MARINA APARTMENT PROJECT PETALUMA, CA AIR QUALITY AND GREENHOUSE GAS EMISSIONS ASSESSMENT

Transcription

1 MARINA APARTMENT PROJECT PETALUMA, CA AIR QUALITY AND GREENHOUSE GAS EMISSIONS ASSESSMENT April 13, 2015 Prepared for - Paul Andronico Basin Street Properties 119 C St Petaluma, CA Via <paul@andronico.com> Prepared by James A. Reyff and William Popenuck 1 Willowbrook Court, Suite 120 Petaluma, California Tel: I&R Project # Executive Summary This air quality and greenhouse gas (GHG) emissions analysis evaluated localized, regional and cumulative impacts from construction and operation of the proposed Marina Apartment project. Construction air quality impacts were addressed by comparing project emissions to significance thresholds, prescribing best management practices to reduce fugitive dust emissions and performing a community/health risk assessment of construction emissions upon existing residences. Operational impacts were evaluated by comparing future project emissions and traffic to significance thresholds. Impacts to new sensitive receptors, or project residents, were evaluated by performing a community/health risk assessment that evaluated effects associated with nearby traffic, future SMART and freight train operations and nearby air pollutant sources permitted by the Bay Area Air Quality Management District (BAAQMD). Finally, GHG emissions were predicted using the CalEEMod model recommended by BAAQMD, evaluating both annual and per capita emissions. No significant impacts air quality or GHG impacts attributable to the project were identified. This analysis followed guidance recommended by the BAAQMD.

2 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 2 Introduction This report addresses air quality impacts and greenhouse gas emissions that the project would contribute to the effect of climate change, as indicated in the environmental checklist questions for compliance with CEQA. The project would construct a new apartment building in Petaluma, California. The proposed project is an 80-unit, 5-story, apartment building at the Petaluma Marina near Lakeville Road and Baywood Drive. The project would be constructed at a portion of the Marina parking lot that is underutilized. The site is flat and would not require substantial demolition or grading. This analysis was conducted following guidance provided by the Bay Area Air Quality Management District (BAAQMD) 1. Each of the CEQA Checklist questions for air quality and climate change are addressed below. Air Quality Setting The project is located in the portion of Sonoma County within the San Francisco Bay Area Air Basin. Ambient air quality standards have been established at both the State and federal level. The Bay Area meets all ambient air quality standards with the exception of ground-level ozone, respirable particulate matter (PM 10 ) and fine particulate matter (PM 2.5 ). High ozone levels are caused by the cumulative emissions of reactive organic gases (ROG) and nitrogen oxides (NOx). These precursor pollutants react under certain meteorological conditions to form high ozone levels. Controlling the emissions of these precursor pollutants is the focus of the Bay Area s attempts to reduce ozone levels. The highest ozone levels in the Bay Area occur in the eastern and southern inland valleys that are downwind of air pollutant sources. High ozone levels aggravate respiratory and cardiovascular diseases, reduced lung function, and increase coughing and chest discomfort. Particulate matter is another problematic air pollutant of the Bay Area. Particulate matter is assessed and measured in terms of respirable particulate matter or particles that have a diameter of 10 micrometers or less (PM 10 ) and fine particulate matter where particles have a diameter of 2.5 micrometers or less (PM 2.5 ). Elevated concentrations of PM 10 and PM 2.5 are the result of both region-wide (or cumulative) emissions and localized emissions. High particulate matter levels aggravate respiratory and cardiovascular diseases, reduce lung function, increase mortality (e.g., lung cancer), and result in reduced lung function growth in children. Toxic air contaminants (TAC) are a broad class of compounds known to cause morbidity or mortality (usually because they cause cancer) and include, but are not limited to, the criteria air pollutants listed above. TACs are found in ambient air, especially in urban areas, and are caused by industry, agriculture, fuel combustion, and commercial operations (e.g., dry cleaners). TACs are typically found in low concentrations, even near their source (e.g., diesel particulate matter near a freeway). Because chronic exposure can result in adverse health effects, TACs are regulated at the regional, state, and Federal level. Diesel exhaust is the predominant TAC in urban air and is estimated to represent about three-quarters of the cancer risk from TACs (based on the Bay Area average). According to the CARB, diesel exhaust is a complex mixture of gases, vapors and fine particles. This complexity makes the evaluation of health effects of diesel exhaust a complex scientific issue. Some of the chemicals in diesel exhaust, such as benzene and formaldehyde, have been previously identified as TACs by the CARB, and are listed as carcinogens either under the state's Proposition 65 or under the Federal Hazardous Air Pollutants programs. 1 BAAQMD BAAQMD CEQA Air Quality Guidelines. May.

