HomeMy WebLinkAbout3.3_AQ-GHG_FroomRanch_DEIR3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
This section analyzes air quality and greenhouse gas (GHG) emissions impacts associated
with the Project, including local and regional air quality within the County. Air quality is
evaluated according to the concentration of pollutants in ambient air. The U.S.
Environmental Protection Agency (U.S. EPA) and California Environmental Protection
Agency (CalEPA) have established national and state criteria to protect public health and
welfare for seven criteria pollutants, including carbon monoxide (CO), nitrogen dioxide
(NO2), ozone (O3), sulfur dioxide (SO2), 10-micron particulate matter (PM10), 2.5-micron
particulate matter (PM2.5) and lead (Pb). The CalEPA has also established state criteria for
sulfates, hydrogen sulfide (H2S), and visibility reducing particulates. Other air pollutants
of concern include toxic air contaminants (TACs) or hazardous air pollutants (HAPs), in
diesel particulate matter, generated from the operation of diesel engines (e.g., trains,
equipment, trucks, etc.).
3.3.1 Environmental Setting
3.3.1.1 Regional Climate and Meteorology
The County’s climate is Mediterranean with warm dry summers and cool damp winters.
Inland areas typically experience a wider range of temperatures than on the coast due to
the separation of regions by coastal mountain ranges. The warmest month in the County is
generally September and the coolest month is January. Maximum temperatures in the
summer in coastal areas average about 70 degrees Fahrenheit, while temperatures in the
high 90s are typical in the inland valleys. Average minimum winter temperatures is 48
degrees Fahrenheit, but can drop to the 30s along the coast to the 20s inland (Western
Regional Climate Center 2016).
The County’s meteorology is largely controlled by a persistent high-pressure system over
the eastern Pacific Ocean. The Pacific high-pressure system remains generally fixed
several hundred miles offshore from May through September. Coastal fog and low clouds
often form in the marine layer along the coast, lessening in the warmer interior valleys
(City of San Luis Obispo 2014).
The speed and direction of local winds are influenced by the location and strength of the
Pacific high-pressure system, by topographical features and by circulation patterns
resulting from temperature differences between land and sea. In spring and summer, when
the Pacific high-pressure system is at its strongest, onshore winds from the northwest
generally prevail during the day. In the fall, onshore surface winds decline and the marine
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layer grows shallow, allowing an occasional weak offshore wind. Pollutants may
accumulate more during this time of year, remaining over the ocean for a few days and
being carried back onshore. Strong inversions, or a deviation in the typical decrease in
temperature with respect to altitude, can form at this time, trapping pollutants near the
ground surface; this effect is intensified when the Pacific high-pressure system weakens
and moves inland to the east. This may produce a condition known as Santa Ana winds
where air, often pollutant-laden, is transported into the County from the east and southeast.
The break-up of this condition generally occurs within seven days and may then result in
stagnant conditions and a build-up of pollutants offshore. The sea breeze can also bring
these pollutants back onshore, where they combine with local emissions and cause higher
pollutant concentrations.
Local meteorological conditions in the Project vicinity typically consist of average
temperatures varying from 40 to 70 degrees Fahrenheit seasonally, with precipitation
observed 33 percent of the year, mainly from December through March. Wind speeds vary
from 0 to 20 mph throughout the year, and the wind is most often out of the northwest and
west. Approximately 90 percent of the total annual rainfall in the County occurs between
November and April; however, rainfall amounts can vary considerably among different
regions in the County. Annual rainfall averages from 16 to 28 inches in the Coastal Plain,
while the Upper Salinas River Valley receives approximately 12 to 20 inches of rain
annually. The Carrizo Plain is the driest area of the County, receiving an average of less
than 12 inches of rain per year (San Luis Obispo County Air Pollution Control District
[SLO County APCD] 2001).
3.3.1.2 Greenhouse Gases and Global Climate Change
The U.S. EPA defines climate change as “any significant change in the measures of climate
lasting for an extended period of time.” In other words, climate change includes major
changes in temperature, precipitation, or wind patterns, among other conditions, that occur
over several decades or longer. Scientific consensus is that human-caused emissions of
GHGs above natural levels is the primary contributor to global climate change. When GHG
levels increase in the atmosphere, the greenhouse effect intensifies on Earth and drives
long-term climate change. GHGs trap heat in the atmosphere and regulate the Earth’s
temperature and include water vapor, carbon dioxide (CO2), methane (CH4), nitrogen
oxides (NOx), chlorofluorocarbons (CFCs) and O3. The largest anthropogenic source of
emissions comes in the form of CO2, which makes up approximately 82 percent of U.S.
GHG emissions annually (U.S. EPA 2017). Although methane, nitrogen oxides,
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chlorofluorocarbons, and hydrocarbons make a smaller portion of GHG volume, they are
powerful greenhouse gases and play an outsized role in climate change.
The primary human activities that emit GHGs include the electric power industry,
transportation, industrial/manufacturing, agricultural, commercial, and residential uses
(U.S. Energy Information Administration [U.S. EIA] 2017). The main sources of GHGs
due to human activity include the combustion of fossil fuels and deforestation (loss of CO2
sequestration); livestock and rice paddy farming, wetland depletions, and landfill emissions
(CH4); refrigeration systems and fire suppression systems use and manufacturing (CFCs);
and agricultural activities, including the use of fertilizers (NOx) (U.S. EPA 2017).
In 2015, the State of California produced approximately 363.5 million metric tons of CO2
equivalent (MMT CO2e) emissions from fossil fuel combustion. Sector sources of these
CO2 emissions are as follows: transportation (56.7 percent), industry (19.6 percent),
electricity generation (12.2 percent), residential (6.4 percent), and commercial (5.1 percent)
(U.S. EIA 2017). In 2016, the City’s emissions amounted to 242,210 metric tons of CO2
equivalent (MT CO2e), an approximately 10 percent reduction compared to the City’s 2005
GHG inventory which amounted to 269,720 MT CO2e. In 2016, GHG emissions in the
City were from transportation (51 percent), commercial and industrial energy (electricity
and natural gas) (22 percent), residential energy (electricity and natural gas) (18 percent),
solid waste (6 percent), wastewater (<1 percent), and off-road sources (6 percent) (City of
San Luis Obispo 2018).
