David Balducci, Align Real Estate Doug Flaming, Doug Flaming Construction Management, Inc. Shari Libicki, Sarah Manzano, Kevin Warner

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1 MEMO Date: 1/13/17 To From CC David Balducci, Align Real Estate Doug Flaming, Doug Flaming Construction Management, Inc. Shari Libicki, Sarah Manzano, Kevin Warner Amara Morrison, Wendel Rosen Black & Dean, LLP Subject Evaluation of the Air Quality, Greenhouse Gas and Noise Impacts of the Proposed Development Relative to the Development of Opportunity Site #5 at 1380 N California Boulevard in Walnut Creek, California Ramboll Environ evaluated the air quality, greenhouse gas (GHG), and noise impacts of the proposed development of 1380 North California Boulevard (the Proposed Project) in Walnut Creek, California. We understand the Proposed Project is covered by the Locust Street/Mt. Diablo Specific Plan (the Specific Plan), but the Proposed Project includes different land uses than what was considered in the Specific Plan and its corresponding EIR. Thus, you have requested that we analyze the air quality, GHG, and noise impacts of the Project compared to the impacts studied in the Environmental Impact Report (EIR) 1 for the Specific Plan to determine if the land use differences for the Proposed Project will result in new impacts that were not identified in the EIR. Ramboll Environ 201 California St Suite 1200 San Francisco, CA USA T F PROPOSED PROJECT DESCRIPTION The Proposed Project is a mixed use development on the corner of North California Boulevard and Cypress Street in Walnut Creek, California. The Proposed Project will include up to 77 residential dwelling units, 20 hotel rooms, and 11,130 square feet of ground floor retail space. The Proposed Project will be located on Opportunity Area #5 in the Specific Plan. The Specific Plan assumed Opportunity Site #5 would be developed into 80,000 square feet of office space and 13,420 square feet of retail space. The Specific Plan assumed the entirety of the Specific Plan area would be developed with cumulative total of 60,000 square feet of residential uses (46 units) and 136,120 square feet of retail uses. DISCUSSION Ramboll Environ reviewed the air quality, GHG, and noise impact discussion in the EIR and evaluated how these might change with the land uses in the Proposed Project. We compared the impacts of the Proposed Project and the project for Opportunity Area #5 in the Specific Plan ( the Specific Plan Project ). The Specific Plan EIR addresses four (4) air quality, two (2) GHG impacts, and five (5) noise impacts. Below is discussion of how the Proposed Project compares to the conclusions made in the EIR with respect to these 11 impacts. Construction AQ Impact Impact AIR-1: Violate any air quality standard or contribute substantially to an existing or projected air quality violation or result in cumulatively considerable net increase of any criteria pollutant for which the project region is in non- 1 City of Walnut Creek Locust Street/Mt Diablo Blvd Specific Plan DEIR. Available at: 1/6

