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HomeMy Public PortalAboutCanyon Springs EIR Scoping - 12.pdf200 Litton Drive, Suite 320 13450 Donner Pass Rd., Ste. B, Truckee, CA 96161 270 County Hospital Road, Suite 127 P.O. Box 2509 Mailing Address: P.O. Box 9766, Truckee, CA 96162 P.O. Box 3981, Quincy, CA 95971 Grass Valley, CA 95945 (530) 550 -7872 / FAX: (530) 587 -2623 (530) 2834654 / FAX: (530) 283 -0699 (530) 274 -9360 / FAX: (530) 274 -7546 email: ryan @myairdistrict.com email: george @myairdistrict.com email: office @myairdistrict.com or . myairdistrict.com May 12, 2011 Town of Truckee Community Development Attn: Denyelle Nishimori, Associate Planner 10183 Truckee Airport Road Truckee, California 96161 Received By Planning Dhdaian MAY 17 2011 Re: Notice of Preparation of the Draft Environmental Impact Report. Canyon Springs Subdivision (Application No. 10- 106 /TM) Dear Denyelle Nishimori: The Northern Sierra Air Quality Management District (District) has reviewed the notice for the referenced project and would like to submit the following commenting agency comments for the official record. In order for the District to comment accurately on this project, the District recommends an Air Quality Analysis be prepared. Emissions must be compared to our Emission Thresholds of Significance to determine the impact this project will have on air quality within the Town of Truckee. Please Note: During construction the following actions may require permits from the District: Any person building, altering, replacing, or operating any source of air contaminants during construction, whether portable or stationary, shall first obtain an Authority to Construct from the Air Pollution Control Officer, unless the District has determined that such equipment is exempt from permitting or unless such equipment is currently registered with the California Air Resources Board under the Portable Equipment Registration Program. The applicant shall be responsible for contacting the District regarding the possible need for permitting. Examples of equipment for which an air pollution permit may be required include, but are not limited to: A. Portable or stationary equipment units including confined and unconfined abrasive blasting, Portland concrete batch plants, sand and gravel screening, rock crushing, and unheated pavement recycling and crushing operations. B. Engines used in conjunction with the aforementioned equipment and the following types of portable operations: well drilling, service or work -over rigs; pumps; compressors; diesel pile- driving hammers; welding equipment; cranes; woodchippers; dredges; equipment necessary for the operation of portable engines and equipment units; and power generation. The operator shall submit an application for Authority to Construct for any source of air contaminants that exists after construction that is not exempt from permit requirements SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA -I - (for example, a gas station). Such requirements do not apply to motor vehicles or self - propelled construction equipment. The applicant should consult the District to determine what other equipment is exempt. Emission Thresholds of Significance This project's emissions and impacts should be reviewed by the District to assure both short- and long -term air pollution emissions are mitigated to below the level of significant air quality impacts. Thresholds of significance illustrate the extent of a sources' impacts and are a basis from which to apply mitigation measures. The District has developed a tiered approach to significance levels; a project with emissions qualifying it for Level A thresholds will require the most basic mitigations. Projects which qualify for Level B will require a more extensive mitigations, and subsequently, those projects which qualify for Level C will require the most extensive application of mitigations. The tiered thresholds for Level A, B and C are given below for a projects' estimated emissions of criteria pollutants in lbs /day. Level A Thresholds NOX ROG PMIO < 24 lbs /day < 24 Ibs /day < 79 lbs /day Level B Thresholds NOX ROG PMIO 25- 136lbs /day 25- 136lbs /day 80- 1361bs /day Level C Thresholds NOX ROG PM10 >137 lbs /day >137 lbs /day >137 lbs /day NOx, ROG and PM 10 emissions must be mitigated to a level below significant. If emissions for NOx, ROG and PMIO exceeds 136 pounds per day (Level C), then there is a significant impact; below Level C would be potentially significant. The Town of Truckee's Air Quality Management Plan calls for "no net increase of PMIO or PM2.5." Therefore, particulate matter emissions should be mitigated 100 %. SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA -2- District Recommendations 1. A detailed air quality analysis of potential emissions (in pounds per day) from this project using a reasonable worst case scenario needs to be included in the EIR. A listing should be provided of the emissions increases anticipated from the project for the various categories of emissions sources by phases or project. A comparison should be made of the total emissions increases for PM 10, reactive organic gases, nitrogen oxides and carbon monoxide to thresholds of significance. The analysis should also include an estimate of greenhouse gas emissions during construction and long - term. Pursuant to provisions and precedents stemming from AB32, greenhouse gas emissions should be quantified for decision- makers and the public to consider. It is important that both short term and long term emission impacts are identified. The impacts of hazardous air pollutants (diesel, asbestos) should be evaluated, as well as an analysis of cumulative air quality impacts. During