Los Angeles River Ecosystem Restoration Integrated Feasibility Study. Appendix F Air Quality

Transcription

1 Los Angeles River Ecosystem Restoration Integrated Feasibility Study Appendix F Air Quality Appendix F : Clean Air Act Applicability Analysis Appendix F 2: Air Quality Calculations Methodology and Data

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3 Appendix F Clean Air Act Applicability Analysis Introduction The General Conformity Rule at Section 76(c) of the Clean Air Act (CAA) ensures that federal actions comply with the national ambient air quality standards (NAAQS). In order to conform with the rule, a federal agency must demonstrate that an action it undertakes, approves, permits, or supports will conform to the appropriate state implementation plan (SIP). The conformity evaluation ensures that projects using federal funds or requiring federal approval not: cause or contribute to any new violation of a NAAQS, increase the frequency or severity of any existing violation, or delay the timely attainment of any standard, interim emission reduction, or other milestone. A conformity determination is required for each criteria pollutant or precursor where the total of direct and indirect emissions of the criteria pollutant or precursor in a nonattainment or maintenance area caused by the Federal action would equal or exceed any of the rates listed in Table 2-. Direct emissions means those emissions of a criteria pollutant or its precursors that are caused or initiated by the Federal action and originate in a nonattainment or maintenance area and occur at the same time and place as the action and are reasonably foreseeable. 4 CFR Indirect emissions means those emissions of a criteria pollutant or its precursors:. That are caused or initiated by the Federal action and originate in the same nonattainment or maintenance area but occur at a different time or place as the action; 2. That are reasonably foreseeable; 3. That the agency can practically control; and 4. For which the agency has continuing program responsibility. For the purposes of this definition, even if a Federal licensing, rulemaking or other approving action is a required initial step for a subsequent activity that causes emissions, such initial steps do not mean that a Federal agency can practically control any resulting emissions (4 CFR 93.52). Total of direct and indirect emissions means the sum of direct and indirect emissions increases and decreases caused by the Federal action; i.e., the net emissions considering all direct and indirect emissions. The portion of emissions which are exempt or presumed to conform under (c), (d), (e), or (f) are not included in the total of direct and indirect emissions. The total of direct and indirect emissions includes emissions of criteria pollutants and emissions of precursors of criteria pollutants (4 CFR 93.52). Direct emissions include construction emissions and indirect emissions include operational emissions from maintenance activities. Maintenance activities are considered exempt under 4 CFR 93.53(c)(2)(iv), and are therefore not included in the total of direct and indirect emissions evaluated in this analysis. from increased visitation by the public as a result of construction of the project cannot be practically controlled by the USACE and are therefore not considered indirect emissions caused by the Federal action. Thus, this analysis is limited to construction emissions. Because all build alternatives would convert the existing LATC site to restored habitat, a functionally equivalent facility is anticipated to be constructed elsewhere in the Los Angeles Basin. from

4 replacement of site functions elsewhere in the basin cannot be practically controlled by the Corps, and the Corps does not have continuing program responsibility; therefore, such emissions are not considered indirect emissions caused by the Federal action in the applicability analysis. Construction of replacement site functions would result in temporary increases in emissions. Operation of replacement site functions may increase localized emissions in and around the replacement site. However, the replacement of the site functions within the Los Angeles Air Basin would not transfer the operational impacts of the site functions to a different air basin. The CEQA lead sponsor will conduct a detailed CEQA analysis in analyzing the replacement of LATC site functions, including air emissions. 2 Applicability An applicability analysis is the process of determining if a Federal action must be supported by a conformity determination (4 CFR 93.52). In this instance, the applicability analysis is applied to Alternative 3v, the National Ecosystem Restoration Plan and Alternative 2, the Recommended Plan. Federal regulation at 4 CFR prescribes rates for criteria pollutants based on area attainment status as presented in Table 2-. Table 2. General Conformity Pollutant Federal Attainment Designation (Tons/Year) Ozone (precursors: VOC or NO x ) a Serious nonattainment 5 Severe nonattainment 25 Extreme nonattainment Other areas outside of an ozone transport region CO, SO 2, and NO 2 All nonattainment and maintenance areas PM Serious nonattainment 7 Moderate nonattainment and maintenance PM 2.5 All nonattainment and maintenance areas Pb (Lead) All nonattainment and maintenance 25 Source: 4 CFR a Ozone precursors (NOx and VOCs): Gasoline and diesel engines do not directly emit ozone. Ozone is a product of NOx and VOCs reacting in the presence of sunlight. Since engines directly emit NOx and VOCs, their values function as surrogates for ozone emissions.

