5.3 Air Quality and Greenhouse Gas Emissions

Transcription

1 5. NEPA 5.3 Air Quality and Greenhouse Gas Emissions For a comprehensive discussion of the Project s affected environment and cumulative impacts as it relates to air quality and greenhouse gas (GHG) emissions, refer to Section 4.3, Air Quality and Greenhouse Gas Emissions and Air Quality Technical Report in Appendix H. This section includes a definition of air quality and GHG emissions; a list of federal, state, regional, and local regulations relevant to analysis of impacts on air quality and GHG emissions under CEQA. This section also includes emissions from construction and operation of the Project analyzed under CEQA. Federal regulations and legislation relevant to the Project are listed as follows Regulatory Setting The following federal regulations are relevant to the Project. For a detailed discussion of the regulatory setting, including state, local, and regional regulations related to air quality and GHG emissions, refer to Appendix E. Federal Clean Air Act 1 Transportation conformity (40 CFR Parts 51 and 93) Mobile Sources Air Toxics (MSAT) Regulation (40 CFR ) Council on Environmental Quality (CEQ) Draft Guidance for Greenhouse Gas Emissions and Climate Change Impacts Bay Area Air Quality Management District (BAAQMD) State Implementation Plans Effects Methods Air Quality Based on the EPA s transportation conformity rule (40 CFR Parts 51 and 93) and federal air quality regulations, the Project would result in an adverse effect to air quality if the following conditions are met. Design and scope of the applicant preferred alternative is inconsistent with the Metropolitan Transportation Commission s (MTC s) Transportation 2035 Plan (Regional Transportation Plan [RTP]) or 2013 Transportation Improvement Program (TIP). Project would worsen existing or contribute to new localized particulate matter (PM) or carbon monoxide (CO) hot-spots. Generate substantial levels of MSAT emissions. Climate Change and Greenhouse Gases There are currently no adopted quantitative thresholds relevant to the NEPA analysis. However, CEQ has proposed 25,000 metric tons (MT) as a trigger for when a detailed GHG 1 The Federal Clean Air Act is also applicable to the CEQA environmental analysis, as noted in Section

2 5. NEPA emissions analysis is warranted. Accordingly, for the purposes of this analysis, direct and indirect GHG emissions from the Project are discussed with respect to the 25,000 MT reference point. Regional Conformity The Project would be located in a nonattainment area with regard to the federal 8-hour ozone standard. Because ozone and its precursors are regional pollutants, the Project must be evaluated under the transportation conformity requirements described in Appendix E, Regulatory Settings. Approval, funding, and implementation of FTA projects are subject to transportation conformity regulations under the CAA (40 CFR 93, Subpart A). Transportation conformity ( conformity ) is a way to ensure that federally funded transportation projects are consistent with air quality goals. In areas that are nonattainment or maintenance for ozone, a project level conformity determination must show that the project comes from a conforming RTP and TIP, and the project s design concept and scope have not changed significantly since the RTP and TIP conformity determination per 40 CFR Additional project-level conformity requirements may apply if the area is in nonattainment or maintenance for other pollutants; such as hot-spot requirements in CO, PM10 and PM2.5 areas as discussed in the following Project-Level Conformity section. Project-Level Conformity As stated above, if a project is located in a nonattainment or maintenance area for localized pollutants (i.e., CO, PM10, and PM2.5), then a hot-spot analysis and possible emission reduction measures are required. Carbon Monoxide The Project is located in a maintenance area with regard to the federal CO standard (see Table 2-2 in the Air Quality Technical Report in Appendix H). Consequently, the evaluation of transportation conformity for CO is required. The CO transportation conformity analysis is based on the BAAQMD s CO screening criteria, which is described in Section 4.3. The criteria provide a conservative indication of whether a project will generate new air quality violations, worsen existing violations, or delay attainment of National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS) for CO. If the screening criteria are met, a quantitative analysis of project-related CO emissions would not be necessary because transportation conformity requirements would be satisfied. Particulate Matter The Project is located in a nonattainment area for the federal PM2.5 standard (see Table 2-2 in the Air Quality Technical Report in Appendix H). Consequently, a project-level conformity determination for PM2.5 is required. In December 2010, EPA finalized conformity guidance for determining which transportation projects must be analyzed for local air quality impacts in PM2.5 and PM10 nonattainment 5-8

