PC - Item 3B - Exhibit F - Appendix A AQ GHG and Energy
Urban Planning ■ Due Diligence ■ Entitlements ■ CEQA/NEPA ■ Development Services ■ Management ■ Public Outreach
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This technical memorandum presents an analysis of the air quality, energy, and greenhouse gas (GHG)
impact for the proposed Mission Villas Residential Development (project), located on Mission Drive east of
Walnut Grove Avenue in the City of Rosemead. The project proposes the construction of 29 single family
homes and eight townhomes with common open space and landscaping on a 3.435-acre site. The site is
mostly vacant, with approximately 2,000 sf of concrete pavement on the south and west side of the project
site. To support the CEQA document for the proposed project, this report analyzes the proposed project’s
construction and operational impacts to air quality (emission of criterial pollutants) emissions using the
California Emissions Estimator Model (CalEEMod v. 2022.1) land use emission model. Table 1 shows the
estimated construction schedule, which is expected to last about 11 months.
Table 1. Construction Schedule
Activity Start Date End Date Total Days
Demolition 3/1/2023 3/2/2023 2
Site Preparation 3/3/2023 3/8/2023 5
Grading 3/9/2023 3/17/2023 8
Building Construction 3/18/2023 12/11/2023 230
Paving 12/12/2023 1/1/2024 18
Architectural Coating 1/2/2024 1/22/2024 18
Summary of Air Quality, Energy and GHG Impacts
Air Quality:
The project’s maximum daily emissions (regional and local) for construction and operation of the project
would not exceed SCAQMD’s regional thresholds of significance. In addition, all construction activities would
comply with applicable SCAQMD rules and regulations, including Rule 403 to minimize fugitive PM dust
emissions, Rule 445 preventing woodfire stoves, and Rule 1113 which allows only Low-Volatile Organic
Compounds (VOC) paints. Projects that do not exceed the regional thresholds are assumed to not have a
significant impact on a project level and cumulative level. Therefore, the proposed project would have less
than significant air quality impacts.
Energy:
The project’s energy consumption for construction does not have any unusual characteristics and is not less
efficient compared with other similar construction sites. The operation of the project is also similar to other
residential projects and would comply with Title 24 as well as all applicable City business and energy codes
and ordinances.
To: City of Rosemead, Planning Division
From: Alex J. Garber
Date: 7/29/2022
Re: Air Quality, Energy, and Greenhouse Gas Impact Analysis for the Mission Villas
Residential Development
Mission Villas Residential Development
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GHG:
Finally, the proposed project’s GHG emissions of 613 MTCO2e per year are below the existing operation
and the SCAQMD significance threshold of 3,000 MTCO2e per year for residential projects. Therefore, the
project has a less then significant impact on GHG emissions.
Air Quality Impact Tables
Regional Emissions
The SCAQMD has adopted maximum daily emission thresholds1 (pounds/day) for the criteria pollutants
during construction and operation of a project. While incremental regional air quality impacts of an
individual project are generally very small and difficult to measure, SCAQMDs regional maximum emission
thresholds set standards to reduce the burden of SCAQMD to attain and maintain ambient air quality
standards. The regional thresholds apply to the criteria pollutants mentioned above and can be found in
Table 2 and Table 3 along with the CalEEMod projects emissions. These emission thresholds include the
project emissions generated both from onsite sources (such as off-road construction equipment and fugitive
dust) and offsite sources (vehicle travel leaving and arriving to the site). As can be seen in Table 2 and Table
3, the project would have less then significant regional air quality impacts.
