This table summarizes the air quality impacts for each of the four actions evaluated in this EIR. Municipal Services Review

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1 3.2 Air Quality Overview of Impacts The analytical approach taken by this Subsequent EIR is described in Section 3.0 (Introduction to Environmental Analysis). The following section provides a description of existing air quality conditions in the SSJID area, identifies applicable air quality plans and regulations, and assesses the potential impacts on air quality. An analysis of cumulative impacts from other past, present and reasonably foreseeable projects is included in Section 5 (Cumulative Impacts) of this Subsequent EIR. This table summarizes the air quality impacts for each of the four actions evaluated in this EIR. Air Quality Impact 3.2-1: Conflict with or obstruct implementation of the applicable air quality plan Impact 3.2-2: Violate any air quality standard or contribute substantially to an existing or projected air quality violation Impact 3.2-3: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard Impact 3.2-4: Expose sensitive receptors to substantial pollutant concentrations Impact 3.2-5: Create objectionable odors affecting a substantial number of people Municipal Services Review Expanded Sphere of Influence Proposed 80-acre Annexation Updated Plan to Provide Retail Electric Service No Impact No Impact No Impact No Impact No Impact No Impact Less than Significant Less than Significant with Mitigation No Impact No Impact No Impact Less than Significant with Mitigation No Impact No Impact Less than Significant Less than Significant with Mitigation No Impact No Impact No Impact No Impact Existing Setting The Sphere Plan and MSR describe existing and planned services provided by SSJID, and these services are considered preexisting or previously approved for the purposes of this EIR. Section 2.0 describes the activities outlined in the Sphere Plan and MSR that are considered preexisting or previously approved activities rather than part of the proposed project. Activities supporting SSJID s existing services are either considered part of the baseline, to the extent that they have already been undertaken, or included in the cumulative impacts analysis as reasonably foreseeable projects, to the extent that they have yet to be implemented. Relevant to the analysis of air quality impacts, SSJID is obligated to extend its services to anyone who requests service within the SSJID boundary, subject to standard terms and conditions. Infrastructure necessary to provide utility services can involve short term construction activities that result in temporary emissions from construction equipment use. Similarly, operation and maintenance of facilities also result in emissions from routine inspection and maintenance activities. The minor and occasional emissions for necessary improvements and upkeep of the utility systems do not interfere with implementation of the applicable air quality management plans, which presume efficient delivery of public utility services. November Draft Subsequent EIR

2 Regional Air Basin The SSJID territory is located in the southern portion of San Joaquin County, which is the northern most county in the San Joaquin Valley Air Basin. The region s air quality is directly related to the basin s topographic features. The San Joaquin Valley Air Basin is defined by the Sierra Nevada Mountains in the east and the Coast Ranges in the west. The mountains surrounding the area restrict air movement through and out of the basin. These topographic features result in weak air flow that becomes blocked vertically by high barometric pressure over the San Joaquin Valley. As a result, the San Joaquin Valley is highly susceptible to pollutant accumulation over time. Thermal inversion layers, where a layer of warm air overlies and contains cooler air below, are common. Inversion layers can create problems in polluted areas because they resist the natural dispersion and dilution of air contaminants. Most of the surrounding mountains are above the normal heights of summer inversion layers, which vary from 1,500 to 3,000 feet (SJVAPCD, 2002) Regulated Pollutants National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS) are planning standards that define the upper limits for ambient airborne concentrations of pollutants. Since publication of 2006 Final EIR, the NAAQS 1 hour ozone standard has been eliminated and the 8 hour has become more stringent along with the standards for fine particulate matter. The standards are designed to protect all aspects of the public health and welfare, with a reasonable margin of safety. At the national level, the federal Clean Air Act requires the U.S. Environmental Protection Agency (U.S. EPA) to establish NAAQS and designate geographic areas that are either attaining or violating the standards. In California, the task of air quality management and regulation has been legislatively granted to the California Air Resources Board (CARB) and local air quality management districts. The CARB establishes CAAQS and designates the attainment status of each area in the State with the standards. The San Joaquin Valley Air Pollution Control District (SJVAPCD) coordinates the efforts to comply with these standards. The NAAQS and CAAQS are established for criteria pollutants. These are ozone, respirable particulate matter (PM10), fine particulate matter (PM2.5), carbon monoxide (CO), nitrogen dioxide (NO 2 ), sulfur dioxide (SO 2 ), and lead. Ozone is an example of a secondary pollutant that is not emitted directly from a source (e.g., an automobile tailpipe), but it is formed in the atmosphere by chemical and photochemical reactions. Reactive organic gases (ROG), including volatile organic compounds (VOC), are regulated as precursors to ozone formation. Table identifies the ambient air quality standards. Table National and California Ambient Air Quality Standards Pollutant Ozone Respirable Particulate Matter (PM10) Fine Particulate Matter (PM2.5) Carbon Monoxide (CO) Nitrogen Dioxide (NO2) Sulfur Dioxide (SO2) Averaging Time 1 hour 8 hours 24 hours Annual Mean 24 hours Annual Mean 1 hour 8 hours 1 hour Annual Mean 1 hour 24 hours California Standards* 0.09 ppm ppm 50 µg/m 3 20 µg/m 3 12 µg/m 3 20 ppm 9.0 ppm 0.18 ppm 0.03 ppm 0.25 ppm 0.04 ppm * ppm=parts per million; µg/m3= micrograms per cubic meter; =no standard. Source: CARB Ambient Air Quality Standards Chart, 2010a. National Standards* ppm 150 µg/m 3 35 µg/m 3 15 µg/m 3 35 ppm 9.0 ppm ppm ppm ppm Draft Subsequent EIR November 2011

