Mitigated Negative Declaration (17-01) for 1402 West Pico Avenue El Centro, California (APN )

Transcription

1 Mitigated Negative Declaration (17-01) for 1402 West Pico Avenue El Centro, California (APN ) General Plan Amendment (17-01) Change of Zone (17-01) Prepared for City of El Centro Community Development Department 1275 Main Street El Centro, CA Prepared by RECON Environmental, Inc Fifth Avenue San Diego, CA P RECON Number 8534 May 22, 2017

2 TABLE OF CONTENTS Acronyms... iii 1.0 Introduction Project Needs and Objectives Project Location and Setting Project Description Land Use and Zoning Authority to Prepare a Mitigated Negative Declaration Results of Public Review Mitigated Negative Declaration Air Quality Greenhouse Gas Emissions Noise Monitoring and Reporting Program Initial Study References Cited FIGURES 1: Regional Location : Project Location on USGS Map : Project Location on Aerial Map : Existing Vehicle Traffic Noise Contours : Future Vehicle Traffic Noise Contours : Construction Noise Contours...32 TABLES 1: Surrounding Land Use and Zoning : Thresholds of Significance for Construction Activities : Thresholds of Significance for Project Operations : Summary of Worst-Case Construction Emissions : Summary of Project Operational Emissions : Project GHG Emissions : Future Vehicle Traffic Noise Levels : Traffic Noise Levels and out Project and Ambient Noise Increases : Construction Noise Levels : Existing + Project Intersection LOS : Existing + Project Segment LOS...71 i

3 TABLE OF CONTENTS (cont.) TABLES (cont.) 12: Near-Term (Existing + Project +Cumulative) Intersection LOS : Near-Term (Existing + Project + Cumulative) Segment LOS : Horizon Year Segment LOS...73 ATTACHMENTS 1a: CalEEMod Output Air Quality - Commercial Office Use 1b: CalEEMod Output Air Quality - Assisted Living Facility 2: Traffic Analysis 3: Traffic Letter Update 4a: CalEEMod Output GHG Emissions - Commercial Office Use 4b: CalEEMod Output GHG Emissions- Assisted Living Facility 5: Noise Analysis 6: Phase 1 Environmental Site Assessment ii

4 Acronyms AAQS Ambient Air Quality Standards AB Assembly Bill ACM asbestos containing materials ADT average daily traffic AQAP Air Quality Attainment Plan BAU Business as Usual CalEEMod California Emissions Estimator Model CalGreen California Green Building Standards CAPCOA California Air Pollution Control Officers Association CARB California Air Resources Board CEC California Energy Commission CEQA California Environmental Quality Act CH4 methane CNEL community noise equivalent level CO carbon monoxide CO2 carbon dioxide CUP Conditional Use Permit db decibel db(a) A-weighted decibel EO Executive Order EPA Environmental Protection Agency ESA Environmental Site Assessment FAR floor area ratio GHG greenhouse gas ICAPCD Imperial County Air Pollution Control District IID Imperial Irrigation District Leq equivalent noise level LOS level of service MND Mitigated Negative Declaration MT CO2E metric-ton of carbon dioxide equivalent N2O nitrous oxide NO2 nitrogen dioxide NPDES National Pollutant Discharge Elimination System O3 ozone OEHHA Office of Environmental Health Hazard Assessment Pb lead PM10 particulates 10 microns or less in diameter PM2.5 particulates 2.5 microns or less in diameter RPS Renewables Portfolio Standard SCAQMD South Coast Air Quality Management District SIP State Implementation Plan SO2 sulfur dioxide SOx sulfur oxide SR-86 State Route 86 SSAB Salton Sea Air Basin v/c volume to capacity iii

5 1.0 Introduction 1.1 Project Needs and Objectives The primary objective of the proposed project (hereafter project) is to provide an infill commercial development in the City of El Centro. 1.2 Project Location and Setting The 7.15-acre project site is located at 1402 West Pico Avenue, El Centro (City), Imperial County, California (Figure 1). The site is generally south of West El Dorado Avenue, north of West Pico Avenue, west of North 12th Street, and east of North Imperial Avenue (State Route 86 [SR-86]). The Assessor s Parcel Number for the site is The project site is relatively flat, and consists of vacant land sparse vegetation (Figure 2). Surrounding uses include a commercial to the west, commercial and single-family residential to the south, and single-family residential to the north and east (Figure 3). The surrounding commercial uses include restaurants, a professional plaza, a pharmacy, and a pre-manufactured home sales office. 1.3 Project Description The project consists of a General Plan Amendment and a rezone from the Low Density Residential designation and R1, single-family residential zone, to the General Commercial designation and CG, general commercial zone. The proposed General Commercial zoning designation allows for a variety of land uses, including neighborhood commercial, office commercial, and heavy commercial. The project proposes commercial office use, which allows for professional and administrative offices, medical care centers and ancillary services (City of El Centro 2003). Two land use options are proposed; commercial office (Option 1) and assisted living facility (Option 2). Option 1 consists of 87,000 square feet of commercial office space. At this time, this project option consists of a land use change and no site plan has been developed. The future office development would be developed in accordance to the City of El Centro Municipal Code, including Chapter 29, Article II, Section 29-63, Commercial zones design standards. Option 2 consists of a senior assisted living facility. A conceptual site design was completed to assess the potential use of the site as an assisted living facility. The facility includes many on-site amenities as well as a local shuttle service for client use (e.g., grocery shopping, pharmacy, and other errands). The project would operate 24/7 and employ up to 40 people, including nurse care. This conceptual design included one two-story structure located in the center of the site, three interior courtyards and up to 453 beds in 382 rooms. This design would allow for one controlled access point on each side of the building and up to 330 parking spaces around the perimeter of the building. To meet storm water requirements, approximately 1 acre of retention basins xeriscaping/landscaping Page 1

