Air Quality Analysis & Greenhouse Gas Emissions Assessment. Air Quality Analysis. Rob Wood Coburn Crossing

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1 140 Litton Drive Suite 240 Grass Valley, CA Tel: Fax: WEBSITE: Truckee: TO: Travis Coggin, Triumph Development DATE: 7/13/16 FROM: PROJECT: SUBJECT: Rob Wood Coburn Crossing Air Quality Analysis & Greenhouse Gas Emissions Assessment This Air Quality Analysis & Greenhouse Gas Emissions (GHG) Assessment is associated with the development of Coburn Crossing project in Truckee. The project proposes development of a 3-story, 75,500 square foot Marriot Springhill Suites hotel consisting of 128 units and five apartment buildings consisting of 138 units. The property located adjacent to Interstate 80 and near downtown Truckee is approximately acres and is currently undeveloped. Air Quality Analysis Northern Sierra Air Quality Management District The Town of Truckee is located within the Mountain Counties Air Basin. The N o rthern Sierra Air Quality Management District (NSAQMD) is the local agency for air quality planning with authority over air pollutant sources within Nevada County, including the Truckee area. Responsibilities of the NSAQMD include, but are not limited to, preparing plans for the attainment of ambient air quality standards, adopting and enforcing rules and regulations concerning sources of air pollution, issuing permits for stationary sources of air pollution, inspecting stationary sources of air pollution, responding to citizen complaints, monitoring ambient air quality and meteorological conditions, and implementing programs and regulations required by the federal Clean Air Act and the Clean Air Act Amendments. Air Pollutants of Concern The air pollutants emitted into the ambient air by stationary and mobile sources are regulated by federal and state law. These regulated air pollutants are known as criteria air pollutants and are categorized into primary and secondary pollutants. Primary air pollutants are those that are emitted directly from sources. Carbon monoxide (CO), reactive organic gases (ROG), nitrogen oxides (NOX), sulfur dioxide (SO2), most particulate matter ( and ), lead, and fugitive dust are primary air pollutants. Of these, CO, SO2,, and are criteria pollutants. ROG and NOX are criteria pollutant precursors and go on to form secondary criteria pollutants through chemical and photochemical reactions in the atmosphere. Ozone (O3) and nitrogen dioxide (NO2) Page 1 of 13

2 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment are the principal secondary criteria pollutants. Presented below is a description of the more significant primary and secondary criteria air pollutants and their known health effects. Page 2 of 13 Carbon monoxide (CO) is a colorless, odorless, toxic gas produced by incomplete combustion of carbon substances, such as gasoline or diesel fuel. The primary adverse health effect associated with CO is interference with normal oxygen transfer to the blood, which may result in tissue oxygen deprivation. Reactive organic gases (ROG) are compounds comprising primarily atoms of hydrogen and carbon. Internal combustion associated with motor vehicle usage is the major source of hydrocarbons. Other sources of ROG include evaporative emissions associated with the use of paints and solvents, the application of asphalt paving, and the use of household consumer products such as aerosols. Adverse effects on human health are not caused directly by ROG, but rather by reactions of ROG to form secondary pollutants such as ozone. Nitrogen oxides (NO X ) serve as integral participants in the process of photochemical smog production. The two major forms of NOX are nitric oxide (NO) and nitrogen dioxide (NO2). NO is a colorless, odorless gas formed from atmospheric nitrogen and oxygen when combustion takes place under high temperature and/or high pressure. NO2 is a reddish-brown irritating gas formed by the combination of NO and oxygen, a byproduct of fuel combustion. NO2 also contributes to the formation of (particulates having an aerodynamic diameter of 10 microns or 0.0 inch or less in diameter) and ozone. NOX acts as an acute respiratory irritant and increases susceptibility to respiratory pathogens. Sulfur dioxide (SO 2 ) is a colorless, pungent, irritating gas formed by the combustion of sulfurous fossil fuels. Fuel combustion is the primary source of SO2. A primary source of SO2 emissions is high sulfur content coal. Gasoline and natural gas have very low sulfur content and hence do not release significant quantities of SO2. Particulate matter (PM) consists of solid and liquid particles of dust, soot, aerosols, and other matter, which are small enough to remain suspended in the air for a long period of time. Particulate matter can be divided into several size fractions. Coarse particles () are between 2.5 and 10 microns in diameter and arise primarily from natural processes, such as wind-blown dust or soil. Fine particles () are less than 2.5 microns in diameter and are produced mostly from combustion or burning activities. Fuel burned in cars and trucks, power plants, factories, fireplaces, and wood stoves produces fine particles. The level of in the air is a public health concern because it can bypass the S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