3 5. NEPA and maintenance areas (Federal Highway Administration and U.S. Environmental Protection Agency 2010). The guidance requires a quantitative hot-spot analysis to be performed for a project of air quality concern (POAQC) or any other project identified by the PM10 or PM2.5 State Improvement Plan (SIP) as a localized air quality concern. POAQC are certain highway and transit projects that involve significant levels of diesel traffic or any other project identified in the PM2.5 or PM10 SIP as a localized air quality concern. As noted in the EPA s March 2006 final rule, the following are examples of POAQCs. A project on a new highway or expressway that serves a significant volume of diesel truck traffic, such as facilities with greater than 125,000 annual average daily traffic (AADT) where at least 8 percent of such AADT is diesel truck traffic. New exit ramps and other highway facility improvements to connect a highway or expressway to a major freight, bus, or intermodal terminal. Expansion of an existing highway or other facility that affects a congested intersection (operated at LOS D, E, or F) that has a significant increase in the number of diesel trucks. Similar highway projects that involve a significant increase in the number of diesel transit busses and/or diesel trucks. A major new bus or intermodal terminal that is considered to be a regionally significant project under 40 CFR An existing bus or intermodal terminal that has a large vehicle fleet where the number of diesel buses increases by 50 percent or more as measured by bus arrivals. As noted in the EPA s March 2006 final rule, the examples below are projects that are not an air quality concern: Any new or expanded highway project that primarily services gasoline vehicle traffic (i.e., does not involve a significant number or increase in the number of diesel vehicles), including such projects involving congested intersections operating at level of service (LOS) D, E, or F. An intersection channelization project or interchange configuration project that involves either turn lanes or slots, or lanes or movements that are physically separated. These kinds of projects improve freeway operations by smoothing traffic flow and vehicle speeds by improving weave and merge operations, which would not be expected to create or worsen PM2.5 or PM10 violations. Intersection channelization projects; traffic circles or roundabouts; intersection signalization projects at individual intersections; and interchange reconfiguration projects that are designed to improve traffic flow and vehicle speeds, do not involve any increases in idling, and would be expected to have a neutral or positive influence on PM2.5 or PM10 emissions as a result. A new or expanded bus terminal that is served by non-diesel vehicles (e.g., compressed natural gas) or hybrid-electric vehicles. 5-9

4 5. NEPA A 50 percent increase in daily arrivals at a small terminal (e.g., a facility with 10 buses in the peak hour). The EPA s conformity guidance details a step-by-step screening procedure to determine whether project-related particulate emissions would have a potential to generate new air quality violations, worsen existing violations, or delay attainment of NAAQS for PM2.5 or PM10. For projects identified as not being a POAQC, PM2.5 and PM10 hot-spot analyses are not required. For these types of projects, state and local project sponsors should briefly document in their project-level conformity determinations that federal CAA and 40 CFR requirements were met without a hot-spot analysis, because such projects have been found to not be of air quality concern under 40 CFR (b)(1). Projects identified as POAQC are required to have a quantitative hot-spot analysis consistent with the EPA s 2010 conformity guidance. MSAT Emissions The Federal Highway Administration s (FHWA s) (2012) Interim Guidance Update on Mobile Source Air Toxic Analysis in NEPA Documents was used to evaluate potential mobile source air toxics (MSAT) emissions associated with the Project. MSATs are a subset of the 188 air toxics defined in the Clean Air Act. The seven main toxics are acrolein, polycyclic organic matter, diesel particulate matter (DPM)/diesel exhaust organic gases, benzene, 1-3 butadiene, naphthalene, and formaldehyde. FHWA s guidance uses a tiered approach to addressing MSAT impacts from roadway projects. The following analysis levels outlined in FHWA s interim guidance were used to determine level of analysis required for Project MSAT impacts. Level 1: Exempt projects with no potential for meaningful MSAT effects. These projects require no analysis. (Examples include: projects qualifying as a categorical exclusion, other projects with no meaningful impacts on traffic volumes or vehicle mix.) Level 2: Projects with low potential for MSAT effects. These projects require a qualitative analysis. (Examples include: projects that serve to improve highway operations, transit, or freight without adding substantial new capacity). Level 3: Projects with have higher potential MSAT. These projects require quantitative analysis to differentiate alternatives. (Examples include: projects that create or significantly alter a major intermodal freight facility involving a significant number of diesel vehicles, create new capacity or add significant capacity to urban highways, or are proposed in proximity to populated areas). This Project qualifies as a project with low potential MSAT effects (Level 2 analysis) and therefore MSAT emissions are analyzed qualitatively. Please refer to the Air Quality Technical Report in Appendix H for additional information on the analysis tiers used to evaluate Project MSAT impacts. 5-10

