulate matter emissions (i.e.,fugitive dust) generated by ground disturbance, paving, and other activities. Emissions from construction equipment are also anticipated and would include CO, nitrogen oxides (NO„), VOC, directly emitted PM2.5 or PM10, and toxic air contaminants such as diesel exhaust particulate matter.
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Project construction activities would include grubbing and land clearing,grading, drainage, utilities, building construction, and paving activities. Sources of fugitive dust would include disturbed soils at the construction site. Unless properly controlled, vehicles leaving the site would deposit dirt and mud on local streets,which could be an additional source of airborne dust after it dries. PM10 emissions would vary from day to day, depending on the nature and magnitude of construction activity and local weather conditions. PM10 emissions would depend on soil moisture, silt content of soil, wind speed, and amount of operating equipment. Larger dust particles would settle near the source, whereas fine particles would be dispersed over greater distances from the construction site.
Water or other soil stabilizers can be used to control dust, resulting in emission reductions of 50 percent or more. SCAQMD has established Rule 403: Fugitive Dust, which would require the applicant to implement measures that would reduce the amount of particulate matter generated during the construction period.The Rule 403 measures that were incorporated in this analysis include:18
• Water active sites at least twice daily(locations where earth disturbance is to occur shall be thoroughly watered prior to earthmoving).
• Cover all trucks hauling dirt, sand, soil, or other loose materials, or maintain at least 2 feet (0.6 meter) of freeboard (vertical space between the top of the load and the top of the trailer) in accordance with the requirements of California Vehicle Code Section 23114. • Reduce traffic speeds on all unpaved roads to 15 miles per hour or less.
In addition to dust-related PM10 emissions, heavy trucks and construction equipment powered by gasoline and diesel engines would generate CO, sulfur oxides (SON), NOR, VOCs, and some soot particulate (PM2.5 and PM10) in exhaust emissions. If construction activities were to increase traffic congestion in the area, CO and other emissions from traffic would increase slightly while those vehicles idle in traffic.These emissions would be temporary in nature and limited to the immediate area surrounding the construction site.
Construction emissions were estimated for the project using CalEEMod and are summarized in Table E. Attachment B includes the CalEEMod output sheets.
The results shown in Table E indicate the proposed project would not exceed the significance criteria for daily VOCs, NOR, CO, SON, PM10, or PM2.5 emissions.Therefore, construction of the proposed project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under an applicable federal or State AAQS. 18 SCAQMD. 2024.South Coast AQMD Rule Book.Website: www.aqmd.gov/home/rules-compliance/rules (accessed November 2024).
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Table E: Short-Term Regional Construction Emissions
Maximum Daily Regional Pollutant Emissions(Ibs/day)
Construction Phase VOC NOx CO SOx Total PM10 Total PM2.s Site Preparation 1.3 12.1 12.7 <1 2.3 1.3 Grading 1.6 14.1 15.3 <1 2.6 1.5 Building Construction 1.1 9.1 11.3 <1 <1 <1 Architectural Coating 0.4 0.9 1.3 <1 <1 <1 Paving 0.5 4.5 7.4 <1 <1 <1
Peak Daily Emissions 1.6 14.1 15.3 <1 2.6 1.5 SCAQMD Threshold 75 100 550 150 150 55 Significant? No No No No No No
Source:Compiled by LSA(November 2024).
Note:The maximum emissions of summer and winter modeling results were used to evaluate construction emissions impacts.
CalEEMod output sheets are provided in Attachment B.Values may not appear to add up correctly due to rounding.
CO=carbon monoxide PMiu=particulate matter less than 10 microns in size lbs/day=pounds per day SCAQMD=South Coast Air Quality Management District NO.=nitrogen oxides SO.=sulfur oxides
PM2.s=particulate matter less than 2.5 microns in size VOC=volatile organic compounds Operational Air Quality Impacts. Long-term air pollutant emissions associated with operation of the proposed project include emissions from area, energy, and mobile sources. Area-source emissions include architectural coatings, consumer products, and landscaping. Energy-source emissions result from utility plants generating electricity used by the project.Typically, energy-source emissions would also include emissions from natural gas consumption, however,the proposed project would not use natural gas. Mobile-source emissions are from vehicle trips associated with operation of the project. Mobile source emissions include VOC and NOx emissions that contribute to the formation of
03.Additionally, PM10 emissions result from running exhaust, tire and brake wear, and the entrainment of dust into the atmosphere from vehicles traveling on paved roadways.