2 attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors) (criteria b and c). (Potentially Significant) The EIR states that construction exhaust emissions are less than significant. For fugitive dust emissions, the EIR applies Mitigation Measure AIR-1. Mitigation Measure AIR-1 implements basic and enhanced dust control procedures. The conclusions in the EIR are not expected to change with the Proposed Project. Because project specific construction information was not known at the time of the Specific Plan EIR, default construction equipment use can be used to estimate impacts. Default construction equipment use is based on site acreage. Because the site acreage is not changing between the Proposed Project and the Specific Plan Project, the default equipment use will also not change. The Proposed Project might have slightly more square footage than the Specific Plan Project. Heavy equipment is largely tied to area of the construction project, as most heavy equipment operation results from site clearing and preparation. Therefore a slight increase in square footage will not change the default heavy equipment hours estimated. However, the construction of the Proposed Project might increase the number of truck trips associated with construction. This is expected to be a minimal increase that would not affect the conclusions in the EIR. Thus, construction emissions are not expected to change with the Proposed Project. Mitigation Measure AIR-1 has dust control procedures for construction projects. Most measures are in line with the Bay Area Air Quality Management District s current basic and enhanced construction mitigation measures or not applicable to the Project. There were additional measures that were not included in the Specific Plan EIR, but would be relevant to the Proposed Project. In an effort to reduce emissions locally, the Project Sponsor would like to implement these as Best Management Practices for the Proposed Project. These are: Post a publicly visible sign with the telephone number and person to contact at the lead agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District s phone number shall also be visible to ensure compliance with applicable regulations. Strive to achieve a project wide fleet-average 20 percent NO X reduction and 45 percent PM reduction compared to the most recent ARB fleet average. Acceptable options for reducing emissions include the use of late model engines, low-emission diesel products, alternative fuels, engine retrofit technology, after-treatment products, add-on devices such as particulate filters, and/or other options as such become available. Operational Air Quality Impact Impact AIR-2: Violate any air quality standard or contribute substantially to an existing or projected air quality violation or result in cumulatively considerable net increase of any criteria pollutant for which the project region is in non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors) (criteria b, and c). (Less than Significant) The EIR evaluated the operational emissions from the components of the Specific Plan and compared them against thresholds of significance. The incremental emissions resulting from the Specific Plan Project were less than significant. 2/6

3 To evaluate if the conclusions in the EIR would change with the Proposed Project, we evaluated how the emissions would change compared to the Specific Plan Project at Opportunity Site #5. Operational emissions are driven by vehicle travel and energy use. 2 Vehicular emissions are dependent on number of trips and vehicle miles travelled (VMT). Kittelson & Associates, Inc. (KAI) analyzed the trip generation and VMT associated with the Proposed Project and the Specific Plan Project. As discussed in their December 8, 2016 memorandum to Doug Flaming and David Balducci, trip generation and VMT are expected to decrease by 19% for the Proposed Project compared to the Specific Plan Project. Thus, vehicular emissions are expected to be reduced with the Proposed Project compared to the Specific Plan Project. Table 1 shows estimates of energy use for the Specific Plan Project based on the energy use assumed in the Specific Plan EIR. Table 2 shows the estimates of energy use for the Proposed Project based on default energy uses from CalEEMod. 3 Table 2 also compares the energy use from the Specific Plan Project to the Proposed Project. Natural gas use for the Proposed Project is expected to be 84% of the natural gas use of the Specific Plan Project. Furthermore, the Proposed Project would be subject to the most recent Title 24 standards that reduce energy use, which are more stringent than standards considered at the time of the EIR. Energy use is expected to be lower with the Proposed Project and thus, emissions are also expected to be lower for the Proposed Project. Trip generation and energy use is expected to decrease for the Proposed Project compared to the Specific Plan Project. The remaining sources of operational emissions are expected to be similar to the emissions of the Specific Plan Project. Thus, operational emissions are expected to be similar or lower for the Proposed Project compared to the Specific Plan Project, and would thus be consistent with the conclusions of Impact AIR-2. Construction and Operational AQ Impacts Impact AIR-3: Expose sensitive receptors to substantial pollutant concentrations (criterion d). (Less than Significant) The EIR evaluated the impact of the Specific Plan Project on carbon monoxide (CO) concentration and risk from diesel particulate matter (DPM). The EIR concluded that construction and operational mobile-source impact of the Specific Plan Project on CO concentration would be less than significant. The EIR also concluded that the DPM released from construction would be less than significant. The conclusions are not expected to change with the Proposed Project. As discussed previously, construction activities of the Proposed Project and the Specific Plan Project are expected to be similar, so impact on CO concentration and risk from DPM from construction would not change. The number of trips generated by the Proposed Project is lower than the number of trips generated by the Specific Plan Project, so the CO impact from operational mobile emissions would be lower for the Proposed Project compared to the Specific Plan Project. Thus, the Proposed Project would be consistent with the conclusions made in Impact AIR-3. 2 Area sources, such as consumer products use, hearth use, and architectural coatings, also contribute to operational criteria air pollutant emissions, but tend to be small compared to vehicular travel and energy use. Thus, area sources are not expected to drastically change the emissions of the Proposed Project compared to the Specific Plan Project and are not studied further here. 3 CalEEMod was developed by Ramboll Environ in collaboration with the California Air Pollution Control Officers Association (CAPCOA) for use in developing emission inventories suitable for CEQA analysis. The model is publically available and employs widely accepted calculation methodologies for emission estimates combined with appropriate default data. 3/6