Table 2. Regional Construction Emission Estimates
Construction Activity
Maximum Daily Regional Emissions
(pounds/day)
ROG NOx CO SOx PM10 PM2.5
2023
Demolition 2.9 28.3 24.9 0.0 1.7 1.2
Site Prep 4.0 39.7 35.5 0.1 6.9 4.3
Grading 2.1 20.1 20.7 0.0 2.8 1.8
Building Construction 1.4 13.1 15.7 0.0 0.6 0.6
Paving 1.1 8.5 10.5 0.0 0.4 0.4
Maximum Daily Emissions 4.0 39.7 35.5 0.1 6.9 4.3
2024
Paving 1.1 8.2 10.5 0.0 0.4 0.4
Architectural Coating 31.3 1.2 1.5 0.0 0.0 0.0
Maximum Daily Emissions 31.3 8.2 10.5 0.0 0.4 0.4
Maximum Daily
Emission 2023-2024 31.3 39.7 35.5 0.1 6.9 4.3
SCAQMD Significance
Thresholds 75 100 550 150 150 55
Threshold Exceeded? No No No No No No
Table 3. Regional Operational Emission Estimates
Operational Activity
Maximum Daily Regional Emissions
(pounds/day)
ROG NOx CO SOx PM10 PM2.5
Area 2.2 0.6 2.4 0.0 0.1 0.1
Energy 0.0 0.6 0.3 0.0 0.1 0.1
Mobile 1.3 1.1 11.6 0.0 0.9 0.2
Total Project Operational
Emissions 3.5 2.4 14.2 0.0 1.0 0.3
SCAQMD Significance
Thresholds 55 55 550 150 150 55
Threshold Exceeded? No No No No No No
Local Emissions
1 SCAQMD April 2019. Found at http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-
significance-thresholds.pdf
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Localized significance thresholds (LSTs) were also adopted by the SCAQMD due to project-related
construction or operational air emissions having the potential to exceed the state and national air quality
standards in the project vicinity, while not exceeding the regional emission significance thresholds adopted
by the SCAQMD. These thresholds set the maximum rates of daily construction or operational emissions from
a project site that would not exceed a national or State ambient air quality standard2. The differences
between regional thresholds and LSTs are as follows:
1. Regional thresholds include all sources of project construction and operational emissions generated
from onsite and offsite emission sources whereas the LSTs only consider the emissions generated from
onsite emission sources.
2. LSTs only apply to CO, NOx, PM10, and PM2.5, while regional thresholds include both ROG and SOx.
3. Regional Thresholds apply to emission sources located anywhere within the SCAQMD whereas the
LSTs are location dependent and also depend on the size of the project, and emission location
relative to the nearest sensitive receptor.
A sensitive receptor is defined as an individual who is most susceptible to negative health affects when
exposed to air pollutants including children, the elderly, and adults with chronic health issues. Such receptors
include residences, schools, elderly care centers, and hospitals. SCAQMD provides screening look up tables
(Appendix C of the SCAQMD 2008 Final Localized Significance Threshold Methodology)3 for projects that
disturb less than or equal to 5 acres in size in a day. These tables were created to easily determine if the
daily emissions of NOx, CO, PM10, and PM2.5 from a project could result in a significant impact to the local
air quality. The thresholds are determined by:
• Source receptor area (SRA), the geographic area within the SCAQMD that can act as both a source
of emissions and a receptor of emission impacts (project is located within SRA 11, South San Gabriel
Valley),
• Size of the project,
• Distance to the nearest sensitive receptor.
The phase with the most ground disturbance would be the grading phase, which would grade 2.5 acres per
day. The thresholds for 2 acres from Appendix C were used for a conservative analysis. Distance to the
nearest sensitive receptor also determines the emission thresholds. The sensitive receptors closest to the project
include residential homes northwest of the project boundary, about 1.35 meters (4.43 feet) from the property
line. These receptors (distance from the project property line to the residential structure) are less than the
minimum distance provided in the lookup tables (25 meters). Therefore, 25 meters (82 feet) was used. Table
4 shows the thresholds and estimated maximum daily construction emissions for the proposed project. As seen
in Table 4, the proposed project has a less then significant localized construction air quality impact.
2 SCAQMD 2008: Final Localized Significance Threshold Methodology. Referenced on 9/3/2020 at
http://www.aqmd.gov/docs/defaultsource/ceqa/handbook/localized-significance-thresholds/final-lst-
methodology-document.pdf
3 SCAQMD 2008: Final Localized Significance Threshold Methodology Appendix C. Referenced on 9/16/2020 at
http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/appendix-c-mass-
rate-lst-look-up-tables.pdf?sfvrsn=2
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Table 4. Localized Construction Emission Estimates
Construction Activity
Maximum Daily Regional Emissions
(pounds/day)
NOx CO PM10 PM2.5
2022
Demolition 27.3 23.5 1.7 1.2
Site Prep 39.7 35.5 6.9 4.3
Grading 20.0 19.7 2.8 1.8
Building Construction 12.8 14.3 0.6 0.6
Paving 8.5 10.5 0.4 0.4
Maximum Daily Emissions 39.7 35.5 6.9 4.3
2023
Paving 8.2 10.5 0.4 0.4
Architectural Coating 1.2 1.5 0.0 0.0
Maximum Daily Emissions 8.2 10.5 0.4 0.4
Maximum Daily Emission 2023-2024 39.7 35.5 6.9 4.3
SCAQMD Significance Thresholds 121 1,031 7 5
Threshold Exceeded? No No No No
According to the SCAQMD LST methodology, LSTs apply to project stationary mobile sources. Projects that
involve mobile sources that spend long periods queuing and idling at a site, such as transfer facilities or
warehousing and distribution buildings, have the potential to exceed the operational localized significance
thresholds. The proposed project would operate 37 residential units, which do not involve vehicles idling or
queueing for long periods. Therefore, due to the lack of significant stationary source emissions, impacts
related to operational localized significance thresholds would be less than significant.