Long-term operational emissions associated with the proposed project were calculated using CalEEMod.The proposed project is a new 3,698-square-foot SAWCO headquarters and associated improvements and a 4,066-square-foot maintenance building, maintenance yard, driveway, parking, solar cover, and landscaping.The SAWCO headquarters was represented in CalEEMod as a Government Office Building and the maintenance building as an Automotive Care Center.
Additionally, a 1.19-acre parking lot was specified to include all pavement onsite and the driveway expansion.The trip generation rates were changed to match the Traffic Impact Analysis,19 the natural gas use was set to zero with the electricity use increased to result in the same energy consumption, and all other parameters were left at CalEEMod defaults.
Table F provides the estimated existing emission estimates and the proposed project's estimated operational emissions.
19 LSA Associates, Inc. (LSA). 2024. Traffic Impact Analysis San Antonio Water Headquarters Project.
November.
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Table F: Project Operational Emissions
Emission Type Pollutant Emissions(lbs/day)
VOCs NOx CO SOX PM10 PM2.5
Mobile Sources 0.4 0.5 4.5 <0.1 1.1 0.3
Area Sources 0.2 <0.1 0.3 <0.1 <0.1 <0.1
Energy Sources 0 0 0 0 0 0
Total Project Emissions 0.6 0.5 4.8 <0.1 1.1 0.3 SCAQMD Threshold 55 55 550 150 150 55
Exceeds Threshold? No No No No No No
Source:Compiled by LSA(November 2024).
Note:The maximum of summer and winter modeling results were used to evaluate the operational emission impacts.
CalEEMod output sheets are provided in Attachment B.Some values may not appear to add correctly due to rounding.
CO=carbon monoxide PM.=particulate matter less than 10 microns in size lbs/day=pounds per day SCAQMD=South Coast Air Quality Management District NOx=nitrogen oxides SOx=sulfur oxides
PM2.5=particulate matter less than 2.5 microns in size VOCs=volatile organic compounds The results shown in Table F indicate the proposed project would not exceed the significance criteria for daily VOC, NOR, CO, SON, PM10, or PM2.5 emissions.Therefore, operation of the proposed project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is in nonattainment under applicable NAAQS or CAAQS.
Long-Term Microscale(CO Hot-Spot)Analysis.Vehicular trips associated with the proposed project would contribute to congestion at intersections and along roadway segments in the vicinity of the proposed project site. Localized air quality impacts would occur when emissions from vehicular traffic increase as a result of the proposed project.The primary mobile-source pollutant of local concern is CO, a direct function of vehicle idling time and,thus, of traffic flow conditions. CO transport is extremely limited. Under normal meteorological conditions, it disperses rapidly with distance from the source. However, under certain extreme meteorological conditions, CO concentrations near a congested roadway or intersection may reach unhealthful levels,thereby affecting local sensitive receptors (e.g., residents, schoolchildren, the elderly, and hospital patients).
Typically, high CO concentrations are associated with roadways or intersections operating at unacceptable levels of service or with extremely high traffic volumes. In areas with high ambient background CO concentrations, modeling is recommended to determine a project's effect on local CO levels.
An assessment of project-related impacts on localized ambient air quality requires that future ambient air quality levels be projected. Existing CO concentrations in the immediate project vicinity are not available.Ambient CO levels monitored at the Fontana-Arrow Highway station (the closest station to the project site), showed a highest recorded 1-hour concentration of 1.9 ppm (the State standard is 20 ppm) and a highest 8-hour concentration of 1.4 ppm (the State standard is 9 ppm) from 2021 to 2023 (see Attachment C).The highest CO concentrations would normally occur during peak traffic hours; hence, CO impacts calculated under peak traffic conditions represent a worst- case analysis. Reduced speeds and vehicular congestion at intersections result in increased CO emissions.
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The proposed project is expected to generate 85 new average daily trips, with 8 net new trips occurring in the a.m. peak hour and 10 net new trips occurring in the p.m. peak hour.20 Therefore, given the extremely low level of CO concentrations in the project area and the lack of traffic impacts at any intersections, project-related vehicles are not expected to result in CO concentrations exceeding the State or federal CO standards. No CO hot spots would occur, and the project would not result in any project-related impacts on CO concentrations.
Localized Significance Thresholds Analysis
An LST analysis was completed to show the construction and operational impacts to the nearest sensitive receptors to the project site, based on a 4.92-acre daily disturbance area for construction and a 4.92-acre area for operations.As described in the Project Description section and in Table A, the nearest sensitive receptors are 90 feet to the west during construction and 300 feet to the north after construction during operations.