3 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment body s natural filtration system more easily than larger particles and can lodge deep in the lungs. A portion of the particulate matter in the air is due to natural sources such as wind-blown dust and pollen, which are associated with the aggravation of respiratory conditions. Man-made sources include combustion, automobiles, field burning, factories, and road dust. Primary sources of emissions are road traffic, construction, open burning, and wildfires. The amount of particulate matter and generated is dependent on the soil type and the soil moisture content. Traffic also generates particulate matter emissions through entrainment of dust and dirt particles that settle onto roadways and parking lots. Methodology & Project Assumptions CalEEMod is a statewide land use emissions computer model accepted by the air districts of California to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects. The model quantifies direct emissions from construction and operations (including vehicle and off-road equipment use), as well as indirect emissions, such as GHG emissions from energy use, solid waste disposal, vegetation planting and/or removal, and water use. Construction emissions are typically short-term impacts from construction activities. Operational emissions are considered long-term based on day to day operations. The mobile source emission factors used in the model (EMFAC2011) includes the Pavley standards and Low Carbon Fuel standards. The model also identifies mitigation measures to reduce criteria pollutant and GHG emissions along with calculating the benefits achieved from measures chosen by the user. The GHG mitigation measures were developed and adopted by the California Air Pollution Control Officers Association (CAPCOA). For purposes of this assessment, CalEEMod was used to quantify emissions and identify mitigation measures to reduce pollutants. The following assumptions were used in the air quality analysis: 3-story, 75,500 square foot hotel; Hotel parking of 132 spaces; 138 apartment units (includes associated parking). Page 3 of 13 S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

4 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment Thresholds NSAQMD has developed thresholds of significance to determine air quality impacts associated with land use development proposals. Thresholds of significance are based on a source s projected impacts and are a basis from which to apply mitigation measures (NSAQMD 2009). NSAQMD has developed a tiered approach to significance levels: a project with daily emissions meeting Level A thresholds will require the most basic mitigations; projects with daily emissions in the Level B range will require more extensive mitigations; and those projects which exceed Level C thresholds will require the most extensive mitigations. The NSAQMDrecommended thresholds are identified below: NSAQMD-RECOMMENDED SIGNIFICANCE THRESHOLDS Significance Level Project-Generated Emissions (lbs/day) NO x ROG PM 10 Level A < 24 < 24 < 79 Level B Level C > 137 > 137 > 137 Source: NSAQMD 2009 Air Quality Results Based on the results of the Air Quality Analysis using CalEEMod computer model (shown below), the unmitigated projected daily emissions is within Level A & B threshold ranges. MAXIMUM UNMITIGATED DAILY EMISSION (LBS/DAY) Category NO x ROG PM 10 Construction Construction Operational - Area Operational - Energy Operational - Mobile Operational - TOTAL Page 4 of 13 S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