The global climate crisis has already impacted the City and will continue to affect an
increasing range of resource areas, including hydrological and biological resources.
Projected impacts to the region caused by global climate change include rising sea levels,
coastal flooding, increased tsunami hazards, drought, increased fire frequency, size, and
severity, and sediment transportation and deposition-related impacts on aquatic ecosystems
(California Natural Resources Agency 2018).
3.3.1.3 Regional Air Quality
The County is part of the South Central Coast Air Basin (SCCAB), which also includes
Santa Barbara and Ventura counties to the south. Air quality within the County is
contingent on several factors including the type, amount and dispersion rates of pollutants
being emitted within the region. Major factors affecting pollutant dispersion, as discussed
in the previous paragraphs, are wind speed and direction, atmospheric stability,
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temperature, the presence or absence of inversions, and the topographic and geographic
features of the region.
3.3.1.4 Regional Emissions
Under the Federal Clean Air Act (FCAA) of 1963, federal air quality standards, known as
the National Ambient Air Quality Standards (NAAQS), were established for the criteria
air pollutants described previously. Similarly, the California Clean Air Act (CCAA) of
1988 establishes state air quality standards that are more stringent than the NAAQS as part
of the California Ambient Air Quality Standards (CAAQS). Measurements of ambient
concentrations of criteria air pollutants are used by the U.S. 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
monitoring data with the national and state air quality 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 in marginal, moderate,
serious, severe, or extreme “non-attainment,” depending on the magnitude of the air quality
standard exceedance. If there are not enough data available to determine whether the
standard is exceeded in an area, the area is designated “unclassified.”
The County has historically been designated as in non-attainment of state standards for 1-
hour and 8-hour O3 (see Table 3.3-1). The national 8-hour O3 standard was lowered from
75 to 70 parts per billion (ppb) on October 1, 2015. The eastern portion of the County is
still designated as in non-attainment for the new standard, while the western portion of the
County is designated as within attainment status (SLO County APCD 2019). O3 is a
secondary pollutant that is not produced directly by a specific emission source, but rather
is formed by a reaction between NOx and reactive organic gases (ROGs) in the presence of
sunlight. Primary sources of NOx are motor vehicles (over 50 percent), public utility power
generation, and fuel combustion by various industrial sources. O3 can impact public health
at higher concentrations by causing respiratory irritation and other effects upon the lungs.
It can also affect sensitive plant species by interfering with photosynthesis, and is therefore
a threat to California agriculture and native vegetation (U.S. EPA 2018).
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Table 3.3-1. Ambient Air Quality Standards and County Attainment Status (2019)
Pollutant Average
Time
California Standards National Standards
Concentration Attainment
Status Concentration Attainment
Status
Ozone (O3) 1 Hour 0.09 ppm (180 μg/m3) Non-
Attainment
-- Non-Attainment
Eastern County
– Attainment
Western County
(Project site)
8 Hour 0.070 ppm (137 μg/m3) 0.070 ppm
(137 μg/m3)
Respirable
Particulate
Matter
(PM10)
24 Hour 50 μg/m3 Non-
Attainment
150 μg/m3 Unclassified*/
Attainment Annual
Arithmetic
Mean
20 μg/m3 --
Fine
Particulate
Matter
(PM2.5)
24 Hour -- Attainment 35 μg/m3 Unclassified*/
Attainment Annual
Arithmetic
Mean
12 μg/m3 12 μg/m3
Carbon
Monoxide
(CO)
1 Hour 20 ppm (23 mg/m3) Attainment 35 ppm (40
mg/m3)
Unclassified*
8 Hour 9 ppm (10 mg/m3) 9 ppm (10
mg/m3)
Nitrogen
Dioxide
(NO2)
1 Hour 0.18 ppm (339 μg/m3) Attainment 100 ppb (188
μg/m3)
Unclassified*
Annual
Arithmetic
Mean
0.030 ppm (57 μg/m3) 0.053 ppm
(100 μg/m3)
Sulfur
Dioxide
(SO2)
1 Hour 0.25 ppm (655 μg/m3) Attainment 75 ppb (196
mg/m3)
Unclassified*
3 Hour -- 0.5 ppm (1300
μg/m3)
24 Hour 0.04 ppm (105 μg/m3) 0.14 ppm
Annual
Arithmetic
Mean
-- 0.030 ppm
Lead (Pb) 30-Day
Average
1.5 μg/m3 Attainment -- No Attainment
Information
Calendar
Quarter
-- 1.5 μg/m3
Rolling 3-
Month
Average
-- 0.15 μg/m3
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Table 3.3-1. Ambient Air Quality Standards and County Attainment Status (2019)
(Continued)
Pollutant Average
Time
California Standards National Standards
Concentration Attainment
Status Concentration Attainment
Status
Visibility
Reducing
Particulates
8 Hour Extinction coefficient of
0.23 per kilometer –
visibility of 10 miles or
more (0.07-30 miles or
more for Lake Tahoe) due
to particulates when relative
humidity is less than 70 %.
Method: Beta Attenuation
and Transmittance through
Filter Tape.
Attainment No Federal Standards
Sulfates 24 Hour 25 μg/m3 Attainment
Hydrogen
Sulfide
(H2S)
1 Hour 0.03 ppm (42 μg/m3) Attainment
Vinyl
Chloride
24 Hour 0.01 ppm (26 μg/m3) No
Attainment
Information
Notes: ppm = parts per million; ppb = parts per billion
μg/m3 = micrograms per cubic meter; mg/m3 = milligram per cubic meter
-- = Not applicable
*Unclassified (U.S. EPA/federal definitions): Any area that cannot be classified on the basis of available information as
meeting or not meeting the national primary or secondary ambient air quality standard for that pollutant.
Attainment (U.S. EPA/federal definitions): Any area that meets the national primary or secondary ambient air quality
standard for that pollutant. (CARB definition): State standard was not exceeded during a three-year period.
Non-Attainment (U.S. EPA/federal definitions): Any area that does not meet, or contributes to an area that does not
meet the national primary or secondary ambient air quality standard for that pollutant. (CARB definitions): State
standard was exceeded at least once during a three-year period.
Source: SLO County APCD 2017b.
