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Home My Public Portal AboutPublic Comment #27 (NSAQMD - Amended)NORTHERN SIERRA AIR QUALITY MANAGEMENT DISTRICT Gretchen Bennitt, Executive Director DISTRICT HEADQUARTERS NORTHERN FIELD OFFICF. 200 Litton Drive, Suite 320 257 E. Sierra, Unit E Mailing Address: P.O. Box 2509 Mailing Address: P.O. Box 2227 Grass Valley, CA 95945 Portola, CA 96122 (530) 274 -9360 / FAX: (530) 274 -7546 (530) 832 -0102 / FAX: (530) 832 -0101 Email: office(omyairdistrict.com Web Site: Email: ryan@myairdistrict.com November 1, 2013 Denyelle Nishimori, Senior Planner Town of Truckee Planning Division 10183 Truckee Airport Road Truckee, CA 96161 Dear Ms. Nishimori: On October 29, 2013 the Northern Sierra Air Quality Management District (NSAQMD) submitted preliminary comments on the Joerger Ranch project EIR. Those preliminary comments briefly covered several topics, including permits and approvals, GHGs, model output reporting, mitigation measures and toxics. Please consider these comments to supersede those preliminary comments in all respects, as these are much more informed. In fact, the preliminary comments were completely incorrect regarding model output reporting and the greenhouse gas analysis; the section of the EIR on greenhouse gases is well done and the model output reporting is fine. As a whole, the DEIR is a well thought -out and well written document, with regard to air quality issues. The NSAQMD applauds the inclusion of sidewalks, bike lanes and numerous traffic improvement measures, as well as other significant air quality mitigations. 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 any 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 protect, 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 light of the fact that the project's net calculated air quality impacts are considerably above the NSAQMD's thresholds of significance and deemed unavoidable, an additional mitigation measure that could be incorporated to reduce emissions is the installation of electric vehicle charging stations at strategic locations within the project. In addition, the NSAQMD encourages the lead agency to work with the project proponent to identify reasonable offsite mitigations. Note that the commitment in the DEIR to fully mitigate particulate matter emissions will likely have some collateral benefits in mitigating other pollutants. Examples of offsite mitigations used elsewhere include woodstove change -out program funding; fire -safe clearing /chipping programs; and establishing /maintaining a residential green -waste drop -off facility (to reduce SI.RVING THL COUNTIES OF N! :VADA, YLUMAS AND SI I. tRA residential open burning of yard waste), which would involve chipping and hauling the waste to a biomass -fired power plant or commercial composting facility. In general, the air quality impact analysis and the proposed mitigation measures are in concert, although in at least one particular the analysis includes more stringent mitigations than the actual proposed mitigations. The air quality calculations (Appendix B) take credit for "Low VOC coatings (50 g/L flat, 100 g/L non -flat and 150 g/L high gloss)." However, the mitigation measure listed in Table ES -3 and in the Air Quality section references Placer County's Rule 218 as the standard for "low VOC paint and architectural coatings." Placer County's Rule 218 is more stringent than the NSAQMD's default to state and federal standards, but is much less stringent than the "50 g/L flat, 100 g/L non -flat and 150 g/L high gloss" used in the emission calculations. Rule 218 specifies 100 g/L flat, 150 g/L non -flat and 250 g/L high - gloss. However, the difference in overall emissions is not substantial enough to change the threshold comparison metric. Also, it is not known if the 50/100/150 criteria can be met through local suppliers. Therefore, the NSAQMD is not recommending that emissions be recalculated specifically for this reason or that the mitigation measure be changed. In addition, the air quality analysis contains a user - entered comment (page 81 of Appendix B) under "Sequestration" that reads, "SCAQMD mitigation tables." A brief description of what this refers to would be helpful in understanding its meaning. The SCAQMD (South Coast Air Quality Management District) generally has more stringent controls than the NSAQMD, due to the severity of its air quality problems. The NSAQMD has some concerns regarding exposure of the public