5 5. NEPA Greenhouse Gas Emissions GHG emissions from construction and operation of the Project were quantified as MT of carbon dioxide equivalents (CO2e) using CalEEMod and EMFAC2011 (air quality mobile source emissions models), respectively. For purposes of this analysis, direct and indirect GHG emissions from the Project are discussed with respect to the 1,100, 10,000, and 25,000 MT thresholds. Please refer to the Air Quality Technical Report in Appendix H for additional information on methods used to evaluate GHG emissions No Build Alternative (No adverse effect) Consistency with the Applicable RTP and TIP Federal approvals are not required for the No Build Alternative because construction and operation of a facility would not occur. Accordingly, no change or improvement in operational conditions along the corridor would occur. Therefore, the No-Build Alternative would have no effect related to metropolitan planning or air quality conformity. Worsen existing or contribute to new localized CO hot-spots No construction activities would occur related to the No Build Alternative, and no change or improvement in operational conditions along the Project corridor would occur. There would be no adverse effect under the No Build Alternative related to localized CO hot-spots and no adverse effect related to metropolitan planning or air quality conformity. Worsen existing or contribute to new localized PM hot-spots Federal approvals are not required for the No Build Alternative. Accordingly, project-level transportation conformity requirements do not apply. There would be no adverse effect under the No Build Alternative related to worsening existing or contributing to new localized PM hot-spots. Generate substantial levels of MSAT emissions As shown in Table 5-4 in the Air Quality Technical Report in Appendix H, it is estimated that ADT on El Camino Real would not exceed the FHWA s MSAT ADT threshold of 140,000. Consequently, based on the FHWA s 2012 MSAT guidance, the No Build Alternative would not have an appreciable difference in overall MSAT emissions relative to existing conditions, and is, therefore, considered to have low potential MSAT effects. The amount of MSAT emitted under the No Build Alternative would be proportional to the amount of VMT along El Camino Real, as well as bus activity at the bus stops. Operation of hybrid diesel-electric buses would reduce MSAT emissions relative to the Rapid 522 service. MSAT emissions would also likely be lower than present levels in the design year as a result 5-11

6 5. NEPA of EPA s national control programs. Therefore, there would be no adverse effect under the No Build Alternative related to generation of substantial levels of MSAT emissions. Generate GHG emissions in excess of CEQ reference point during construction There would be no emissions effect because construction would not occur. There would be no adverse effect under the No Build Alternative related to generation of GHG emissions during construction. Generate GHG emissions in excess of CEQ reference point during operation As discussed in Section 4.3, implementation of the No Build Alternative would reduce longterm GHG emissions relative to existing conditions. Since there would be no adverse effect under the No Build Alternative related to generation of GHG emissions during operations, this effect would be beneficial Build Alternatives (No adverse effect after mitigation) Consistency with the Applicable RTP and TIP The Project is included in MTC s RTP Plan Bay Area and 2013 TIP under project identification number The RTP (as amended) and 2013 TIP were found to conform to the SIP by FTA/FHWA on August 12, The Project s design, concept, and cost match the description included in the RTP and TIP. Upon selection of a preferred alternative, VTA will consult with MTC on the need for an amendment to Plan Bay Area and before completion of the NEPA process. Any RTP amendment would ensure that, prior to preparation of the final environmental document for the Project, the design, concept, and scope for the LPA will be consistent with the Project description in the amended RTP and TIP. The Project s regional conformity determination requirement is satisfied. There would be no adverse effect under the Build Alternatives related to consistency with the applicable RTP and TIP. Worsen existing or contribute to new localized CO hot-spots Construction Federal transportation conformity requirement under 40 CFR (c)(5) requires the evaluation of construction-related hot-spot emissions if construction activities would last longer than 5 years in one general location. Because construction of the Project is expected to last approximately 2 years, a construction-related CO hot-spot analysis is not required under transportation conformity requirements. Temporary increases of emissions during construction are not expected to generate new air quality violations, worsen existing conditions, or delay attainment of NAAQS and CAAQS for CO. There would be no adverse 5-12