6 would be provided on-site. Site access would be provided via two driveways on W. Pico Avenue. As Option 1, Option 2 would be ultimately developed in accordance the City of El Centro Municipal Code. As the full-width frontage roadway improvements and utilities already exist adjacent to the project site, no off-site project improvements besides connections to utilities in West Pico Avenue are included in the proposed project. 1.4 Land Use and Zoning The land use and zoning designations surrounding the project site are shown in Table 1. Table 1 Surrounding Land Use and Zoning Land Use Zoning East Low Density Residential R1 single-family residential zone West General Commercial CH heavy commercial zone North Low Density Residential R1 single-family residential zone South General Commercial CG general commercial zone Low Density Residential R1 single-family residential zone 1.5 Authority to Prepare a Mitigated Negative Declaration As provided in California Environmental Quality Act (CEQA) Section , a Mitigated Negative Declaration (MND) may be prepared for a project when the Initial Study has identified potentially significant effects on the environment, but revisions in the project plans or proposals made by, or agreed to by, the applicant before the proposed Negative Declaration and Initial Study are released for public review would avoid the effects or mitigate the effects to a point where clearly no significant effect on the environment would occur, and there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment. The City is the Lead Agency under CEQA. Based on the findings of the Initial Study/Environmental Checklist for this project, the City has determined that preparation of a MND is the appropriate method by which to obtain compliance CEQA. The Initial Study/Environmental Checklist is included as Section 4.0 of this report. Page 2

7 AA ll E a UV 86 a S i p e l k F e r e e n C Salton Sea Calipatria s t H i g h l i n e C o a c h e l l a C C o a c h e l l a C C a n a l a nn aa ll N e w v i R e r Westmorland Brawley UV 78 I M P E R I A L C O U N T Y W e s t s i d e M a i n C a n a l UV 111 aa m m oo i v R ee rr UV 115 Imperial o C o y t W a e s h Seeley 8 e n t r a l M a i n C kj El Centro Holtville SAN BERNARDINO C a n a l Heber RIVERSIDE SAN DIEGO IMPERIAL LA PAZ UV 98 A l l A m e r i c a nn CC aa nn M E X I C O a l a l Calexico A l l A m e r i c a n C a n a l Alamo MEXICO YUMA Alamo 0 Miles 5[ kj Project Location M:\JOBS5\8534\common_gis\fig1.mxd 3/29/2017 fmm FIGURE 1 Regional Location

8 Map Source: USGS 7.5 minute topographic map series, El Centro quadrangle, 1979, T15SR14E 0 Feet 2,000[ Project Boundary M:\JOBS5\8534\common_gis\fig2.mxd 3/29/2017 fmm FIGURE 2 Project Location on USGS Map

9 SR 86 SR 86 Image Source: USDA FSA NAIP (flown June 2014) Lincoln Ave Frontage Rd W Pico Ave W Pico Ave 0 Feet 200 [ Project Boundary M:\JOBS5\8534\common_gis\fig3.mxd 3/29/2017 fmm FIGURE 3 Project Location on Aerial Photograph

10 1.6 Results of Public Review ( ) No comments were received during the public input period. ( ) Comments were received during the public input period, but they do not address the Draft Mitigated Negative Declaration findings or the accuracy or completeness of the Initial Study. No response is necessary. The letters are attached. ( ) Comments addressing the findings of the Draft Mitigated Negative Declaration and/or accuracy or completeness of the Initial Study were received during the public input period. The letters and responses are presented at the beginning of this Final MND. Copies of the Mitigated Negative Declaration and any Initial Study support material are available for review at the City of El Centro, 1275 Main Street, El Centro, California Signature Norma Villicaña, Community Development Director City of El Centro Date Date of Final MND Page 6

11 2.0 Mitigated Negative Declaration 2.1 Air Quality Existing Conditions Air pollution affects all southern Californians. Effects can include increased respiratory infections, increased discomfort, missed days from work and school, and increased mortality. Polluted air also damages agriculture and our natural environment. The analysis of impacts is based on State of California (state) and federal ambient air quality standards (AAQS) and assessed in accordance the guidelines, policies, and standards established by the City of El Centro and the Imperial County Air Pollution Control District (ICAPCD) Regulatory Framework The state of California is divided geographically into 15 air basins for the purpose of managing the air resources of the state on a regional basis. Areas in each air basin are considered to share the same air masses and, therefore, are expected to have similar ambient air quality. If an air basin is not in either federal or state attainment for a particular pollutant, the basin is classified as moderate, serious, severe, or extreme (there is also a marginal classification for federal non-attainment areas) non-attainment area. The project site is located in the Salton Sea Air Basin (SSAB). Emission standards for mobile sources are established by state and federal agencies such as the California Air Resources Board (CARB) and the U.S. Environmental Protection Agency (EPA). Reducing mobile source emissions requires the technological improvement of existing mobile sources and the examination of future mobile sources such as those associated new or modification projects. Stationary sources of air pollution are generally regulated through the permitting process as implemented by the local air district. The regulatory framework described below details the federal and state agencies that are in charge of monitoring and controlling mobile and stationary source air pollutants and what measures are currently being taken to achieve and maintain healthful air quality in the SSAB. AAQS represent the maximum levels of background pollution considered safe, an adequate margin of safety, to protect the public health and welfare. Six pollutants of primary concern are designated: ozone (O3), carbon monoxide (CO), sulfur dioxide (SO2), nitrogen dioxide (NO2), lead (Pb), and particulate matter including suspended particulates that are 10 microns or less in diameter (PM10) and suspended particulates that are 2.5 microns or less in diameter (PM2.5). The ICAPCD is the agency that regulates air quality in the SSAB. The ICAPCD provides guidance to mitigate adverse impacts to air quality from development projects in Page 7