3 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 3 Grenhouses Gases - Setting Gases that trap heat in the atmosphere, GHGs, regulate the earth s temperature. This phenomenon, known as the greenhouse effect, is responsible for maintaining a habitable climate. The most common GHGs are carbon dioxide and water vapor but there are also several others, most importantly methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). These are released into the earth s atmosphere through a variety of natural processes and human activities. Sources of GHGs are generally as follows: Carbon dioxide and nitrous oxide are byproducts of fossil fuel combustion. Nitrous oxide is primarily associated with agricultural operations such as fertilization of crops. Methane is commonly created by off-gassing from agricultural practices (e.g., keeping livestock) and landfill operations. Chlorofluorocarbons were widely used as refrigerants, propellants, and cleaning solvents but their production has been reduced by international treaty. Hydrofluorocarbons are now used as a substitute for chlorofluorocarbons in refrigeration and cooling. Perfluorocarbons and sulfur hexafluoride emissions are commonly created by industries such as aluminum production and semi-conductor manufacturing. Each GHG has its own potency and effect upon the earth s energy balance. This is expressed in terms of a global warming potential (GWP), with carbon dioxide being assigned a value of 1 and sulfur hexafluoride being several orders of magnitude stronger with a GWP of 23,900. In GHG emission inventories, the weight of each gas is multiplied by its GWP and is measured in units of carbon dioxide equivalents (CO 2 e). An expanding body of scientific research supports the theory that global warming is currently affecting changes in weather patterns, average sea level, ocean acidification, chemical reaction rates, and precipitation rates, and that it will increasingly do so in the future. The climate and several naturally occurring resources within California could be adversely affected by the global warming trend. Increased precipitation and sea level rise could increase coastal flooding, saltwater intrusion, and degradation of wetlands. Mass migration and/or loss of plant and animal species could also occur. Potential effects of global climate change that could adversely affect human health include more extreme heat waves and heat-related stress; an increase in climate-sensitive diseases; more frequent and intense natural disasters such as flooding, hurricanes and drought; and increased levels of air pollution. Regulatory Setting The U.S. Environmental Protection Agency (U.S. EPA) is responsible for enforcing the federal Clean Air Act and the 1990 amendments to it, as well as the national ambient air quality standards (federal standards) that the U.S. EPA establishes. These standards identify levels of air quality for six criteria pollutants, which are considered the maximum levels of ambient air pollutants considered safe, with an adequate margin of safety, to protect public health and welfare. The six criteria pollutants are ozone (O 3 ), carbon dioxide (CO), nitrogen dioxide (NO 2 ), sulfur dioxide (SO 2 ), respirable particulate matter with an aerodynamic diameter of 10 micrometers (PM 10 ), fine particulate matter with an aerodynamic diameter of 2.5 micrometers (PM 2.5 ), and lead (Pb). The U.S. EPA also has regulatory and enforcement jurisdiction over emission sources beyond state waters (outer continental shelf) and sources that are under the exclusive authority of the federal government, such as aircraft, train locomotives, and interstate trucking. As part of its enforcement responsibilities, the U.S. EPA requires each state with nonattainment areas (i.e., areas that do not meet national ambient air quality standards) to prepare and submit a State

4 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 4 Implementation Plan (SIP) that demonstrates the means to attain the federal standards. The SIP must integrate federal, state, and local plan components and regulations to identify specific measures to reduce pollution in nonattainment areas, using a combination of performance standards and market-based programs. The California Air Resources Board (CARB), a department of the California Environmental Protection Agency, oversees air quality planning and control throughout California. It is primarily responsible for ensuring implementation of the 1989 amendments to the California Clean Air Act (CCAA), responding to the federal CAAA requirements, and regulating emissions from motor vehicles and consumer products within the state. CARB has established emission standards for vehicles sold in California and for various types of equipment available commercially. It also sets fuel specifications to further reduce vehicular emissions and develops airborne toxic control measures to reduce toxic air contaminants (TAC) identified under CARB regulations. Both the U.S. EPA and CARB established ambient air quality standards for common air pollutants. These ambient air quality standards are prescribed levels of pollutants that represent safe levels that avoid specific adverse health effects associated with each pollutant. The ambient air quality standards cover what are called criteria pollutants because the health and other effects of each pollutant are described in criteria documents. The federal and state ambient standards were developed independently with differing purposes and methods, although both processes attempted to avoid health-related effects. As a result, federal and state standards differ in some cases. In general, California standards are more stringent. This is particularly true for ozone and respirable particulate matter (PM 10 ). The Bay Area Air Quality Management District (BAAQMD) is the regional agency tasked with managing air quality in the region. At the State level, the California Air Resources Board (a part of the California Environmental Protection Agency) oversees regional air district activities and regulates air quality at the State level. The BAAQMD has published CEQA Air Quality Guidelines that are used in this assessment to evaluate air quality impacts of projects. 2 Significance Thresholds In June 2010, BAAQMD adopted thresholds of significance to assist in the review of projects under CEQA. These thresholds were designed to establish the level at which BAAQMD believed air pollution emissions would cause significant environmental impacts under CEQA and were posted on BAAQMD s website and included in the Air District's updated CEQA Guidelines (updated May 2011). The significance thresholds identified by BAAQMD and used in this analysis are summarized in Table 1. BAAQMD s adoption of significance thresholds contained in the 2011 CEQA Air Quality Guidelines was called into question by an order issued March 5, 2012, in California Building Industry Association (CBIA) v. BAAQMD (Alameda Superior Court Case No. RGI ). The order requires BAAQMD to set aside its approval of the thresholds until it has conducted environmental review under CEQA. The ruling made in the case concerned the environmental impacts of adopting the thresholds and how the thresholds would indirectly affect land use development patterns. In August 2013, the Appellate Court struck down the lower court s order to set aside the thresholds. However, this litigation remains pending as the California Supreme Court recently accepted a portion of CBIA's petition to review the appellate court's decision to uphold BAAQMD's adoption of the thresholds. The specific portion of the argument to be considered is in regard to whether CEQA requires consideration of the effects of the environment on a project (as contrasted to the effects of a proposed project on the environment). Therefore, the significance thresholds contained in the 2011 CEQA Air Quality Guidelines are applied to this project. 2 Bay Area Air Quality Management District BAAQMD CEQA Air Quality Guidelines. May.