4 Impact AIR-4: The Specific Plan is consistent with the Bay Area Clean Air Plan, therefore the project will not have a cumulative air quality impact. (Less than Significant) The EIR states that the Specific Plan will be consistent with clean air planning efforts and therefore the Specific Plan will not contribute to a cumulative air quality impact. Because emissions from the Proposed Project will be lower than the Specific Plan Project, the Proposed Project will be consistent with the conclusions made in Impact AIR-4. Construction and Operational GHG Impacts Impact GHG-1: Greenhouse gas (GHG) emissions from implementation of the Specific Plan would not conflict with the state goal of reducing GHG emissions in California, consistent with AB 32. (Less than Significant) The EIR evaluates three types of analyses in determining whether the Specific Plan would conflict with state goals for reducing GHG emissions and concluded that the Specific Plan Project would be less than significant. The conclusions are not expected to change with the Proposed Project, as described below. The first analysis used to determine if the Specific Plan Project would conflict with state goals was identifying potential conflicts with the 44 Early Action Strategies identified by CARB. The Specific Plan Project did not conflict with these Strategies because they do not apply to land use development. The same conclusion would apply to the Proposed Project as well. The second analysis used to determine if the Specific Plan Project would conflict with state goals was comparing GHG emissions from the Specific Plan to GHG reduction goal of 174 million metric tons per year of CO 2e emissions by The EIR concluded the GHG emissions from the Specific Plan were quite small compared to the reduction goal and would not conflict with the state s ability to meet the reduction goals. This conclusion would hold true for the Proposed Project as well. Similar to the discussion in Impact AIR-2, GHG emissions from the Proposed Project are expected to be similar or lower compared to the Specific Plan Project. The emissions considered in this section of the EIR are construction and operational. As discussed previously, construction activity and emissions from the Proposed Project are expected to be similar to the activity and emissions for the Specific Plan Project. Operational GHG emissions are driven by vehicle travel and energy use. 4 As discussed in Impact AIR-2, the Proposed Project is expected to reduce trip generation for the Proposed Project compared to the Specific Plan Project. Thus, mobile emissions are expected to be lower for the Proposed Project. GHG emissions from energy use include electricity and natural gas use. As shown in Table 2, electricity use of the Proposed Project is expected to be 53% of the Specific Plan Project and natural gas use is expected to be 84% of the Specific Plan Project. As stated above, the emissions from vehicle travel and energy use are expected to be lower for the Proposed Project compared to the Specific Plan Project and construction emissions are expected to be similar. Thus, the Proposed Project would be consistent with this conclusion. The third analysis used to determine if the Specific Plan Project would conflict with state goals was determining whether the basic design parameters of a project are inherently energy efficient. The EIR stated the policies of the Specific Plan that support this idea and references policies from Walnut Creek s General Plan These policies would also apply to the Proposed Project, so the Proposed Project would be consistent with analysis in the EIR. 4 Water use and waste generation also contribute to GHG emissions. However, these activities usually are only about 5-10% of total GHG emissions. Thus, any change in water use or waste generation will have a small impact on total emissions. 4/6

