Air Quality. Chapter 7. MVY Martha s Vineyard Airport 7.1 AFFECTED ENVIRONMENT Introduction

Transcription

1 MVY Martha s Vineyard Airport Chapter 7 Air Quality 7.1 AFFECTED ENVIRONMENT Introduction This section of the DEIR/EA describes the air pollutants of concern in this study, the regulatory setting governing the project, the affected environment with respect to air quality in the vicinity of Martha s Vineyard Airport (MVY) and the anticipated impacts of the proposed airport improvement program. The air quality analysis for this DEIR/EA was prepared in accordance with National Environmental Policy Act requirements as specified in Council on Environmental Quality regulations 1, the Federal Aviation Administration (FAA) Order A, Airports Environmental Handbook 2, the FAA Air Quality Procedures for Civilian Airports & Air Force Bases 3, the Certificate of the Secretary of Environmental Affairs on the Environmental Notification Form (EOEA #13024, June 5, 2003), the Certificate of the Secretary of Environmental Affairs on the Notice of Project Change (EOEA #13024, September 25, 2003) and a mesoscale waiver recommendation received from the Massachusetts Department of Environmental Protection. 4 The analysis evaluates the Existing Conditions and two future scenarios: the 2010 No-Build and 2010 Build alternatives Pollutant Health Effects Public awareness of the effects of air pollution has increased noticeably in recent years. This is evidenced by the passage of the Clean Air Act in 1970 and subsequent major Amendments in 1977 and Air pollution is of concern because of its demonstrated 1 Regulations for Implementing the National Environmental Policy Act. 40 CFR Parts (43 FR 55978, November 29, 1978; amended 51 FR 15618, April 25, 1986). 2 Federal Aviation Administration. Airport Environmental Handbook. Washington, DC. Order A. October 8, Federal Aviation Administration, Office of Environment and Energy (AEE-120), and U.S. Air Force. Air Quality Procedures for Civilian Airports & Air Force Bases. Report No. FAA-AEE Washington, DC. April This guidance supplements the FAA Airport Environmental Handbook (Order A). 4 The recommendation is contained in an dated March 8, 2004, from Jerome Grafe of the MA DEP to Nicholas Zavolas, MEPA analyst. The states in part: I am recommending that the mesoscale analysis requirement of the MEPA Certificate dated June 5, 2003 for the MVA Improvements Project be waived... A review of the ENF numbers determined that project related trips versus background, plus regional trip growth results in less than the 3000 trip threshold. In a subsequent NPC (undated), the proponent substituted a supermarket for a jail facility resulting in a further net reduction in project related trips... I recently spoke to Lionel Lucien at MHD concerning project vs. non-project trip generation and the NPC. He concurred that the project now proposed will account for fewer than 800 trips, obviating the need for a mesoscale analysis. 7 Air Quality 7-1

2 Draft Environmental Impact Report/Environmental Assessment effects on human health. Of special concern are the respiratory effects of the pollutants, as well as their general toxic effects. The air pollutants of concern in the assessment of impacts from airport-related sources are listed here, along with a description of their potential health effects: Volatile Organic Compounds (VOC s) VOC s are a general class of compounds containing hydrogen and carbon, and are a precursor to the formation of the pollutant ozone. While concentrations of VOC s in the atmosphere are not generally measured, ground-level ozone is measured and used to assess potential health effects. Emissions of VOC and nitrogen oxides (NOx) react in the presence of the ultraviolet radiation component of sunlight to form ozone in the atmosphere. These reactions occur over periods of hours to days during atmospheric dilution and transport downwind. Accordingly, ozone is regulated as a regional pollutant and is not assessed on a project-specific basis Nitrogen Oxides (NOx) Nitrogen oxides (NOx) are formed when combustion temperatures are extremely high, as in aircraft and vehicle engines, causing atmospheric nitrogen and oxygen gases to combine in the engine combustion chamber. Of the various oxides of nitrogen, nitric oxide (NO) and nitrogen dioxide (NO 2 ) are the most significant air pollutants. NO is a colorless and odorless gas. It is relatively harmless to humans but quickly converts to NO 2. NO 2 has been found to be a lung irritant capable of producing pulmonary edema, and can lead to respiratory illnesses such as bronchitis and pneumonia. Nitrogen oxides are also precursors to ozone formation Ozone Ozone is a strong oxidizer and a pulmonary irritant that affects the respiratory mucous membranes, other lung tissues, and respiratory functions. Human exposure to ozone can result in symptoms such as tightness in the chest, coughing, and wheezing, and can ultimately result in asthma, bronchitis, and emphysema. Ozone also can cause damage to vegetation and many materials Carbon Monoxide (CO) Carbon monoxide (CO) is a colorless and odorless gas which is a product of incomplete combustion. CO is absorbed by the lungs and reacts with hemoglobin to reduce the oxygen carrying capacity of the blood. At low concentrations, CO has been shown to aggravate the symptoms of cardiovascular disease. It can cause headaches and nausea, and at sustained high concentration levels, can lead to coma and death Particulate Matter Particulate matter is made up of small solid particles and liquid droplets. PM10 refers to particulate matter with a nominal aerodynamic diameter of 10 micrometers and smaller, and PM2.5 refers to particulate matter with an aerodynamic diameter of 2.5 micrometers and smaller. Particulates enter the body by way of the respiratory system. Particulates 7 Air Quality 7-2

