HomeMy Public PortalAboutPublic Comment #20 (NSAQMD)1
Laura Dabe
Subject:FW: PC-3 DEIR Public Comment #20
From: Sam Longmire [mailto:sam@myairdistrict.com]
Sent: Tuesday, October 29, 2013 12:02 PM
To: Denyelle Nishimori
Cc: Gretchen Bennitt, APCO
Subject: Joerger Ranch DEIR Comments
Dear Ms. Nishimori:
On behalf of the Northern Sierra Air Quality Management District (NSAQMD), I am in the process of reviewing the
extremely large DEIR for the proposed Joerger Ranch project. I know that the comment period ends today, but I will not
be able to finalize my comments today due to computer issues (my Dropbox link to the planning files does not work any
more and the Town of Truckee website is extremely slow) and having to go home to care for a sick child. Below are my
preliminary comments, which I hope to provide more detail and clarification on tomorrow. I hope this is acceptable, and
I apologize in advance for any incomplete or incorrect information contained herein.
The NSAQMD applauds the inclusion of sidewalks and bike lanes, as well as other significant air quality mitigation
measures. Electric vehicle charging stations could be added to the air quality mitigation list.
Regarding permits and approvals, some aspects of the project are likely to require permitting by the NSAQMD. In
particular, an Authority to Construct/Permit to Operate will be required for the gas station, and may be required for
other sources of air contaminants such as standby generator engines and any spray booth/coating operation. In
general, if any source of air contaminants is proposed as part of the project, the NSAQMD should be consulted regarding
the potential need for permitting. In addition, required approvals from the NSAQMD include the dust control plan
required under Rule 226: Dust Control.
In my quick review, I did not notice a GHG discussion component.
The air quality impact modeling is reported in tons per year, which don’t necessarily convert accurately to lbs per day,
which is the metric upon which the air quality impact threshold is based.
There seems to be somewhat of a disconnect between the air quality impact analysis and the proposed mitigation
measures. The analysis includes more stringent mitigations than the actual proposed mitigations.
The Northern Sierra Air Quality Management District has some concerns regarding exposure of the public to diesel
particulate matter (DPM, a listed Toxic Air Contaminant) from truck traffic near the intersection of Joerger Drive and
Soaring Way. There is seasonal heavy truck traffic associated with the facilities on Joerger Drive (including Teichert),
which is not specifically addressed in the DEIR. The DEIR says on page ES‐4 and ES‐5 that the intersection of Joerger
Drive and Soaring Way would include a 4‐way stop with a through/left‐turn pocket to Joerger, while the document
describes a roundabout in a later section. The adequacy of the traffic impact analysis and modeled NOx and DPM
emissions regarding The potential for frequent truck traffic at the intersection, combined with benzene and other toxics
from the nearby gas station, could potentially create an area of significant toxic risk from air contaminants. The DEIR
lists the potential for public exposure to toxic air contaminants and odors as less than significant, but it would more
appropriately be potentially significant. This should be examined in more detail in the EIR.
I must go now, and will revise/complete my comments as soon as possible.
Sincerely,
Sam Longmire, APCS
2
Samuel F. Longmire, MSES
Air Pollution Control Specialist III
Northern Sierra Air Quality Management District
PO Box 2509, Grass Valley, CA 95945
Phone: (530) 274-9360 x106
Fax: (530) 274-7546