3 The primary health effects of the criteria air pollutants are as follows: Ozone (O 3 ): aggravation of respiratory and cardiovascular diseases; impairment of cardiopulmonary function; and eye irritation. Ozone can also affect sensitive plant species by interfering with photosynthesis, and is therefore a threat to California agriculture and native vegetation. Particulate matter (PM10 and PM2.5): increased risk of chronic respiratory disease such as bronchitis, emphysema, and asthma; reduced lung function; increased cough and chest discomfort; and particulates may lodge in and/or irritate the lungs. Carbon monoxide (CO): impairment of oxygen transport in the bloodstream; aggravation of cardiovascular disease; impairment of central nervous system function; fatigue, headache, confusion, dizziness; death at high levels of exposure; and aggravation of some heart diseases (angina). Nitrogen dioxide (NO 2 ): risk of acute and chronic respiratory disease. Sulfur dioxide (SO 2 ): aggravation of respiratory diseases (asthma, emphysema); reduced lung function; and irritation of eyes. Toxic air contaminants (TACs) are a category of air pollutants separate from criteria pollutants that pose a present or potential hazard to human health, but which tend to be emitted on a localized and sourcespecific basis and cause impacts that are typically more localized than those created by criteria air pollutants. There are more than 900 toxic air contaminants recognized by different regulatory agencies. Although ambient air quality standards do not exist for these pollutants, sources are regulated with emission and risk based requirements at the federal, State, and local levels Air Quality Planning and Attainment The CARB is responsible for oversight of air quality management in the State. Setting emissions standards and regulations for most mobile sources (e.g., autos, light duty trucks, off road equipment, etc.) and overseeing the local air pollution control districts are two of CARB s major roles. The San Joaquin Valley Air Pollution Control District is responsible for demonstrating that attainment of the ambient air quality standards is either achieved or will be achieved through proper regional planning. The SJVAPCD regulates stationary emission sources and indirectly manages emissions from mobile sources and construction equipment through coordination with local municipalities and metropolitan planning organizations, such as the San Joaquin Council of Governments (SJCOG). Because of ongoing violations of the NAAQS and CAAQS for ozone, PM10, and PM2.5, the San Joaquin Valley Air Basin is designated as a nonattainment area for these criteria pollutants. The SJVAPCD manages these pollutants through a long term attainment planning process that forecasts emissions and future concentrations depending on changes in source activity (population and economic growth), regulatory programs, and meteorological conditions. The air quality plans for attainment demonstration (one each for ozone and PM10) are evolving documents that are updated approximately triennially to reflect the changing population, economic, land use, and transportation conditions in the San Joaquin Valley. Ozone Planning. The SJVAPCD Governing Board voluntarily downgraded the region from a severe federal nonattainment status for the federal 1 hour ozone standard to extreme, and submitted an Extreme Ozone Attainment Demonstration Plan to EPA in This plan includes elements to attain the federal 1 hour ozone standard that are the foundation for later ozone plans and was approved on March 8, 2010 by U.S.EPA. November Draft Subsequent EIR

