JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
November 19, 2024
Cristobal Carrillo, Associate Planner
City of Visalia
707 W. Acequia Ave.
Visalia, CA 93291
RE: Appeal of Conditional Use Permit No. 2024-17
Dear Cristobal Carrillo:
JK Consulting Group prepared the following response to comments associated with the Appeal of Conditional Use Permit (CUP) No. 2024-17. The Project includes the development of a gas station with approximately fourteen (14) multi-pump dispensers/fuel canopy along with a kiosk and underground storage tanks. The Project site is located at the southwest corner of Visalia Parkway and Mooney Boulevard (State Route 63). Approximately 7.5 million gallons of gasoline and 1.2 million gallons of diesel fuel will be sold annually. To address comments related to the appeal of CUP No. 2024-17, JK Consulting Group provides the following response(s) to comments as noted in Exhibit 1 and Exhibit 2 attached to this letter.
When evaluating a project’s impact to adjacent sensitive receptors, those who are susceptible to adverse health effects from exposure to toxic air contaminants (children, elderly, the ill, schools, libraries, day care centers, nursing homes, retirement homes, health clinics, and hospitals), the first step is to evaluate the project against available screening tools/methodologies. In evaluating the proposed Project, the first step included a comparison of the Project to Table 1, which provides recommendations for siting ‘new sensitive land uses’ within proximity to facilities known to generate toxic air contaminants (TACs). While the Project proposes a facility known to generate TACs to be located adjacent to sensitive land uses, Table 1 may be used as a screening tool to determine if further analysis of the Project is warranted. In this case, the Project is located within 300 feet of sensitive receptors and does not meet the ‘recommendations’ of Table 1 and must provide a site-specific analysis of impacts to sensitive receptors. It should be noted that the ‘recommendations’ in Table 1 are advisory, as noted in the footnotes of Table 1, and would not supersede site-specific analysis which determines the actual risk from a particular facility.
The next or second step is to perform a Prioritization Analysis consistent with California Air Pollution Control Officers Association’s (CAPCOA) methodology. The San Joaquin Valley Air Pollution Control District (SJVAPCD), the agency responsible for monitoring and regulating air pollutant emissions from stationary, area, and indirect sources within Tulare County, created a prioritization calculator based on CAPCOA guidelines which may be used to evaluate a projects potential impact to sensitive receptors. “Prioritization” results are a conservative health risk representation and the SJVAPCD recommends a more refined analysis be performed for any project resulting in a Prioritization score of 10 or greater.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
The storage and combustion of fuel at the Project site poses potential health risks associated with Benzene, Toluene, Xylenes, Ethyl Benzene, Hexane, Naphthalene, Propylene (propene) exposure in addition to Diesel Particulate Matter (DPM). Toxic emissions associated with Project operations were used as inputs to the SJVAPCD Prioritization Calculator which generated a prioritization score of 8.62 for the Project. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.62 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. Based upon SJVAPCD guidance, TAC emissions associated with the Project are considered less than significant and would not expose sensitive receptors to substantial pollutant concentrations. Further analysis is not required/warranted per SJVAPCD guidance since the Prioritization Score is less than 10.
It should be noted that idling vehicles at the gasoline station would generate criteria pollutant and greenhouse gas (GHG) emissions. Considering trip generation rates from the Institute of Transportation Engineers (ITE) Trip Generation Handbook and criteria pollutant emission factors from EMFAC 2017 and 2021 for Light-Heavy Duty vehicles, the gas station would generate emissions as follows:
Pollutant EMFAC 2017 EMFAC 2021
ROG 0.065706 tons/yr 0.065953 tons/yr
CO 0.550752 tons/yr 0.551055 tons/yr
NOx 0.059816 tons/yr 0.059015 tons/yr
CO2 20.452703 tons/yr 20.453493 tons/yr
SOx 0.000200 tons/yr 0.000201 tons/yr
PM10 0.000638 tons/yr 0.000639 tons/yr
PM2.5 0.000610 tons/yr 0.000611 tons/yr
The SJVAPCD has established a significance threshold of 10 tons/year for ROG, 100 tons/year for CO, 10 tons/year for NOx, 27 tons/year for SOx, and 15 tons/year for PM10 and PM2.5. Results show that emissions from idling will not exceed the established SJVAPCD criteria. It should be noted that EMFAC does not include emission factors for PM10 and PM2.5 for gasoline vehicles since the PM contribution to ambient air quality from gasoline vehicles is normally negligible. The SJVAPCD has not established a significance threshold for GHG emissions (CO2).