5 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 5 Table 1. Air Quality Significance Thresholds Construction Thresholds Pollutant Criteria Air Pollutants Average Daily Emissions (lbs./day) Operational Thresholds Average Daily Emissions (lbs./day) Annual Average Emissions (tons/year) ROG NO x PM PM CO Dust Not Applicable Construction Dust Ordinance or other Best Management Practices 9.0 ppm (8-hour average) or 20.0 ppm (1- hour average) Not Applicable Health Risks and Hazards for New Sources and Single Sources Affecting Sensitive Receptors Excess Cancer Risk Chronic or Acute Hazard Index Incremental annual average PM per one million µg/m 3 Health Risks and Hazards for Sensitive Receptors (Cumulative from all sources within 1,000 foot zone of influence) and Cumulative Thresholds for New Sources Excess Cancer Risk 100 per one million Chronic Hazard Index 10.0 Annual Average PM µg/m 3 Greenhouse Gas Emissions from Land Use Projects GHG Annual Emissions 1,100 metric tons or 4.6 metric tons per capita Note: ROG = reactive organic gases, NOx = nitrogen oxides, PM 10 = course particulate matter or particulates with an aerodynamic diameter of 10 micrometers (µm) or less, PM 2.5 = fine particulate matter or particulates with an aerodynamic diameter of 2.5µm or less; and GHG = greenhouse gas. Impact 1: Conflict with or obstruct implementation of the applicable air quality plan? Less than significant The most recent clean air plan is the Bay Area 2010 Clean Air Plan that was adopted by BAAQMD in September The proposed project would not conflict with the latest Clean Air planning efforts since the project would have emissions well below the BAAQMD thresholds (see Impact 2), and development would be near existing transit with regional connections. The project, at 80 apartments with shared parking, is too small to exceed any of the significance thresholds and, thus, it is not required to incorporate project-specific transportation control measures listed in the latest Clean Air Plan

6 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 6 Impact 2: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable Federal or State ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? Less than significant The Bay Area is considered a non-attainment area for ground-level ozone and fine particulate matter (PM 2.5 ) under both the Federal Clean Air Act and the California Clean Air Act. The area is also considered non-attainment for respirable particulates or particulate matter with a diameter of less than 10 micrometers (PM 10 ) under the California Clean Air Act, but not the Federal act. The area has attained both State and Federal ambient air quality standards for carbon monoxide. As part of an effort to attain and maintain ambient air quality standards for ozone and PM 10, the BAAQMD has established thresholds of significance for these air pollutants and their precursors. These thresholds are for ozone precursor pollutants (ROG and NOx), PM 10 and PM 2.5 and apply to both construction period and operational period impacts. Due to the project size, construction exhaust and operational period emissions would be less than significant. In their 2011 update to the CEQA Air Quality Guidelines, BAAQMD identified the size of land use projects that could result in significant air pollutant emissions. For construction exhaust and evaporative ROG impacts, the apartment land use size was identified at 240 dwelling units. For operational impacts, the project size was identified at 494 dwelling units. Since the project proposes 80 apartments and does not require extensive demolition or grading, it is concluded that emissions would be below the BAAQMD significance thresholds for both construction exhaust and operational emissions (see Table 1). However, construction activities, particularly during site preparation and grading would temporarily generate fugitive dust in the form of PM 10 and PM 2.5. Sources of fugitive dust would include disturbed soils at the construction site and trucks carrying uncovered loads of soils. Unless properly controlled, vehicles leaving the site would deposit mud on local streets, which could be an additional source of airborne dust after it dries. dust emissions would vary from day to day, depending on the nature and magnitude of construction activity and local weather conditions. dust emissions would also depend on soil moisture, silt content of soil, wind speed, and the amount of equipment operating. Larger dust particles would settle near the source, while fine particles would be dispersed over greater distances from the construction site. The BAAQMD CEQA Air Quality Guidelines consider these impacts to be less than significant if best management practices are employed to reduce these emissions. Assuming that BMPs listed below are included in the project, emissions would be less than significant, because the project would be below the screening size for both construction exhaust and operational period emissions. Construction BMPs: Include measures to control dust emissions. Implementation of the measures recommended by BAAQMD and listed below would reduce the air quality and fugitive dust-related impacts associated with grading and new construction to a less than significant level. The contractor shall implement the following Best Management Practices that are required of all projects: 1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day. 2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered. 3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.