3 MVY Martha s Vineyard Airport over 10 micrometers in size tend to be captured on the mucous membranes in the nose and throat and are readily expelled. Particles smaller than 10 micrometers, and especially particles smaller than 2.5 micrometers, can reach the air ducts (bronchi) and the air sacs (alveoli). Particulates, especially PM2.5, have been associated with increased respiratory diseases such as asthma, bronchitis, and emphysema; cardiopulmonary disease; and cancer. PM10 and PM2.5 levels are regulated by emissions limits and by Federal and state ambient air quality standards. The ambient air quality standards for PM2.5 have been subject to litigation that had prevented their enforcement. This litigation was concluded in March 2003, and EPA is now in the process of implementing the PM2.5 standards. EPA has not issued technical guidance on project-level assessment of ambient PM2.5 concentrations, and at this time there are no regulatory requirements to perform an assessment of PM2.5 levels for this DEIR/EA Sulfur Dioxide (SO2) Sulfur dioxide (SO 2 ) is a colorless and odorless gas which is formed during the combustion of fuels containing sulfur compounds. It can cause irritation and inflammation of tissues with which it comes into contact. Inhalation can cause irritation of the mucous membranes causing bronchial damage, and it can exacerbate pre-existing respiratory diseases such as asthma, bronchitis, and emphysema. Exposure to SO 2 can cause damage to vegetation, corrosion damage to many materials, and soiling of clothing and buildings. Transportation sources do not emit significant amounts of SO 2, and emissions of SO 2 are not assessed in this DEIR/EA Lead Lead is no longer considered to be a pollutant of concern for transportation projects because the major source of lead emissions to the atmosphere had been from motor vehicles burning fuels with additives that contained lead. However, emissions from this source have been nearly eliminated as unleaded fuels have replaced leaded fuels nationwide. Therefore, lead emissions are not assessed in this DEIR/EA Regulatory Setting This section describes the applicable regulations that govern air quality in the project study area at both the Federal and state levels. This section also describes the procedures that will be needed to demonstrate compliance with these regulations and related criteria Regulations Affecting Air Quality The air quality statutes and regulations that are applicable to the proposed activities at MVY include the Clean Air Act of , the 1977 Clean Air Act Amendments 6, the 1990 Clean Air Act Amendments (CAAA) 7, the National Ambient Air Quality 5 The Clean Air Act of 1970, U. S. Congress, Public Law , 42 U.S.C The 1977 Clean Air Act Amendments, U.S. Congress, Public Law 95-95, 42 U.S.C The 1990 Clean Air Act Amendments, U.S. Congress, Public Law , 42 U.S.C Air Quality 7-3