7 5. NEPA effect under the Build Alternatives related to worsening or contribution to new localized PM hot-spots. Operation The Project corridor is within a maintenance area for the federal CO standard. Therefore, pursuant to 40 CFR Part 93, a project-level operational CO analysis is required for conformity purposes. As discussed in Impact AQG-3b in Section 4.3, Air Quality and Greenhouse Gas Emissions, implementation of the Project would not increase traffic volumes at affected intersections to more than 44,000 vehicles per hour. The Project is also consistent with applicable congestion management programs. Accordingly, pursuant to the BAAQMD s (2011) California Environmental Quality Act Air Quality Guidelines, the project is not expected to cause or contribute to new or worsened violations of the NAAQS or CAAQS. Project-level CO conformity determination requirements are satisfied. There would be no adverse effects under the Build Alternatives related to worsening existing or contributing to new localized CO hot-spots. Worsen existing or contribute to new localized PM hot-spots Construction Federal transportation conformity requires the evaluation of construction-related hot-spot emissions if construction activities will last longer than five years in one general location. As construction of the Project is expected to last approximately two years, a construction-related PM hot-spot analysis is not required under transportation conformity requirements. Operation The Project corridor is within a nonattainment area for federal PM2.5 standard. Therefore, pursuant to 40 CFR Part 93, a project-level operational PM2.5 analysis is required for conformity purposes. A quantitative hot-spot analysis is only required for projects identified as a POAQC, as defined in 40 CFR (b)(1). As described below, the Project does not meet any of the project types considered to be POAQC by the EPA s final rule. Accordingly, the Project is not considered to be a POAQC and project-level PM conformity determination requirements are satisfied. Confirmation of this finding was obtained following interagency consultation with MTC s Air Quality Conformity Task Force on April 24, 2014 (for the conformity documentation refer to Appendix H). There would be no adverse effects under the Build Alternatives related to worsening existing or contributing to new localized PM hot-spots. The following is a list of projects that are considered POAQCs and an analysis of why this Project is not considered a POAQC. 5-13

8 5. NEPA New or expanded highway projects that have a significant number of or significant increase in diesel vehicles. Implementation of the Project would not result in the construction of a new or expanded highway system that would have a significant number of or significant increase in diesel vehicles. As shown in Table 5-4 in the Air Quality Technical Report in Appendix H, maximum average daily traffic (ADT) on the Project corridor would not exceed 59,000 under any of the Build Alternative. Of this, trucks would only comprise 1 to 2 percent of traffic (truck ADT ranges from 379 to 1,118), depending on the alternative. Future truck traffic on the Project corridor, therefore, would not be considered significant because it would be well below the EPA s guidance criteria of 10,000 vehicles per day. In addition to relatively low truck volumes, Table 5-5 in the Air Quality Technical Report further indicates that implementation of the Build Alternatives would decrease truck ADT relative to the No Build Alternative on almost all segments of the Project corridor. The largest increase in truck ADT would be west of Jordan Street under Alternative 4a. The estimated truck increase would not exceed 2 ADT, which is less than 0.1 percent of total ADT on affected segments. The Build Alternatives, therefore, would not result in a significant increase in diesel vehicles or DPM emissions. Rather, the Build Alternatives are expected to reduce localized DPM concentrations in the Project corridor because of reductions in transit idling time (see discussion below under (iii)). Construction of the dedicated lanes under Alternatives 3a, 3b, 4a, 4b, and 4c would move BRT service away from the roadway edge, which may also reduce DPM concentrations at receptor locations adjacent to the Project corridor. Projects affecting intersections that are at LOS D, E, or F with a significant number of diesel vehicles, or those that will change to LOS D, E, or F because of increased traffic volumes from a significant number of diesel vehicles related to the Project. Implementation of the Project would result in a benefit regarding overall diesel emissions through reductions in regional VMT and transit idling times in the Project corridor. Tables 5-6 and 5-7 in the Air Quality Technical Report in Appendix H also indicate that the Build Alternatives would have little effect on delay and LOS) at intersections in the Project corridor. Within segments that include a dedicated lane, conditions at many intersections would improve relative to the No Build Alternative due to updated signal timing and diversion of vehicles to other routes. However, the Build Alternatives could affect some intersections on El Camino Real and The Alameda that are expected to operate at LOS D, E, or F during the PM peak hour. Likewise, as traffic diverts away from the Project corridor, some intersections in the surrounding area may be affected by the Build Alternatives. Opening Year (2018 Conditions) As shown in Table 5-6 in the Air Quality Technical Report, a maximum of 22 intersections on El Camino Real that are expected to operate at LOS D, E, or F during the 2018 PM peak hour. Of these intersections, five would be degraded one LOS grade under Alternative 4c and four would be degraded under Alternative 4b. While delay is expected to slightly increase at these intersections, implementation of Alternatives 4b and 4c would reduce the number of 5-14