Energy
The State CEQA Guidelines do not have specific thresholds for Energy consumption. Rather, the question in
Appendix G: VI Energy (a) asks, “[Does the proposed project] Result in potentially significant environmental
impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project
construction or operation?”. Therefore, for the purpose of this analysis, a significant impact would occur if:
• The Project design and/or location encourages wasteful, inefficient, and unnecessary consumption
of energy, especially fossil fuels such as coal, natural gas, and petroleum, as well as the use of fuel
by vehicles anticipated to travel to and from the project.
The following assumptions were used to calculate the energy consumption of the proposed project:
• The project’s construction and operational energy consumption would be provided by Southern
California Edison Company.
• Construction equipment fuel consumption derived from ARB Offroad2021 emission model
• Fuel Consumption from vehicle travel derived from ARB EMFAC2021 emission model
• Electrical and natural gas usage derived from the CalEEMod model
Construction
Electricity and Natural Gas Usage:
Due to the project size and the fact that construction is temporary, the electricity used would be substantially
less than that required for project operation and would have a negligible contribution to the project’s overall
energy consumption. The electric power used would be for as-necessary lighting and electronic equipment
such as computers inside temporary construction trailers. Natural gas is not anticipated to be needed for
construction activities. Any consumption of natural gas would be minor and negligible in comparison to the
operation of the proposed project.
Petroleum Fuel Usage:
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The construction equipment associated with construction activities (off-road/heavy duty vehicles) would rely
on diesel fuel as would vendor and haul trucks involved in delivering building materials and removing the
demolition debris from the project site. Construction workers would travel to and from the project site
throughout the duration of construction, and for a conservative analysis it is assumed that construction workers
would travel in gasoline-powered passenger vehicles.
Table 5 shows the total fuel consumption and horsepower-hour data contained within the ARB OffRoad2021
emission model for specific types of diesel construction equipment. It should be noted that the total fuel
consumption is a conservative analysis and would likely overstate the amount of fuel usage, as specific
construction equipment is not expected to operate during the duration of the construction activity (i.e., crane).
Table 6 summarizes the project’s construction vehicle fuel usage based on vehicle miles traveled and fuel
usage factors contained in the ARB EMFAC2021. The trips included are worker vehicles, vendor vehicles, and
haul vehicles. Table 7 shows the overall fuel consumption for construction of the proposed project.
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Table 5. Construction Equipment Fuel Usage
Activity Equipment Number
Hours
per
day
Horse-
power
Load
Factor
Days of
Construction
Total
Horsepower-
hours
Fuel Rate
(gal/hp-hr)
Fuel Use
(gallons)
Demolition
Rubber Tired Dozers 2 8 367 0.4 2 4,698 0.020615155 97
Concrete/Industrial Saws 1 8 33 0.73 2 385 0.041912413 16
Excavators 3 8 36 0.38 2 657 0.019868435 13
Site Preparation Rubber Tired Dozers 3 8 367 0.4 5 17,616 0.020615155 363
Tractors/Loaders/Backhoes 4 8 84 0.37 5 4,973 0.019155948 95
Grading
Graders 1 8 148 0.41 8 3,884 0.021167864 82
Excavators 1 8 36 0.38 8 876 0.019868435 17
Tractors/Loaders/Backhoes 3 8 84 0.37 8 5,967 0.019155948 114
Rubber Tired Dozers 1 8 367 0.4 8 9,395 0.020615155 194
Model Building Construction
Cranes 1 8 367 0.29 230 195,831 0.014896922 2,917
Forklifts 3 8 82 0.2 230 90,528 0.010444038 945
Generator Sets 1 8 14 0.74 230 19,062 0.042356362 807
Tractors/Loaders/Backhoes 1 8 84 0.37 230 57,187 0.019155948 1,095
Welder 3 8 46 0.45 230 114,264 0.025848623 2,954
Paving
Tractors/Loaders/Backhoes 1 8 84 0.37 18 4,476 0.019155948 86
Cement and Mortar Mixers 2 8 10 0.56 18 1,613 0.019767572 32
Pavers 1 8 81 0.42 18 4,899 0.021536901 106
Paving Equipment 2 8 89 0.36 18 9,228 0.01846541 170
Rollers 2 8 36 0.38 18 3,940 0.019837453 78
Architectural Coating Air Compressors 1 8 78 0.48 18 5,391 0.027606329 149
Total 10,233
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Table 6. Estimated Project Vehicle Fuel Usage
Construction
Source Number VMT Fuel Rate Gallons of Diesel
Fuel
Gallons of
Gasoline Fuel
Haul Trucks 56 1,120 5.96 188 0
Vendor Trucks 4 9,384 8.87 1,058 0
Worker Vehicles 72 80,179 25.91 0 3,095
Total 1,246 3,095
Table 7. Total Construction Fuel Usage
Construction Source Gallons of Diesel Fuel Gallons of Gasoline Fuel
Construction Vehicles 1,246 3,095
Off-road Construction
Equipment 10,233 0
Total 11,479 3,095
Operation
The operation of the proposed project would consume electricity, natural gas, and petroleum. The net energy
consumption can be found in Table 8 below. Electricity and natural gas consumption were found in the Annual
CalEEMod Output Sheets attached. The gasoline consumption rates utilize the same assumptions that were
used for the worker vehicles.