12 Imperial County. The ICAPCD has prepared guidelines for the implementation of CEQA in their CEQA Air Quality Handbook, dated November 2007 (ICAPCD 2007). The document is intended to develop protocol to address air quality impacts in the SSAB. The State Implementation Plan (SIP) is a collection of documents that set forth the state s strategies for achieving the air quality standards. The ICAPCD is responsible for preparing and implementing the portion of the SIP applicable to the SSAB. The ICAPCD adopts rules, regulations, and programs to attain state and federal air quality standards, and appropriates money (including permit fees) to achieve these objectives Existing Air Quality Air quality at a particular location is a function of the kinds and amounts of pollutants being emitted into the air locally and throughout the basin and the dispersal rates of pollutants in the region. The major factors affecting pollutant dispersion are wind speed and direction, vertical dispersion of pollutants (which is affected by inversions), and local topography. The SSAB is a federal non-attainment area for 8-hour ozone, PM10, and PM2.5, and a state non-attainment area for 1-hour ozone, 8-hour ozone, and PM10. Air quality is commonly expressed as the number of days in which air pollution levels exceed state standards set by the CARB or federal standards set by the EPA. The ICAPCD maintains air quality monitoring stations throughout Imperial County. Air pollutant concentrations and meteorological information are continuously recorded at these stations. Measurements are then used by scientists to help forecast daily air pollution levels. The El Centro Ninth Street monitoring station, located approximately one mile south of the project site, is the nearest station to the project area. Ozone, carbon monoxide, nitrogen dioxide, PM10, and PM2.5 are monitored at the Ninth Street monitoring station. Natural wind events and agricultural operations are major sources of air pollution in the SSAB. Other sources of emissions are categorized as stationary and mobile. Stationary sources are generally categorized as either point sources or area sources. Point sources are large emitters at an identified location such as power plants and manufacturing facilities. Area sources consist of small emissions in a general area such as water heaters and architectural coating. Mobile sources are categorized as either on-road or off-road. On-road mobile sources are vehicles on freeways and roadways. Off-road sources include trains, ships, construction equipment, and other emitters that operate off freeways and roadways Significance Thresholds The ICAPCD CEQA Air Quality Handbook establishes the following four separate evaluation categories (ICAPCD 2007). 1. Comparison of calculated project emissions to ICAPCD emission thresholds. 2. Consistency the most recent Clean Air Plan for Imperial County. Page 8

13 3. Comparison of predicted ambient pollutant concentrations resulting from the project to state and federal health standards, when applicable. 4. The evaluation of special conditions which apply to certain projects. According to the ICAPCD CEQA Air Quality Handbook, the analysis of construction impacts is to emphasize implementation of effective and comprehensive control measures rather than produce a detailed evaluation of the emissions. The thresholds for construction activities (Table 2) are intended to serve as a guide for project developers and interested parties in determining the recommended type of mitigation measures. No matter the size of the project, the standard mitigation measures for construction equipment and fugitive PM10 control for construction activities should be implemented at all construction sites. Additional measures may apply to construction sites greater than five acres. Control measures for fugitive PM10 construction emissions in Imperial County are found in the ICAPCD Regulation VIII and in the Imperial County CEQA Air Quality Handbook, and are discussed below in Section Table 2 Thresholds of Significance for Construction Activities Threshold Pollutant (pounds per day) 10-micron Particulate Matter (PM10) 150 Reactive Organic Gases (ROG) 75 Nitrogen Oxide (NOx) 100 Carbon Monoxide (CO) 550 SOURCE: ICAPCD Table 3 provides general guidelines for determining the significance of impacts based on the total emissions that are expected from project operation established by the ICAPCD. The ICAPCD does not have a threshold for PM2.5. A threshold of 55 pounds per day for PM2.5 was obtained from the South Coast Air Quality Management District (SCAQMD) Final Methodology to Calculate PM2.5 and PM2.5 Significance Thresholds (SCAQMD 2006). Tier 1 projects are required to implement all standard mitigation measures. Tier 2 projects are required to implement all standard mitigation measures as well as all feasible discretionary mitigation measures. Table 3 Thresholds of Significance for Project Operations Pollutant Tier 1 (pounds/day) Tier 2 (pounds/day) 10-micron Particulate Matter (PM10) and greater Nitrogen Oxide (NOx) and greater Sulfur Oxide (SOx) and greater Carbon Monoxide (CO) and greater Reactive Organic Gases (ROGs) and greater Level of Significance SOURCE: ICAPCD Page 9