5 The federal action will occur in the South Coast Air Basin (SCAB), which is currently in extreme nonattainment for ozone (precursors: VOC or NOx); nonattainment for PM2.5; maintenance for PM; maintenance for NO2; attainment for SO2; and maintenance for CO; partial nonattainment for lead. Based on the present NAAQS attainment designation for the SCAB, implementation of Alternative 3v or Alternative 2 would conform to the SIP if annual emissions for ozone precursors (VOC or NOx), NO2, PM2.5, PM, CO, and lead remain below the rates listed in Table 2-2. Air Table 2 2. Federal Attainment Designations for the South Coast Air Basin and Applicable SCAB Federal Attainment Designation (Tons/Year) Ozone (precursors: VOC or NO x ) Extreme Nonattainment PM2.5 Nonattainment PM Maintenance NO2 Maintenance CO Attainment/Maintenance SO 2 Attainment Pb (Lead) Nonattainment (Partial) a 25 Source: USEPA, Green Book Nonattainment Areas (Accessed at on March 6, 25) a U.S. EPA designated the Los Angeles County portion of the SCAB (excluding the high desert areas, and San Clemente and Santa Catalina Islands) as nonattainment for the recently revised (28) federal lead standard (.5 μg/m3, rolling 3-month average). South Coast Air Quality Management District, 22 Air Quality Management Plan, p. 2-. Since the project is located within Los Angeles County, lead is Nonattainment for the purpose of this analysis. Air quality analysis methodology and results for Alternative 3v and Alternative 2 are found in Appendix F Methodology and Data Tables. Annual construction emissions for Alternative 3v and Alternative 2 are shown in Tables 3- through 3-2, respectively. Table 3. Alternative 3v Direct Annual (Construction) General Conformity (tons/yr) 27 Emis s ions Emis s ions Ozone (VOC) Ozone (NOX) NO CO PM PM2.5 <

6 Table 3 2. Alternative 2 Direct Annual (Construction) General Conformity (tons/yr) Emis s ions Ozone (VOC) < Ozone (NOX) < NO2 < CO < PM < PM2.5 < Estimates of lead emissions were not calculated for construction and operational phases. Lead emissions from mobile sources in California have significantly decreased due to the near elimination of lead in fuels. Thus, CalEEMod, the South Coast Air Quality Management District-approved emission modeling software, does not provide estimated emissions for lead. Little to no quantifiable and foreseeable lead emissions would be generated by the alternatives. Based on the above, total direct and indirect emissions of ozone precursors (VOC or NOx), NO2, PM2.5, PM, CO, and lead caused by the Federal action do not equal or exceed the emission levels listed in Table Conclusion The applicability analysis shows that direct and indirect emissions for Alternative 3v, the NER Plan, and Alternative 2, the Locally Preferred Plan and Recommended Plan, would not equal or exceed the prescribed emission levels. Neither alternative would cause or contribute to any new violation of a NAAQS, increase the frequency or severity of any existing violation, or delay the timely attainment of any standard, interim emission reduction, or other milestones. Thus, a general conformity determination is not required.

7 Appendix F 2 Air Quality Calculations Methodology and Data Following public review, further analysis was performed that included a more detailed cost analysis using Mii software, real estate cost updates, and further modified contingencies based upon a full cost risk summary analysis. This analysis identified a more cost effective variation on Alternative 3 [referred to throughout the Integrated Feasibility Report (IFR) and Appendices as Alternative 3v ] that is identical to Alternative 3 except for Reach 7, where it includes the reach plan included in Alternative 2 that provides acres of marsh and a connection to the Los Angeles State Historic Park. As described in the IFR, the previously identified NER plan has been modified to include the substitution of the Reach 7 plan on the basis of the analysis referenced above; Alternative 3v is the NER plan. Because the analysis in this Appendix included analysis of all of the components of Alt 3v, no separate or additional analysis is necessary. For the assessment of Alternative 3v for Reaches -6 and 8, see the Alternative 3 analysis included in this Appendix. For the assessment of Alternative 3v for Reach 7, see the Alternative 2 analysis included in this Appendix. Alternative 2 is the Recommended Plan in the IFR. Modeling Software Air pollutant emissions associated with each alternative were estimated using CalEEMod Version software. The air emissions modeling software developed by the Southern California Air Quality Management District (SCAQMD) in collaboration with other air districts in California to estimate criteria air pollutant and greenhouse gas emissions from various land use development projects. The emission modeling software is used by air districts within California. Model Assumptions: The cascade defaults option in CalEEMod was deselected for all data entry and report outputs. Project Characteristics: The project location is within the South Coast Air Basin with the following defaults within CalEEMod: 2.2 m/s wind speed, 3 days precipitation frequency, Climate Zone 9, and urban land use setting. No utility company was selected since construction and operational phases of the project are not expected to utilize electrical power on a long-term basis. Land Use: The land use type is Recreational (user-defined recreational) with acre project area. Construction For construction emissions an equipment inventory was developed for specific tasks required to implement management measures listed in Section of the Integrated Feasibility Report (See Attachment ). Equipment information included off-road and on-road equipment types, quantity of equipment, hours of off-road equipment operation, and on-road transportation distances. For each alternative, a general multi-year construction schedule (Attachment 2) and detailed construction phasing for each management measure (Attachment 9 of the Cost Appendix) were entered into CalEEMod. Each measure entered into CalEEMod was correlated with information from the equipment inventory.

