HomeMy WebLinkAboutAttachmt 7 - Appdx 8.5
Appendix 8.5
Supplemental Air Quality Analysis
Dublin Ranch West Draft Supplemental ErR
City of Dublin
Page 154
November 2004
AIR QUALITY IMPACT EVALUATION FOR THE
DUBLIN RANCH WEST DEVELOPMENT
CITY OF DUBLIN
,
. Prepared for:
Jerry Haag, Urban Planner
2029 University Avenue
Berkeley, CA. 94704
October 2003
INTRODUCTION
Air quality impacts of the project were analyzed in Chapter 3.11 of the Eastern Dublin EIR. This
supplement to the EIR examines compliance with applicable significance thresholds, utilizes
updated methods of analysis, and is based on current traffic forecasts that reflect changes in
roadway improvements and travel patterns that have occurred since certification of the Eastern
Dublin EIR. This supplement also examines changes in the regulatory standards since the
previous EIR.
ENVIRONMENTAL SETTING
The project is within the Livermore-Amador Valley. The Livermore-Amador Valley forms a
small subregional air basin distinct from the larger San Francisco Bay Area Air Basin. The
Livermore-Amador Valley air basin is surrounded on all sides by high hills or mountains.
Significant breaks in the hills surrounding the air basin are Niles Canyon and the San Ramon
Valley, which extends northward into Contra Costa County.
The terrain of the Livermore-Amador Valley influences both the climate and air pollution
potential of the sub-regional air basin. As an inland, protected valley, the area has generally
lighter winds and a higher frequency of calm conditions when compared to the greater Bay Area.
The occurrence of episodes of high atmospheric stability, known as inversion conditions,
severely limits the ability of the atmosphere to disperse polluùµ1ts vertically. Inversions occur
during all seasons in the Bay Area, but are particularly prevalent in the summer months when
they are present about 90% of the time in both morning and afternoon.
According to the Bay Area Air Quality Management District, air pollution potential is high in the
Livermore Valley, especially for ozone in the summer and fall (BAAQMD, 1999). High
temperatures increase the potential for ozone, and the valley not only traps locally generated
pollutants but also can be the receptor of ozone and ozone precursors from upwind portions of
the greater Bay Area. Transport of pollutants also occurs between the Livermore Valley and the
San Joaquin Valley to the east.
During the winter, the sheltering effect of terrain and its inland location results in frequent
surface-based inversions. Under these conditions, pollutants such as carbon monoxide from
automobiles and particulate matter generated by fireplaces and agricultural burning can become
concentrated. .
IMPACTS AND MITIGATIONS FROM THE EASTERN DUBLIN EIR
The Eastern Dublin EIR identified significant impacts related to construction, mobile source and
stationary source emissions (Impacts 3.11/A, B, C, E). Mitigation measures were adopted to
control construction dust and exhaust emissions, and to minimize mobile and stationary source
emissions through, among other things, cooperative transportation and air quality planning and
transportation demand management. All mitigation.measures adopted upon approval of the
Eastem Dublin GP AlSP continue to apply to implementing actions and projects such as the
proposed project. Even with mitigation, however, significant cumulative construction, mobile
source and stationary source impacts remained. (Impacts 3.11A, 311B, 3011C, and 3.11E). Upon
..,
approval of the Eastern Dublin GPA/SP, the City adopted a Statement of Overriding
Considerations for these significant unavoidable impacts. (Resolution No. 53-93.)
SUPPLEMENTAL IMPACTS AND MITIGATION MEASURES
The proposed General Plan and Specific Plan amendment would change land uses and
development intensity from those analyzed in the Eastern Dublin EIR. The proj ect would
increase daily traffic generation over that assumed in the Eastern Dublin EIR
Since preparation of the Eastern Dublin EIR there have been several regulatory changes and
methods for air quality analysis as well as applicable thresholds of significance have changed.
