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
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(530) 274 -9360 / FAX: (530) 274 -7546 email: ryan @myairdistrict.com email: george @myairdistrict.com
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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
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(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 %.
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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
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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.
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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
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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.
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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
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