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CC - Item 3A - Attachment G - Appendix A - Air Quality Greenhouse Gas Analysis - Strathmore Garvey Air Quality GHG Report AIR QUALITY and GHG IMPACT ANALYSES STRATHMORE AND GARVEY MIXED-USE PROJECT CITY OF ROSEMEAD, CALIFORNIA Prepared by: Sara Friedman Gerrick Giroux & Associates Prepared for: Phil Martin Phil Martin & Associates Date: September 27, 2022 Project No.: P22-033 AQ Strathmore and Garvey, Rosemead AQ - 1 - PROJECT DESCRIPTION The 1.21 acre Project site is located at the northwest corner of the intersection of Strathmore Avenue and Garvey Avenue in the City of Rosemead. The site is currently developed with retail and outdoor storage uses. The proposed project involves redevelopment with a seven-story mixed- use structure comprised of 93 apartment dwelling units, 6,040 sf of retail space, 12,801 sf of office space, and a parking on lower levels providing 208 parking spaces. The project is anticipated to be operational by 2024. ATMOSPHERIC SETTING The climate of the Rosemead area, as with all of Southern California, is governed largely by the strength and location of the semi-permanent high pressure center over the Pacific Ocean and the moderating effects of the nearby vast oceanic heat reservoir. Local climatic conditions are characterized by very warm summers, mild winters, infrequent rainfall, moderate daytime on- shore breezes, and comfortable humidities. Unfortunately, the same climatic conditions that create such a desirable living climate combine to severely restrict the ability of the local atmosphere to disperse the large volumes of air pollution generated by the population and industry attracted in part by the climate. Rosemead is situated in an area where the pollutants generated in coastal portions of the Los Angeles basin undergo photochemical reactions and then move inland across the Project site during the daily sea breeze cycle. The resulting smog at times gives the western San Gabriel Valley some of the worst air quality in all of California. The worst air quality, however, has gradually been moving eastward. The area of heaviest ozone air pollution has gradually moved eastward from Pasadena in the 1960’s to Glendora and even Upland/Ontario in the 1990’s. Elevated smog levels nevertheless persist in the Rosemead area during the warmer months of the year. Despite dramatic improvement in air quality in the local area throughout the last several decades, the Project site is expected to continue to experience some unhealthful air quality until beyond 2020. Temperatures in the Project vicinity average 62 degrees Fahrenheit annually with summer afternoons in the low 90’s and winter mornings in the low 40’s. Temperatures much above 100 or below 30 degrees occur infrequently only under unusual weather conditions and even then these limits are not far exceeded. In contrast to the slow annual variation of temperature, precipitation is highly variable seasonally. Rainfall in the eastern portions of Los Angeles County averages 17 inches annually and falls almost exclusively from late October to early April. Summers are very dry with frequent periods of 4-5 months of no rain at all. Because much of the rainfall comes from the fringes of mid-latitude storms, a shift in the storm track of a few hundred miles can mean the difference between a very wet year and a year with drought conditions. Winds across the Project area are an important meteorological parameter because they control both the initial rate of dilution of locally generated air pollutant emissions as well as their regional Strathmore and Garvey, Rosemead AQ - 2 - trajectory. Local wind patterns show a fairly unidirectional daytime onshore flow from the SW- W with a very weak offshore return flow from the NE that is strongest on winter nights when the land is colder than the ocean. The onshore winds during the day average 6-8 mph, while the offshore flow is often calm or drifts slowly westward at 1-3 mph. During the daytime, any locally generated air emissions are thus transported eastward toward San Bernardino and Cajon Pass without generating any localized air quality impacts. Strathmore and Garvey, Rosemead AQ - 3 - AIR QUALITY SETTING AMBIENT AIR QUALITY STANDARDS (AAQS) In order to gauge the significance of the air quality impacts of the proposed Project, those impacts, together with existing background air quality levels, must be compared to the applicable ambient air quality standards. These standards are the levels of air quality considered safe, with an adequate margin of safety, to protect the public health and welfare. They are designed to protect those people most susceptible to further respiratory distress such as asthmatics, the elderly, very young children, people already weakened by other disease or illness, and persons engaged in strenuous work or exercise, called "sensitive receptors." Healthy adults can tolerate occasional exposure to air pollutant concentrations considerably above these minimum standards before adverse effects are observed. Recent research has shown, however, that chronic exposure to ozone (the