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Home My WebLink About6.2 SB343 Avalon Bay DA Appeal #2400-20/410-30/450-30/600-60 May 17, 2011 ~/ ~ \ ~~' ~~ ~ 1 / ' \ ~. /~:' S B 343 Senate Bill 343 mandates supplemental materials that have been received by the City Clerk's offiCe that relate to an agenda item after the agenda packets have been distributed to the City Council be available to the public. . - The attached document was received in the City Clerk's office after distribution of the May 17, 2011 City Council meeting agenda packet. 05/17/11 6.2 ~~ T~~~ !~~ 7 400 Race Street, Suite Z00 ,A San Jose, CA 95126 A Tc] (~108) 983- i500 ~ Fa~ (408) 237-91G7 ~~ ~,~. f C:(~,~~t~4tU\I"C[LS,~~c'. ~ May 17, 2011 vlike Porto Community DeveIopment Director City of Dublin 700 Civic P}aza Dublin, CA 9~568 Phone: (925) 833-6650 FaY:(925} 833-6651 Re: Avalon Dublin Station II Dear 1~~. Porto: i am writing,to propose a slight modification to AyalonBay'.s. proposed project, DEiblin Station II .. , ~("Project"), in response to a st3ggestion by. appellant Carpenters Local Union ~umber 713 ("Uiiion".).. , In particular•, AvalonBay is voluntarily modifying ~the Pi•o~ect to incorpo~~a,te the air filtration system , . described more fully in the attached letter from l~lichaeI Keinath and Shari Libicki at ENVIRON: ~ The Carpenters Locai Union Number 7I3 {"Union") is appealing the Planning Cominission's approval of the Site Deveiopm;ent Review and Vesting Tentative Map. Among.other ttiings, the Union alleges. that the City should have prepared an EIR prior to approving the Project due to its close proximity to - . ~ Interstate 580. The Union suggests that the Projec# should incorporate a fltration system to minimize any related impacts. ~ AvalonBay is serioi~s about its commitment to both the euvi;•onment aiici its fuhire residents. Indaed, the Project is exactly the type of environmentally beneficial infill, transit orien#ed development that state and Iocal p~licy encourages. Due to AvalonBay's commitment #v a state-of the-art facility, it will include the filtration system more fully described in the ENVIRON letter. Further, as that letter indicates, any impacts to future residents, if any, are greatly minirnized and are not considered a significant impact. Sincerely, ` AvaionBay Communities, Inc. a ~/ ~~ f 14 j ~ i c. i C~-~- '' ~~~~'. ~ ~ ~e ~ey P. White Senior Development Director cc: Jeri Ram, City of Dublin Jeff Baker, City of Dubtin Attachment: Letter from Michael Keinath, Senior Manager, ENVIRON to Jeff White, Seniol• Development Director, AvalonBay Communities, Inc. (May 17, 2011) ~NVI RON May 17, 2011 Via Electronic Mail Jeff White ~Senior Development Director AvalonBay Communities 185 Berry Street, Suite 3500 San Francisco, CA 9410 Re: Summary of Potential Mitigation Measures to Reduce Exposure to Freeway Emissions, Proposed Dublin Station II, Dublin, California Dear Mr. White: Per your request, ENVIRON has prepared the following summary of the effectiveness of a ventilation and filtration system for reducing indoor pollutant concentrations resulting from ~ vehicular emissions on Interstate 580 (I-580) which is nearby to the proposed Dublin Station II Project in Dublin, California. ~ Background on Proposed Dublin Station Development The proposed project, Avalon T ransit Center Site C, also known as Dubli n Station II (herein designated as "ProjecY'), is a residential project comprised of 505 apartment units, a 4,223 square foot fitness center, 733 spaces of structured parking within two buildings, 25 private on- street parking spaces and 40 public on-street parking spaces on a combined 7.2-acre site located within the Transit Center Village planning area. Site C is a 5-sided site located immediately north of the East Dublin-Pleasanton Bay Area Rapid Transit (BART) station underpass entry (providing access to the BART station), Iron Horse Parkway to the east and Demarcus Boulevard to the west. The site is currently used as a surface parking lot of approximately 1,086 spaces for the BART station. Uses surrounding and adjacent to the project site are: • To the north: High density residential and mixed use projects Elan and Dublin Station I located across from the project site by a village green/community greenbelt, known as Campbell;Green; • To the southeast: Recently completed BART Station parking structure and bus parking along the opposite side of Iron Horse Parkway; • To the east: Planned for hotel and/or office use, but currently vacant; • To the south: I-580 (approximately 250 feet to the nearest travel lane) and BART Station; and • To the west: Open-air bus terminal, surFace parking and a Pacific Gas Electric power substation. The Project is located within the Eastern Dublin Specific Plan for the Transit Center Project ("Specific Plan"). The City previously certified, an Environmental Impact Report for the Specific Plan and the City has determined that the Project is exempt from further California Environmental Quality Act (CEQA) review pursuant to Government Code section 65457. 