4 The U.S.EPA is also reviewing the SJVAPCD s 2007 Ozone Plan to attain the federal 8 hour ozone standard that was approved by CARB on June 14, This plan aims to reduce ozone and would also provide particulate matter benefits, primarily by achieving a 75% reduction in NOx emissions by The plan relies on four main approaches: tighter SJVAPCD regulations for stationary sources, wider use of incentive based measures (like the Carl Moyer Program) to accelerate deployment of cleaner sources, new innovative programs for trip reduction and energy conservation, and expanded controls on mobile source tailpipe emissions. Particulate Matter Planning. The 2007 PM10 Maintenance Plan illustrates how the SJVAPCD intends to continue the efforts of the 2003 PM10 Plan and 2006 PM10 Plan that implemented aggressive PM10 controls in the region, including Reasonably Available Control Measures (RACM) for large existing sources of PM10 and fugitive dust. In response to the 2007 PM10 Maintenance Plan, in November 2008, the U.S. EPA redesignated the SJVAPCD to attainment for the federal PM10 standard (73 FR 66759, November 12, 2008). The 2008 PM2.5 Plan was adopted by the SJVAPCD Governing Board on April 30, 2008, and it includes measures for attaining the 1997 and 2006 federal PM2.5 standards. The 2008 PM2.5 Plan shows that emission reductions of NOx, directly emitted PM2.5, and SO 2 are needed to demonstrate attainment of the PM2.5 NAAQS in the San Joaquin Valley. The U.S. EPA review of the SJVAPCD s 2008 PM2.5 Plan is ongoing through Carbon Monoxide Planning. Improvements in CO conditions led by lower emitting motor vehicles and reformulated fuels allowed the region to be upgraded to a status of CO attainment in Toxic Air Contaminants. Management of toxic air contaminants is accomplished through a combination of source identification, risk characterization, control requirements, and avoidance of land use conflicts. Mobile sources of TACs (such as particulates from diesel exhaust) are managed through vehicle emission control programs implemented on a State and federal level with the cooperation of fuel suppliers and vehicle and engine manufacturers. Management of the public s exposure to odors is also generally accomplished by avoiding land use conflicts with appropriate distances Applicable Air Quality Regulations CARB Statewide Portable Equipment Registration Program. This program allows operation of portable equipment throughout California without having to obtain individual permits from local air districts. This program provides convenience to construction contractors who may move heavy construction equipment throughout the State. CARB Off Road Equipment Standards. The California Clean Air Act mandates CARB to achieve the maximum degree of emission reductions from all off road mobile sources in order to attain the State ambient air quality standards. Off road mobile sources include construction and farming equipment. Tier 1, Tier 2, and Tier 3 standards for large compression ignition engines used in off road mobile sources went into effect in California in 1996, 2001, and 2006 respectively. In addition, equipment can be retrofitted to achieve higher Tier standard using the CARB verified retrofit technologies. These standards and ongoing rulemaking jointly address NOx emissions and toxic particulate matter from diesel combustion. SJVAPCD Rules 4101 and 4102 (Visible Emissions and Nuisances). These rules apply to any source of air contaminants, and they prohibit emissions of visible air contaminants to the atmosphere and any activity that creates a public nuisance. Draft Subsequent EIR November 2011

5 SJVAPCD Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Maintenance Operations). This rule applies to the use of asphalt for paving, should it be necessary to resurface substation sites or restore roadways disturbed by project activities. SJVAPCD Regulation VIII (Fugitive PM10 Prohibitions). This series of rules is aimed at reducing fugitive PM10 emissions. Sources regulated under these rules include: construction, excavation, earthmoving activities, carryout and trackout, open areas, paved and unpaved roads, unpaved vehicle/equipment traffic areas, and agricultural sources. Regulation VIII was most recently revised in 2004, and violating Regulation VIII would be subject to enforcement action by SJVAPCD. Regulation VIII requires implementation of various dust control measures (watering unpaved surfaces, minimizing vehicle speeds on unpaved surfaces, etc.) to ensure that visible dust emissions are substantially eliminated. See the discussion of Impacts and Mitigation (Section ) for a detailed description of Regulation VIII requirements. SJVAPCD Rule 9510 (Indirect Source Review). The Indirect Source Review (ISR) rule requires quantification and control of indirect, area source, and construction emissions for certain development projects requiring discretionary approval. An application and an air impact assessment demonstrating a prescribed level of indirect source emission reductions are required for larger development projects. Examples of projects triggering ISR applicability are residential (50 units or greater), commercial (2,000 square feet or larger), and government (10,000 square feet or larger) developments or transportation projects that cause construction emissions (over two tons of NOx or PM10). Because the proposed project would affect only utility infrastructure, SJVAPCD Rule 9510 would not apply Existing Local Air Quality Conditions CARB and SJVAPCD continually monitor the ambient concentrations of criteria pollutants including ozone, inhalable particulate matter (PM10), fine particulate matter (PM2.5), and carbon monoxide (CO). The monitoring station nearest the SSJID territory is in Stockton at Hazelton Avenue. Table summarizes the relevant data Sensitive Receptors Land uses such as schools, children s day care centers, hospitals, and convalescent homes are considered to be more sensitive than the general public to poor air quality because the population groups found at these uses have increased susceptibility to respiratory distress. Persons engaged in strenuous work or exercise also have increased sensitivity to poor air quality. Residential areas are considered more sensitive to air quality conditions compared to commercial and industrial areas because people generally spend longer periods of time at their residences, with associated greater exposure to ambient air quality conditions. Each of these land uses can be found within the SSJID territory and in close proximity to proposed project activities. In Manteca, homes are about 150 feet north of the location of new equipment proposed for the Manteca Substation, and along many of the proposed underground cable sites, homes would be within roughly 50 feet of the work. November Draft Subsequent EIR