4 Draft Environmental Impact Report/Environmental Assessment Standards 8, the Massachusetts Ambient Air Quality Standards 9, the Massachusetts State Implementation Plan 10 and associated general conformity regulations Ambient Air Quality Standards Under the authority of the Clean Air Act and the CAAA, the U.S. Environmental Protection Agency (EPA) established a set of National Ambient Air Quality Standards (NAAQS) for various criteria air pollutants. These standards are intended to protect the public health and welfare. Primary air quality standards are established at levels which should protect the public health from harm with an adequate margin of safety. Secondary standards are set at levels necessary to protect the public welfare (buildings, clothing, and vegetation) from any known or anticipated adverse effects of a pollutant. The State of Massachusetts Ambient Air Quality Standards are similar to the National standards. These standards are summarized in Table 7-1. Compliance with the National and State standards must be achieved by any proposed project being constructed in the Commonwealth of Massachusetts Attainment Status and SIP Requirements The EPA designates geographical regions of the country as attainment areas if ambient pollutant concentrations are in compliance with the NAAQS, and as nonattainment areas if ambient pollutant concentrations are not in compliance with the NAAQS. MVY is located on the island of Martha s Vineyard which, at its closest point to the mainland, is approximately four miles off Falmouth on Cape Cod. This area of Massachusetts has been classified as in attainment for CO, NO 2, PM10, SO 2 and lead. The EPA has not yet made attainment designations for PM2.5. For ozone, Eastern Massachusetts was designated as the Boston-Lawrence-Worcester (Eastern Massachusetts), MA-NH Ozone Nonattainment Area due to measured violations of the ozone standards at several monitoring sites in the region. Martha s Vineyard lies within this nonattainment area. In accordance with the classification scheme established by the CAAA, the EPA classified the Eastern Massachusetts Ozone Nonattainment Area as Serious with respect to the one-hour ozone standard. Like other Serious one-hour ozone nonattainment areas, Eastern Massachusetts is required to attain the one-hour ozone standard by the year On April 15, 2004, EPA issued final rules 11,12 that designate Eastern Massachusetts as a Moderate nonattainment area with respect to the eight-hour ozone standard. This 8 National Ambient Air Quality Standards. 40 CFR 50, Section Massachusetts Ambient Air Quality Standards. 310 CMR Massachusetts Department of Environmental Protection Eastern Massachusetts Supplement to the July 1998 Ozone Attainment Demonstration State Implementation Plan Submittal. Boston, MA. September 6, Final Rule to Implement the 8-Hour Ozone National Ambient Air Quality Standard Phase CFR Part 81. April 15, Available: 12 Air Quality Designations and Classifications for the 8-Hour Ozone National Ambient Air Quality Standards; Early Action Compact Areas with Deferred Effective Dates. 40 CFR Part 81. April 15, Available: 7 Air Quality 7-4

5 MVY Martha s Vineyard Airport Table 7-1 National and Massachusetts Ambient Air Quality Standards Pollutant Standard Type Averaging Period a National b,c Massachusetts c Carbon Monoxide Primary and Secondary e 8 hours d 9 ppm (10 mg/m 3 ) 10 mg/m 3 (9 ppm) Primary and Secondary e 1 hour d 35 ppm (40 mg/m 3 ) 40 mg/m 3 (35 ppm) Ozone Primary and Secondary 8 hours f 0.08 ppm (155 µg/m 3 ) No MA 8-hour standard Primary and Secondary 1 hour g 0.12 ppm (235 µg/m 3 ) 0.12 ppm (240 µg/m 3 ) Nitrogen Dioxide Respirable Particulates (PM10) Respirable Particulates (PM2.5) Sulfur Dioxide Primary and Secondary Annual ppm (100 µg/m 3 ) 100 µg/m 3 (0.05 ppm) Primary and Secondary Annual h 50 µg/m 3 50 µg/m 3 Primary and Secondary 24 hours i 150 µg/m µg/m 3 Primary and Secondary Annual h 15 µg/m 3 No MA annual standard Primary and Secondary 24 hours j 65 µg/m 3 No MA 24-hour standard Primary Annual 80 µg/m 3 (0.03 ppm) 80 µg/m 3 (0.03 ppm) Primary 24 hours d 365 µg/m 3 (0.14 ppm) 365 µg/m 3 (0.14 ppm) Secondary 3 hours d 1300 µg/m 3 (0.5 ppm) 1300 µg/m 3 (0.5 ppm) Lead Primary and Secondary Calendar quarter 1.5 µg/m µg/m 3 Notes: a Annual concentrations are means; concentrations for shorter periods are maximums. b National short-term standards are not to be exceeded more than once in a calendar year. c Units are parts per million (ppm), milligrams per cubic meter (mg/m 3 ), and micrograms per cubic meter (µg/m 3 ). d National standards are block averages rather than moving averages. e National secondary standards for carbon monoxide have been repealed. f Maximum daily 8-hour average (averaged over a three-year period, the 3-year average of the annual fourthhighest daily maximum 8-hour average ozone concentration must be less than or equal to the standard). g Maximum daily 1-hour average (averaged over a three-year period, the expected number of days above the standard must be less than or equal to one per year). h Annual average over a three-year period must be less than or equal to the standard. i 99th percentile daily 24-hour mean PM10 concentration, averaged over a three-year period. j 98th percentile daily 24-hour mean PM2.5 concentration, averaged over a three-year period. Sources: National standards - 40 CFR 50. Massachusetts standards CMR Air Quality 7-5