5 Impact GHG-2: Implementation of the Specific Plan, combined with past, present, and reasonably foreseeable probable future projects, considering construction and operation activities, would not result in a substantial cumulative increase GHG emissions. (Less than Significant) The EIR states that the effect of GHG emissions is cumulative and implementation of the Specific Plan would not substantially increase GHG emissions if it complies with all state and local goals and polices. This statement holds true for the Proposed Project, so the Proposed Project would be consistent with the conclusions made in Impact GHG-2. Construction and Operational Noise Impacts Impact NOI-1: Development of the Specific Plan will result in temporary noise or vibration impacts related to construction activities (criteria a, b, and d). (Potentially Significant) The EIR states that noise from demolition of existing structures and construction of the Specific Plan would result in temporary noise-related impacts, and that noise from some construction activities could result in adverse effects on the ambient noise environment. Pile driving within 50 feet of existing buildings will require mitigation in the form of pre-and post-construction surveys to look for cracks in buildings (Mitigation Measure NOI-1). The conclusions regarding construction noise, as well as the mitigation requirement NOI-1, are not expected to change with the Proposed Project. As discussed previously, construction activities related to the Proposed Project and the Specific Plan Project are expected to be similar, and noise generated by such activities is not expected to change. The duration (i.e., overall schedule) of haul traffic noise may be extended relative to the Specific Plan, however the expected level of impact would not change compared to the Specific Plan Project based on similar haul routes and truck types. Thus, the Proposed Project would be consistent with the conclusions made in Impact NOI-1. Impact NOI-2: Residential uses built as part of the Specific Plan could be exposed to excessive exterior and interior noise levels (criterion a). (Less than Significant) The EIR states that existing noise levels at residential units within the Specific Plan would be within the range of conditionally acceptable (existing exterior levels are between 68 and 72 dba, DNL). The City s Building Department will require that residential apartments meet the interior state standard of 45 dba, Ldn. Air conditioning may be required for residential units to ensure proper ventilation and cooling should windows be required to remain closed to meet the 45 dba Ldn noise standard. The conclusions regarding acceptable interior levels through air conditioning and closed windows is not expected to change with the Proposed Project. Residential units proposed with the Project would be expected to be designed to the same state noise standard (i.e., 45 dba, Ldn, indoors with windows closed), and will be subject to approval from the City s Building Department. The hotel proposed for the Project would be designed to meet the same noise standards as for new residential units. Thus, the Proposed Project would be consistent with the conclusions made in Impact NOI-2. Impact NOI-3: Operational activities associated with the Specific Plan could affect residences developed as part of the Specific Plan (criteria a and c). (Potentially Significant) The EIR states that non-transportation noise sources associated with operation of the Specific Plan would include commercial sources such as HVAC equipment, trash compactors, loading areas, truck idling, and other miscellaneous powered equipment. For residential areas within the Specific Plan that could be exposed to high levels of noise from these sources, several mitigation measures have been proposed: 5/6

6 - Mitigation Measure NOI-3a: Require that noise emissions from Specific Plan commercial facilities do not exceed normally acceptable exterior levels at new residential units; require adherence to the state noise insulation standard (Title 24 of the California Code of Regulations, Part 2, Appendix Chapter 12A). - Mitigation Measure NOI-3b: Require that noise from commercial operations, such as loading, material handling, garbage collection, etc., does not exceed 45 dba Leq, or the existing ambient noise level if greater than 45 dba, at the exterior of noise sensitive receptors, in any one hour between 10:00 p.m. and 6:00 a.m. - Mitigation Measure NOI-3c: Require that HVAC units and other building equipment are located far from residential areas, or shielded from line of sight to residential receivers. Also, require that truck delivery areas be located far from residential areas, and to the extent possible, design buildings such that they provided shielding between truck areas and residential receivers. The conclusions regarding on-site stationary commercial facilities and equipment, as well as truck areas, and the mitigation measures required to ensure acceptable interior levels at residential apartments, is not expected to change with the Proposed Project. Residential units proposed with the Project would be expected to be designed such that they afforded the same level of noise protection from onsite stationary equipment and truck areas. The hotel proposed for the Project would be designed to meet the same noise standards as for new residential units. Thus, the Proposed Project would be consistent with the conclusions made in Impact NOI-3. Impact NOI-4: Project-generated vehicle traffic associated with the Specific Plan will result in an increase in ambient noise levels on local roadways (Less than Significant) The EIR states that traffic generated by the Specific Plan is expected to reduce daily vehicle trips across the local street network. The Project would result in reduced traffic volumes, and therefore would continue to result in less than significant noise impacts. Thus, the Proposed Project would be consistent with the conclusions made in Impact NOI-4. Impact NOI-5: Implementation of the Specific Plan, combined with other past, present, and reasonably foreseeable development in the vicinity, will not result in cumulative noise impacts (Less than Significant) The EIR states that cumulative noise levels from development of the Specific Plan (including construction and operational noise and vibration) are expected to be increased in the vicinity of the Specific Plan. Noise mitigation measures identified above for NOI-1 and NOI-3 are anticipated to ensure that the potential for cumulative noise impacts is less than significant. Most residential and commercial elements of the Project are similar to the Specific Plan (i.e., residential apartments, retail, and parking). The hotel proposed for the Project is expected to generate noise emission consistent with both the residential and commercial facilities that are proposed for the Project and Specific Plan. Therefore, the conclusion regarding cumulative noise is not expected to change with the Proposed Project. Thus, the Proposed Project would be consistent with the conclusions made in Impact NOI-5. 6/6