8 Maximum daily and annual emissions were estimated for each construction year for all alternatives. Results were compared to applicable regulatory thresholds in Chapter 5 of the Integrated Feasibility Report. Operational (Maintenance) Maintenance activities would likely entail annual vegetation maintenance activities over a 3 day period. Required equipment would include approximately five medium duty pickup trucks, two backhoes, two loaders, one excavator, two chippers, and two dump trucks. In so far as all build alternatives share many common restoration features, the scope, nature, and duration of maintenance activities are not expected to be notably different. As a result, operational emissions for all build alternatives are not expected to be substantially different. Furthermore, operational emissions are not expected to substantially change from year to year. As a result, maximum daily and annual emissions estimates were limited to one year. Operational (Increased Visitations) An increase of approximately 572 average daily visitors is projected with implementation of any build alternatives (See Recreational Analysis Appendix, Tables 3 and 4). It was not feasible to use CalEEMod to estimate emissions for vehicle trips not associated with recognized land uses and associated square footages. were estimated in Microsoft Excel using SCAQMD emissions factors for passenger vehicles (model years ). Daily and annual CO2e emissions were calculated using U.S. Environmental Protection Agency s CO2e calculator at Lead (Pb) Estimates of lead emissions were not calculated for construction and operational phases. Lead emissions from mobile sources in California have significantly decreased due to the near elimination of lead in fuels. Thus, CalEEMod does not provide estimated emissions for lead. Little to no quantifiable and foreseeable lead emissions would be generated by the alternatives. Greenhouse Gas The SCAQMD adopted a quantitative significance threshold of, metric tons (MT) per year for industrial (stationary source) projects. In the absence of applicable greenhouse gas (GHG) thresholds for ecosystem restoration projects, the, metric ton threshold for GHG is adopted for use in this analysis. GHG emissions are reported as CO2 equivalents (CO2e). All three sources of GHG emissions were included: construction, maintenance, and increased visitation. Maintenance and increased are considered operational emissions. The SCAQMD recommends that the total construction emissions be amortized over the lifetime of the project and then added to annual operational emissions. If the lifetime of a project is not known, then a 3-year lifetime is assumed. Construction related GHG emissions were amortized over a 3 year period by summing the annual GHG emissions over the duration of construction and dividing by 3. The amortized values were added to operational GHG emissions. Unlike construction emissions, operational GHG emissions were assumed to remain the same from year to year. General and Detailed Schedules General schedules for each alternative are found in Attachment 2. Detailed construction schedules for Alternative 2 and were developed (see Attachment 9 of the Cost Appendix). Detailed construction

