Vista Canyon Transit Center - Air Quality Technical Memorandum

Transcription

1 803 Camarillo Springs Road, Suite C Camarillo, California (805) FAX (805) MEMORANDUM To: Kris Markarian, City of Santa Clarita Job No From: Susan Tebo, Impact Sciences, Inc. Eric Bell, Impact Sciences, Inc. Subject: Vista Canyon Transit Center - Air Quality Technical Memorandum Date: August 30, 2013 INTRODUCTION The project includes development of a transit center consisting of a Metrolink Station (platform, access, and associated track work) and bus transfer station. Required parking consisting of approximately 500 spaces would be provided by an adjacent project developer. This technical memorandum provides an analysis of the potential air quality impacts from construction and operation of the transit station portion of the full project. The impacts associated with operation of the Transit Center were compared to the thresholds of significance established by the South Coast Air Quality Management District (SCAQMD). Thresholds of significance during project operation are based on mass daily emission thresholds for volatile reactive organic compounds (VOCs), oxides of nitrogen (NOX), carbon monoxide (CO), sulfur dioxide (SO2), respirable particulate matter less than 10 microns in diameter (PM10), and fine particulate matter less than 2.5 microns in diameter (PM2.5). In addition, the SCAQMD has promulgated localized significance thresholds (LSTs) that identify local ambient air impacts during project construction and operation for nitrogen dioxide (NO2), CO, PM10, and PM2.5. In addition, the SCAQMD requires an evaluation of the project s impact on local CO

2 Page 2 concentrations near impacted intersections and roadways. Finally, greenhouse gas (GHG) emissions are analyzed with respect to draft thresholds developed by the SCAQMD. REGULATORY SETTING The project site is in the City of Santa Clarita, in Los Angeles County. The site is located in the South Coast Air Basin (Basin). An air basin is a geographical region that shares the same air pollution concerns. The Basin consists of Orange County and the urbanized portions of Los Angeles, Riverside, and San Bernardino Counties. The SCAQMD is the air pollution control agency for the Basin. While GHGs act on a global scale, the SCAQMD has prepared draft guidance materials for assessing the significance of GHG emissions for land use projects located within its jurisdiction. This assessment has been prepared in accordance with guidance documents and materials provided by the SCAQMD. THRESHOLDS OF SIGNIFICANCE In accordance with California Environmental Quality Act (CEQA) Guidelines (Appendix G), the following significance threshold criteria should be used to evaluate the potential air quality impacts of proposed projects within the City of Santa Clarita. The project would have a significant air quality impact if it would: conflict with or obstruct implementation of the applicable air quality plan, violate any air quality standard or contribute substantially to an existing or projected air quality violation, result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors), expose sensitive receptors to substantial pollutant concentrations, or create objectionable odors affecting a substantial number of people. In accordance with State CEQA Guidelines (Appendix G), the following significance threshold criteria should be used to evaluate the potential GHG impacts of proposed projects. The project would have a significant GHG emissions impact if it would: generate greenhouse gas 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 greenhouse gases.

3 Page 3 The State CEQA Guidelines (Section ) provide that, when available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make determinations of significance. The potential air quality impacts of the proposed project are, therefore, evaluated according to thresholds developed by the SCAQMD, which are listed below. Emissions Thresholds The SCAQMD has developed both regional and localized significance thresholds for criteria air pollutants. These thresholds apply to both construction and operation of a proposed project. The regional thresholds are based on mass emission rates, while the localized thresholds are based on concentrations of pollutants at specific receptor locations. The SCAQMD has not adopted GHG thresholds, but has published draft thresholds that are in common use for environmental analyses in the Basin. GHG emissions may be compared to either a mass emission rate threshold or a mass emissions per service person threshold (also known as an efficiency metric), where a service person is a resident or employee of the proposed project. Air Quality Impacts Would the project: (a). Conflict with or obstruct implementation of the applicable air quality plan? Less than Significant Impact. The project is consistent with the Air Quality Management Plan (AQMP). (b). Violate any air quality standard or contribute substantially to an existing or projected air quality violation? Construction Less than Significant Impact. Construction emissions are generated from the use of mobile equipment and motor vehicles, disturbance of soil, and the application of architectural coatings and paving materials. Construction emissions are generally proportional to the scale of construction activities, including area of buildings to be demolished, land disturbed, and new buildings constructed. This project was analyzed as part of the larger Vista Canyon project in the Vista Canyon EIR. The transit station was assumed to be part of Phase 3 of the Vista Canyon project, taking place in the third year of construction. The total construction emissions for year 3 of construction are below the significance thresholds for construction, indicating that the emissions for the transit center would be as well.