primary ingredient in photochemical smog) may lead to adverse respiratory health even at concentrations close to the ambient standard. National AAQS were established in 1971 for six pollution species with states retaining the option to add other pollutants, require more stringent compliance, or to include different exposure periods. The initial attainment deadline of 1977 was extended several times in air quality problem areas like Southern California. In 2003, the Environmental Protection Agency (EPA) adopted a rule, which extended and established a new attainment deadline for ozone for the year 2021. Because the State of California had established AAQS several years before the federal action and because of unique air quality problems introduced by the restrictive dispersion meteorology, there is considerable difference between state and national clean air standards. Those standards currently in effect in California are shown in Table 1. Sources and health effects of various pollutants are shown in Table 2. The Federal Clean Air Act Amendments (CAAA) of 1990 required that the U.S. Environmental Protection Agency (EPA) review all national AAQS in light of currently known health effects. EPA was charged with modifying existing standards or promulgating new ones where appropriate. EPA subsequently developed standards for chronic ozone exposure (8+ hours per day) and for very small diameter particulate matter (called "PM-2.5"). New national AAQS were adopted in 1997 for these pollutants. Planning and enforcement of the federal standards for PM-2.5 and for ozone (8-hour) were challenged by trucking and manufacturing organizations. In a unanimous decision, the U.S. Supreme Court ruled that EPA did not require specific congressional authorization to adopt national clean air standards. The Court also ruled that health-based standards did not require preparation of a cost-benefit analysis. The Court did find, however, that there was some inconsistency between existing and "new" standards in their required attainment schedules. Such attainment-planning schedule inconsistencies centered mainly on the 8-hour ozone standard. EPA subsequently agreed to downgrade the attainment designation for a large number of communities to “non-attainment” for the 8-hour ozone standard. Strathmore and Garvey, Rosemead AQ - 4 - Table 1 Strathmore and Garvey, Rosemead AQ - 5 - Table 1 (continued) Strathmore and Garvey, Rosemead AQ - 6 - Table 2 Health Effects of Major Criteria Pollutants Pollutants Sources Primary Effects Carbon Monoxide (CO) • Incomplete combustion of fuels and other carbon-containing substances, such as motor exhaust. • Natural events, such as decomposition of organic matter. • Reduced tolerance for exercise. • Impairment of mental function. • Impairment of fetal development. • Death at high levels of exposure. • Aggravation of some heart diseases (angina). Nitrogen Dioxide (NO2) • Motor vehicle exhaust. • High temperature stationary combustion. • Atmospheric reactions. • Aggravation of respiratory illness. • Reduced visibility. • Reduced plant growth. • Formation of acid rain. Ozone (O3) • Atmospheric reaction of organic gases with nitrogen oxides in sunlight. • Aggravation of respiratory and cardiovascular diseases. • Irritation of eyes. • Impairment of cardiopulmonary function. • Plant leaf injury. Lead (Pb) • Contaminated soil. • Impairment of blood function and nerve construction. • Behavioral and hearing problems in children. Respirable Particulate Matter (PM-10) • Stationary combustion of solid fuels. • Construction activities. • Industrial processes. • Atmospheric chemical reactions. • Reduced lung function. • Aggravation of the effects of gaseous pollutants. • Aggravation of respiratory and cardio respiratory diseases. • Increased cough and chest discomfort. • Soiling. • Reduced visibility. Fine Particulate Matter (PM-2.5) • Fuel combustion in motor vehicles, equipment, and industrial sources. • Residential and agricultural burning. • Industrial processes. • Also, formed from photochemical reactions of other pollutants, including NOx, sulfur oxides, and organics. • Increases respiratory disease. • Lung damage. • Cancer and premature death. • Reduces visibility and results in surface soiling. Sulfur Dioxide (SO2) • Combustion of sulfur-containing fossil fuels. • Smelting of sulfur-bearing metal ores. • Industrial processes. • Aggravation of respiratory diseases (asthma, emphysema). • Reduced lung function. • Irritation of eyes. • Reduced visibility. • Plant injury. • Deterioration of metals, textiles, leather, finishes, coatings, etc. Source: California Air Resources Board, 2002. Strathmore and Garvey, Rosemead AQ - 7 - Evaluation of the most current data on the health effects of inhalation of fine particulate matter prompted the California Air Resources Board (ARB) to recommend adoption of the statewide PM-2.5 standard that is more stringent than the federal standard. This standard was adopted in 2002. The State PM-2.5 standard is more of a goal in that it does not have specific attainment planning requirements like a federal clean air standard, but only