6 Draft Environmental Impact Report/Environmental Assessment designation takes effect on June 15, As a Moderate ozone nonattainment area, Eastern Massachusetts is required to attain the eight-hour ozone standard by the year With designations in place for the eight-hour ozone standard, the EPA plans to revoke the one-hour ozone standard in June To avoid backsliding, or losing clean air progress toward attaining the one-hour standard, the April 15, 2004 rules require that current emission control measures for the one-hour standard must stay in place until the area attains the eight-hour ozone standard. In compliance with the mandates of the CAAA, the Massachusetts Department of Environmental Protection (DEP) has developed a State Implementation Plan (SIP) for air pollution control. The SIP defines the process by which the NAAQS will be attained, and defines the control strategies and schedule that the state will employ to reduce emissions in order to attain the one-hour ozone standard by 2007 and the eight-hour ozone standard by To comply with the SIP, a proposed project must not result in any violations of the NAAQS or Massachusetts standards, and must meet the conditions of the conformity regulations Conformity with the Massachusetts SIP Under Section 176(c) of the Federal Clean Air Act, 42 U.S.C. 7670(c), Federal agencies, such as FAA, are prohibited from engaging in, supporting in any way, providing financial assistance for, licensing or permitting, or approving any activity that does not conform to an approved SIP. Since MVY is located in an ozone nonattainment area, it is FAA's responsibility under Section 176(c) to assure that the proposed project conforms to the Massachusetts SIP. The EPA has issued rules for determining conformity of Federal actions in nonattainment areas. The General Conformity Rule 13 applies to "non-transportation" projects, i.e., projects not funded by the Federal Highway Administration (FHWA), Federal Transit Administration (FTA), or U.S.C. Title 23. Under this applicability definition, non-transportation projects include airport projects for which FAA is the sponsoring Federal agency. The EPA General Conformity Rule defines a "conforming" project as one that: conforms to the SIP's overall objective of eliminating or reducing the severity and number of air quality violations in a state, and achieving expeditious attainment of the NAAQS; does not cause or contribute to new NAAQS violations in the area; does not increase the frequency or severity of existing NAAQS violations in the area; and does not delay the state's timely attainment with the NAAQS or impede required progress toward attainment. The General Conformity Rule established emissions thresholds, or de minimis levels, for use in evaluating the conformity of a project. For purposes of attaining the ozone standard, emissions of the ozone precursor pollutants VOC and NOx are assessed. In a serious one-hour ozone nonattainment area, such as Eastern Massachusetts, these thresholds are 50 tons per year of VOC and 50 tons per year of NOx. The thresholds in 13 General Conformity Rule. 40 CFR Part 51 Subpart W. Promulgated in the Federal Register at 58 FR November 30, Air Quality 7-6