The County is in non-attainment for the state PM10 standards; however, the County is within
attainment of national PM10 standards. PM10 is comprised of finely divided solids and
liquids such as dust, soot, aerosols, fumes, and mists. Human activities that generate PM10
include agricultural operations, industrial processes, fossil fuel combustion, construction
and demolition operations, and entrapment of road dust into the atmosphere. Natural
sources include wind-blown dust, wildfire smoke, and sea spray salt (U.S. EPA 2018).
3.3.1.5 Emissions in the Vicinity of the Project Site
The Project site is composed of grazing land and disturbed/developed area in the
northwestern area of the site that comprises the historic Froom Ranch Dairy complex (see
Section 3.5, Cultural and Tribal Cultural Resources), a construction storage yard, and
quarry/aggregate mining pit and storage area. Ongoing construction storage yard activities
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generate fugitive dust via uncovered stockpiles of various materials such as dirt and rock
and pollutant emissions from operation of heavy construction equipment and trucks.
Information about the daily average operations of equipment at the Project site varies
substantially due to the nature of the existing construction business. However, based on
field observations and aerial imagery, the regular driving of heavy trucks and earthmoving
equipment within the quarry and on the property also contributes to existing onsite fugitive
dust and diesel particulate emissions. The 3.2-acre onsite stormwater detention basin does
not produce emissions besides those associated with infrequent maintenance clearing;
based on aerial imagery, clearing of vegetation within the basin occurred in 2013 and 2018.
The remainder of the site is unimproved, consisting of natural areas that do not currently
produce emissions.
The Project site is surrounded to the north, east, and south by urban development, including
the Irish Hills Plaza shopping center to the north, several automobile dealerships to the
east, and four hotels and Mountainbrook Church to the south. These uses generate traffic
on local roads. LOVR runs immediately east of the Project site and U.S. 101 is located as
close as 400 and 600 feet south of the Specific Plan area. Vehicles in the Project vicinity
contribute to existing emissions in the SCCAB, along with land uses, equipment, and
industrial processes within urban areas, and agricultural uses in rural areas.
The Project site lies within the Naturally Occurring Asbestos (NOA) buffer area per the
SLO County APCD’s NOA map and is therefore subject to CARB’s Air Toxics Control
Measure (ATCM) for Construction, Grading, Quarrying, and Surface Mining Operations.
CARB has identified asbestos as a TAC that if inhaled may result in the development of
lung cancer or cause other health hazards. NOA can be found in serpentine rock and can
be released into the air when it is broken or crushed. In the County, serpentine rock is
located in many regions, including the Project site. Work in serpentine areas requires a
SLO County APCD pre-approved dust control plan and may include asbestos air
monitoring. Prior to any grading activities at a site within an area potentially containing
NOA, the Applicant is required to comply with the applicable sections contained in the
NOA ATCM, including the California Code of Regulations (CCR) Title 17, Section 93105.
The air monitoring station located nearest to the Project site is the San Luis Obispo –
Higuera Street station, located at 3220 S. Higuera Street, approximately 1.0 mile northeast
of the Project site. This station has been active since 2005 and is operated by CARB and
measures O3, PM2.5, and PM10 (CARB 2018). Table 3.3-2 summarizes the annual air
quality emissions data for the local airshed between the years 2016-2018, with values
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exceeding state emissions underlined (there were no federal exceedances at this monitoring
station recorded during this period).1 The number of exceedance days for each pollutant
are also shown. This table shows the general air quality trends of the area for pollutants
measured near the Project site.
Table 3.3-2. Ambient Air Quality Data at San Luis Obispo – Higuera Street
Station
O3 ppb PM10 μg/m3 PM2.5 μg/m3
Worst
1-Hour
Worst
8-Hour
O3 Exceedance
Days 1-Hour/
8-Hour
Worst
24-Hour
Exceedance
Days
Worst
24-Hour
Exceedance
Days
2016 69 62 0/0 42 0 21 0
2017 74 66 0/0 62 3 25 0
2018 62 53 0/0 46 0 13 0
Threshold 90 70 50 -
Notes: ppb = parts per billion, μg/m3 = micrograms per cubic meter; underlined values have exceeded state emissions
standards; there are no values at this station that exceed federal emission standards.
Source: CARB 2018; 2019.
3.3.1.6 Sensitive Receptors
The SLO County APCD defines sensitive receptors as people that have an increased
sensitivity to air pollution or environmental contaminants. Sensitive receptor locations
include schools, parks and playgrounds, day care centers, nursing homes, hospitals, and
residential dwelling unit(s) (SLO County APCD 2012). These uses are considered sensitive
as they are more likely to contain populations of people who have an increased sensitivity
to air pollution or environmental contaminants. Children under the age of 16 are
particularly susceptible to health problems from air emissions exposure for developing
lungs, as well as elderly people over 65, individuals with respiratory and cardiovascular
health problems, and people conducting strenuous work or active exercise.
There are no existing sensitive receptors within or immediately adjacent to the Project site.
The Project site is surrounded by undeveloped land in the Irish Hills Natural Reserve and
commercial development, including four hotels, Mountainbrook Church, automobile
dealerships and service centers, and the Irish Hills Plaza shopping center. Mountainbrook
Church lies approximately 75 feet from the southern boundary of the Project site and 580
feet from the Upper Terrace. Mountainbrook Church is open daily and offers religious
services throughout the week, including classes and programs for children and youth, with
1 A local airshed is defined as a geologic area that shares a common air flow or atmosphere that is exposed to the same condition, such
as source of pollutants or dispersion.
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most programs offered during evenings and weekends. Four hotels (Rose Garden Inn,
Courtyard by Marriott, Hampton Inn & Suites, and Motel 6) are located 40 to 160 feet east
of the Project site boundary. The closest school is Pacific Beach High School, which is
approximately 0.27 mile northwest of the Project site and is considered the nearest sensitive
receptor. Neither the Mountainbrook Church or the hotels along Calle Joaquin are
considered sensitive receptors to air pollutants, as guests and visitors of these developments
are considered transient and would not be exposed to air pollutant emissions for extended
periods of time. The closest existing residential area is approximately 0.3 mile northeast of
the Project site.