Pursuant to Guidelines section 15162 and 15163, this supplement assesses whether new or
intensified air quality impacts will result from increased regional traffic and changed regulatory
standards.
Changes to the Regulatory Setting
Ambient Air Quality Standards
The federal and California ambient air quality standards are summarized in Table 1 for important
pollutants. The federal and state ambient standards were developed independently with differing
purposes and methods, although both federal and state standards are intended to avoid
health-related effects. As a result, the federal and state standards differ in some cases. In general,
the California state standards are more stringent. This is particularly true for ozone and PMIO'
The U.S. Environmental Protection Agency established new national air quality standards for
ground-level ozone and for fine particulate matter in 1997. The existing I-hour ozone standard of
0.12 PPM microns or less) is to be phased out and replaced by an 8-hour standard of 0.08 PPM.
Implementation of the 8-hour standard was delayed by litigation, but was determined to be valid
and enforceable by the U. S. Supreme Court in a decision issued in February of 2001. However,
the new federal ozone standard is not yet in effect pending final resolution of this litigation and
adoption of implementing regulations.
In 1997 new national standards for fin~ Particulate Matter (diameter 2.5 microns or less) were
adopted for 24-hour and annual averaging periods. The current P MID standards were to be
retained, but the method and form for· determining compliance with the standards were to be
revised. Implementation of this standard was delayed by litigation and will not occur until the U.
S. Environmental Protection Agency has issued court-approved guidance.
The State of California regularly reviews scientific literature regarding the health effects and
exposure to PM and other pollutants. On May 3, 2002, the California Air Resources Board
(CARE) staff recommended lowering the level of the annual standard for PMlO and establishing a
new annual standard for PM2.5 (particulate matter 2.5 micrometers in diameter and smaller). The
new standards became effective on July 5, 2003.
~
Table 1
Federal and State Ambient Air Quality Standards
Pollutant Averaging Federal State
Time Primary Standard
Standard
Ozone I-Hour 0.12 ppm 0.09 ppm
8- Hour 0.08 ppm --
Carbon Monoxide 8-Hour 9.0 ppm 9.0 ppm
I-Hour 35.0 ppm 20.0 ppm
Nitrogen Dioxide Annual 0.05 ppm --
I-Hour -- 0.25 ppm
Sulfur Dioxide Annual 0.03 ppm --
24-Hour 0.14 ppm 0.05 ppm
I-Hour -- 0.25 ppm
PMIO Annual 50 ug/m3 20 ug/m3
24-Hour 150 ug/m3 50 ug/m3
P M2.5 Annual 15 ug/m3 12 ug/m3
24-Hour 65 ug/m3 --
Lead 30-Day Avg. -- 1.5 ug/m3
, 3-Month Avg. 1.5 ug/m 3 --
ppm = parts per million
uglm3 = Micrograms per Cubic Meter
In addition to the criteria pollutants discussed above, Toxic Air Contaminants (TACs) are
another group of pollutants of concern. Toxic Air Contaminants (TACs) are injurious in small
quantities and are regulated despite the absence of criteria documents. The identification,
regulation and monitoring ofTACs is relatively recent compared to that for criteria pollutants.
Current Air Ouality
The project is within the nine-county Bay Area Air Basin. The Bay Area Air Quality
Management District (BAAQMD) operates a network of air quality monitoring sites in the
region. The closest to the site is located in central Livermore on Old First Street. Table 2 shows
a summary of air quality data for this monitoring site for the period 2000-2002. Data are shown
for ozone, carbon monoxide, PM 10, and nitrogen dioxide. The number of days exceeding each
standard is shown for each year.
Table 2 shows that concentrations of carbon monoxide and nitrogen dioxide at the Livermore
monitoring site meet state/federal standards. Ozone concentrations exceed both the state and
federal standards, and exhibit wide variations from year-to-year related to meteorological
conditions. Years where the summer months tend to be warmer than average tend to have higher
average ozone concentrations while years with cooler than average temperatures tend to have
lower average ozone concentrations.
