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HomeMy Public PortalAbout4d-AirQualityNOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 163 D. AIR QUALITY This section has been prepared using methodologies and assumptions recommended in the air quality impact assessment guidelines of the Northern Sierra Air Quality Management District (NSAQMD).1 In keeping with these guidelines, this section describes existing air quality in Truckee and the Nevada County Area, impacts of future traffic on local carbon monoxide levels, impacts of land use related vehicular emissions that have regional effects, and other effects of the project related to air quality. Mitigation measures to reduce or eliminate potentially significant air quality impacts are identified, where appropriate. 1. Setting The following discussion provides an overview of existing air quality conditions in the region and in Truckee. Ambient standards and the regulatory framework relating to air quality are summarized. Climate, air quality conditions, and typical air pollutant types and sources are also described. a. Air Quality Standards, Regulatory Framework and Attainment Status. Air quality standards, the regulatory framework, and State and federal attainment status are discussed below. (1) Air Quality Standards. Both the State and federal governments have established health-based Ambient Air Quality Standards for six air pollutants: carbon monoxide (CO), ozone (O3), nitrogen dioxide (NO2), sulfur dioxide (SO2), lead (Pb), and suspended particulate matter (PM). In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride and visibility- reducing particles. These standards are designed to protect public health and welfare with a reasonable margin of safety. In addition to primary and secondary Ambient Air Quality Standards, the State of California has established a set of episode criteria for O3, CO, NO2, SO2, and PM. These criteria refer to episode levels representing periods of short-term exposure to air pollutants that actually threaten public health. Health effects are progressively more severe as pollutant levels increase from Stage One to Stage Three. California Ambient Air Quality Standards and National Ambient Air Quality Standards for the criteria air pollutants are listed in Table IV.D-1. Health effects of these criteria pollutants are described in Table IV.D-2. (2) Air Quality Regulatory Framework. The Federal Clean Air Act governs air quality in the United States. In addition to being subject to federal requirements, air quality in California is also governed by more stringent regulations under the California Clean Air 1 Northern Sierra Air Quality Management District. Website: http://www.myairdistrict.com/. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 164 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) Table IV.D-1 Federal and State Ambient Air Quality Standards Pollutant Averaging Time California Standardsa Federal Standardsb Concentrationc Method d Primaryc,e Secondaryc,f Methodg Ozone (O3) 1-Hour 0.09 ppm (180 μg/m3) Ultraviolet Photometry No federal standard Same as Primary Standard Ultraviolet Photometry 8-Hour 0.070 ppm (137 μg/m3) 0.08 ppm (147 μg/m3) Respirable Particulate Matter (PM10) 24-Hour 50 μg/m3 Gravimetric or Beta Attenuation 150 μg/m3 Same as Primary Standard Inertial Separation and Gravimetric Analysis Annual Arithmetic Mean 20 μg/m3 – Fine Particulate Matter (PM2.5) 24-Hour No Separate State Standard 35 μg/m3 Same as Primary Standard Inertial Separation and Gravimetric Analysis Annual Arithmetic Mean 12 μg/m3 Gravimetric or Beta Attenuation 15 μg/m3 Carbon Monoxide (CO) 8-Hour 9.0 ppm (10 mg/m3) Non-Dispersive Infrared Photometry (NDIR) 9 ppm (10 mg/m3) None Non- Dispersive Infrared Photometry (NDIR) 1-Hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) 8-Hour (Lake Tahoe) 6 ppm (7 mg/m3) – Nitrogen Dioxide (NO2) Annual Arithmetic Mean 0.03 ppm (56 μg/m3) Gas Phase Chemilumin- escence 0.053 ppm (100 μg/m3) Same as Primary Standard Gas Phase Chemilumin- escence 1-Hour 0.18 ppm (339 μg/m3) – Lead 30-day average 1.5 μg/m3 Atomic Absorption – – High-Volume Sampler and Atomic Absorption Calendar Quarter – 1.5 μg/m3 Same as Primary Standard Sulfur Dioxide (SO2) Annual Arithmetic Mean – Ultraviolet Fluorescence 0.030 ppm (80 μg/m3) – Spectrophot o-metry (Pararosanili ne Method) 24-Hour 0.04 ppm (105 μg/m3) 0.14 ppm (365 μg/m3) – 3-Hour – – 0.5 ppm (1300 μg/m3) 1-Hour 0.25 ppm (655 μg/m3) – – NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 165 Pollutant Averaging Time California Standardsa Federal Standardsb Concentrationc Method d Primaryc,e Secondaryc,f Methodg Visibility- Reducing Particles 8-Hour Extinction coefficient of 0.23 per kilometer - visibility of 10 miles or more (0.07–30 miles or more for Lake Tahoe) due to particles when relative humidity is less than 70 percent. Method: Beta Attenuation and Transmittance through Filter Tape. No Federal Standards Sulfates 24-Hour 25 μg/m3 Ion Chromatography Hydrogen Sulfide 1-Hour 0.03 ppm (42 μg/m3) Ultraviolet Fluorescence Vinyl Chlorideh 24-Hour 0.01 ppm (26 μg/m3) Gas Chromatography a California standards for ozone, carbon monoxide (except Lake Tahoe), sulfur dioxide (1 and 24 hour), nitrogen dioxide, suspended particulate matter—PM10, PM2.5, and visibility reducing particles, are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations. b National standards (other than ozone, particulate matter, and those based on annual averages or annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest eight hour concentration in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24 hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24 hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. Contact U.S. EPA for further clarification and current federal policies. c Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas. d Any equivalent procedure which can be shown to the satisfaction of the ARB to give equivalent results at or near the level of the air quality standard may be used. e National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. f National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant. g Reference method as described by the EPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the EPA. h The ARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants. Source: ARB, 2008. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Table IV.D-2 Health Effects of Air Pollutants Pollutant Health Effects Examples of Sources Suspended Particulate Matter (PM2.5 and PM10) ƒ Reduced lung function ƒ Aggravation of the effects of gaseous pollutants ƒ Aggravation of respiratory and cardio respiratory diseases ƒ Increased cough and chest discomfort ƒ Soiling ƒ Reduced visibility ƒ Stationary combustion of solid fuels ƒ Construction activities ƒ Industrial processes ƒ Atmospheric chemical reactions Ozone (O3) ƒ Breathing difficulties ƒ Lung damage ƒ Formed by chemical reactions of air pollutants in the presence of sunlight; common sources are motor vehicles, industries, and consumer products Carbon Monoxide (CO) ƒ Chest pain in heart patients ƒ Headaches, nausea ƒ Reduced mental alertness ƒ Death at very high levels ƒ Any source that burns fuel such as cars, trucks, construction and farming equipment, and residential heaters and stoves Lead (Pb) ƒ Organ damage ƒ Neurological and reproductive disorders ƒ High blood pressure ƒ Metals processing ƒ Fuel combustion ƒ Waste disposal Nitrogen Dioxide (NO2) ƒ Lung damage ƒ See carbon monoxide sources Toxic Air Contaminants ƒ Cancer ƒ Chronic eye, lung, or skin irritation ƒ Neurological and reproductive disorders ƒ Cars and trucks, especially diesels ƒ Industrial sources such as chrome platers ƒ Neighborhood businesses such as dry cleaners and service stations ƒBuilding materials and products Source: ARB and EPA, 2007. Act. At the federal level, the United States Environmental Protection Agency (EPA) admin- isters the Clean Air Act (CAA). The California CAA is administered by the California Air Resources Board (ARB) at the State level and by the Air Quality Management Districts at the regional and local levels. The NSAQMD regulates air quality at the regional level. Federal CAA. The 1970 Federal CAA authorized the establishment of national health- based air quality standards and also set deadlines for their attainment. The Federal CAA Amendments of 1990 changed deadlines for attaining national standards as well as the remedial actions required of areas of the nation that exceed the standards. Under the CAA, State and local agencies in areas that exceed the national standards are required to develop State Implementation Plans to demonstrate how they will achieve the national standards for ozone by specified dates. The CAA requires that projects receiving federal funds demon- strate conformity to the approved State Implementation Plan and local air quality attainment 166 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY plan for the region. Conformity with the State Implementation Plan requirements also satisfies the CAA requirements. California CAA. In 1988, the California CAA required that all air districts in the State endeavor to achieve and maintain California Ambient Air Quality Standards for CO, Ozone, SO2 and NO2 by the earliest practical date. The California CAA provides districts with new authority to regulate indirect sources and mandates that air quality districts focus particular attention on reducing emissions from transportation and area-wide emission sources. Each district plan is to achieve a 5 percent annual reduction, averaged over consecutive three- year periods, in district-wide emissions of each nonattainment pollutant or its precursors. Additional physical or economic development within the region would tend to impede the emissions reduction goals of the California CAA. Generally, the State standards for these pollutants are more stringent than the national standards. United States Environmental Protection Agency. The EPA is responsible for enforc- ing the Federal CAA. The EPA is also responsible for establishing the National Ambient Air Quality Standards (NAAQS). The NAAQS are required under the 1977 CAA and subsequent amendments. The EPA regulates emission sources that are under the exclusive authority of the federal government, such as aircraft, ships, and certain types of locomotives. The agency has jurisdiction over emission sources outside state waters (e.g., beyond the outer continental shelf) and establishes various emission standards, including those for vehicles sold in states other than California. California Air Resources Board. In California, the ARB, which is part of the California Environmental Protection Agency (Cal EPA), is responsible for meeting the State require- ments of the Federal CAA, administering the California CAA, and establishing the California Ambient Air Quality Standards (CAAQS). The California CAA, as amended in 1992, requires all air districts in the State to endeavor to achieve and maintain the California Ambient Air Quality Standards (CAAQS). The CAAQS are generally more stringent than the corresponding federal standards and incorporate additional standards for sulfates, hydrogen sulfide, vinyl chloride and visibility reducing particles. The ARB regulates mobile air pollution sources, such as motor vehicles. Automobiles sold in California must meet the stricter emission standards established by the ARB. The agency is responsible for setting emission standards for vehicles sold in California and for other emission sources, such as consumer products and certain off-road equipment. The ARB established passenger vehicle fuel specifications, which became effective on March 1996. Since 1996, Executive Order D-5-99 was signed on March 25, 1999, which directs the phase-out of methyl tertiary butyl ether (MTBE) in California's gasoline by December 31, 2002. The Executive Order also directs the ARB to adopt gasoline regulations to facilitate the removal of MTBE without reducing the emissions benefits of the existing program. Additional refinements and amendments to the reformulated gasoline regulations were made in 2004 and 2007; the most recent California reformulated gasoline regulation became effective on August 29, 2008. N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 167 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 168 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) The ARB oversees the functions of local air pollution control districts and air quality management districts, which in turn administer air quality activities at the regional and county level. Air Quality and Land Use Handbook. The ARB has also developed an Air Quality and Land Use Handbook 2 which is intended to serve as a general reference guide for evaluating and reducing air pollution impacts associated with new projects that go through the land use decision-making process. The ARB handbook recommends that planning agencies strongly consider proximity to these sources when finding new locations for "sensitive" land uses such as homes, medical facilities, daycare centers, schools and playgrounds. Air pollution sources of concern include freeways, rail yards, ports, refineries, distribution centers, chrome plating facilities, dry cleaners and large gasoline service stations. Key recommendations in the Handbook include taking steps to avoid siting new, sensitive land uses (including residences, day care centers, playgrounds or medical facilities): ƒ Within 500 feet of a freeway, urban roads with 100,000 vehicles / day or rural roads with 50,000 vehicles/day. ƒ Within 1,000 feet of a major service and maintenance rail yard. ƒ Immediately downwind of ports (in the most heavily impacted zones) and petroleum refineries. ƒ Within 300 feet of any dry cleaning operation (for operations with two or more machines, provide 500 feet). ƒ Within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater). The Handbook specifically states that these recommendations are advisory and acknowl- edges land use agencies have to balance other considerations, including housing and transportation needs, economic development priorities, and other quality of life issues. Northern Sierra Air Quality Management District. The three-county Northern Sierra area is considered, in air quality terms, an air basin. Overall, the air quality conditions in Nevada County are fairly good due to favorable climate conditions that result in moderate temperatures and good ventilation. However, exceedances of air quality standards for ozone and respirable particulate matter pose challenges for air pollution control agencies. Most of Nevada County’s ozone is transported by wind from the Sacramento and Bay Areas. In 2004, Western Nevada County was designated non-attainment for the federal 8-hour Ozone 2 California Air Resources Board, 2005. Air Quality and Land Use Handbook: A community Health Perspective. April. NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Standard of 0.08 ppm; however, the eastern portion of Nevada County, including the Town of Truckee, remains in attainment for the federal 8-hour Ozone Standard. The NSAQMD is primarily responsible for assuring that the National and State ambient air quality standards are attained and maintained in the counties of Nevada, Plumas and Sierra. The NSAQMD is also responsible for adopting and enforcing rules and regulations concerning air pollutant sources, issuing permits for stationary sources of air pollutants, inspecting stationary sources of air pollutants, responding to citizen complaints, monitoring ambient air quality and meteorological conditions, awarding grants to reduce motor vehicle emissions, conducting public education campaigns, as well as many other activities. The NSAQMD has jurisdiction over the three-county Northern Sierra area. The NSAQMD has rules and regulations to protect regional air quality. District Rule 226 would be applicable to the proposed project. The rule requires the submittal of a Dust Control Plan to the District for approval prior to any surface disturbance, including clearing of vegetation. The NSAQMD would prefer to have the conditions of the Dust Control Plan included in the General Notes and/or the Grading Plan for the project. Local Policies. The Conservation and Open Space element of the Town of Truckee’s General Plan includes the following policies related to air quality: Policies COS-13.1: Requires multi-family residential, commercial, industrial, subdivisions and other discretionary development to maintain consistency with the goals, policies and control strategies of the Town’s Particulate Matter Air Quality Plan. COS-13.2: Existing non-paved roads within new development and subdivision, and existing off- site non-paved roads that serve new development and subdivisions shall be paved to the extent necessary to offset emissions generated by the development and subdivision traffic to the degree feasible. New non-paved roads shall not be allowed for new development and subdivisions except for single-family residences, secondary residential units and duplexes on existing lots. New paving shall take into consideration the policies under Goal COS-11 concerning minimization of impacts to water quality and groundwater recharge that may result from increases in paved areas. COS-13.3: Require all construction projects to implement dust control measures to reduce particulate matter emissions due to disturbance of exposed top-soils. Such measures would include watering of active areas where disturbance occurs, covering haul loads, maintaining clean access roads, and cleaning the wheels of construction vehicles accessing disturbed areas of the site. COS-14.1: Minimize potential impacts created by unpleasant odors, as well as other airborne pollutants from industrial and commercial developments. N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 169 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 170 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) COS-14.2: Prohibit sensitive receptors such as residential uses, schools and hospitals, from locating in the vicinity of industrial and commercial uses known to emit toxic, hazardous or odoriferous air pollutants, and prohibit the establishment of such uses in the vicinity of sensitive receptors. COS-14.3: Reduce automobile dependence, thereby reducing greenhouse gas emissions, by encouraging mixed land use patterns that locate services such as banks, child care facilities, schools, neighborhood shopping centers and restaurants in close proximity to employment centers and residential neighborhoods. COS-14.4: Review all discretionary development applications to determine the need for pedestrian/bike paths connecting to adjacent development and services, in order to provide alternatives to automobile transportation. COS-14.5: Encourage the use of alternative fuels in vehicle fleets operated by local ski resorts, local Special Districts, and by the Town. COS-14.6: Work with