3.3.1.7 Odors/Nuisance Emissions
Common sources of odors and nuisance emissions include wastewater treatment plants,
landfills, composting facilities, petroleum refineries, and chemical manufacturing
facilities. The nearest such source of odor to the Project site is the San Luis Obispo Water
Resource Recovery Facility (WRRF) located approximately 0.66 mile east of the Project
site boundary, across U.S. 101. Odors from the WRRF, which are caused from H2S, a gas
that smells like rotten eggs, are not perceptible at the Project site based on field
reconnaissance by the EIR consultant from 2017 through 2019.
3.3.2 Regulatory Setting
Air quality and GHG emissions are governed primarily by federal and state laws, although
local jurisdiction laws would also apply to future development under the Project. Federal,
state, and local regulations that are directly relevant to the Project are summarized below.
3.3.2.1 Federal
Federal Clean Air Act
The FCAA was enacted in 1970 and amended in 1977 and 1990, and was the first
comprehensive federal law to regulate air emissions from stationary and mobile sources.
Among other things, the law authorizes the U.S. EPA to establish NAAQS. The NAAQS
help to ensure basic health and environmental protection from air pollution. The FCAA
also gives the U.S. EPA authority to limit emissions of air pollutants coming from sources
like chemical plants, utilities, and steel mills.
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U.S. Environmental Protection Agency
The U.S. EPA is the federal agency responsible for enforcing the FCAA of 1970 (as
amended in 1977 and 1990). The U.S. EPA has established NAAQS for O3, CO, NO2, SOx,
PM10, PM2.5, and Pb, as shown in Table 3.3-1. The U.S. EPA also maintains jurisdiction
over emissions sources outside state waters (outer continental shelf) and establishes various
emissions standards for vehicles sold in states other than California (as the CalEPA has
established more stringent emissions standards for vehicles sold in California).
As part of its enforcement responsibilities, the U.S. EPA requires each state that is in non-
attainment for any federal criteria pollutant to prepare and submit a State Implementation
Plan (SIP) that identifies the measures necessary 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. The FCAA allows states to
adopt ambient air quality standards and other regulations, provided they are at least as
stringent as the federal standards.
3.3.2.2 State
California Clean Air Act
The CCAA was enacted in 1988 and requires all areas of the state to achieve and maintain
the CAAQS by the earliest practicable date. The CAAQS includes more stringent standards
than the NAAQS. The CAAQS were established within the CCAA of 1988 for criteria
pollutants and additional standards for sulfates, H2S, vinyl chloride, and visibility reducing
particles (see Table 3.3-1). The CCAA requires each APCD in California to adopt
strategies for achieving the NAAQS and CAAQS by the earliest practicable date. CARB
is responsible establishes emissions standards for vehicles sold and operated within the
state, while the local APCD is responsible for enforcing standards and regulating stationary
sources.
California Air Resources Board
CARB, a part of CalEPA, is responsible for the coordination and administration of both
federal and state air pollution control programs within California. In this capacity, CARB
conducts research, sets CAAQS, compiles emission inventories, develops suggested
control measures, provides oversight of local programs, and prepares the SIP. CARB
establishes emissions standards for motor vehicles sold in California, consumer products
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(such as hair spray, aerosol paints, and barbecue lighter fluid), and various types of
commercial equipment. It also sets fuel specifications to further reduce vehicular
emissions.
In April 2005, CARB issued a guidance document on air quality and land use, “Air Quality
and Land Use Handbook: A Community Health Perspective”, which recommends that
sensitive land uses not be located within 500 feet of a freeway or other “High Traffic
Roadway” and that a site-specific health risk assessment be performed as a way to more
accurately evaluate the risk. “High Traffic Roadways” are defined as urban roadways with
100,000 vehicles per day (vpd) or more, or rural roads with 50,000 or more vpd. In traffic-
related studies, the additional non-cancer health risk attributable to proximity to high-
volume roadways was seen within 1,000 feet and was strongest within 300 feet. California
freeway studies show about a 70 percent drop-off in particulate pollution levels at 500 feet.
The nearest highway or High Traffic Roadway is U.S. 101 located approximately 400 to
800 feet from Project site.
California Global Warming Solutions Act (Assembly Bill 32)
The California State Legislature enacted Assembly Bill (AB) 32, the California Global
Warming Solutions Act of 2006. AB 32 requires that GHGs emitted in California be
reduced to 1990 levels by the year 2020. “Greenhouse gases” as defined under AB 32
include CO2, CH4, NOx, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.
CARB is the state agency charged with monitoring and regulating sources of GHGs. AB
32 states the following:
Global warming poses a serious threat to the economic well-being, public health,
natural resources, and the environment of California. The potential adverse impacts of
global warming include the exacerbation of air quality problems, a reduction in the
quality and supply of water to the state from the Sierra snowpack, a rise in sea levels
resulting in the displacement of thousands of coastal businesses and residences, damage
to marine ecosystems and the natural environment, and an increase in the incidences of
infectious diseases, asthma, and other human health-related problems.
CARB approved the 1990 GHG emissions level of 427 MMT CO2e on December 6, 2007
(CARB 2007). Therefore, emissions generated in California in 2020 are required to be
equal to or less than 427 MMT CO2e.
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Senate Bill 32 and Assembly Bill 197
Senate Bill (SB) 32 and AB 197 were both approved by Governor Jerry Brown on
September 8, 2016 and became effective on January 1, 2017. SB 32 sets into law the targets
for GHG emissions reductions at 40 percent of 1990 levels by 2030, as mandated under
Governor Jerry Brown’s Executive Order B-30-15. AB 197 is paired with SB 32 and is a
measure that increases legislative oversight over the CARB, in order to ensure strategies
to lower emissions favor those most impacted by climate change.
Executive Order S-13-08
Executive Order S-13-08 indicates that “climate change in California during the next
century is expected to shift precipitation patterns, accelerate sea level rise and increase
temperatures, thereby posing a serious threat to California’s economy, to the health and
welfare of its population and to its natural resources.” Pursuant to the requirements in the
order, the 2009 California Climate Adaptation Strategy (California Natural Resources
Agency 2009) was adopted, which is the “ ...first statewide, multi-sector, region-specific,
and information-based climate change adaptation strategy in the United States.” Objectives
include analyzing risks of climate change in California, identifying and exploring strategies
to adapt to climate change, and specifying a direction for future research.