By design,the localized impact analysis only includes on-site sources; however,the CalEEMod outputs do not separate on-site and off-site emissions for mobile sources. For a worst-case scenario assessment,the emissions detailed in Table G assume all area-and energy-source emissions would occur on site, and 5 percent of the project-related new mobile sources (which is an estimate of the amount of project-related vehicle travel would occur on site). Considering the total trip length included in CalEEMod,the 5 percent assumption is conservative.Table G shows the results of the LST analysis during project construction and operation.
Table G: Project Localized Construction and Operational Emissions Pollutant Emissions(lbs/day)
Source NOx CO PM10 PM2.5
Construction Emissions
On-Site Emissions 14 15 3 2
Localized Significance Threshold 270 2,230 18 9 Significant? No No Yes Yes
Operational Emissions
On-Site Emissions <1 <1 <0.1 <0.1
Localized Significance Threshold 361 4,742 18 5 Significant? No No No No
Source:Compiled by LSA(November 2024).
Note:Source Receptor Area 32,emissions based on construction disturbing the entire site and operations occurring on the full project site.LSTs at a distance of 90 feet for construction and 300 feet for operations.
CO=carbon monoxide PM2.s=particulate matter less than 2.5 microns in size lbs/day=pounds per day Mho=particulate matter less than 10 microns in size NOx=nitrogen oxides
As shown in Table G,the proposed project would not result in an exceedance of a SCAQMD LST during project construction or operation. During construction, construction contractors would be required to implement measures to reduce or eliminate emissions by implementing SCAQMD Rule 20 LSA. 2024. Traffic Impact Analysis San Antonio Water Headquarters Project. November. 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 24 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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403 dust control measures.21 In addition,the maximum daily emissions associated with project construction emissions are identified in Table E and indicate the project would not exceed the significance criteria for VOCs, NO, CO, SOx, PM10, or PM2.5 emissions.Therefore,the emissions associated with construction of the proposed project would not be expected to exceed the most stringent applicable federal or State ambient air quality standards. It should be noted that the ambient air quality standards are developed and represent levels at which the most susceptible persons (children and the elderly) are protected. In other words,the ambient air quality standards are purposefully set low to protect children,the elderly, and those with existing respiratory problems.Therefore,given the temporary nature of short-term construction impacts, and the absence of any exceeded threshold of significance related to construction impacts, construction of the proposed project would not exceed SCAQMD thresholds and would not expose nearby sensitive receptors to substantial pollutant concentrations. No significant health risk would occur from project construction emissions.
Similarly, as indicated in Table F, operation of the proposed project would not exceed the significance criteria for VOCs, NO, CO, SOx, PM10, or PM2.5 emissions.
The SCAQMD's numeric regional mass daily emissions thresholds are based in part on Section 180 (e) of the federal Clean Air Act. It should be noted that the numeric regional mass daily emissions thresholds have not changed since their adoption as part of SCAQMD's CEQA Air Quality Handbook published in 1993 (over 30 years ago).22 The numeric regional mass daily emission thresholds are also intended to provide a means of consistency in significance determination within the environmental review process.
As noted in the Brief of Amicus Curiae by the SCAQMD,23 the SCAQMD has acknowledged that for criteria pollutants, it would be extremely difficult, if not impossible,to quantify health impacts for various reasons, including modeling limitations as well as where in the atmosphere air pollutants interact and form.
Additionally,the SCAQMD acknowledges that health effects quantification from 03, as an example, is correlated with the increases in ambient levels of 03 in the air(concentration)that an individual person breathes.The SCAQMD goes on to state that it would take a large amount of additional emissions to result in a modeled increase in ambient 03 levels over the entire region.The SCAQMD states that based on its own modeling in its 2012 AQMP,24 a reduction of 432 tons (864,000 pounds) per day of NOx and a reduction of 187 tons (374,000 pounds) per day of VOCs would reduce 03 levels 21 SCAQMD. 2024.South Coast AQMD Rule Book.Website: www.aqmd.gov/home/rules-compliance/rules (accessed November 2024).
22 SCAQMD. 1993. CEQA Air Quality Handbook. Website: www.agmd.gov/home/rules-compliance/ceqa/air- quality-analysis-handbook/ceqa-air-quality-handbook-(1993) (accessed November 2024). 23 SCAQMD. 2015.Amicus Curiae Brief of South Coast Air Quality Management District.April.Website:
www.courts.ca.gov/documents/9-s219783-ac-south-coast-air-quality-mgt-dist-041315.pdf(accessed November 2024).
24 SCAQMD. 2012. Final 2012 Air Quality Management Plan.Website: https://www.agmd.gov/home/air- quality/air-quality-management-plans/air-quality-mgt-plan/final-2012-air-quality-management-plan (accessed November 2024).