9 schedules for Alternative 6 and were not. However, Alternative 6 is a truncated variation of Alternative 2. Likewise, Alternative is a truncated variation of Alternative 3. As a result, appropriate construction phases entered into CalEEMod for Alternative 2 were deleted to estimate emissions for Alternative 6. Likewise, appropriate construction phases entered into CalEEMod for Alternative 3 were deleted to estimate emissions for Alternative. Deleted construction phases for Alternative 3 and 6 are shown below: Alternative (model derivations from ALT 3 multi-year schedule):. The construction duration is a -year period between March 6, 27 and December 25, 226. REACH 7 only includes daylighting of 3 storm drains: Removed measure 2 lower channel banks and provide setback levees or berms Removed measure 7 habitat corridors/riparian planting on banks 2. REACH 6 includes primary riparian corridor planting in Taylor Yard and concrete removal on left bank. Removed measure 6 bioengineering channel walls Removed measure 7 habitat corridors/riparian planting on banks 3. REACH 3 only includes modification of storm drain, and riparian planting along Zoo Drive. Removed measure 3/5 create geomorphology and planting Removed measure divert tributary and river flow into side channel Moved mobilization and preparatory work (4 days) from February 224 to February 225. NO construction takes place in 224 Alternative 6 (model derivations from ALT 2 multi-year schedule):. The construction duration is a 5-year period between October 2, 28 and February 6, Removed the following measures from Reach 7: Measure 8 creation of wetland flood control basin (corn field) Measure 27 tributary channels/widen channel (Arroyo Seco) Measure 26 terrace banks 3. Reach 7: Added Measure 2 Lower channel banks and provide setback levees or berms 4. Removed the following measures from Reach 2: Measure 27 modify trapezoidal channel to vertical sides Measure 6 bioengineer channel walls Reduced mobilization/prep from 3 days to 2 days.

10 Attachment : Equipment List Off Road Equipment Loader Grader Roller Loader Dozer Roller Backhoe On Road Trips/Day Mile/Trip QuantityHrs./Day Equipment Aggregate Base & Asphalt 8 Haul: 5-cy trucks crew Backfill & Compacted Fill 2 8 Haul: 8 8 Crew: Chain link Fence 8 Haul: flatbed trucks 6 crew Clearing & Grubbing Rubber-tired dozer 8 Haul: 5-cy trucks 6 3 crew Cofferdam Installation Crane 8 Haul: flatbed trucks 5 Excavator crew Concrete Planters Forklift 8 Haul: flatbed trucks 4 3 Demolition concrete/riprap Excavator 8 Haul: 5-cy trucks 4 3 Rubber-tired loaders 2 8 crew Demolition storm drain excavator 8 Haul: flatbed trucks 2 Erosion Control Backhoe 8 Haul: Crane 8 crew 4 Excavate Embankments Scraper 8 Haul: 5-cy trucks 6 3 Loader 8 Crew Excavate, Grade Control Excavator 8 Haul: 5-cy trucks Grader 8 Crew: 3 Install storm drain Fork lift 8 Haul: concrete truck 72 Impermeable Layer Fork lift 8 Haul: flatbed trucks 25 Crane 8 Crew: 5 Irrigation Ditch Digger 8 Haul Crew: 2 Mobilization Haul: flatbed trucks 3 crew Planting Backhoe 8 Haul: 2 Crew: 3 Restrooms Fork lift 8 Haul: 7 crane 8 Crew: 4 Riprap Placement Loader 8 Haul: 5-cy trucks 6 3 Excavator 8 Crew 5 Sheet Pile & Asphalt Demolition Excavator 8 Haul: 5-cy trucks 4 3 Stone placement & tie-in Excavator 8 Haul: 5-cy trucks 7 Loader 8 Crew: 3 Topsoil Grader 8 Haul: 5 Loader 8 Crew: Dozer 8 Trail, viewpoints, parking lots Roller 8 Haul: 5-cy trucks Grader 8 Crew: 8 dozer 8 Loader 8 Utility Towers Crane 8 Haul: concrete truck 2 Haul: flatbed trucks 2 2 Crew: 6

11 Attachment 2: General Multi-Year Schedule Alternative LERRDS, Plans & Specs, Procurement Actual Construction TOTAL Reach Name #YRS 25 Reach 8 Reach 7 Reach 6 Reach 5 Reach 4 Reach 3 Reach 2 Reach Assumptions:. Prep time (P&S, procurement) is shown immediately preceeding construction Alternative 3 LERRDS, Plans & Specs, Procurement Actual Construction TOTAL Reach Name #YRS 25 Reach 8 Reach 7 Reach 6 Reach 5 Reach 4 Reach 3 Reach 2 Reach

12 Alternative 3V LERRDS, Plans & Specs, Procurement Actual Construction Reach Name TOTAL #YRS Reach 6 4 Reach 5.9 Reach Reach Reach 2 2 Reach 2.4 Reach Reach

13 Alternative 6 LERRDS, Plans & Specs, Procurement Actual Construction TOTAL #YRS Reach 6 5 Reach 5 6 Reach Reach Reach 3 6 Reach 2 2 Reach 2.4 Reach 8 7 Alternative 2 LERRDS, Plans & Specs, Procurement TOTAL #YRS Reach 6 Reach 5 Reach 4 Reach 7 Reach 3 Reach 2 5 Reach Reach 8 Actual Construction