7 MVY Martha s Vineyard Airport the Eastern Massachusetts moderate eight-hour ozone nonattainment area are 50 tons per year of VOC and 100 tons per year of NOx. The project-related changes in the sum of "direct" and "indirect" emissions, as defined in the conformity rules, must be estimated. If the net emission increases due to the project are less than the lower of these thresholds (50 tons per year of VOC or NOx), then the project is presumed to conform and no further conformity evaluation is required. If the emission increases exceed the lower of these thresholds, then a conformity determination is required, including mitigation measures if necessary. Notwithstanding these emission thresholds, a conformity determination is required if the project would be regionally significant as defined in the General Conformity Rule. For purposes of conformity, a project is regionally significant if the emission increase due to the project would equal or exceed ten percent of the total emission inventory for the entire nonattainment area. For the Massachusetts portion of the Boston-Lawrence- Worcester, MA-NH Serious Ozone Nonattainment Area in 1996, the total emissions were 328,148 tons per year of VOC and 231,564 tons per year of NOx 14. Therefore, a project is regionally significant for purposes of general conformity if its emission increases exceed 32,815 tons per year of VOC or 23,156 tons per year of NOx. In addition to the requirements of the Federal general conformity rule, EPA has issued rules for determining conformity of transportation projects (i.e., highway or transit projects which are funded by FHWA, FTA, or U.S.C. Title 23) located in nonattainment areas 15. As this project has no FHWA or FTA funding, and does not require approval from these agencies, the Transportation Conformity Rule does not apply Existing Ambient Air Quality Measured in the Region The DEP maintains a statewide network of monitoring stations which routinely sample pollutant concentrations in the ambient air, and provide data to assess compliance with the NAAQS and to evaluate the impact of pollution control strategies. There are no DEP monitoring stations on Martha s Vineyard. The nearest DEP monitor is located in Fairhaven, MA, approximately 22 miles from the airport. Table 7-2 presents the maximum ozone concentrations measured at the Fairhaven monitor, as reported by DEP 16 for the most recent three full years of data ( ). These data can be compared to the NAAQS presented in Table U.S. Environmental Protection Agency. National Emission Trends Viewer CD. Version 2.0. EPA/454/C Washington, DC. July Transportation Conformity Rule. 40 CFR Part 51 Subpart T and Part 93 Subpart A as amended. Promulgated at 58 FR (November 24, 1993), major amendments promulgated at 62 FR (August 15, 1997). 7 Air Quality 7-7

8 Draft Environmental Impact Report/Environmental Assessment Table 7-2 Ambient Ozone Concentrations Measured at DEP Fairhaven Monitor Maximum Concentration (ppm 1 ) No. of Days Averaging Period Year 1st 2nd 3rd 4th Standard Exceeded One Hour Eight Hours Note: 1. Parts per million. Measured values may be compared to the standards shown in Table 7-1. Source: Massachusetts Department of Environmental Protection, as reported to U.S. Environmental Protection Agency AIRData website ( Monitor Values Report accessed February 2, While violations of the ozone standards were measured at Fairhaven and other locations on mainland Massachusetts in recent years, ozone is a regional problem that is related largely to transport of precursor pollutants from upwind emission sources. Ozone concentrations on Martha s Vineyard would not be significantly affected by local emission sources. Because of Martha s Vineyard's offshore location and the relatively low intensity of development on the island, concentrations of pollutants other than ozone are unlikely to exceed the NAAQS due to local emission sources (including the airport). 7.2 ENVIRONMENTAL CONSEQUENCES Emission Sources and Regulatory Thresholds Air pollutants are emitted from a variety of sources at an airport. These sources include aircraft engines; aircraft ground support equipment; motor vehicles on the airport roadways, in parking facilities, and at terminal curbsides; and miscellaneous sources such as aircraft maintenance, fuel storage and handling, and building space heating. Because most of the project consists of taxiway and ramp work, roadways and parking, and building construction, the project will affect primarily aircraft and motor vehicles, including traffic generated by the proposed jail and office development. The project was evaluated with respect to operational or activity thresholds established by FAA, EPA and DEP. If a project exceeds a threshold, then specific types of air quality analysis are required. A General Conformity evaluation of increases in total emissions is required regardless of activity levels. The relationships of the forecasted 16 Massachusetts Department of Environmental Protection, as reported to U.S. Environmental Protection Agency AIRData website ( Monitor Values Report accessed February 2, Air Quality 7-8