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at the highest monitored site by only 9 parts per billion (ppb).As such,the SCAQMD concludes that it is not currently possible to accurately quantify 03-related health impacts caused by NOx or VOC emissions from relatively small projects (defined as projects that are not regional in scope) due to photochemistry and regional model limitations (see page 11 of the SCAQMD Brief of Amicus Curiae).
To underscore this point, the SCAQMD goes on to state that it has only been able to correlate potential health outcomes for very large emissions sources. As part of its rulemaking activity, specifically 6,620 pounds per day(lbs/day) of NOx and 89,180 lbs/day of VOCs were expected to result in approximately 20 premature deaths per year and 89,947 school absences due to 03.As identified in Tables E and F, NOx and VOC emissions during project construction and operation would be well below 6,620 lbs/day of NOx and 89,180 lbs/day of VOCs.
Due to the small size of the proposed project in relation to the overall Basin,the level of emissions is not sufficiently high to use a regional modeling program to correlate health effects on a Basin-wide level. On a regional scale,the quantity of emissions from the project is incrementally minor. Because the SCAQMD has not identified any other methods to quantify health impacts from small projects and due to the size of the project, it is speculative to assign any specific health effects to small project-related emissions. However, based on this localized analysis,the proposed project would not expose sensitive receptors to substantial pollutant concentrations.Therefore,the project would not expose sensitive receptors to substantial levels of pollutant concentrations, impacts would be less than significant.
Odors
Heavy-duty equipment on the project site during construction would emit odors, primarily from equipment exhaust. However,the construction activity would cease after individual construction is completed. No other sources of objectionable odors have been identified for the proposed project during construction.
The proposed project would be required to comply with SCAQMD Rule 402. SCAQMD Rule 402 regarding nuisances states, "A person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property."' Examples of odor-generating projects are wastewater treatment plants, compost facilities, landfills, solid-waste transfer stations,fiberglass manufacturing facilities, paint/coating operations (e.g., auto body shops), dairy farms, petroleum refineries, asphalt batch plants, chemical manufacturing, and food manufacturing facilities.The proposed project would include a 1,350 sf Starbucks coffee shop with drive-through and associated improvements;therefore,the proposed project would not include land uses that would be expected to generate odors. 25 SCAQMD. 2024.South Coast AQMD Rule Book.Website: www.aqmd.gov/home/rules-compliance/rules (accessed November 2024).
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Once operational, the proposed project would involve minor odor-generating activities (e.g.,trash, landscape equipment, application of exterior paints, etc.). However, unlike the odor-generating land uses identified above,these are not considered potential generators of odor that could affect a substantial number of people. Further, project-generated refuse would be stored in covered containers and would be removed at regular intervals to minimize odors. In addition,the proposed project be required to comply with the CalRecycle waste diversion program and recycling of solid and organic waste.Therefore, operational uses are not anticipated to emit any objectionable odors.
Therefore,the proposed project would not result in other emissions (e.g.,those leading to odors) adversely affecting a substantial number of people.
Greenhouse Gas Emission Impacts
The following sections describe the proposed project's construction-and operation-related GHG impacts and consistency with applicable GHG reduction plans.
Generation of Greenhouse Gas Emissions
This section describes the proposed project's construction-and operation-related GHG emissions and contribution to global climate change.The SCAQMD has not addressed emission thresholds for construction in its CEQA Air Quality Handbook; however, SCAQMD requires quantification and disclosure.Thus,this section discusses construction emissions.
Construction Greenhouse Gas Emissions. Construction activities associated with the proposed project would produce combustion emissions from various sources. Construction would emit GHGs through the operation of construction equipment and from worker and builder supply vendor vehicles for the duration of the approximately 15-month construction period. The combustion of fossil-based fuels creates GHGs such as CO2, CH4, and N20. Furthermore,the fueling of heavy equipment emits CH4. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change.
As indicated above, SCAQMD does not have an adopted threshold of significance for construction- related GHG emissions. However, lead agencies are required to quantify and disclose GHG emissions that would occur during construction.The SCAQMD then requires the construction GHG emissions to be amortized over the life of the project (which is defined as 30 years), added to the operational emissions, and compared to the applicable interim GHG significance threshold tier. Based on CalEEMod, it is estimated that the project would generate 396 MT CO2e during construction of the project. When amortized over the 30-year life of the project, annual emissions would be 13 MT CO2e.
Operational Greenhouse Gas Emissions. Long-term GHG emissions are typically generated from mobile sources (e.g., cars,trucks, and buses), area sources (e.g., maintenance activities and landscaping), indirect emissions from sources associated with energy consumption, and refrigerant fugitive emissions.