the NSAQMD to accurately monitor PM10, Carbon Monoxide, and other regulated air pollutants in Truckee, and to upgrade its facilities as needed in the future to ensure that accurate monitoring is maintained. COS-14.7: Promote the use of public and private transit services within Truckee and between the Town and ski resorts and other destinations in the Tahoe area. COS-14.8: Require developers of projects that would locate sensitive receptors such as residences within the California Air Resource Board’s recommended buffer of 500 feet of I-80 and the railway to prepare a health risk assessment to determine the significance of the impact, and to incorporate project-specific mitigations to minimize or avoid this risk. COS-14.9: Require new development with the potential to generate significant quantities of ozone precursor air pollutants to be analyzed in accordance with guidelines provided by the NSAQMD and appropriate mitigation be applied to the project to minimize these emissions. The Town of Truckee has also taken several steps to improve air quality and reduce particulate matter pollution. In response to poor air quality conditions and the designation of a nonattainment area from the EPA, the Town Council adopted the Particulate Matter Air Quality Management Plan 3 in order to improve air quality. The goal of this air quality management plan is as follows: “The Town shall achieve and maintain compliance with National Ambient Air Quality Standards for PM10 and PM2.5 as established by the United States Environmental Protection Agency. The Town shall strive to achieve compliance with State Ambient Air 3 Town of Truckee, 1999. Particulate Matter Air Quality Management Plan. July 15. NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Quality Standards for PM10 as established by State law and shall make reasonable progress toward achieving State particulate matter standards.” The Particulate Air Quality Management Plan includes nine objectives, the first of which states that new development will mitigate to the maximum extent feasible its particulate matter emissions from solid fuel burning devices and re-entrained road dust. In addition, the plan contains several Control Strategies that are applicable to the project, including Construction/Grading Regulations, Large Project Emissions Offset, and Road Surfacing. The implementation guidelines for each of these strategies are summarized below. Construction/Grading Regulations: (1) Best Available Control Measures (BACM) will be used in implementing development regulations. Because broom or mechanical sweeping does not control particulate matter emissions but rather entrains dust into the air, broom or mechanical sweeping is not considered a BACM without other measures to control dust during sweeping. (2) Paved access points or aprons onto Town streets should be installed at the beginning of construction of large projects. The aprons should be flushed and swept at least once daily. (3) Grading Ordinance provisions should be adopted to identify temporary and permanent erosion control measures and require on-going monitoring of project grading. Plan Area inspections should be required before grading is initiated to ensure all necessary control measures, including proper staking and tree protection measures, are in place. (4) A dust suppression plan should be required with grading plans for larger projects. Regular watering and other dust-preventive measures (e.g., hydroseeding, revegetation) should occur on a frequent basis during project construction. (5) For larger projects, securities or bonds may be required to ensure that dust control measures are properly implemented during grading. Large Project Emissions Offset: (1) A large development project will be considered a project that results in 100 or more single- family residential lots, 200 or more multi-family residential units, 40,000 square feet or more of office, commercial, and/or industrial floor space, or any equivalent combination thereof. (2) Guidelines and methodologies will be developed by Town staff with the assistance of the Northern Sierra Air Quality Management District to calculate particulate matter emissions and identify feasible mitigation measures. The guidelines will identify those emission sources for which emissions must be estimated (e.g., wood combustion devices, vehicle emissions, re-entrained road dust both on- and off-site) and list feasible mitigation measures that may be implemented to offset emissions. (3) Emissions generated by the project shall be offset by 100 percent upon implementation of the mitigation measures. The offset should be proportional to fine and coarse particulate matter emissions generated by the project. For example, if 40 percent of the project’s particulate matter emissions are fine, then 40 percent of the offset should be directed to reducing fine particulate matter emissions. N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 171 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY (4) If there are not sufficient measures that can be implemented to offset project emissions, a mitigation fee ($ per annual ton) may be paid in-lieu of other mitigation measures. The amount of the mitigation fee will be determined as part of the guidelines and methodology to be developed as part of this control strategy. The mitigation fees will be used as part of the Town’s air quality mitigation funds to study and reduce particulate matter pollution and to implement other control strategies. Road Surfacing: (1) Projects and subdivisions will be required to offset (by paving of roadways) 100 percent of their emissions generated by new traffic on non-paved roadways. Exemptions will be provided for single-family residences, duplexes, and secondary residential units constructed on existing lots and for subdivision roads that provide access to four or less parcels. (3) Attainment Status Designations. The California Air Resources Board is required to designate areas of the State as attainment, nonattainment or unclassified for any State standard. An “attainment” designation for an area signifies that pollutant concentrations did not violate the standard for that pollutant in that area. A “nonattainment” designation indicates that a pollutant concentration violated the standard at least once, excluding those occasions when a violation was caused by an exceptional event, as defined in the criteria. An “unclassified” designation signifies that data does not support either an attainment or nonattainment status. The California Clear Air Act divides districts into moderate, serious, and severe air pollution categories, with increasingly stringent control requirements mandated for each category. The U.S. EPA designates areas for O3, CO, and NO2 as either “does not meet the primary standards,” or “cannot be classified,” or “better than national standards.” For SO2, areas are designated as “does not meet the primary standards,” “does not meet the secondary standards,” “cannot be classified,” or “better than national standards.” In 1991, new nonattainment designations were assigned to areas that had previously been classified as Group I, II, or III for PM10 based on the likelihood that they would violate national PM10 standards. All other areas are designated “unclassified.” Table IV.D-3 provides a summary of the attainment status for the Nevada County with respect to national and State ambient air quality standards. As noted in the table footnotes, while western Nevada County has recently been designated as non-attainment for the federal 8-hour Ozone Standard, the eastern portion of Nevada County, including the Town of Truckee, remains in attainment for the federal 8-hour Ozone Standard. b. Existing Climate and Air Quality. The following discussion provides brief summaries of regional air quality, local climate and air quality, and air pollution climatology. (1) Regional Air Quality. The Town of Truckee and the Martis Valley Region is in a mountain-type air basin. Mountainous terrain surrounding the region limits the mixing of air near the surface, and because of the high elevation, radiative cooling is considerable. 172 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Table IV.D-3 NSAQMD Nevada County Attainment Status Pollutant Averaging Time California Standardsa National Standardsb Concentration Attainment Status Concentration Attainment Status Carbon Monoxide (CO) 8-Hour 9.0 ppm (10 mg/m3) Unclassified 9.0 ppm (10 mg/m3) Attainmentc 1-Hour 20.0 ppm (23 mg/m3) Attainment 35.0 ppm (40 mg/m3) Attainment Nitrogen Dioxide (NO2) Annual Mean 0.03 ppm (56 μg/m3) Not Applicable 0.053 ppm (100 μg/m3) Attainment 1-Hour 0.18 ppm (338 μg/m3) Attainment Not Applicable Not Applicable Ozone (O3) 8-Hour 0.070 ppm c (137 μg/m3) Nonattainment 0.08 ppm (147 μg/m3) Nonattainment d 1-Hour 0.09 ppm (180 μg/m3) Nonattainment Not Applicable Not Applicable Suspended Particulate Matter (PM10) Annual Mean 20 μg/m3 Nonattainment Not Applicable Not Applicable 24-Hour 50 μg/m3 Nonattainment 150 μg/m3 Unclassified Suspended Particulate Matter (PM2.5) Annual Mean 12 μg/m3 Unclassified 15 μg/m3 Attainment 24-Hour Not Applicable Not Applicable 35 μg/m3 Unclassified Lead (pb) 30-Day Average 1.5 μg/m Attainment Not Applicable Not Applicable Calendar Quarter Not Applicable Not Applicable 1.5 μg/m3 Attainment Sulfur Dioxide (SO2) Annual Mean Not Applicable Not Applicable 0.03 ppm (80 μg/m3) Attainment 24-Hour 0.04 ppm (105 μg/m3) Attainment 0.14 ppm (365 μg/m3) Attainment 1-Hour 0.25 ppm (655 μg/m3) Attainment Not Applicable Not Applicable a California standards for O3, CO (except Lake Tahoe), SO2 (1-hour and 24-hour), NO2 and PM10 are values that are not to be exceeded. If the standard is for a 1-hour, 8-hour, or 24-hour average, then some measurements may be excluded. In particular, measurements are excluded that ARB determines would occur less than once per year on the average. b National standards other than for 03 and those based on annual averages or annual arithmetic means are not to be exceeded more than once a year. For example, the 03 standard is attained if, during the most recent 3-year period, the average number of days per year with maximum hourly concentrations above the standard is equal to or less than 1. c Attainment status based on .08 ppm standard d Only western Nevada County is non-attainment for the federal 8-hour standard. Eastern Nevada County, including the Town of Truckee remains in attainment. Notes: Lead (Pb) is not listed in the above table because it has been in attainment since the 1980s. ppm = parts per million mg/m3 = milligrams per cubic meter μg/m3 = micrograms per cubic meter Source: Northern Sierra Air Quality Management District, Northern Sierra Attainment Status, 2008. N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 173 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Radiative cooling occurs when the ground cools faster than the air at night, causing the layer of air next to the ground in lower-lying valleys to be cooler; at high elevations where there is less moisture in the air to retain heat from the daytime, the ground cools the air faster. At nighttime, cold air sinks off the mountains into the basin, further lowering the temperature. Thus, Truckee typically records the lowest temperature in the United States on several days during the year, mostly in late spring through summer. The Town of Truckee is within the jurisdiction of the NSAQMD, which regulates air quality for Nevada, Plumas and Sierra Counties. Air quality conditions in the Northern Sierra area have improved significantly since the NSAQMD was created in 1986. Ambient concentra- tions of air pollutants and the number of days during which the region exceeds air quality standards have fallen dramatically. Exceedances of air quality standards occur primarily during meteorological conditions conducive to high pollution levels, such as cold, windless winter nights or hot, sunny summer afternoons. Ozone levels, measured by peak concentrations and the number of days over the State 1- hour standard, have declined substantially as a result of aggressive programs by the NSAQMD and other regional, State and federal agencies. The reduction of peak concentra- tions represents progress in improving public health; however, the Northern Sierra area still exceeds the State standard for 1-hour ozone. Particulate matter is the primary pollutant of concern in Truckee. Inhalable particulate or PM10 (particulate matter 10 microns or less in diameter) and PM2.5 (particulate matter 2.5 microns or less in diameter) refers to a wide variety of solid or liquid particles in the atmosphere. These include smoke, dust, aerosols and metallic oxides. Some of these particulates are considered toxic. Although particulates are found naturally in the air, most particulate matter found in the region are emitted either directly or indirectly by motor vehicles, industry, construction, wood burning, re-entrained road dust, and wind erosion of disturbed areas. Most PM2.5 is comprised of combustion products (i.e. soot). High levels of PM10 and PM2.5 can lead to adverse health effects, nuisance concerns and reduced visibility. The Northern Sierra area is considered a nonattainment area for PM10 and PM2.5 relative to the State standard, and unclassified for the federal standards. No exceedances of the State or federal CO standards have been recorded at any of the region’s monitoring stations since 1991. The Northern Sierra area is currently considered a maintenance area for State and federal CO standards. Toxic air contaminants (TACs) are not criteria pollutants, but are associated with health- related effects and have appreciable concentrations within the Northern Sierra area. The U.S. EPA and the ARB have identified over 800 substances that are emitted into the air that may affect human health. Some of these substances are considered to be carcinogens, while others are known to have other adverse health effects. As part of ongoing efforts to identify 174 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 175 and assess potential health risks to the public, the NSAQMD has collected and compiled air toxics emissions data from industrial and commercial sources of air pollution throughout the three-county area. Monitoring data and emissions inventory of toxic air contaminants helps the NSAQMD determine health risk to Northern Sierra residents. The 2003 emissions inventory shows that emissions of many TACs are decreasing in the Nevada, Plumas and Sierra Counties. Ambient monitoring concentrations of TACs indicate that pollutants emitted primarily from motor vehicles (1,3-butadiene and benzene) account for slightly over one half of the average calculated cancer risk from ambient air in the Northern Sierra area. According to the NSAQMD, ambient benzene levels declined dramatically in 1996 with the advent of Phase 2 reformulated gasoline. Due to this reduction, the calculated average cancer risk based on monitoring results has been reduced to 143 in one million; however, this risk does not include the risk resulting from exposure to diesel particulate matter or other compounds not monitored. Although not specifically monitored, recent studies indicate that exposure to diesel particulate matter may contribute significantly to a cancer risk (approximately 500- 700 in one million) that is greater than all other measured TACs combined.4 Most of Nevada County’s ozone is transported by wind from the Sacramento and Bay Areas. Ozone is formed by volatile compounds (VOC or ROG) and oxides of nitrogen (NOx) reacting in sunlight, especially in hot days. Ozone is an unstable 3-oxygen molecule that oxidizes substances it contacts. Nearly half of California’s ozone is from car and truck exhaust. The rest is from power production, off-road equipment, industry, consumer products, vegetation and other sources. As noted previously, the eastern portion of Nevada County, including the Town of Truckee, remains in attainment for the federal 8-hour Ozone Standard. The Federal Clean Air Act sets requirements for non-attainment areas. Western Nevada County must prepare an Attainment Plan that meets these requirements and shows how ozone levels will be lowered to meet standards as expeditiously as practicable. Over the past year, the District adopted all applicable “reasonably available control technologies.” Major air pollution sources are subject to an emission offset program, and federally funded projects such as highway improvements must be shown to not make the problem worse. Another requirement is that Western Nevada County must reduce its emissions of ozone precursors by at least 3 percent per year. Most necessary reductions are expected from Statewide measures and from cars becoming cleaner. Additional requirements vary depending on an area’s classification, which is tied to a demonstration that the standard can be met by a specific year. (2) Local Climate and Air Quality. Air quality is a function of both local climate and local sources of air pollution. The amount of a given air pollutant in the atmosphere is 4 Ibid. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY determined by the amount of pollutant released and the atmosphere’s ability to transport and/or dilute that pollutant. The major determinants of transport and dilution are wind, atmospheric stability, terrain, and, for photochemical pollutants, sunshine. Temperatures in Truckee range widely through the course of a day and through the year. In summer, typical ranges are from 35 to 40 degrees Fahrenheit (F) in the morning to above 80 degrees (F) in the afternoons. Temperatures in winter can range from nearly zero degrees (F) in the mornings to above 40 degrees (F) during the afternoon. Annually, mean temperatures (as measured at Truckee USFS Ranger Station) range from an average minimum of 15 degrees (F) in January to an average maximum of 82 degrees (F) in August. The frost-free season in Truckee averages only 30 days. Although summer thunderstorms are common, most precipitation falls from late October through early May with winter precipitation usually taking the form of snow. The cold temperatures and snow cover on the ground are conducive to the creation of temperature inversion layers. Mountainous terrain surrounds the Truckee area and is most pronounced in the west and the south. This area surrounded by mountainous terrain can be described as an air basin for the Truckee region in which air freely circulates within the basin but can be prevented or curtailed from leaving the basin by the higher elevations. The air pollution potential is lowest for the parts of the subregion that are highly elevated, due largely to good ventila- tion and less influx of pollutants from upwind sources. Pollutants can rise above these higher elevations, but they can be prevented from escaping the basin by temperature inversions. The occurrence of light winds in the evenings and early mornings occasionally causes elevated pollutant levels. The air pollution potential is greater at the lower elevated parts of this subregion because of the lower frequency of strong winds. A temperature inversion is created when a stable mass of warmer air lies or sits atop a mass of colder air. This prevents the cold air from rising and mixing with the warmer air. Moun- tains surrounding a valley or basin act as a rim, much like the sides of a cup or bowl, and prevent the cold air from moving laterally. The lack of air movement and turbulence resulting from the inversion layer (acting as a lid) and the mountains (acting as the bowl) curbs the dispersal of pollutants. Particulates cannot rise above the inversion layer, and instead of dispersing and thinning out in a larger air volume, the particulates are trapped within a smaller, confined air space. This increases particulate matter concentrations because more and more particulate matter is concentrated in a smaller volume of air that cannot expand to accommodate the increased particulate matter emissions This subregion contains a variety of industrial air pollution sources. Some industries are quite close to residential areas. The subregion is also traversed by frequently congested freeways such as I-80 and Highway 89. Traffic and congestion, and the motor vehicle emissions they generate, are increasing. 