5 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment During construction, the maximum daily emission for NOx is anticipated to be approximately 53.5 lbs/day, occurring in A daily emission of lbs/day is within the Level B threshold. The maximum daily emission for ROG is anticipated to be approximately 28.4 lbs/day, occurring in 2017 which is also within the Level B threshold. reaches a maximum daily emission of approximately 21.0 lbs/day in 2017, within the Level A threshold range. Following construction, the maximum unmitigated daily emissions of NOx, ROG, and fall roughly within the same threshold ranges as during construction (threshold levels A & B). While these ranges are not considered significant under CEQA guidelines, NSAQMD recommends the following mitigation measures for projects within Levels A & B thresholds to further reduce daily emissions: Mitigation Measures Air Quality The Project should incorporate the following mitigation measures during the construction phase, as recommended by NSAQMD for emissions within the Level B Threshold range: 1. Open burning of vegetative material is prohibited. Suitable alternatives are hauling, chipping, mulching, or conversion to biomass fuel. 2. Grid power shall be used (as opposed to diesel generators) for job site power needs where feasible during construction. 3. Temporary traffic control shall be provided during all phases of construction to improve traffic flow as deemed appropriate by local transportation agencies. 4. Wood burning appliances shall be prohibited. Each residence shall be equipped with a non-wood burning source of heat. 5. Streets shall be designed to maximize pedestrian access to transit stops. 6. Prepare a Dust Control Plan in compliance with District / State Rules & Regulations as follows: Recommended Dust Control Plan Conditions a) The applicant shall be responsible for ensuring that all adequate dust control measures are implemented in a timely manner during all phases of project development and construction. b) All material excavated, stockpiled, or graded shall be sufficiently watered, treated, or covered to prevent fugitive dust from leaving the property boundaries and Page 5 of 13 S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

6 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment causing a public nuisance or a violation of an ambient air standard. Watering should occur at least twice daily, with complete site coverage. c) All areas with vehicle traffic shall be watered or have dust palliative applied as necessary for regular stabilization of dust emissions. d) All on-site vehicle traffic shall be limited to a speed of 15 mph on unpaved roads. e) All land clearing, grading, earth moving, or excavation activities on a project shall be suspended as necessary to prevent excessive windblown dust when winds are expected to exceed 20 mph. f) All inactive portions of the development site shall be covered, seeded, or watered until a suitable cover is established. Alternatively, the applicant may apply Countyapproved nontoxic soil stabilizers to all inactive construction areas (previously graded areas which remain inactive for 96 hours) in accordance with the local grading ordinance. g) All material transported off-site shall be either sufficiently watered or securely covered to prevent public nuisance, and there must be a minimum of six (6) inches of freeboard in the bed of the transport vehicle. h) Paved streets adjacent to the project shall be swept or washed at the end of each day, or more frequently if necessary, to remove excessive or visibly raised accumulations of dirt and/or mud which may have resulted from activities at the project site. i) Prior to final occupancy, the applicant shall re-establish ground cover on the site through seeding and watering in accordance with the local grading ordinance. CEQA Compliance The impact analysis provided is based on the application of the following State CEQA Guidelines Appendix G thresholds of significance, which indicate that a project would have a significant impact if it would: 1. Conflict with or obstruct implementation of any applicable air quality plan. By assessing air pollution and emissions associated with this Project and recommending mitigation measures based on Thresholds of Significance established by NSAQMD, the Project complies with both NSAQMD regulations and the Particulate Matter Air Quality Management Plan adopted by the Town of Truckee in July, Therefore, this impact is considered less than significant. Page 6 of 13 S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