6 Table Summary of Ambient Air Quality Data, Stockton Pollutant Most Restrictive Standard Ozone (1-hour, ppm) 0.09 (CAAQS) Ozone (8-hour, ppm) (CAAQS) Ozone (days over the 1-hour State standard) PM10 (24-hour, µg/m 3 ) 50 (CAAQS) PM10 (annual average, µg/m 3 ) 20 (CAAQS) PM10 (est. days over the 24-hour State standard) PM2.5 (24-hour, µg/m 3 ) 35 (NAAQS) PM2.5 (annual average, µg/m 3 ) 12 (CAAQS) PM2.5 (days over the 24-hour federal standard) CO (1-hour, ppm) 20 (CAAQS) CO (8-hour, ppm) 9.0 (CAAQS) NO2 (1-hour, ppm) (NAAQS) NO2 (annual average, ppm) (NAAQS) SO2 (1-hour, ppm) (NAAQS) SO2 (24-hour, ppm) 0.04 (CAAQS) Notes: ppm=parts per million; µg/m 3 = micrograms per cubic meter; =not applicable. Source: CARB Air Quality Data Statistics, 2010b, USEPA Air Data, Environmental Impacts and Mitigation Measures Significance Criteria The following significance criteria for air quality were derived from Appendix G of the State CEQA Guidelines. An impact to air quality would be significant 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 non attainment 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. The State CEQA Guidelines also permit lead agencies, in making determinations of significance for air quality impacts, to rely on criteria recommended by the local air pollution control district or air quality management district. The San Joaquin Valley Air Pollution Control District established thresholds of significance in its guidelines in 2002 (SJVAPCD, 2002). The guidelines define separate thresholds for construction emissions, project operation and use, and cumulative impacts. According to these criteria, a project would cause a significant adverse air quality impact if it would: Draft Subsequent EIR November 2011

7 Cause construction activities that would not comply with SJVAPCD Regulation VIII or implement effective and comprehensive control measures; Cause operational emissions of air pollutants that would cause or substantially contribute to either localized or regional violations of the ambient air quality standards [emissions of more than 10 tons per year (tpy) of NOx or VOC or more than 15 tpy of PM10 would substantially contribute to ongoing regional ozone or PM10 violations, based on the thresholds of Table 4 1 in SJVAPCD Rule 2201]; or Cause exposure of sensitive receptors to substantial concentrations of TACs or objectionable odors. If project development would individually cause a significant air quality impact from project operations, then the cumulative impacts of the project would be considered significant (SJVAPCD, 2002) Impacts and Mitigation The following section analyzes the air quality impacts of the four separate actions: Sphere Plan and Municipal Services Review, Proposed Expanded Sphere of Influence, Proposed 80 acre annexation, and Updated Plan to Provide Retail Electric Service. Sphere Plan and Municipal Services Review This analysis discusses the potential impacts associated with the Sphere Plan and MSR that can be identified during this programmatic review, and separate discussions follow disclosing the impacts related to the other adoption and approval actions: the proposed SOI expansion, proposed 80 acre annexation, and plan to provide retail electric service. Projects that would occur with or without the adoption and approval of the Sphere Plan and MSR, such as the Water Transfer Renewal Project, Phase II of the South County Water Supply Program (SCWSP), the supply of drinking water to Escalon and Ripon, and the Division 9 Project were subject to or will in the future be subject to separate environmental review. These infrastructure improvements are analyzed as part of this EIR as foreseeable projects for potential cumulative impacts (Section 5, Cumulative Impacts). Improvements associated with the proposed retail electric service plan that appear in the Sphere Plan and MSR are analyzed below as part of the Updated Plan to Provide Retail Electric Service. The Sphere Plan and MSR describe a variety of infrastructure investments necessary to provide an adequate level of service within the SOI. The analysis of the Sphere Plan and MSR discusses the general types of site specific impacts that could occur. However, no construction activities are proposed for approval with the potential adoption of the Sphere Plan and MSR. Any construction related to these infrastructure investments would occur with or without the adoption and approval of the Sphere Plan and MSR. The MSR, technically, is not a plan that commits SSJID to any particular course of action; rather, it is a review of services provided within a particular area, with the idea that it will provide information useful to LAFCo as it makes decisions. Impact 3.2 1: Conflict with or obstruct implementation of the applicable air quality plan Air quality management plans are based on an array of assumptions, including the expectation that essential public utility services are readily available and provided with reasonable efficiency. Adopting the Sphere Plan and MSR would demonstrate SSJID s ability to provide these essential utility services, and it would not obstruct any aspect of air quality management planning that relies on the reliable and November Draft Subsequent EIR

8 efficient availability of these services. Because the existing previously planned services provided by SSJID and improvements described in the Sphere Plan and MSR are part of the environmental setting, no new construction or change in action would occur. No potential conflicts or obstructions to existing air quality management plans would occur with adoption of the Sphere Plan and MSR. Mitigation for Impact No mitigation is required. Impact 3.2 2: Violate any air quality standard or contribute substantially to an existing or projected air quality violation The Sphere Plan and MSR describe a variety of infrastructure improvements necessary to provide an adequate level of service within the SOI, including linear infrastructure necessary for previously approved and operational activities (e.g., water supply pipelines). Infrastructure improvements and maintenance activities needed for providing services, at times, requires mobilizing a construction workforce. The number of workers necessary and the related construction or maintenance traffic is limited to only the needed crews, usually a few workers, which leads to existing traffic related emissions. Haul truck traffic includes trucks carrying equipment and materials, such as pipes or trenchers, along the alignments of infrastructure improvements. Emissions due to providing SSJID s existing and previously planned services are part of the environmental setting activities, and no new construction or change in action would occur with adoption of the Sphere Plan and MSR. Therefore, adopting the Sphere Plan and MSR would not cause emissions that could violate or contribute to a violation of any air quality standard. No impact would occur. Mitigation for Impact No mitigation is required. Impact 3.2 3: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non attainment under an applicable federal or State ambient air quality standard Emissions occurring as a result of infrastructure improvements that SSJID must undertake to provide an adequate level of service within the SOI during the life of the SOI, and during operation and maintenance of the utility systems, are already part of SSJID s previously approved plans for providing services. Existing emissions from SSJID activities that are previously approved and are operational are part of the existing environmental setting and the baseline for environmental analysis. Because the existing previously planned services provided by SSJID and improvements described in the Sphere Plan and MSR are baseline activities, no new construction or change in action would occur. Therefore, adoption of the Sphere Plan and MSR would not result in approval of any project that would generate air pollutants. Routine emissions occurring under the Sphere Plan and MSR would not result in a cumulatively considerable net increase for pollutants for which the region is nonattainment (ozone, PM10, or PM2.5). No impact would occur. Mitigation for Impact No mitigation is required. Draft Subsequent EIR November 2011