As described in the Project Description section above,the proposed project is a new 3,698-square- foot SAWCO headquarters and associated improvements and a 4,066-square-foot maintenance building, maintenance yard, driveway, parking, solar cover, and landscaping. 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 27 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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As discussed in the traffic memorandum26 for the proposed project, upon completion of construction activities, operation of the proposed project would result in approximately 85 new daily vehicle trips.
GHG emissions were estimated using CalEEMod.Table H shows the estimated operational GHG emissions for the proposed project. Motor vehicle emissions are the largest source of GHG emissions for the project, at approximately 49 percent of the project total. Refrigerant sources are the next largest category, at approximately 35 percent. Energy, water, and waste sources represent approximately 14 percent, 1 percent, and 2 percent of the total emissions, respectively. Area sources make up less than 1 percent of the total emissions.
Table H: Greenhouse Gas Emissions
Operational Emissions(MT/yr)
Emission Type
CO2 CH4 N20 Refrigerant CO2e Percentage of Total Mobile Source 190 <0.1 <0.1 — 193 49
Area Source <1 <0.1 <0.1 — <1 <1
Energy Source 55 <0.1 <0.1 — 56 14
Water Source 3 <0.1 <0.1 — 4 1
Waste Source 2 <0.1 <0.1 — 6 2
Refrigerant Source — — — 140 140 35 _ Total Operational Emissions 399
Amortized Construction Emissions 13
Total Annual Emissions 412
SCAQMD Threshold 3,000
Exceedance? No
Source:Compiled by LSA(November 2024).
Note:Figures may not appear to add correctly due to rounding.
CH4=methane MT/yr=metric tons per year
CO2=carbon dioxide N20=nitrous oxide
CO2e=carbon dioxide equivalent SCAQMD=South Coast Air Quality Management District As discussed above, a project would have less than significant GHG emissions if it would result in operational-related GHG emissions of less than 3,000 MT CO2e per year. Based on the analysis results, the proposed project would result in approximately 412 MT CO2e per year, which would not exceed the SCAQMD threshold of 3,000 MT CO2e per year.Therefore, project-level and cumulative GHG emissions would be less than significant, and operation of the proposed project would not generate GHG emissions that would have a significant effect on the environment.
Consistency with Greenhouse Gas Reduction Plans
The following discussion evaluates the proposed project according to the goals of the 2022 Scoping Plan and SCAG's 2020-2045 RTP/SCS.
2022 Scoping Plan. EO B-30-15 added the immediate target of reducing GHG emissions to 40 percent below 1990 levels by 2030. SB 32 affirms the importance of addressing climate change by 26 LSA. 2024. Traffic Impact Analysis San Antonio Water Headquarters Project. November. 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 28 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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codifying into statute the GHG emissions reduction target of at least 40 percent below 1990 levels by 2030 contained in EO B-30-15. CARB released the 2017 Scoping Plan to reflect the 2030 target set by EO B-30-15 and codified by SB 32.27 SB 32 builds on AB 32 and keeps California on the path toward achieving the State's 2050 objective of reducing emissions to 80 percent below 1990 levels.
AB 197, the companion bill to SB 32, provides additional direction to CARB that is related to the adoption of strategies to reduce GHG emissions. Additional direction in AB 197 that is intended to provide easier public access to air emission data collected by CARB was posted in December 2016.
AB 1279 codifies the State goals of achieving net carbon neutrality by 2045 and maintaining net negative GHG emissions thereafter.
In addition, the 2022 Scoping Plan28 assesses progress toward the statutory 2030 target while laying out a path to achieving carbon neutrality no later than 2045.The 2022 Scoping Plan focuses on outcomes needed to achieve carbon neutrality by assessing paths for clean technology, energy deployment, natural and working lands, and others, and is designed to meet the State's long-term climate objectives and support a range of economic, environmental, energy security, environmental justice, and public health priorities.
The 2022 Scoping Plan focuses on building clean energy production and distribution infrastructure for a carbon-neutral future, including transitioning existing energy production and transmission infrastructure to produce zero-carbon electricity and hydrogen, and utilizing biogas resulting from wildfire management or landfill and dairy operations, among other substitutes.The 2022 Scoping Plan states that in almost all sectors, electrification will play an important role. The 2022 Scoping Plan evaluates clean energy and technology options and the transition away from fossil fuels, including adding four times the solar and wind capacity by 2045 and about 1,700 times the amount of current hydrogen supply. As discussed in the 2022 Scoping Plan, EO N-79-20 requires that all new passenger vehicles sold in California be zero-emission by 2035 and that all other fleets transition to zero-emission as fully as possible by 2045, which will reduce the percentage of fossil fuel combustion vehicles.