14 2.1.3 Analysis of s Construction impacts are short term and result from fugitive dust, equipment exhaust, and indirect effects associated construction workers and deliveries. Operational impacts can occur on two levels: regional or local. In the case of this project, operational impacts would be primarily due to emissions from mobile sources associated the vehicular travel along the roadways in the project area ICAPCD Emissions Thresholds a. Construction Emissions Heavy-duty construction equipment is usually diesel powered. In general, emissions from diesel-powered equipment contain more nitrogen oxides, sulfur oxides, and particulate matter than gasoline-powered engines. However, diesel-powered engines generally produce less carbon monoxide and less reactive organic gases than gasoline-powered engines. Standard construction equipment includes dozers, rollers, scrapers, dewatering pumps, backhoes, loaders, paving equipment, delivery/haul trucks, jacking equipment, welding machines, pile drivers, and so on. Emissions associated construction of this project were calculated using the California Emissions Estimator Model (CalEEMod) computer program (CAPCOA 2016) assuming that construction for either Option 1 or Option 2 would begin in January 2018 and last approximately 14 months. Primary inputs are the numbers of each piece of equipment and the length of each construction stage. Specific construction phasing and equipment parameters are not available at this time. However, CalEEMod can estimate the required construction equipment when project-specific information is unavailable. The estimates are based on surveys, performed by the SCAQMD and the South Coast Air Quality Management District, of typical construction projects which provide a basis for scaling equipment needs and schedule a project s size. Air emission estimates in CalEEMod are based on the duration of construction phases; construction equipment type, quantity, and usage; grading area; season; and ambient temperature, among other parameters. Project construction would occur in five stages: site preparation, grading/excavation, building construction, paving, and architectural coatings. Table 4 shows the total projected construction maximum daily emission levels for each criteria pollutant along the ICAPCD threshold of significance. CalEEMod output foroffice space and the assisted living facility are contained in Attachments 1a and 1b, respectively. Page 10

15 Table 4 Summary of Worst-Case Construction Emissions (pounds/day) Pollutant ROG NOx CO SOx PM10 PM2.5 Option 1 Commercial Office Site Preparation Grading Building Construction Paving Architectural Coatings Maximum Daily Emissions ICAPCD Significance Threshold Option 2 Assisted Living Site Preparation Grading Building Construction Paving Architectural Coatings Maximum Daily Emissions ICAPCD Significance Threshold SOURCE: Attachments 1a and 1b. ROG = reactive organic gases; NOx = nitrogen oxide; CO = carbon monoxide; SOx = sulfur oxide; PM10 = 10-micron particulate matter; PM2.5 = 2.5-micron particulate matter Emissions summarized in Table 4 are the maximum emissions for each pollutant and they may occur during different phases of construction. These are, therefore, the worst-case emissions. For assessing the significance of the air quality emissions resulting during construction of the proposed project, the construction emissions were compared to the ICAPCD thresholds of significance for construction activities (see Table 2). As shown in Table 4, worst-case emissions are projected to be less than the thresholds for all criteria pollutants. s would be less than significant. Fugitive dust is recognized by Imperial County as a contributor to PM10 pollution and a health hazard. All construction sites, regardless of size, must comply the requirements contained in Regulation VIII. Although compliance Regulation VIII does not constitute mitigation under the reductions attributed to environmental impacts, its main purpose is to reduce the amount of PM10 entrained into the atmosphere as a result of anthropogenic (man-made) fugitive dust sources. According to the ICAPCD CEQA Air Quality Handbook, regardless of the size of the project, the standard mitigation measures for construction equipment and fugitive PM10 must be implemented at all construction sites. The implementation of discretionary mitigation measures apply to those construction sites which are 5 acres or more for non-residential developments or 10 acres or more in size for residential developments. Because the project site is 7.15 acres, the project is required to implement all standard and discretionary measures. These measures are discussed in Section Page 11

16 b. Operation Emissions Mobile source emissions would originate from traffic generated by the project. Area source emissions would result from the use of natural gas, consumer products, as well as applying architectural coatings and landscaping activities. Mobile source operational emissions are based on the trip rate, trip length for each land use type and size. According to the project traffic report, Option 1, office space, would generate 1,740 average daily trips, and Option 2, the assisted living facility, would generate 1,133 average daily trips (LOS Engineering, Inc. 2017a and 2017b). The total trip generation is multiplied by the regional trip length to determine total project annual vehicle miles traveled (VMT). Default trip lengths and vehicle emission factors were used. Area source emissions associated the project include consumer products, natural gas used in space and water heating, architectural coatings, and landscaping equipment. Hearths (fireplaces) and woodstoves are also a source of area emissions; however, the project would not include hearths or woodstoves. Consumer products are chemically formulated products used by household and institutional consumers, including, but not limited to, detergents, cleaning compounds, polishes, floor finishes, disinfectants, sanitizers, and aerosol paints but not including other paint products, furniture coatings, or architectural coatings. Emissions due to consumer products are calculated using total building area and product emission factors. Emissions are generated from the combustion of natural gas used in space and water heating. Emissions are based on the Residential Appliance Saturation Survey which is a comprehensive energy use assessment that includes the end use for various climate zones in California. For architectural coatings, emissions result from evaporation of solvents contained in surface coatings such as in paints and primers. Emissions are based on the building surface area, architectural coating emission factors, and a reapplication rate of 10 percent of area per year. Landscaping maintenance includes fuel combustion emission from equipment such as lawn mowers, rototillers, shredders/grinders, blowers, trimmers, chain saws, and hedge trimmers as well as air compressors, generators, and pumps. Emission calculations take into account building area, equipment emission factors, and the number of operational days (summer days). Table 5 provides a summary of the operational emissions generated by the project. CalEEMod output files for project operation of office space and the assisted living facility are contained in Attachments 1a and 1b, respectively. As shown, project-generated emissions are projected to be less than the City s significance thresholds for all criteria pollutants for both development options, and the project would be considered a Tier 1 project. According to the ICAPCD CEQA Air Quality Handbook, Tier 1 projects are required to implement all standard operational mitigation measures. These measures are discussed in Section Page 12