176 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Pollutant monitoring results for the years 2005 to 2007 are shown in Table IV.D-4. The closest monitoring station to the Plan Area for O3, PM10 and PM2.5 is the Truckee-Fire Station, Truckee. There is no available monitoring data from monitoring stations within the three-county air basin for CO, NO2, and SO2 concentrations for the past three years. The available air quality monitoring results indicate that air quality in the Plan Area has generally been good during this three-year period. As indicated in the monitoring results, the State O3 standard was exceeded seven times in the year 2006, and five times in 2007; while the federal 8-hour O3 standard was exceeded four times in 2006. Federal PM10 standards were exceeded once in this area during the three-year period. No violations of the State or federal standards for PM2.5 were recorded at this station for the years 2005 to 2007. c. Air Quality Issues. The section describes the key air quality issues in the Nevada County area. (1) Local Carbon Monoxide Hot Spots. Local air quality is most affected by CO emissions from motor vehicles. CO is typically the pollutant of greatest concern because it is created in abundance by motor vehicles and it does not readily disperse into the air. Idling freight trains are also a source of CO emissions. Because CO does not readily disperse, areas of vehicle congestion can create “pockets” of high CO concentration called “hot spots.” These pockets have the potential to exceed the State 1-hour standard of 20.0 ppm and/or the 8-hour standard of 9.0 ppm. While CO transport is limited, it disperses with distance from the source under normal meteorological conditions. However, under certain extreme meteorological conditions, CO concentrations near congested roadways or intersections may reach unhealthful levels that adversely affect local sensitive receptors (e.g., residents, schoolchildren, the elderly, hospital patients, etc.). Typically, high CO concentrations are associated with roadways or intersections operating at unacceptable levels of service or with extremely high traffic volumes. In areas with high ambient background CO concentration, modeling is recommended to determine a project’s effect on local CO levels. (2) Vehicle Emissions. Long-term air emission impacts are those associated with changes in automobile travel within the City. Mobile source emissions would result from vehicle trips associated with increased vehicular travel. As is true throughout much of the U.S., motor vehicle use is projected to increase substantially in the region. The NSAQMD, local jurisdictions, and other parties responsible for protecting public health and welfare will continue to seek ways of minimizing the air quality impacts of growth and development in order to avoid further exceedances of the standards. N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 177 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 178 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) Table IV.D-4 Ambient Air Quality at the Truckee Monitoring Station Pollutant Standard 2005 2006 2007 Carbon Monoxide (CO) Maximum 1 hour concentration (ppm) ND ND ND Number of days exceeded: State: > 20 ppm ND ND ND Federal: > 35 ppm ND ND ND Maximum 8 hour concentration (ppm) ND ND ND Number of days exceeded: State: > 9 ppm ND ND ND Federal: > 9 ppm ND ND ND Ozone (O3) Maximum 1 hour concentration (ppm) 0.080 0.092 0.081 Number of days exceeded: State: > 0.09 ppm 0 0 0 Maximum 8 hour concentration (ppm) 0.068 0.079 0.074 Number of days exceeded: State: > 0.07 ppm 0 7 5 Federal: > 0.75 ppm 0 4 0 Coarse Particulates (PM10) Maximum 24 hour concentration (μg/m3) 127 167 ND Number of days exceeded: State: > 50 μg/m3 ND ND ND Federal: > 150 μg/m3 0 1 ND Annual arithmetic average concentration (μg/m3) 29 29 ND Exceeded for the year: State: > 20 μg/m3 Yes Yes ND Federal: > 50 μg/m3 No No ND Fine Particulates (PM2.5) Maximum 24 hour concentration (μg/m3) 35 28 18 Number of days exceeded: Federal: > 65 μg/m3 0 0 0 Annual arithmetic average concentration (μg/m3) 6.8 6.3 6.0 Exceeded for the year: State: > 12 μg/m3 No No No Federal: > 15 μg/m3 No No No Nitrogen Dioxide (NO2) Maximum 1 hour concentration (ppm) ND ND ND Number of days exceeded: State: > 0.25 ppm ND ND ND Annual arithmetic average concentration (ppm) ND ND ND Exceeded for the year: Federal: > 0.053 ppm ND ND ND Sulfur Dioxide (SO2) Maximum 1 hour concentration (ppm) ND ND ND Number of days exceeded: State: > 0.25 ppm ND ND ND Maximum 3 hour concentration (ppm) ND ND ND Number of days exceeded: Federal: > 0.5 ppm ND ND ND Maximum 24 hour concentration (ppm) ND ND ND NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 179 Pollutant Standard 2005 2006 2007 Number of days exceeded: State: > 0.04 ppm ND ND ND Federal: > 0.14 ppm ND ND ND Annual arithmetic average concentration (ppm) ND ND ND Exceeded for the year: Federal: > 0.030 ppm ND ND ND Notes: ppm = parts per million μg/m3= micrograms per cubic meter ND = No data. There was insufficient (or no) data for monitoring stations within the air basin to determine the value. Source: ARB and EPA Web sites. LSA Associates, Inc. 2008. (3) Fugitive Dust. Fugitive dust emissions are generally associated with demolition, land clearing, exposure of soils to the air, and cut and fill operations. Dust generated during construction varies substantially on a project-by-project basis, depending on the level of activity, specific construction operations, and weather conditions. The U.S. EPA has developed an approximate emission factor for construction-related emissions of total suspended particulate of 1.2 tons per acre per month of activity. This factor assumes a moderate activity level, moderate silt content in soils being disturbed, and a semi-arid climate. The California Air Resources Board estimates that 64 percent of construction-related total suspended particulate emissions is PM10. Therefore, the emission factors for uncontrolled construction-related PM10 emissions are: ƒ 0.77 tons per acre per month of PM10; or ƒ 51 pounds per acre per day of PM10. However, construction emissions can vary greatly depending on the level of activity, the specific operations taking place, the equipment being operated, local soils, weather conditions, and other factors. There are a number of feasible control measures that can be reasonably implemented to significantly reduce PM10 emissions from construction. Fugitive dust sources also include emissions from re-entrained road dust. This emission source is of particular air quality concern in the Nevada County area. Substantial amounts of road sand and salt are applied to Town roads and State highways for traction control during winter storm periods. The sand and salt are "kicked-up" into the air by vehicles when the storm period ends and the roads (and the sand and salt) begin to dry out. The amount of dust and dirt on the roads during the non-winter months is substantially less than the winter months and generally is comprised of fugitive dust blown onto the road and dirt and mud tracked onto the road by vehicles coming from construction sites and unpaved roads. (4) Odors. Odors are also an important element of local air quality conditions. Major sources of odors include restaurants, manufacturing plants, and agricultural operations. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 180 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) Other odor producers include the industrial facilities within the region. While sources that generate objectionable odors must comply with air quality regulations, the public’s sensi- tivity to locally produced odors often exceeds regulatory thresholds. (5) Construction Equipment Exhaust. Construction activities cause combustion emissions from utility engines, heavy-duty construction vehicles, equipment hauling materials to and from construction sites, and motor vehicles transporting construction crews. Exhaust emissions from construction activities vary daily as construction activity levels change. The use of construction equipment results in localized exhaust emissions. (6) Solid Fuel Burning Emissions. Particulate emissions from residential solid-fuel burning devices are primarily a seasonal concern in the Nevada County region. Residential solid-fuel burning devices are mostly used for heating purposes during the colder temperatures of late fall, winter, and early spring. Also, emissions from woodheaters and fireplaces will be augmented by increased occupancy of second or vacation homes on weekends and holiday periods. According to the Town’s Particulate Matter Air Quality Concern Management Plan document, it is estimated that nearly 90 percent of all single- family homes in the Truckee air basin have at least one solid fuel burning device (excluding pellet stoves). Although data on particle size of woodsmoke is scarce, 80 percent to 95 percent of woodsmoke particulate matter is less than 2.5 microns in size.5 d. Global Climate Change Issues. This section provides a summary of the character- istics of global climate change and describes the regulatory framework addressing global climate change. (1) Characteristics of Global Climate Change. Global climate change is the observed increase in the average temperature of the Earth’s atmosphere and oceans in recent decades. The Earth’s average near-surface atmospheric temperature rose 0.6 ± 0.2° Celsius (°C) (1.1 ± 0.4° Fahrenheit [°F]) in the 20th century. The prevailing scientific opinion on climate change is that most of the warming observed over the last 50 years is attributable to human activities.6 The increased amounts of carbon dioxide (CO2) and other greenhouse gases (GHGs) are the primary causes of the human-induced component of warming. They are released by the burning of fossil fuels, land clearing, agriculture, etc., and lead to an increase in the greenhouse effect. 5 Raus, J.A. and J.J. Huntzicker. Composition and Size Distribution of Residential Wood Smoke Aerosols. Presented at the 21st Annual Meeting of the Air and Waste Management Association, Pacific Northwest International Section, Portland OR, November 1984. 6 Intergovernmental Panel on Climate Change (IPCC), Climate Change 2001: The Scientific Basis, http://www.grida.no/climate/ipcc_tar/wg1/index.htm. NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY GHGs are present in the atmosphere naturally, are released by natural sources, or formed from secondary reactions taking place in the atmosphere. The six gases that are widely seen as the principal contributors to global climate change as follows: ƒ Carbon dioxide (CO2) ƒ Methane (CH4) ƒ Nitrous oxide (N2O) ƒ Hydroflourocarbons (HFCs) ƒ Perflourocarbons (PFCs) ƒ Sulfur Hexaflouride (SF6) Over the last 200 years, humans have caused substantial quantities of GHGs to be released into the atmosphere. These extra emissions are increasing GHG concentrations in the atmosphere, and enhancing the natural greenhouse effect, which is believed to be causing global warming. While manmade GHGs include naturally-occurring GHGs such as CO2, methane, and N2O, some gases, like HFCs, PFCs, and SF6, known collectively as chloro- fluorocarbons (CFCs), are completely new to the atmosphere. Some gases, such as water vapor, are short-lived in the atmosphere. Others remain in the atmosphere for significant periods of time, contributing to climate change in the long term. Water vapor is excluded from the list of GHGs above because it is short-lived in the atmos- phere and its atmospheric concentrations are largely determined by natural processes, such as oceanic evaporation. For the purposes of this EIR, the term “GHGs” will refer collectively to the above six gases only. These gases vary considerably in terms of Global Warming Potential (GWP): the relative effectiveness of a gas to absorb infrared radiation, remain in the atmosphere, and contribute towards global warming. The GWP of each gas is measured relative to carbon dioxide, the most abundant GHG; thus, GHG emissions are typically measured in terms of pounds or tons of “CO2 equivalents” (CO2eq). Table IV.D-5 shows the GWPs for each type of GHG. For example, sulfur hexaflouride is 22,800 times more potent at contributing to global warming than carbon dioxide. The following discussion summarizes the characteristics of the six GHGs listed above. Carbon Dioxide (CO2). In the atmosphere, carbon generally exists in its oxidized form, as CO2. Natural sources of CO2 include the respiration (breathing) of animals and plants, and evaporation from the oceans. Increased CO2 concentrations in the atmosphere have been primarily linked to increased combustion of fossil fuels. Natural sources release approximately 150 billion tons of CO2 each year, far outweighing the 7 billion tons of manmade emissions from fossil fuel burning, waste incineration, deforestation, and other manmade sources. Nevertheless, natural removal processes, such as photosynthesis by N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 181 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Table IV.D-5 Global Warming Potentials Gas Atmospheric Lifetime (Years) Global Warming Potential (100-Year Time Horizon) Carbon Dioxide 50-200 1 Methane 12 25 Nitrous Oxide 114 298 HFC-23 270 14,800 HFC-134a 14 1,430 HFC-152a 1.4 124 PFC: Tetrafluoromethane (CF4) 50,000 7,390 PFC: Hexafluoromethane (C2F6) 10,000 12,200 Sulfur Hexafluoride (SF6) 3,200 22,800 Source: IPCC, 2007. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the Fourth Assessment Report of the IPCC. land- and ocean-dwelling plant species, cannot keep pace with this extra input of manmade CO2, and consequently, the gas is building up in the atmosphere. Fossil fuel combustion accounted for 98 percent of gross California CO2 emissions from manmade sources. California's total CO2 emissions from fossil fuel combustion in 2002 were 360 million metric tons of CO2, which accounts for approximately 7 percent of the U.S. emissions from this source. The transportation sector accounted for the largest portion of CO2 emissions, with gasoline consumption making up the greatest portion of these emissions. Methane (CH4). Methane is produced when organic matter decomposes in environments lacking sufficient oxygen. Natural sources include wetlands, termites, and oceans. Decomposition occurring in landfills accounts for the majority of human-generated CH4 emissions in California and in the United States as a whole. Agricultural processes such as intestinal fermentation, manure management, and rice cultivation are also significant sources of CH4 in California. Methane accounted for approximately 6 percent of gross climate change emissions (CO2eq) in California in 2002. Total annual emissions of methane are approximately 500 million tons, with manmade emissions accounting for the majority. As with CO2, the major removal process of atmospheric methane—chemical breakdown in the atmosphere—cannot keep pace with source emissions, and methane concentrations in the atmosphere are increasing. Nitrous Oxide (N2O). Nitrous oxide is a product of the reaction that occurs between nitrogen and oxygen during fuel combustion. Both mobile and stationary combustion emit 182 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N2O, and the quantity emitted varies according to the type of fuel, technology, and pollution control device used, as well as maintenance and operating practices. Agricultural soil management and fossil fuel combustion are the primary sources of human-generated N2O emissions in California. Nitrous oxide emissions accounted for nearly 7 percent of climate change emissions (CO2eq) in California in 2002. Hydrofluorocarbons (HFCs), Perfluorocarbons (PFCs), and Sulfur Hexafluoride (SF6). HFCs are primarily used as substitutes for ozone-depleting substances regulated under the Montreal Protocol. PFCs and SF6 are generally emitted from various industrial processes including aluminum smelting, semiconductor manufacturing, electric power transmission and distribution, and magnesium casting. There is no aluminum or magnesium production in California; however, the rapid growth in the semiconductor industry leads to greater use of PFCs. HFCs, PFCs, and SF6 accounted for about 3.5 percent of gross climate change emissions (CO2eq) in California. As a result of the combined effects of the GHGs described above, climate studies indicate that California is likely to see a temperature increase of 3 to 4°F over the next century. Because primary GHGs have a long lifetime in the atmosphere, accumulate over time, and are generally well-mixed, their impact on the atmosphere is mostly independent of the point of emission. Climate change refers to any significant change in measures of climate (such as temperature, precipitation, or wind) lasting for an extended period (decades or longer). Climate change may result from: ƒ Natural factors, such as changes in the sun’s intensity or slow changes in the Earth’s orbit around the sun. ƒ Natural processes within the climate system (e.g., changes in ocean circulation and reduction in sunlight from the addition of GHGs and other gases to the atmosphere from volcanic eruptions). ƒ Human activities that change the atmosphere’s composition (e.g., through burning fossil fuels) and the land surface (e.g., from deforestation, reforestation, urbanization, and desertification). The impact of anthropogenic activities on global climate change is readily apparent in the observational record. For example, surface temperature data show that 11 of the 12 years from 1995 to 2006 rank among the 12 warmest since 1850, the beginning of the instrumental record for