CARB has established a significance threshold of 7,000 MT CO2eq per year. GHG emissions from idling vehicles at the gas station represent 0.3% of the CARB threshold.
“Exhibit 1”
Response to Exhibit 1/Comment-1
Comment noted. Table 1 of the Health Risk Assessment provides ‘recommendations’ for the siting of new sensitive land uses near the source categories (i.e. gasoline dispensing facilities) presented in the table. It should be noted that the ‘recommendations’ are advisory, as noted in the footnotes of Table 1, and would not supersede site-specific analysis which determines the actual risk from a particular facility. Table 1 can be used as a first step in ‘screening out’ development Projects with uses that generate toxic emissions. In Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
this case, the Project does not meet the ‘recommendations’ of Table 1 and must provide a site-specific analysis of impacts to sensitive receptors. The Health Risk Assessment prepared for the Project demonstrates a less than significant impact from toxic emissions generated by Project operations.
Toxic emissions associated with Project operations were used as inputs to the SJVAPCD Prioritization Calculator which generated a prioritization score of 8.62 for the Project. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.62 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. Based upon SJVAPCD guidance, Toxic Air Contaminant (TAC) emissions associated with the Project are considered less than significant and would not expose sensitive receptors to substantial pollutant concentrations. Further analysis/modeling is not required per SJVAPCD guidance since the Prioritization (Max) Score is less than 10.
Response to Exhibit 1/Comment-2
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-3
Comment noted. The SJVAPCD only assesses Heavy-Heavy-Duty Truck (HHDT) Diesel Particulate Matter (DPM) for risk assessments. The Health Risk Assessment prepared by JK Consulting Group, LLC focused on truck trips to the gas station. The Big Box Retail Store will generate approximately 15 truck trips per day for deliveries. Utilizing the methodology presented in the Health Risk Assessment, toxic emissions associated with Project (including truck trips to the Big Box Retail Store) operations were used as inputs to the SJVAPCD Prioritization Calculator which generated a prioritization score of 8.68 for the Project.
Results indicate that toxic emissions associated with the Project (including truck trips to the Big Box Retail Store) will generate a prioritization (max) score of 8.68 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. Based upon SJVAPCD guidance, Toxic Air Contaminant (TAC) emissions associated with the Project are considered less than significant and would not expose sensitive receptors to substantial pollutant concentrations. Further analysis/modeling is not required per SJVAPCD guidance since the Prioritization (Max) Score is less than 10.
Response to Exhibit 1/Comment-4
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-5
Comment noted. The storage and combustion of gasoline at the Project site poses potential health risks associated with Benzene exposure in addition to Diesel Particulate Matter (DPM). Toxic emissions associated with Project operations were used as inputs to the SJVAPCD Prioritization Calculator which generated a prioritization score of 8.62 for the Project. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.62 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. Based upon SJVAPCD guidance, Toxic Air Contaminant (TAC) Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
emissions associated with the Project are considered less than significant and would not expose sensitive receptors to substantial pollutant concentrations. Further analysis/modeling is not required per SJVAPCD guidance since the Prioritization (Max) Score is less than 10.
Response to Exhibit 1/Comment-6
Comment noted. See Response to Exhibit 1/Comment-1
Response to Exhibit 1/Comment-7
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-8
Comment noted. See Response to Exhibit 1/Comment-1
Response to Exhibit 1/Comment-9
Comment noted. See Response to Exhibit 1/Comment-1
Response to Exhibit 1/Comment-10
Comment noted. See Response to Exhibit 1/Comment-1
Response to Exhibit 1/Comment-11
Comment noted. See Response to Exhibit 1/Comment-1
Response to Exhibit 1/Comment-12
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-13
Comment noted. See Response to Exhibit 1/Comment-5
Response to Exhibit 1/Comment-14
Comment noted. See Response to Exhibit 1/Comment-1
Response to Exhibit 1/Comment-15
Comment noted. The 2017 version of the Emission Factor model (EMFAC), developed by the California Air Resources Board (ARB), is a mathematical model that was developed to calculate emission rates from motor vehicles that operate on highways, freeways, and local roads in California and is commonly used by the ARB to project changes in future emissions from on-road mobile sources. It should be noted that EMFAC 2017 is approved by the Environmental Protection Agency (EPA).