Executive Order B-30-15
Executive Order B-30-15, set into state law by SB 32, establishes a California GHG
reduction target of 40 percent below 1990 levels by 2030. California is on track to meet or
exceed the current target of reducing GHG emissions to 1990 levels by 2020, as established
in AB 32. California's new emissions reduction target of 40 percent below 1990 levels by
2030 will make it possible to reach the ultimate goal of reducing emissions by 80 percent
under 1990 levels by 2050. This is in line with the scientifically established levels needed
in the U.S. to limit global warming below 2 degrees Celsius - the warming threshold at
which scientists say there will likely be major climate disruptions such as super droughts
and rising sea levels. The reduction targets mandated under Executive Order B-30-15 were
set into law under SB 32 in September 2016.
Executive Order B-55-18
On September 10, 2018, Governor Edmund G. Brown Jr. issued Executive Order B-55-18
to establish a new ambitious statewide goal to achieve carbon neutrality as soon as possible,
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but no later than 2045, and achieve and maintain net negative targets of reducing GHG
emissions.
California Air Resources Board: Scoping Plan
On December 11, 2008, CARB adopted the Scoping Plan as directed by AB 32 (CARB
2008). The Scoping Plan identifies actions designed to reduce overall GHG emissions in
California to the levels required by AB 32. Measures applicable to development projects
include those related to energy-efficiency building and appliance standards, the use of
renewable sources for electricity generation, regional transportation targets, and green
building strategies. Relative to transportation, the Scoping Plan includes nine measures or
recommended actions related to reducing vehicle miles traveled (VMT) and vehicle GHGs
through fuel and efficiency measures. These measures would be implemented statewide
rather than on a project-by-project basis.
CARB released the First Update to the Climate Change Scoping Plan in May 2014 to
provide information on the development of measure-specific regulations and to adjust
projections in consideration of the economic recession (CARB 2014). In the update, CARB
estimated the AB 32 Baseline 2020 to be 509 MMT CO2e. The Scoping Plan’s current
estimate of the necessary GHG emission reductions is 78 MMT CO2e (CARB 2014). This
represents an approximately 15.32-percent reduction. CARB is forecasting that this would
be achieved through the following reductions by sector: 25 MMT CO2e for energy,
23 MMT CO2e for transportation, 5 MMT CO2e for high-global warming potential (GWP)
GHGs, and 2 MMT CO2e for waste. The remaining 23 MMT CO2e would be achieved
through Cap-and-Trade Program reductions. This reduction is flexible – if CARB receives
new information and changes the other sectors’ reductions to be less than expected, the
agency can increase the Cap-and-Trade Program reduction (and vice versa).
In response to EO B-30-15 and SB 32, all state agencies with jurisdiction over sources of
GHG emissions were directed to implement measures to achieve reductions of GHG
emissions to meet the 2030 and 2050 targets. CARB was directed to update the Scoping
Plan to reflect the 2030 target, and, and adopted the 2017 Climate Change Scoping Plan:
The Strategy for Achieving California’s 2030 Greenhouse Gas Target on November 30,
2017. The 2030 mid-term target outlined in the Scoping Plan is critical to help frame the
suite of policy measures, regulations, planning efforts, and investments in clean
technologies and infrastructure needed to continue driving down emissions. The Second
Update to the Scoping Plan was approved by CARB on December 14, 2017.
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Senate Bill 375
Passing the Senate on August 30, 2008, SB 375 was signed into law on September 30,
2008. Per SB 375, the transportation sector is the largest contributor of GHG emissions.
SB 375 does the following: (1) requires metropolitan planning organizations to include
sustainable community strategies in their regional transportation plans for reducing GHG
emissions, (2) aligns planning for transportation and housing, and (3) creates specified
incentives for the implementation of the strategies.
Senate Bill 743
SB 743, adopted September 27, 2013, encourages land use and transportation planning
decisions and investments that reduce VMT that contribute to GHG emissions. SB 743
eliminated the measurement of automobile delay, including level of service (LOS), as a
metric for determining traffic impacts. SB 743 required the State Office of Planning and
Research (OPR) to develop revisions to the CEQA Guidelines establishing criteria for
determining the significance of transportation impacts of projects within transit priority
areas that promote the reduction of GHG emissions, the development of multi-modal
transportation networks, and a diversity of land uses. For land use projects, OPR identified
VMT per capita, VMT per employee, and net VMT as new metrics for transportation
analysis. Additional provisions of SB 743 include reforming aesthetics and parking CEQA
analysis for urban infill projects and in transit priority areas. Regulatory changes to the
CEQA Guidelines that implement SB 743 were approved on December 28, 2018. July 1,
2020 is the statewide implementation date and agencies may opt-in use of new metrics
prior to that date. OPR released a December 2018 Technical Advisory that contains
recommendations regarding assessment of VMT, thresholds of significance, and mitigation
measures.
Air Toxics Control Measure for Construction, Grading, Quarrying, and Surface Mining
Operations
Under CARB's NOA ATCM for Construction, Grading, Quarrying, and Surface Mining
Operations, prior to any grading activities at a site identified as having the potential to
contain NOA, the Owner or Operator will be required to comply with the applicable
sections contained in the NOA ATCM. Projects that require grading within an area where
an NOA may be present are required to demonstrate adequate dust control measures with
the SLO County APCD. For example, for projects that require grading of 1 acre or more
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
in serpentine, a geologic evaluation and Asbestos Dust Mitigation Plan must be submitted
to the SLO County APCD.
3.3.2.3 Local
City of San Luis Obispo Climate Action Plan
The City’s Climate Action Plan, adopted by Resolution No. 10388 in 2012, is a strategic
document based on the idea that effective global solutions to climate change will largely
be the result of collective action of local communities and governments. The Climate
Action Plan enables the City to maintain local control of implementing state direction (AB
32 – the California Global Warming Solutions Act) to reduce GHG emissions to 1990
levels by 2020. The adjusted GHG emissions forecast shows that implementation of all
strategies in this plan can achieve a 15 percent reduction from baseline levels by 2020,
which will meet required AB 32 state reduction goals. The plan identifies strategies to
guide the development and implementation of GHG reduction measures in the City and
quantifies the emissions reductions that result from these strategies. The Climate Action
Plan proposes strategies to reduce GHG emissions from community-wide activities and
government operations. Community-wide activities are broken down into six focus areas:
buildings, renewable energy, transportation and land use, water, solid waste, and parks and
open space. Corresponding goals include: energy-efficient buildings, clean and renewable
energy sources, improved transportation options, reduced water consumption, reduced
waste, and maintenance and growth of the urban forest.