global surface temperature. In addition, the atmospheric water vapor content has increased since at least the 1980s over land, sea, and in the upper atmosphere, consistent with the capacity of warmer air to hold more water vapor; ocean temperatures are warmer to depths of 3,000 feet; and a marked decline has occurred in N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 183 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 184 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) mountain glaciers and snow pack in both hemispheres, and polar ice and ice sheets in both the Arctic and Antarctic regions. Air trapped by ice has been extracted from core samples taken from polar ice sheets to determine the global atmospheric variation of CO2, CH4 and N2O, from before the start of industrialization (around 1750) to over 650,000 years ago. For that period, it was found that CO2 concentrations ranged from 180 parts per million (ppm) to 300 ppm. For the period from around 1750 to the present, global CO2 concentrations increased from a pre-indust- rialization period concentration of 280 ppm to 379 ppm in 2005, with the 2005 value far exceeding the upper end of the preindustrial period range. The primary effect of global climate change has been a rise in the average global tropo- spheric temperature of 0.2°C per decade, determined from meteorological measurements worldwide between 1990 and 2005. Climate change modeling using 2000 emission rates shows that further warming could occur, which would induce further changes in the global climate system during the current century. Changes to the global climate system, ecosystems, and California would include, but would not be limited to: ƒ The loss of sea ice and mountain snow pack, resulting in higher sea levels and higher sea surface evaporation rates with a corresponding increase in tropospheric water vapor due to the atmosphere’s ability to hold more water vapor at higher temperatures. ƒ Rise in global average sea level primarily due to thermal expansion and melting of glaciers and ice caps in the Greenland and Antarctic ice sheets. ƒ Changes in weather that include widespread changes in precipitation, ocean salinity, and wind patterns, and more energetic aspects of extreme weather, including droughts, heavy precipitation, heat waves, extreme cold, and the intensity of tropical cyclones. ƒ Decline of the Sierra snowpack, which accounts for approximately half of the surface water storage in California, by 70 percent to as much as 90 percent over the next 100 years. ƒ Increase in the number of days conducive to ozone formation by 25 to 85 percent (depending on the future temperature scenario) in high ozone areas of Los Angeles and the San Joaquin Valley by the end of the 21st century; and ƒ High potential for erosion of California’s coastlines and seawater intrusion into the Delta and levee systems due to the rise in sea level. Emissions Inventories. An emissions inventory that identifies and quantifies the primary human-generated sources and sinks of GHGs 7 is essential for addressing climate 7 A GHG sink is a reservoir that accumulates and stores carbon for an indefinite period and is the opposite of a carbon source. Plants, soil, and the oceans can also remove atmospheric CO2 by photosynthesis and other processes. NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY change. This section summarizes the latest information on global, United States, California, and local human-generated GHG emission inventories. Global Emissions. Worldwide emissions of GHGs in 2004 were 30 billion tons of CO2eq per year (including both ongoing emissions from industrial and agricultural sources, but excluding emissions from land-use changes). U.S. Emissions. In 2004, the United States emitted about 8 billion tons of CO2eq or about 25 tons/year/person. Of the four major sectors nationwide — residential, commercial, industrial and transportation — transportation accounts for the highest fraction of GHG emissions (approximately 35 to 40 percent); these emissions are entirely generated from direct fossil fuel combustion. State of California Emissions. In 2004, California emitted approximately 480 million metric tons of CO2eq, or about 6 percent of the U.S. emissions. This large number is due primarily to the sheer size of California compared to other states. By contrast, California has the fourth lowest per-capita carbon dioxide emission rate from fossil fuel combustion in the country, due to the success of its energy-efficiency and renewable energy programs and commitments that have lowered the State’s GHG emissions rate of growth by more than half of what it would have been otherwise. Another factor that has reduced California’s fuel use and GHG emissions is its mild climate compared to that of many other states. The California EPA Climate Action Team stated in its March 2006 report that the compo- sition of gross climate change pollutant emissions in California in 2002 (expressed in terms of CO2eq) were as follows: ƒ Carbon dioxide (CO2) accounted for 83.3 percent; ƒ Methane (CH4) accounted for 6.4 percent; ƒ Nitrous oxide (N2O) accounted for 6.8 percent; and ƒ Fluorinated gases (HFCs, PFC, and SF6) accounted for 3.5 percent. The California Air Resources Board estimates that transportation is the source of approxi- mately 38 percent of the State’s GHG emissions in 2004, followed by electricity generation (both in-State and out-of-State) at 25 percent, and industrial sources at 20 percent. Agri- culture is the source of approximately 6 percent, as are residential and commercial activities. ARB is responsible for developing the California Greenhouse Gas Emission Inventory. This inventory accounts for all GHG emissions within the state of California and supports the AB 32 Climate Change Program. ARB’s current GHG emission inventory is based on State-wide fuel use, processing, and activity data. These estimates are based on the actual amount of N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 185 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY all fuels combusted in the State, which accounts for over 85 percent of the greenhouse gas emissions within California. ARB staff has projected 2020 business-as-usual GHG emissions, which represent the emissions that would be expected to occur in the absence of any GHG reduction actions. ARB staff estimates the State-wide 2020 business-as-usual GHG emissions will be 596 million metric tons (MMT) of CO2eq. Emission reductions that are projected to result from the recommended measures in the Draft Scoping Plan in support of the AB 32 Climate Change Program total 169 MMT of CO2eq, which would allow California to attain the 2020 emissions goal of 427 MMT of CO2eq. GHG emissions in 2020 from the transportation sector as a whole are expected to increase to 225.4 MMT of CO2eq, or approximately 38 percent of the total statewide CO2eq emissions. The industrial sector consists of large stationary sources of GHG emissions and includes oil and gas production and refining facilities, cement plants, and large manufact- uring facilities. Emissions for this sector are forecast to grow to 100.5 MMT of CO2eq by 2020, or 17 percent of the statewide total. The commercial and residential sectors are expected to contribute 46.7 MMT of CO2eq, or about 8 percent of the total State-wide GHG emissions in 2020. Nevada County/Town of Truckee. As of September 2008, greenhouse gas emission inventories were not available for Nevada County and the Town of Truckee (2) Regulatory Framework. The regulatory framework for GHG emissions and global climate change are discussed in this section. Federal Regulations. In February 2002, the United States government announced a comprehensive strategy to reduce the GHG intensity of the American economy by 18 percent over the 10-year period from 2002 to 2012. GHG intensity measures the ratio of GHG emissions to economic output. New and refined technologies offer great promise to reduce GHG emissions significantly. The federal government established the multi-agency Climate Change Technology Program (CCTP) in February 2002 to accelerate the development and deployment of key technologies. In February 2002, the United States government also announced a climate change research initiative to focus on key remaining gaps in climate change science. To meet this goal, the federal multiagency Climate Change Science Program (CCSP) was established to investigate natural and human-induced changes in the Earth’s global environmental system; to monitor, understand, and predict global change; and to provide a sound scientific basis for national and international decision-making. The CCTP works closely with CCSP to make further progress in understanding and addressing global climate change. The United States Environmental Protection Agency’s (EPA’s) primary role in CCSP is evaluating the potential 186 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY consequences of climate variability and the effects on air quality, water quality, ecosystems, and human health in the United States. Currently there are no adopted federal regulations to control global climate change. However, recent authority has been granted to the EPA that may change the voluntary approach currently taken to address this issue. On April 2, 2007, the United States Supreme Court ruled that the EPA has the authority to regulate CO2 emissions under the federal Clean Air Act (CAA). Over a decade ago, most countries joined an international treaty, the United Nations Framework Convention on Climate Change (UNFCCC), to begin to consider what can be done to reduce global warming and to cope with the physical and socioeconomic effects of climate change. More recently, a number of nations have approved an addition to the treaty: the Kyoto Protocol, which has more powerful (and legally binding) measures. Because it will affect virtually all major sectors of the economy, the Kyoto Protocol is considered to be the most far-reaching agreement on environment and sustainable development ever adopted. Most of the world’s countries eventually agreed to the Protocol, but some nations (including the United States) chose not to ratify it. The Kyoto Protocol entered became law on February 16, 2005 for signatory nations. As of July 2008, 182 countries have ratified the agreement. Participating nations are separated into Annex 1 countries (i.e., industrialized nations) and Non-Annex 1 countries (i.e., developing nations) that have different requirements for GHG reductions. The goal of the Protocol is to achieve overall emissions reduction targets for six GHGs by 2012. The six GHGs regulated under the Protocol are CO2, CH4, N2O, sulfur hexafluoride, hydrofluoro- carbons, and perfluorocarbons. Each nation must reduce GHG emissions by a certain percentage below 1990 levels (e.g., 8 percent reduction for the European Union, 6 percent reduction for Japan). The average reduction target for nations participating in the Kyoto Protocol is approximately 5 percent below 1990 levels. Although the United States has not ratified the Protocol, on February 14, 2002, it established a goal of an 18 percent reduction in GHG emissions intensity by 2012. GHG intensity is the ratio of GHG emissions to economic output (i.e., gross domestic product). State Regulations. In 1967, the California Legislature passed the Mulford-Carrell Act, which combined two Department of Health bureaus, the Bureau of Air Sanitation and the Motor Vehicle Pollution Control Board, to establish the Air Resources Board (ARB). Since its formation, the ARB has worked with the public, the business sector, and local governments to find solutions to California’s air pollution problems. The resulting State air quality standards set by the ARB continue to outpace the rest of the nation and have prompted the development of new antismog technology for industrial facilities and motor vehicles. N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 187 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 188 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) California’s major initiatives for reducing GHG emissions are outlined in Assembly Bill 32 (AB 32), the “Global Warming Solutions Act,” passed by the California State legislature on August 31, 2006, a 2005 Executive Order, and a 2004 ARB regulation to reduce passenger car GHG emissions. These efforts aim at reducing GHG emissions to 1990 levels by 2020, a reduction of approximately 25 percent, and then an 80 percent reduction below 1990 levels by 2050. The ARB has established the level of GHG emissions in 1990 at 427 million metric tons (MMT) of CO2eq, therefore requiring a reduction of approximately 173 MMT of CO2eq by 2020. The main strategies for attaining these reductions are outlined in the Scoping Plan, which when completed will include a range of GHG reduction actions that may include direct regulations, alternative compliance mechanisms, monetary and non-monetary incentives, voluntary actions, and market-based mechanisms such as a cap-and-trade system. In June 2005, Governor Schwarzenegger established California’s GHG emissions reduction targets in Executive Order S-3-05. The Executive Order established the following goals: GHG emissions should be reduced to 2000 levels by 2010; GHG emissions should be reduced to 1990 levels by 2020; and GHG emissions should be reduced to 80 percent below 1990 levels by 2050. On January 18, 2007, California further solidified its dedication to reducing GHGs by setting a new Low Carbon Fuel Standard for transportation fuels sold within the State. Executive Order S-1-07 sets a declining standard for GHG emissions measured in CO2 equivalent gram per unit of fuel energy sold in California. The target of the Low Carbon Fuel Standard is to reduce the carbon intensity of California transportation fuels by at least 10 percent by 2020. Pursuant to the requirements of AB 32, the State’s reduction in GHG emissions will be accomplished through an enforceable State-wide cap on GHG emissions that will be phased- in starting in 2012. ARB must prepare a plan demonstrating how the 2020 deadline can be met by January 1, 2009, or earlier. However, as immediate progress in reducing GHGs can and should be made, AB 32 directed ARB and the newly created Climate Action Team (CAT) to identify a list of “discrete early action GHG reduction measures” that can be adopted and made enforceable by January 1, 2010. CAT is a consortium of representatives from State agencies who have been charged with coordinating and implementing GHG emission reduction programs that fall outside of ARB’s jurisdiction. In June 2007 ARB approved a list of 37 early action measures, including three discrete early action measures (Low Carbon Fuel Standard, Restrictions on High Global Warming Potential Refrigerants, and Landfill Methane Capture). 8 The ARB adopted additional early action measures in October 2007 that tripled the number of discrete early action measures, including Smartway truck efficiency, Port electrification, reduction of perfluorocarbons from the semiconductor industry, reduction of propellants in consumer products, proper tire 8 California Air Resources Board. 2007. Expanded List of Early Action Measures to Reduce Greenhouse Gas Emissions in California Recommended for Board Consideration. October. NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 189 inflation, and sulfur hexafluoride (SF6) reductions from the non-electricity sector. The combination of early action measures is estimated to reduce statewide greenhouse gas emissions by nearly 16 million metric tons.9 Specific policies included in the ARB’s October 2007 Early Action Measure report that are relevant to this project include 10 : ƒ Guidance and Protocols for Local Governments to Facilitate GHG Emission Reductions. Local governments have the power to affect the main sources of pollution directly linked to climate change through infrastructure investments, land use decisions, building codes, and municipal service management. Development of a State guidance document and local government protocols is needed to encourage and support greater and coordinated local action statewide. ƒ Cool Communities Program. Develop research and real-world experience-based guidelines on actions that could be taken, documenting options, costs, and benefits. This would be a non-regulatory voluntary program with a set of guidelines to be adopted to foster the establishment or transition to cool communities in California. Programs for cool roofs, cool pavements, and shade trees and urban forests would be considered by ARB for implementation. ƒ Anti-Idling Enforcement. ARB adopted a diesel particulate air toxic control measure in June 2004 to control idling of diesel-fueled commercial motor vehicles. Enforcement commenced the following year. This rule prohibits, with some exceptions, the idling of diesel-fueled commercial motor vehicles for more than five minutes, and applies to both trucks and buses greater than 10,000 lbs. gross vehicle weight. AB 32 requires ARB to prepare a Scoping Plan that contains the main strategies California will use to reduce the GHGs that cause climate change. In June 2008 ARB released an initial draft of the Scoping Plan, including the following relevant measures 11 : ƒ Energy Efficiency. Maximize energy efficiency building and appliance standards, and pursue additional efficiency efforts. Reductions could be achieved through enhancements to existing programs such as increased incentives and even more stringent building codes and appliance efficiency standards. In addition, the use of solar water heaters can reduce natural gas use in homes and businesses. 9 California Air Resources Board. 2007. “ARB approves tripling of early action measures required under AB 32”. New Release 07-46. http://www.arb.ca.gov/newsrel/nr102507.htm. October 25. 10 California Air Resources Board. 2007. Expanded List of Early Action Measures to Reduce Greenhouse Gas Emissions in California Recommended for Board Consideration. October. 11 California Air Resources Board. 2008. Climate Change Draft Scoping Plan: a framework for change. June. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Buildings are the second largest contributor to California’s greenhouse gas emissions. Green buildings offer a comprehensive approach to reducing greenhouse gas emissions that cross-cut multiple sectors including Energy, Water, Waste, and Transportation. Green buildings exceed minimum energy efficiency standards, decrease consumption of potable water, reduce solid waste during construction and operation, and incorporate sustainable and low-emitting materials that contribute to healthy indoor air quality ƒ Local Government Actions and Regional Targets. Encourage local governments to set quantifiable emission reduction targets for their jurisdictions; recommend regional greenhouse gas emission reduction targets. The actions that local governments take individually, and through local and regional planning processes, can reduce greenhouse gas emissions associated with transportation, energy, waste/recycling, and water use. Local governments should build on existing strategies and adopt best practices to achieve greenhouse gas reductions through Community Energy, Community Waste and Recycling, Community Water and Wastewater Systems, Community Transportation, and Community Design. Further discussion and analysis of these, and additional greenhouse gas reduction measures in relation to the project is presented in Table IV.D-11. To address GHG emission and global climate change in General Plans and CEQA documents, Senate Bill 97 (Chapter 185, 2007) requires the Governor’s Office of Planning and Research (OPR) to develop CEQA guidelines on how to address global warming emissions and mitigate project-specific GHG. OPR is required to prepare, develop, and transmit these guidelines on or before July 1, 2009. Until such a plan has been adopted, direction for evaluation of and potential mitigation for incremental project impacts to global warming is not available. Because the transportation sector accounts for more than half of California’s CO2 emissions, the California State Assembly enacted Assembly Bill 1493 (AB 1493, Pavley) was enacted on July 22, 2002. AB 1493 requires ARB to set GHG emission standards for passenger vehicles, light duty trucks, and other vehicles determined to be vehicles whose primary use is noncommercial personal transportation in the State manufactured in 2009 and all subsequent model years. In setting these standards, the ARB considered cost effectiveness, technological feasibility, and economic impacts. ARB adopted the standards in September 2004. When fully phased in, the near-term (2009 to 2012) standards would result in a reduction of approximately 22 percent in GHG emissions compared to the emissions from the 2002 fleet, while the midterm (2013 to 2016) standards would result in a reduction of approximately 30 percent. Some currently used technologies that achieve GHG reductions include small engines with superchargers, continuously variable transmissions, and hybrid electric drive. To set its own GHG emissions limits on motor vehicles, California must receive a waiver from the EPA. However, in December 2007, the 190 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 191 EPA denied the request from California for the waiver. In January 2008, the California Attorney General filed a petition for review of the EPA’s decision in the Ninth Circuit Court of Appeals, though no decision on that petition has been made. Thus, California cannot implement AB 1493 at this time. Local Policies. As indicated earlier in this chapter, the Town of Truckee has numerous policies that are related to improving air quality. The Town of Truckee General Plan contains over 100 policies that would have a positive impact on air quality and reduction of emissions, including policies that focus on bicycle and pedestrian programs, mixed-use and open space development, transit, and transportation control measures. 2. Relevant Railyard Draft Master Plan Policies The Draft Master Plan does not include specific polices related to air quality. 3. Impacts and Mitigation Measures This section evaluates potential impacts to air quality resulting from implementation of the proposed project. The evaluation of environmental effects presented in this section focuses on consistency with air quality management plans, and potential air quality impacts associated with construction emissions, odors, and development-related traffic emissions. Mitigation measures are proposed as appropriate. a. Criteria of Significance. (1) Air Quality. Implementation of the project would have a significant impact on air quality if it would: ƒ Violate any air quality standard (including the policies and standards of the Particulate Matter Air Quality Management Plan of the Town of Truckee) or contribute substantially to an existing or projected air quality violation. ƒ Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). ƒ Expose sensitive receptors to substantial pollutant concentrations. ƒ Frequently create substantial objectionable odors affecting a substantial number of people. ƒ Contribute to CO concentrations exceeding the State AAQS of 9 ppm averaged over 8 hours and 20 ppm for 1 hour. ƒ Result in total emissions of ROG, NOx, or PM10 that exceed 136 lbs/day. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 192 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) ƒ Result in potential to expose persons to substantial levels of Toxic Air Contaminants (TAC), such that the probability of contracting cancer for the Maximally Exposed Individual (MEI) exceeds 10 in one million. ƒ Result in ground level concentrations of non-carcinogenic TACs such that the Hazard Index would be greater than 1 for the MEI. (2) Global Climate Change. Increasing public awareness and general scientific consensus regarding global climate change have placed a new focus on the California Environmental Quality Act (CEQA) as a means to address a project’s effects on greenhouse gas emissions. CEQA requires that lead agencies consider the reasonably foreseeable adverse environmental effects of projects considered for approval. According to recent letters from California’s Office of the Attorney General,12 global climate change can be considered an “effect on the environment” and an individual project’s incremental contribution to global climate change can have a cumulatively considerable impact Cumulative impacts are the collective impacts of one or more past, present, or future projects, that when combined, result in adverse changes to the environment. Climate change is a global environmental problem in which (a) any given development project contributes only a small portion of any net increase in GHGs and (b) global growth is con- tinuing to contribute large amounts of GHGs across the globe. Therefore, this study addresses climate change as a cumulative impact. The evaluation of environmental effects presented in this section focuses on potential climate change impacts associated with the project’s increase in GHG emissions. Mitigation measures are proposed as necessary. There is no CEQA statute, regulation, or judicial decision that requires an EIR to analyze the GHG emissions of a project, or whether a project will have a significant impact on global warming. Senate Bill 97 directs OPR to develop CEQA Guidelines to address GHG emissions, and to adopt these Guidelines by January 1, 2010. OPR has not issued any formal regulations as of September 2008. However, OPR did issue informal guidance in the form of a Technical Advisory in June 2008 on how to address climate change through CEQA review. The recommended approach for GHG analysis included in OPR’s June 2008 release is to (1) identify and quantify GHG emissions, (2) assess the significance of the impact on climate change, and (3) if significant, identify alternatives and/or mitigation measures to reduce the impact below significance. Neither the CEQA statute nor Guidelines prescribe thresholds of significance or a particular methodology for performing an impact analysis, and no State agency or local air quality 12 State of California. Department of Justice. 2008. Comment letter to the City of Concord re “Concord Community Reuse Plan Draft Environmental Impact Report – SCH #2007052094.” August 8. NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY management district has issued any regulations or standards of significance for the analysis of GHGs under CEQA; as with most environmental topics, significance criteria are left to the judgment and discretion of the lead agency. Land use projects may contribute to the phenomenon of global climate change in ways that would be experienced worldwide, and with some specific effects felt in California. However, no scientific study has established a direct causal link between individual land use project impacts and global warming. AB 32 requires State-wide GHG emissions to be reduced to 1990 levels by 2020. Although these State-wide reductions are now mandated by law, no generally applicable GHG emission threshold has yet been established, nor is formal regulatory agency guidance on global climate change analysis in CEQA documents anticipated to be available until mid-2009. CEQA Guidelines Section 15064(b) provides that the “determination of whether a project may have a significant effect on the environment calls for careful judgment on the part of the public agency involved, based to the extent possible on scientific and factual data,” and further, states that an “ironclad definition of significant effect is not always possible because the significance of an activity may vary with the setting.” Some policy makers and regulators suggest that a zero emissions threshold would be appropriate when evaluating GHGs and their potential effect on climate change. However, most feel that such an absolute threshold would be analytically impractical and would interfere with the ability of the economy to function. Further, prior CEQA case law makes clear that the “one additional molecule” rule is not consistent with CEQA. Such a rule also appears inconsistent with the State’s approach to mitigation of climate change impacts. AB 32 does not prohibit all new GHG emissions; rather, it requires a reduction in State-wide emissions to a given level. Thus, AB 32 recognizes that GHG emissions will continue to occur; increases will result from certain activities, but reductions must occur elsewhere. Bearing in mind that CEQA does not require “perfection” but instead “adequacy, completeness, and a good faith effort at full disclosure,” the analysis below is based on methodologies and information available to the City at the time the study was prepared. Estimation of GHG emissions in the future does not account for all changes in technology that may reduce such emissions; therefore, the estimates are based on past performance and represent a scenario that is worse than that which is likely to be encountered (after energy-efficient technologies have been implemented). Additionally, as explained in greater detail below, many uncertainties exist regarding the precise relationship between specific levels of GHG emissions and the ultimate impact on the global climate. Significant uncertainties also exist regarding potential mitigation strategies. Thus, while information is presented below to assist the public and the City’s decision makers in understanding the project’s potential contribution to global climate change impacts, a direct comparison between particular project characteristics and particular climate change impacts is not N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 193 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 194 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) possible, nor can a quantifiable relationship be established between any particular proposed mitigation measure and any reduction in climate change impacts. Because no applicable numeric thresholds have yet been defined, and because the precise causal link between an individual project’s emissions and global climate change has not been developed, it is reasonable to conclude that an individual development project cannot generate a high enough quantity of GHG emissions to affect global climate change. However, individual projects incrementally contribute toward the potential for global climate change on a cumulative basis in concert with all other past, present, and reasonably foreseeable future projects. This study identifies qualitative factors to determine whether this project’s emissions should be considered cumulatively significant. Until regulatory agencies devise a generally applicable climate change threshold, the analysis used in this study may or may not be applicable to other projects within the Town of Truckee. This report analyzes whether the project has a cumulatively significant contribution to the impact of global climate change under the following qualitative standard: ƒ Whether the proposed project conflicts with or obstructs the implementation of green- house gas reduction measures under AB 32 or other state regulations. If a project implements reduction strategies identified in AB 32, the Governor’s Executive Order S-3-05, or other strategies to help toward reducing GHGs to the level proposed by the Governor, it could reasonably follow that the project would not result in a significant contribution to the cumulative impact of global climate change. b. Less-Than-Significant Air Quality Impacts. This section discusses less-than- significant air quality impacts. (1) (2) Odor Emissions. Heavy-duty equipment in the Plan Area during construction would emit odors. However, the construction activity would be short-term and would cease to occur after individual construction is completed. No other sources of objectionable odors have been identified for the proposed project and no mitigation measures are required. Operational Emissions – CO Analysis. Vehicular traffic associated with the proposed project would emit carbon monoxide (CO) into the air along roadway segments and near intersections. Because CO does not readily disperse, areas of vehicle congestion can create pockets of high CO concentrations, called “hot spots.” Typically, high CO concentrations are associated with roadways or intersections operating at deficient levels of service (LOS) or with extremely high traffic volumes. Table IV.D-6 lists the existing baseline conditions No Project and Plus Project concentrations. Table IV.D-7 lists the cumulative (year 2025) No Project and Plus Project CO concentrations for the studied intersections. NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 195 Based on the methodology suggested by the U.S. EPA and the California Department of Transportation, the second highest CO concentrations monitored at the nearest air monitoring station in the past two years (in this case 3.4 ppm for the 1-hour period and 2.6 ppm for the 8-hour period) were used as the background CO concentrations. Emission factors for study scenarios were obtained from the latest ARB data. Results shown in Table IV.D-6 indicate that all of the existing baseline No Project and Plus Project 1-hour and 8-hour CO concentrations would be below the federal and State CO standards. The 1-hour CO levels range from 4.1 ppm to 8.1 ppm, which is less than half of the State CO standard of 20 ppm. The 8-hour CO levels range from 3.1 ppm to 5.9 ppm, which is also lower then the State and federal standard of 9 ppm. Modeled input values are included in the Appendix D. Table IV.D-7 shows that all of the cumulative conditions for the year 2025 No Project and Plus Project 1-hour and 8-hour CO concentrations would be below the federal and State CO standards. The 1-hour CO levels range from 3.6 ppm to 4.8 ppm, which is less than half of the State CO standard of 20 ppm. The 8-hour CO levels range from 2.7 ppm to 3.6 ppm, which is also lower then the State and federal standard of 9 ppm. Results indicate that CO concentrations would increase by less than 1 ppm with implementation of the proposed project. Implementation of the proposed project would not cause an exceedance of State or federal CO standards. Therefore, the proposed project would not lead to significant CO impacts and no mitigation is required. (3) Mobile Source Toxic Air Contaminants. LSA Associates, Inc. completed a health risk analysis for the proposed project. The analysis considered specific meteorological conditions in the Plan Area and the proximity of existing and future residences to the adjacent railroad tracks. The analysis assumes individual inhalation of 100 percent outdoor air at that location for 70 years (residing outside the residence 350 days of every year and 24-hours each day). A report to the Air Resources Board in 1998 acknowledges that people spend a majority of time indoors, and that to accurately estimate the population’s exposure to toxic air pollutants, risk assessors must consider the amount of time people spend in different environments. The report found that toxic air concentrations were more than one third less in residences and schools, and almost one half less in offices as compared to outdoor areas.13 Therefore, results of the health risk assessment present a conservative analysis of potential health risks. 13 Krieger, Robert K., D. Ames, J. Brooks, G. Shiroma, and P. Venturini, 1998. Report to the Air Resources Board on the Proposed Identification of Diesel Exhaust as a Toxic Air Contaminant, Part A, Exposure Assessment. April 22. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 196 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) Table IV.D-6 Existing Baseline No Project and Plus Project CO Concentrations Intersection Receptor Distance to Road Centerline (Meters) Project Related Increase 1-hr/8-hr (ppm) No Project/Plus Project 1-Hour CO Concentration (ppm) No Project/Plus Project 8- Hour CO Concentration (ppm) Exceeds State Standards 1-Hr 8-Hr SR 89 South and West River Street 14 0.2 / 0.2 6.3 / 6.5 4.6 / 4.8 No No 12 0.2 / 0.2 6.3 / 6.5 4.6 / 4.8 No No 12 0.3 / 0.2 6.2 / 6.5 4.6 / 4.8 No No 12 0.2 / 0.1 6.2 / 6.4 4.6 / 4.7 No No McIver Crossing and West River Street 14 0.3 / 0.3 5.6 / 5.9 4.1 / 4.4 No No 14 0.3 / 0.2 5.5 / 5.8 4.1 / 4.3 No No 14 0.3 / 0.2 5.5 / 5.8 4.1 / 4.3 No No 14 0.3 / 0.2 5.3 / 5.6 3.9 / 4.1 No No Donner Pass Road and McIver Crossing 8 0.2 / 0.2 6.7 / 6.9 4.9 / 5.1 No No 8 0.2 / 0.1 6.5 / 6.7 4.8 / 4.9 No No 8 0.2 / 0.1 6.4 / 6.6 4.7 / 4.8 No No 8 0.3 / 0.2 6.3 / 6.6 4.6 / 4.8 No No Spring Street and Donner Pass Road 13 0.3 / 0.2 6.0 / 6.3 4.4 / 4.6 No No 10 0.2 / 0.1 5.9 / 6.1 4.4 / 4.5 No No 10 0.3 / 0.2 5.8 / 6.1 4.3 / 4.5 No No 10 0.2 / 0.1 5.8 / 6.0 4.3 / 4.4 No No Bridge Street and Donner Pass Road 14 0.7 / 0.5 6.3 / 7.0 4.6 / 5.1 No No 14 0.7 / 0.5 6.1 / 6.8 4.5 / 5.0 No No 14 0.5 / 0.3 6.1 / 6.6 4.5 / 4.8 No No 14 0.5 / 0.4 6.0 / 6.5 4.4 / 4.8 No No Bridge Street and Church Street 10 0.4 / 0.2 4.2 / 4.6 3.2 / 3.4 No No 10 0.4 / 0.3 4.1 / 4.5 3.1 / 3.4 No No 10 0.4 / 0.3 4.1 / 4.5 3.1 / 3.4 No No 10 0.4 / 0.3 4.1 / 4.5 3.1 / 3.4 No No Bridge Street and Jibboom Street 10 0.1 / 0.1 4.6 / 4.7 3.4 / 3.5 No No 10 0.1 / 0.1 4.6 / 4.7 3.4 / 3.5 No No 8 0.2 / 0.2 4.3 / 4.5 3.2 / 3.4 No No 8 0.2 / 0.2 4.3 / 4.5 3.2 / 3.4 No No Donner Pass Road and Church Street 8 0.5 / 0.4 4.7 / 5.2 3.5 / 3.9 No No 8 0.4 / 0.3 4.7 / 5.1 3.5 / 3.8 No No 8 0.4 / 0.3 4.6 / 5.0 3.4 / 3.7 No No 8 0.4 / 0.3 4.6 / 5.0 3.4 / 3.7 No No Donner Pass Road and Keiser Street 10 0.2 / 0.2 4.7 / 4.9 3.5 / 3.7 No No 10 0.3 / 0.3 4.6 / 4.9 3.4 / 3.7 No No 10 0.2 / 0.2 4.6 / 4.8 3.4 / 3.6 No No 10 0.2 / 0.2 4.6 / 4.8 3.4 / 3.6 No No Glenshire Drive and Donner Pass Road 12 0.4 / 0.3 5.8 / 6.2 4.3 / 4.6 No No 12 0.3 / 0.2 5.5 / 5.8 4.1 / 4.3 No No 12 0.3 / 0.2 5.4 / 5.7 4.0 / 4.2 No No 10 0.4 / 0.3 5.3 / 5.7 3.9 / 4.2 No No Donner Pass Road and Pioneer Trail 12 0.2 / 0.2 5.7 / 5.9 4.2 / 4.4 No No 12 0.2 / 0.2 5.6 / 5.8 4.1 / 4.3 No No 12 0.1 / 0.0 5.5 / 5.6 4.1 / 4.1 No No 10 0.1 / 0.0 5.5 / 5.6 4.1 / 4.1 No No NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 197 Intersection Receptor Distance to Road Centerline (Meters) Project Related Increase 1-hr/8-hr (ppm) No Project/Plus Project 1-Hour CO Concentration (ppm) No Project/Plus Project 8- Hour CO Concentration (ppm) Exceeds State Standards 1-Hr 8-Hr Bridge Street and West River Street 14 0.3 / 0.2 6.4 / 6.7 4.7 / 4.9 No No 14 0.3 / 0.2 6.1 / 6.4 4.5 / 4.7 No No 14 0.3 / 0.2 6.0 / 6.3 4.4 / 4.6 No No 14 0.2 / 0.1 5.9 / 6.1 4.4 / 4.5 No No Palisades Drive and Brockway Road 14 0.5 / 0.4 7.0 / 7.5 5.1 / 5.5 No No 14 0.3 / 0.2 6.9 / 7.2 5.1 / 5.3 No No 14 0.5 / 0.4 6.6 / 7.1 4.8 / 5.2 No No 14 0.6 / 0.5 6.3 / 6.9 4.6 / 5.1 No No Martis Valley Road and Brockway Road 8 0.2 / 0.1 5.8 / 6.0 4.3 / 4.4 No No 8 0.2 / 0.2 5.6 / 5.8 4.1 / 4.3 No No 8 0.2 / 0.2 5.6 / 5.8 4.1 / 4.3 No No 8 0.2 / 0.1 5.4 / 5.6 4.0 / 4.1 No No SR 267 and Soaring Way 14 0.2 / 0.1 7.9 / 8.1 5.8 / 5.9 No No 14 0.2 / 0.1 7.8 / 8.0 5.7 / 5.8 No No 14 0.1 / 0.1 7.7 / 7.8 5.6 / 5.7 No No 14 0.1 / 0.1 7.7 / 7.8 5.6 / 5.7 No No SR 267 and Schaffer Mill Road 14 0.2 / 0.2 7.6 / 7.8 5.5 / 5.7 No No 14 0.2 / 0.1 7.4 / 7.6 5.4 / 5.5 No No 14 0.1 / 0.0 7.2 / 7.3 5.3 / 5.3 No No 14 0.1 / 0.0 7.2 / 7.3 5.3 / 5.3 No No SR 267 and Northstar Drive 12 0.2 / 0.1 6.2 / 6.4 4.6 / 4.7 No No 12 0.2 / 0.2 6.0 / 6.2 4.4 / 4.6 No No 10 0.1 / 0.0 5.9 / 6.0 4.4 / 4.4 No No 10 0.1 / 0.1 5.8 / 5.9 4.3 / 4.4 No No SR 267 and SR 28 EB Ramps 17 0.1 / 0.0 6.9 / 7.0 5.1 / 5.1 No No 17 -0.1 / -0.1 6.7 / 6.6 4.9 / 4.8 No No 16 0.1 / 0.0 6.5 / 6.6 4.8 / 4.8 No No 16 0.2 / 0.2 6.3 / 6.5 4.6 / 4.8 No No Donner Pass Road and Donner Pass Road Extension 14 -0.4 / -0.3 6.0 / 5.6 4.4 / 4.1 No No 14 -0.3 / -0.2 5.8 / 5.5 4.3 / 4.1 No No 14 -0.6 / -0.4 5.8 / 5.2 4.3 / 3.9 No No 14 -0.2 / -0.1 5.4 / 5.2 4.0 / 3.9 No No Donner Pass Road Extension and Glenshire Drive 14 0.4 / 0.2 5.2 / 5.6 3.9 / 4.1 No No 14 0.1 / 0.1 5.1 / 5.2 3.8 / 3.9 No No 14 0.3 / 0.2 4.9 / 5.2 3.7 / 3.9 No No 12 0.3 / 0.2 4.9 / 5.2 3.7 / 3.9 No No Note: Includes ambient one-hour concentration of 3.4 ppm and ambient eight-hour concentration of 2.6 ppm. Measured at the 468 Manzanita Ave, Chico, CA AQ Station in Butte County. The State one-hour standard is 20 ppm and the eight-hour standard is 9 ppm. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Table IV.D-7 Cumulative 2025 No Project and Plus Project CO Concentrations Receptor Distance to Road Centerline (Meters) Project Related Increase 1-hr/8-hr (ppm) No Project/Plus Project One- Hour CO Concentration (ppm) No Project/Plus Project Eight- Hour CO Concentration (ppm) Exceeds State Standards Intersection 1-Hr 8-Hr 14 0.0 / 0.0 4.1 / 4.1 3.1 / 3.1 No No 14 0.1 / 0.1 4.0 / 4.1 3.0 / 3.1 No No SR 89 South and West River Street 12 0.0 / 0.0 4.0 / 4.0 3.0 / 3.0 No No 12 0.0 / 0.0 4.0 / 4.0 3.0 / 3.0 No No 14 0.1 / 0.1 3.8 / 3.9 2.9 / 3.0 No No 14 0.0 / 0.0 3.8 / 3.8 2.9 / 2.9 No No McIver Crossing and West River Street 14 0.0 / 0.0 3.8 / 3.8 2.9 / 2.9 No No 14 0.0 / 0.0 3.8 / 3.8 2.9 / 2.9 No No 8 0.1 / 0.0 3.9 / 4.0 3.0 / 3.0 No No 8 0.0 / 0.0 3.9 / 3.9 3.0 / 3.0 No No Donner Pass Road and McIver Crossing 8 0.0 / 0.0 3.9 / 3.9 3.0 / 3.0 No No 8 0.0 / 0.0 3.9 / 3.9 3.0 / 3.0 No No 13 0.0 / 0.0 3.8 / 3.8 2.9 / 2.9 No No 12 0.0 / 0.0 3.8 / 3.8 2.9 / 2.9 No No Spring Street and Donner Pass Road 10 0.0 / 0.0 3.8 / 3.8 2.9 / 2.9 No No 10 0.0 / 0.0 3.8 / 3.8 2.9 / 2.9 No No 14 -0.1 / -0.1 4.1 / 4.0 3.1 / 3.0 No No 14 -0.2 / -0.1 4.1 / 3.9 3.1 / 3.0 No No Bridge Street and Donner Pass Road 14 -0.1 / 0.0 4.0 / 3.9 3.0 / 3.0 No No 14 -0.1 / 0.0 4.0 / 3.9 3.0 / 3.0 No No 10 -0.1 / -0.1 3.8 / 3.7 2.9 / 2.8 No No 10 0.0 / 0.0 3.7 / 3.7 2.8 / 2.8 No No Bridge Street and Church Street 10 0.0 / 0.0 3.7 / 3.7 2.8 / 2.8 No No 10 0.0 / 0.0 3.7 / 3.7 2.8 / 2.8 No No 8 -0.1 / -0.1 3.9 / 3.8 3.0 / 2.9 No No 8 0.0 / 0.0 3.8 / 3.8 2.9 / 2.9 No No Bridge Street and Jibboom Street 8 0.0 / 0.0 3.8 / 3.8 2.9 / 2.9 No No 8 0.0 / 0.0 3.8 / 3.8 2.9 / 2.9 No No 8 -0.2 / -0.1 3.7 / 3.5 2.8 / 2.7 No No 8 -0.1 / 0.0 3.6 / 3.5 2.7 / 2.7 No No Donner Pass Road and Church Street 8 -0.1 / 0.0 3.6 / 3.5 2.7 / 2.7 No No 8 -0.1 / 0.0 3.6 / 3.5 2.7 / 2.7 No No 10 0.0 / 0.0 3.7 / 3.7 2.8 / 2.8 No No 10 -0.1 / -0.1 3.7 / 3.6 2.8 / 2.7 No No Donner Pass Road and Keiser Street 10 0.0 / 0.0 3.6 / 3.6 2.7 / 2.7 No No 10 0.0 / 0.0 3.6 / 3.6 2.7 / 2.7 No No 12 -0.1 / -0.1 4.1 / 4.0 3.1 / 3.0 No No 12 -0.1 / 0.0 4.0 / 3.9 3.0 / 3.0 No No Glenshire Drive and Donner Pass Road 12 -0.1 / 0.0 4.0 / 3.9 3.0 / 3.0 No No 10 0.0 / 0.0 3.9 / 3.9 3.0 / 3.0 No No 14 0.0 / 0.0 4.3 / 4.3 3.2 / 3.2 No No 14 0.0 / 0.0 4.3 / 4.3 3.2 / 3.2 No No Donner Pass Road and Pioneer Trail 14 -0.1 / 0.0 4.3 / 4.2 3.2 / 3.2 No No 14 0.0 / 0.0 4.2 / 4.2 3.2 / 3.2 No No 8 -0.1 / 0.0 4.6 / 4.5 3.4 / 3.4 No No 8 0.0 / 0.0 4.5 / 4.5 3.4 / 3.4 No No SR 89 North and Donner Pass Road 8 -0.1 / -0.1 4.4 / 4.3 3.3 / 3.2 No No 8 0.0 / 0.0 4.3 / 4.3 3.2 / 3.2 No No 198 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 199 Intersection Receptor Distance to Road Centerline (Meters) Project Related Increase 1-hr/8-hr (ppm) No Project/Plus Project One- Hour CO Concentration (ppm) No Project/Plus Project Eight- Hour CO Concentration (ppm) Exceeds State Standards 1-Hr 8-Hr Bridge Street and West River Street 14 0.0 / 0.0 4.1 / 4.1 3.1 / 3.1 No No 14 -0.1 / -0.1 4.1 / 4.0 3.1 / 3.0 No No 14 -0.1 / -0.1 4.1 / 4.0 3.1 / 3.0 No No 14 0.0 / 0.0 4.0 / 4.0 3.0 / 3.0 No No Palisades Drive and Brockway Road 12 -0.1 / 0.0 4.3 / 4.2 3.2 / 3.2 No No 12 0.0 / 0.0 4.2 / 4.2 3.2 / 3.2 No No 10 0.0 / 0.0 4.2 / 4.2 3.2 / 3.2 No No 10 0.0 / 0.0 4.1 / 4.1 3.1 / 3.1 No No Martis Valley Road and Brockway Road 8 0.0 / 0.0 4.1 / 4.1 3.1 / 3.1 No No 8 0.0 / 0.0 4.1 / 4.1 3.1 / 3.1 No No 8 0.0 / 0.0 4.1 / 4.1 3.1 / 3.1 No No 8 0.0 / 0.0 4.1 / 4.1 3.1 / 3.1 No No SR 267 and Soaring Way 14 -0.1 / -0.1 4.8 / 4.7 3.6 / 3.5 No No 14 -0.1 / -0.1 4.8 / 4.7 3.6 / 3.5 No No 14 0.0 / 0.0 4.7 / 4.7 3.5 / 3.5 No No 14 0.0 / 0.0 4.7 / 4.7 3.5 / 3.5 No No SR 267 and Schaffer Mill Road 14 -0.1 / -0.1 4.5 / 4.4 3.4 / 3.3 No No 14 0.0 / 0.0 4.4 / 4.4 3.3 / 3.3 No No 14 0.0 / 0.0 4.4 / 4.4 3.3 / 3.3 No No 14 0.0 / 0.0 4.4 / 4.4 3.3 / 3.3 No No SR 267 and Northstar Drive 12 0.0 / 0.0 4.3 / 4.3 3.2 / 3.2 No No 12 0.0 / 0.0 4.2 / 4.2 3.2 / 3.2 No No 10 0.0 / 0.0 4.2 / 4.2 3.2 / 3.2 No No 10 -0.1 / -0.1 4.2 / 4.1 3.2 / 3.1 No No SR 267 and SR 28 EB Ramps 17 0.0 / 0.0 4.1 / 4.1 3.1 / 3.1 No No 17 0.0 / 0.0 4.1 / 4.1 3.1 / 3.1 No No 16 0.0 / 0.0 4.0 / 4.0 3.0 / 3.0 No No 16 0.0 / 0.0 4.0 / 4.0 3.0 / 3.0 No No Donner Pass Road and Donner Pass Road Extension 14 0.0 / 0.0 3.6 / 3.6 2.7 / 2.7 No No 14 0.0 / 0.0 3.6 / 3.6 2.7 / 2.7 No No 14 -0.1 / 0.0 3.6 / 3.5 2.7 / 2.7 No No 12 -0.1 / 0.0 3.6 / 3.5 2.7 / 2.7 No No Donner Pass Road Extension and Glenshire Drive 10 -0.1 / 0.0 4.0 / 3.9 3.0 / 3.0 No No 10 -0.1 / 0.0 4.0 / 3.9 3.0 / 3.0 No No 10 -0.1 / 0.0 4.0 / 3.9 3.0 / 3.0 No No 10 -0.1 / 0.0 4.0 / 3.9 3.0 / 3.0 No No Note: Includes ambient 1-hour concentration of 3.4 ppm and ambient 8-hour concentration of 2.6 ppm. Measured at the 468 Manzanita Ave, Chico, CA AQ Station in Butte County. The State 1-hour standard is 20 ppm and the 8- hour standard is 9 ppm. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 200 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) (4) (5) General Health Risks of Toxics. Determining how hazardous a substance is depends on many factors, including the amount of the substance in the air, how it enters the body, how long the exposure lasts, and what organs in the body are affected. One major way these substances enter the body is through inhalation of either gases or particulates. While many gases are harmful, very small particles penetrate deep into the lungs, contributing to a range of health problems. Exhaust from diesel engines is a major source of these airborne particles. California’s Office of Environmental Health Hazard Assessment (OEHHA) has determined that long-term exposure to diesel exhaust particulates poses the highest cancer risk of any toxic air contaminant it has evaluated. Fortunately, improvements to diesel fuel and diesel engines have already reduced emissions of some of the contaminants, which, when fully implemented, will result in a 75 percent reduction in particle emissions from diesel-powered trucks and other equipment by 2010 (compared to 2000 levels) and an 85 percent reduction by 2020. There are currently no federal project-level requirements for air toxics analysis, and CEQA only requires a consideration of the risks from toxics. The NSAQMD has not established its own health risk thresholds, instead complying with the State’s maximum individual cancer risk significance threshold of 10 in 1 million (1.0 x 10-5) and a noncarcinogenic hazard index of 1.0. Analysis of Site Specific Toxics. According to ARB,14 when conducting a health risk assessment (HRA), the surrogate for whole diesel exhaust is diesel particulate matter, and is used as the basis for the potential risk calculations. When conducting an HRA, the potential cancer risk from inhalation exposure to diesel PM will outweigh the potential non- cancer health impacts. Therefore, inhalation cancer risk is required for every HRA. When comparing whole diesel exhaust to speciated diesel exhaust (e.g., polynuclear aromatic hydrocarbons, metals), potential cancer risk from inhalation exposure to whole diesel exhaust will outweigh the multi-pathway cancer risk from the speciated components. For this reason, there will be few situations where an analysis of multi-pathway risk is necessary.15 To estimate the potential cancer risk associated with project-related diesel engine exhaust, a dispersion model is used to translate an emission rate from a source location to a concentration at a receptor location of interest. Dispersion modeling varies from the simpler, more conservative screening-level analysis to the more complex and refined detailed analysis. This assessment was conducted using the ARB health risk model, HARP, which includes the EPA complex dispersion model ISCST3. In addition to examining the 14 Air Resources Board, 2005. http://www.arb.ca.gov/toxics/harp/docs/userguide/ appendixK.pdf. 15 OEHHA. 2003. Air Toxics Hot Spots Program Risk Assessment Guidelines, Appendix D, Risk Assessment Procedures to Evaluate Particulate Emissions from Diesel-Fueled Vehicles, Section B. August. NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 201 risks from diesel exhaust particulate, this assessment includes the risks from diesel exhaust gases. This model provides a detailed estimate of concentrations considering site and source geometry, source strength, distance to receptor, and site specific meteorological data. Emission Estimates. The only trains operating on the loop track in the vicinity of the project are snow clearing equipment called spreaders and flangers. These operate as needed, as much as 24 hours a day during heavy snow fall. Typically the period from about mid-October through mid-March is when sufficient snow accumulates to require clearing. These devices are powered by diesel (engine) locomotives of varying size and horsepower. Emissions from locomotives are relatively low. Emissions factors in the EPA’s Technical Highlights: Emission Factors for Locomotives (EPA420-F-97-051, December 1997) were used to estimate train emissions. Since the health risk covers a 70-year period and the model only accepts one emission rate for that whole period, the emissions factors shown in Table IV.D-8 for 2025 were selected as a conservative representative for the whole period. Trains, in general, and these flangers and spreader in particular, are rarely, if ever, operated at full throttle. Emissions vary considerably as the throttle is adjusted. The throttle position is referred to as the load factor, and for this analysis it was assumed that a 50 percent load factor was a conservative estimate of this equipment use, since this portion of track is primarily used to turn the equipment around. The typical load factor assumed for line haul locomotives is 40 percent.16 The train equipment was modeled as a series of 45 volume emission sources spaced at various intervals located depending on the proximity to the Plan Area, as shown in Figure IV.D-1. The total concentration at the residential area is the sum of all sources of emissions. Such model input details as stack height and dimensions were based on a typical electric/diesel hybrid locomotive. Receptors were placed in a general grid extending in all directions to characterize the risk level isopleths and at locations of residences. The most representative meteorological data available is from the City of Reno area. 17 The model input and output sheets, including the model grid and isopleths results, are included in Appendix D. 16 U.S. Environmental Protection Agency, Compilation of Air Pollution Factors Volume II: Mobile Sources, Fourth Edition, September 1985. 17 ARB web site, www.arb.ca.gov/toxics/harp/metfiles.htm, on 4/24/08. Table IV.D-8 Train Emission Factors (g/bhp-hr) Category VOC PM10 Locomotives operating in 2025 0.36 0.22 Notes: g/bhp-h = Grams Per Brake Horsepower-Hour. Source: EPA EPA420-F-97-051, December 1997. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY The emissions from trains moving by on the mainline are included in this analysis based on the conservatively high emissions rates used. However, such emissions are negligible compared to the emissions from the very slowly moving spreaders and flangers. The mainline trains only pass infrequently compared to the spreaders and flangers that, when there is snow, operate as much as 24 hours a day. Additionally, the mainline train engine would be operating in a mode that is more efficient resulting in lower emissions per mile than the spreaders and flangers. Further, the mainline train emissions are near to the Plan Area only momentarily as they pass by. Diesel powered road vehicles are also sources of diesel PM in the project vicinity. However, the emissions from the spreaders and flangers are of much greater concern than emissions from diesel-powered road vehicles, primarily because the spreaders and flangers operate nearly non-stop for days into weeks during heavy snowfall periods. Delivery trucks, which are not all diesel-powered, would only operate occasionally, by comparison. Additionally, the emissions from road vehicles such as delivery trucks are restricted by State and federal regulations resulting in lower emissions every year, much less than even 10 years ago. Including the truck emissions in this estimate does not measurably change the findings of this analysis, and is therefore considered to be less than significant. Acute Emission Impacts. Exposure to diesel exhaust can have immediate health effects. Diesel exhaust can irritate the eyes, nose, throat, and lungs, and it can cause coughs, headaches, lightheadedness, and nausea. In studies with human volunteers, diesel exhaust particles made people with allergies more susceptible to the materials to which they are allergic, such as dust and pollen. Exposure to diesel exhaust also causes inflammation in the lungs, which may aggravate chronic respiratory symptoms and increase the frequency or intensity of asthma attacks. However, according to the rulemaking on Identifying Particulate Emissions from Diesel-Fueled Engines as a Toxic Air Contaminant (ARB 1998), the available data from studies of humans exposed to diesel exhaust are not sufficient for deriving an acute non-cancer health risk guidance value. While the lung is a major target organ for diesel exhaust, studies of the gross respiratory effects of diesel exhaust in exposed workers have not provided sufficient exposure information to establish a short-term non-cancer health risk guidance value for respiratory effects. However, for this assessment Acrolein was included as a part of diesel exhaust to insure that this acute effect was not overlooked. Table IV.D-9 shows the resulting acute health risk is 0.031 compared to the threshold of 1.0. Therefore, the potential for short- term acute exposure would be less than significant. Table IV.D-9 Inhalation Health Risks from Train Sources Nearest Future Residence (Feet) Carcinogenic Inhalation Health Risk Chronic Inhalation Health Index Acute Inhalation Health Index 7.1 0.0065 0.017 100 10 in a million 1.0 1.0 Threshold Source: LSA Associates, Inc., 2008. 202 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 203 The ARB has taken steps to achieve the risk reduction goals of the Diesel Risk Reduction Plan including the facilitation of a voluntary agreement with Union Pacific Railroad Company (UPRR) and Burlington Northern Santa Fe (BNSF) Railway Company which became effective on June 30, 2005. The Agreement obligates UPRR and BNSF to reduce locomotive and associated diesel particulate emissions in and around California's railyards and railroad rights-of-way. To reduce diesel emissions, the agreement includes a statewide idling reduction program and maximum use of low sulfur diesel in locomotives fueled in California. The agreement also requires a detailed evaluation of advanced control measures that could reduce diesel particulate emissions up to 90 percent from uncontrolled levels generated by applicable locomotives. Additionally, several State and federal rulemaking efforts are underway to reduce emissions from railroads including the Carol Moyer program 18 and other incentive efforts, and Governor Schwarzenegger’s Goods Movement Action Plan for California’s ports, railways and highway system.19 18 The Carl Moyer program is grant program implemented by a partnership of ARB and local air districts that fund the incremental cost of cleaner-than-required engines and other sources of pollution. Projects to reduce emissions from on-road heavy duty vehicles, idle reduction technologies, locomotives and others are eligible for the program. 