9 Impact 3.2 4: Expose sensitive receptors to substantial pollutant concentrations Emissions occur along narrow utility corridors as a result of infrastructure improvements or operation and maintenance of the utility systems. Routine activity occurring under the Sphere Plan and MSR may temporarily bring construction equipment close to sensitive receptors. However, because the existing previously planned services provided by SSJID and improvements described in the Sphere Plan and MSR are part of the existing environmental setting, no new construction or change in action would occur. As adoption of the Sphere Plan and MSR would not result in approval of any project that would generate air pollutants, adopting the Sphere Plan and MSR would not result in the exposure of sensitive receptors to air pollutant concentrations. No impact would occur. Mitigation for Impact No mitigation is required. Impact 3.2 5: Create objectionable odors affecting a substantial number of people Implementing the Sphere Plan and MSR would not result in approval of any project causing odors. Therefore, there would be no impact under the Sphere Plan and MSR related to objectionable odors. Mitigation for Impact No mitigation is required. Proposed Expanded Sphere of Influence The following presents a general discussion of whether the proposed expanded sphere of influence (SOI) would create an adverse air quality effect. This analysis is a programmatic assessment of the proposed SOI described in Section The expanded SOI would make the SOI boundaries consistent with the Manteca city limits. SSJID facilities are presently used for stormwater drainage in this area. Adoption of the expanded SOI would not directly or indirectly impact air quality since the proposed SOI requires no construction or operation activities that would emit air pollutants. The proposed SOI would pose no potential to conflict with or obstruct implementation of air quality management plans. With no construction or change in operation activity, the proposed SOI would not generate emissions that could violate or contribute to a violation of any air quality standard. Similarly, adoption of the expanded SOI would not have any potential to expose sensitive receptors to odors or other pollutants. Proposed 80 Acre Annexation The following presents a discussion of whether the 80 acre annexation would create an adverse effect to air quality. This analysis is a project level assessment of the annexation. This annexation has been proposed as a separate action wholly independent of and for distinctly different reasons than SSJID s proposed plan to provide retail electric services, and it is not dependent in any way upon SSJID s separate proposal to provide such electric services. The proposed 80 acre annexation is described in Section and would be located west of the intersection of French Camp Road and Austin Road, near Castle Road, see Figure 2 1. Minor construction would be required to install an electrically powered sprinkler sump from the existing SSJID irrigation facilities to the 80 acre property. This construction would be limited in nature and would involve travel November Draft Subsequent EIR

10 on rural paved and unpaved roads to reach the existing SSJID facilities and limited use of construction equipment within the private property, similar to that for the routine operation and maintenance that currently occurs along the irrigation district pipelines and canals. Emissions created while installing the sump would occur soon after approval of the annexation; would not likely overlap with construction emissions of the proposed electric service plan; and would be substantially less than the daily levels of emissions for other construction contemplated in this analysis (see Table 3.2 3). The annexation would pose no potential to conflict with or obstruct implementation of air quality management plans, and because the work would be complete within one month and result in no permanent source of emissions, there would be no potential for the emissions to be cumulatively considerable. No sources of odors would occur during installation or operation of the electric sprinkler sump. Impact 3.2 2: Violate any air quality standard or contribute substantially to an existing or projected air quality violation Delivering irrigation water to the proposed annexation through existing SSJID facilities would provide the landowner with an alternative to groundwater pumping. The emissions caused by construction to install the sprinkler sump and the associated travel on rural paved and unpaved roads would be similar to those that occur for the routine operation and maintenance that currently occurs along the irrigation district canals. Construction on the property would be required to comply with relevant subsections within SJVAPCD Regulation VIII so that the various dust control measures (watering unpaved surfaces, minimizing vehicle speeds on unpaved surfaces, etc.) would ensure that visible dust emissions are substantially eliminated. Construction on the proposed 80 acre annexation would commence soon after approval, and this would not be likely to overlap with construction of the proposed electric distribution system modifications, which would be likely to commence construction later. If the proposed annexation is approved after the proposed electric service plan moves forward, then construction on the property could overlap for no more than one month with construction of the proposed electric distribution facilities. With the minor level of construction required to be in compliance with SJVAPCD Regulation VIII, the limited use of construction equipment for annexing this property would not cause or contribute substantially to any violation of air quality standards. The resulting impact would be less than significant. Mitigation for Impact No mitigation is required. Impact 3.2 4: Expose sensitive receptors to substantial pollutant concentrations The proposed annexation property is surrounded on all sides by orchards, and no sensitive receptor would be located near the construction necessary to install the sprinkler sump. Construction emissions during a one month period, and the level of activity would not cause substantial concentrations of any pollutant at receptors. Compliance with SJVAPCD Regulation VIII would help to prevent a nuisance, and ensure appropriate dust control, resulting in a less than significant impact. Mitigation for Impact No mitigation is required. Updated Plan to Provide Retail Electric Service Approving the plan to provide retail electric service would lead to SSJID conducting the construction necessary to separate the electric distribution system and the necessary operational activities to keep Draft Subsequent EIR November 2011