requires continued progress towards attainment. Similarly, the ARB extensively evaluated health effects of ozone exposure. A new state standard for an 8-hour ozone exposure was adopted in 2005, which aligned with the exposure period for the federal 8-hour standard. The California 8-hour ozone standard of 0.07 ppm is more stringent than the federal 8-hour standard of 0.075 ppm. The state standard, however, does not have a specific attainment deadline. California air quality jurisdictions are required to make steady progress towards attaining state standards, but there are no hard deadlines or any consequences of non- attainment. During the same re-evaluation process, the ARB adopted an annual state standard for nitrogen dioxide (NO2) that is more stringent than the corresponding federal standard, and strengthened the state one-hour NO2 standard. As part of EPA’s 2002 consent decree on clean air standards, a further review of airborne particulate matter (PM) and human health was initiated. A substantial modification of federal clean air standards for PM was promulgated in 2006. Standards for PM-2.5 were strengthened, a new class of PM in the 2.5 to 10 micron size was created, some PM-10 standards were revoked, and a distinction between rural and urban air quality was adopted. In December, 2012, the federal annual standard for PM-2.5 was reduced from 15 g/m3 to 12 g/m3 which matches the California AAQS. The severity of the basin’s non-attainment status for PM-2.5 may be increased by this action and thus require accelerated planning for future PM-2.5 attainment. In response to continuing evidence that ozone exposure at levels just meeting federal clean air standards is demonstrably unhealthful, EPA had proposed a further strengthening of the 8-hour standard. A new 8-hour ozone standard was adopted in 2015 after extensive analysis and public input. The adopted national 8-hour ozone standard is 0.07 ppm which matches the current California standard. It will require three years of ambient data collection, then 2 years of non- attainment findings and planning protocol adoption, then several years of plan development and approval. Final air quality plans for the new standard are likely to be adopted around 2022. Ultimate attainment of the new standard in ozone problem areas such as Southern California might be after 2025. In 2010 a new federal one-hour primary standard for nitrogen dioxide (NO2) was adopted. This standard is more stringent than the existing state standard. Based upon air quality monitoring data in the South Coast Air Basin, the California Air Resources Board has requested the EPA to designate the basin as being in attainment for this standard. The federal standard for sulfur dioxide (SO2) was also recently revised. However, with minimal combustion of coal and mandatory use of low sulfur fuels in California, SO2 is typically not a problem pollutant. Strathmore and Garvey, Rosemead AQ - 8 - BASELINE AIR QUALITY Long-term air quality monitoring is carried out by the South Coast Air Quality Management District (SCAQMD) at various monitoring stations. There are no nearby stations that monitor the full spectrum of pollutants. Ozone, carbon monoxide, PM-2.5 and nitrogen oxides are monitored at the Pico Rivera facility, while 10-micron diameter particulate matter (PM-10) is measured at the Azusa station. Table 3 summarizes the last four years of monitoring data from a composite of these data resources. The following conclusions can be drawn from this data: a. Photochemical smog (ozone) levels occasionally exceed standards. The 1-hour state ozone standard has been exceeded two percent of all measured days and the 8-hour federal standard have been exceeded on three percent of all measured days in the past four years. The 8-hour state standard has been exceeded three percent of days for the same period. While ozone levels are still high, they are much lower than 10 to 20 years ago. Attainment of all clean air standards in the Project vicinity is not likely to occur soon, but the severity and frequency of violations is expected to continue to slowly decline during the current decade b. Measurements of carbon monoxide have shown very low baseline levels in comparison to the most stringent one- and eight-hour standards. c. Respirable dust (PM-10) levels and calculated to have exceed the state standard on approximately 14 percent of measurement days in the last four years for which there is data, but the less stringent federal PM-10 standard has not been violated once for the same period. Year to year fluctuations of overall maximum 24-hour PM-10 levels seem to follow no discernable trend. d. A substantial fraction of PM-10 is comprised of ultra-small diameter particulates capable of being inhaled into deep lung tissue (PM-2.5). SCAQMD data suggests that approximately two percent of all days have exceeded the24-hour threshold in the past four years. PM-2.5 can be an occasional air quality concern in the Project area. Although complete attainment of every clean air standard is not yet imminent, extrapolation of the steady improvement trend suggests that such