9 5. NEPA diesel vehicles operating on all segments of the Project corridor except near Hedding Street, which is east of the affected intersections (see Table 5-5). Alternatives 4b and 4c would also improve LOS and delay at five intersections on El Camino Real relative to the No Build Alternative. Accordingly, Alternatives 4b and 4c would neither have an adverse effect on air quality related to diesel emissions generated at these intersections nor significantly increase the number of diesel vehicles in the Project corridor. Alternatives 3a, 3b, and 4a would worsen LOS at three intersections on El Camino Real that are expected to operate at LOS D, E, or F during the 2018 PM peak (see Table 5-6 in the Air Quality Technical Report). These intersections are all located between Lawrence Expressway and Lafayette Street, which corresponds to the area analyzed in roadway segments 2 (East of Jefferson) and 3 (West of Bowers). As shown in Table 5-5 in the Air Quality Technical Report, Alternatives 3a through 4a would reduce the number of diesel vehicles operating on these corresponding segments along the Project corridor. The alternatives would also improve LOS and delay at up to four intersections on El Camino Real, relative to the No Build Alternative. Accordingly, Alternatives 3a, 3b, and 4a would neither have an adverse effect on air quality related to diesel emissions generated at these intersections nor significantly increase the number of diesel vehicles in the Project corridor. Implementation of Alternative 2 would not worsen LOS at any intersections on El Camino Real that are projected to operate at LOS D, E, or F during the 2018 PM peak hour. Therefore, Alternative 2 would have no adverse effects on air quality related to diesel emissions. Diverted Traffic (2018 Conditions) As shown in the Air Quality Technical Report, up to 11 intersections in the surrounding area expected to operate at LOS D, E, or F during the 2018 PM peak hour may be degraded one LOS grade as a result of Project implementation. The majority of diverted traffic is expected to be passenger vehicles that would not represent a significant source of diesel emissions. Moreover, the impacts of some diverted traffic on surrounding intersections would be mitigated through signal timing improvements, restriping, and installation of new traffic signals (see MM TRA-A: Implement signal optimization, traffic signal installation, and roadway striping improvements at impacted intersections). Implementation of MM TRA-A would mitigate intersection traffic impacts at all but four intersections on the diversion route. While these intersections would continue to operate at LOS D, E, or F, most diverted traffic would be personal automobiles, which are almost entirely comprised of nondiesel, gasoline fueled vehicles. If some of the diverted traffic includes diesel trucks, the maximum change in diverted trucks is likely to be a small percentage of all VMT. For example, there would be 150 medium and heavy trucks diverted in segment 6 (east of Bush Street in Mountain View to Jordan Avenue in Los Altos) under Alternative 4c, which represents 0.29 percent of all ADT on this segment (150/50,730 = 0.29 percent). These vehicles would be distributed among several alternative routes. Accordingly, the 150 trucks from segment 6 would not be diverted or concentrated at one of the six significantly 5-15