17 Table 5 Summary of Project Operational Emissions (pounds/day) Pollutant ROG NOx CO SOx PM10 PM2.5 Option 1 Commercial Office Area Sources Energy Sources Mobile Sources Total ICAPCD Significance Threshold Option 2 Assisted Living Area Sources Energy Sources Mobile Sources Total ICAPCD Significance Threshold SOURCE: Attachments 1a and 1b. ROG = reactive organic gases; NOx = nitrogen oxide; CO = carbon monoxide; SOx = sulfur oxide; PM10 = 10-micron particulate matter; PM2.5 = 2.5-micron particulate matter Plan Consistency The current Clean Air Plans in the project area include the ozone Air Quality Attainment Plan (AQAP) and PM10 SIP. The ICAPCD CEQA Air Quality Handbook states that a consistency analysis the Clean Air Plans is required for large residential developments and large commercial developments which are required to develop an EIR and/or a Comprehensive Air Quality Analysis Report. Because emissions would be less than the operational significance thresholds for all criteria pollutants for both development options, the project would be considered a Tier 1 project, and is not required to prepare a Comprehensive Air Quality Analysis Report. Additionally, because the project would not result in significant unmitigated impacts, the project is not required to prepare an EIR. Because the project emissions would be less than the applicable thresholds, the project would not emit pollutants at a level that would interfere implementation of the Clean Air Plans Pollutant Concentrations As discussed in Section , to help protect public health and welfare, the state and federal governments established AAQS for criteria pollutants. When a large residential and/or commercial project is deemed to have the potential to cause an exceedance of the AAQS, an ICAPCD air quality dispersion model may be required to determine localized concentrations. As discussed in Section , construction and operational emissions are projected to be less than the applicable thresholds for all criteria pollutants. Project-related traffic would emit CO. Localized CO concentration is a direct function of motor vehicle activity at signalized intersections (e.g., idling time and traffic flow conditions), particularly during peak commute hours and meteorological conditions. Under Page 13

18 specific meteorological conditions (e.g., stable conditions that result in poor dispersion), CO concentrations may reach unhealthy levels respect to local sensitive land uses. CO hotspots due to traffic almost exclusively occur at signalized intersections that operate at a level of service (LOS) E or below. Projects may result in or contribute to a CO hotspot if they worsen traffic flow at signalized intersections operating at LOS E or F. The LOS of an intersection in morning and evening peak traffic hours is commonly abbreviated LOS AM/PM. Based on the traffic impact analysis, the project would not result in a signalized intersection to operate at LOS E or worse (Attachments 2 and 3; LOS Engineering, Inc. 2017a and 2017b), and, therefore, is not anticipated to result in a CO hot spot Special Conditions Additional analysis is required for development projects that are located in proximity to existing industrial operations that have the potential to emit toxic or hazardous air pollutants, or for commercial or industrial projects proposed in 1,000 feet of a school. The project site is not located in 1,000 feet of a school. The project would not result in the exposure of sensitive receptors to toxic or hazardous air pollutants from project operation. Construction equipment is diesel powered. Diesel particulate matter has been identified as a toxic air contaminant. The health risks associated diesel particulate matter are those related to long-term exposures (i.e., cancer and chronic effects) (California EPA Office of Environmental Health Hazard Assessment [OEHHA] 2015). Long-term health risk effects to residents are generally evaluated for an exposure period of 70 years (i.e., lifetime exposure) (OEHHA 2015). Residential uses are located in the vicinity of the project site. However, because risk is based on a lifetime of exposure and because construction would be short-term, impacts due to construction diesel particulate matter would be less than significant Significance of s As discussed, construction and operational emissions would be less than the significance thresholds for all criteria pollutants. The project would not conflict Clean Air Plans or expose sensitive receptors to substantial pollutant concentrations. Although impacts would be less than significant, the ICAPCD CEQA Air Quality Handbook contains standard mitigation measures for construction equipment and fugitive PM10 that shall be implemented at all construction sites, as appropriate and feasible, regardless of site size. The ICAPCD CEQA Air Quality Handbook also contains discretionary measures for fugitive PM10 control that shall be implemented at non-residential construction sites greater than five acres and residential construction sites greater than ten acres. The project is non-residential and is 7.15 acres; therefore, all standard and discretionary measures for construction-related emissions (listed below in Section 2.1.5) shall apply. Additionally, the project is considered a Tier 1 project and is required to implement all standard operational mitigation measures (listed below in Section 2.1.5). Page 14