attainment could occur within the reasonably near future. Strathmore and Garvey, Rosemead AQ - 9 - Table 3 Air Quality Monitoring Summary (2018-2021) (Expected Number of Days Standards Were Exceeded, and Maximum Levels During Such Violations) Pollutant/Standard 2018 2019 2020 2021 1-Hour > 0.09 ppm (S) 3 5 20 2 8-Hour > 0.07 ppm (S) 5 7 23 3 8- Hour > 0.075 ppm (F) 2 3 15 0 Max. 1-Hour Conc. (ppm) 0.12 0.11 0.17 0.10 Max. 8-Hour Conc. (ppm) 0.08 0.09 0.11 0.07 Carbon Monoxide 1-Hour > 20. ppm (S) 0 0 0 0 1-Hour > 9. ppm (S, F) 0 0 0 0 Max 8-Hour Conc. (ppm) 1.8 1.9 1.7 na Nitrogen Dioxide 1-Hour > 0.18 ppm (S) 0 0 0 0 Max. 1-Hour Conc. (ppm) 0.08 0.06 0.07 0.07 Respirable Particulates (PM-10) 24-Hour > 50 g/m3 (S) 59 24 na 66 24-Hour > 150 g/m3 (F) 0 0 0 0 Max. 24-Hr. Conc. (g/m3) 78. 82. 95. 79. Fine Particulates (PM-2.5) 24-Hour > 35 g/m3 (F) 6 3 15 9 Max. 24-Hr. Conc. (g/m3) 56.3 50.2 82.9 66 na=not available S=State Standard F=Federal Standard Source: South Coast AQMD – Pico Rivera Air Monitoring Station for Ozone, CO, NOx and PM-2.5 Azusa Monitoring Station for PM-10 data: www.arb.ca.gov/adam/ Strathmore and Garvey, Rosemead AQ - 10 - AIR QUALITY PLANNING The Federal Clean Air Act (1977 Amendments) required that designated agencies in any area of the nation not meeting national clean air standards must prepare a plan demonstrating the steps that would bring the area into compliance with all national standards. The SCAB could not meet the deadlines for ozone, nitrogen dioxide, carbon monoxide, or PM-10. In the SCAB, the agencies designated by the governor to develop regional air quality plans are the SCAQMD and the Southern California Association of Governments (SCAG). The two agencies first adopted an Air Quality Management Plan (AQMP) in 1979 and revised it several times as earlier attainment forecasts were shown to be overly optimistic. The 1990 Federal Clean Air Act Amendment (CAAA) required that all states with air-sheds with “serious” or worse ozone problems submit a revision to the State Implementation Plan (SIP). Substantial reductions in emissions of ROG, NOx and CO are forecast to continue throughout the next several decades. Unless new particulate control programs are implemented, PM-10 and PM- 2.5 are forecast to slightly increase. The Air Quality Management District (AQMD) adopted an updated clean air “blueprint” in August 2003. The 2003 Air Quality Management Plan (AQMP) was approved by the EPA in 2004. The AQMP outlined the air pollution measures needed to meet federal health-based standards for ozone by 2010 and for particulates (PM-10) by 2006. The 2003 AQMP was based upon the federal one- hour ozone standard which was revoked late in 2005 and replaced by an 8-hour federal standard. Because of the revocation of the hourly standard, a new air quality planning cycle was initiated. With re-designation of the air basin as non-attainment for the 8-hour ozone standard, a new attainment plan was developed. This plan shifted most of the one-hour ozone standard attainment strategies to the 8-hour standard. As previously noted, the attainment date was to “slip” from 2010 to 2021. The updated attainment plan also includes strategies for ultimately meeting the federal PM-2.5 standard. Because Projected attainment by 2021 required control technologies that did not exist yet, the SCAQMD requested a voluntary “bump-up” from a “severe non-attainment” area to an “extreme non-attainment” designation for ozone. The extreme designation was to allow a longer time period for these technologies to develop. If attainment cannot be demonstrated within the specified deadline without relying on “black-box” measures, EPA would have been required to impose sanctions on the region had the bump-up request not been approved. In April 2010, the EPA approved the change in the non-attainment designation from “severe-17” to “extreme.” This reclassification set a later attainment deadline (2024), but also required the air basin to adopt even more stringent emissions controls. In other air quality attainment plan reviews, EPA had disapproved part of the SCAB PM-2.5 attainment plan included in the AQMP. EPA stated that the current attainment plan relied on PM- 2.5 control regulations that had not yet been approved or implemented. It was expected that several rules that were pending approval would remove the identified deficiencies. If these issues were not resolved within the next several years, federal funding sanctions for transportation Projects could Strathmore and Garvey, Rosemead AQ - 11 - result. The 2012 AQMP included in the current California State Implementation Plan (SIP) was expected to remedy identified PM-2.5 planning deficiencies. The federal Clean Air Act requires that non-attainment air basins have EPA approved attainment plans in place. This requirement includes the federal one-hour ozone standard even though that standard was revoked almost ten years ago. There was no approved attainment plan for the one- hour federal standard at the time of revocation. Through a legal quirk, the SCAQMD is now required to develop an AQMP for the long since revoked one-hour