11 up the electric system. Each of these types of activities would cause emissions potentially affecting air quality. This impact analysis discusses the potential project specific impacts associated with the plan to provide retail electric services and identifies mitigation measures for potentially significant impacts. This represents a project level assessment of the updated plan and also a programmatic level assessment of foreseeable consequences of the retail electric service plan, such as the expansion of SSJID s retail electric service to Area D or Area E (see Figure 2 2 in Chapter 2, Project Description). However, SSJID has no immediate plans to annex areas within Area D or Area E or to provide retail electric service in these areas. If the current proposal for retail electric service is approved and if the areas are annexed in the future, SSJID would likely expand this service to Area E within 10 years and to Area D within 30 years. Mitigation measures that apply to the proposal for retail electric service would likely also apply to the future expansion of electric service within the SOI. Approval of the proposed project, however, would not commit SSJID to exactly these mitigation measures for possible future annexations because considerations may arise within 30 years that would make the near term measures obsolete or outdated. Specific proposals for annexations or service beyond SSJID s existing territory may need to undergo the project level environmental review process and other required approvals should SSJID decide to pursue such an annexation or service expansion in the future. Emissions from Construction of Proposed Distribution System Modifications Construction activities for implementing the plan to provide retail electric service are described in detail in Section 2.4 of this EIR (see Section 2, Project Description) and would include installation of new distribution line poles, underground excavation of trenches, stringing of the new conductor, modification to existing substations, and construction of the proposed Jack Tone Substation. Actual construction activities for separation of the distribution system are expected to occur over approximately nine months, with one month of testing before the system is energized. This would be the most intense period of work. Substantially less activity would occur after the first year and after the separation. The construction activity to separate the systems would then be followed by substantially less activity as SSJID conducts distribution system maintenance throughout the operational life of the electric facilities. Up to eight separate contractor construction crews, each containing about three to five workers, would work on the various overhead and underground electric distribution system modifications to separate the systems, for up to about 40 workers. Over the operational life of the electric facilities, SSJID would add new employees for distribution system operation and maintenance including a staff of about 70 additional full time workers. Criteria pollutant and toxic air contaminant emissions would occur during use of the construction equipment and vehicles. Construction equipment (e.g., digger derricks, bucket trucks, cable dollies backhoes, etc.) and materials (e.g., poles, conductor, asphalt, etc.) would be mobilized throughout the SSJID territory. In addition, debris (e.g., demolished pavement, old poles and conductor, excavated soils, etc.) would need to be hauled offsite for recycling or disposal at the nearest approved and appropriate facility, for example the Class II landfill on Austin Road, north of Manteca (Forward Inc.). Approximately 34.5 miles of new or reconductored distribution system facilities would be built. Work would occur in existing public utility easements or rights of way. However, any work on paved or unpaved surfaces would create fugitive dust emissions. Some of this activity would occur within close proximity of sensitive uses (with localized effects discussed below). November Draft Subsequent EIR