The City is currently updating the Climate Action Plan, including an updated GHG
inventory and measures to achieve a net-zero carbon emissions target communitywide. The
updated plan will include strategies that can achieve 40 percent reduction from baseline
levels by 2030, which will meet required SB 32 state reduction goals. In addition, at a City
Council hearing held on September 18, 2018, the City declared its intent to adopt a target
for achieving citywide carbon neutrality by the year 2035. The update to the Climate Action
Plan will identify new measures and policies applicable to development within the City for
reducing carbon emissions from various sources, including energy consumption,
transportation, and organic waste disposal, to achieve this target.
Clean Energy Choice Program
The City is currently developing local amendments to the 2019 California Building Code
(CBC) to encourage all-electric new buildings. When paired with Monterey Bay
Community Power's carbon free electricity supply, all electric new buildings are carbon
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
free and avoid health and safety issues associated with fossil fuels and GHGs. At its
meeting on Tuesday, September 3, 2019, the City Council approved the Clean Energy
Choice Program. The City anticipates the second reading of the ordinance and subsequent
implementation to occur in early 2020. The City joins more than 50 other California
communities currently considering ways to encourage cleaner buildings. Unlike some
cities that are banning natural gas entirely, the proposed Clean Energy Choice Program
will provide options to people who want to develop new buildings with natural gas. New
projects wishing to use natural gas will be required to build more efficient and higher
performing buildings and offset natural gas use by performing retrofits on existing
buildings or by paying an in-lieu fee that will be used for the same purpose.
County of San Luis Obispo Clean Air Plan and CEQA Air Quality Handbook
SLO County APCD adopted the Clean Air Plan in January 1992; the Clean Air Plan was
updated in 1998, and again in 2001. The Clean Air Plan is a comprehensive planning
document designed to reduce emissions from traditional industrial and commercial
sources. The Clean Air Plan also aims to reduce emissions from motor vehicles by
establishing goals and targets for reducing personal vehicle trips and trip lengths, such as
encouraging or promoting multimodal alternatives. The purpose of the Clean Air Plan is to
address the attainment and maintenance of state and federal ambient air quality standards
by following a comprehensive set of emission control measures within the plan.
In 2009, SLO County APCD adopted guidelines for assessment and mitigation of air
quality impacts under CEQA. The CEQA Air Quality Handbook, which was updated in
2012 (SLO County APCD 2012) and subsequently amended in 2017 (SLO County APCD
2017), is an advisory document that provides lead agencies, consultants, and project
applicants with uniform procedures for addressing air quality issues in environmental
documents. The CEQA Air Quality Handbook also includes standard construction and
operational mitigation measures that may be applied to projects that exceed SLO County
APCD thresholds. For instance, SLO County APCD requires inclusion of Best Available
Control Technologies (BACTs) for construction equipment when estimated O3precursor
emissions for the equipment and vehicle fleet are expected to exceed adopted thresholds of
significance and implementation of fugitive dust control measures (watering of the grading
site, vegetation of exposed soils, early roadway paving, construction vehicle speed control,
etc.) for any project with a grading area greater than 4 acres or that are located within 1,000
feet of any sensitive receptor.
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3.3.3 Environmental Impact Analysis
3.3.3.1 Thresholds of Significance
Air Quality CEQA Thresholds
Significance criteria for evaluating impacts on air quality emissions associated with the
Project are based on Appendix G of the CEQA Guidelines. Implementation of the Project
would have a significant impact on air quality and GHG emissions if the Project would:
a) Conflict with or obstruct implementation of the SLO County APCD’s adopted
Clean Air Plan (including providing for growth that is above the rate of growth
contained in the Clean Air Plan);
b) Result in a cumulatively considerable net increase of any criteria pollutant for
which the Project region is in non-attainment under an applicable federal or state
ambient air quality standard;
c) Expose sensitive receptors to substantial pollutant concentrations; or
d) Result in other emissions (such as those leading to odors) adversely affecting a
substantial number of people.
Non-Applicable Threshold(s)
• Threshold (d) (Other emissions affecting a substantial number of people): The
Project would not involve the development of the types of land uses that generate
non-criteria pollutant emissions or odors that would affect a substantial number of
people such as wastewater treatment plants, landfills, composting facilities,
refineries, or chemical plants. Nor would the Project locate sensitive receptors
within proximity of these types of sources. Therefore, the Project would not have a
potential to have an impact related to odors and nuisance emissions and this issue
will not be further discussed.
SLO County APCD Clean Air Plan
As recommended by SLO County APCD, the most appropriate standard for assessing the
significance of potential air quality impacts is the preparation of a consistency analysis
where the project is evaluated against the land use goals, policies, and population
projections contained in the current Clean Air Plan. The rationale for requiring the
preparation of a consistency analysis is to ensure the attainment projections developed by
SLO County APCD are met and maintained. SLO County APCD’s CEQA Air Quality
Handbook recommends evaluation of the following questions:
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
• Are the population projections used in the plan equal to or less than those used in
the most recent Clean Air Plan for the same area;
• Is the rate of increase in vehicle trips and miles traveled less than or equal to the
rate of population growth for the same area; and
• Have all applicable land use and transportation control measures from the most
recent version of the Clean Air Plan been included in the plan to the maximum
extent feasible?
SLO County APCD Significance Criteria (Air Quality and Criteria Air Pollutants)
Significance Criteria for Construction-Related Emissions
Short-term construction emission thresholds for the SLO County APCD (Table 3.3-3), as
stated in SLO County APCD’s CEQA Air Quality Handbook are described below. Due to
the length of the Project’s construction phases, quarterly thresholds are used in this
analysis.
ROG and NOx Emissions
• Daily: For construction projects, the 137 pounds per day (lbs/day) threshold
requires Standard Mitigation Measures;
• Quarterly – Tier 1: For construction projects exceeding the 2.5 tons per quarter
(ton/qtr) threshold, Standard Mitigation Measures and Best Available Control
Technology (BACT) for construction equipment are required. Offsite mitigation
may be required if feasible mitigation measures are not implemented, or if no
mitigation measures are feasible for the project; and
• Quarterly – Tier 2: For construction exceeding the 6.3 ton/qtr threshold, Standard
Mitigation Measures, BACT, implementation of a Construction Activity
Management Plan (CAMP), and offsite mitigation are required.