federal ozone standard. Because the current SIP for the basin contains a number of control measures for the 8-hour ozone standard that are equally effective for one-hour levels, the 2012 AQMP was believed to satisfy hourly attainment planning requirements. AQMPs are required to be updated at regular intervals. The 2012 AQMP was adopted in early 2013. An updated 2016 AQMP was adopted by the SCAQMD Board in March 2017. The 2016 AQMD demonstrated the emissions reductions shown in Table 4 compared to the 2012 AQMP. Table 4 Comparison of Emissions by Major Source Category From 2012 AQMP Pollutant Stationary Sources Mobile Sources VOC -12% -3% NOx -13% -1% SOx -34% -23% PM2.5 -9% -7% *source 2016 AQMP SCAQMD has initiated the development of the 2022 AQMP to address the attainment of the 2015 8-hour ozone standard (70 ppb) for South Coast Air Basin and Coachella Valley which will focus on attaining the 70 ppb 8-hour ozone National Ambient Air Quality Standard (NAAQS) by 2037. On-road vehicles and off-road mobile sources represent the largest categories of NOx emissions. Accomplishment of attainment goals requires an approximate 70% reduction in NOx emissions. Large scale transition to zero emission technologies is a key strategy. To this end, Governor Executive Order N-79-20 requires 100 percent EV sales by 2035 for automobiles and short haul drayage trucks. A full transition to EV buses and heavy-duty long-haul trucks is required by 2045. The proposed Project does not directly relate to the AQMP in that there are no specific air quality programs or regulations governing mixed use development Projects. Conformity with adopted plans, forecasts and programs relative to population, housing, employment and land use is the primary yardstick by which impact significance of planned growth is determined. The SCAQMD, however, while acknowledging that the AQMP is a growth-accommodating document, does not favor designating regional impacts as less-than-significant just because the proposed development is consistent with regional growth Projections. Air quality impact significance for the proposed Project has therefore been analyzed on a Project-specific basis. Strathmore and Garvey, Rosemead AQ - 12 - AIR QUALITY IMPACT STANDARDS OF SIGNIFICANCE Air quality impacts are considered “significant” if they cause clean air standards to be violated where they are currently met, or if they “substantially” contribute to an existing violation of standards. Any substantial emissions of air contaminants for which there is no safe exposure, or nuisance emissions such as dust or odors, would also be considered a significant impact. Appendix G of the California CEQA Guidelines offers the following four tests of air quality impact significance. A Project would have a potentially significant impact if it: a) Conflicts with or obstructs implementation of the applicable air quality plan. b) Results in a cumulatively considerable net increase of any criteria pollutants for which the Project region is non-attainment under an applicable federal or state ambient air quality standard. c) Exposes sensitive receptors to substantial pollutant concentrations. d) Creates objectionable odors affecting a substantial number of people. Primary Pollutants Air quality impacts generally occur on two scales of motion. Near an individual source of emissions or a collection of sources such as a crowded intersection or parking lot, levels of those pollutants that are emitted in their already unhealthful form will be highest. Carbon monoxide (CO) is an example of such a pollutant. Primary pollutant impacts can generally be evaluated directly in comparison to appropriate clean air standards. Violations of these standards where they are currently met, or a measurable worsening of an existing or future violation, would be considered a significant impact. Many particulates, especially fugitive dust emissions, are also primary pollutants. Because of the non-attainment status of the South Coast Air Basin (SCAB) for PM-10, an aggressive dust control program is required to control fugitive dust during Project construction. Secondary Pollutants Many pollutants, however, require time to transform from a more benign form to a more unhealthful contaminant. Their impact occurs regionally far from the source. Their incremental regional impact is minute on an individual basis and cannot be quantified except through complex photochemical computer models. Analysis of significance of such emissions is based upon a specified amount of emissions (pounds, tons, etc.) even though there is no way to translate those emissions directly into a corresponding ambient air quality impact. Because of the chemical complexity of primary versus secondary pollutants, the SCAQMD has designated significant emissions levels as surrogates for evaluating regional air quality impact significance independent of chemical transformation processes. Projects with daily emissions that Strathmore and Garvey, Rosemead AQ - 13 - exceed any of the following emission thresholds are recommended by the SCAQMD to be considered significant under CEQA guidelines. Table 