7 ATTACHMENT TABLES Ramboll Environ

8 Table 1: Energy Use for Opportunity Site 5 in the Specific Plan 1380 N California Blvd Walnut Creek, California Land Use Sub Type Strip Mall General Office Building Estimated Energy Use per Unit 1 Electricity Natural Gas Land Use Size Unit Total Electricity Use 2 Total Natural Gas Use 2 kwh per unit kbtu per unit kwh/yr kbtu/yr ,420 sf 185, , ,000 sf 1,027,200 1,920,000 Total 1,212,933 2,387,016 Notes: 1. Electricity and Natural Gas use are the intensity values used in the Specific Plan EIR. Appendix B of the EIR shows that default energy intensities from URBEMIS were used. These values are the default intensities from URBEMIS Total energy use is the product of the estimated energy use per unit and the land use size. Abbreviations: DU - dwelling units kbtu - 1,000 British thermal units kwh - kilowatt hour sf - square feet yr - year References: City of Walnut Creek Locust Street/Mt Diablo Boulevard Specific Plan. Responses to Comments/Final Environmental Impact Report. Available online at: URBEMIS 2007 v9.2. Available online at:

9 Land Use Sub Type Strip Mall Apartments Mid Rise Hotel Table 2: Energy Use for Proposed Project at Opportunity Site N California Blvd Walnut Creek, California Estimated Energy Use per Unit 1 Electricity Natural Gas Land Use Size Unit kwh per unit kbtu per unit kwh/yr kbtu/yr ,130 sf 130,110 27,714 3,527 8, DU 271, ,826 12,255 67, Room 245,098 1,346,875 Total for Proposed Project 646,752 2,000,415 Total for Specific Plan Project 3 1,212,933 2,387,016 Ratio of Energy Use - Proposed Project/Specific Plan Project 4 Total Electricity Use 2 Total Natural Gas Use 2 53% 84% Notes: 1. Electricity and Natural Gas use are default values from CalEEMod for all energy use types. CalEEMod default energy use for hotel is in terms of square feet. This was converted to per room using 1,452 square feet per room, which is also a CalEEMod default. 2. Total energy use is the product of the estimated energy use per unit and the land use size. 3. Total for Specific Plan Project from Table Ratio of energy use is the increase or decrease in energy use for the Proposed Project compared to the Specific Plan Project. The Proposed Project is expected to use less electricity and natural gas than the Specific Plan Project. Abbreviations: DU - dwelling units kbtu - 1,000 British thermal units kwh - kilowatt hour sf - square feet yr - year References: California Air Pollution Control Officers Association (CAPCOA) CalEEMod. Available at: