HomeMy WebLinkAbout4.C._Air_QualityIV. ENVIRONMENTAL IMPACT ANALYSIS
C. AIR QUALITY
INTRODUCTION
This section of the Draft EIR describes existing air quality in the project area evaluates the potential for
air quality impacts associated with implementation of the proposed project. This includes the potential for
the proposed project to conflict with or obstruct implementation of the applicable air quality plan, to
violate an air quality standard or contribute substantially to an existing or projected air quality violation,
to result in a cumulatively considerable net increase of any criteria pollutant for which the project region
is non-attainment, to expose sensitive receptors to substantial pollutant concentrations, or to create
objectionable odors affecting a substantial number of people. Where appropriate, this section provides
project level analysis for the Phase 1 Precise Plan, and program level analysis for the remainder of
development proposed by the Gateway Business Park Master Plan. A regulatory framework is also
provided in this section describing applicable agencies and regulations related to air quality.
The section has been prepared using methodologies and assumptions recommended in the air quality
CEQA
impact assessment guidelines of the Bay Area Air Quality Management District (BAAQMD)
Guidelines: Assessing the Air Quality Impacts of Projects and Plans
, most recently published in
December 1999. The air quality assessment considers “criteria air pollutants” (pollutants for which state
and federal ambient standards exist), “toxic air contaminants” (pollutants that pose human health risks)
and greenhouse gases.
Preparation of this section used data from various sources. These sources include the City of South San
Francisco General Plan prepared by Dyett & Bhatia and adopted in October 1999; the East of 101 Area
Plan prepared by Brady and Associates and adopted in July 1994; and the Gateway Business Park Traffic
Impact Study prepared in Crane Transportation Group 2009.
No comment letters related to air quality were received in response to the June 16, 2008 Notice of
Preparation (NOP) or the October 22, 2008 Revised NOP circulated for the project. The NOP and
comment letters are included in Appendix A of this Draft EIR.
ENVIRONMENTAL SETTING
Background
Air pollutant emissions within the Bay Area are generated by stationary and mobile sources. Stationary
sources can be divided into two major subcategories: point and area sources. Point sources occur at an
identified location and are usually associated with manufacturing and industry. Examples are boilers or
combustion equipment that produces electricity or generates heat. Area sources are widely distributed and
produce many small emissions. Examples of area sources include residential and commercial water
heaters, painting operations, lawn mowers, agricultural fields, landfills, and consumer products such as
barbeque lighter fluid and hair spray. Mobile sources refer to emissions from motor vehicles, including
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tailpipe and evaporative emissions, and are classified as either on-road or off-road. On-road sources may
be legally operated on roadways and highways. Off-road sources include aircraft, ships, trains, racecars,
and self-propelled construction equipment. Mobile sources account for the majority of the air pollutant
emissions within the San Francisco Air Basin (Basin). Air pollutants can also be generated by the natural
environment such as when fine dust particles are pulled off the ground surface and suspended in the air
during high winds.
Both the federal and state governments have established ambient air quality standards for outdoor
concentrations of various pollutants in order to protect public health. The national and state ambient air
quality standards have been set at levels where concentrations could be generally harmful to human health
and welfare, and to protect the most sensitive persons from illness or discomfort with a margin of safety.
The air pollutants for which national and state standards have been promulgated and which are most
relevant to air quality planning and regulation in the Bay Area include ozone, carbon monoxide (CO),
respirable particulate matter (PM), fine particulate matter (PM), sulfur dioxide (SO), and lead. In
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addition, toxic air contaminants and greenhouse gases (GHGs) are of concern. Each of these is briefly
described below.
Ozone (O) is a highly reactive and unstable gas that is formed when reactive organic gases
3
(ROGs) and nitrogen oxides (NO), both byproducts of internal combustion engine exhaust,
X
undergo slow photochemical reactions in the presence of sunlight. Ozone concentrations are
generally highest during the summer months when direct sunlight, light wind, and warm
temperature conditions are favorable to the formation of this pollutant.
Carbon Monoxide (CO) is a colorless, odorless gas produced by the incomplete combustion of
carbon-containing fuels, such as gasoline or wood. CO concentrations tend to be the highest
during the winter morning, when little to no wind and surface-based inversions trap the pollutant
at ground levels. Because CO is emitted directly from internal combustion engines, unlike ozone,
motor vehicles operating at slow speeds are the primary source of CO in the Basin. The highest
ambient CO concentrations are generally found near congested transportation corridors and
intersections.
Respirable Particulate Matter (PM) and Fine Particulate Matter (PM) consist of extremely
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small, suspended particles or droplets 10 microns and 2.5 microns or smaller in diameter,
respectively. Some sources of particulate matter, like pollen and windstorms, are naturally
occurring. However, in populated areas, most particulate matter is caused by road dust, diesel
soot, combustion products, abrasion of tires and brakes, and construction activities.
Nitrogen dioxide (NO) is a nitrogen oxide compound that is produced by the combustion of
2
fossil fuels, such as in internal combustion engines (both gasoline and diesel powered), as well as
point sources, especially power plants. Of the seven types of nitrogen oxide compounds, NO is
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the most abundant in the atmosphere. As ambient concentrations of NO are related to traffic
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density, commuters in heavy traffic may be exposed to higher concentrations of NO than those
2
indicated by regional monitors.
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Sulfur dioxide (SO) is a colorless, extremely irritating gas or liquid. It enters the atmosphere as a
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pollutant mainly as a result of burning high sulfur-content fuel oils and coal and from chemical
processes occurring at chemical plants and refineries. When SO oxidizes in the atmosphere, it
2
forms sulfates (SO). Collectively, these pollutants are referred to as sulfur oxides (SO).
4X
Lead (Pb) occurs in the atmosphere as particulate matter. The combustion of leaded gasoline is
the primary source of airborne Pb in the Basin. The use of leaded gasoline is no longer permitted
for on-road motor vehicles, so the majority of such combustion emissions are associated with off-
road vehicles such as race cars. However, because it was emitted in large amounts from vehicles
when leaded gasoline was used for on-road motor vehicles, Pb is present in many soils and can
get resuspended in the air. Other sources of Pb include the manufacturing and recycling of
batteries, paint, ink, ceramics, ammunition, and the use of secondary Pb smelters.
Toxic Air Contaminants (TAC) refer to a diverse group of air pollutants that are capable of
causing chronic (i.e., of long duration) and acute (i.e., severe but of short duration) adverse
effects on human health. They include both organic and inorganic chemical substances that may
be emitted from a variety of common sources including gasoline stations, motor vehicles, dry
cleaners, industrial operations, painting operations, and research and teaching facilities. TACs are
different than “criteria” pollutants in that ambient air quality standards have not been established
for them, largely because there are hundreds of air toxics and their effects on health tend to be felt
on a local scale rather than on a regional basis.
Greenhouse Gases (GHGs) refer to a group of compounds that are believed to affect global
climate conditions. GHGs include carbon dioxide (CO), methane (CH), O, water vapor, nitrous
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oxide (NO), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride
2
(SF). Carbon dioxide is the most abundant GHG. Other GHGs are less abundant, but have higher
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global warming potential than CO. Simply put, the greenhouse effect compares the Earth and the
2
atmosphere surrounding it to a greenhouse with glass panes. The glass panes in a greenhouse let
heat from sunlight in and reduce the amount of heat that escapes.
Forest fires, decomposition, industrial processes, landfills, and consumption of fossil fuels for
power generation, transportation, heating, and cooking are the primary sources of GHG
emissions. There appears to be a close relationship between the concentration of greenhouse
gases in the atmosphere and global temperatures. A number of scientists believe that the amount
of greenhouse gas emissions in the atmosphere has increased at a rapid rate due to the use of
machines powered by fossil fuels and that these gases are increasing global temperatures.1 If not
abated, the warming increase could reduce water supply, increase erosion of coastlines, increase
2
seawater intrusion, increase power demand, and worsen air quality.
1
Intergovernmental Panel on Climate Change. Climate Change 2007 – The Physical Science Basis, Summary
for Policymakers, 2007.
2
California Environmental Protection Agency, Climate Action Team, Climate Action Team Report to Governor
Schwarzenegger and the Legislature, March 2006.
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State standards have been promulgated for other air pollutants, including SO, hydrogen sulfide, and
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visibility reducing particles. The state also recognizes vinyl chloride as a TAC with an undetermined
threshold level of exposure for adverse health effects. Vinyl chloride and hydrogen sulfide emissions are
generally generated from mining, milling, refining, smelting, landfills, sewer plants, cement
manufacturing, or the manufacturing or decomposition of organic matter. The state standards for sulfate
and visibility reducing particles are not exceeded anywhere in the Basin.
Pb is typically only emitted during demolition of structures expected to include Pb-based paint and
materials. However, the project applicant would be required to follow federal and state regulations that
govern the renovation and demolition of structures where materials containing Pb are present. Further
discussion on the presence and removal of Pb-based materials is included in Hazards and Hazardous
Materials.
Health Effects of Air Pollutants
Ozone
Individuals exercising outdoors, children and people with preexisting lung disease such as asthma and
chronic pulmonary lung disease are considered to be the most susceptible sub-groups for ozone effects.
Short-term exposures (lasting for a few hours) to ozone at levels typically observed in areas of high ozone
can result in breathing pattern changes, reduction of breathing capacity, increased susceptibility to
infections, inflammation of the lung tissue, and some immunological changes. Elevated ozone levels are
associated with increased school absences. In recent years, a correlation between elevated ambient ozone
levels and increases in daily hospital admission rates, as well as mortality, has also been reported.
An increased risk for asthma has been found in children who participate in multiple sports and live in high
ozone communities.
Ozone exposure under exercising conditions is known to increase the severity of the above mentioned
observed responses. Animal studies suggest that exposure to a combination of pollutants that include
ozone may be more toxic than exposure to ozone alone. Although lung volume and resistance changes
observed after a single exposure diminish with repeated exposures, biochemical and cellular changes
appear to persist, which can lead to subsequent lung structural changes.
Carbon Monoxide
Individuals with a deficient blood supply to the heart are the most susceptible to the adverse effects of CO
exposure. The effects observed include earlier onset of chest pain with exercise, and electrocardiograph
changes indicative of worsening oxygen supply to the heart.
Inhaled CO has no direct toxic effect on the lungs, but exerts its effect on tissues by interfering with
oxygen transport and competing with oxygen to combine with hemoglobin present in the blood to form
carboxyhemoglobin (COHb). Hence, conditions with an increased demand for oxygen supply can be
adversely affected by exposure to CO. Individuals most at risk include patients with diseases involving
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heart and blood vessels, fetuses, and patients with chronic hypoxemia (oxygen deficiency) as seen in high
altitudes.
Reduction in birth weight and impaired neurobehavioral development have been observed in animals
chronically exposed to CO, resulting in COHb levels similar to those observed in smokers. Recent studies
have found increased risks for adverse birth outcomes with exposure to elevated CO levels. These include
pre-term births and heart abnormalities.
Particulate Matter
A consistent correlation between elevated ambient fine particulate matter (PM and PM) levels and an
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increase in mortality rates, respiratory infections, number and severity of asthma attacks and the number
of hospital admissions has been observed in different parts of the United States and various areas around
the world. In recent years, some studies have reported an association between long-term exposure to air
pollution dominated by fine particles and increased mortality, reduction in life-span, and an increased
mortality from lung cancer.
Daily fluctuations in PM concentration levels have also been related to hospital admissions for acute
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respiratory conditions in children, to school and kindergarten absences, to a decrease in respiratory lung
volumes in normal children and to increased medication use in children and adults with asthma. Recent
studies show lung function growth in children is reduced with long-term exposure to particulate matter.
The elderly, people with pre-existing respiratory or cardiovascular disease and children appear to be more
susceptible to the effects of high levels of PM and PM.
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Nitrogen Dioxide
Population-based studies suggest that an increase in acute respiratory illness, including infections and
respiratory symptoms in children (not infants), is associated with long-term exposures to NOat levels
2
found in homes with gas stoves, which are higher than ambient levels found in Southern California.
Increase in resistance to air flow and airway contraction is observed after short-term exposure to NOin
2
healthy subjects. Larger decreases in lung functions are observed in individuals with asthma or chronic
obstructive pulmonary disease (e.g., chronic bronchitis, emphysema) than in healthy individuals,
indicating a greater susceptibility of these sub-groups.
In animals, exposure to levels of NO considerably higher than ambient concentrations results in
2
increased susceptibility to infections, possibly due to the observed changes in cells involved in
maintaining immune functions. The severity of lung tissue damage associated with high levels of ozone
exposure increases when animals are exposed to a combination of ozone and NO.
2
Sulfur Dioxide
A few minutes exposure to low levels of SO can result in airway constriction in some asthmatics, all of
2
whom are sensitive to its effects. In asthmatics, increase in resistance to air flow, as well as reduction in
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breathing capacity leading to severe breathing difficulties, are observed after acute exposure to SO. In
2
contrast, healthy individuals do not exhibit similar acute responses even after exposure to higher
concentrations of SO.
2
Animal studies suggest that despite SO being a respiratory irritant, it does not cause substantial lung
2
injury at ambient concentrations. However, very high levels of exposure can cause lung edema (fluid
accumulation), lung tissue damage, and sloughing off of cells lining the respiratory tract.
Some population-based studies indicate that the mortality and morbidity effects associated with fine
particles show a similar association with ambient SO levels. In these studies, efforts to separate the
2
effects of SO from those of fine particles have not been successful. It is not clear whether the two
2
pollutants act synergistically or one pollutant alone is the predominant factor.
Lead
Fetuses, infants, and children are more sensitive than others to the adverse effects of Pb exposure.
Exposure to low levels of Pb can adversely affect the development and function of the central nervous
system, leading to learning disorders, distractibility, inability to follow simple commands, and lower
intelligence quotient. In adults, increased Pb levels are associated with increased blood pressure.
Pb poisoning can cause anemia, lethargy, seizures, and death, although it appears that there are no direct
effects of Pb on the respiratory system. Pb can be stored in the bone from early age environmental
exposure, and elevated blood Pb levels can occur due to breakdown of bone tissue during pregnancy,
hyperthyroidism (increased secretion of hormones from the thyroid gland) and osteoporosis (breakdown
of bony tissue). Fetuses and breast-fed babies can be exposed to higher levels of Pb because of previous
environmental Pb exposure of their mothers.
Toxic Air Contaminant Emissions
TACs are airborne substances that are capable of causing chronic (i.e., of long duration) and acute (i.e.,
severe but of short duration) adverse effects on human health. They include both organic and inorganic
chemical substances that may be emitted from a variety of common sources including gasoline stations,
motor vehicles, dry cleaners, industrial operations, painting operations, and research and teaching
facilities. TACs are different from the “criteria” pollutants previously discussed in that ambient air quality
standards have not been established for them.
Existing Regional Air Quality
Measurements of ambient concentrations of the criteria pollutants are used by the United States
Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) to assess and
classify the air quality of each air basin, county, or, in some cases, a specific developed area. The
classification is determined by comparing actual monitoring data with federal and state standards. If a
pollutant concentration in an area is lower than the standard, the area is classified as being in
“attainment.” If the pollutant exceeds the standard, the area is classified as a “nonattainment” area. If
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there are not enough data available to determine whether the standard is exceeded in an area, the area is
designated “unclassified.”
Air quality in the basin is monitored by the Bay Area Air Quality Management District (BAAQMD),
which operates a regional network of air pollution monitoring stations to determine if the federal and state
standards for criteria air pollutants and emission limits of toxic air contaminants are being achieved. The
Bay Area Basin is considered “nonattainment” for ozone federal standards, and is considered
“nonattainment” for state standards for ozone and respirable particulate matter (PM). It is in
10
“attainment” for the federal standard for PM, and in “attainment” for both the federal and state ambient
10
air quality standards for PM, SO, Pb, and NO, which is a pure form of NO.
2.522X
The average daily emissions inventory for the entire Bay Area and San Mateo County is summarized in
Table IV.C-1. In the Bay Area, motor vehicles generate the majority of ROG, NO, and CO emissions;
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stationary sources generate the most SO; and area-wide sources generate the most airborne particulate.
X
Existing Local Air Quality
The BAAQMD monitors ambient air pollutant concentrations through a series of monitoring stations
located throughout the Bay Area. While no monitoring station is located in South San Francisco,
BAAQMD samples local air quality from the nearby Arkansas Street station in San Francisco,
approximately twelve miles from the project area. Table IV.C-2 identifies the national and state ambient
air quality standards for relevant air pollutants along with the ambient pollutant concentrations that have
been measured at the Arkansas Street-San Francisco monitoring station through the period of 2006 to
2008. Monitoring was not conducted at this station for the CO maximum 1-hour concentration, or for
SO. Therefore, no site-specific data is available for those emission levels.
2
Table IV.C-1
2008 Estimated Average Daily Regional Emissions
Emissions in Tons Per Day
Emissions Source
ROGCONOSOPMPM
xx102.5
Bay Area
Stationary (Point) Sources 106.6 44.3 50.6 45.9 16.3 12.1
Area-Wide Sources 87.9 161.9 16.9 0.6 175.5 52.9
Mobile Sources 183.1 1,541.5 380.5 14.9 20.3 16.3
Natural (non-anthropogenic) Sources 106.5 49.4 1.6 0.5 5.1 4.3
Total Emissions 484.1 1,797.0 449.7 62.0 217.2 85.6
San Mateo County
Stationary (Point) Sources 7.4 2.1 1.7 0.1 1.0 0.8
Area-Wide Sources 8.7 11.0 1.9 0.1 16.5 4.2
Mobile Sources 19.2 161.1 54.0 7.9 3.0 2.5
Natural (non-anthropogenic) Sources 6.9 -- -- -- -- --
Total Emissions 42.2 174.2 57.6 8.0 20.4 7.4
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Table IV.C-1
2008 Estimated Average Daily Regional Emissions
Emissions in Tons Per Day
Emissions Source
ROGCONOSOPMPM
xx102.5
Source: California Air Resources Board, website: http://www.arb.ca.gov/app/emsinv/emssumcat.php, August 2009.
"-" represents data not available.
Monitoring station measurements indicate that air quality in the vicinity of South San Francisco performs
well against state standards for criteria air pollutants. Ambient PM concentrations have violated the state
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standard on occasion at the Arkansas Street station. PM in the atmosphere is the result of many dust-
10
and fume-producing industrial and agricultural operations, construction, fugitive sources (such as
roadway dust), and atmospheric photochemical reactions involving ROGs and NO. For carbon
X
monoxide, a product of incomplete combustion, the air in South San Francisco meets state and federal
standards; however, concentrations in the vicinity of congested intersections and highway segments
would potentially be higher than the monitoring data indicates.
BAAQMD maintains an inventory of substantial stationary sources of TAC emissions in the Bay Area.
According to the South San Francisco General Plan, as of 2002, there are seventeen such sources that
exceeded trigger threshold listed within South San Francisco, fourteen of which are dry cleaners. The
remaining sources include the South San Francisco San Bruno Wastewater Treatment Plant, the Shell Oil
Company Distribution Plant, and the Superior Aluminum Body Corporation.
Existing Project Area Emissions
Existing Localized CO Concentrations
Traffic-congested roadways and intersections have the potential to generate localized high levels of CO.
Localized areas where ambient concentrations exceed national and/or state standards for CO are termed
CO “hotspots.” The BAAQMD considers CO as a localized problem requiring additional analysis when a
project is likely to subject sensitive receptors to CO hotspots. Land uses such as primary and secondary
schools, hospitals, and convalescent homes are considered to be sensitive receptors to poor air quality
because the very young, the old, and the infirm are more susceptible to respiratory infections and other air
quality-related health problems than the general public.
A child care facility is located within the project site. However, the on-site child care facility will be
closed at the completion of Phase I (2015 buildout). In addition, a child care facility will be located at 559
Gateway Boulevard located less than 100 feet from the project site. Both child care facilities would be
considered sensitive receptors for localized CO concentrations. Residential uses are considered sensitive
because people in residential areas are often at home for extended periods of time, so they could be
exposed to pollutants for extended periods. Recreational areas are considered moderately sensitive to poor
air quality because vigorous exercise associated with recreation places a high demand on the human
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respiratory function. No sensitive receptors are within a ¼-mile of the project site, other than the above
mentioned child care facilities.
Localized CO concentrations are calculated based on a simplified CALINE4 screening procedure
developed by BAAQMD. The simplified model is intended as a screening analysis, which identifies a
potential CO hotspot. This methodology assumes worst-case conditions and provides a screening of
maximum, worst-case CO concentrations. Only intersections that were projected to operate at level of
service (LOS) E or F were analyzed. As all other intersections would operate at a better LOS, localized
CO concentrations at those intersections would be expected to be less. None of the existing intersections
operate at a LOS E or F therefore none of these intersections were evaluated.
Table IV.C-2
Ambient Pollutant Concentrations Registered at the San Francisco-Arkansas Street Station
Year
Emissions Source
2006 2007 2008
Ozone
Maximum 1-hour concentration measured 0.053 ppm 0.060 ppm 0.082 ppm
Days exceeding State 0.09 ppm 1-hour standard 0 0 0
Maximum 8-hour concentration 0.046 ppm 0.053 ppm 0.066 ppm
Days exceeding national 0.075 ppm 8-hour standard 0 0 0
Days exceeding State 0.07 ppm 8-hour standard 0 0 0
Respirable Particulate Matter (PM)
10
333
Maximum 24-hour concentration measured 61.4 µg/m 69.8 µg/m 41.3 µg/m
3
Days exceeding national 150 µg/m 24-hour standard 0 0 0
3
Days exceeding State 50 µg/m 24-hour standard 17.3 12 0
Fine Particulate Matter (PM)
2.5
333
Maximum 24-hour concentration measured 54.3 µg/m 45.2 µg/m 29.4 µg/m
3
Days exceeding national 65 µg/m 24-hour standard 3.1 5.1 *
Carbon Monoxide (CO)
Maximum 1-hour concentration measured * * *
Days exceeding national 35.0 ppm 1-hour standard * * *
Days exceeding State 20.0 ppm 1-hour standard 0 0 0
Maximum 8-hour concentration measured 2.09 ppm 1.60 ppm 2.29 ppm
Days exceeding national & State 9.0 ppm 8-hour standard 0 0 0
Nitrogen Dioxide (NO)
2
Maximum 1-hour concentration measured 0.107 ppm 0.069 ppm 0.062 ppm
Days exceeding State 0.25 ppm 1-hour standard 0 0 0
AAM 0.016 ppm 0.016 ppm 0.016 ppm
Does measured AAM exceed national 0.0534 ppm AAM standard? No No No
Note: ppm = parts per million by volume
3
µg/m = micrograms per cubic meter
AAM = annual arithmetic mean
* = insufficient data
Source: California Air Resources Board, website: http://www.arb.ca.gov/adam/cgi-bin/db2www/adamtop4b.d2w/start,
September 2009.
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Regulatory Setting
Air quality within the Bay Area is addressed through the efforts of various federal, state, regional, and
local government agencies. These agencies work jointly, as well as individually, to improve air quality
through legislation, regulations, planning, policy-making, education, and a variety of programs. The
agencies responsible for improving the air quality within the Bay Area are discussed below.
Federal
The EPA is responsible for setting and enforcing the federal ambient air quality standards for atmospheric
pollutants. It regulates emission sources that are under the exclusive authority of the federal government,
such as aircraft, ships, and certain locomotives.
As part of its enforcement responsibilities, the EPA requires each state with nonattainment areas to
prepare and submit a State Implementation Plan (SIP) that demonstrates the means to attain the federal
standards. The SIP must integrate federal, state, and local plan components and regulations to identify
specific measures to reduce pollution, using a combination of performance standards and market-based
programs within the timeframe identified in the SIP.
State
CARB
The CARB, a part of the California Environmental Protection Agency, is responsible for the coordination
and administration of both federal and state air pollution control programs within California. In this
capacity, the CARB conducts research, sets California Ambient Air Quality Standards, compiles emission
inventories, develops suggested control measures, provides oversight of local programs, and prepares the
SIP. The CARB establishes emissions standards for motor vehicles sold in California, consumer products
(e.g., hair spray, aerosol paints, and barbecue lighter fluid) and various types of commercial equipment. It
also sets fuel specifications to further reduce vehicular emissions. To address diesel particulate and other
TAC emissions, the CARB has recently finalized an Air Quality and Land Use Handbook: A Community
Health Perspective (April 2005) as an “informational guide” to prioritize the important sources of TACs
and reduce exposures to proximate populations.
California Global Warming Solutions Act
Currently the Federal Government does not regulate emissions of greenhouse gases; however, the State of
California has been proactive in studying the impacts of climate change. In 2005, in recognition of
California’s vulnerability to the effects of climate change, Governor Schwarzenegger issued Executive
Order S-3-05, which sets forth a series of target dates by which statewide emission of greenhouse gas
would be progressively reduced, as follows:
By 2010, reduce greenhouse gas emissions to 2000 levels;
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By 2020, reduce greenhouse gas emissions to 1990 levels; and
By 2050, reduce greenhouse gas emissions to 80 percent below 1990 levels.
In 2006, the State Legislature passed the California Global Warming Solutions Act of 2006 (Assembly
Bill No. 32; California Health and Safety Code Division 25.5, Sections 38500, et seq., or AB 32), which
requires the California Air Resources Board (CARB) to design and implement emission limits,
regulations, and other measures, such that feasible and cost-effective statewide greenhouse gas emissions
are reduced to 1990 levels by 2020 (representing an approximate 25 percent reduction in emissions). In
June 2007, CARB directed staff to pursue 37 early actions for reducing greenhouse gas emissions under
the California Global Warming Solutions Act of 2006 (AB 32). The broad spectrum of strategies to be
developed – including a Low Carbon Fuel Standard, regulations for refrigerants with high global warming
potentials, guidance and protocols for local governments to facilitate greenhouse gas reductions, and
green ports – reflects that the serious threat of climate change requires action as soon as possible
(California Air Resources Board, September 2007a. Draft List of Early Action Measures to Reduce
Greenhouse).
In addition to approving the 37 greenhouse gas reduction strategies, CARB directed staff to further
evaluate early action recommendations made at the June 2007 meeting, and to report back to CARB
within six months. Since the June 2007 CARB hearing, CARB staff has evaluated all 48
recommendations submitted by several stakeholder and several internally-generated staff ideas and
published the Expanded List of Early Action Measures To Reduce Greenhouse Gas Emissions In
California Recommended For Board Consideration in October 2007 (California Air Resources Board,
September 2007a.) Draft List of Early Action Measures to Reduce Greenhouse Gas Emissions in
California Recommended for Board Consideration in October 2007b). Based on its additional analysis,
CARB staff is recommending the expansion of the early action list to a total of 44 measures. Nine of the
strategies meet the AB 32 definition of discrete early action measures. Discrete early action measures are
measures that will be in place and enforceable by January 1, 2010. The discrete early action items
include: (1) a Low Carbon Fuel standards for ethanol, biodiesel, hydrogen, electricity, compressed natural
gas, liquefied petroleum gas and biogas; (2) restrictions on High Global Warming Potential Refrigerants;
(3) Landfill Methane Capture, (4) Smartway Truck Efficiency; (5) Port Electrification; (6) Reduction of
perfluorocarbons from the semiconductor industry; (7) Reduction of propellants in consumer products; (8)
Tire inflation; and (9) Sulfur Hexafluoride (SF) reductions from non-electricity sector. The entire list of
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early action strategies is shown in Table IV.C-3.
In total, the 44 recommended early actions have the potential to reduce greenhouse gas emissions by at
least 42 million metric tons per year of carbon dioxide equivalent (COe) emissions by 2020, representing
2
about 25 percent of the estimated reductions needed by 2020 (California Air Resources Board Res.
No.07-55 (Dec. 6, 2007), available at http://www.arb.ca.gov/cc/inventory/1990level/arb_res07-
55_1990_ghg_level.pdf). The 44 measures are in the sectors of fuels, transportation, forestry, agriculture,
education, energy efficiency, commercial, solid waste, cement, oil and gas, electricity, and fire
suppression. The 2020 target reductions are currently estimated to be 174 million metric tons per year of
CO2e emissions. (California Air Resources Board, October 2007, Expanded List of Early Action
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Measures To Reduce Greenhouse Gas Emissions In California Recommended For Board Consideration.)
CARB has approved a 1990 emissions inventory and 2020 limit of 427 million metric tons per year of
CO2e emissions (California Air Resources Board Res. No.07-55 (Dec. 6, 2007), available at
http://www.arb.ca.gov/cc/inventory/1990level/arb_res07-55_1990_ghg_level.pdf).
In addition to identifying early actions to reduce greenhouse gases, CARB has also developed mandatory
greenhouse gas reporting regulations pursuant to requirements of AB 32. The regulations will require
emissions reporting for classes of facilities that collectively account for 94 percent of the stationary
source emissions in California, including cement plants, oil refineries, electric generating
facilities/providers, co-generation facilities, hydrogen plants and other stationary combustion sources that
emit more than 25,000 metric tons per year of COe emissions. (California Air Resources Board,
2
December 6, 2007c, Proposed Regulation for the Mandatory Reporting of California Greenhouse Gas
Emissions Pursuant to the California Global Warming Solutions Act of 2006 (AB 32), available at
http://www.arb.ca.gov/cc/ccei/reporting/GHGReportBoardSlides12_06_07.pdf (proposed regulations
were approved by CARB on December 6, 2007).) Presumably, while individual facilities within these
classes may not create significant greenhouse gas impacts, emissions from these types of facilities are
likely to be cumulatively considerable. Likewise, facilities or projects not included among the classes
required to report under CARB’s mandatory reporting regulations are not expected to have cumulatively
considerable greenhouse gas impacts.
In August 2007, California Senate Bill 97 (SB 97) was passed requiring the Office of Planning and
Research (OPR) to develop CEQA guidelines for the effects and mitigation of greenhouse gas emissions.
SB 97 requires OPR, by July 1, 2009, to prepare, develop, and transmit to the State Resources Agency
guidelines for the feasible mitigation of GHG emissions, as required by CEQA, including, but not limited
to, effects associated with transportation or energy consumption. Following receipt of these guidelines,
the Resources Agency must certify and adopt the guidelines prepared by OPR by January 1, 2010.
OPR submitted its proposed guidelines to the Secretary for Natural Resources on April 13, 2009. The
Natural Resources Agency will begin a formal rulemaking process to certify and adopt the amendments
as part of the state regulations implementing CEQA by January 2010. Until these Guidelines are
approved, OPR released a Technical Advisory in June 2008 to provide interim advice to lead agencies
regarding the analysis of greenhouse gas emissions in environmental documents. The Technical Advisory
encourages lead agencies to follow three basic steps: (1) identify and quantify the greenhouse gas
emissions that could result from the proposed project; (2) analyze the effects of those emissions and
determine whether the effect is significant, and (3) if the impact is significant, identify feasible mitigation
measures or alternatives that will reduce the impact below a level of significance.
In its Draft CEQA Guideline Amendments, OPR does not identify a threshold of significance for
greenhouse gas emissions, nor does it prescribe assessment methodologies or specific mitigation
measures. Instead, the draft amendments encourage lead agencies to consider many factors in performing
a CEQA analysis, but rely on the lead agencies in making their own determinations based upon
substantial evidence. The draft amendments also encourage public agencies to make use of programmatic
mitigation plans and programs from which to tier when they perform individual project analyses.
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-12
City of South San Francisco October 2009
In September of 2008, the California legislature adopted SB 375, legislation which: (1) relaxes CEQA
requirements for some housing projects that meet goals for reducing greenhouse-gas emissions and (2)
requires the regional governing bodies in each of the state’s major metropolitan areas to adopt, as part of
their regional transportation plan, “sustainable community strategies” that will meet the region’s target for
reducing GHG emissions. SB 375 creates incentives for implementing the sustainable community
strategies by allocating federal transportation funds only to projects that are consistent with the emissions
reductions.
Local
Bay Area Air Quality Management District
The BAAQMD is the primary agency responsible for comprehensive air pollution control in the entire
San Francisco Bay Area Air Basin. To that end, the BAAQMD, a regional agency, works directly with
the Association of Bay Area Governments, the Metropolitan Transportation Commission, and local
governments and cooperates actively with all federal and state government agencies. The BAAQMD
develops rules and regulations, establishes permitting requirements for stationary sources, inspects
emissions sources, and enforces such measures through educational programs or fines, when necessary.
Table IV.C-3
Recommended AB32 Greenhouse Gas Measures to be Initiated by CARB
(between 2007 and 2012)
ID # SectorStrategy Name ID # SectorStrategy Name
1 Fuels Above Ground Storage 23 Commercial SF6 reductions from the
Tanksnon-electric sector
2 Transportation Diesel – Offroad 24 Transportation Tire inflation program
equipment (non-
agricultural)
3 Forestry 25 Transportation Cool automobile paints
Forestry protocol
endorsement
4 Transportation Diesel – Port trucks 26 Cement Cement (A): Blended
cements
5 Transportation Diesel – Vessel main 27 Cement Cement (B): Energy
engine fuel efficiency of California
specificationscement facilities
6 Transportation Diesel – Commercial 28 Transportation Ban on HFC release from
harbor craft Motor Vehicle AC service
/ dismantling
7 Transportation Green ports 29 Transportation Diesel – offroad
equipment (agricultural)
8 Agriculture 30 Transportation
Manure management Add AC leak tightness test
(methane digester and repair to Smog Check
protocol)
9 Education Local gov. Greenhouse 31 Agriculture Research on GHG
Gas (GHG) reduction reductions from nitrogen
guidance / protocols land applications
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-13
City of South San Francisco October 2009
Table IV.C-3
Recommended AB32 Greenhouse Gas Measures to be Initiated by CARB
(between 2007 and 2012)
ID # SectorStrategy Name ID # SectorStrategy Name
10 Education Business GHG 32 Commercial Specifications for
reduction guidance / commercial refrigeration
protocols
11EnergyCool communities 33 Oil and Gas Reduction in venting /
Efficiencyprogram leaks from oil and gas
systems
12 Commercial 34 Transportation
Reduce high Global Requirement of low-GWP
Warming Potential GHGs for new Motor
(GWP) GHGs in Vehicle ACs
products
13 Commercial Reduction of PFCs 35 Transportation Hybridization of medium
from semiconductor and heavy-duty diesel
industry vehicles
14 Transportation SmartWay truck 36 Electricity Reduction of SF6 in
efficiencyelectricity generation
15 Transportation Low Carbon Fuel 37 Commercial High GWP refrigerant
Standard (LCFS) tracking, reporting and
recovery program
16 Transportation 38 Commercial
Reduction of HFC-Foam recovery /
134a from DIY Motor destruction program
Vehicle AC servicing
17 Waste Improved landfill gas 39FireAlternative suppressants in
captureSuppression fire protection systems
18 Fuels Gasoline dispenser 40 Transportation Strengthen light-duty
hose replacement vehicle standards
19 Fuels Portable outboard 41 Transportation Truck stop electrification
marine tanks with incentives for
truckers
20 Transportation Standards for off-cycle 42 Transportation Diesel – Vessel speed
driving conditions reductions
21 Transportation 43 Transportation
Diesel – Privately Transportation
owned on-road trucks refrigeration – electric
standby
22 Transportation Anti-idling 44 Agriculture Electrification of
enforcement stationary agricultural
engines
Source: CARB, 2007.
In 1991, the Bay Area 1991 Clean Air Plan (CAP) was developed to address the state requirements of the
California Clean Air Act. The Plan has been updated twice, in 1994 and 1997, with the continued goal of
improving air quality through tighter industry controls, cleaner fuels, and combustion in cars and trucks,
and increased commute alternatives.
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-14
City of South San Francisco October 2009
The BAAQMD is directly responsible for reducing emissions from stationary (area and point), mobile,
and indirect sources. It has responded to this requirement by preparing a sequence of Ozone Attainment
Plans and CAPs that comply with the federal Clean Air Act and the California Clean Air Act,
accommodate growth, reduce the pollutant levels in the Bay Area, meet federal and state ambient air
quality standards, and minimize the fiscal impact that pollution control measures have on the local
economy. The Ozone Attainment Plans are prepared for the federal ozone standard, and the CAPs are
prepared for the state ozone standards. The most recent Ozone Attainment Plan was adopted by the
BAAQMD Board of Directors on October 2001 and demonstrates attainment of the federal ozone
standard in the Bay Area by 2006. The current regional CAP was adopted by the Board of Directors on
December 20, 2000. It identifies the control measures that would be implemented through 2006 to reduce
major sources of pollutants. These planning efforts have substantially decreased the population’s
exposure to unhealthful levels of pollutants, even while substantial population growth has occurred within
the Bay Area. The CAP predicts that regional ozone concentrations will decrease by 1.2 percent per year
or 9.0 percent over the 12 years after it was adopted.
Although no plans are currently required to demonstrate attainment of federal or state particulate matter
standards, the CAP discusses this pollutant since the health effects of particulates can be serious, and
many of the measures identified in the Plan to reduce ROGs and NOx as ozone precursor emissions will
also reduce ambient concentrations of particulate matter.
South San Francisco General Plan
Local jurisdictions, such as the City of South San Francisco, have the authority and responsibility to
reduce air pollution through its police power and decision-making authority. Specifically, the City is
responsible for the assessment and mitigation of air emissions resulting from its land use decisions. The
City of South San Francisco is also responsible for the implementation of transportation control measures
as outlined in the CAP. Examples of such measures include bus turnouts, energy efficient streetlights, and
synchronized traffic signals.
City of South San Francisco environmental plans and policies recognize community goals for air quality.
Chapter 7.3 of the South San Francisco General Plan identifies goals and policies that help the City
contribute to regional air quality improvement efforts, and are consistent with the CAP. These are
outlined as follows:
Continue to work toward improving air quality and meeting all federal and state ambient air
quality standards by reducing the generation of air pollutants from stationary and mobile sources,
where feasible.
Encourage land use and transportation strategies that promote use of alternatives to the
automobile for transportation, including bicycling, bus transit, and carpooling.
Minimize conflicts between sensitive receptors and emissions generators by distancing them from
one another.
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-15
City of South San Francisco October 2009
Cooperate with the BAAQMD to achieve emissions reductions for nonattainment pollutants and
their precursors, including CO, ozone, and PM, by implementation of air pollution control
10
measures as required by federal and state statutes.
Use the City’s development review process and the CEQA regulations to evaluate and mitigate
the local and cumulative effects of new development on air quality.
Adopt the standard construction dust abatement measures included in BAAQMD’s CEQA
Guidelines.
Require new residential development and remodeled existing homes to install clean-burning
fireplaces and wood stoves.
In cooperation with local conservation groups, institute an active urban forest management
program that consists of planting new trees and maintaining existing ones.
In accordance with CEQA requirements and the CEQA review process, the City assesses the air quality
impacts of new development projects, requires mitigation of potentially adverse air quality impacts by
conditioning discretionary permits and monitors and enforces the implementation of such mitigation. The
City does not, however, have the expertise to develop plans, programs, procedures, and methodologies to
ensure that air quality within the City and region will meet federal and state standards. Instead, the City
relies on the expertise of the BAAQMD and utilizes the BAAQMD CEQA Guidelines as the guidance
document for the environmental review of plans and development proposals within its jurisdiction.
The goals and policies outlined in the City of South San Francisco East of 101 Area Plan are generally
consistent with the General Plan, as well as the CAP.
ENVIRONMENTAL IMPACTS
The project would be constructed in five phases from 2011 to 2020. Near-term projects will be completed
in 2015 and will consist of Phase 1 and Phase 2. The Master Plan buildout would consist of all five phases
and be complete by 2020. For the purposes of this EIR, an evaluation was conducted for both the near-
term projects and the Master Plan buildout.
Thresholds of Significance
The following thresholds of significance are based on Appendix G of the 2006 CEQA Guidelines. For
purposes of this Draft EIR, implementation of the proposed project could result in potentially significant
impacts to air quality if the proposed project would result in any of the following:
Conflict with or obstruct implementation of the applicable air quality plan.
Violate any air quality standard or contribute substantially to an existing or projected air quality
violation.
Result in a cumulatively considerable net increase of any criteria pollutant for which the project
region is non-attainment under an applicable federal or state ambient air quality standard
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-16
City of South San Francisco October 2009
(including releasing emissions which exceed quantitative thresholds for ozone precursors such as
ROGs and NO).
X
Expose sensitive receptors to substantial pollutant concentrations.
Create objectionable odors affecting a substantial number of people.
BAAQMD CEQA
The thresholds discussed below are currently recommended by the BAAQMD in the
Guidelines
to determine the significance of air quality impacts.
Construction/Demolition Emissions
According to the BAAQMD CEQA Guidelines, PM is the pollutant of greatest concern with respect to
10
construction activities. Construction emissions of PM can vary greatly depending upon the level of
10
activity, construction equipment, local soils, and weather conditions, among other factors. As a result, the
BAAQMD CEQA Guidelines
specifies, “[t]he District’s approach to CEQA analyses of construction
impacts is to emphasize implementation of effective and comprehensive control measures rather than
detailed quantification of emissions.” Therefore, the determination of significance with respect to
construction emissions should be based on a consideration of the control measures to be implemented. If
BAAQMD CEQA Guidelines
all the applicable control measures for PM indicated in the would be
10
implemented, then air pollutant emissions from construction activities would be considered less than
significant. If a project would not implement all applicable control measures, construction emissions
would be considered a significant impact.
Operational Emissions
The BAAQMD recommends that individual project’s impacts involving direct and/or indirect operational
emissions that exceed the following thresholds be considered significant:
80 pounds per day (ppd) of ROG
80 ppd of NO
x
80 ppd of PM
10
Direct emissions are those that are emitted on a site and include stationary sources and on-site mobile
equipment. Examples of land uses and activities that generate direct emissions are industrial operations
and sources subject to an operating permit by the BAAQMD. Indirect emissions come from mobile
sources that access the project site but generally emit off site. For many types of land-use development
projects, the principal sources of air pollutant emissions are the motor vehicle trips generated by the
project. It should be noted that these significance thresholds do not account for the size of the project and
therefore a larger project is more likely to exceed these thresholds.
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-17
City of South San Francisco October 2009
Local CO Concentrations
Indirect CO emissions are considered significant if they will contribute to a violation of the State
standards for CO (9 ppm averaged over 8 hours and 20 ppm over 1 hour). CO emissions are localized,
and typically analyzed in terms of their impacts to specific roadway segments or intersections.
Construction equipment exhaust contains CO and ozone precursors. However, these exhaust emissions
are included in the emission inventory that is the basis for regional air quality plans, and are not expected
to impede attainment and maintenance of ozone and CO standards in the Bay Area. In addition, as
mentioned before, although State standards for PM exist, area designations have not yet been
2.5
determined. As a result, State plans for addressing PM emissions are not yet in place and air quality
2.5
management districts do not include these emissions in their analyses of construction impacts.
TACs
Projects that have the potential to emit TACs could also result in significant air quality impacts. As stated
BAAQMD CEQA Guidelines,
in the a project that emits TACs and exceeds the following criteria is
considered to have a significant air quality impact:
Probability of contracting cancer for the Maximally Exposed Individual (MEI) exceeds 10 in
3
one million; or
Ground-level concentrations of non-carcinogenic TACs would result in a hazard index
4
greater than one (1) for the MEI.