7 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 7 4. All vehicle speeds on unpaved roads shall be limited to 15 mph. 5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used. 6. Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points. 7. All construction equipment shall be maintained and properly tuned in accordance with manufacturer s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. 8. 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. Impact 3: Violate any air quality standard or contribute substantially to an existing or projected air quality violation? Less than significant As discussed under Impact 2, the project would have emissions less than the BAAQMD screening size for evaluating impacts related to ozone and particulate matter. Therefore, the project would not contribute substantially to existing or projected violations of those standards. Carbon monoxide emissions from traffic generated by the project would be the pollutant of greatest concern at the local level. Congested intersections with a large volume of traffic have the greatest potential to cause high-localized concentrations of carbon monoxide. Air pollutant monitoring data indicate that carbon monoxide levels have been at healthy levels (i.e., below State and federal standards) in the Bay Area since the early 1990s. As a result, the region has been designated as attainment for the standard. Intersections affected by the project would have traffic volumes far less than the BAAQMD screening criteria and, thus, would not cause a violation of an ambient air quality standard or have a considerable contribution to cumulative violations of these standards. 3 For example, Lakeville Highway would carry 37,000 annual average daily trips (AADT) and U.S. Highway 101 would carry 87,000 AADT, as reported by Caltrans. 4 Caltrans data indicates between 8 and 10 percent of the AADT traffic occur during the peak hour; therefore, the total peak-hour traffic at the interchange of U.S. 101 and Lakeville Highway would be less than 12,400 vehicles per hour. Impact 4: Expose sensitive receptors to substantial pollutant concentrations? Less than significant Operation of the project is not expected to cause any localized emissions that could expose sensitive receptors to unhealthy air pollutant levels. No stationary sources of TACs, such as generators, are 3 For a land-use project type, the BAAQMD CEQA Air Quality Guidelines state that a proposed project would result in a less than significant impact to localized carbon monoxide concentrations if the project would not increase traffic at affected intersections to more than 44,000 vehicles per hour. 4 California Department of Transportation Traffic Volumes on the California State Highway System.

8 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 8 proposed as part of the project. Construction activity would generate dust and equipment exhaust on a temporary basis. A community risk assessment was conducted to assess the impact of TACs emitted from construction activity upon nearby sensitive receptors. The project would introduce new residents (i.e., sensitive receptors) to exposures of TACs from Lakeville Highway (State Route 116), U.S. Highway 101 traffic and a nearby gasoline station. The effects of these exposures were evaluated using screening community risk assessment tools provided by BAAQMD and refined dispersion modeling of Lakeville Highway traffic. There are thresholds that address both the impact of single and combined TAC sources upon projects that affect existing sensitive receptors or include new sensitive receptors (see Table 1). Construction Activity Construction equipment and associated heavy-duty truck traffic generates diesel exhaust, which is a known TAC. Diesel exhaust poses both a health and nuisance impact to nearby receptors. A health risk assessment of the project construction activities was conducted that evaluated potential health effects of existing sensitive receptors from construction emissions of diesel particulate matter or DPM. 5 Emissions from construction activity were estimated and a dispersion model was used to predict the off-site DPM concentrations at sensitive receptors so that lifetime cancer risks could be predicted. The closest off-site sensitive receptors are residences to the northeast along Perry lane, about 600 feet away. Figure 1 shows the project site and sensitive receptor locations used in the air quality dispersion modeling analysis where potential health impacts were evaluated. Figure 1 Project Construction Site and Locations of Sensitive Receptors and Maximum Cancer Risks The California Emissions Estimator Model, CalEEMod, Version was used to predict emissions for construction activity. CalEEMod provides emission estimates for both on-site and off-site construction activities. On-site activities are primarily made up of construction equipment emissions, while off-site 5 DPM is identified by California as a toxic air contaminant due to the potential to cause cancer.