5 Daily Emissions Thresholds Source: SCAQMD CEQA Air Quality Handbook, November, 1993 Rev. Pollutant Construction Operations ROG 75 55 NOx 100 55 CO 550 550 PM-10 150 150 PM-2.5 55 55 SOx 150 150 Lead 3 3 Strathmore and Garvey, Rosemead AQ - 14 - CONSTRUCTION ACTIVITY IMPACTS CalEEMod was developed by the SCAQMD to provide a model by which to calculate both construction emissions and operational emissions from a variety of land use Projects. It calculates both the daily maximum and annual average emissions for criteria pollutants as well as total or annual greenhouse gas (GHG) emissions. The site is currently developed with retail and outdoor storage uses. The proposed project involves redevelopment with a seven-story mixed-use building comprised of 93 apartment dwelling units, 6,040 sf of retail, 12,801 sf of office, and a parking on lower levels providing 208 parking spaces. Construction was modeled in CalEEMod2020.4.0 using the construction equipment and schedule for a Project of this size as shown in Table 6. Table 6 Construction Activity Equipment Fleet Phase Name and Duration Equipment Demolition (20 days) 1 Concrete Saw 1 Dozer 3 Loader/Backhoes Grading (4 days) 1 Grader 1 Dozer 2 Loader/Backhoes Construction (200 days) 1 Crane 1 Generator Set 1 Loader/Backhoe 3 Welders 1 Forklift Paving (10 days) 1 Paver 1 Paving Equipment 1 Mixer 1 Loader/Backhoe 1 Roller Utilizing this indicated equipment fleet and durations shown in Table 6 the following worst-case daily construction emissions are calculated by CalEEMod and are listed in Table 7. Strathmore and Garvey, Rosemead AQ - 15 - Table 7 Construction Activity Emissions Maximum Daily Emissions (pounds/day) Maximal Construction Emissions ROG NOx CO SO2 PM-10 PM-2.5 2023 39.9 14.6 16.8 0.0 3.2 1.9 SCAQMD Thresholds 75 100 550 150 150 55 Peak daily construction activity emissions are estimated be below SCAQMD CEQA thresholds with active dust suppression (watering at least 2x a day during grading activities). Construction equipment exhaust contains carcinogenic compounds within the diesel exhaust particulates. The toxicity of diesel exhaust is evaluated relative to a 24-hour per day, 365 days per year, 70-year lifetime exposure. The SCAQMD does not generally require the analysis of construction-related diesel emissions relative to health risk due to the short period for which the majority of diesel exhaust would occur. Health risk analyses are typically assessed over a 9-, 30-, or 70-year timeframe and not over a relatively brief construction period due to the lack of health risk associated with such a brief exposure. LOCALIZED SIGNIFICANCE THRESHOLDS The SCAQMD has developed analysis parameters to evaluate ambient air quality on a local level in addition to the more regional emissions-based thresholds of significance. These analysis elements are called Localized Significance Thresholds (LSTs). LSTs were developed in response to Governing Board’s Environmental Justice Enhancement Initiative 1-4 and the LST methodology was provisionally adopted in October 2003 and formally approved by SCAQMD’s Mobile Source Committee in February 2005. Use of an LST analysis for a Project is optional. For the proposed Project, the primary source of possible LST impact would be during construction. LSTs are applicable for a sensitive receptor where it is possible that an individual could remain for 24 hours such as a residence, hospital or convalescent facility. LSTs are only applicable to the following criteria pollutants: oxides of nitrogen (NOx), carbon monoxide (CO), and particulate matter (PM-10 and PM-2.5). LSTs represent the maximum emissions from a Project that are not expected to cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standard and are developed based on the ambient concentrations of that pollutant for each source receptor area and distance to the nearest sensitive receptor. LST screening tables are available for 25, 50, 100, 200- and 500-meter source-receptor distances. For this Project, there are adjacent residential uses such that the most conservative 25-meter distance was modeled. Strathmore and Garvey, Rosemead AQ - 16 - The SCAQMD has issued guidance on applying CalEEMod to LSTs. LST pollutant screening level concentration data is currently published for 1, 2- and 5-acre sites for varying distances. For this Project, the most stringent thresholds for a 1-acre site were applied. The following thresholds and emissions in Table 8 are therefore determined (pounds per day): Table 8 LST and Project Emissions (pounds/day) 1.0 acre/25 meters South San Gabriel Valley CO NOx PM-10 PM-2.5 LST Threshold 673 83 5 4 Max On-Site Emissions 17 15 3 2 CalEEMod Output in Appendix *Emissions for LST are limited to those generated on site and do not include regional emissions for on-road truck haul and include active dust suppression during grading activities LSTs were compared to the maximum daily construction activities. As seen in Table 8, LST impacts are less-than-significant. OPERATIONAL IMPACTS The Project would generate 864 daily trips using trip generation numbers provided in the Project traffic report. Operational