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Table 2
Air Quality at Livermore Monitoring Site, 2000-2002
Days Standard Exceeded During:
Pollutant
Ozone
Ozone
Ozone
PMIO
PMIO
PM2.5
Carbon
Monoxide
Nitrogen
Dioxide
Source: CARB, 2003
Standard
Federal I-Hour
2000
1
2001
o
2002
2
State I-Hour
7
9
10
Federal 8-Hour
2
2
6
Federal 24-Hour
o
o
o
State 24-Hour
2
3
o
Federal 24- Hour
o
1
o
State/F ederal
8- Hour
State I-Hour
o
o
o
o
o
o
Levels ofPMlO and PM2.5 at Livermore meet the federal ambient standards but exceed the more
stringent state standards.
Attainment Status
The federal Clean Air Act and the California Clean Air Act of 1988 require that the California Air
Resources Board (CARB), based on air quality monitoring data, designate air basins within the
state where the federal or state ambient air quality standards are not met as "non-attainment
areas". Because of the differences between the federal and state standards, the designation of
non-attainment areas is different under the federal and state leg.islation.
In 1995, after several years of minimal violations of the federal one-hour ozone standard, the U.S.
Environmental Protection Agency (EPA) revised the designation of the Bay Area Air Basin from
"non-attainment" to "attainment" for this standard. However, with less favorable meteorology in
subsequent years, violations of the one-hour ozone standard again were observed in the basin,
particularly at the Livermore monitoring station. Effective August 1998, the EP A downgraded
the Bay Area's classification for this standard from a "maintenance" area to an "unclassified
non-attainment" area. Also in 1998, after many years without violations of any carbon monoxide
(CO) standards, the attainment status for CO was upgraded to "attainment."
"
The San Francisco Bay Area Air Basin is currently non-attainment for ozone (state and federal
ambient standards) and PM10 (state ambient standard). However, in April 2004,U~S.EPA:made
a final finding that the, Bay Area has attained the national 1 "ho.ur ozone standard.. The findi:r1g ··of
attainment does not mean :theBayAreahas,been:rec1assi:fied,as an attainment area for thel~hour
standard. The-regionmustsubIriitare-designationrequesttoEPAiri order to be reclassified as all
attainÌnentarea.
TheC~iforniaAirResol.1rces,~oard:ancl.,U; S;r;nVironmentalProtection AgencY'hayeboth
proposed that the SahFrancisco'BayAreabeclas!)ifiedasanonattainment-areafor'the federa18-
hour standard. The California Air'ResourcesBoardà.nd U. S. Environmental Protection Agency
have both proposed that the San Francisco Bay Area ,be considered Unc1assifiablewithrespect' to
the federalPM2.sstandards.Unclassifiablemeansthatanareacannot be dassifiedonthe.þasisof
. ,- - ,., . .' '. '
. . . . -
available information as meeting or notmëetingthenational' primary or $econdary.aiI1bierttaiI
quaIitystandaI'd for the pollutant. U;S .EPA plans tofimilizePM2:5 designations by December
15,2004.
While air quality plans exist for ozone, none exists (or is currently required) for P MIO' The
Revised San Francisco Bay Area Ozone Attainment Plan for the I-Hour National Ozone Standard
(BAAQMD, 2001) is the current ozone air quality plan required under the federal Clean Air.
The state-mandated regional air quality plan is the Bay Area 2000 Clean Air Plan (BAAQMD,
2000). These plans contain mobile source controls, stationary source controls and
transportation control measures to be implemented in the region to attain the state and federal
ozone standards within the Bay Area Air Basin.
Significance Thresholds
The BAAQMD has revised recommended thresholds of significance since publication of the East
Dublin EIR" (BAAQMD, 1999). The document BAAQMD CEQA Guidelines establishes the
following impact criteria:
· A significant impact on local air quality is defined as an increase in carbon monoxide
concentrations that causes a violation of the most stringent ambient air quality standard
for carbon monoxide (20 ppm for the one-hour averaging period, 9.0 ppm for the eight-
hour averaging period).