the construction phase, there are many short -term air quality impacts from construction vehicles and earth moving. Emissions estimates in pounds per day should be provided for the following sources of pollution: A. Tailpipe emissions of particulate, carbon monoxide and nitrous oxide from diesel powered earth moving equipment. B. Particulate emissions from vehicular traffic on unpaved roads. C. Particulate emissions from soil disturbance. This estimate should be based upon how many acres are disturbed by earth moving equipment. Long -term or mobile source emissions should be estimated using the latest CAPCOA/ARB- approved version of URBEMIS or CalEEMod computer models. Emissions estimates should be provided in pounds per day and tons per year. If the traffic study for this project identifies any intersection(s) that would fall below a Level of Service D under this project alone or cumulative development scenarios, a detailed Caline 4 carbon monoxide analysis should be prepared. The traffic study should evaluate project alone and cumulative Level of Service impacts to such intersections. Additionally, particulate emissions from traffic on sanded, paved roads should be estimated. 2. A Setting and Background section should be included so that significance of the project and cumulative projects can be determined. 3. Qualitatively discuss the project's air quality impacts in relation to recently promulgated National Ambient Air Quality Standards for ozone and particulate SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA -3- matter (PM10 and PM2.5). What effect will this project have on the District's ability to meet these standards? 4. Identify meaningful mitigation measures that can be implemented to reduce short - and long -term air quality impacts. Qualitatively and quantitatively (when possible) evaluate the effectiveness of the mitigation measures that are proposed to reduce air quality impacts. 5. It is important to discuss how the mitigation measures will be monitored to ensure they are implemented. Mitigation Measures As stated in the California Environmental Qualit} Act, the commenting agency (the District) shall submit to the lead agency complete and detailed performance objectives for mitigation measures. Once emission impacts from the above listed sources are calculated, please review the suggested list of mitigations offered below for both short-term and long term sources. This list is not all- inclusive, and may be revised by the lead agency. As the lead agency, the planning agency will either accept or reject recommendations of the District (as a commenting agency). Please contact our office to discuss these mitigations before your agency commits to a final mitigation plan for this project. Be aware that compliance with the prescribed air quality mitigations during project construction and subsequent land use will be the primary responsibility of the project developer, with oversight by the planning agency with jurisdiction as established by the California Environmental Quality Act. It is expected that projects with higher emissions (Level C Thresholds) will automatically mitigate more emissions, quantitatively, than will a lower impact project (Level A). 1. Mitigations Suggested for Use During Construction Phase of Project For all Significance Level Thresholds (A, B and C) a. Alternati%es to open burning of vegetative material will be used unless otherwise deemed infeasible by the District. Among suitable alternatives are chipping, mulching, or conversion to biomass fuel. b. Adequate dust control measures will be implemented in a timely and effective manner during all phases of project development and constriction. C. All material excavated, stockpiled, or graded should be sufficiently watered, treated or covered, to prevent fugitive dust from leaving property boundaries and causing a public nuisance or a violation of an ambient air standard. Watering should occur at least twice daily with complete site coverage, preferably in the mid - morning and after work is completed each day. d. All areas (including unpaved roads) with vehicle traffic should be watered or have dust palliatives applied, as necessary, for regular stabilization of dust emissions. e. All on -site vehicles should be limited to a speed of 15 mph on unpaved roads. SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA -4- f All land clearing, grading, earth moving or excavation activities on a project will be suspended as necessary when winds are expected to exceed 20 mph. g. All material transported off -site will be either sufficiently watered or securely covered to prevent a public nuisance. h. If serpentine rock is found in the area, the presence of asbestos, in the chrysotile or amphibole forms must be determined. Additional mitigations may be needed on a site - specific basis. i. Temporary traffic control will be provided during all phases of the construction to improve traffic flow as deemed appropriate by local transportation agencies and /or Caltrans. j. Construction activities should be scheduled to direct traffic flow to off -peak hours as much as practicable. For Classifications as Level B Threshold k. All controls discussed above (a j ) should be implemented. 