Odors
Odors would be considered significant if the project would result in a frequent exposure of members of
the public to objectionable odors. According to the BAAQMD, typical uses that may result in significant
odor impacts include wastewater treatment plant, sanitary landfill, transfer station, composting facility,
petroleum refinery, asphalt batch plant, chemical manufacturing, fiberglass manufacturing,
painting/coating operations, rendering plant, and coffee roasters.
Greenhouse Gas Emissions
At this time there are no statewide guidelines for greenhouse gas emission impacts, but this will be
addressed through the provisions of SB 97. As stated above, SB 97 requires the State Office of Planning
and Research ("OPR") to develop CEQA guidelines for the effects and mitigation of greenhouse gas
emissions. Unfortunately, the guidelines will not be available for some time as OPR has until July 1, 2009
to draft the new greenhouse gas guidelines, and the State Resources Agency will thereafter have until
3
An MEI is a hypothetical off-site person, usually at or near the site boundary, who would receive the maximum
exposure from a facility’s operations.
4
A hazard index measures the potential for non-cancer health effects. It is the ratio of the estimated exposure
level to the Reference Exposure Level, which is the level at or below which no adverse health effects are
anticipated.
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-18
City of South San Francisco October 2009
January 1, 2010 to certify and adopt the regulations. In the interim, OPR, in collaboration with the
California Resources Agency, the California Environmental Protection Agency and the California Air
Resources Board, recently provided a new technical advisory containing informal guidance for public
agencies as they address the issue of climate change in their CEQA documents. This technical advisory
provides OPR's perspective on the issue and precedes the development of draft implementing regulations
for CEQA, in accordance with Senate Bill 97 (Chapter 185, Statutes of 2007).
In summary, OPR recommends each public agency that is a lead agency for complying with CEQA to
develop its own approach to performing a climate change analysis for projects that generate GHG
emissions. A consistent approach should be applied for the analysis of all such projects, and the analysis
must be based on best available information. For these projects, compliance with CEQA entails three
basic steps:
identify and quantify the GHG emissions;
assess the significance of the impact on climate change; and
if the impact is found to be significant, identify alternatives and/or mitigation measures that
will reduce the impact below significance.
Although, there is currently no adopted threshold for all County projects, for this analysis, a project would
be considered to have a significant impact if the project would conflict with or obstruct implementation of
greenhouse gas reduction measures under AB 32 and other state regulations.
Three types of analyses are used to determine whether the project could be in conflict with the State
measures for reducing greenhouse gas emissions. The analyses are as follows:
Whether the project conflicts with or obstructs implementation of CARB’s 44 early action
strategies.
Whether the project will be subject to CARB’s mandatory reporting. Qualifying projects
include cement plants, oil refineries, electric generating facilities/providers, co-generation
facilities, hydrogen plants and other stationary combustion sources that emit more than
25,000 metric tons per year of COe emissions. Projects that are not included among these
2
classes of facilities and will not emit 25,000 metric tons per year of COe emissions or more
2
are not required to report emissions to CARB and are not considered to be cumulatively
considerable.
Whether elements of the project, mitigation measures, and County policies and requirements
contribute to the efficiency of the project and reduce greenhouse gas emissions. Most projects
include project components and/or mitigation measures that may not be intended to reduce
greenhouse gas emissions, but will nonetheless have this effect. Similarly, many County
policies and requirements, such as traffic demand management programs, may also operate to
improve the efficiency and reduce emissions associated with the project.
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-19
City of South San Francisco October 2009
Cumulative Impacts
According to the BAAQMD CEQA Guidelines, any project that would individually have a significant air
quality impact would also have a significant cumulative air quality impact. For a project that does not
individually have a significant air quality impact, the BAAQMD requires that a determination of
cumulative impacts be based on an evaluation of the consistency of the proposed project with the local
General Plan and of the General Plan with the regional air quality plan. The appropriate regional air
quality plan for this analysis is the 2000 CAP. If a project is proposed in a city or county with a General
Plan that is consistent with the CAP, and the project is consistent with that General Plan, the project
would not have a significant cumulative impact. If the city or county General Plan is not consistent with
the CAP, or the project is not consistent with the General Plan, quantitative analysis is required to
determine whether the impact is significant.
Project Impacts
Impact IV.C-1: The proposed project would conflict with the applicable air quality plan.
Approval of the proposed project would require a General Plan Amendment. For General Plan
CEQA Guidelines
amendments, the BAAQMD recommend that the impact of the change in land use
designation with respect to vehicle miles traveled (VMT) and the potential for the project to exposure
sensitive receptors to sources of objectionable odors, toxics, or accidental releases of hazardous materials
be evaluated to determine consistency with the current CAP. As described in Section IV.M,
Transportation, the proposed land use associated with the proposed project would generate more vehicle
trips (and more miles traveled) than those that could be generated under the existing General Plan
designation. Section IV.M recommends the implementation of a Transportation Demand Management
(TDM) program consistent with the City of South San Francisco ordinance. This TDM program would
reduce the number of vehicle trips generated by the project and associated VMT. However, the TDM
would not reduce the number of trips and VMT to an amount that would be assumed under the existing
significant and unavoidable
General Plan designation for the site. Thus, this impact would be considered .
Impact IV.C-2: The proposed project would violate an air quality standard.
Construction/Demolition Emissions
The proposed project would involve the demolition of the existing structures on the site and construction
of office buildings. During the construction phase of development of the proposed project, on-site
stationary sources, heavy-duty construction vehicles, construction worker vehicles, and energy use would
generate emissions. In addition to construction vehicle emissions, fugitive dust would also be generated
during grading and construction activities. Dust is generated when grading equipment breaks down
surface materials. The resulting dust, which includes PM, is subsequently entrained into the air by wind
10
and vehicle tires. Although much of this airborne dust would settle out on or near the project site, smaller
particles would remain in the atmosphere, increasing existing particulate levels within the surrounding
area. Sensitive receptors that could be affected by construction include the existing residential areas near
the project site. Although the project’s construction-related emissions would be temporary in duration, in
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-20
City of South San Francisco October 2009
the absence of control measures, the emissions could be substantial. This would be a temporary, but
significant impact
potentially . As described above, the determination of significance with respect to
construction emissions is based on whether all the applicable control measures for PM indicated in the
10
BAAQMD CEQA Guidelines
would be implemented. Therefore, upon implementation of Mitigation
less than significant
Measure C-1.1 listed below, this impact would be.
Mitigation Measure IV.C-2.1 Construction/Demolition Emissions
Implementation of the following measures would reduce airborne dust by reducing and controlling loose
soils in areas subject to dust creating activity. As a condition of the construction contracts, the project
sponsors shall require that construction contractors follow these construction practices:
a.Water all active construction areas at least twice daily.
b.Cover all trucks hauling soil, sand, and other loose materials or require all trucks
to maintain at least two feet of freeboard.
c.Pave, apply water three times daily, or apply non-toxic soil stabilizers on all
unpaved access roads, parking areas, and staging areas at the construction sites.
d.Sweep daily (with water sweepers) all paved access roads, parking areas, and
staging areas at the construction sites.
e.Sweep public streets adjacent to construction sites daily (with water sweepers) if
visible soil material is carried onto the streets.
f.Hydroseed or apply non-toxic soil stabilizers to inactive construction areas
(previously graded areas inactive for ten days or more).
g.Enclose, cover, water twice daily, or apply non-toxic soil binders to exposed
stockpiles (dirt, sand, etc.).
h.Limit traffic speeds on unpaved roads to 15 miles per hour.
i.Install sandbags or other erosion control measures to prevent silt runoff to public
roadways.
j.Replant vegetation in disturbed areas as soon as possible.
k.Wash off the tires or tracks of all trucks and equipment leaving the construction
site.
l.Install wind breaks at the windward sides of the construction areas
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-21
City of South San Francisco October 2009
m.Suspend excavation and grading activities when wind (as instantaneous gusts)
exceeds 25 miles per hour.
Regional Operational Emissions – Daily Emissions of ROG, NO, and PM
x10
Operational emissions associated with the ultimate development and operation of the proposed project
would result primarily from increased vehicular trips to and from the commercial development. Other
sources of emissions associated with the project would include area source emissions, such as the regular
use of natural gas for water heaters and cooking appliances. The primary sources of emissions would
continue to occur from the vehicular trips generated by the project.