4 Page 4 Localized emissions for the Vista Canyon project were estimated to exceed the thresholds for nitrogen oxides (NOx), PM10, and PM2.5. However, localized pollutant concentrations associated with construction of the transit station would also be a very small fraction of the concentrations calculated for the full project. Assuming a simple linear relationship, the resulting concentrations from the fraction of emissions from the transit station compared with maximum emissions from the full project would be well below the localized thresholds for construction. Operational Less than Significant Impact. Operational emissions associated with the development and operation of the Vista Canyon project would result primarily from increased vehicular trips to and from the site. Other sources of emissions would include new area/stationary sources such as water and space heaters and cooking appliances, landscape maintenance equipment, and consumer products. The estimated emissions associated with full project operation were estimated to exceed SCAQMD thresholds. However, the overwhelming majority of these emissions result from traffic associated with residential and commercial uses, with area emissions from the same sources the second largest factor. The transit station would generate approximately 1,500 daily trips and resulting emissions would be well below the SCAQMD significance thresholds. (c). Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors); Less than Significant Impact. The SCAQMD recommends that the emissions-based thresholds be used to determine if a project s contribution to regional cumulative emissions is cumulatively considerable. Individual projects that exceed the SCAQMD-recommended daily thresholds for project-specific impacts would be considered to cause a cumulatively considerable increase in emissions for those pollutants for which the Basin is in nonattainment. As discussed above, construction and operation of the project would not result in daily construction emissions that exceed the thresholds of significance recommended by the SCAQMD. Therefore, the project would not generate a cumulatively considerable contribution to air pollutant emissions during project construction or operation. (d). Expose sensitive receptors to substantial pollutant concentrations; Less than Significant Impact. Localized CO concentrations have the potential to exceed the air quality standards at heavily congested roadway intersections. Localized areas where ambient concentrations exceed state and/or federal standards are termed CO hotspots. The Air Basin was designated as an attainment area

5 Page 5 for CO by the USEPA in June There have been no violations of CO standards in the Air Basin in over 10 years. Analysis in the EIR demonstrated that CO impacts associated with the Vista Canyon project as a whole would be well below both state and federal standards, and therefore this portion of the project would also be below state and federal standards. Therefore, the transit station would also have a less than significant impact on potential CO hotpots. No further analysis is required. In addition to criteria pollutants, the SCAQMD assesses levels of toxic air contaminants (TACs) in the Basin. The proposed project potentially includes diesel-powered buses and trains, which have the potential to emit TACs. The potential for the Vista Canyon project to expose receptors to increased health risks were analyzed in the previous EIR, with the finding that the impact would be less than significant. Therefore, the transit station impacts would be far less and therefore also less than significant. No further analysis is required. (e). Create objectionable odors affecting a substantial number of people. Less than Significant Impact with Mitigation. Project construction would involve the uses of equipment creating exhaust pollutants from on-site earth movement and from equipment bringing asphalt and other materials to the site. With regard to nuisance odors, any air quality impacts would be confined to the immediate vicinity of the equipment itself. By the time such emissions reach any sensitive receptor sites away from the site, they are typically diluted to well below any level of air quality concern. Construction of the project is temporary and is not expected to cause an odor nuisance. The SCAQMD lists land uses primarily associated with odor complaints as waste transfer and recycling stations, wastewater treatment plants, landfills, composting operations, petroleum operations, food and byproduct processes, factories, and agricultural activities, such as livestock operations. The proposed project does not include any of those land use types, and the potential impact would be less than significant. No further study is required. Greenhouse Gas Impacts Would the project: (a). Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. Less than Significant Impact. The proposed project would result in emissions of GHGs during construction and operation. These emissions, primarily CO2, methane (CH4), and nitrous oxide (N2O), are the result of fuel combustion by construction equipment and motor vehicles. The other primary GHGs

6 Page 6 (hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride) are typically associated with specific industrial sources and are not expected to be emitted by the project. The proposed project is a transit center, the primary purpose of which is to encourage the use of mass transit. Mass transit is considered a practical and effective method for reducing GHG emissions through reduced trips of single-occupant vehicles. Mass transit is commonly included in lists of methods to mitigate GHG emissions. Furthermore, the Vista Canyon project was found to have a less than significant impact with regard to GHG emissions, partly due to the inclusion of the transit station. Therefore the proposed project will have a less than significant impact. (b). Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. Less than Significant Impact. As mentioned, the primary purpose of the proposed project is to reduce GHG emissions and to help ensure compliance with GHG reduction plans such as AB 32 and SB 375. Mass transit is recognized as an effective method of reducing GHG emissions by the USEPA, the Federal Transit Administration (FTA), the California Air Resources Board, the SCAQMD, the California Air Pollution Control Officers Association, the Intergovernmental Panel on Climate Change, and numerous other agencies and organizations. Mass transit does so by reducing single vehicle trips, and replacing them with more efficient transportation modes such as buses and trains. The FTA states that subways and metros produce 76 percent less GHG emissions per passenger mile than an average single passenger vehicle, light rail systems 62 percent less, and buses 33 percent less. Therefore the proposed project will have a less than significant impact. GENERAL CONFORMITY Under section 176(c)(1) of the federal CAA, federal agencies that "engage in, support in any way or provide financial assistance for, license or permit, or approve any activity" 1 must demonstrate that such actions do not interfere with state and local plans to bring an area into attainment with the NAAQS. Specifically, the South Coast Air Basin is designated as nonattainment with respect to the NAAQS for ozone, PM10, and PM2.5. The Basin was redesignated as attainment for the NAAQS for CO and is subject to an approved maintenance plan. The program by which a federal agency determines that its action would not obstruct or conflict with air quality attainment plans is called "general conformity." The implementing regulations for general conformity are found in Code of Federal Regulations, title 40, part 51, subpart W and part 93, 1 42 U.S.C. 7506(c).