9 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 9 activity includes worker and vendor traffic. The CalEEMod modeling was based on schedule and equipment usage assumptions predicted by CalEEMod. Construction truck hauling traffic generation was based on the amount of material to be imported or exported along with estimates of cement and asphalt needed. Construction Emissions The following land use types were input to the CalEEMod model. Mid Rise Apartment = 80 Apartments, 92,833 square feet total (gross area) Parking Lot = 117 spaces Site Area for construction = 3 acres The CalEEMod model provided total construction PM 2.5 exhaust emissions (assumed to be diesel particulate matter) for the off-road construction equipment and for exhaust emissions from on-road vehicles (haul trucks, vendor trucks, and worker vehicles), with total emissions of tons (490 pounds). In evaluating potential impacts, it was assumed that all emissions from on-road vehicles would occur at the construction site. PM 2.5 dust emissions were calculated by CalEEMod as tons (101 pounds) for the overall construction period. Construction Dispersion Modeling The U.S. EPA ISCST3 dispersion model was used to predict DPM and PM 2.5 concentrations at existing sensitive receptors in the vicinity of the project construction area. The ISCST3 dispersion model is a BAAQMD-recommended model for use in modeling analysis of these land use types of emission activities for CEQA projects. 6 Emission sources for the construction site were grouped into two categories, exhaust emissions of DPM and fugitive PM 2.5 dust emissions. The ISCST3 modeling utilized one area source to model DPM exhaust emissions. An emission release height of 6 meters (20 feet) was used for the area-source exhaust emissions from construction equipment. This elevated source height reflects the height of the equipment exhaust pipes plus an additional distance for the height of the exhaust plume above the exhaust pipes to account for plume rise of the heated exhaust gases. One area source was also used to model fugitive PM 2.5 dust emissions from the construction area. For modeling fugitive PM 2.5 emissions, a near-ground level release height of two meters (6 feet) was used for the area source. Emissions from vehicle travel in and around the project site were included in the modeled area sources. That is, the mobile emissions generated by CalEEMod were added to the construction equipment emissions and included in the area sources used in the modeling. Construction emissions were modeled as occurring daily between 7 a.m. and 4 p.m. when the majority of the construction activity involving equipment usage would be conducted. Construction of the project is expected to occur over an approximate one-year period starting in The modeling used a five-year data set ( ) of hourly meteorological data from the Petaluma Municipal Airport prepared by the BAAQMD for use with the ISCST3 model. The airport is located 1.7 miles northeast of the project site. Annual DPM and PM 2.5 concentrations from construction emissions, assumed to all occur in 2016, were calculated at nearby sensitive receptors using the model. Model receptors were placed at each nearby residences. DPM and PM 2.5 concentrations were calculated at sensitive receptors using a receptor height of 1.5 meters (4.9 feet). 6 Bay Area Air Quality Management District (BAAQMD), 2012, Recommended Methods for Screening and Modeling Local Risks and Hazards, Version 3.0. May.

10 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 10 Predicted Construction Cancer Risk, PM 2.5 Concentrations and Hazards Table 2 shows the resulting community risk impacts resulting from construction of the Proposed Project and combined existing sources of TACs (e.g., highway traffic). The maximum modeled DPM concentrations occurred north of the project site on the north side of Lakeville Highway. The location of the receptor with maximum exposure is identified in Figure 1. Increased cancer risks were calculated using the modeled DPM concentrations and BAAQMD recommended risk assessment methods for infant (3rd trimester through 2 years of age), child (2 years through 16 years), and adult exposures. 7 The cancer risk calculations were based on applying the BAAQMD recommended age sensitivity factors to the DPM exposures. Age-sensitivity factors reflect the greater sensitivity of infants and small children to cancer causing TACs. BAAQMD recommended exposure parameters were used for the cancer risk calculations. 8 Infant and child exposures were assumed to occur at all residences. Results of this assessment indicate that for project construction the incremental residential child cancer risk at the maximally exposed individual (MEI) receptor would be 2.7 in one million and the incremental residential adult cancer risk would be 0.1 in one million. These increased cancer risks for child and infant exposures would be below the BAAQMD significance threshold of a cancer risk of 10 in one million or greater, and would be considered a less-than-significant impact. Table 2. Community Risk Levels Affecting Associated with Construction Cancer Risk (per million) Annual PM 2.5 (µg/m 3 ) Acute or Chronic Hazard Index Source Construction Residential Receptor (worst-case infant/child) <0.01 Single Source Threshold Significant? No No No Contribution from Combined Sources at Maximum Exposed Receptor Lakeville Road traffic >25 ft North U.S. 101 at >1,000 ft <1.9 <0.02 <0.01 Plant G10736 at >500 ft Metron Super Gas at 910 Baywood Dr <0.01 Combined Source <13.9 <0.14 <0.05 Combined Source Threshold Significant? No No No Note: The maximum for each source unlikely to occur in same place on the project site, but this combined level assumes that scenario as a worst-case assessment. The maximum modeled annual PM 2.5 concentration was 0.04 micrograms per cubic meter (μg/m 3 ) occurring at the same location where the maximum residential cancer risk would occur. This PM 2.5 concentration is lower than the BAAQMD significance threshold of 0.3 μg/m 3 used to judge the significance of health impacts from PM 2.5. This would be considered a less-than-significant impact. Potential non-cancer health effects due to chronic exposure to DPM were also evaluated. Non-cancer health hazards from TAC exposure are expressed in terms of a hazard index (HI), which is the ratio of the 7 Bay Area Air Quality Management District (BAAQMD), 2012, Recommended Methods for Screening and Modeling Local Risks and Hazards, May. 8 Bay Area Air Quality Management District (BAAQMD), 2010, Air Toxics NSR Program Health Risk Screening Analysis Guidelines, January.

