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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. 11 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. 10 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. 11