9 MVY Martha s Vineyard Airport project activity levels to the relevant thresholds are given below for the 2010 future conditions, and the impacts of the Build Alternative are assessed compared to the No- Build Alternative No-Build and Build Alternatives: Emissions All Airport-Related Effects Airport operations were compared for the No-Build Alternative and the Build Alternative in The Build Alternative will not lead to an increase in aircraft operations or enplanements, and will not lead to a change in the fleet mix of aircraft using the airport. Therefore, no increase in airside emissions is anticipated as a result of the Build Alternative. Rather, the project will reduce aircraft delays by providing more efficient circulation of aircraft on the taxiways, apron, and aircraft parking areas. Consequently, a slight reduction is anticipated in emissions from aircraft idling and taxiing on the ground. The proposed improvements to the passenger terminal, roadways and parking in the terminal area, and cargo facilities are not anticipated to lead to any increase in emissions, because they will not result in any increase in aircraft operations, enplanements, or motor vehicle volumes. More efficient motor vehicle circulation is anticipated with the terminal area improvements. Consequently, slight reductions are expected in emissions from motor vehicle circulation in the terminal area. Only three components of the project would generate new or increased traffic and emissions in These are the proposed 79-bed jail (180 average vehicle-trips per day or ADT), 10,000 square feet of office development (114 ADT), and the 400-space rental car parking lot (500 ADT). Together, these three components will generate 794 new ADT. As discussed below, this modest amount of new traffic and emissions is less than DEP s threshold for requiring further analysis. Therefore, the project s addition of 794 ADT to the area s roadway network is not considered to lead to adverse air quality impacts. The improved terminal and the proposed jail may result in increases in emissions from the building heating and cooling systems. However, this increase is expected to be minor, and may be reduced by energy-efficient features planned for the new structures. Therefore, the net effect of the Build Alternative on emissions from all sources at the airport is expected to be neutral or possibly a slight reduction in total emissions Roadway Traffic Effects The DEP has issued guidance 17 on emission inventories (also known as mesoscale analysis) for projects in an EIR. The DEP guidelines established traffic volume thresholds of 3,000 ADT for office projects, and 6,000 ADT for other non-residential projects. New facilities that would generate more than these threshold levels of trips per 17 Massachusetts Department of Environmental Protection. Guidelines for Performing Mesoscale Analysis of Indirect Sources. Boston, MA. March Air Quality 7-9

10 Draft Environmental Impact Report/Environmental Assessment day are subject to a mesoscale analysis. For an existing facility that already generates roadway traffic, such as the airport, these thresholds apply only to the forecast traffic increase due to the project. Traffic levels that would occur with the future No-Build Alternative are not included in calculating the increase for comparison to these thresholds. During the ENF review process, DEP commented 18 that the EIR should include a mesoscale analysis. The EOEA Certificate on the ENF mandated a mesoscale air quality analysis. The EOEA Certificate on the Notice of Project Change made no further statement on air quality. The ENF had stated that the Existing number of vehicletrips per day (ADT) is 8,350, the Change will be 6,200 ADT, and the Total will be 14,550 ADT. As the Change of 6,200 ADT exceeded the threshold of 6,000 specified in the DEP guidance, the Certificate required a mesoscale analysis. However, the 6,000 ADT threshold specified in the guidance refers to a comparison between the Build Alternative and the No-Build Alternative in the same year. The Change stated in the ENF expressed the increase in ADT from the 2003 Existing Conditions to the 2010 Build Alternative. As such, the Change of 6,200 ADT included 3,600 ADT due to regional growth and forecasted non-project-related increases in Airport patronage that are not part of the Martha s Vineyard Airport Improvement Program. The increase in vehicle-trips due to the Martha s Vineyard Airport Improvement Program alone was only 2,600 ADT in the ENF. The Notice of Project Change involved a land use substitution. In place of the 20,000 square foot supermarket analyzed in the original ENF as induced development, a 79-bed county jail is proposed. The jail will generate many fewer vehicle-trips than the supermarket would have. With the jail in place, the increase in vehicle-trips due to the Martha s Vineyard Airport Improvement Program (the 2010 Build Alternative), relative to the 2010 No-Build Alternative, will be only 794 ADT as discussed previously. As the increase in daily vehicle-trips due to the airport Improvement Program is less than the thresholds of 3,000 ADT and 6,000 ADT specified in DEP guidance, the Program as currently proposed does not trigger the thresholds for a mesoscale analysis. The program sponsor, the Martha s Vineyard Airport Commission, requested by letter dated November 20, 2003 that the DEP modify its comment letter and not require a mesoscale analysis of the Martha s Vineyard Airport Improvement Program. The DEP is recommending this waiver request and has so notified MEPA (see footnote #4). This DEIR/EA assumes the EOEA Secretary will concur with the MA DEP recommendation; thus, this DEIR/EA contains no mesoscale analysis. The assessment of airport-wide effects in Section indicates that no adverse air quality impacts would occur due to project-related emissions. 18 Christine Kirby, Massachusetts Department of Environmental Protection. Memorandum to EOEA Secretary Ellen Roy Herzfelder. Boston, MA. May 12, Air Quality 7-10