11 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 11 TAC concentration to a reference exposure level (REL). California s Office of Environmental Health and Hazards (OEHHA) has defined acceptable concentration levels for contaminants that pose non-cancer health hazards. TAC concentrations below the REL are not expected to cause adverse health impacts, even for sensitive individuals. The chronic inhalation REL for DPM is 5 μg/m 3. The maximum modeled annual DPM concentration was μg/m 3, which is much lower than the REL. The maximum computed hazard index based on this DPM concentration is less than 0.01, which is much lower than the BAAQMD significance criterion of a hazard index greater than 1.0. This would be considered a lessthan-significant impact. Attachment 1 includes the CalEEMod modeling output, dispersion modeling summary and cancer risk calculations. Combined Construction Community Risk Levels The combined community risk levels associated with construction were computed at the receptor most affected by project construction. This would be a residence along Perry Lane. Other sources within 1,000 feet of the project that could affect this receptor are Lakeville Highway (Route 116) traffic (within 50 feet), Plant G10736 at 910 Baywood Drive (over 500 feet). and U.S. 101 traffic that is beyond 1,000 feet from the receptor (but within 1,000 feet of the site). The combined community risk levels for construction activities are shown in Table 2. The combined cancer risk, annual PM 2.5 concentration and non-cancer hazard would be below the combined-source significance thresholds. Operational Exposures Operational community risk impacts include the effect of nearby sources of TACs affecting the project site where new sensitive receptors would reside. A review of the area indicates that there are roadways within 1,000 feet of the site that could adversely affect new residences and one listed stationary sources of air pollution. In addition, the SMART rail line includes the operation of freight trains and future dieselpowered passenger trains or diesel mobile units. This analysis first used screening data provided by BAAQMD to identify the potential cancer risk and PM 2.5 exposure risks. Potentially significant risks were further evaluated using refined modeling techniques. Results of this analysis are presented in Table 3 and described below. Table 3 Combined Operational Community Risk Levels Annual PM 2.5 (µg/m 3 ) Acute or Chronic Hazard Index Cancer Risk Source (per million) U.S. 101 traffic at 400 ft West Link 744 (6ft elevation) <0.01 Lakeville Highway traffic at 125 ft North Refined modeling using Emfac2011/Cal3qhcr <0.01 Plant G10736 at 600 ft Metron Super Gas at 910 Baywood Dr <0.01 SMART Train Line at >200 ft west Includes freight trains < <0.01 Single Source Threshold Significant? No No No Combined Source < <0.03 Combined Source Threshold Significant? No No No Note: The maximum for each source unlikely to occur in same place on the project site, but this combined level assumes that scenario as a worst-case assessment.

12 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 12 State Highways Two State highways are within 1,000 feet of the project site: U.S. 101 at 400 feet west (including the eastward expansion) and Lakeville Highway (State Route 116) at about 125 feet to the north. BAAQMD provides a Google Earth Highway Screening Analysis Tool that can be used to identify screening level impacts from State Highways. This tool was used to identify the screening community risk levels from U.S. 101 and Lakeville Highway. U.S.101 traffic impacts were identified using Link 744 for a 6-foot-high exposure at the site (i.e., ground level exposure). Screening level impacts identified using this tool were below the BAAQMD significance thresholds (see Table 3). The screening tool indicated that exposures from Lakeville Highway at the ground floor dwelling units closest to Lakeville Highway were slightly above the cancer risk threshold. To further evaluate this impact, a refined analysis was conducted. This refined analysis was focused on assessing the impacts from Lakeville Highway traffic. The refined analysis involved predicting traffic emissions for the traffic volume and mix of vehicle types on Lakeville Highway. These emissions were input to a dispersion model to predict exposure to TACs. The associated cancer risk was computed based on the modeled exposures. A review of the traffic information reported by Caltrans indicates that in the vicinity of the project area, Lakeville Highway has 37,000 annual average daily trips (AADT), as reported by Caltrans. 9 This includes about 6.7 percent trucks, of which 3.7 percent are considered heavy duty trucks and 3.2 percent are medium duty trucks. The analysis involved the development of DPM and organic TAC emissions for traffic on Lakeville Highway using the CARB EMFAC2011 emission factor model and the traffic mix reported above. EMFAC2011 is the California Air Resources Board s (CARB) motor vehicle emission factor model. DPM emissions are projected to decrease in the future and are reflected in the EMFAC2011 emissions data. CARB regulations require on-road diesel trucks to be retrofitted with particulate matter controls or replaced to meet new 2010 engine standards that have much lower DPM and PM 2.5 emissions. This regulation will substantially reduce these emissions between 2013 and While new trucks and buses will meet strict federal standards, this measure is intended to accelerate the rate at which the fleet either turns over so there are more cleaner vehicles on the road, or retrofitted to meet similar standards. With this regulation, older, more polluting trucks would be removed from the roads sooner. Traffic Emissions. Emission factors for DPM (PM 2.5 exhaust from diesel vehicles) were developed for the year Default EMFAC2011 vehicle model year distributions for Sonoma County were used in calculating emissions for Emissions were based on an average speed of 30 mph, 10 miles below the posted speed limit, for all hours of the day. The number of vehicles per hour and emissions per vehicle mile traveled were assumed to be constant throughout the day. Year 2020 emissions were conservatively assumed as being representative of future conditions over the time period that cancer risks are evaluated (70 years), since, as discussed above, overall vehicle emissions, and in particular diesel truck emissions will decrease in the future. Emissions of total organic gases (TOG) were also calculated for 2020 using the EMFAC2011 model. These TOG emissions were then used in the modeling of the organic TACs. TOG emissions from exhaust and from running evaporative loses from gasoline vehicles were calculated using EMFAC2011 default model values for Sonoma County along with the traffic volumes and vehicle mixes for Lakeville Highway. The EMFAC2011 emission rates used in the analysis are included in Attachment 2. 9 California Department of Transportation Traffic Volumes on the California State Highway System.