14 Attachment 3: CalEEMod Data Tables (Annual and Daily) for Construction and Maintenance & Calculations for Visitation Table 5 5: Alternative Annual General Conformity (tons/yr) Ozone (VOC).2.2 Ozone (NOX).38.2 NO CO.8.8 PM.7.7 PM CO2e 3 4 Table 5 6: Alternative Daily Regional Sigfinicant Local Significant VOC NOX CO SO2 PM PM2.5 CO2e n/a n/a n/a 4 3 n/a < < < < < < < < < Table 5-7: OPERATIONS ANNUAL: MAINTENANCE AND VISITATIONS COMBINED (ALL ALTERNATIVES) General Conformity (tons/yr) Ozone (VOC) Ozone (NOX) NO2 CO PM PM2.5 CO2e. Maintenance Visitations

15 Table 5-8: OPERATIONS DAILY: MAINTENANCE AND VISITATIONS COMBINED (ALL ALTERNATIVES) Regional Sigfinicant Local Significant Maintenance Visitations VOC 55 n/a NOX CO SO2 5 n/a.3.2 PM PM CO2e n/a n/a Table 5-9: Alt GHG Annual CO2e Sources SCAQMD GHG (MT/yr) Annual (MT/year) Construction n/a 29 Maintenance n/a 48 Visitations n/a 279 Total CO2e, 256 Table 5 : Alternative 3 Annual General Conformity (tons/yr) Ozone (VOC) Ozone (NOX) NO CO PM PM CO2e

16 Table 5 : Alternative 3 Daily Regional Sigfinicant Local Significant VOC 75 n/a NOX CO SO2 5 n/a PM PM CO2e n/a n/a Table 5-2: Alt 3 GHG Annual CO2e Sources SCAQMD GHG (MT/yr) Annual (MT/year) Construction n/a 46 Maintenance n/a 48 Visitations n/a 279 Total CO2e, 273 Table 5 3: Alternative 3 V Annual General Conformity (tons/yr) Ozone (VOC) Ozone (NOX) NO CO PM PM2.5 < CO2e

17 Table 5 4: Alternative 3 V Daily Regional Sigfinicant Local Significant VOC 75 n/a NOX CO SO2 5 n/a PM PM CO2e n/a n/a Table 5-5: Alt 3v GHG Annual CO2e Sources SCAQMD GHG (MT/yr) Annual (MT/year) Construction n/a 4 Maintenance n/a 48 Visitations n/a 279 Total CO2e, 268 Table 5 6: Alternative 6 Annual General Conformity (tons/yr) Ozone (VOC) < Ozone (NOX) < NO2 < CO < PM < PM2.5 < CO2e

18 Table 5 7: Alternative 6 Daily Regional Sigfinicant Local Significant VOC 75 n/a NOX CO SO2 5 n/a < PM PM CO2e n/a n/a Table 5-8: Alt 6 SPL GHG Annual CO2e Sources SCAQMD GHG (MT/yr) Annual (MT/year) Construction n/a 88 Maintenance n/a 48 Visitations n/a 279 Total CO2e, 225 Table 5 9: Alternative 2 Annual General Conformity (tons/yr) Ozone (VOC) < Ozone (NOX) < NO2 < CO < PM < PM2.5 < CO2e

19 Table 5 2: Alternative 2 Daily Regional Sigfinicant Local Significant VOC 75 n/a NOX CO SO2 5 n/a < PM PM CO2e n/a n/a Table 5-2:Alt 2 GHG Annual CO2e Sources SCAQMD GHG (MT/yr) Annual (MT/year) Construction n/a Maintenance n/a 48 Visitations n/a 279 Total CO2e, 2227 MAINTENANCE ANNUAL General Conformity (tons/yr) ROG.3 NOX.4 CO.28 PM.2 PM2.5.2 CO2e

20 MAINTENANCE DAILY Regional Local Sigfinicant Significant VOC 55 n/a 2.4 NOX CO SO2 5 n/a.3 PM PM CO2e n/a n/a 3563 DAILY VISITATION factors average miles per car number of cars per day pounds per day Metric tons per year CO2e Daily CO2e Annual CO NOx ROG SOx PM PM CO CH CO2e 2, metric tons per year = lbs/day * 36 days * metric tons/lb Annual CO2e calculated with EPA CO2e calculator at gasses used are CO2 (275 metric tons) and CH4 (.65 metric tons) emissions factors from SCAQMD on-road factors for passenger vehicles; all model years from Daily CO2e = (27+.42) = 272 lbs per EPA CO2e calculator