11 MVY Martha s Vineyard Airport No-Build and Build Alternatives: Ambient Concentrations All Airport-Related Effects The FAA's Air Quality Procedures for Civilian Airports & Air Force Bases guidance document states that if the level of annual enplanements exceeds 1,300,000, or the level of general aviation and air taxi activity exceeds 180,000 operations per year, or a combination thereof, an assessment of ambient concentrations should be considered. Concentrations would be assessed using dispersion modeling and compared to the NAAQS. The FAA considers that airports with activity levels below these thresholds are very unlikely to have pollutant concentrations above the NAAQS, and no ambient concentrations assessment is required. These FAA criteria refer to total airport activity, not the change due to the project. The forecast activity levels for MVY in 2020 are 238,914 total enplanements and 115,104 total operations. These activity levels fall below the FAA thresholds. Accordingly, Airport operations are not expected to lead to pollutant levels above the NAAQS, and no ambient concentrations assessment was conducted for the DEIR/EA Roadway Traffic Effects Localized air quality effects of motor vehicle traffic, also known as microscale impacts, were addressed using EPA guidance 19 for CO. Motor vehicles produce most of the ambient CO, and emission rates of CO from vehicles are relatively high compared to emissions of other pollutants. The values of the NAAQS for CO are relatively low. Should adverse impacts occur due to local sources, the NAAQS for CO would be the first standard to be exceeded. Accordingly, CO is used to indicate the potential for localized adverse air quality impacts from motor vehicles in general and at roadway intersections in particular. Motor vehicles emit CO at the highest rates when they are operating at low speeds or idling in queues. For this reason, the potential for adverse air quality impacts is greatest at intersections where traffic is most congested. The EPA evaluation procedure, which is also applied by DEP, involves screening the signalized intersections in the study area based on traffic level of service (LOS) and volume. The EPA Region 1 office and the DEP require screening only of signalized intersections because unsignalized intersections are unlikely to have volumes and delays that are sufficiently severe to cause adverse air quality impacts. None of the intersections identified in the project traffic studies is signalized, and no signalization is proposed with the project. In addition, as discussed previously, the project will add only 794 daily trips to the local roadway system in Therefore, no adverse CO levels are expected for the forecast 2010 traffic levels with or without the project, and no further microscale analysis was performed for the DEIR/EA. 19 U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Guideline for Modeling Carbon Monoxide From Roadway Intersections, EPA-454/R , Research Triangle Park, NC, November Air Quality 7-11

12 Draft Environmental Impact Report/Environmental Assessment 7.3 CONSTRUCTION IMPACTS The proposed project will include site preparation, excavation, and construction of buildings, pavement, and infrastructure. Such construction activities can result in shortterm impacts on ambient air quality. These potential impacts include increased emissions from motor vehicles due to traffic disruption, emissions of fugitive dust, and direct emissions from construction equipment and trucks. These impacts will be temporary, and will affect only the immediate vicinity of the construction sites and access routes. A number of regulations and guidelines require mitigation of these potential impacts. All construction will be performed in accordance with the provisions of FAA Advisory Circular 150/ A, Standards for Specifying Construction of Airports, Item P- 156, Temporary Air and Water Pollution, Soil Erosion, and Siltation Control. General air pollution and nuisance conditions are prohibited by DEP regulations 310 CMR 7.01 (general prohibition) and 310 CMR 7.09 (dust and odors). Traffic disruption, such as from construction vehicles accessing the work sites, can lead to increased traffic congestion and consequent increases in motor vehicle exhaust emissions. These potential adverse effects can be mitigated by implementing proper traffic management techniques during the construction period. These techniques could include specifying truck routes, establishing staging areas for equipment and materials, designating parking areas for construction workers' vehicles, providing traffic control at the site accesses, and minimizing the volumes of construction-related vehicles during regional peak traffic periods. Fugitive dust emissions can occur during ground excavation, material handling and storage, movement of equipment at the site, and transport of material to and from the site. Fugitive dust is most likely to be a problem during periods of intense activity and would be accentuated by windy and/or dry weather conditions. DEP regulation 310 CMR 7.09 requires that dust impacts be mitigated. Good housekeeping practices such as wetting, paving, landscaping, or chemically treating exposed earth areas, covering dust-producing materials during transport, limiting dust-producing construction activities during high wind conditions, and providing street sweeping or tire washes for trucks leaving the site, can minimize the impacts from fugitive dust. Compared with emissions from other transportation sources in the study area, emissions from construction equipment and trucks are generally insignificant with respect to compliance with the NAAQS. However, opportunities exist for reducing these emissions. If the Martha s Vineyard Airport Commission designates this project for participation in the DEP s voluntary Massachusetts Diesel Retrofit Program (MDRP), then the construction contracts will require that heavy duty diesel-fueled equipment used on this project be equipped with emission controls. To implement this mitigation measure, the construction contractor must participate in the MDRP through retrofitting emission controls on diesel equipment that is not already equipped with controls. Other 7 Air Quality 7-12