7 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment 2. Violate any air quality standard or contribute substantially to an existing or projected air quality violation. The accepted software program to determine air quality impacts (CalEEMod Version ) was used to estimate overall emissions for both construction and operational phases associated with this Project. A detailed report of the results is contained herein. Based on the results of the analysis and incorporation of recommended mitigation measures, the Project does not violate any air quality standard nor does the Project contribute substantially to an air quality violation. Therefore, this impact is considered less than significant. 3. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). CEQA defines cumulative impacts as two or more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. The proposed project will not result in a significant increase in particulate matter or other ozone precursors (above the Level A threshold established by NSAQMD). Additionally, incorporation of the recommended Mitigation Measures will ensure than any increase to criteria pollutants are minimal. Therefore, this impact is considered less than significant. 4. Expose sensitive receptors to substantial pollutant concentrations. Sensitive receptors are people that have an increased sensitivity to air pollution or environmental contaminants. Sensitive receptor locations include schools, parks and playgrounds, daycare centers, nursing homes, hospitals, and residential dwelling unit(s). Based on CalEEMod Air Quality Analysis, air pollutants associated with this project are not considered substantial or significant under CEQA; therefore this impact is considered less than significant. 5. Create objectionable odors affecting a substantial number of people. The occurrence and severity of odor impacts depends on numerous factors, including the nature, frequency, and intensity of the source, wind speed and direction, and the sensitivity of the receptors. Land uses commonly considered to be potential sources of odorous emissions include wastewater treatment plants, sanitary landfills, food Page 7 of 13 S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

8 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment processing facilities, chemical manufacturing plants, rendering plants, paint/coating operations, and agricultural feedlots and dairies. This project does not propose any uses typical of creating objectionable odors; therefore there is no impact. Greenhouse Gas Assessment Northern Sierra Air Quality Management District The Northern Sierra Air Quality Management District (NSAQMD) is the local agency for air quality planning with authority over air pollutant sources within Nevada County. The NSAQMD has not yet established significance thresholds for greenhouse gas emissions from project operations. Primary Greenhouse Gasses (GHG s) The primary greenhouse gases in the Earth's atmosphere are water vapor, carbon dioxide, methane, nitrous oxide, and ozone. These various gases in the earth s atmosphere, classified as atmospheric greenhouse gases (GHGs), play a critical role in determining the earth s surface temperature. For most nonindustrial development projects, motor vehicles make up the bulk of GHG emissions. The primary greenhouse gases emitted by motor vehicles include carbon dioxide, methane, nitrous oxide, and hydrofluorocarbons (CARB 2). Carbon dioxide (CO 2 ) is a colorless, odorless gas. CO2 is emitted in a number of ways, both naturally and through human activities. The largest source of CO2 emissions globally is the combustion of fossil fuels such as coal, oil, and gas in power plants, automobiles, industrial facilities, and other sources. A number of specialized industrial production processes and product uses such as mineral production, metal production, and the use of petroleum-based products can also lead to CO2 emissions. The atmospheric lifetime of CO2 is variable because it is so readily exchanged in the atmosphere (USEPA 2011a). Methane (CH 4 ) is a colorless, odorless gas that is not flammable under most circumstances. CH4 is the major component of natural gas, about 87 percent by volume. It is also formed and released to the atmosphere by biological processes occurring in anaerobic environments. Methane is emitted from a variety of both human-related and natural sources. Human-related sources include fossil fuel production, animal husbandry (intestinal fermentation in livestock and manure management), rice cultivation, biomass Page 8 of 13 S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