19 2.1.5 Measures Construction The following measures have been shown to significantly reduce emissions and shall be implemented as part of project (Option 1 and Option 2) construction: 1. Standard Measures for Construction Equipment Use alternative fueled or catalyst-equipped diesel-construction equipment, including all off-road and portable diesel-powered equipment. Minimize idling time either by shutting equipment off when not in use or reduce the time idling to five minutes as a maximum. Limit, to the extent feasible, the hours of operation of heavy-duty equipment and/or the amount of equipment in use. Replace fossil-fueled equipment electrically driven equivalents (provided they are not run via a portable generator set). 2. Enhanced Measures for Construction Equipment Curtail construction during periods of high ambient pollutant concentrations; this may include ceasing of construction activity during the peak hour vehicular traffic on adjacent roadways. Implement activity management (e.g., reschedule activities to reduce short-term impacts). 3. Standard Measures for Fugitive PM10 Control All disturbed areas, including bulk material storage which is not being actively utilized, shall be effectively stabilized, and visible emissions shall be limited to no greater than 20 percent opacity for dust emissions by using water, chemical stabilizers, dust suppressants, tarps, or other suitable material such as vegetative ground cover. All on-site and off-site unpaved roads shall be effectively stabilized, and visible emissions shall be limited to no greater than 20 percent opacity for dust emissions by paving, chemical stabilizers, dust suppressants, and/or watering. All unpaved areas of one acre or more 75 or more average vehicle trips per day shall be effectively stabilized, and visible emissions shall be limited to no greater than 20 percent opacity for dust emissions by paving, chemical stabilizers, dust suppressants, and/or watering. The transport of bulk material shall be completely covered, unless six inches of freeboard space from the top of the container is maintained no spillage and loss Page 15

20 of bulk material. In addition, the cargo compartment of all haul trucks is to be cleaned and/or washed at delivery site after removal of bulk material. All track-out or carry-out shall be cleaned at the end of each workday or immediately when mud or dirt extends a cumulative distance of 50 linear feet or more onto a paved road in an urban area. Movement of bulk material handling or transfer shall be stabilized prior to handling or at points of transfer the application of sufficient water, chemical stabilizers, or by sheltering or enclosing the operation and transfer line. The construction of any new unpaved road is prohibited in any area a population of 500 or more, unless the road meets the definition of a temporary unpaved road. Any temporary unpaved road shall be effectively stabilized, and visible emissions shall be limited to no greater than 20 percent opacity for dust emission by paving, chemical stabilizers, dust suppressants, and/or watering Operation Standard mitigation measures for commercial projects include the following site design and energy efficiency standards: 1. Standard Site Design Measures: Provide on-site bicycle lockers and/or racks. Provide on-site eating, refrigeration, and food vending facilities to reduce lunchtime trips. Provide shower and locker facilities to encourage employees to bike and/or walk to work. Provide for paving a minimum of 100 feet from the property line for commercial driveways that access County paved roads as per County Standard Commercial Driveway Detail 410B (formerly SW-131A). 2. Standard Energy Efficiency Measures: Implement measures which meet mandatory, prescriptive, and/or performance measures as required by Title Significance after Implementation of the ICAPCD CEQA Air Quality Handbook standard and discretionary measures for construction equipment and fugitive PM10 would ensure that impacts would be less than significant. Page 16

21 2.2 Greenhouse Gas Emissions Existing Conditions Regulatory Framework A summary of some of the key programs and regulations concerning GHG emissions and climate change is presented below. a. Federal Corporate Average Fuel Economy The project would generate additional vehicle trips. These vehicles would consume fuel and would result in GHG emissions. The federal Corporate Average Fuel Economy standards determine the fuel efficiency of certain vehicle classes in the U.S. Current fuel economy standards are 54.5 miles per gallon for cars and light-duty trucks by Model Year These standards will nearly double the fuel efficiency of those vehicles compared to new vehicles currently on our roads. With improved gas mileage, fewer gallons of transportation fuel would be combusted to travel the same distance, thereby reducing nationwide GHG emissions associated vehicle travel. b. State Executive Orders and Statewide GHG Emission Targets Executive Order (EO) S-3-05 established the following GHG emission reduction targets for the state of California: by 2010, reduce GHG emissions to 2000 levels; by 2020, reduce GHG emissions to 1990 levels; by 2050, reduce GHG emissions to 80 percent below 1990 levels. EO B-30-15, issued on April 29, 2015, establishes an interim GHG emission reduction goal for the state of California by 2030 of 40 percent below 1990 levels. This EO also directed all state agencies jurisdiction over GHG-emitting sources to implement measures designed to achieve the new interim 2030 goal, as well as the pre-existing, long-term 2050 goal identified in EO S Additionally, this EO directed CARB to update its Climate Change Scoping Plan to address the 2030 goal. Assembly Bill 32 - California Global Warming Solutions Act In response to EO S-3-05, the California Legislature passed Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006, and thereby enacted Sections of the California Health and Safety Code. The heart of AB 32 is its requirement that Page 17