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
For comparison purposes only, the analysis was evaluated using EMFAC 2021 considering the same methodologies used in the Health Risk Assessment prepared by JK Consulting Group. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.63 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. The prioritization (max) score increases by 0.01 compared to results from the use of EMFAC 2017.
Response to Exhibit 1/Comment-16
Comment noted. See Response to Exhibit 1/Comment-1. The Prioritization (Max) Score of 8.62 is based upon the 7.5 million gallons of gasoline and 1.2 million gallons of diesel fuel that are projected to be sold annually. The Prioritization (Max) Score of 8.62 is not related to the number of pumps at the gas station but is directly related to the fuel throughput of the station.
Response to Exhibit 1/Comment-17
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-18
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-19
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-20
Comment noted. See Response to Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-21
Comment noted. The two adjacent mobile home parks are the nearest sensitive receptors to be impacted by the Project. While the Cottonwood Elementary School that is situated 0.4 miles (640 meters) from the site is also considered a sensitive receptor, impacts to the school would also be deemed insignificant.
Considering the information presented in Table 2 and the distance from the Project to the school (640 meters), a Prioritization (Max) Score of 0.095 would be attributed to sensitive receptors at the school as a result of Project operations.
Response to Exhibit 1/Comment-22
Comment noted. The analysis provided in the Health Risk Assessment is consistent with SJVAPCD methodology and industry standards.
Response to Exhibit 1/Comment-23
Comment noted. See Response to Exhibit 1/Comment-5.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-24
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-25
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-26
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-27
Comment noted. See Response to Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-28
Comment noted. See Response to Exhibit 1/Comment-1 and Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-29
Comment noted. See Response to Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-30
Comment noted. Table 1 of the Health Risk Assessment provides ‘recommendations’ for the siting of new sensitive land uses near the source categories presented in the table. It should be noted that the ‘recommendations’ are advisory, as noted in the footnotes of Table 1, and would not supersede site- specific analysis which determines the actual risk from a particular facility. The Health Risk Assessment prepared for the Project demonstrates a less than significant impact from toxic emissions generated by Project operations.
Toxic emissions associated with Project operations were used as inputs to the SJVAPCD Prioritization Calculator which generated a prioritization score of 8.62 for the Project. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.62 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. Based upon SJVAPCD guidance, TAC emissions associated with the Project are considered less than significant and would not expose sensitive receptors to substantial pollutant concentrations. In addition, dispersion modeling is not needed since the Prioritization (Max) Score is less than 10.
Response to Exhibit 1/Comment-31
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-32
Comment noted. See Response to Exhibit 1/Comment-30.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-33
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-34
Comment noted. See Response to Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-35
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-36
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-37
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-38
Comment noted. See Response to Exhibit 1/Comment-1. The Prioritization (Max) Score of 8.62 is based upon the 7.5 million gallons of gasoline and 1.2 million gallons of diesel fuel that are projected to be sold annually. The Prioritization (Max) Score of 8.62 is not related to the number of pumps at the gas station but is directly related to the fuel throughput of the station.
The length of truck idling at the Project site is consistent with SJVAPCD regulations.
Response to Exhibit 1/Comment-39
Comment noted. See Response to Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-40
Comment noted. See Response to Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-41
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-42
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-43
Comment noted. See Response to Exhibit 1/Comment-1.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-44
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-45
Comment noted. See Response to Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-46
Comment noted. See Response to Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-47
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-48
Comment noted. See Response to Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-49
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-50
Comment noted. See Response to Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-51
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-52
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-53
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-54
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-55
Comment noted. See Response to Exhibit 1/Comment-1.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-56
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-57
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-58
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-59
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-60
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-61
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-62
Comment noted. The storage and combustion of gasoline at the Project site poses potential health risks associated with Benzene, Toluene, Xylenes, Ethyl Benzene, Hexane, Naphthalene, Propylene (propene) exposure in addition to Diesel Particulate Matter (DPM) as shown in Appendix C of the Health Risk Assessment. Toxic emissions associated with Project operations were used as inputs to the SJVAPCD Prioritization Calculator which generated a prioritization score of 8.62 for the Project. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.62 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. Based upon SJVAPCD guidance, Toxic Air Contaminant (TAC) emissions associated with the Project are considered less than significant and would not expose sensitive receptors to substantial pollutant concentrations. Further analysis/modeling is not required per SJVAPCD guidance since the Prioritization (Max) Score is less than 10.