emissions were calculated using CalEEMod2020.4.0 for an assumed full occupancy year of 2024. The operational impacts are shown in Table 9. As shown, operational emissions will not exceed applicable SCAQMD operational emissions CEQA thresholds of significance. Table 9 Proposed Uses Daily Operational Impacts (2024) Operational Emissions (lbs/day) Source ROG NOx CO SO2 PM-10 PM-2.5 Area* 2.7 0.1 7.7 <0.1 <0.1 0.1 Energy <0.1 0.3 0.2 <0.1 <0.1 <0.1 Mobile 2.4 2.4 22.5 0.1 5.3 1.4 Total 5.1 2.8 30.4 0.1 5.3 1.5 SCAQMD Threshold 55 55 550 150 150 55 Exceeds Threshold? No No No No No No *no wood burning fireplaces-only natural gas Source: CalEEMod Output in Appendix Strathmore and Garvey, Rosemead AQ - 17 - CONSTRUCTION EMISSIONS MINIMIZATION Construction activities are not anticipated to cause dust emissions to exceed SCAQMD CEQA thresholds. Nevertheless, emissions minimization through enhanced dust control measures is recommended for use because of the non-attainment status of the air and proximity of residential uses. Recommended measures include: Fugitive Dust Control • Apply soil stabilizers or moisten inactive areas. • Water exposed surfaces as needed to avoid visible dust leaving the construction site (typically 2-3 times/day). • Cover all stock piles with tarps at the end of each day or as needed. • Provide water spray during loading and unloading of earthen materials. • Minimize in-out traffic from construction zone • Cover all trucks hauling dirt, sand, or loose material and require all trucks to maintain at least two feet of freeboard • Sweep streets daily if visible soil material is carried out from the construction site Similarly, ozone precursor emissions (ROG and NOx) are calculated to be below SCAQMD CEQA thresholds. However, because of the regional non-attainment for photochemical smog, the use of reasonably available control measures for diesel exhaust is recommended. Combustion emissions control options include: Exhaust Emissions Control • Utilize well-tuned off-road construction equipment. • Establish a preference for contractors using Tier 3 or better rated heavy equipment. • Enforce 5-minute idling limits for both on-road trucks and off-road equipment. Strathmore and Garvey, Rosemead AQ - 18 - GREENHOUSE GAS EMISSIONS “Greenhouse gases” (so called because of their role in trapping heat near the surface of the earth) emitted by human activity are implicated in global climate change, commonly referred to as “global warming.” These greenhouse gases contribute to an increase in the temperature of the earth’s atmosphere by transparency to short wavelength visible sunlight, but near opacity to outgoing terrestrial long wavelength heat radiation in some parts of the infrared spectrum. The principal greenhouse gases (GHGs) are carbon dioxide, methane, nitrous oxide, ozone, and water vapor. For purposes of planning and regulation, Section 15364.5 of the California Code of Regulations defines GHGs to include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride. Fossil fuel consumption in the transportation sector (on- road motor vehicles, off-highway mobile sources, and aircraft) is the single largest source of GHG emissions, accounting for approximately half of GHG emissions globally. Industrial and commercial sources are the second largest contributors of GHG emissions with about one-fourth of total emissions. California has passed several bills and the Governor has signed at least three executive orders regarding greenhouse gases. GHG statues and executive orders (EO) include AB 32, SB 1368, EO S-03-05, EO S-20-06 and EO S-01-07. AB 32 is one of the most significant pieces of environmental legislation that California has adopted. Among other things, it is designed to maintain California’s reputation as a “national and international leader on energy conservation and environmental stewardship.” It will have wide- ranging effects on California businesses and lifestyles as well as far reaching effects on other states and countries. A unique aspect of AB 32, beyond its broad and wide-ranging mandatory provisions and dramatic GHG reductions are the short time frames within which it must be implemented. Major components of the AB 32 include: • Require the monitoring and reporting of GHG emissions beginning with sources or categories of sources that contribute the most to statewide emissions. • Requires immediate “early action” control programs on the most readily controlled GHG sources. • Mandates that by 2020, California’s GHG emissions be reduced to 1990 levels. • Forces an overall reduction of GHG gases in California by 25-40%, from business as usual, to be achieved by 2020. • Must complement efforts to achieve and maintain federal and state ambient air quality standards and to reduce toxic air contaminants. Statewide, the framework for developing the implementing regulations for AB 32 is under way. Maximum GHG reductions are expected to derive from increased vehicle fuel efficiency, from greater use of renewable energy and from increased structural energy efficiency. Additionally, through the California Climate Action Registry (CCAR now called