19 The Goods Movement Action Plan will develop a statewide implementation plan for goods movement capacity expansion, goods movement-related environmental and community mitigation, and goods movement-related homeland security and public safety enhancement. It will define the required elements to synchronize and to integrate efforts to achieve relief and improvement. Carcinogenic, Chronic and Acute Impacts. The results of the health risk assessment are also shown in Table IV.D-9 and in Figure IV.D-1. The highest carcinogenic risk level shown in Figure IV.D-1 is within a portion of proposed Industrial Heritage (IH) District. The IH District would include development of residential units (see Chapter 3, Project Description). The peak carcinogenic health risk level for at the location of any currently planned residences is approximately 7.0 in a million. Table IV.D-9 shows the resulting chronic and acute health risks are 0.0065 and 0.017, respectively, compared to their thresholds of 1.0. Therefore, the health risks for both long-term and short- term exposures to the rail operations would be less than significant. While the above modeling and comparison to the EPA threshold addresses the single emissions source of the railroad operations adjacent to the site, the average California carcinogenic inhalation heath risk from all sources of exposure is currently 701 in a million. The California Air Resources Board (ARB) has identified diesel locomotives and railyard activities as a significant source of toxic emissions. In September 2000, the ARB approved the comprehensive Diesel Risk Reduction Plan to reduce diesel emissions from both new and existing diesel-fueled engines and vehicles. The goal of the Plan is to reduce diesel PM emissions and the associated health risk by 75 percent in 2010 and 85 percent by 2020. dRssaPrennoD dR s s aP ren noD dRyawkcorB cificaPnreh tuoS RR Rive r S t \\Sau1-sr\on-site\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Admin EIR\Figures N FEET (APPROXIMATE) MAP SOURCE: Windows Local.Live / PREPARED BY: LSA ASSOCIATES, INC. 16008000 - Emission Locations 1 2 5 LEGEND - Carcinogenic Risk Level - 1 in 1Million - Carcinogenic Risk Level - 2 in 1 Million - Carcinogenic Risk Level - 5 in 1 Million 80 80 - Project Site 89 89 2 2 2 1 1 1 1 1 2 5 5 5 FIGURE IV.D-1 Truckee Railyard Master Plan EIR Health Risk Analysis Results NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 205 (6) Project-Related Greenhouse Gas Emissions Sources. Construction and operation of Master Plan development would generate GHG emissions, with the majority of energy consumption (and associated generation of GHG emissions) occurring during the project’s operation (as opposed to its construction). Typically, more than 80 percent of the total energy consumption takes place during the average expected lifetime use of buildings and less than 20 percent is consumed during construction. As of yet, there is no study that quantitatively assesses all of the GHG emissions associated with each phase of the construction and use of an individual development. Overall, the following activities associated with the proposed project could contribute to the generation of GHG emissions: ƒ Removal of Vegetation. The removal of vegetation for construction results in a loss of the carbon sequestration in plants during the construction period. However, planting of new or replacement vegetation (e.g., street trees) would result in a net addition to carbon sequestration capacity and lower the carbon footprint of the project over its useful life. ƒ Construction Activities. Construction equipment typically uses fossil-based fuels to operate. The combustion of fossil-based fuels creates GHGs such as CO2, CH4, and N2O. Furthermore, CH4 is emitted during the fueling of heavy equipment. ƒ Gas, Electric and Water Use. Natural gas use results in the emissions of two GHGs: CH4 (the major component of natural gas) and CO2 from the combustion of natural gas. Electricity use can result in GHG production if the electricity is generated by combusting fossil fuel. California’s water conveyance system is energy intensive. Preliminary estimates indicate that the total energy used to pump and treat this water exceeds 6.5 percent of the total electricity used in the State per year. ƒ Solid Waste Disposal. Solid waste disposal contributes to GHG emissions in a variety of ways. Landfilling and other methods of disposal use energy for transporting and manag- ing the waste and they produce additional GHGs to varying degrees. Landfilling, the most common waste management practice, results in the release of CH4 from the anaerobic decomposition of organic materials. CH4 is 25 times more potent a GHG than CO2. However, landfill CH4 can also be a source of energy. In addition, many materials in landfills do not decompose fully, and the carbon that remains is sequestered in the landfill and not released into the atmosphere. ƒ Motor Vehicle Use. Transportation associated with the proposed project would result in GHG emissions from the combustion of fossil fuels in daily automobile and truck trips. GHG emissions associated with the project would occur over the short term from construc- tion activities, consisting primarily of emissions from equipment exhaust. There would also be long-term regional emissions associated with project-related vehicular trips and station- TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY ary source emissions such as natural gas used for heating. Preliminary guidance from OPR and recent letters from the Attorney General critical of CEQA documents that have taken different approaches indicate that lead agencies should calculate, or estimate, emissions from vehicular traffic, energy consumption, water conveyance and treatment, waste gener- ation, and construction activities. The calculation presented below includes construction emissions in terms of CO2, and annual CO2eq GHG emissions from increased energy consumption, water usage, solid waste disposal, as well as estimated GHG emissions from vehicular traffic that would result from implementation of the Master Plan. GHG emissions generated by the proposed project would predominantly consist of CO2. In comparison to criteria air pollutants, such as ozone and PM10, CO2 emissions persist in the atmosphere for a substantially longer period of time. While emissions of other GHGs, such as CH4, are important with respect to global climate change, emission levels of other GHGs are less dependent on the land use and circulation patterns associated with the proposed land use development project than are levels of CO2. Construction Impacts. Construction activities produce combustion emissions from various sources such as site grading, utility engines, on-site heavy-duty construction vehicles, equipment hauling materials to and from the site, asphalt paving, and motor vehicles transporting the construction crew. Exhaust emissions from on-site construction activities would vary daily as construction activity levels change. The only GHG with well-studied emissions characteristics and published emissions factors for construction equipment is CO2. Using the URBEMIS 2007 model, it is estimated the average daily CO2 emissions associated with construction equipment exhaust for the proposed project would be approximately 1,189 per year, with total project construction- related CO2 emissions of 14,266 tons. Model output sheets are included in Appendix D. Architectural coatings (e.g., paint) used in construction of the specific Master Plan projects may contain volatile organic compounds (VOCs) that are similar to reactive organic gases (ROG) and are part of ozone precursors. However, there are no significant emissions of GHGs from architectural coatings. Operational Impacts. Long-term operation of the proposed project would generate GHG emissions from area and mobile sources, and indirect emissions from stationary sources associated with energy consumption. Mobile-source emissions of GHGs would include project-generated vehicle trips associated with employee commutes, and visitor and delivery vehicle trips to the Plan Area. Area-source emissions would be associated with activities such as landscaping and maintenance of proposed land uses, natural gas for heating, and other sources. Increases in stationary source emissions would also occur at off- site utility providers as a result of demand for electricity, natural gas, and water by the proposed uses. 206 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY ƒ Energy and Natural Gas Use. Buildings represent 39 percent of U.S. primary energy use and 70 percent of electricity consumption. The proposed project would increase the demand for electricity and natural gas due to the increased square footage and number of employees. The project would indirectly result in increased GHG emissions from off- site electricity generation at power plants (approximately 2,400 tons of CO2eq/year). ƒ Water Use. Water-related energy use consumes 19 percent of California’s electricity, 30 percent of its natural gas, and 88 billion gallons of diesel fuel every year. Energy use and related GHG emissions are based on water supply and conveyance, water treatment, water distribution, and wastewater treatment. Project-related estimates of water usage and related energy usage are based a Water Supply Assessment detailed in Section IV.E. Utilities. The water demand projection for development within the Master Plan Area is 406.2 acre-feet per year. ƒ Solid Waste Disposal. The proposed project would also generate solid waste during the operation phase of the project. The California Integrated Waste Management Board (CIWMB) estimates an average waste generation rates for residents and employees per jurisdiction. The 1,527 new residents and 349 employees (estimated based on office and commercial square footage) resulting from buildout of the proposed Master Plan would generate approximately 2.7 tons per day of solid waste. To determine the net GHG emissions from landfilling, the CO2eq emissions from CH4 generation, carbon storage (treated as negative emissions), and transportation CO2 emissions were considered. ƒ Mobile Sources. Mobile sources (vehicle trips and associated miles traveled) would be the largest emission source of GHGs associated with the proposed project. Transportation is also the largest source of GHG emissions in California and represents approximately 38 percent of annual CO2 emissions generated in the State. Like most land use development projects, vehicle miles traveled (VMT) is the most direct indicator of CO2 emissions from the proposed project and associated CO2 emissions function as the best indicator of total GHG emissions. The proposed project would generate an additional 9,580 trips over current conditions. The proposed project would generate up to 17,000 tons of CO2eq per year of new emissions, as shown in Table V.D-10. This is less than 0.0033 percent of the State’s total emissions in 2004. The emissions from vehicle exhaust comprise approximately 82 percent of the project’s total CO2eq emissions. The rate of emissions from vehicle exhaust is controlled by the State and federal governments and are outside the control of the Town of Truckee. However, project-related vehicular emissions would be reduced by the project design, which includes site planning that encourages bicycling and public transportation use and promotes numerous smart land use strategies. The proposed project has components that are pedestrian-oriented, includes a mix of uses including housing, live/work, artisan industry and commercial land uses, includes a diversity of housing types, promotes compact development, accommodates variety of transportation modes, including N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 207 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY transit and transit shelters, provides a network of pedestrian sidewalks and bicycle lanes and paths. Approximately 14 percent of the CO2eq emissions are primarily associated with building heating systems and increased regional power plant electricity generation due to the project’s electrical demands. Specific development projects proposed under the Master Plan would comply with existing State and federal regulations regarding the energy efficiency of buildings, appliances, and lighting, which would reduce the project’s electricity demand. The new buildings would be constructed in accordance with current energy efficiency standards. The emissions from electricity generation also include estimates for water supply and conveyance, water treatment, water distribution, and wastewater treatment. The remaining GHG emissions are associated with natural gas combustion (4 percent) and disposal of solid waste (less than 1 percent). Compliance with AB 32. The California Environmental Protection Agency Climate Action Team (CAT) and the California Air Resources Board (ARB) have developed several reports to achieve the Governor’s GHG targets that rely on voluntary actions of California businesses, local government and community groups, and State incentive and regulatory programs. These include the CAT’s 2006 “Report to Governor Schwarzenegger and the Legislature,” ARB’s 2007 “Expanded List of Early Action Measures to Reduce Greenhouse Gas Emissions in California,” and ARB’s “Climate Change Draft Scoping Plan: a Framework for Change.” The reports identify strategies to reduce California’s emissions to the levels proposed in Executive Order S-3-05 and AB 32 that are applicable to proposed project. The strategies that apply to the project are contained in Table IV.D-11, which summarizes the extent to 208 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Table IV.D-10 Long-Term Project Operational Emissions of GHGs Emissions (tons per year) Emission Source CO2 CH4 N2O CO2eq Vehicles 14,000 0.43 1.4 14,000 Electricity Production 2,400 0.026 0.015 2,400 Natural Gas Combustion 740 0.014 0.014 740 Solid Waste N/A N/A N/A 118 17,000 0.47 1.4 17,000 Total Annual Emissions Source: LSA Associates, Inc., August 2008. which the project complies with the strategies to help California reach the emission reduction targets. The strategies listed in Table IV.D-11 are either part of the project, required mitigation measures, or requirements under local or State ordinances. With implementation of these strategies/measures, the project’s contribution to cumulative GHG emissions would be reduced to a less-than-significant level. It should be noted that, the project would also be subject to all applicable regulatory requirements, including the City’s Standard Conditions of Approval, which would also reduce GHG emissions of the project. It is important to consider the context for GHG emissions. GHG emissions are dispersed throughout the atmosphere worldwide, and the effects of climate change are borne globally, unlike CAP emissions, which have regional and/or local impacts on air quality. As noted earlier, the extent to which GHG emissions attributable to the project can be treated as “new” is uncertain. For this reason and others discussed above in the section describing methods for analysis, it is more relevant to consider the GHG-efficiency (i.e., energy efficiency) of a project rather than simply the mass of GHG emissions. The various strategies set forth above would reduce greenhouse gas emissions. In many cases these strategies are part of the project or required mitigation measures. In some cases, they are a plan that requires approval by the ARB Board. The measures must be adopted through the normal rulemaking process with the necessary public review and input. In some cases, legislative action may be necessary. The specifics of these strategies and actions are not available at the time of publication of this EIR. In addition, the project would be subject to all applicable regulatory requirements, which would also reduce the GHG emissions of the project. After implementation of Mitigation Measure AIR-2 and application of regulatory requirements, the Master Plan would implement appropriate GHG reduction strategies and not conflict with or impede implementation of N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 209 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 210 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) Table IV.D-11 Project Compliance with Greenhouse Gas Emission Reduction Strategies Strategy Project Compliance Energy Efficiency Measures Building Energy Efficiency Standards in Place and in Progress.a Public Resources Code 25402 authorizes the Energy Commission to adopt and periodically update its building energy efficiency standards (that apply to newly constructed buildings and additions to and alterations to existing buildings). Energy Efficiency.b Maximize energy efficiency building and appliance standards, and pursue additional efficiency efforts. Reductions could be achieved through enhancements to existing programs such as increased incentives and even more stringent building codes and appliance efficiency standards. Compliant. The proposed project would be required to comply with the updated Title 24 standards for building construction. The project is seeking Leadership in Energy and Environmental Design (LEED) certification that will achieve energy efficiency levels that exceed Title 24. Appliance Energy Efficiency Standards in Place and in Progress.a Public Resources Code 25402 authorizes the Energy Commission to adopt and periodically update its appliance energy efficiency standards (that apply to devices and equipment using energy that are sold or offered for sale in California). Compliant. Appliances within the Plan Area would be consistent with existing energy efficiency standards. Water Conservation and Efficiency Measures Water Use Efficiency.b Approximately 19 percent of all electricity, 30 percent of all natural gas, and 88 million gallons of diesel are used to convey, treat, distribute and use water and wastewater. Increasing the efficiency of water transport and reducing water use would reduce GHG emissions. Compliant. The proposed project will incorporate water conservation measures, including the installation of landscaping that does not require permanent irrigation and a stormwater management system that infiltrates, reuses, or evapotranspires rain. Solid Waste Reduction Measures Increase Waste Diversion, Composting, and Commercial Recycling, and Move Toward Zero- Waste. Increase waste diversion from landfills beyond the 50 percent mandate to provide for additional recovery of recyclable materials. Composting and commercial recycling could have substantial GHG reduction benefits. In the long term, zero-waste policies that would require manufacturers to design products to be fully recyclable may be necessary. Compliant. Preliminary data available from the California Integrated Waste Management Board (CIWMB) indicates that the Town of Truckee currently exceeds the 50% diversion rates (70% in 2006) with the implementation of 37 programs, including source reduction, recycling, and public education. NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Table IV.D-11 Project Compliance with Greenhouse Gas Emission Reduction Strategies (continued) N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 211 Strategy Project Compliance Transportation and Motor Vehicle Measures Vehicle Climate Change Standards. b AB 1493 (Pavley) required the State to develop and adopt regulations that achieve the maximum feasible and cost-effective reduction of GHG emissions from passenger vehicles and light duty trucks. Regulations were adopted by the ARB in September 2004. Light-Duty Vehicle Efficiency Measures. Implement additional measures that could reduce light-duty GHG emissions. For example, measures to ensure that tires are properly inflated can both reduce GHG emissions and improve fuel efficiency. Adopt Heavy- and Medium-Duty Fuel and Engine Efficiency Measures. Regulations to require retrofits to improve the fuel efficiency of heavy-duty trucks that could include devices that reduce aerodynamic drag and rolling resistance. This measure could also include hybridization of and increased engine efficiency of vehicles. Low Carbon Fuel Standard.b ARB identified this measure as a Discrete Early Action Measure. This measure would reduce the carbon intensity of California's transportation fuels by at least 10% by 2020. Compliant. The Master Plan does not involve the manufacture, sale, or purchase of vehicles. However, vehicles that operate within and access the Plan Area would comply with any vehicle and fuel standards that the ARB adopts. Measures to Improve Transportation Energy Efficiency.b Builds on current efforts to provide a framework for expanded and new initiatives, including incentives, tools, and information that advance cleaner transportation and reduce greenhouse gas emissions. Compliant. The proposed project promotes programs which encourage bicycling and public transportation use through site planning and design elements. The proposed project includes a bicycle lane and sidewalks throughout Plan Area. Air Quality mitigation measure AIR-2 also requires other measures to promote alternative transit. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Table IV.D-11 Project Compliance with Greenhouse Gas Emission Reduction Strategies (continued) 212 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) Strategy Project Compliance Smart Land Use and Intelligent Transportation Systems (ITS). Smart land use strategies encourage jobs/housing proximity, promote transit-oriented development, and encourage high-density residential/commercial development along transit corridors. ITS is the application of advanced technology systems and management strategies to improve operational efficiency of transportation systems and movement of people, goods and services. Compliant. The proposed project includes several “Districts”, which promote numerous smart land use strategies. The project has components that are pedestrian-oriented, includes a mix of uses including housing, live/work, artisan industry and commercial land uses, includes a diversity of housing types, promotes compact development, accommodates variety of transportation modes, including transit and transit shelters, and provides a network of pedestrian sidewalks and bicycle lanes and paths. Other Local Government Actions and Regional Targets. Encourage local governments to set quantifiable emission reduction targets for their jurisdictions; recommend regional greenhouse gas emission reduction targets. The actions that local governments take individually, and through local and regional planning processes, can reduce greenhouse gas emissions associated with transportation, energy, waste/recycling, and water use. Local governments should build on existing strategies and adopt best practices to achieve greenhouse gas reductions through Community Energy, Community Waste and Recycling, Community Water and Wastewater Systems, Community Transportation, and Community Design. Compliant with Improvement Measures Included The Town of Truckee has incorporated a variety of measures into the 2025 General Plan that will reduce greenhouse gas emissions. The project incorporates a number of strategies to reduce GHG emissions through energy and community design. Measures to Reduce High Global Warming Potential (GWP) Gases. ARB has identified Discrete Early Action measures to reduce GHG emissions from the refrigerants used in car air conditioners, semiconductor manufacturing, and consumer products. ARB has also identified potential reduction opportunities for future commercial and industrial refrigeration, changing the refrigerants used in auto air conditioning systems, and ensuring that existing car air conditioning systems do not leak. Compliant. Products used, sold, or serviced in the Plan Area would comply with current and future ARB rules and regulations. NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Table IV.D-11 Project Compliance with Greenhouse Gas Emission Reduction Strategies (continued) N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 213 Strategy Project Compliance Anti-Idling Enforcement.b ARB adopted a diesel particulate air toxic control measure in June 2004 to control idling of diesel- fueled commercial motor vehicles. Enforcement commenced the following year. This rule prohibits, with some exceptions, the idling of diesel-fueled commercial motor vehicles for more than 5 minutes, and applies to both trucks and buses greater than 10,000 lbs. gross vehicle weight. Compliant. Vehicles that access the site would comply with all anti-idling regulations, including ARB’s limits on diesel-fueled commercial motor vehicle idling. a California Environmental Protection Agency. 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature. March. b California Air Resources Board. 2008. Climate Change Draft Scoping Plan: a framework for change. June. Source: LSA Associates, Inc., 2008. reduction goals identified in AB 32, the Governor’s Executive Order S-3-05, and other strategies to help reduce GHGs to the level proposed by the Governor. (7) Impacts to the Proposed Project from Global Climate Change. Local temperatures could increase in time as a result of global climate change, with or without implementation of the proposed project. This increase in temperature could lead to other climate effects including, but not limited to, increased flooding due to increased precipi- tation and runoff and a decrease in the Sierra snowpack. Since the Plan Area is not located in an area that would be subject to coastal or other flooding resulting from climate change, the potential effects of climate change (e.g., effects of flooding on the Plan Area due to sea level rise) on the proposed project would not be significant. b. Significant Impacts. Implementation of the Master Plan would result in significant impacts related to air quality as described below. Impact AIR-1: Demolition and construction period activities could generate significant dust, exhaust, and organic emissions. (S) The proposed project would require excavation/removal of substantial amounts of soil. The excavation of soil and other existing infrastructure improvements are construction activities with a high potential for creating air pollutants. In addition to the dust created during demolition and excavation, substantial dust emissions could be created as debris and soil are loaded into trucks for disposal. TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY Construction dust would also continue to affect local air quality during construction of the project. Construction activities would generate exhaust emissions from vehicles/equipment and fugitive particulate matter emissions that would affect local air quality. Construction activities are also a source of organic gas emissions. Solvents in adhesives, non-water-base paints, thinners, some insulating materials and caulking materials would evaporate into the atmosphere and would participate in the photochemical reaction that creates urban ozone. Asphalt used in paving is also a source of organic gases for a short time after its application. Project related construction emissions were calculated using the URBEMIS 2007 model. The emissions were calculated assuming construction phasing from the year 2009 through the year 2020. The NSAQMD does not have significance thresholds for construction emissions. Construction emission estimates are included in Appendix D. The effects of construction activities would be increased dustfall and locally elevated levels of PM10 downwind of construction activity. Construction dust would be generated at levels that would create an annoyance to nearby properties. Implementation of the following mitigation measure would reduce construction period air quality impacts to a less-than-significant level. Mitigation Measure AIR-1: The project applicant shall submit a grading plan for the project which includes the following conditions: a. Alternatives to open burning of vegetative material will be used unless otherwise deemed infeasible by the Town Planner. Among suitable alternatives are chipping, mulching or conversion to biomass fuel. b. The applicant shall be responsible for ensuring that adequate dust control measures are implemented in a timely manner during all phases of project development and construction. c. Temporary traffic control shall be provided during all phases of construction to improve traffic flow as deemed appropriate by local transportation agencies and/or Caltrans. d. Construction activities should be scheduled to direct traffic flow to off-peak hours as much as practicable. e. All material excavated, stockpiled, or graded shall be sufficiently watered, treated, or covered to prevent fugitive dust from leaving the property boundaries and causing a public nuisance or violation of ambient air standard during the dry season. Watering should occur at least twice daily, with complete site coverage during the dry season. 214 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY f. All areas with vehicle traffic shall be watered or have dust palliative applied as necessary for regular stabilization of dust emissions. g. All on-site vehicle traffic shall be limited to a speed of 15 mph on unpaved roads. h. All land clearing, grading, earth moving, or excavation activities on a Plan Area shall be suspended as necessary to prevent excessive windblown dust when winds are expected to exceed 20 mph. i. All inactive portions of the development site (previously graded areas which remain inactive for 96 hours) shall be covered, seeded, or watered until a suitable cover is established. Alternatively, the applicant may apply County-approved non-toxic soil stabilizers (according to manufacturers specifications) to all inactive construction areas in accordance with the local grading ordinance. j. 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. k. 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 silt and/or mud which may have resulted from activities at the Plan Area. l. Wheel washers shall be installed where project vehicles and/or equipment enter and/or exit onto paved streets from unpaved roads. Vehicles and/or equipment shall be washed prior to each trip if necessary. m. 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. (LTS) Impact AIR-2: Implementation of the Master Plan would result in an increase in Long Term Regional Emissions that would exceed the Northern Sierra Air Quality Management District Significance Criteria. (S) Long-term air emission impacts would be those associated with changes in permanent usage of the Plan Area. Mobile source emissions would result from vehicle trips associated with the proposed project. Increases in long-term stationary emissions associated with buildout of the Plan were calculated along with project-related mobile source emissions. The Urban Emission Model was used to calculate long-term stationary and mobile source emissions associated with the proposed project. URBEMIS output sheets are included in Appendix D of this report. N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 215 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY The daily emissions associated with project operational stationary and mobile source emissions are identified in Table IV.D-12 for reactive organic gases (ROG) and nitrogen oxides (NOx) (two precursors of ozone) and coarse and fine particle matter (PM10 and PM2.5 respectively). The NSAQMD has established thresholds of significance for ozone precursors and PM10 of 136 pounds per day; however, they have not established a threshold for emissions of PM2.5. Proposed project emissions shown in Table IV.D-10 would exceed these thresholds of significance for ROG, and PM10, and therefore, the proposed project would have a significant effect on regional air quality. Table IV.D-12 Project Regional Emissions in Pounds Per Day Reactive Organic Gases Nitrogen Oxides PM10 PM2.5 Project Buildout Regional Emissions 181.32 70.43 238.31 163.15 NSAQMD Significance Threshold 136.0 136.0 136.0 NA Exceed? Yes No Yes NA Source: LSA Associates, Inc., 2008. Implementation of the following mitigation measure would help to reduce regional air quality impacts of the proposed project: Mitigation Measure AIR-2: The project applicant shall implement the following mitigation measures: a. Each residence shall be equipped with a non-wood burning source of heat. Prior to issuance of any temporary or final certificates of occupancy or prior to recordation of the final map, the applicant shall prohibit the use of woodstoves within the Plan Area by placing a deed restriction on the title of the property or shall pay an air quality mitigation fee to the Air Quality Mitigation fund to offset PM10 emissions from solid fuel burning appliances. All new solid fuel burning appliances shall be EPA Phase II Certified and limited to one wood-burning appliance per residence. The amount of the mitigation fee shall be $300 for each solid fuel burning appliance that will or may be installed or the fee established by the Town Council resolution and in effect at the time of building permit issuance or final map recordation. b. The project shall provide for on-site bus turnouts, passenger benches, and shelters as demand and service routes warrant, subject to review and approval by the Town Engineer. c. The proposed project shall contribute a proportionate share to the development and/or continuation of a regional transit system. Contributions may consist of dedicated right-of-way, capital improvements, easements, etc. The Town Engineer shall be consulted for specific needs. 216 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) NOVEMBER 2008 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY d. All inactive portions of the development site (previously graded areas which remain inactive for 96 hours) shall be covered, seeded, or watered until a suitable cover is established. Alternatively, the applicant may apply Town-approved non-toxic soil stabilizers (according to manufacturers specifications) to all inactive construction areas in accordance with the local grading ordinance. e. The project shall provide for pedestrian access between bus service and major transportation points within the project where feasible. f. The project shall contribute a proportion share to traffic-flow improvements (i.e., right-of-way, capital improvements) that reduce emissions and are not considered as substantial growth-inducing. The local transportation agency shall be consulted for specific needs. g. A particulate matter emissions study meeting the requirements of the Particulate Matter Air Quality Management Plan shall be submitted in order to estimate the amount of emissions associated with full build-out of the project and generated from vehicle tail pipes and re-entrained road dust. The study shall be prepared by traffic and air quality consultants who have been approved by the Town Planner prior to preparation of the study. The study shall be consistent with the emissions calculation formulas utilized in the Particulate Matter Air Quality Management Plan and shall comply with all requirements of the Town Planner. Prior to issuance of any temporary or final certificates of occupancy for the permit, the applicant shall pay an air quality mitigation fee to the Air Quality Mitigation fund to offset PM10 emissions from vehicle tail pipes and re-entrained road dust. The amount of the mitigation fee shall be $7,366 per ton of emissions generated by development authorized by the permit or allowed upon recordation of the final map or the fee established by Town Council resolution and in effect at the time of building permit issuance or final map recordation. Even with implementation of this multipart mitigation measure, emissions would exceed the regional emission threshold. Additional measures are not available to reduce regional air quality impacts to a less-than-significant level. Therefore, this impact would be significant and unavoidable. (SU) Impact AIR-3: Implementation of the Master Plan could result in construction activities unexpectedly encountering hazard materials or hazardous waste in soil that could result in exposure of persons in the Plan Area to stationary source toxic air contam- inants. (S) While implementation of the Master Plan would not include any known stationary toxic air contaminant sources (i.e., sources other than the mobile source toxic air contaminants discussed in Section IV.D.2.a(3) above), the historic uses of the site have potentially resulted N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) 217 TRUCKEE RAILYARD DRAFT MASTER PLAN EIR NOVEMBER 2008 IV. SETTING, IMPACTS AND MITIGATION MEASURES D. AIR QUALITY 218 N:\2007\1407542 Truckee Railyard Master Plan EIR\Documents\Public Review Draft\4d-AirQuality.doc (11/4/2008) in groundwater and soil contamination that could become sources of stationary toxic air contaminants if disturbed during the construction phases of the project. Section IV.J, Hazards and Public Safety, of this document discusses impacts associated with potential hazard materials or hazardous waste materials potentially being found in the soil and groundwater of the proposed Master Plan site. The following summarizes the discussion contained within the Hazards section. The Master Plan Area has areas of known and potential, but as yet uncharacterized, or only partly characterized, soil and groundwater contamination associated with historic site uses. Potential sources of the contamination include former commercial and industrial uses that have occupied the Master Plan Area. The chemicals in the soil and groundwater are hazardous and exposure to the chemicals via direct contact, inhalation or other means may present a risk to future site occupants. Businesses that transport, store and handle hazardous materials have operated in the Master Plan Area in the past and continue to operate there now. In addition to hazardous materials sites compiled pursuant to Government Code Section 65962.5 (Table IV.J-1), there are other businesses in the area that have reported hazardous materials releases or usage, including the storage of fuel or other chemicals in underground storage tanks and transport via pipelines. There is some possibility that historic or current businesses in the Master Plan Area have had unreported releases of hazardous materials. If these materials are encountered unexpectedly during construction they would present a risk to workers, the public or the environment. However, implementation of the following mitigation measure would prevent exposure of persons within the Plan Area to these potential toxic air contaminants and would thus reduce this impact to a less-than-significant level: Mitigation Measure AIR-3: The project applicant shall implement mitigation measures HAZ-1, HAZ-2a, and HAZ-2b. (LTS)