Idling vehicles at the gasoline station would generate criteria pollutant and greenhouse gas (GHG) emissions. Considering trip generation rates from the Institute of Transportation Engineers (ITE) Trip Generation Handbook and criteria pollutant emission factors from EMFAC 2017 and 2021 for Light-Heavy Duty vehicles, the gas station would generate emissions as follows:
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Pollutant EMFAC 2017 EMFAC 2021
ROG 0.065706 tons/yr 0.065953 tons/yr
CO 0.550752 tons/yr 0.551055 tons/yr
NOx 0.059816 tons/yr 0.059015 tons/yr
CO2 20.452703 tons/yr 20.453493 tons/yr
SOx 0.000200 tons/yr 0.000201 tons/yr
PM10 0.000638 tons/yr 0.000639 tons/yr
PM2.5 0.000610 tons/yr 0.000611 tons/yr
The SJVAPCD has established a significance threshold of 10 tons/year for ROG, 100 tons/year for CO, 10 tons/year for NOx, 27 tons/year for SOx, and 15 tons/year for PM10 and PM2.5. Results show that emissions from idling will not exceed the established SJVAPCD criteria. It should be noted that EMFAC does not include emission factors for PM10 and PM2.5 for gasoline vehicles since the PM contribution to ambient air quality from gasoline vehicles is normally negligible. The SJVAPCD has not established a significance threshold for GHG emissions (CO2).
CARB has established a significance threshold of 7,000 MT CO2eq per year. GHG emissions from idling vehicles at the gas station represent 0.3% of the CARB threshold.
Response to Exhibit 1/Comment-63
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-64
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-65
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-66
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-67
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-68
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-69
Comment noted. See Response to Exhibit 1/Comment-30.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-70
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-71
Comment noted. The Prioritization (Max) Score of 8.62 is based upon the 7.5 million gallons of gasoline and 1.2 million gallons of diesel fuel that are projected to be sold annually. The Prioritization (Max) Score of 8.62 is not related to the number of pumps at the gas station but is directly related to the fuel throughput of the station.
The length of truck idling at the Project site is consistent with SJVAPCD regulations.
Response to Exhibit 1/Comment-72
Comment noted. See Response to Exhibit 1/Comment-30. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-73
Comment noted. See Response to Exhibit 1/Comment-30. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-74
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-75
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-76
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-77
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-78
Comment noted. See Response to Exhibit 1/Comment-1.
Response to Exhibit 1/Comment-79
Comment noted. See Response to Exhibit 1/Comment-30.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-80
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-81
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-82
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-83
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-84
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-85
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-86
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-87
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-88
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-89
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-90
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-91
Comment noted. The Project complies with local and state requirements.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-92
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-93
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-94
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-95
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-96
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-97
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-98
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-99
Comment noted. See Response to Exhibit 1/Comment-5, Exhibit 1/Comment-30 and Exhibit 1/Comment-
71. Response to Exhibit 1/Comment-100
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-101
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-102
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-103
Comment noted. The Project complies with local and state requirements.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-104
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-105
Comment noted. See Response to Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-106
Comment noted. The Health Risk Assessment identifies residences surrounding the Project as sensitive receptors.
Response to Exhibit 1/Comment-107
Comment noted. Table 1 of the Health Risk Assessment provides ‘recommendations’ for the siting of new sensitive land uses near the source categories presented in the table. It is agreed that the information presented in Table 1 can also be used as ‘guidance’ on siting new facilities, such as gas stations, near sensitive receptors. It should be noted that the ‘recommendations’ are advisory, as noted in the footnotes of Table 1, and would not supersede site-specific analysis which determines the actual risk from a particular facility. The Health Risk Assessment prepared for the Project demonstrates a less than significant impact from toxic emissions generated by Project operations.
Toxic emissions associated with Project operations were used as inputs to the San Joaquin Valley Air Pollution Control District (SJVAPCD) Prioritization Calculator which generated a prioritization score of 8.62 for the Project. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.62 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. Based upon SJVAPCD guidance, TAC emissions associated with the Project are considered less than significant and would not expose sensitive receptors to substantial pollutant concentrations. In addition, dispersion modeling is not needed since the Prioritization (Max) Score is less than 10.