22 CARB establish an emissions cap and adopt rules and regulations that would reduce GHG emissions to 1990 levels by As directed by AB 32, in 2008, CARB adopted the Climate Change Scoping Plan: A Framework for Change (2008 Scoping Plan). The 2008 Scoping Plan identifies the main strategies the State of California will implement to achieve the GHG reductions necessary to reduce statewide forecasted business as usual (BAU) GHG emissions in 2020 to the state s historic 1990 emissions level. Vehicle and Fuel Standards The Advanced Clean Cars program, adopted January 2012, combines the control of smog, soot-causing pollutants and greenhouse gas emissions into a single coordinated package of requirements for model years 2015 through Accordingly, the Advanced Clean Cars program coordinates the goals of the Pavley, low emissions vehicle, zero emission vehicle, and Clean Fuels Outlet programs in order to lay the foundation for the commercialization and support of these ultra-clean vehicles. The Low Carbon Fuel Standard promotes the use of GHG-reducing transportation fuels, e.g., liquid biofuels, renewable natural gas, electricity, and hydrogen, through a declining carbon intensity standard. Renewables Portfolio Standard The Renewables Portfolio Standard (RPS) promotes diversification of the state s electricity supply and decreased reliance on fossil fuel energy sources. Originally adopted in 2002 a goal to achieve a 20 percent renewable energy mix by 2020 (referred to as the Initial RPS ), the goal has been accelerated and increased by EOs S and S to a goal of 33 percent by In April 2011, SB 2 (1X) codified California s 33 percent RPS goal. In September 2015, the California Legislature passed SB 350, which increases California s renewable energy mix goal to 50 percent by year Renewable energy includes (but is not limited to) wind, solar, geothermal, small hydroelectric, biomass, anaerobic digestion, and landfill gas. California Energy Code The California Code of Regulations, Title 24, Part 6 is the Energy Efficiency Standards or California Energy Code. This code, originally enacted in 1978, establishes energy efficiency standards for residential and non-residential buildings in order to reduce California s energy consumption. The Energy Code is updated periodically to incorporate and consider new energy efficiency technologies and methodologies as they become available. New construction and major renovations must demonstrate their compliance the current Energy Code through submission and approval of a Title 24 Compliance Report to the local building permit review authority and the California Energy Commission (CEC). By reducing California s energy consumption, emissions of statewide GHGs may also be reduced. The current version of the Energy Code, known as the 2016 Energy Code, became effective January 1, Page 18

23 California Green Building Standards California Green Building Standards (CalGreen) instituted mandatory minimum environmental performance standards for all ground-up new construction of commercial and low-rise residential buildings, state-owned buildings, schools, and hospitals. It also includes voluntary tiers (I and II) stricter environmental performance standards for these same categories of residential and non-residential buildings. The mandatory standards require: 20 percent mandatory reduction in indoor water use relative to specified baseline levels; 50 percent construction/demolition waste diverted from landfills; Mandatory inspections of energy systems to ensure optimal working efficiency; and Requirements for low-pollutant emitting exterior and interior finish materials such as paints, carpets, vinyl flooring, and particleboards. Assembly Bill 341 Solid Waste Diversion The Commercial Recycling Requirements mandate that businesses (including public entities) that generate 4 cubic yards or more of commercial solid waste per week and multifamily residential five units or more arrange for recycling services. Businesses can take one or any combination of the following in order to reuse, recycle, compost, or otherwise divert solid waste from disposal. Additionally, AB 341 mandates that 75 percent of the solid waste generated be reduced, recycled, or composted by Existing GHG Emissions The project site is currently undeveloped and is not a source of GHG emissions Significance Thresholds Thresholds used to evaluate impacts related to greenhouse gas emissions are based on applicable criteria in the CEQA Guidelines (California Code of Regulations Sections ), Appendix G. A significant impact related to greenhouse gas emissions would occur if the project would: 1) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment; and/or 2) Conflict an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases. No GHG emission threshold has been adopted by the City or ICAPCD for land development projects. The City is a member of the Southern California Association of Governments. Thus, in the absence of a threshold of significance for GHG emissions, the project is Page 19

24 evaluated based on the SCAQMD s recommended/preferred option threshold for all land use types of 3,000 metric ton of carbon dioxide equivalent (MT CO2E) per year (SCAQMD 2008). This threshold is appropriate for addressing potential impacts associated climate change. According to the SCAQMD, this is the primary threshold used for determining significance. This threshold uses the EO S-3-05 goal as the basis for deriving the screening level. The screening level for stationary sources is based on an emission capture rate of 90 percent for all new or modified projects. The capture of 90 percent of new development establishes a strong basis for demonstrating that cumulative reductions are being achieved across the state to achieve AB 32 goals (CAPCOA 2008). Thus, for the purposes of this analysis, the City is using a threshold of 3,000 MT CO2E annually Analysis of s Methodology and Assumptions To evaluate the project s net GHG emissions, emissions were calculated using the CalEEMod version released in September 2016 by CAPCOA (CAPCOA 2016). CalEEMod was developed the participation of several state air districts, including the San Diego Air Pollution Control District. CalEEMod can be used to calculate emissions from construction (off-road vehicles), mobile (on-road vehicles), energy (electricity and natural gas), area (fireplaces, consumer products [cleansers, aerosols, solvents], landscape maintenance equipment, architectural coatings), water and wastewater, and solid waste sources. GHG emissions are estimated in terms of total MT CO2E. Emissions were calculated for project operation in year The analysis methodology and input data are described in the following sections. Where project-specific data was not available, model inputs were based on information provided in the CalEEMod User s Guide (CAPCOA 2016). Thus, the project was modeled an operational year of 2020 to parallel the year of the City and State GHG reduction goals. a. Construction Emissions Construction activities emit GHGs primarily though combustion of fuels (mostly diesel) in the engines of off-road construction equipment and through combustion of diesel and gasoline in on-road construction vehicles and the commute vehicles of the construction workers. Smaller amounts of GHGs are also emitted through the energy use embodied in water use for fugitive dust control. Every phase of the construction process, including demolition, grading, paving, and building, emits GHGs in volumes directly related to the quantity and type of construction equipment used. GHG emissions associated each phase of project construction are calculated by multiplying the total fuel consumed by the construction equipment and worker trips by applicable emission factors. The number and pieces of construction equipment are calculated based on the project-specific design. In the absence of project-specific construction information, equipment for all phases of construction is estimated based on the size of the land use. Page 20