1. All inactive portions of the construction site should be covered, seeded, or watered until a suitable cover is established. m. The applicant will be responsible for applying County- approved non -toxic soil stabilizers (according to manufacturer's specifications) to all inactive construction areas (previously graded areas which remain inactive for 96 hours) in accordance with the local grading ordinance. Acceptable materials that may be used for chemical stabilization of soils include petroleum resins, asphaltic emulsions, acrylics and adhesives which do not violate Regional Water Quality Control Board or California Air Resource Board standards. For Classification as Level C Threshold n. All controls discussed above (a -m) should be implemented. o. During initial grading, earth moving, or site preparation, larger projects may be required to construct a paved (or dust palliative treated) apron, at least 100 feet in length, onto the paved road(s). p. Wheel washers will be installed where project vehicles and /or equipment enter and /or exit onto paved streets from unpaved roads on larger projects. Vehicles and /or equipment will be washed prior to each trip, if necessary. II. Mitigation for Residential Heating if Project Emissions are Classified as either Level A, B or C Threshold a. The District strongly recommends that all wood burning appliances be prohibited. Gas, pellet or fuel -oil heating appliances are viable alternatives. If the project insists upon installing wood - burning appliances, they may still be able to meet the Truckee General Plan's air quality goal of no net increase of particulate matter by participating in a "Great Stove Changeout Program" or contributing financially to SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA -5- any other programs that will offset the emissions that will be caused by the wood burning heating appliances installed in the project. Additionally, if wood- burning appliances are allowed within new construction under this plan, then each residential unit and occupied commercial building must have residential wood combustion units and/or fireplaces that are Environmental Protection Agency (EPA) Phase II or better devices. Any wood burning appliance or fireplace that is not EPA Phase II certified or better shall be prohibited. Additionally, each residential unit and occupied commercial building shall not emit more then 7.5 g /hr of particulate matter. III. Mitigation for Public Transit For All Significance Thresholds (Level A, B or Q a. Street should be designed to maximize pedestrian access to transit stops, where feasible. For Classification as Level C Threshold b. The project will provide for on -site road and off -site bus turnouts, passenger benches, and shelters as demand and service routes warrant subject to review and approval by local transportation planning agencies. C. Larger projects may be required to contribute a proportionate share to the development and /or continuation of a regional transit system. Contributions could consist of dedicated right -of -way, capital improvements, easements, etc. IV. Mitigation for Traffic Emissions For Classification as Level B Threshold a. The project will provide for pedestrian access between bus service and major transportation points within the project where deemed feasible. b. The project should contribute to traffic -flow improvements (IE. right -of -way, capital improvements, etc.) that reduce emissions and are not considered as substantially growth inducing. C. Larger projects may be required to provide for, contribute to, or dedicate land for the provision of off -site bicycle trails linking the project to designated bicycle commuting routes in accordance with an adopted citywide or countrywide bikeway plan. V. Mitigation for Land Use Emissions For Classification as Level B Threshold a. The project will incorporate mixed uses, where permitted by local development regulations, to achieve a balance of commercial, employment, and housing options within the project site. SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA -6- b. Larger projects will provide for neighborhood parks or other recreational options such as trails to minimize vehicle travel to off -site recreational uses and /or commercial areas. C. The project should provide densities of nine units per acre or greater, where allowed by the General Plan and /or Zone Plan, along bus routes and at bus stops to encourage transit use. d. The project should encourage neighborhood retail sales and services. Offsite Mitigation If a new project is unable to provide adequate on -site mitigation of their long -term air quality impacts, an off -site mitigation program may be necessary. Projects emitting high levels of pollutants (as determined by the District) may be required to implement all feasible on -site mitigation measures AND participate in an offsite mitigation program to reduce emissions. Impacts of local pollutants are cumulatively significant when modeling shows that combined emissions from the project and other existing and planned projects will exceed air quality standards. With an offsite mitigation program, these programs could be better coordinated, especially across county jurisdictional lines. Mitigation Monitoring and Reporting A mitigation monitoring and reporting program should be developed for each mitigated project and should include the following components: 1. A description of each mitigation measure adopted by the Lead Agency; 2. The party responsible for implementing each mitigation measure; 3. A schedule for the implementation of each measure; 4. The agency or entity responsible for monitoring mitigation measure implementation; 5. Criteria for assessing whether each measure has been implemented; 6. Enforcement mechanisms. Please add the District to your distribution list for copies of future documents pertaining to this project, so that the District can review and comment on the adequacy of the Air Quality Analysis and mitigation measures. Please feel free to contact me at 530 -550 -7872 if you have any questions or comments Sincerely, Ryan Murano Air Pollution Control Specialist III SERVING THE COUNTIES OF NEVADA, PLUMAS AND SIERRA -7-