13 MVY Martha s Vineyard Airport potential mitigation measures, if approved by the Martha s Vineyard Airport Commission, that could help satisfy the intent of this program may include specification of low-emissions equipment (EPA Tier 2 or Tier 3 compliant), or the use of alternativefueled or electric equipment where feasible. Emission controls and proper operation and maintenance will minimize nuisance odor and smoke impacts as well as reducing total pollutant emissions and concentrations. Excessive idling of engines should be prohibited in accordance with DEP regulation 310 CMR If all equipment is properly operated and maintained, no adverse effects on air quality are expected. 7.4 CONFORMITY EVALUATION The Build Alternative is evaluated under the General Conformity Rule, as described previously. Under the General Conformity Rule a project is presumed to conform to the SIP s goals for achieving compliance with the ambient air quality standards if the increase in emissions due to the proposed Federal action is less than the de minimis thresholds outlined in 40 CFR Part 93. With respect to the area s serious ozone nonattainment status, the critical thresholds are 50 tons per year of VOC s and 50 tons per year of NOx. In addition to the de minimis test, a conformity determination is also required if the emissions increase due to the project would equal or exceed ten percent of the total emission inventory for the entire nonattainment area. The air quality assessment has shown that any increases in VOC and NOx emissions due to the project are expected to be much less than the general conformity thresholds of a 50 tpy increase in VOC or a 50 tpy increase in NOx. Any increases also would be much less than the thresholds of 32,815 tons per year of VOC or 23,156 tons per year of NOx at which a project in Eastern Massachusetts is considered to be regionally significant for purposes of conformity. Compliance with the General Conformity Rule also requires that VOC s and NOx emissions due to construction activities be addressed. The construction of the individual facilities that make up the project is proposed to occur over an eight-year period from Federal Fiscal Year (FY) 2003 through FY Based on this extended schedule, and on previous experience with similar and larger airport projects in which construction emissions were quantified in detail, the emissions during construction of all components of this project are expected to be well under the de minimis thresholds of 50 tons per year for each pollutant. Therefore, construction emissions associated with the Martha s Vineyard Airport Improvement Program will conform to the SIP. The air quality assessment has demonstrated that any emission increases due to project operation will be much less than the de minimis thresholds, and that the project is not regionally significant for purposes of conformity. Construction emissions are also expected to be much less than the de minimis thresholds. Accordingly, it is determined 7 Air Quality 7-13

14 Draft Environmental Impact Report/Environmental Assessment under the General Conformity Rule that the increases in emissions due to the project will not: Cause or contribute to any new violation of any of the NAAQS in the MVY project area; Increase the frequency or severity of any existing violation of any NAAQS in the project area; or, Delay timely attainment of NAAQS or any required interim emission reductions in the project area. Therefore, the Proposed Action (the Build Alternative) complies with the General Conformity Rule, is in conformity with the SIP, and is in accordance with Section 176(c) of the 1990 Clean Air Act Amendments. Consequently, no mitigation measures are required with respect to conformity with the SIP. 7.5 CONCLUSIONS The air quality analysis has demonstrated that any increases in emissions due to the project will be insignificant. The analysis also shows that the proposed project conforms to the SIP in compliance with the General Conformity Rule. Consequently, no air quality mitigation measures are required for project operation. Potential air quality impacts during construction can be minimized by the mitigation measures described above. 7 Air Quality 7-14