The predicted mobile source and area source emissions associated with project operation were calculated
using the URBEMIS 2007 computer model distributed for use by the CARB and recommended for use by
the BAAQMD. The average daily indirect and direct emissions associated with the proposed project are
presented in Table IV.C-4 and are compared with the BAAQMD project-specific recommended
thresholds of significance for the sources of pollutants for near-term projects (2015) and Master Plan
buildout (2020). As shown in the table, the project would not generate average daily direct and indirect
emissions of ROG and NOandPM in excess of the significance thresholds by 2015.
x10
Under the 2020 buildout, the project would not generate average daily direct and indirect emissions of
ROG and NOin excess of the significance thresholds. However, project emissions for PM would
x10
exceed BAAQMD-recommended thresholds for the Master Plan buildout. Short of reducing project
generated traffic, there are no mitigation measures available to reduce this impact. Therefore, impacts
related to generation of operational emissions of PMfor the 2020 Master Plan buildout would be
10
significant and unavoidable.
Table IV.C-4
Air Pollutant Emissions from Project Operations (lbs/day)
Operational Activity ROGNOx PM
10
Near-Term Projects 2015
Project Operational Emissions 29.06 35.91 76.80
8.94 13.01 24.78
a
Removed Emissions
20.12 22.90 52.02
Net Emissions
80 80 80
Significance Threshold
No No No
Significant Impact?
Master Plan Buildout 2020
Project Operational Emissions 44.76 59.41 151.44
11.66 15.55 40.40
a
Removed Emissions
33.1 43.86 111.04
Net Emissions
80 80 80
Significance Threshold
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-22
City of South San Francisco October 2009
Table IV.C-4
Air Pollutant Emissions from Project Operations (lbs/day)
Operational Activity ROGNOx PM
10
No No Yes
Significant Impact?
Notes:
a
Removed emissions include existing buildings to be removed during the
near-term projects or Master Plan buildout.
Source: Christopher A. Joseph & Associates, 2009.
Mitigation Measure IV.C-2.2 Regional Operational Emissions – Daily Emissions of ROG, NO, and
x
PM
10
As noted earlier, the primary sources of long-term, indirect emissions associated with the project are
motor vehicles. The current evaluation includes implementation of a TDM program estimated to account
for a 20 percent reduction in trip generation. However, even with the reduced traffic resulting from the
significant and unavoidable
TDM program, this impact would be .
Impact IV.C-3: The proposed project would not expose sensitive receptors to substantial pollutants.
Local CO Concentrations
As stated previously, the BAAQMD recommends that CO modeling be performed for projects for which
traffic would affect intersections or roadway segments operating at LOS E or F, or would cause a decline
to LOS E or F. Thus, CO modeling was performed for the following study intersections:
Near-Term Projects (2015)
Oyster Point Boulevard / Dubuque Avenue / U.S.101 Northbound On-Ramp
Oyster Point Boulevard / Gateway Boulevard / U.S.101 Southbound (Flyover) Off-Ramp
Oyster Point Boulevard / Veterans Boulevard
E. Grand Avenue / Gateway Boulevard
Airport Boulevard / San Mateo Avenue / Produce Avenue
Gateway Boulevard / South Airport Boulevard / Mitchell Avenue
5
Master Plan Buildout (2020)
Airport Boulevard / U.S.101 Southbound Off-Ramp
Oyster Point Boulevard / Dubuque Avenue / U.S.101 Northbound (Flyover) Off-Ramp
5
Although the Master Plan Buildout year is 2020, traffic volume calculations were carried out to 2035 to capture a
cumulative scenario.
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-23
City of South San Francisco October 2009
Oyster Point Boulevard / Gateway Boulevard / U.S.101 Southbound (Flyover) Off-Ramp
Oyster Point Boulevard / Veterans Boulevard
Airport Boulevard / San Mateo Avenue / Produce Avenue
East Grand Avenue / Gateway Boulevard
Airport Boulevard / Grand Avenue
Gateway Boulevard / South Airport Boulevard / Mitchell Avenue
For this analysis, CO concentrations were calculated based on a simplified CALINE4 screening procedure
developed by the BAAQMD. This methodology assumes worst-case conditions (i.e., wind direction is
parallel to the primary roadway, 90 to the secondary road; wind speed of less than one meter per second;
and a high level of atmospheric stability or lack of change) and provides a screening of maximum, worst-
case CO concentrations. Maximum CO concentrations were calculated for peak-hour traffic volumes at
the study intersections noted above. Results are presented below in Tables IV.C-5 and IV.C-6.
Based on the CALINE4 computer-modeling results (Tables IV.C-5 and IV.C-6), local CO concentrations
would not exceed State or national ambient air quality standards. Therefore, emissions of CO associated
less than significant
with the project would be with no mitigation warranted.
Table IV.C-5
Predicted Future Localized Carbon Monoxide Concentrations for Near-Term Projects (2015)
CO Concentrations in Parts Per Million
Intersection
Roadway Edge 25 Feet 50 Feet
1-Hour 8-Hour 1-Hour 8-Hour 1-Hour 8-Hour
Oyster Point Blvd & Dubuque Ave/U.S. 101
3.9 2.5 3.4 2.3 3.3 2.1
Northbound On-Ramp (signal)
Oyster Point Blvd/U.S 101 Southbound
3.8 2.5 3.4 2.2 3.2 2.1
(Flyover) Off-Ramp (Signal) & Gateway Blvd
Oyster Point Blvd & Veterans Blvd 3.7 2.4 3.3 2.1 3.1 2.0
East Grand Ave & Gateway Blvd 3.3 2.2 3.1 2.0 3.0 1.9
Airport Blvd/Produce Ave & San Mateo Ave 3.3 2.2 3.1 2.0 3.0 1.9
Gateway Blvd/South Airport Blvd & Mitchell
3.2 2.1 3.0 1.9 2.9 1.9
Ave
Note: National 1-hour standard is 35.0 ppm
State 1-hour standard is 20.0 ppm
National and State 8-hour standard is 9.0 ppm
Source: Christopher A. Joseph & Associates, 2009. Based on year 2015 EMFAC2007 Winter emission factors.
BAAQMD CEQA Guidelines
According to the , when considered potential impacts related to TACs, two
situations should be considered: 1) the proposed project is a source of TACs and is near sensitive
receptors; or 2) sensitive receptor within the proposed project is near an existing source of TACs. TACs
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-24
City of South San Francisco October 2009
are typically associated with a variety of sources, including industrial facilities such as refineries,
chemical plants and chrome platers, commercial facilities such as dry cleaners and gasoline stations, and
motor vehicles. TACs emissions from motor vehicles are generally a result of diesel exhaust emissions
associated with truck or bus operations and along heavily-traveled freeways.
The proposed project does not include land uses such as those previously described, but it would generate
traffic trips. Although the project would generate new traffic trips, the amount of TACs that would be
generated by these new trips is not anticipated to be of a high enough concentration to pose a cancer risk
that exceeds 10-in-1-million or a non-cancer risk greater than a hazard index of 1.0. Therefore, project
less than significant
impacts related to TACs would be .
Since the proposed project would include the continuation of the existing child day care facility though
Phase 1a, the impact of TACs from nearby stationary and mobile sources on this sensitive receptor was
evaluated. A total of 15 stationary sources with emission inventories were identified (Figure IV.C-1).
Stationary sources are required to conduct an AB2588 “hot spot” evaluation to determine the risk to the
surrounding area. Those facilities determined to be “high priority” with respect to potential impacts are
required to prepare a facility-wide health risk assessment. Based on a review of the CARB emission
inventory, no facilities requiring a facility-wide health risk assessment are within a ¼-mile radius of the
existing child day care facility. However, the emission inventories of the 15 facilities within ¼ mile of the
facility were used to estimate risks from emitted TACs to the child day care facility.
Table IV.C-6
6
Predicted Future Localized Carbon Monoxide Concentrations for Master Plan Buildout (2020)
CO Concentrations in Parts Per Million
Intersection
Roadway Edge 25 Feet 50 Feet
1-Hour 8-Hour 1-Hour 8-Hour 1-Hour 8-Hour
Airport Blvd & U.S. 101 Southbound Off-Ramp 3.0 1.9 2.8 1.8 2.7 1.8
Oyster Point Blvd & U.S. 101 Northbound Off-
3.3 2.1 3.0 2.0 2.9 1.9
Ramp/Dubuque Ave
Oyster Point Blvd/U.S. 101 Southbound
3.6 2.4 3.2 2.1 3.1 2.0
(Flyover) Off-Ramp & Gateway Blvd
Oyster Point Blvd & Veterans Blvd 3.5 2.3 3.2 2.1 3.0 2.0
Airport Blvd & Grand Ave 3.0 1.9 2.8 1.8 2.8 1.8
East Grand Ave & Gateway Blvd 3.2 2.1 3.0 1.9 2.9 1.9
Airport Blvd/Produce Ave & San Mateo Ave 3.2 2.1 3.0 1.9 2.9 1.9
Gateway Blvd/South Airport Blvd & Mitchell
3.1 2.0 2.9 1.9 2.8 1.8
Ave
6
Although the Master Plan Buildout year is 2020, traffic volume calculations were carried out to 2035 to capture a
cumulative scenario.