Table 8. Annual Operational Energy Requirements
Operational Source Energy Usage
Electricity (Kilowatt-Hours)
Project 252,539
Natural Gas (Thousands British Thermal Units)
Project 1,242,170
Petroleum (gasoline) Consumption
Annual VMT Gallons of Gasoline Fuel
Project 1,127,736 43,533
Conclusion
The proposed project has no unusual characteristics that would make the construction fuel and energy
consumption associated with construction of the project less efficient compared with other similar construction
sites throughout the state. The consumption would also be temporary and localized. Operation of the 29
single family and eight townhome residential units would comply with all the energy efficiency requirements
under Title 24 and all applicable City business and energy codes ordinances. Therefore, the construction
and operation of the project would result in a less than significant impact for inefficient, wasteful, or
unnecessary energy use, and no mitigation would be required.
Greenhouse Gas
SCAQMD has convened a Greenhouse Gas Emissions (GHG) CEQA Significance Threshold Working Group
to help lead agencies determine significance thresholds for GHG emissions when SCAQMD is not the lead
agency. The last working group was held September 2010 (Meeting No. 15)4 and proposed a tiered
approach, equivalent to the existing consistency determination requirements in CEQA Guidelines Sections
15064(h)(3), 15125(d), or 15152(a). The most recent proposal issued in Meeting No. 15 uses a tiered
approach, Tier 1 to Tier 5, to evaluate potential GHG impacts from various uses. This assessment will apply
4 SCAQMD 2010. Minutes of the GHG CEQA Significance Threshold Stakeholder Working Group #15. Referenced
on 9/21/2020 at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-
significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf
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the Tier 3: Numerical Screening Thresholds approach. Tier three consists of screening values in metric tons of
carbon dioxide equivalent (MTCO2e) (converting other greenhouse gasses to an equivalent impact of CO2),
which the lead agency can choose, but must be consistent with all projects within its jurisdiction. A project’s
construction emissions are averaged over 30 years and are added to the project’s operational emissions. If
a project’s emissions are below one of the following screening thresholds, then the project impact would be
is less than significant:
• Option 1: All land use types: 3,000 MTCO2e per year
• Option 2: Based on land use type: residential: 3,500 MTCO2e per year; commercial: 1,400
MTCO2e per year; or mixed use: 3,000 MT CO2e per year
Executive Order S-3-05’s year 2050 goal is the basis of SCAQMD’ draft Tier 3 screening level thresholds.
The objective of the Executive Order is to contribute to capping worldwide CO2 concentrations at 450 ppm,
stabilizing global climate change. The City of Tustin utilizes Option 1, and therefore the threshold is 3,000
MTCO2e per year.
The project’s construction GHG emissions are shown in Table 9 and the overall construction and operational
emissions are shown in Table 10 These emissions were calculated using the CalEEMod Model. The construction
emissions are amortized over 30 years. As shown in Table 10, the net GHG emissions are 613 MTCO2e per
year, below the existing operation and the 3,000 MTCO2e per year. Therefore, the project would have a
less than significant GHG impact.
Table 9. Project Construction GHG Emissions
Activity
Annual GHG Emissions
(MTCO2e)
2023 369
2024 2
Total Emissions 371
Total Emissions Amortized
Over 30 Years 12
Table 10. Total GHG Emissions
Activity
Annual GHG Emissions
(MTCO2e)
Project Operational Emissions
Mobile 412
Area 10
Energy 172
Water 4
Waste 3
Total Project Gross Operation
Emissions
601
Project Construction Emissions 12
Total Emissions 613
Significance Threshold 3,000
Threshold Exceeded? No
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Figure 1: Project Site Plan
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CalEEMod Output Sheets
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Fuel Calculations