13 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 13 Dispersion Modeling. Dispersion modeling of DPM and organic TAC emissions was conducted using the CAL3QHCR model, which is recommended by the BAAQMD for this type of analysis. 10 North and south bound traffic on Lakeville Highway within about 1,000 feet of the project site were evaluated with the model. The five-year data set of hourly meteorological data ( ) from the Petaluma Municipal Airport obtained from BAAQMD was used in the modeling. Other inputs to the model included road geometry, hourly traffic volumes, and emission factors. The modeling included on-site receptors placed throughout the proposed residential area. Receptor heights of 1.5 meters (5 feet) were used that are representative of the lowest level where residences will be constructed (i.e., ground level). Figure 1 also shows the roadway segments modeled and residential receptor locations used in the modeling. The maximum modeled concentrations and community risk impacts are shown in Table 3. Cancer Risk Computations. Using the modeled annual average DPM and TOG concentrations, the individual cancer risks were computed using the methods recommended by BAAQMD. 11 The factors used to compute cancer risk are highly dependent on modeled concentrations, exposure period or duration, and the type of receptor. The exposure level is determined by the modeled concentration; however, it has to be averaged over a representative exposure period. The averaging period is dependent on many factors, but mostly the type of sensitive receptor that would reside at a site. This assessment conservatively assumed long-term residential exposures. BAAQMD has developed exposure assumptions for typical types of sensitive receptors. For residential exposures this includes nearly continuous exposure over 70 years for 24 hours per day. It should be noted that the cancer risk calculations for 70-year residential exposures reflect use of BAAQMD s most recent cancer risk calculation method, adopted in January This method applies BAAQMD recommended Age Sensitivity Factors to the cancer risks for residential exposures, accounting for age sensitivity to TACs. Age-sensitivity factors reflect the greater sensitivity of infants and children to cancer causing TACs. The cancer risk calculations were based on applying the BAAQMD recommended 70 year average age sensitivity factor of 1.7 to the maximum modeled TAC concentrations based on 2020 emissions. The maximum increased cancer risk was computed as 6.3 in one million. This was modeled at a receptor representative of the residential units closest to Lakeville Highway, and is shown on Figure 1. Cancer risks at other locations would be lower than the maximum risk. The maximum increased cancer risk is below the BAAQMD s threshold of 10 in one million excess cancer cases per million. The modeling results and health risk calculations for the receptor with the maximum cancer risk from Lakeville Highway traffic are also provided in Attachment 2. BAAQMD-Permitted Stationary Sources BAAQMD s Stationary Source Screening Analysis Tool was used to identify stationary sources that may affect future residential development at the site. This is a Google Earth map tool used to identify BAAQMD permitted stationary sources. The linked database includes the associated estimated cancer risk and hazard impacts predicted by BAAQMD. One source affecting the site were identified: Plant G10736 at 600 ft. This source is the Metron Super Gas at 910 Baywood Dr. The BAAQMD Google Earth Tool provides screening community risk levels that are adjusted for distance (i.e., 600 feet) using their Distance Adjustment Multiplier Tool for Gasoline Dispensing Facilities (GDF). Resulting community risk levels obtained using this screening procedure were below the significance thresholds for single sources (see Table 3). SMART Train Line The Sonoma-Marin Rail Transit (SMART) railroad lies over 200 feet from proposed residences. The rail line currently experiences infrequent freight train activity. Eventually SMART trains and freight trains will be using this rail line on a regular basis. Environmental studies were performed for each proposed 10 BAAQMD, Recommended Methods for Screening and Modeling Local Risks and Hazards. May BAAQMD, Air Toxics NSR Program Health Risk Screening Analysis (HSRA) Guidelines, January.