10 5. NEPA impacted intersections in this segment. Therefore, even with trucks included in the diverted traffic, this minor increase would not result in PM2.5 hot-spots. Horizon Year (2040 Conditions) As shown in Table 5-7 in the Air Quality Technical Report, a maximum of 29 intersections in the Project corridor that are expected to operate at LOS D, E, or F during the 2040 PM peak hour. Of these intersections, four would be degraded one more LOS grade under Alternative 4c and three would be degraded under Alternative 4b. While delay is expected to slightly increase at these intersections, implementation of Alternatives 4b and 4c would reduce the number of diesel vehicles operating on all segments of the Project corridor (see Table 5-5 in the Air Quality Technical Report). Alternatives 4b and 4c would also improve LOS and delay at up to 12 intersections in the Project corridor relative to the No Build Alternative. Accordingly, the alternatives would neither have an adverse effect on air quality related to diesel emissions generated at these intersections nor significantly increase the number of diesel vehicles in the Project corridor. Alternatives 3a through 4a would worsen LOS at two intersections on El Camino Real that are expected to operate at LOS D, E, or F during the 2040 PM peak (see Table 5-7 in the Air Quality Technical Report). These intersections are all located between Lawrence Expressway and Lafayette Street, which correspond to roadway segments 2 (East of Jefferson) and 3 (West of Bowers). As shown in Table 5-5 in the Air Quality Technical Report, Alternatives 3a through 4a would reduce the number of diesel vehicles operating on these corresponding segments along the Project corridor. The alternatives would also improve LOS and delay at up to eight intersections on El Camino Real relative to the No Build Alternative. Accordingly, the alternatives would neither have an adverse effect on air quality related to diesel emissions generated at these intersections nor significantly increase the number of diesel vehicles in the Project corridor. Implementation of Alternative 2 would not worsen LOS at any intersections on El Camino Real projected to operate at LOS D, E, or F during the 2040 PM peak hour. Diverted Traffic (2040 Conditions) As shown in the Air Quality Technical Report, up to 11 intersections in the surrounding area expected to operate at LOS D, E, or F during the 2040 PM peak hour may be degraded one LOS grade as a result of Project implementation (Alternative 4c). The majority of diverted traffic is expected to be passenger vehicles that would not represent a significant source of diesel emissions. Moreover, the impacts of diverted traffic on some surrounding intersections would be mitigated through signal timing improvements, restriping, and/or installation of new traffic signals (see MM TRA-A). As described previously, minor increases in diverted traffic would not result in PM2.5 hot-spots. New bus and rail terminals and transfer points that have a significant number of diesel vehicles congregating at a single location. Under the Build Alternatives VTA would 5-16