9 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment Page 9 of 13 burning, and waste management. These activities release significant quantities of methane to the atmosphere. Natural sources of methane include wetlands, gas hydrates, permafrost, termites, oceans, freshwater bodies, on wetland soils, and other sources such as wildfires. Methane s atmospheric lifetime is about 12 years (USEPA 2011b). Nitrous oxide (N 2 O) is a clear, colorless gas with a slightly sweet odor. N2O is produced by both natural and human-related sources. Primary human-related sources of N2O are agricultural soil management, animal manure management, sewage treatment, mobile and stationary combustion of fossil fuels, and nitric acid production. N2O is also produced naturally from a wide variety of biological sources in soil and water, particularly microbial action in wet tropical forests. The atmospheric lifetime of N2O is approximately 120 years (USEPA 2010a). Hydrofluorocarbons (HFCs) are man-made chemicals, many of which have been developed as alternatives to ozone-depleting substances for industrial, commercial, and consumer products. The only significant emissions of HFCs before 1990 were of the chemical HFC-23, which is generated as a byproduct of the production of HCFC-22 (or Freon 22, used in air conditioning applications). The atmospheric lifetime for HFCs varies from just over a year for HFC-152a to 260 years for HFC-23. Most of the commercially used HFCs have atmospheric lifetimes less than 15 years (e.g., HFC-134a, which is used in automobile air conditioning and refrigeration, has an atmospheric life of 14 years) (USEPA 2010b). Perfluorocarbons (PFCs) are colorless, highly dense, chemically inert, and nontoxic. Natural geological emissions have been responsible for the PFCs that have accumulated in the atmosphere in the past; however, the largest current source is aluminum production, which releases CF4 and C2F6 as byproducts. The estimated atmospheric lifetimes for CF4 and C2F6 are 50,000 and 10,000 years, respectively (EFCTC 2; USEPA 2010b). Sulfur hexafluoride (SF 6 ) is an inorganic compound that is colorless, odorless, nontoxic, and generally nonflammable. SF6 is primarily used as an electrical insulator in high voltage equipment. The electric power industry uses roughly 80 percent of all SF6 produced worldwide. SF6 has an atmospheric life of 3,200 years (USEPA 2010b). Each GHG differs in its ability to absorb heat in the atmosphere based on the lifetime, or persistence, of the gas molecule in the atmosphere. Gases with high global warming potential, such as HFCs, PFCs, and SF6, are the most heat-absorbent. Methane traps over 21 times more heat per molecule than CO2, and N2O absorbs 310 times more heat per S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

10 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment molecule than CO2. Often, estimates of GHG emissions are presented in carbon dioxide equivalents (CO2e), which weight each gas by its global warming potential. Expressing GHG emissions in carbon dioxide equivalents takes the contribution of all GHG emissions to the greenhouse effect and converts them to a single unit equivalent to the effect that would occur if only CO2 were being emitted. California Building Energy Efficiency Standards Title 24, Part 6 of the California Code of Regulations, known as the Building Energy Efficiency Standards, was established in 1978 in response to a legislative mandate to reduce California s energy consumption. The standards are updated periodically to allow consideration and possible incorporation of new energy efficiency technologies and methods. On January 1, 2010, the California Building Standards Commission adopted CALGreen and became the first state in the United States to adopt a statewide green building standards code. CALGreen is a stringent building code that was established for the purpose of reducing greenhouse gas emissions to pre levels and lowering energy, water consumption and construction waste in efforts to protect California s fragile environment. Thresholds of Significance To meet GHG emission targets of AB 32, California would need to generate less GHG emissions in the future than current levels. It is recognized, however, that for most projects there is no simple metric available to determine if a single project would substantially decrease overall GHG emission levels or conflict with the goals of AB 32. Thresholds of significance illustrate the extent of an impact and are a basis from which to apply mitigation measures. Significance thresholds for greenhouse gas emissions resulting from land use development projects have not been established in Nevada County (as previously mentioned, the NSAQMD has not yet established significance thresholds for greenhouse gas emissions from project operations). However, new structures proposed as part of this Project are required to meet current CALGreen Building Codes. This requirement helps to ensure operational GHG emissions over the long term will not conflict with the goals of AB 32. Calculations of GHG emissions typically focus on CO2 because it is the most commonly produced GHG in terms of number of sources and volume generated, and because it is among the easiest GHGs to measure. This analysis also assesses N2O and CH4 emissions for other primary source categories of emissions (e.g., motor vehicles and energy use associated with long-term Page 10 of 13 S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