Response to Exhibit 1/Comment-108
Comment noted. See Response to Exhibit 1/Comment-107.
Response to Exhibit 1/Comment-109
Comment noted. See Response to Exhibit 1/Comment-107.
Response to Exhibit 1/Comment-110
Comment noted. See Response to Exhibit 1/Comment-107.
Response to Exhibit 1/Comment-111
Comment noted. See Response to Exhibit 1/Comment-107.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-112
Comment noted. See Response to Exhibit 1/Comment-107.
Response to Exhibit 1/Comment-113
Comment noted. See Response to Exhibit 1/Comment-107.
Response to Exhibit 1/Comment-114
Comment noted. See Response to Exhibit 1/Comment-107.
Response to Exhibit 1/Comment-115
Comment noted. See Response to Exhibit 1/Comment-107.
Response to Exhibit 1/Comment-116
Comment noted. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.62 for ‘ALL’ sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project as determined by SJVAPCD methodology. The score is not based upon a 328-foot distance, but all sensitive receptors that fall between 0 and 328-feet.
Response to Exhibit 1/Comment-117
Comment noted. See Response to Exhibit 1/Comment-116.
Response to Exhibit 1/Comment-118
Comment noted. See Response to Exhibit 1/Comment-116.
Response to Exhibit 1/Comment-119
Comment noted. The comment raised is not within the scope of the HRA Study per guidelines established by the SJVAPCD.
Response to Exhibit 1/Comment-120
Comment noted. The comment raised is not within the scope of the HRA Study per guidelines established by the SJVAPCD.
Response to Exhibit 1/Comment-121
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-122
Comment noted. The Project complies with local and state requirements.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-123
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Response to Exhibit 1/Comment-124
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-125
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-126
Comment noted. See Response to Exhibit 1/Comment-1 and Exhibit 1/Comment-5.
Response to Exhibit 1/Comment-127
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-128
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-129
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-130
Comment noted. The comment raised is not within the scope of the HRA Study per guidelines established by the SJVAPCD.
Response to Exhibit 1/Comment-131
Comment noted. The comment raised is not within the scope of the HRA Study per guidelines established by the SJVAPCD.
Response to Exhibit 1/Comment-132
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-133
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 1/Comment-134
Comment noted. See Response to Exhibit 1/Comment-5 and Exhibit 1/Comment-30.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 1/Comment-135
Comment noted. Table 1 of the Health Risk Assessment provides ‘recommendations’ for the siting of new sensitive land uses near the source categories (i.e. gasoline dispensing facilities) presented in the table. It should be noted that the ‘recommendations’ are advisory, as noted in the footnotes of Table 1, and would not supersede site-specific analysis which determines the actual risk from a particular facility. The Health Risk Assessment prepared for the Project demonstrates a less than significant impact from toxic emissions generated by Project operations.
Toxic emissions associated with Project operations were used as inputs to the SJVAPCD Prioritization Calculator which generated a prioritization score of 8.62 for the Project. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.62 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. Based upon SJVAPCD guidance, TAC emissions associated with the Project are considered less than significant and would not expose sensitive receptors to substantial pollutant concentrations. In addition, dispersion modeling is not needed since the Prioritization (Max) Score is less than 10.
Response to Exhibit 1/Comment-136
Comment noted. The Project complies with local and state requirements.
“Exhibit 2”
Response to Exhibit 2/Comment-1
Comment noted. The comment raised is not within the scope of the HRA Study per guidelines established by the SJVAPCD.
Response to Exhibit 2/Comment-2
Comment noted. The Health Risk Assessment prepared for the Project demonstrates a less than significant impact from toxic emissions generated by Project operations.
Toxic emissions associated with Project operations were used as inputs to the SJVAPCD Prioritization Calculator which generated a prioritization score of 8.62 for the Project. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.62 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. Based upon SJVAPCD guidance, Toxic Air Contaminant (TAC) emissions associated with the Project are considered less than significant and would not expose sensitive receptors to substantial pollutant concentrations. Further analysis/modeling is not required per SJVAPCD guidance since the Prioritization (Max) Score is less than 10.