12 Construction of the electric distribution system modifications would generate emissions at the locations of the work along the right of way of public roads and at substation sites. The impacts would principally consist of exhaust emissions from heavy duty diesel and gasoline powered construction equipment (e.g., ozone precursors, NOx and VOC, other criteria pollutants, such as CO and PM10, and toxic exhaust emissions) and fugitive particulate matter (dust) from travel on unpaved surfaces. Beyond the boundaries of the right of way and substations, exhaust emissions would also be caused by workers commuting to and from the work sites, from trucks hauling conductor, pole segments, and other equipment and supplies to the sites, and crew trucks (e.g., derrick trucks, bucket trucks, pickups). Table shows the estimated emissions caused by the proposed construction activities. Supporting calculations are shown in this Subsequent EIR Appendix B, Air Quality Attachment. Table Construction Emissions Caused by Proposed Retail Electric Service Plan NOx PM10 CO VOC SOx NOx PM10 CO VOC SOx Construction Activity/Phase (lb/day) (lb/day) (lb/day) (lb/day) (lb/day) (ton) (ton) (ton) (ton) (ton) On-road crew and workers On-road diesel trucks Off-road equipment exhaust Fugitive dust Total Construction Emissions Threshold for Significance None None None None None None 10 None Source: Appendix B, Air Quality Attachment. Aspen Environmental Group, Note: Total construction emissions reported in tons, expected to occur over a twelve-month period. Emissions during Operation and Maintenance of SSJID Electric Distribution System Once construction of the SSJID modifications is complete, operational emissions would result from vehicle use for periodic maintenance, repair, and inspection of the SSJID distribution system components, and from vehicles used by the staff of about 70 additional new employees for distribution system operation and maintenance. The minor mobile source emissions would be the only direct source of emissions related to project operation. System monitoring, control, and inspections would induce light and medium heavy duty truck traffic, similar to the traffic caused by PG&E for upkeep of the existing system. The emission rates occurring as a result of the operation and maintenance of the electric distribution system over the life of the system would be no greater than those shown during the period for constructing the distribution system modifications (see Table 3.2 3) and in line with the baseline condition for PG&E s upkeep. Emissions from Power Generating Facilities Approval of the plan to provide retail electric service would also allow SSJID to replace PG&E in making decisions on power purchases for electricity used in the SSJID territory. SSJID proposes no new power plants or electric generating facilities, but it would procure power from wholesalers. SSJID proposes to make power purchases on the open market from a mix of renewable and natural gas fired resources. This electricity would be delivered through the interconnected transmission system that currently serves SSJID. These purchases would displace power purchases currently made by PG&E. SSJID would purchase approximately the same amount of power that PG&E would no longer need to acquire. Where PG&E s power purchases are largely from a mix of resources (including hydroelectric, geothermal, natural gas fired, and other resources) across the PG&E territory and California, PG&E did not achieve the Draft Subsequent EIR November 2011

13 20% Renewable Portfolio Standard (RPS) goal by Upon entering retail electric service, SSJID would become subject to targets to acquire its power according to the statewide RPS of 33% by the end of 2020 and a minimum of 20% in interim years. Since SSJID is committed to providing at least 20% renewable power, this should lead to an indirect reduction of some emissions from natural gas fired power plants that produce electricity for PG&E. However, it would be speculative to characterize any change in air quality impacts caused by power generated for SSJID customers. The air quality impacts caused by any power plant or electric generation facility are highly variable depending on the design and sitespecific conditions each individual power plant, varying with the generating technology and the regional air basin or setting of every different power plant. Overall power plant air quality impacts would not be substantially different from those that would occur if PG&E continued ownership of the distribution system. Impact 3.2 1: Conflict with or obstruct implementation of the applicable air quality plan A project would be inconsistent with the established regional air quality plans for attainment if it would result in population and/or employment growth or growth in vehicle miles traveled exceeding the growth assumptions of the air quality plans. The SJVAPCD air quality plans for ozone and particulate matter have each been updated recently, and they anticipate and allow for population and/or employment growth, including developing the necessary new infrastructure. A project would also be judged to obstruct implementation of the air quality plans if it would interfere with implementation of the transportation control measures in the plans. The retail electric service plan would add a total of approximately 70 permanent workers for the electric service operations. The addition of these new jobs would not result in substantial employment or population growth. As shown in Section 3.9 (Socioeconomics, Public Services, and Utilities), San Joaquin County is expected to witness substantial population growth, and the effect of SSJID providing electric service would not substantially contribute to this growth. One objective of the proposed project is to coordinate local water conservation, energy efficiency, and demand management programs, which would be fully compatible with air quality planning goals related to energy conservation. The proposed electric service plan would not conflict with the growth assumptions in the air quality plans nor obstruct implementation of any of the proposed control measures contained in these plans, and therefore, would have no impact on applicable air quality plans. The possible future expansion of SSJID s retail electric service to Area D and Area E (Figure 2 2 in Chapter 2, Project Description) would also not impact applicable air quality plans. Mitigation for Impact No mitigation is required. Impact 3.2 2: Violate any air quality standard or contribute substantially to an existing or projected air quality violation The entire San Joaquin Valley Air Basin often violates state and federal ozone ambient air quality standards and is a nonattainment area for particulate matter (state PM10; state and federal PM2.5). Therefore, emissions of exhaust from vehicles and equipment or from dust related to an individual project, if substantial, can contribute to the existing violations of the ozone or particulate matter standards. The SJVAPCD defines a substantial contribution for ozone precursor emissions (NOx or VOC) as those exceeding 10 tpy and for particulate matter (PM10) as those exceeding 15 tpy, for recurring sources (project operations). The SJVAPCD recommends a qualitative approach emphasizing implementation of November Draft Subsequent EIR