11 5. NEPA construct new BRT stations that could affect localized PM concentrations generated at bus transfer points. Up to 16 BRT stations are proposed, depending on the alternative. Fourteen stations would be at the same location as the existing Rapid 522 stops. In areas with mixedflow lanes, the new BRT stations would replace the existing bus stops and serve both BRT and Local 22 buses. In areas with dedicated lanes, the existing curbside stops would remain to provide service to the Local 22 and new median stations would be constructed for BRT buses. The BRT stations constructed as part of the Project would include ticket vending machines on the platforms and other BRT station amenities. These features would facilitate passenger boarding and reduce total bus idling time by up to 30 seconds per stop relative to the existing Rapid 522 service. As shown in Table 5-8 in the Air Quality Technical Report, off-board fare collection would reduce idling DPM emissions relative to the No Build Alternative, which could reduce receptor exposure to DPM concentrations adjacent to existing bus stops. Bus idling at the two optional stations proposed at locations without existing Rapid 522 service 2 would increase localized DPM emissions. Three optional BRT station locations are being considered: Escuela Avenue, Churchill Avenue, and Embarcadero Road. Single-family homes are located adjacent to the potential Escuela Avenue and Churchill Avenue Station locations. Stanford University and Palo Alto High School are within 1,000 feet of the Churchill Avenue and Embarcadero Road locations. While stations at these locations would represent new BRT bus transfer points, total weekday BRT idle time at the stations is expected to be around 55 minutes, which would be less than 6 percent of the 18-hour BRT operational weekday. As noted above, idling time per platform would be limited to 30 to 36 seconds per vehicle. Based on the idling emissions estimated for the entire Project corridor (up to 32 platforms) (see Table 5-8 in the Air Quality Technical Report in Appendix H), increases in DPM concentrations associated with idling at the new stations would be minor and would not represent a significant source of new diesel exposure. Expanded bus and rail terminals and transfer points that significantly increase the number of diesel vehicles congregating at a single location. As discussed above, the Project would provide up to 16 new BRT stations, 14 of which would be at the same location as existing Rapid 522 stops. Implementation of the Build Alternatives would not affect the number of buses stopping at these stations. Accordingly, the Project would not result in a significant increase in the number of diesel buses congregating at existing bus stations. Buses stopping at the two optional stations would represent an increase in the number of diesel buses congregating at these locations. Approximately 92 buses would stop at each BRT platform per weekday, which would be less than 1 percent of total ADT and would not represent a significant increase in diesel vehicles. Projects in or affecting locations, areas, or categories of sites which are identified in the PM10 or PM2.5 applicable implementation plan or implementation plan 2 The Local 22 currently stops at the optional BRT station locations. The number of Local 22 trips and idling time would not be affected, relative to the No Build Alternative. 5-17

12 5. NEPA submission, as appropriate, as sites of violation or possible violation. The Project corridor is not in or affecting an area or location identified in the 2012 PM2.5 implementation plan. Moreover, the Project is not expected to introduce significant amounts of diesel truck traffic within the Project area that would result in PM hot-spots. Generate substantial levels of MSAT emissions This EIR/EA includes a basic analysis of the anticipated MSAT emission impacts of the Build Alternatives. However, available technical tools do not make it possible to predict the Project-specific health impacts of the emission changes associated with each Build Alternative. Because of these limitations, the following discussion is included in accordance with CEQ regulations (40 CFR [b]) regarding incomplete or unavailable information. Although this analysis was developed for evaluating projects with regard to NEPA, the evaluation is also appropriate for evaluating MSAT under CEQA and the BAAQMD Air Quality Guidelines. A discussion of incomplete or unavailable information is provided in the MSAT Health Risk Assessment, which is available in Appendix H. One of the purposes of the Project is to enhance the multi-modal character of the Project corridor. As shown in Table 5-4 in the Air Quality Technical Report in Appendix H, it is estimated that ADT on the Project corridor would not exceed the FHWA s MSAT ADT threshold of 140,000. Consequently, based on the FHWA s 2012 MSAT guidance, the Project would not make an appreciable difference in overall MSAT emissions and is, therefore, considered a Project with low potential MSAT effects (Level 2 analysis). Therefore, a qualitative analysis of potential MSAT emissions was performed using data in the Traffic Operations Analysis Report in Appendix H. For each Build Alternative, the amount of MSAT emitted would be proportional to the amount of VMT along the Project corridor and bus activity at the BRT stations, assuming that other variables are the same for each alternative. The VMT estimated for the Build Alternatives is lower than that for the No Build Alternative (see Table 5-4 in the Air Quality Technical Report. Decreases in VMT associated with the Build Alternatives would likely lead to lower MSAT emissions from vehicle operation. Because the estimated VMT under each of the Build Alternatives is nearly the same, varying by less than 1 percent, it is expected there would be no appreciable difference in overall MSAT emissions from vehicle operation among the various alternatives. The dedicated lanes constructed for Alternatives 3a, 3b, 4a, 4b, and 4c would have the effect of moving some bus traffic farther from homes, schools, and businesses adjacent to the roadway edge. Therefore, under Alternatives 3a, 3b, 4a, 4b, and 4c, there may be localized areas along the Project corridor where ambient MSAT concentrations could be lower than under the No Build Alternative. Off-board fare collection that reduces bus idling is also expected to reduce localized MSAT emissions at BRT stations under any of the Build Alternatives. Slight increases in MSAT emissions at the two optional BRT stations may occur; however, the magnitude and the 5-18