7 Page 7 subpart B. In addition, the SCAQMD has adopted the federal general conformity regulations as Regulation XIX, Rule Under the general conformity regulations, both the direct and indirect emissions associated with a federal action must be evaluated. Subpart W defines direct emissions as: [T]hose emissions of a criteria pollutant or its precursors that are caused or initiated by the Federal action and occur at the same time and place as the action. 2 Indirect emissions are defined as: [T]hose emissions of a criteria pollutant or its precursors that: (1) Are caused by the Federal action, but may occur later in time and/or may be farther removed in distance from the action itself but are still reasonably foreseeable; and (2) The Federal agency can practicably control and will maintain control over due to a continuing program responsibility of the Federal agency. 3 A conformity determination is required for each criteria pollutant or precursor where the total of direct and indirect emissions of the criteria pollutant or precursor in a federal nonattainment or maintenance area would equal or exceed specified annual emission rates, referred to as "de minimis" thresholds, or would be "regionally significant." A project's direct and indirect emissions are regionally significant if they exceed 10 percent or more of a nonattainment or maintenance area's emissions inventory for that pollutant. For ozone precursor and PM10, the de minimis thresholds depend on the severity of the nonattainment classification; for other pollutants, the threshold is set at 100 tons per year. The South Coast Air Basin is designated as severe-17 nonattainment for ozone, serious nonattainment for PM10, and nonattainment for PM2.5. The Basin is subject to an approved CO maintenance plan, and therefore, the general conformity regulations also apply for this pollutant. The relevant de minimis thresholds for the South Coast Air Basin are shown below in Table C.F.R Ibid.

8 Page 8 Pollutant Table 1 General Conformity De Minimis Thresholds Attainment Status Annual Emissions (ton/yr) NOx Nonattainment/Severe-17 (Ozone) 10 1 VOC Nonattainment/Severe-17 (Ozone) 10 1 PM10 Nonattainment/Serious 70 PM2.5 (direct) Nonattainment 100 PM2.5 (NOx) 2 (Nonattainment) 100 PM2.5 (VOC and NH3) 3 (Nonattainment) 100 PM2.5 (SOx) (Nonattainment) 100 CO Attainment/Maintenance 100 Notes: 1 The South Coast Air Basin currently is designated as Severe-17 (25 ton/year de minimis threshold for NO x and VOC), but the SCAQMD has requested a redesignation to Extreme (10 ton/year de minimis threshold for NO x and VOC). The SCAQMD has recommended using the Extreme designation for purposes of this Project (Jill Whynot, Planning and Rules Manager, SCAQMD, July 11, 2007). 2 NO x is included for PM2.5 unless determined not to be a significant precursor. However, the NO x threshold based on its contribution to ozone is more stringent. 3 VOC and ammonia (NH 3 ) are not included for PM2.5 unless determined to be a significant precursor. However, the VOC threshold based on their contribution to ozone is more stringent. Only very minor emissions of ammonia would be emitted to the atmosphere as a result of the proposed action. No federal agency will maintain control over the project once constructed. Accordingly, this evaluation will only consider emissions associated with the construction of the project. As mentioned, the transit station is part of Phase 3 of the construction schedule. The estimates of maximum daily direct emissions for this phase were calculated in the previous environmental assessment. Because the de minimis thresholds are annual values, the estimated daily emissions for each quarter were multiplied by the assumed construction days in a year (e.g., generally 260 construction days) and divided by 2,000 to convert pounds to tons. The resultant annual emissions for each nonattainment or maintenance pollutant in each construction year are shown in Table 2. It should be noted that these values are for all of Phase 3 of construction, while the transit station is only a small portion of Phase 3. Year VOC Table 2 Direct Annual Construction Emissions NOx CO SOx PM10 PM Thresholds Exceeds Threshold? NO NO NO NO NO NO

9 Page 9 As shown in Table 2, the annual direct emissions would not exceed the de minimis threshold. Thus, no conformity analysis is required for this project.