Diesel Particulate Matter (DPM) Emissions
• Daily: For projects expected to be completed in less than one quarter, exceedance
of the 7 lbs/day threshold requires Standard Mitigation Measures;
• Quarterly – Tier 1: For construction projects lasting more than one quarter,
exceedance of the 0.13 ton/qtr threshold requires Standard Mitigation Measures,
and BACT for construction equipment; and
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
• Quarterly – Tier 2: For construction projects lasting more than one quarter,
exceedance of the 0.32 ton/qtr threshold requires Standard Mitigation Measures,
BACT, implementation of a CAMP, and offsite mitigation.
Fugitive Particulate Matter (PM10), Dust Emissions
• Quarterly: Exceedance of the 2.5 ton/qtr threshold requires Fugitive PM10
Mitigation Measures and may require the implementation of a CAMP.
If construction-related emissions of the Project equal or exceed any of the thresholds stated
above, mitigation of construction activities and implementation of BACT would be
required.
Table 3.3-3. Thresholds of Significance for Construction Operations
Pollutant of Concern Threshold
Tons/Qtr Tier 1 Tons/Qtr Tier 2 lbs/Day
ROG + NOx (combined) 2.5 6.3 137
Diesel Particulate Matter (DPM) 0.13 0.32 7
PM10 - 2.5 -
Source: SLO County APCD 2012a.
Significance Criteria for Operational Emissions
Long-term operational emission thresholds for the County, as stated in SLO County
APCD’s CEQA Air Quality Handbook, have been set by SLO County APCD as follows
(see Table 3.3-4):
Ozone Precursor (ROG + NOx) Emissions
• Projects which emit 25 lbs/day or more of ROG and NOx should be submitted to
SLO County APCD for review. Onsite mitigation is recommended. If feasible
mitigation is incorporated and emissions are still greater than 25 lbs/day, then an
EIR should be prepared.
• Projects which emit 25 tons/year or more of ROG and NOx require the preparation
of an EIR.
Diesel Particulate Matter (DPM) Emissions
• Projects that emit over 1.25 lbs/day of DPM require implementation of onsite
BACT measures.
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Fugitive Particulate Matter (PM10) Dust Emissions
• Projects that emit over 25 lbs/day or 25 tons/year of PM10 require implementation
of permanent dust control measures to mitigate emissions or provide suitable offsite
mitigation approved by SLO County APCD.
Table 3.3-4. Thresholds of Significance for Operational Operations
Pollutant of Concern Threshold
Daily Annual
ROG + NOx (combined) 25 lbs/day 25 tons/year
Diesel Particulate Matter (DPM) 1.25 lbs/day -
PM10 25 lbs/day 25 tons/year
Source: Sa SLO County APCD 2012a.
GHGs and Climate Change CEQA Thresholds
According to Appendix G of the CEQA Guidelines, impacts related to GHG emissions
from the Project would be significant if the Project would:
• Generate GHG emissions, either directly or indirectly, that may have a significant
impact on the environment; and/or
• Conflict with an applicable plan, policy or regulation adopted for the purpose of
reducing the emissions of GHGs.
Significance Criteria for GHGs
The City has not adopted GHG emissions thresholds for use in CEQA documents, but SLO
County APCD has adopted recommended GHG significance thresholds. These thresholds
are based on AB 32 GHG emission reduction goals, which take into consideration the
emission reduction strategies outlined in CARB’s Scoping Plan. The GHG significance
thresholds include one qualitative threshold and two quantitative thresholds options for
evaluation of operational GHG emissions. Lead agencies may select most applicable of the
above thresholds to determine the significance of a project’s GHG emission impact to a
level of certainty based on the type of project.
The qualitative threshold option is based on a consistency analysis in comparison to a
Qualified GHG Reduction Strategy, or equitably similar adopted policies, ordinances and
programs. If a project complies with a Qualified GHG Reduction Strategy that is
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
specifically applicable to the project, then the project would be considered less than
significant. The 2012 Climate Action Plan serves as the City’s Qualified GHG Reduction
Strategy, consistent with SLO County APCD guidance and CEQA Guidelines Section
15183.5(b), which allows for streamlining of the GHG impacts analysis of projects that are
consistent with the Climate Action Plan. This EIR includes an analysis of the Project’s
conformance with the City’s adopted Climate Action Plan. However, the Climate Action
Plan was prepared to comply with the requirements of AB 32 and achieve the goals of the
AB 32 Scoping Plan, which have a horizon year of 2020. The adopted Climate Action Plan
does not reflect the SB 32 targets for GHG emissions reductions at 40 percent of 1990
levels by 2030. Therefore, the City’s Climate Action Plan is not compliant with SB 32 and
cannot be considered a qualified GHG reduction strategy for assessing the significance of
GHG emissions generated by projects with a horizon year post 2020. Therefore, the Project
is also evaluated against reduced quantitative GHG emissions thresholds, as discussed
below.
Under SLO County APCD’s two quantitative significance thresholds, a residential and/or
commercial project is considered to result in a significant impact if annual GHG emissions
exceed a Bright-Line threshold of 1,150 MT CO2e or exceed an efficiency threshold of 4.9
MT CO2e/service population (SP). The Bright-Line numeric threshold of 1,150 MT
CO2e/yr represents an emissions level below which a project’s contribution to global
climate change would be deemed less than “cumulatively considerable.” However,
emissions from projects that exceed the 1,150 MT CO2e/yr Bright-Line Threshold could
still be found less than cumulatively significant if the project as a whole would result in a
GHG efficiency of 4.9 MT CO2e/SP/yr or less. If projects as proposed exceed both
thresholds, they would be required to implement mitigation measures to bring them below
the 1,150 MT CO2e/yr Bright-Line Threshold or within the 4.9 MT CO2e/SP/yr Efficiency
Threshold. If required mitigation could not bring a project below either threshold
requirement, the project would be found cumulatively significant.