• Energy-efficient measures are intended to maximize energy efficiency building and appliance standards, pursue additional efficiency efforts including new technologies and new policy and implementation mechanisms, and pursue comparable investment in energy efficiency from all retail providers of electricity in California. In addition,these measures are designed to expand the use of green building practices to reduce the carbon footprint of California's new and existing inventory of buildings.The proposed project would develop an existing undeveloped portion of SAWCO land into new SAWCO headquarters.As mentioned above, the proposed project would not be powered by natural gas, and no natural gas would be used during construction or operation of the proposed project. The elimination of natural gas in new development would help projects implement their"fair share" of achieving long-term 2045 carbon neutrality consistent with State goals. As such, if a project does not use natural gas, a lead agency can conclude that it would be consistent with achieving the 2045 neutrality goal and 27 CARB. 2022.2022 Scoping Plan for Achieving Carbon Neutrality. December.Website:ww2.arb.ca.gov/ sites/default/files/2023-04/2022-sp.pdf(accessed November 2024). 28 CARB. 2017. California's 2017 Climate Change Scoping Plan. November. 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 29 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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will not have a cumulative considerable impact on climate change.The proposed project does not include natural gas. In addition,the proposed project would comply with the latest Title 24 standards regarding energy conservation and green building standards.Therefore, the proposed project would comply with applicable energy measures.
• Water conservation and efficiency measures are intended to continue efficiency programs and use cleaner energy sources to move and treat water. Increasing the efficiency of water transport and reducing water use would reduce GHG emissions.As noted above,the project would be required to comply with the latest Title 24 standards, which include a variety of different measures, including reduction of wastewater and water use. The proposed project would also include low water landscape in their design. In addition,the proposed project would be required to comply with the California Model Water Efficient Landscape Ordinance.Therefore,the proposed project would not conflict with any of the water conservation and efficiency measures. • The goal of transportation and motor vehicle measures is to develop regional GHG emissions reduction targets for passenger vehicles. Specific regional emission targets for transportation emissions would not directly apply to the proposed project. However,vehicles traveling to the project site would comply with the Pavley II (LEV III) Advanced Clean Cars Program.The second phase of Pavley standards reduces GHG emissions from new cars by 34 percent from 2016 levels by 2025, resulted in a 3 percent decrease in average vehicle emissions for all vehicles as of 2020.
Therefore, the proposed project would not conflict with the identified transportation and motor vehicle measures.
The proposed project would comply with existing State regulations adopted to achieve the overall GHG emission reduction goals identified in the 2022 Scoping Plan, EO B-30-15, SB 32, AB 197, and AB 1279.
SCAG's Regional Transportation Plan/Sustainable Communities Strategy.SCAG's 2024-2050 RTP/SCS29 identifies land use strategies that focus on new housing and job growth in areas served by high-quality transit, and other opportunity areas would be consistent with a land use development pattern that supports and complements the proposed transportation network.The core vision in the 2024-2050 RTP/SCS is to better manage the existing transportation system through design management strategies, integrate land use decisions and technological advancements, create complete streets that are safe for all roadway users, preserve the transportation system, and expand transit and foster development in transit-oriented communities.The 2024-2050 RTP/SCS contains transportation projects to help more efficiently distribute population, housing, and employment growth, as well as providing a forecast development pattern that is generally consistent with regional-level General Plan data.The forecast development pattern, when integrated with the financially constrained transportation investments identified in the 2024-2050 RTP/SCS, would reach the regional target of reducing GHG emissions from automobiles and light- duty trucks by 8 percent by 2020 and 19 percent by 2035 (compared to 2005 levels per capita 29 SCAG. 2020.Connect SoCal:The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments.Website:scag.ca.gov/sites/main/files/file- attachments/0903fconnectsocal-plan_0.pdf?1606001176(accessed November 2024). 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 30 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
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emission levels).The 2024-2050 RTP/SCS does not require that local General Plans, Specific Plans, or zoning be consistent with the 2024-2050 RTP/SCS, but it provides incentives for consistency for governments and developers.
Implementing SCAG's RTP/SCS will greatly reduce the regional GHG emissions from transportation, helping to achieve statewide emissions reduction targets.As demonstrated in the Consistency with Applicable Air Quality Plans section,the proposed project does not meet the criteria identified in State CEQA Guidelines Section 15205.b.2 (Projects of Statewide, Regional, or Areawide Significance) for projects of statewide, regional, or areawide significance. In addition, while the proposed project would require a change to the General Plan land use designation and the current zoning, the City plans to update both the General Plan and zoning to accommodate the project. As demonstrated in Table H, the proposed project would not generate significant levels of GHGs,thus would not interfere with SCAG's ability to achieve the region's GHG reduction target of 19 percent below 2005 per capita emissions levels by 2035. Furthermore,the proposed project is not regionally significant per State CEQA Guidelines Section 15206, and, as such, it would not conflict with the SCAG RTP/SCS targets since those targets were established and are applicable on a regional level.