the Climate Action Reserve), general and industry-specific protocols for assessing and reporting GHG emissions have been Strathmore and Garvey, Rosemead AQ - 19 - developed. GHG sources are categorized into direct sources (i.e. company owned) and indirect sources (i.e. not company owned). Direct sources include combustion emissions from on-and off- road mobile sources, and fugitive emissions. Indirect sources include off-site electricity generation and non-company owned mobile sources. THRESHOLDS OF SIGNIFICANCE In response to the requirements of SB97, the State Resources Agency developed guidelines for the treatment of GHG emissions under CEQA. These new guidelines became state laws as part of Title 14 of the California Code of Regulations in March, 2010. The CEQA Appendix G guidelines were modified to include GHG as a required analysis element. A Project would have a potentially significant impact if it: • Generates GHG emissions, directly or indirectly, that may have a significant impact on the environment, or, • Conflicts with an applicable plan, policy or regulation adopted to reduce GHG emissions. Section 15064.4 of the Code specifies how significance of GHG emissions is to be evaluated. The process is broken down into quantification of Project-related GHG emissions, making a determination of significance, and specification of any appropriate mitigation if impacts are found to be potentially significant. At each of these steps, the new GHG guidelines afford the lead agency with substantial flexibility. Emissions identification may be quantitative, qualitative or based on performance standards. CEQA guidelines allow the lead agency to “select the model or methodology it considers most appropriate.” The most common practice for transportation/combustion GHG emissions quantification is to use a computer model such as CalEEMod, as was used in the ensuing analysis. The significance of those emissions then must be evaluated; the selection of a threshold of significance must take into consideration what level of GHG emissions would be cumulatively considerable. The guidelines are clear that they do not support a zero net emissions threshold. If the lead agency does not have sufficient expertise in evaluating GHG impacts, it may rely on thresholds adopted by an agency with greater expertise. On December 5, 2008 the SCAQMD Governing Board adopted an Interim quantitative GHG Significance Threshold for industrial Projects where the SCAQMD is the lead agency (e.g., stationary source permit Projects, rules, plans, etc.) of 10,000 Metric Tons (MT) CO2 equivalent/year. In September 2010, the SCAQMD CEQA Significance Thresholds GHG Working Group released revisions which recommended a threshold of 3,000 MT CO2e for all land use Projects. This 3,000 MT/year recommendation has been used as a guideline for this analysis. In the absence of an adopted numerical threshold of significance, Project related GHG emissions in excess of the guideline level are presumed to trigger a requirement for enhanced GHG reduction at the Project level. Strathmore and Garvey, Rosemead AQ - 20 - PROJECT RELATED GHG EMISSIONS GENERATION Construction Activity GHG Emissions CalEEMod assumes the Project to require approximately one year for construction. During Project construction, the CalEEMod2020.4.0 computer model predicts that the construction activities will generate the annual CO2e emissions identified in Table 10. Table 10 Construction Emissions (Metric Tons CO2e) CO2e Year 2023 365.9 Amortized 12.2 CalEEMod Output provided in appendix SCAQMD GHG emissions policy from construction activities is to amortize emissions over a 30- year lifetime. The amortized level is also provided. GHG impacts from construction are considered individually less-than-significant. Project Operational GHG Emissions The input assumptions for operational GHG emissions calculations, and the GHG conversion from consumption to annual regional CO2e emissions are summarized in the CalEEMod2020.4.0 output files found in the appendix of this report. The total operational and annualized construction emissions for the proposed Project are identified in Table 11. The Project GHG emissions are considered less-than-significant. Table 11 Operational Emissions (Metric Tons CO2e) Consumption Source Area Sources* 1.6 Energy Utilization 261.9 Mobile Source 840.2 Solid Waste Generation 30.7 Water Consumption 43.2 Construction 12.2 Total 1,189.8 Guideline Threshold 3,000 *natural gas hearth Strathmore and Garvey, Rosemead AQ - 21 - CONSISTENCY WITH GHG PLANS, PROGRAMS AND POLICIES The City of Rosemead has not yet developed a Greenhouse Gas Reduction Plan. The applicable GHG planning document is AB-32. As discussed above, the Project is not expected to result in a significant increase in GHG emissions. As a result, the Project results in GHG emissions below the recommended SCAQMD 3,000-ton threshold. Therefore, the Project would not conflict with any applicable plan, policy, or regulation to reduce GHG emissions. Strathmore and Garvey, Rosemead AQ - 22 - CALEEMOD2020.4.0 COMPUTER MODEL OUTPUT • DAILY EMISISONS • ANNUAL EMISSIONS