11 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment operation of the project). All GHG s are factored in and reported as carbon dioxide equivalents (CO2e). In order to obtain the CO2e, each individual GHG is multiplied by its global warming potential. Methodology & GHG Results CalEEMod was utilized to estimate the proposed project s CO2, N2O and CH4 annual emissions (unmitigated) from construction and operational operations. As described above, overall estimates of GHG emissions are presented in carbon dioxide equivalents (CO2e) in metric tons per year. The CO2e for a project s Overall Operational is based on the cumulative total of 5 categories: Area, Energy, Mobile, Waste, and Water. Construction and Operational emissions related to project implementation are detailed in the CalEEMod report and summarized below: MAXIMUM GHG EMISSIONS (MT/YR) CO 2 e (Unmitigated) CO 2 e (Mitigated) Overall Construction Overall Construction Overall Operational 2,731 2,018 GHG Emissions - Construction The proposed project would result in approximately 545 metric tons of direct emissions of GHGs during construction, occurring in GHG emissions as a result of construction are anticipated to drop to approximately 286 metric tons during Construction of the project is anticipated to occur over a 2-year period so there are no anticipated GHG emissions resulting from construction after GHG Emissions - Operational The largest contributor of GHG emissions during day to day operations are passenger vehicles. In fact, the consumption of fuel (or mobile emissions ) accounts for more than 79% of the entire operational emissions associated with this project. The project design incorporates several elements to significantly reduce the mobile GHG emissions including but not limited to: Page 11 of 13 S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

12 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment intersection improvements (roundabout), construction of a transit stop, construction of on- and off-site trails, higher density housing, bicycle parking, etc. These design elements combined with mitigation measures reduce the unmitigated mobile CO2e by at least 30% and the overall operational emissions are reduced by at least 26% (see CalEEMod Annual results). In response to AB 32 (Global Warming Solutions Act of 2006), changes to State regulations will continue to take effect in the near future to substantially reduce GHG emissions related to automobiles. CARB s Post-Processor tool estimates at least an 18 percent reduction in GHGs generated by automobiles by Compliance with CalGreen standards further reduce GHG emissions associated with internal combustion engines through new requirements to provide electric vehicle charging stations and parking spaces designated for electric vehicles only. Emissions have also been effectively mitigated at the refiner/importer level through AB 32 s Cap & Trade Program. Since high GHG emissions primarily involve the consumption of fuel, the Cap & Trade Program was recently expanded to cover those fuels. Since the beginning of 2015, fuel producers and importers are required to obtain allowances or offsets for the GHG emissions produced from the consumption of their fuel. In terms of energy, all new buildings associated with this project will be constructed to meet the California Building Energy Efficiency Standards, which went into effect July 1, Electricity use in new residential construction is reduced by 36.4 percent compared to the 2008 Standards, peak demand is reduced by 40.4 percent, and gas is reduced by 6.5 percent. These percentage savings are relative to heating, cooling, lighting and water heating only and do not include other appliances, outdoor lighting that is not attached to buildings, plug loads, or other energy uses. CEQA Compliance Per Appendix G of the State CEQA Guidelines, impacts related to climate change are significant if implementation of the proposed project would result in any of the following: 1. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment. The Project is not anticipated to result in a significant impact on the environment. Based on the size and scope of the project, adherence to current building codes, project design and implementation of mitigation measures, the Project significantly reduces GHG emissions from unmitigated levels (more than 26% reduction). Page 12 of 13 S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

13 MEMORANDUM (continued) Date: July 13, 2016 To: Triumph Development Re: Coburn Crossing Air Quality Analysis & GHG Assessment 2. Conflict with any applicable plan, policy, or regulation of an agency adopted for the purpose of reducing the emissions of greenhouse gases. All construction related to this project is required to meet current Building Codes which are intended to substantially reduce GHG emissions. The Project does not conflict with any applicable plans, policies or regulations intended to reduce GHG emissions. Page 13 of 13 S:\~ JOBS\ TRUCKEE MARRIOTTS\ADMIN\REPORTS\AIR QUALITY & GHG\AIR QUALITY & GREENHOUSE GAS ASSESSMENT-DRAFT.DOCX

