Tuscan Village Addendum

Transcription

1 Tuscan Village Addendum To: Date: Subject: Bruce Ambo, Principal Planner, City of Chico Planning Services March 19, 2018 Tuscan Village Addendum (Amber Lynn Estates) Response to Butte County AQMD Comments PROJECT BACKGROUND A Mitigated Negative Declaration (MND) for the Tuscan Village development proposal was adopted by the Chico City Council on August 7, The MND concluded that the construction of 76 singlefamily units, 19 second dwelling units, 105 multi-residential units, and commercial uses spanning 1.8 acres on the Project site would result in less than significant air quality impacts with the implementation of Mitigation Measure B.1 (Air Quality). The MND set forth Mitigation Measure B.1 (Air Quality) to reduce construction air emissions. After adoption of the MND, Planning Commission Resolution approved the development of 76 attached single-family units and 79 multi-family units on the Project site, concluding such development is included within the scope of the MND analysis. In 2018, an addendum to the MND was prepared in order to determine whether, and to what extent, the MND remains sufficient to address the potential air quality and greenhouse gas-related impacts, among other environmental topic areas, of the proposed adjustments (Revised Project) to the land use mix, or whether additional documentation is required under the California Environmental Quality Act (CEQA) (Pub. Resources Code, Section 21000, et seq.). This memorandum and attached supporting documents have been prepared as a response to the comments to the addendum received from the Butte County Air Quality Management District (BCAQMD) on March 14, RESPONSE TO BUTTE COUNTY AIR QUALITY MANAGEMENT DISTRICT The Revised Project is currently proposing to develop 118 detached single family residential units on the Project site. As noted in the 2018 Addendum, construction would generate short-term emissions of criteria air pollutants. The criteria pollutants of primary concern within the Project area include ozone-precursor pollutants [i.e., reactive organic gas (ROG) and nitrogen oxide (NOx)], coarse particulate matter (PM10), and fine particulate matter (PM2.5). Construction-generated emissions are short term and of temporary duration, lasting only as long as construction activities occur.

2 The BCAQMD comment letter recognizes that the Revised Project is anticipated to have less air quality-related impacts than the previously analyzed project, yet also notes that in addition to the daily construction thresholds promulgated by the District, annual construction thresholds also apply to the Project. The BCAQMD also recommends calculating construction-related emissions accounting for BCAQMD Rule 230, Architectural Coatings, which includes limits to the VOC content in paint. Annual Construction Emissions The estimated maximum annual construction emissions associated with 1) the Previously Analyzed Project and subject of the MND, 2) the Previously Approved Project per Planning Commission Resolution 08-15, and 3) the Revised Project, are summarized in the following Table. Emissions have been calculated to account for BCAQMD Rule 230, Architectural Coatings. The estimated construction emissions attributable to each of the three scenarios was estimated under the assumption that the majority of construction activities occur within the dry weather season (March October). Source Annual Construction Emissions Summary (Tons per Year) Reactive Organic Gas Nitrogen Carbon Monoxide Pollutant Sulfur Coarse Particulate Matter Fine Particulate Matter Previously Analyzed Project (76 single-family units, 19 second dwelling units, 105 multi-residential units, and commercial uses spanning 1.8 acres) Year One Construction Year Two Construction Year Three Construction Maximum Emissions Previously Approved Project (76 attached single-family units and 79 multifamily units) Year One Construction Year Two Construction Maximum Emissions Revised Project (118 detached single family residential units) Year One Construction Year Two Construction Year Three Construction Maximum Emissions Source: CalEEMod version Refer to Attachment A for Model Data Outputs. Notes: The Previously Analyzed Project and Revised Project occur in 2 distinct construction phases.

3 As shown, the estimated construction emissions are generally the same for each modeled scenario. Emissions of the ozone precursors, ROG and NOx would be emitted at the greatest potency with development of the Previously Analyzed Project in the MND, however emissions of CO are greatest with development of the Previously Approved Project scenario. Development of the Revised Project would result in the lowest emissions of NOx, carbon monoxide (CO), and PM10. ROG emissions associated with the Revised Project would be greater than those generated under the Previously Approved Project scenario, yet less than those generated under the Previously Analyzed Project scenario/subject of the MND. As previously described, the BCAQMD has established annual thresholds of significance for air quality for construction activities of land use development projects such as that proposed. The BCAQMD considers projects that emit more than 4.5 tons of NOx or more than 4.5 of ROG annually to be significant. As shown, none of the modeled scenarios would surpass any of these significance thresholds. Daily Construction Emissions The estimated maximum daily construction emissions associated with 1) the Previously Analyzed Project and subject of the MND, 2) the Previously Approved Project per Planning Commission Resolution 08-15, and 3) the Revised Project, are summarized in the following Table. Emissions have been calculated to account for BCAQMD Rule 230, Architectural Coatings. The estimated construction emissions attributable to each of the three scenarios was estimated under the assumption that the majority of construction activities occur within the dry weather season (March October).

4 Source Maximum Daily Construction Emissions Summary (Pounds per Day) Reactive Organic Gas Nitrogen Carbon Monoxide Pollutant Sulfur Coarse Particulate Matter Fine Particulate Matter Previously Analyzed Project (76 single-family units, 19 second dwelling units, 105 multi-residential units, and commercial uses spanning 1.8 acres) Site Preparation Emissions Grading Emissions Maximum Emissions Previously Approved Project (76 attached single-family units and 79 multifamily units) Site Preparation Emissions Grading Emissions Maximum Emissions Revised Project (118 detached single family residential units) Site Preparation Emissions Grading Emissions Maximum Emissions Source: CalEEMod version Refer to Attachment A for Model Data Outputs. Notes: The Previously Analyzed Project and Revised Project occur in 2 distinct construction phases. The emissions shown represent the maximum daily emissions. As shown, the estimated construction emissions are generally the same for each modeled scenario. Emissions of the ozone precursor, ROG, would be emitted at the greatest potency with development of the Previously Analyzed Project in the MND, however emissions of the other ozone precursor, NOx, are the same for each scenario. Emissions are both coarse and fine particulate matter are also the same for each scenario. Development of the Revised Project would result in the lowest emissions of CO and SOx. ROG emissions associated with the Revised Project would be greater than those generated under the Previously Approved Project scenario, yet less than those generated under the Previously Analyzed Project scenario/subject of the MND.

5 The BCAQMD has established daily thresholds of significance for air quality for construction activities of land use development projects such as that proposed. The BCAQMD considers projects that emit more than 137 pounds of ROG, 137 pounds of NOx, OR 80 pounds of PM10 daily to be significant. As shown, none of the modeled scenarios would surpass any of these significance thresholds. Project construction associated with the Revised Project would not result in new or more severe impacts. It is also acknowledged that all development projects in the City of Chico are required to implement BCAQMD best practices to minimize air pollutant emission impacts as a standard condition of approval. BCAQMD best practices include measures to limit diesel particulate matter generated by construction equipment as well as fugitive dust from ground disturbing activities.