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-25
City of South San Francisco October 2009
Table IV.C-6
6
Predicted Future Localized Carbon Monoxide Concentrations for Master Plan Buildout (2020)
CO Concentrations in Parts Per Million
Intersection
Roadway Edge 25 Feet 50 Feet
1-Hour 8-Hour 1-Hour 8-Hour 1-Hour 8-Hour
Note: National 1-hour standard is 35.0 ppm
State 1-hour standard is 20.0 ppm
National and State standard is 9.0 ppm
Source: Christopher A. Joseph & Associates, 2009. Based on year 2020 EMFAC2007 Winter emission factors.
The most significant mobile source identified was U.S.101, approximately 1,000 feet (0.19 miles) west of
proposed project. Diesel particulate matter (DPM), a known toxic air contaminant, would occur from
trucks traveling along U.S.101. To address diesel particulate emissions, statewide programs and
regulations are presently being developed and implemented by CARB and U.S. EPA to reduce the risks
of exposure to diesel exhaust. These programs include emission control requirements along with subsidies
for upgrading older diesel engines to low-emission models.
Dispersion modeling was performed using the Lakes Environmental ISC – AERMOD Version 5.8.1
version of the US EPA’s Industrial Source Complex—Short Term, Release 3 (ISCST3) model (Version
02035) to estimate the ground-level diesel concentrations. The dispersion model used an emission factors
for diesel-powered trucks obtained from the EMFAC2007 computer model along with available truck
average daily traffic counts published by the California Department of Transportation, Traffic and
7
Vehicle Data Systems Unit. As a conservative estimate, the modeling estimated ground-level diesel
concentrations along the proposed property fence line. The estimated air concentration calculated by the
air quality dispersion model was then used to calculate the cancer risk and non-cancer hazard effects for
the evaluated receptors exposed to TACs based on methodologies consistent with the Cal/EPA’s Office of
Environmental Health Hazard Assessment Air Toxics Hot Spots Program Risk Assessment and School
8, 9
Site Risk Assessment Guidelines. Children could potentially be present at the child day care facility for
up to five years in duration (from age 1 to 6). It was conservatively assumed that children at the child day
care facility would be outdoors throughout the duration of their stay at the project site. However, indoor
TACs air concentrations are likely to be significantly lower due to HVAC systems. In addition, the child
day care facility would no longer be present on-site after the completion of Phase 1a.
Based on the dispersion model, the maximum concentration of TACs in air would be along the western
fence line. Only the single highest concentration at receptor height was evaluated, since it can be
reasonably assumed that other receptors in the area would have a concentration less then the maximum.
7
CalDOT, 2007AADT. Accessed October 2008 http://www.dot.ca.gov/hq/traffops/saferesr/trafdata/.
8
Cal/EPA OEHHA, Air Toxics Hot Spots Program Risk Assessment Guidelines, 2003.
9
Cal/EPA OEEHA, Guidance for School Site Risk Assessment Pursuant to Health and Safety Code Section
901(f). 2004.
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-26
City of South San Francisco October 2009
The maximum concentrations determined for the area would result in an incremental lifetime cancer risk
of 0.95 in one million, which is below the significance criteria of 10 per one million. In addition, the
TACs concentration for the area would result in a chronic non-cancer health risk of approximately 0.013
and an acute non-cancer health risk of 0.0069. Any non-cancer health risk less than one (1) is considered
less than significant
to be . The estimated maximum cancer and non-cancer health impacts are
summarized in Table IV.C-7. Despite the conservative approach taken for this HRA, the inhalation cancer
risk, chronic non-cancer hazard index, and acute non-cancer hazard index at the proposed project are
below the significance thresholds. Therefore, impacts from nearby sources to the sensitive receptors
less than significant
located at the project site would be and no mitigation is warranted.
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-27
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City of South San Francisco October 2009
Table IV.C-7
Proposed Project Estimated Health Risks
Impact Value
Cancer Risk 0.95 in one million
Significance Threshold 10 in one million
Significant Impact? No
Chronic Non-Cancer HI 0.013
Significance Threshold 1.0
Significant Impact? No
Acute Non-Cancer HI 0.0069
Significance Threshold 1.0
Significant Impact? No
Notes: Non-Cancer HI = Non-Cancer Health Index
Source: Christopher A Joseph & Associates, October 2008.
Impact IV.C-4: The proposed project would not create objectionable odors.
According to the BAAQMD CEQA Guidelines, the types of projects that commonly result in odor
impacts include: wastewater treatment plant, sanitary landfills, transfer stations, composting facilities,
petroleum refineries, asphalt batch plants, chemical manufacturing, fiberglass manufacturing, auto body
shops, rendering plants, and coffer roasters. The proposed project does not include any of these uses and
would not create objectionable odors that would affect a substantial number of people. Therefore, project
less than significant
impacts related to odors would be , and no further analysis of this issue is required.
Impact IV.C-5: The proposed project would not conflict with the State goals in AB 32 (California
Global Warming Solutions Act).
As stated, above, three types of analyses are used to determine whether the project could be in conflict
with the State measures for reducing greenhouse gas emissions. The analyses are as follows:
Item A:
The project does not pose any apparent conflict with the most recent list of the CARB early action
strategies (see Table IV.C-3). In addition, as mentioned above, the 44 measures are in the sectors of fuels,
transportation, forestry, agriculture, education, energy efficiency, commercial, solid waste, cement, oil
and gas, electricity, and fire suppression. As the project is an office park, it is not considered a part of any
of the listed sectors.
Item B:
The project is not the type of project that would be required to report emissions to CARB (i.e., the
project is not a cement plant, oil refinery, electric generating facility/provider, co-generation facility, or
hydrogen plant or other stationary combustion source that emits more than 25,000 metric tons per year of
Gateway Business Park Master Plan IV.C. Air Quality
Draft Environmental Impact Report Page IV.C-29
City of South San Francisco October 2009
COe emissions). Therefore, the specific emissions from this project would not be expected to have a
2
substantial impact on Global Climate Change.
As shown in Table IV.C-8, project construction greenhouse gas emissions for the proposed project would
be approximately 2,193 metric tons per year of COe emissions and the net increase in COe emissions
22
resulting from the project would be approximately 14,884 metric tons per year (including emissions from
vehicle trips, space heating and indirect emissions from the use of electricity). Operational emissions
would therefore be lower than the reporting limit, which is 25,000 metric tons per year of COe
2
emissions. Accordingly, the project would not be subject to CARB’s mandatory reporting requirements.
Table IV.C-8
Predicted Proposed Project Greenhouse
Gas Emissions
COe Emissions
2
in Metric Tons
Emissions Source per Year
Construction (2011-2020) 2,193
Master Plan Buildout (2020)
Natural Gas Use 1,603
Electrical Use 6,360
Motor Vehicles 11,946
Total 19,909
Existing (2010)
Natural Gas Use 370
Electrical Use 1,468
Motor Vehicles 3,187
Total 5,025
Net Increase 14,884
Source: Christopher A. Joseph & Associates, 2008.
Item C:
The project would be in accordance with BAAQMD required mitigation measures for
construction and operations emissions, which would reduce GHGs. In addition, the project includes a
TDM program designed to reduce vehicle-miles-traveled.
The review of Items A, B, and C indicate that the project would not conflict with the State goals in AB 32
less than significant.
and therefore this impact would be
CUMULATIVE IMPACTS
According to the BAAQMD CEQA Guidelines, any project that would individually have a significant air
quality impact would also have a significant cumulative air quality impact. Approval of the proposed
project would require a General Plan Amendment and the proposed land use associated with the proposed
project would generate more vehicle trips (and more miles traveled) than those that could be generated
Gateway Business Park Master Plan IV.C. Air Quality
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City of South San Francisco October 2009
under the existing General Plan designation. However, the TDM would not reduce the number of trips
and VMT to an amount that would be assumed under the existing General Plan designation for the site
significant and unavoidable
and this impact would be . Since the proposed project would exceed the
BAAQMD-recommended operational emissions thresholds for individual projects, the cumulative air
significant and unavoidable
quality impacts are also considered .
LEVEL OF SIGNIFICANCE AFTER MITIGATION
Implementation of Mitigation Measure IV.C-2.1 identified in this section would adequately mitigate
less than significant
potential construction dust impacts. These impacts would also be reduced to a level.
As stated above, the TDM program may reduce total traffic to a greater degree through additional
measures. However, the TDM would not reduce the number of trips and VMT to an amount that would be
assumed under the existing General Plan designation for the site and impacts to consistency with an
significant and unavoidable
applicable air quality plan would be . Additionally, operational impacts
related to the violation of an air quality standard, even with implementation of Mitigation Measure IV.C-
significant and unavoidable
2.2, would remain .
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