25 Construction emissions were modeled assuming construction would begin in January 2017 and approximately 14 months. Based on guidance from the SCAQMD, total construction GHG emissions resulting from a project should be amortized over 30 years and added to operational GHG emissions to account for their contribution to GHG emissions over the lifetime of a project (SCAQMD 2009). b. Vehicle Emissions GHG emissions from vehicles come from the combustion of fossil fuels in vehicle engines. The vehicle emissions are calculated based on the vehicle type and the trip rate for each land use. The vehicle emission factors and fleet mix used in CalEEMod are derived from CARB s 2014 Emission Factors model. According to the project traffic report, Option 1, office space, would generate 1,740 average daily trips, and Option 2, the assisted living facility, would generate 1,133 average daily trips (see Attachments 2 and 3; LOS Engineering, Inc. 2017a and 2017b). The total trip generation is multiplied by the regional trip length to determine total project annual vehicle miles traveled (VMT). Default trip lengths and vehicle emission factors were used. c. Energy Emissions GHGs are emitted as a result of activities in buildings for which electricity and natural gas are used as energy sources. GHGs are emitted during the generation of electricity from fossil fuels off-site in power plants. These emissions are considered indirect but are calculated in association a building s operation. Electric power generation accounts for the second largest sector contributing to both inventoried and projected statewide GHG emissions. Combustion of fossil fuel emits criteria pollutants and GHGs directly into the atmosphere. When this occurs in a building, this is considered a direct emissions source associated that building. CalEEMod estimates emissions from the direct combustion of natural gas for space and water heating. Energy consumption values are based on the CEC-sponsored California Commercial End Use Survey and Residential Appliance Saturation Survey studies, which identify energy use by building type and climate zone. Because these studies are based on older buildings, adjustments have been made in CalEEMod to account for changes to Title 24 Building Codes. CalEEMod is based on the 2013 Title 24 energy code (Part 6 of the Building Code). The project would be subject to the 2016 Title 24 energy code. Preliminary CEC estimates indicate that non-residential uses built consistent 2016 Title 24 requirements will be 5 percent more energy efficient than those built consistent 2013 Title 24 requirements (CEC 2015). The project would be served by the Imperial Irrigation District (IID). Therefore, IID s specific energy-intensity factors (i.e., the amount of CO2, methane [CH4], and N2O per kilowatt-hour) are used in the calculations of GHG emissions. As discussed, the state mandate for renewable energy is 33 percent by However, the energy-intensity factors included in CalEEMod by default only represent a 8.3 percent procurement of renewable Page 21

26 energy. To account for the continuing effects of RPS through 2020, the energy-intensity factors included in CalEEMod were reduced by 24.7 percent. d. Area Source Emissions Area sources include GHG emissions that would occur from the use of landscaping equipment. The use of landscape equipment emits GHGs associated the equipment s fuel combustion. The landscaping equipment emission values were derived from the 2011 In-Use Off-Road Equipment Inventory Model (CARB 2011). e. Water and Wastewater Emissions The amount of water used and wastewater generated by a project has indirect GHG emissions associated it. These emissions are a result of the energy used to supply, distribute, and treat the water and wastewater. In addition to the indirect GHG emissions associated energy use, wastewater treatment can directly emit both CH4 and N2O. The indoor and outdoor water use consumption data for each land use subtype comes from the Pacific Institute s Waste Not, Want Not: The Potential for Urban Water Conservation in California 2003 (as cited in CAPCOA 2016). Based on that report, a percentage of total water consumption was dedicated to landscape irrigation, which is used to determine outdoor water use. Wastewater generation was similarly based on a reported percentage of total indoor water use (CAPCOA 2016). The project would be subject to CalGreen, which requires a 20 percent increase in indoor water use efficiency. Thus, in order to demonstrate compliance CalGreen, a 20 percent reduction in indoor water use was included in the water consumption calculations for the project. In addition to water reductions under CalGreen, the GHG emissions from the energy used to transport the water are affected by RPS. As discussed previously, to account for the effects of RPS through 2020, the energy-intensity factors included in CalEEMod were reduced by 24.7 percent. f. Solid Waste Emissions The disposal of solid waste produces GHG emissions from anaerobic decomposition in landfills, incineration, and transportation of waste. To calculate the GHG emissions generated by disposing of solid waste for the project, the total volume of solid waste was calculated using waste disposal rates identified by California Department of Resources Recycling and Recovery. The methods for quantifying GHG emissions from solid waste are based on the Intergovernmental Panel on Climate Change method, using the degradable organic content of waste. GHG emissions associated the project s waste disposal were calculated using these parameters. According to a CalRecyle report to the Legislature, as of 2013 California has achieved a statewide 50 percent diversion of solid waste from landfills through reduce/recycle/compost programs (CalRecycle 2015). However, AB 341 mandates that 75 percent of the solid waste generated be reduced, recycled, or composted by Page 22