13 5. NEPA duration of these potential increases compared with the No Build Alternative cannot be reliably quantified because of incomplete or unavailable information in forecasting projectspecific MSAT health impacts. In sum, the Project in the design year may decrease levels of MSAT emissions in the Project corridor relative to the No Build Alternative. There could also be slight localized MSAT reductions due to the dedicated lanes and rapid operating features associated with BRT. Regardless of the alternative chosen, MSAT emissions would likely be lower than present levels in the design year as a result of EPA s national control programs that are projected to reduce annual MSAT emissions by more than 80 percent from 2010 to Based on fleet mix and turnover, VMT growth rates, and local control measures, local conditions may differ from these national projections. However, the EPA-projected reductions are so significant (even after accounting for VMT growth) that MSAT emissions in the Project corridor are likely to be lower in the future as well. There would be no adverse effect under the Build Alternatives related to generation of substantial levels of MSAT emissions. Generate GHG emissions in excess of CEQ reference point during construction As shown in Table in Section 4.3, Air Quality and Greenhouse Gas Emissions, GHG emissions generated from construction of the Build Alternatives would range from 420 for Alternative 2 to 1,242 MT CO2e in 2017 for Alternative 4c and from 4 for Alternative 3a to 240 MT CO2e for Alternative 4c in These increases would be below the CEQ s 25,000 MT reference point. Moreover, implementation of the BAAQMD s recommended best management practices (BMPs), as outlined in MM AQG-E: Implement BAAQMD recommended BMPs to reduce GHG emissions in Section 4.3, would also help reduce construction-related GHG emissions. There would be no adverse effect under the Build Alternatives related to generation of GHG emissions during construction. Generate GHG emissions in excess of CEQ reference point during operation As shown in Table in Section 4.3, implementation of Alternatives 3b and 4a would reduce long-term GHG emissions relative to the No Build. This effect would be beneficial. In comparison, GHG emissions would slightly increase with implementation of Alternatives 2, 3a, 4b, and 4c under 2040 conditions relative to the No Build Alternative. These increases would not exceed the CEQ s 25,000 MT reference point. There would be no adverse effect under the Build Alternatives related to generation of GHG emissions during operation Measures to Minimize Harm No Build Alternative No adverse air quality or GHG emission effects would occur under the No Build Alternative; therefore, no mitigation measures are required. 5-19

14 5. NEPA Build Alternatives In order to ensure that adverse air quality effects related to diverted traffic and generation of GHG emissions during construction are minimized, the following mitigation measures are recommended (complete text of mitigation measures are provided in Section 4.3, Air Quality and Greenhouse Gas Emissions, and 4.12, Transportation and Traffic. MM AQG-E: Implement BAAQMD recommended BMPs to reduce GHG emissions MM TRA-A: Implement signal optimization, traffic signal installation, and roadway striping improvements at impacted intersections Cumulative Impacts Refer to Section 4.3, Air Quality and Greenhouse Gas Emissions for a discussion of cumulative impacts pursuant to NEPA. 5.4 Biological Resources For a comprehensive discussion of the Project s affected environment as it relates to biological resources, refer to Section 4.4, Biological Resources and the Biological Resources Technical Memorandum in Appendix H. For a comprehensive discussion of the Project s cumulative biological resources impacts, refer to Section Effects Methods This section examines whether the Project would have an adverse effect on existing terrestrial vegetation or animals and whether the Project would adversely affect any species, or their habitat, listed as federally threatened or endangered or otherwise specially protected by applicable law No Build Alternative (No adverse effect) Under the No Build Alternative, no physical or operational improvements would be made to the Project corridor. No adverse effects related to biological resources would occur under the No Project Alternative Build Alternatives (No adverse effect after mitigation) As described in Section 4.4, Biological Resources, the potential would exist under any of the Build Alternatives for the release of contaminants directly or indirectly into water bodies crossing under the Project corridor. These pollutants could degrade the physical conditions of the water features. Central California coast steelhead could occur within Stevens Creek in the study area. Release of pollutants from Project construction activities could result in direct or indirect mortality of steelhead and habitat loss, which would be an adverse effect. However, 5-20