· A significant impact on regional air quality is defined as an increase in emissions of an
ozone precursor or PMJO exceeding the BAAQMD thresholds of significance. The
current significance thresholds are 80 pounds per day (or 15 tons/year) for ozone
precursors or PMJO.
· Any proposed project that would individually have a significant air quality impact would
also be considered to have a significant cumulative air quality impact.
· Any project with the potential to frequently expose members of the public to
objectionable odors would be deemed to have a significant impact.
"
· Any project with the potential to expose sensitive receptors or the general public to
substantial levels of toxic air contaminants would be deemed to have a significant impact.
Despite the establishment of both federal and state standards for PM2.5 (particulate matter, 2.5
microns), the BAAQMD has not developed a threshold of significance for this pollutant. For
this analysis, PM2.5 impacts would be considered significant if project emissions of P MJO exceed
80 pounds per day.
The current BAAQMD significanc~ threshold for construction dust impact is based on the
appropriateness of construction dust controls. The BAAQMD guidelines provide feasible
control measures for construction emission ofPMlO' If the appropriate construction controls are
to be implemented, then air pollutant emissions for construction activities would be considered
less- than-significant.
Revised Mitigation Recommendations
The document BAAQMD CEQA Guidelines was published subsequent to the publicaton of the
East Dublin EIR. These guidelines provided recommended mitigation practices during
construction based on the size of the project and expanded recommended mitigations for
operational impacts of commercial projects.
Impacts and Mitigation Measures
Supplemental Impact A Q 1: Construction activities would have the potential to cause nuisance
related to dust and PMJ{jo
The current BAAQMD significance threshold for construction dust impact is based on the
appropriateness of construction dust controls. If the appropriate construction controls are to be
implemented, then air pollutant emissions for construction activities would be considered less-
than-significant. Mitigation Measure MM 3.11/1.0 in the East Dublin EIR implements most, but
not all, of the currently recommeded measures.
Supplemental Mitigaton AQ 1: In addition to measures identified in MM 3.11/1.0 of the East
Dublin EIR. the City of Dublin shall:
$ Require construction contractors to water or cover stockpiles of debris, soil, sand or other
materials that can be blown by the wind.
$ Require construction contractors to sweep daily (preferably with water sweepers) all
paved access road, parking areas and staging areas at construction sites.
$ Require construction contractors to install sandbags or other erosion control measures to
prevent silt runoff to public roadways.
According the current BAAQMD CEQA guidelines, implementation of these mitigation
measures would reduce construction period air quality impacts to a less-than-significant level.
'7
Supplemental Impact AQ 2: The project would result in a regional emission increase that
would exceed the BAAQMD significance thresholds for ozone precursors.
Vehicle trips generated by the project would result in air pollutant emissions affecting the entire
San Francisco Bay Air Basin. Regional emissions associated with project vehicle use have been
calculated using the URBEMIS-2002 emission model.
The incremental daily emission increase associated with project operational trip generation is
identified in Table 3 for reactive organic gases ànd oxides of nitrogen (two precursors of ozone)
and PM 10, Also shown is the emission increase under the existing Specific Plan designations.
The Bay Area Air Quality Management District's thresholds of significance for these pollutants
are also shown. Proposed project emissions shown in Table 3 would exceed these thresholds of
Table 3
Project Regional Emissions in Pounds Per Day
. Reactive Nitrogen PMlO
Organic Oxides
Gases
Project 116.9 116.6 89.9
Development under Existing 109.5 102.9 78.9
Specific Plan
BAAQMD $ignificance 80.0 80.0 80.0
Threshold
significance for ROG and NOx, so the proposed project would have a significant effect on
regional ozone air quality.