14 Page 1 of 30 Date: 7/13/2016 2:28 PM 1.0 Project Characteristics 1.1 Land Usage Truckee Marriott Northern Sierra AQMD Air District, Winter Land Uses Size Metric Lot Acreage Floor Surface Area Population Parking Lot Space , Hotel Room , Apartments Mid Rise Dwelling Unit , Other Project Characteristics Urbanization Urban Wind Speed (m/s) 2.2 Precipitation Freq (Days) 72 Climate Zone 1 Operational Year 2018 Utility Company Pacific Gas & Electric Company CO2 Intensity (lb/mwhr) CH4 Intensity (lb/mwhr) N2O Intensity (lb/mwhr) User Entered Comments & Non-Default Data

15 Page 2 of 30 Date: 7/13/2016 2:28 PM Project Characteristics - TDPUD has indicated that PG&E has similar Intensity Factors. Land Use - 1. Lot acreage of the hotel = footprint. 2. Hotel square footage based on gross area of building. 3. Residential square footage based on gross area of all apartment buildings. 4. Population based on 2.51 persons/unit per 2014 Truckee census. 5. Parking count based on hotel parking ONLY. Parking for residential is included in Lot Acreage. Construction Phase - Construction, Paving & Architectural Coating anticipated to occur concurrently. Grading - Road Dust - 100% of roads on-site will be paved as part of this project. Woodstoves - 1. Assume no woodstoves or fireplaces. Landscape Equipment - # of snow days derived from Truckee weather information. Energy Use - Sequestration - Land Use Change - Construction Off-road Equipment Mitigation - Mobile Land Use Mitigation - Area Mitigation - Water Mitigation - Energy Mitigation - Waste Mitigation -

16 Page 3 of 30 Date: 7/13/2016 2:28 PM Table Name Column Name Default Value New Value tblconstructionphase NumDays tblconstructionphase NumDays tblconstructionphase PhaseEndDate 3/15/2019 4/27/2018 tblconstructionphase PhaseEndDate 3/15/2019 4/27/2018 tblconstructionphase PhaseStartDate 4/28/2018 6/12/2017 tblconstructionphase PhaseStartDate 6/10/2017 6/12/2017 tblconstructionphase PhaseStartDate 5/13/2017 5/15/2017 tblconstructionphase PhaseStartDate 4/28/2018 6/12/2017 tblfireplaces NumberGas tblfireplaces NumberNoFireplace tblfireplaces NumberWood tbllandscapeequipment NumberSnowDays 0 42 tbllanduse LandUseSquareFeet 185, , tbllanduse LandUseSquareFeet 138, , tbllanduse LotAcreage tbllanduse Population tblprojectcharacteristics OperationalYear tblwoodstoves NumberCatalytic tblwoodstoves NumberNoncatalytic Emissions Summary

17 Page 4 of 30 Date: 7/13/2016 2:28 PM 2.1 Overall Construction (Maximum Daily Emission) Unmitigated Construction ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Year lb/day lb/day , , , , , , , , , Mitigated Construction ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Year lb/day lb/day , , , , , , , , , ROG NOx CO SO2 Bio- CO2 NBio-CO2 CO2 CH4 N20 CO2e Percent Reduction

18 Page 5 of 30 Date: 7/13/2016 2:28 PM 2.2 Overall Operational Unmitigated Operational ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Area e- Energy e Mobile , , , , , , Mitigated Operational ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Area e- Energy e Mobile , , , , , ,

19 Page 6 of 30 Date: 7/13/2016 2:28 PM ROG NOx CO SO2 Bio- CO2 NBio-CO2 CO2 CH4 N20 CO2e Percent Reduction Construction Detail Construction Phase Phase Number Phase Name Phase Type Start Date End Date Num Days Week Num Days Phase Description 1 Site Preparation Site Preparation 5/1/2017 5/12/ Grading Grading 5/15/2017 6/9/ Building Construction Building Construction 6/12/2017 4/27/ Paving Paving 6/12/2017 4/27/ Architectural Coating Architectural Coating 6/12/2017 4/27/ Acres of Grading (Site Preparation Phase): 0 Acres of Grading (Grading Phase): 10 Acres of Paving: 0 Residential Indoor: 201,103; Residential Outdoor: 67,034; Non-Residential Indoor: 115,626; Non-Residential Outdoor: 38,542 (Architectural Coating sqft) OffRoad Equipment