CONCLUSION
Based on the analysis presented above, construction and operation of the proposed project would not result in the generation of criteria air pollutants that would exceed SCAQMD thresholds of significance. Compliance with SCAQMD Rule 403: Fugitive Dust30 would further reduce construction dust impacts. Emissions released during construction of the proposed project are estimated to be minimal and would not be cumulatively considerable.The proposed project is not expected to produce significant emissions that would affect nearby sensitive receptors.The proposed project would also not result in objectionable odors affecting a substantial number of people. GHG emissions released during construction and operation of the project are estimated to be minimal and would not be cumulatively considerable. In addition,the proposed project would generally be consistent with both the CARB Scoping Plan31 and the SCAG RTP/SCS.32 Attachments: A: Figures
B: CalEEMod Output
C: Fontana-Arrow Highway Air Quality Monitoring Data
3° SCAQMD. 2024.South Coast AQMD Rule Book.Website: www.agmd.gov/home/rules-compliance/rules (accessed November 2024).
31 CARB. 2022.2022 Scoping Plan for Achieving Carbon Neutrality. December.Website:ww2.arb.ca.gov/ sites/default/files/2023-04/2022-sp.pdf(accessed November 2024). 32 SCAG. 2020.Connect SoCal:The 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy of the Southern California Association of Governments.Website:scag.ca.gov/sites/main/files/file- attachments/0903fconnectsocal-plan_O.pdf?1606001176(accessed November 2024). 11/19/24 s\\aznasunifiler2\projects\2024\20241723_San Antonio Driveway Expansion\PRODUCTS\Technical Studies\Air Quality and GHG\Draft Report\ 31 20241723 San Antonio Driveway Expansion-AQ Memo_RLSO.docxx
AIR QUALITY AND GREENHOLISE GAS TECHNICAL MEMORANDUM SAN ANTONIO WATER HEADQUARTERS L I SA NOVEMBER 2024 UPLANO,CALIFORNIA
ATTACHMENT A
FIGURES
Figure 1: Project Location and Vicinity
Figure 2: Site Plan
Figure 3: Project Location
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AIR QUALITY AND GREE.NHOLISE GAS TECHNICAL MEMORANDUM SAN ANTONIO WATER HEADQUARTERS [A NOVEMBER 2024 UPLANO,CALIFORNIA 'll7
ATTACHMENT B
CALEEMOD OUTPUT
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San Antonio Water HQ Custom Report, 11/7/2024
San Antonio Water HQ Custom Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
3. Construction Emissions Details
3.1. Site Preparation (2025) - Unmitigated
3.3. Grading (2025) - Unmitigated
3.5. Building Construction (2025) - Unmitigated
3.7. Building Construction (2026) - Unmitigated
3.9. Paving (2026) - Unmitigated
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San Antonio Water HQ Custom Report, 11/7/2024
3.11. Architectural Coating (2026) - Unmitigated
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.3. Area Emissions by Source
4.3.1. Unmitigated
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
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5.2.1. Unmitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.10. Operational Area Sources
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
5.11. Operational Energy Consumption
5.11.1. Unmitigated
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5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
8. User Changes to Default Data
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1 . Basic Project Information
1 .1 . Basic Project Information
Data Field Value
Project Name San Antonio Water HQ
Construction Start Date 4/1/2025
Operational Year 2026
Lead Agency Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.80
Precipitation (days) 2.20
Location 34.13563245525083, -117.64489903150591 County San Bernardino-South Coast
City Upland
Air District South Coast AQMD
Air Basin South Coast
TAZ 5225
EDFZ 10