Supplemental Mitigaton AQ 2: In addition to measures identified in MM 3.11/5.0-11.0 of the
East Dublin EIR. the City of Dublin shall require that the following be implemented:
· The project proponent should negotiate with LA VTA for the eventual extension of
transit service to the project site. Construct or reserve land fo transit facilities such as
bus turnoutslbus bulbs, benches, etc
· Provide bicycle land and/or paths, connected to community-wide network.
· Provide sidewalks and/or paths, connected to adjacent land uses, transit stops, and/or
community-wide network.
R
· Provide neighborhood-serving shops and services within or adjacent to residential project.
Revise land use to provide a mixed of residential and residential-serving land uses.
· Provide shuttle service to regional transit system or multimodal center.
· Provide a satellite telecommute center for project residents.
·
Provide interconnected street network, with a regular grid or similar interconnected street
pattern.
Implementation of the mitigation measures in the Eastern Dublin EIR (Mitigation Measures
3.1115.0-11.0 together with the above measures will not achieve the more than 30% reduction in
project-related emissions that would be needed to reduce emissions below the BAAQMD
thresholds of signficance. Ozone air quality impacts will remain significant and unavoidable.
Supplemental Impact AQ 3: Project-related regional emissions would exceed the BAAQMD
thresholds of significance for ozone precursors, resulting in a significant cumulative impact.
According to BAAQMD significance criteria, any proposed project that would individually have
a significant air quality impact would also be considered to have a significant cumulative air
quality impact. Since the proposed project, after mitigation, would exceed the BAAQMD
thresholds of significance for Reactive Organic Gases and Nitrogen Oxides, the project would
have a significant cumulative impact on regional air quality.
Supplemental Mitigation Measure AQ 3: Same as Supplemental Mitigation AQ-2.
Supplemental Impact AQ 4: The project would change traffic volumes and congestion levels,
changing carbon monoxide concentrations. This is a less-than-significant impact.
On the local scale, the project would change traffic on the local street network, changing carbon
monoxide levels along roadways used by project traffic. Carbon monoxide is an odorless,
colorless poisonous gas whose primary source in the Bay Area is automobiles. Concentrations of
this gas are highest near intersections of major roads. New vehicle trips add to carbon monoxide
concentrations near streets providing access to the site.
The Bay Area Air Quality Management District=s BAAQMD CEQA Guidelžnes recommends
estimation of carbon monoxide concentrations for projects where project traffic would impact
intersections or roadway links operating at Level of Service D, E, or F or would cause Level of
Service to decline to D, E, or F.
The analysis of intersection Level of Service (LOS) prepared for the project found that, of the 19
existing intersections studied, none would operate at LOS D or worse after addition of project
traffic in either the AM or PM peak traffic hour. Therefore, the BAAQMD threshold trigger
level for estimating carbon monoxide modeling of concentrations would not be exceeded.
o
Considering that the proposed project is in an attainment area for carbon monoxide (the state and
federal ambient standards are met) and that Dublin has relatively low background levels of carbon
monoxide compared to other parts of the Bay Area and that Levels of Service at intersections
affected by project traffic would remain relatively good, the conclusion of the East Dublin EIR
that the project would have a less-than-significant impact on local carbon monoxide
concentrations is confirmed.
Carbon monoxide impact of development under the existing Specific Plan would be somewhat
less than that of the proposed project. Carbon monoxide impacts are roughly proportional to
vehicle trips. Development of the site under existing Specific Plan designations would generate
about 92% of the daily trips of the current proposal. The impact of development under the
existing Specific Plan designations on carbon monoxide concentrations would be less-than-
significant.
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References
Bay Area Air Quality Management District, Bay Area CEQA Guidelines, 1999.
Bay Area Air Quality Management District, Bay Area 2000 Clean Air Plan and Triennial
Assessment December 20,2000.
Bay Area Air Quality Management District, Revised San Francisco Bay Area Ozone Attainment
Plan for the I-Hour National Ozone Standard, October 24, 2001.
California Air Resources Board (CARB), Aerometric Data Analysis and Management (ADAM),
2003.
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