Response to Exhibit 2/Comment-3
Comment noted. The Project complies with local and state requirements.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 2/Comment-4
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 2/Comment-5
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 2/Comment-6
Comment noted. See Response to Exhibit 2/Comment-2
Response to Exhibit 2/Comment-7
Comment noted. See Response to Exhibit 2/Comment-2
Response to Exhibit 2/Comment-8
Comment noted. As noted in the SJVAPCD Guide for Assessing and Mitigating Air Quality Impacts, March 19, 2015, there are various tools that can be used to screen toxic sources impacting sensitive receptors.
The California Air Pollution Control Officers Association’s (CAPCOA) Health Risk Assessments for Proposed Land Use Projects (July 2009) references Table 1 (RECOMMENDATIONS ON SITING NEW SENSITIVE LAND USES SUCH AS RESIDENCES, SCHOOLS, DAYCARE CENTERS, PLAYGROUNDS, OR MEDICAL FACILITIES) of the Health Risk Assessment prepared for the Project as one of several screening tools. The July 2009 guidance document goes on to indicate that if a screening risk assessment shows that risk is a concern, a more refined analysis may be prepared to provide more accurate information for decision makers.
Screening assessments use more conservative assumptions and thus gives higher risk than refined assessments.
Table 1 of the Health Risk Assessment provides ‘recommendations’ for the siting of new sensitive land uses near the source categories (i.e. gasoline dispensing facilities) presented in the table. It should be noted that the ‘recommendations’ are advisory, as noted in the footnotes of Table 1, and would not supersede site-specific analysis which determines the actual risk from a particular facility. Table 1 can be used as a first step in ‘screening out’ development Projects with uses that generate toxic emissions. In this case, the Project does not meet the ‘recommendations’ of Table 1 and must provide a site-specific analysis of impacts to sensitive receptors. The Health Risk Assessment prepared for the Project demonstrates a less than significant impact from toxic emissions generated by Project operations.
Toxic emissions associated with Project operations were used as inputs to the SJVAPCD Prioritization Calculator which generated a prioritization score of 8.62 for the Project. Results indicate that toxic emissions associated with the Project will generate a prioritization (max) score of 8.62 for ALL sensitive receptors within 0 to 100 meters (0 to 328 feet) of the Project. Based upon SJVAPCD guidance, Toxic Air Contaminant (TAC) emissions associated with the Project are considered less than significant and would not expose sensitive receptors to substantial pollutant concentrations. Further analysis/modeling is not required per SJVAPCD guidance since the Prioritization (Max) Score is less than 10.
Cristobal Carrillo, Associate Planner
November 19, 2024
JK Consulting Group, LLC
www.Jkconsultinggroupllc.com
Response to Exhibit 2/Comment-9
Comment noted. See Response to Exhibit 2/Comment-8
Response to Exhibit 2/Comment-10
Comment noted. The comment raised is not within the scope of the HRA Study per guidelines established by the SJVAPCD.
Response to Exhibit 2/Comment-11
Comment noted. The comment raised is not within the scope of the HRA Study per guidelines established by the SJVAPCD.
Response to Exhibit 2/Comment-12
Comment noted. The Project complies with local and state requirements.
Response to Exhibit 2/Comment-13
Comment noted. See Response to Exhibit 2/Comment-8.
Should you have any further questions or comments, please contact me by email at [email protected].
Sincerely,
Jason Ellard, Principal
JK Consulting Group, LLC
Attachment
EXHIBIT 2
EXHIBIT 1
EXHIBIT 3
EXHIBIT 2
CAEVCAEVCAEVCACACAEVCAEVCA CAEVCACA
TRASHRECYCLEGREASETANK
EVCS STATION(VAN ACCESSIBLE)EVCSSTATIONEVCSSTATIONEVCSSTATION
DIRECTION OF TRAVEL
CUSTOMER SIDE
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DIRECTION OF TRAVEL
CUSTOMER SIDE
REAR SIDE
CLEAN AIR/VANPOOL/EVCLEAN AIR/VANPOOL/EV
CLEAN AIR/VANPOOL/EV
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DIRECTION OF TRAVEL
DO NOT ENTERSTOPSTOPEXITEXITEXITEXITEXITEXITEXITEXITEXITEXITEXITEXITEXITEXITEXITEXIT
PRELIMINARY SITE PLANPROPOSED SAM'S CLUB
NORTH
PRELIMINARY SITE PLANPROPOSED RETAIL BUILDING