14 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 14 use and used to predict community risk levels from these activities 12,13. Both studies predicted maximum risk levels for a position 30 feet from the rail line. Although these predictions are for positions much closer than depicted for project residences, they were used as screening values for this analysis. Both health risk studies for these environmental evaluations were conducted prior to BAAQMD s adoption of age-sensitivity factors, which account for the greater sensitivity of infants and small children to cancercausing TACs. The levels predicted in each study were increased by a factor of 1.7 to account for the age-sensitivity factors that assume the presence of infants and small children at residences. The predicted cancer risk, annual PM 2.5 concentrations and non-cancer hazards at 30 feet from the tracks is below the BAAQMD significance thresholds. These levels would be lower at over 200 feet from the tracks where project residences would be located. Combined Operational Community Risk Levels The combined community risk levels, shown in Table 3, are computed by adding the maximum TAC impacts together (although they would occur at different locations across the project site). The combined cancer risk would be 11.1 per million, combined PM 2.5 concentration would be 0.15 µg/m 3 and the noncancer HI would be less than 0.1. Community risk impacts would be below the thresholds for combined and single source levels. Impact 5: Create objectionable odors affecting a substantial number of people? significant Less than The project would generate localized emissions of diesel exhaust during construction equipment operation and truck activity. These emissions may be noticeable from time to time by nearby receptors. However, they would be localized and are not likely to adversely affect people off site by resulting in confirmed odor complaints. The project would not include any sources of significant odors that would cause complaints from surrounding uses. This would be a less-than-significant impact Impact 6: Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment? Less than significant The project is located in the southern portion of Sonoma County, where air quality is regulated at the local level by the Bay Area Air Quality Management District. The BAAQMD CEQA Air Quality Guidelines contain methodology and thresholds of significance for evaluating greenhouse gas (GHG) emissions from land use type projects. The BAAQMD thresholds were developed specifically for the Bay Area after considering the latest Bay Area GHG inventory and the effects of Assembly Bill 32 (AB 32) scoping plan measures that would reduce regional emissions. BAAQMD intends to achieve GHG reductions from new land use developments to close the gap between projected regional emissions with AB 32 scoping plan measures and the AB 32 targets. The BAAQMD suggested applying GHG efficiency thresholds to projects with emissions of 1,100 metric tons (MT) of CO 2 e (carbon dioxide equivalency) or greater 14. Projects that have emissions below 1,100 MT of CO 2 e per year are considered to have less than significant GHG emissions. Methodology GHG emissions were computed for the construction period and the build out (or operational) scenario of 12 Draft Environmental Impact Report (DEIR) for the North Coast Railroad Authority Project (SCH ) 13 Supplemental Environmental Impact Report (SEIR) for the Sonoma-Marin Area Rail Transit Project (SCH ) 14 BAAQMD California Environmental Quality Act Guidelines Update Proposed Thresholds of Significance. December.

15 Marina Apartment Project April 13, 2015 Air Quality and GHG Emissions Assessment Page 15 the proposed project. Specifically, construction emissions were computed for both construction and operation of the project using the California Emission Estimator model, CalEEMod Version Construction emissions were based on the size and type of the project and model defaults, including those for phasing, duration and equipment usage. The model predicts emissions of GHG in the form of equivalent carbon dioxide emissions or CO 2 e. CalEEMod predicts emission from traffic generated by the project as well as emissions associated with energy usage, water usage and solid waste generation. CalEEMod is the model recommended by BAAQMD for predicting emissions from land use development projects, such as this one. The following land use types were input to the model. Mid Rise Apartment = 80 Apartments, 92,833 square feet total (gross area) Parking Lot = 117 spaces Site Area for construction = 3 acres Construction Emissions The CalEEMod model was used to predict construction GHG emissions. The model, using the type and size of the project, generates a default 12-month construction schedule. Construction phases included minor demolition, site preparation, site grading, some paving, building construction and application of architectural coatings. CO 2 emissions associated with construction were assumed to occur mostly in 2016, with some emission occurring in early Under this scenario, construction of the project would emit 456 MT of CO 2 e. Neither the Petaluma nor BAAQMD have quantified thresholds for construction activities. However, the annual emissions would be below the lowest project emission threshold considered by BAAQMD. Operational Emissions The CalEEMod model along with the project vehicle trip generation rates and estimates were used to predict operational period GHG emissions associated with operation of a fully developed site under the proposed project. The model uses mobile emission factors from the California Air Resources Board s EMFAC2011 model and adjusts these based on the effect of new regulations to reduce GHG emissions. These regulations include the Pavley Rule that increases fleet efficiency (reducing fuel consumption) and the low carbon fuel standard. This model is sensitive to the year selected, since vehicle emissions have and continue to be reduced due to fuel efficiency standards and low carbon fuels. Adjustments to the modeling are described below. Year of Analysis Emissions associated with vehicle travel depend on the year of analysis. The earlier the year, the higher the emission rates as CalEEMod uses the California Air Resources Board s EMFAC2011 motor vehicle emissions model. This model assumes reduced emission rates as newer vehicles with lower emission rates replace older, more polluting vehicles through attrition of the overall vehicle fleet. The earliest year the project could be possibly constructed and fully operated for one year would be Full build out occurring later than 2017 would result in lower emissions. CalEEMod Traffic Inputs Traffic trip generation rates provided by the project traffic consultant (W-Trans) were used in lieu of the CalEEMod default assumptions (note that there was a very small difference in trip generations rates). The types of trips and trip lengths were based on CalEEMod defaults. Energy Consumption Energy usage emissions include those from natural gas combustion and electricity usage. CalEEMod model default energy usage inputs were used in the modeling. CalEEMod has a default rate of 641.3