14 effective and comprehensive control measures for fugitive dust to determine whether construction emissions would cause a substantial contribution. The SJVAPCD recognizes that construction phase emissions are generally short term in duration. It is not necessary for every project to quantify construction emissions and compare them to prescribed thresholds, but for large construction projects, equipment can cause emissions over the quantitative thresholds established by the SJVAPCD for project operations. SSJID s proposed activities for electric distribution system construction and operation would be required to comply with SJVAPCD rules including Regulation VIII. Regulation VIII requires implementation of various dust control measures to ensure that visible dust emissions are substantially eliminated. SJVAPCD Regulation VIII requires that: All disturbed areas, including storage piles, which are not being actively utilized for construction purposes, shall be effectively stabilized of dust emissions using water, chemical stabilizer/suppressant, covered with a tarp or other suitable cover or vegetative ground cover. All onsite unpaved roads and offsite unpaved access roads shall be effectively stabilized of dust emissions using water or chemical stabilizer/suppressant. All land clearing, grubbing, scraping, excavation, land leveling, grading, cut & fill, and demolition activities shall be effectively controlled of fugitive dust emissions utilizing application of water or by presoaking. When materials are transported offsite, all material shall be covered, or effectively wetted to limit visible dust emissions, and at least six inches of freeboard space from the top of the container shall be maintained. All operations shall limit or expeditiously remove the accumulation of mud or dirt from adjacent public streets at the end of each workday. (The use of dry rotary brushes is expressly prohibited except where preceded or accompanied by sufficient wetting to limit the visible dust emissions. Use of blower devices is expressly forbidden.) Following the addition of materials to, or the removal of materials from, the surface of outdoor storage piles, said piles shall be effectively stabilized of fugitive dust emissions utilizing sufficient water or chemical stabilizer/suppressant. Within urban areas, trackout shall be immediately removed when it extends 50 or more feet from the site and at the end of each workday. Any site with 150 or more vehicle trips per day shall prevent carryout and trackout. SJVAPCD Rule 8021 (Subsection 6.4) of Regulation VIII also requires SSJID to notify the SJVAPCD prior to commencing earthmoving activities on the proposed Jack Tone Substation site. For any site up to five acres in size, the SJVAPCD must be notified at least 48 hours prior to commencing earthmoving. The additional, or enhanced, dust control measures recommended by SJVAPCD for project construction are shown below (from Tables 6 2 and 6 3 of SJVAPCD, 2002). SJVAPCD recommends that project proponents shall: Draft Subsequent EIR November 2011

15 Limit traffic speeds on unpaved roads to 15 mph. Install sandbags or other erosion control measures to prevent silt runoff to public roadways from sites with a slope greater than 1 percent. Install wheel washers for all exiting trucks, or wash off all trucks and equipment leaving the site. Install wind breaks at windward side(s) of construction areas. Suspend excavation and grading activity when winds exceed 20 mph. Limit area subject to excavation, grading, and other construction activity at any one time. Implementing Mitigation Measure 3.2 2a would ensure that SSJID s activities would be consistent with the SJVAPCD recommendations for enhanced and additional dust control (SJVAPCD, 2002), which go beyond the requirements of Regulation VIII. Recommended measures related to installing wheel washers and wind breaks would not be effective or appropriate for the narrow utility corridors of the electric distribution system, and they would provide little or no incremental value beyond the other measures identified. These two measures are normally for large construction sites. The proposed Jack Tone Substation site would not exceed two acres. The distribution system modifications would involve work over a widely distributed area, almost entirely within the established right of way of public roads. As such, much of the activity would occur on or near paved surfaces. Work at existing substations would also occur on developed surfaces unlikely to add substantial mud the wheels of construction vehicles. Additionally, Regulation VIII requires removal of trackout and expeditiously removing the accumulation of mud or dirt any public streets adjacent to project work. Wind breaks or other artificial barriers would be unnecessary because the proposed substation area would be small, and the existing substation sites are previously developed and fenced near the closest receptors. While the location of the Jack Tone Substation has been identified, the location of long term improvements that might be needed to respond to future growth and development remains unknown. It is assumed at this time any future substation would be similar or identical in size to Jack Tone Substation and require similar construction activities. Implementing Mitigation Measure 3.2 2b would ensure that SSJID s activities would be consistent with SJVAPCD recommendations for controlling construction equipment emissions (from Table 6 4 of SJVAPCD, 2002). These practices ensure that equipment emissions would be subject to effective and comprehensive control. Implementing Mitigation Measures 3.2 2a and 3.2 2b regarding dust control and equipment emissions would eliminate the possibility of construction emissions having the potential to violate air quality standards or contribute substantially to existing violations. Table shows that construction emissions would be less than thresholds established by SJVAPCD for a substantial contribution from recurring sources (project operations), indicating that the short term construction impacts would not be likely to cause emissions at high enough rate to substantially contribute to either localized or regional violations of the ambient air quality standards. Emissions from operation and maintenance of the electric distribution system over the life of the system would be no greater than those for construction (Table 3.2 3), and these emissions would be essentially offset by an expected reduction in emissions from PG&E crews and staff currently operating the electric distribution system in the SSJID territory, although the level of emissions occurring from PG&E crews and staff today is unknown. With SSJID required to comply with SJVAPCD Regulation VIII, and by implementing the effective and comprehensive control measures for dust and equipment exhaust, the emissions due to SSJID implementing the proposed electric distribution system construction and operation would not cause or contribute sub November Draft Subsequent EIR