Electric Utility Southern California Edison Gas Utility Southern California Gas
App Version 2022.1.1.28
1 .2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area(sq ft) Landscape Area(sq Special Landscape Population Description ft) Area(sq ft)
Government Office 3.70 1000sgft 0.08 3,698 26,077 0.00 — Main Building Building Page 666 of 1374
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Automobile Care 4.07 1000sgft 0.09 4,066 20,000 0.00 - Maintenance Center Building
Parking Lot 51.7 1000sgft 1.19 0.00 0.00 0.00 - Total Paving 1 .3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected
2. Emissions Summary
2.1 . Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily, - - - - - - - - - - - - - - - Summer
(Max)
Unmit. 1.56 14.1 15.3 0.02 0.64 1.97 2.62 0.59 0.92 1.51 - 2,596 2,596 0.11 0.03 0.95 2,606 Daily, - - - - - - - - - - - - - - - - - Winter
(Max)
Unmit. 1.47 9.55 12.1 0.02 0.33 0.25 0.56 0.30 0.06 0.35 - 2,201 2,201 0.09 0.03 0.02 2,212 Average - - - - - - - - - - - - - - - -Daily (Max)
Unmit. 0.79 5.38 7.15 0.01 0.19 0.15 0.33 0.17 0.04 0.21 - 1,266 1,266 0.05 0.02 0.24 1,273 Annual - - - - - - - - - - - - - - - - - (Max)
Unmit. 0.14 0.98 1.31 < 0.005 0.03 0.03 0.06 0.03 0.01 0.04 - 210 210 0.01 <0.005 0.04 211 Exceeds - - - - - - - - - - - - - - - - - (Daily
Max)
Threshol 75.0 100 550 150 - - 150 - - 55.0 - - - - - - - d
Unmit. No No No No No - - No - - - - - Page�67 of 1374 6/35
San Antonio Water HQ Custom Report, 11/7/2024
Exceeds - - - - -
(Average
Daily)
Threshol 75.0 100 550 150 - - 150 - - 55.0
d
Unmit. No No No No - - No - - No - - - - - - -
2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year ROG NOx CO SO2 PM10E PM10D PM1OT PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 R CO2e Daily- - - - - - - - - - - - - - - - - - Summer
(Max)
2025 1.56 14.1 15.3 0.02 0.64 1.97 2.62 0.59 0.92 1.51 - 2,596 2,596 0.11 0.03 0.95 2,606 2026 1.48 9.54 12.4 0.02 0.32 0.25 0.56 0.29 0.06 0.35 - 2,222 2,222 0.09 0.03 0.95 2,234 Daily- - - - - - - - - - - - - - - - - - Winter
(Max)
2025 1.14 9.07 11.0 0.02 0.33 0.22 0.55 0.30 0.05 0.35 - 2,047 2,047 0.09 0.03 0.02 2,058 2026 1.47 9.55 12.1 0.02 0.32 0.25 0.56 0.29 0.06 0.35 - 2,201 2,201 0.08 0.03 0.02 2,212 Average
Daily
2025 0.62 4.96 6.01 0.01 0.18 0.15 0.33 0.17 0.04 0.21 - 1,111 1,111 0.05 0.02 0.22 1,117 2026 0.79 5.38 7.15 0.01 0.19 0.15 0.33 0.17 0.04 0.21 - 1,266 1,266 0.05 0.02 0.24 1,273 Annual - - - - - - - - - - - - - - - - - 2025 0.11 0.91 1.10 < 0.005 0.03 0.03 0.06 0.03 0.01 0.04 - 184 184 0.01 <0.005 0.04 185 2026 0.14 0.98 1.31 <0.005 0.03 0.03 0.06 0.03 0.01 0.04 - 210 210 0.01 <0.005 0.04 211
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. ROG NOx CO SO2 PM10E PM10D PM1OT PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N20 [: CC2e 7/35
San Antonio Water HQ Custom Report, 11/7/2024
Daily, - - - - - -
Summer
(Max)
Unmit. 0.61 0.46 4.84 0.01 0.01 1.04 1.05 0.01 0.26 0.27 12.4 1,567 1,579 1.31 0.06 847 2,477 Daily, - - - - - - - - - - - - - - - -Winter (Max)
Unmit. 0.53 0.49 3.66 0.01 0.01 1.04 1.05 0.01 0.26 0.27 12.4 1,489 1,501 1.31 0.06 843 2,395 Average - - - - - - - - - - - - - - - - - Daily
(Max)
Unmit. 0.57 0.50 4.04 0.01 0.01 1.04 1.05 0.01 0.26 0.27 12.4 1,502 1,514 1.31 0.06 845 2,410 Annual
(Max)
Unmit. 0.10 0.09 0.74 < 0.005 <0.005 0.19 0.19 < 0.005 0.05 0.05 2.05 249 251 0.22 0.01 140 399 Exceeds - - - - - - - - - - - - - - - - - (Daily
Max)
Threshol 55.0 55.0 550 150 - - 150 - - 55.0 - - - - - - - d
Unmit. No No No No - - No - - No - - - - - Exceeds - - - - - - - - - - - - (Average
Daily)
Threshol 55.0 55.0 550 150 - - 150 - - 55.0 - - - - - - - d
Unmit. No No No No - - No - - No - - - - - - - Exceeds - - - - - - - - - - - - - - - - - (Annual)
Threshol - - - - - - - - - - - - - - - - 3,000 d
Unmit. - - - - - - - - - - - - - - No