to diesel particulate matter (DPM, a listed Toxic Air Contaminant) and other toxics (as well as odors) from traffic and other sources near the intersection of Joerger Drive and Soaring Way, particularly under atmospheric inversion conditions. In order to more fully inform the public and decision makers, this should be discussed in the FEIR. The presence of seasonal heavy truck traffic associated with the facilities on Joerger Drive (including Teichert, which is not specifically addressed in the DEIR), combined with benzene and other toxics from the proposed gas station, automobile exhaust and possible emissions from manufacturing and other facilities yet to be determined, could potentially create an area of significant toxic risk from air contaminants. The traffic report (Appendix D2), pages 29 and 54, lists the percentage of heavy vehicles at the Soaring Way / Joerger Road intersection as 2 %. Casual daytime observations of the intersection indicate that this percentage is too low. Even with this 2% assumption, the intersection is identified as exceeding the LOS standard under the project (page 31 of Appendix D1). The Teichert aggregate and asphalt production facility on Joerger Drive is quite large, and at certain times (subject to market demand) the truck traffic to and from Teichert is heavy. These times don't necessarily coincide with the modeled /observed peak traffic hour. The NSAQMD recommends that a verification or "ground - truthing" of the truck traffic assumptions be conducted through contacting the existing businesses and other entities on Joerger Drive regarding the number and frequency of trucks passing through the intersection. If additional information reveals that the situation at the intersection is untenable, one solution may be to include another access point from Joerger Drive onto northbound 267, north of the project where Joerger is close to 267. Absent this, the SERVING THE COUNTIES OF NEVADA, YLUMAS AND SIERRA NSAQMD supports the installation of a roundabout (proposed mitigation measure 3.11- 1 H) at the Soaring Way /Joerger Dr. intersection (assuming the radius is adequate to accommodate large trucks). Mitigation Measure 3.1 -6 reads, "All off road construction equipment must utilize `Diesel Oxidation Catalyst' and Tiered Engine that are certified to effectively reduce NOx emissions by 40 %." This is both difficult to enforce and somewhat vague. It seems to mean that engines have to emit 40% less NOx than a Tier Zero engine, but even this is difficult to interpret. An older Tier Zero engine, for example, typically emits more than a newer Tier Zero engine. Also, for engines less than 50 hp, even a brand new Tier 4 engine does not provide a 40% reduction from Tier Zero. In general, based on a comparison of reductions from Tier Zero for different engine ages and sizes, a 40% reduction equates roughly to a Tier 2 engine. As a related matter, if a piece of equipment has already been retrofitted with a Diesel Particulate Filter to reduce air toxics emissions, it may not be possible to also add a Diesel Oxidation Catalyst. Therefore, the NSAQMD strongly recommends that Mitigation Measure 3.1 -6 be changed to read something to the effect of, "All offroad construction equipment engines must either be CARIB certified as at least Tier 2 engines or be equipped with either a Diesel Oxidation Catalyst or a Diesel Particulate Filter that is in good repair and maintained according to manufacturer's specifications and recommendations." The DEIR doesn't go into detail about how some of the proposed air quality mitigation measures will be accomplished, so it is important to provide adequate details in the Final EIR and /or the Mitigation Monitoring and Reporting Program (MMRP) to ensure that the mitigations that have been committed to in the DEIR for the purpose of reducing calculated project emissions actually come into being. The NSAQMD hereby approves the conditions in Mitigation measure 3.1 -5 as a Dust Control Plan for the project, pursuant to NSAQMD Rule 226: Dust Control. The dust control conditions should be included on grading or improvement plans for each portion of the project, preferably in their own section with an obvious title such as "Dust Control." Please include the NSAQMD on the distribution list for the Final EIR, as well as the MMRP if it is separate from the Final EIR. Please contact me with any questions. Sincerely, Samuel F. Long ire, APCS SERVING THE COUNTIES OF NEVADA, YLUMAS AND SIERRA