201 California Street, Suite 1280, San Francisco, CA 94608 www.environcorp.com Tel: +1 415.796.1950 Fax: +1 415.398.5812 Mr. Jeff White - 2- May 17, 2011 We understand that due to its proximity to the I-580 (with the Project ranging from 250 to 800 feet away from the nearest travel lane), a fresh air ventilation system will be installed in all exterior facing residential units (except Campbell Lane) of the Project to provide noise suppression. The ventilation system will operate continuously and can be designed in such a way to integrate filtration of fresh air. Filtration System Minimizes Exposure to Pollutants The environmental impact report (E1R) prepared for the Specific Plan did not identify any significant impacts relating to the exposure of.residents living in the Project to toxic air contaminants resulting from tra~c on I-580. ~ Although the 2002 EIR did not evaluate any toxic air contaminant related significant impacts, in order to be most protective of the future residents, we understand that AvalonBay has voluntarily agreed to implement an air filtration system. The purpose of this letter is to assess the effectiveness of such a system. We understand that AvalonBay will install a system that complies with filtration mitigation identified in Bay Area Air Quality Management DistricYs (BAAQMD's) recent CEQA Guidelines, including: "lnstall and maintain air filtration. systems of fresh air supply either on an • individual unit-by-unit basis, with individual air intake and exhaust ducts ventilating each ~unit separately, or through a centralized building ventilation system. The ventilation system should be certified to achieve a performance effectiveness, for example, to remove at least 85% of ambient PM2.5 concentrations from indoor areas. Air intakes should be located away from emission sources areas, such as major roadways." This recommendation is based on the wor k of Fisk et a1.,2 who conducted a study of the performance and costs of particulate air filtration technologies and determined that ASHRAE Dust Spot 85°/a (MERV 13) filters provided an 80% or greater reduction of outdoor fine particulate matter (such as diesel particulate matter) if the ventilation system is operated with one air exchange per hour of outside air and four air exchanges per hour of recirculated air. The removal efficiency increased up to 95% with use of a high efficiency particulate air (HEPA) filter. , We note that at the time of the 2002 EIR, there was developed scientific literature relating to this topic as referenced by the California Air Resources Board in their 2005 Air Quality and Land Use Handbook: A Community Health Perspective . See: . ^ Brunekreef, B. et al. "Air pollution from truck traffic and lung function in children living near motorways." Epidemiology. 1997; 8:298-303 ' ^ Lin, S. et al. "Childhood asthma hospitalization and residential exposure to state route traffic." Environ Res. 2002; 88:73-81 ^ Venn. et al. "Living near a main road and the risk of wheezing illness in children." American Journal of Respiratory and Critical Care Medicine. 2001; Vo1.164, pp. 2177-2180 ^ Zhu, Y et al. "Study of ultra-fine particles near a major highway with heavy-duty diesel traffic." Atmospheric Environment. 2002 ; 36:4323-4335 ^ Knape, M. "Traffic related air pollution in city districts near motorways." The Science of the Total Environment. 1999; 235:339-341 ^ ARB Diesel Risk Reduction Plan. (2000) ^ Delfino RJ "Epidemiologic Evidence for Asthma and Exposure to Air Toxics: Linkages Between Occupational, Indoor, and Community Air Pollution Research." Environmental Health Perspectives. (2002) 110 (supplement 4 ): 573-589 ^ English P., Neutra R., Scalf R. Sullivan M. Waller L. Zhu L. "Examining Associations Between Childhood Asthma and Traffic Flow Using a Geographic Information System °(1999) Environmental Health Perspectives 107(9): 761-767 2 Fisk, W.J., D. Faulkner, J. Palonen, and O. Seppanen. 2002. Performance and costs of particle air filtration technologies. lndoorAir. 12: 223-234. Mr. Jeff White - 3- May 17, 2011 Installing filters and designing the proposed ventilation system in such a way to meet the parameters specified by Fisk et al. (i.e., with one air exchange per hour of outside air and four air exchanges per hour of recirculated air), the ventilation would significantly reduce cancer risks and PM2.5 concentrations. The type of filtration required (MERV 13 or HEPA) would be dependent on the location of an individual unit w ith respect to I-580 (closest units would require HEPA while those further could use ME RV 13); however, a detailed analysis would be required to determine which units would require which type of filtration. The use of filtration as a mitigation measure to address toxic air contaminants has been used in other jurisdictions. For example, in 2008 the City and Counry of San F rancisco adopted San Francisco Health.Code Article 38 ("Article 38") which requires that projects which exceed a PM2.5 action level are required to incorporate ventilation systems to remove 80% of PM2.5 from outdoor air.3~4 Based on our experience with similarly situated projects, conducting a detailed evaluation of traffic emissions and modifyi ng the Project to include the filtration system described above can adeq uately protect future residents in compliance with BAAQMD guidance. Summary Provided that the Project requires an Operation and~ Maintenance M anual for the heating ~a nd ventilation system and the filter which includes the operating instructions and maintenance and replacement schedule, the installation of MERV 13 or.HEPA filters can effectively reduce cancer risk and PM2.5 concentrations. ~ ~ ~ If you have any questions, please feel fr ee to contact-M icliael at 510.420.2539 or mkeinath(a?environcorp.com. Thank you for the opportunity to assist you with this matter. ,.. , Sincerely, ichael Keinath, PE Senior Manager ~ f~ ~ ^~ r - "`%`~ , ~~..l~ ,~`~ ; ^~hari Libicki, PhD Principal MTK:py u:\avalonbay\report\san_francisco-#2995617-v1-revised_avalon_Itr_from_environ_final.doc.docx [03-26957A] 3 City and County of San Francisco, California. Health Code. Article 38: Air Quality Assessment and Ventilation Requirement for Urban Infill Residential Development. December 5, 2008. a Bhatia, Rajiv and Thomas Rivard. 2008. Assessment and Mitigation of Air Pollutant Health Effects from Intra-urban Roadways: Guidance for Land Use Planning and Environmental Review. Department of Public Health, City and County of San Francisco. May 6. ,