20 Page 7 of 30 Date: 7/13/2016 2:28 PM Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Site Preparation Rubber Tired Dozers Site Preparation Tractors/Loaders/Backhoes Grading Excavators Grading Graders Grading Rubber Tired Dozers Grading Tractors/Loaders/Backhoes Building Construction Cranes Building Construction Forklifts Building Construction Generator Sets Building Construction Tractors/Loaders/Backhoes Building Construction Welders Paving Pavers Paving Paving Equipment Paving Rollers Architectural Coating Air Compressors Trips and VMT Phase Name Offroad Equipment Count Worker Trip Number Vendor Trip Number Hauling Trip Number Worker Trip Length Vendor Trip Length Hauling Trip Length Worker Vehicle Class Vendor Vehicle Class Hauling Vehicle Class Site Preparation LD_Mix HDT_Mix HHDT Grading LD_Mix HDT_Mix HHDT Building Construction LD_Mix HDT_Mix HHDT Paving LD_Mix HDT_Mix HHDT Architectural Coating LD_Mix HDT_Mix HHDT 3.1 Mitigation Measures Construction

21 Page 8 of 30 Date: 7/13/2016 2:28 PM Water Exposed Area Clean Paved Roads 3.2 Site Preparation Unmitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Dust Off-Road , , , , , , Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor Worker e e e e e e e e

22 Page 9 of 30 Date: 7/13/2016 2:28 PM 3.2 Site Preparation Mitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Dust Off-Road , , , , , , Mitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor Worker e e e e e e e e

23 Page 10 of 30 Date: 7/13/2016 2:28 PM 3.3 Grading Unmitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Dust Off-Road , , , , , , Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor Worker e e e e e e e e

24 Page 11 of 30 Date: 7/13/2016 2:28 PM 3.3 Grading Mitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Dust Off-Road , , , , , , Mitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor Worker e e e e e e e e

25 Page 12 of 30 Date: 7/13/2016 2:28 PM 3.4 Building Construction Unmitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Off-Road , , , , , , Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor e e Worker , , , , , ,

26 Page 13 of 30 Date: 7/13/2016 2:28 PM 3.4 Building Construction Mitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Off-Road , , , , , , Mitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor e e Worker , , , , , ,

27 Page 14 of 30 Date: 7/13/2016 2:28 PM 3.4 Building Construction Unmitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Off-Road , , , , , , Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor e e Worker e , , , , , ,

28 Page 15 of 30 Date: 7/13/2016 2:28 PM 3.4 Building Construction Mitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Off-Road , , , , , , Mitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor e e Worker e , , , , , ,

29 Page 16 of 30 Date: 7/13/2016 2:28 PM 3.5 Paving Unmitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Off-Road , , , Paving , , , Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor Worker e e e e e e e e

30 Page 17 of 30 Date: 7/13/2016 2:28 PM 3.5 Paving Mitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Off-Road , , , Paving , , , Mitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor Worker e e e e e e e e

31 Page 18 of 30 Date: 7/13/2016 2:28 PM 3.5 Paving Unmitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Off-Road , , , Paving , , , Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor Worker e e e e e e e e

32 Page 19 of 30 Date: 7/13/2016 2:28 PM 3.5 Paving Mitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Off-Road , , , Paving , , , Mitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor Worker e e e e e e e e

33 Page 20 of 30 Date: 7/13/2016 2:28 PM 3.6 Architectural Coating Unmitigated Construction On-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Archit. Coating Off-Road e e Unmitigated Construction Off-Site ROG NOx CO SO2 Bio- CO2 NBio- CO2 CO2 CH4 N2O CO2e Hauling Vendor Worker e e e e e e