However, SLO County APCD’s thresholds and the City’s Climate Action Plan are specific
to AB 32 goals and do not consider the 2030 GHG reduction targets contained in SB 32
that was adopted 2016. The 2017 Climate Change Scoping Plan sets the state on a course
to reduce GHG emissions an additional 40 percent below 1990 levels by 2030 under SB
32. Within the Scoping Plan, CARB recommends a statewide target of no more than 6 MT
CO2e/SP/yr by 2030 (CARB 2017b). However, this statewide target is based on all
emissions sectors in the state, statewide population forecasts, and necessary statewide
reductions, and is not reflective of local conditions. In an attempt to inform new GHG
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
thresholds for land use development projects in compliance with the targets set forth in SB
32, the Association of Environmental Professionals (AEP) in 2016 released a Climate
Change Committee White Paper which developed an example GHG efficiency target of
2.6 MT CO2e/SP/yr by 2030 (AEP 2016).
The current SLO County APCD GHG quantitative thresholds for land use projects would
achieve AB 32 targets but not SB 32 targets. Since the Project’s operational year (2025)
would exceed the AB 32 target year (2020) and given most recent guidance described
above, it is reasonable to apply a reduced threshold to the Project. Therefore, the Project is
also analyzed against the SLO County APCD GHG thresholds reduced by 40 percent to
account for the continued reductions required by 2030 under SB 32. For this comparison,
the bright line threshold was reduced to 690 MT CO2e and the efficiency threshold was
reduced to 2.65 MT of CO2e/SP/yr for the purposes of analysis of Project impacts where
current adopted thresholds do not uphold state law (SB 32) and City goals and policies, as
further discussed below.
At a City Council hearing held on September 18, 2018, the City declared its intent to adopt
a target for achieving citywide net-zero GHG emissions by the year 2035. For the purposes
of this analysis, the Project’s stationary (non-mobile) operational emissions are also
analyzed for compliance with the City’s 2035 net-zero GHG emissions target, as it aligns
with current City objectives and is consistent with and exceeds the GHG emissions targets
established under SB 32 and requirements of Executive Order B-55-18.
3.3.3.2 Impact Assessment Methodology
This analysis addresses both short-term construction impacts and long-term operational
impacts from air pollutant emissions generated by the Project. Potential impacts are
identified, along with potential mitigation measures that could avoid or reduce impacts.
This discussion of air quality and GHG impacts is based on a review of information
contained in the City’s General Plan, the Draft FRSP, the County’s Clean Air Plan, the
City’s Climate Action Plan, and the California Emissions Estimator Model (CalEEMod)
runs completed for the Project (Appendix D). CalEEMod was performed for each phase of
proposed Project implementation, as described in Section 2.6, Project Construction.
Criteria Pollutants
This analysis focuses on the air quality impacts that could occur from criteria air pollutant
emissions associated with the construction and operation of the Project, including impacts
from Project-related traffic volumes. Project-related construction and operational
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
emissions for ROG, NOx, DPM, and PM10 were estimated using CalEEMod Version
2016.3.2 computer model, and then compared to the thresholds of significance defined
above. See Appendix D for CalEEMod worksheet results.
The air quality analysis and CalEEMod estimates for criteria air pollutants follow the
guidelines and methodologies recommended in SLO County APCD’s CEQA Air Quality
Handbook (2012). Construction emissions from heavy-duty diesel exhaust were calculated
using SLO County APCD’s CEQA handbook and typical construction equipment details
provided in Section 2.6.2, Construction Activities. Emissions factors for calculating
emissions from construction equipment, including fugitive dust emissions from ground
disturbance and stockpile activities were based upon default CalEEMod assumptions
supplemented by Project-specific details where reasonable. In accordance with SLO
County APCD recommendations, an overall qualitative analysis was conducted to
determine if emissions resulting from implementation of the Project would be consistent
with the emissions projections in the most recent version of the Clean Air Plan.
Construction Air Quality Emissions
Construction emissions are estimated using CalEEMod for each phase of Project
construction, including excavation and site preparation, building construction, and
architectural coatings as presented in Table 2-7 of Section 2.6.1, Project Construction
Phases. Emission estimates are based on the anticipated types and amount of equipment
that would be used in Project construction, the amount of demolition debris and excavated
soil to be removed, the size and type of new construction, anticipated construction
schedule, and the vehicle trips generated by construction workers (refer to Section 2.6,
Project Construction).
Project construction would temporarily increase diesel emissions and would generate
particulate matter (dust). Construction equipment within the Project site that would
generate ROGs and NOx emissions could include graders, excavators, dump trucks, cranes,
and bulldozers. It is assumed that all construction equipment used would be diesel powered.
The precise construction timeline for the Project depends on the timing of entitlements and
permit processing. For the purposes of studying the reasonable worst-case emissions for
this EIR, construction activity for the Project is assumed to occur over a five-year period
beginning in 2020. See Section 2.6, Project Construction, for details about Project phasing.
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Operational Air Quality Emissions
Operational emissions associated with the Project are estimated using CalEEMod for
mobile source, area, and energy emissions. Mobile emissions would be generated by the
resident, employee, visitor, and material delivery motor vehicle trips to and from the
Project site. These are calculated based on the Project’s Transportation Impact Study (TIS)
trip generation and other default traffic assumptions (see Appendix J). Area source
emissions would be generated by consumer products (e.g., household cleaning products),
architectural coatings, and landscape maintenance equipment.2 Energy source emissions
would be generated by emissions resulting from electricity and natural gas consumption
for space and water heating and powering electrical appliances. The default emissions were
used for area and energy sources with consideration of SLO County APCD rules and
regulations that would be required of the Project related to the Project’s operations. Use-
specific water demands estimated in the Project’s Water Supply Assessment (Appendix K)
were utilized for estimating air and GHG emissions from operational water demands. To
determine if an air quality impact would occur, the increase in emissions was compared
with SLO County APCD’s operational thresholds.
Prior to full buildout of the Project by 2025, it is anticipated that the Lower Area of
Villaggio would be fully occupied and operational starting in 2022, prior to completion the
Upper Terrace of Villaggio and the Madonna Froom Ranch portion of the Specific Plan
area. For the purposes of this analysis, full occupancy of the Specific Plan area is assumed
to occur in 2024-2025, following completion of Madonna Froom Ranch.
GHG and Climate Change
Consistent with CEQA and SLO County APCD’s recommendations, the significance of
the Project’s GHG emissions and resulting global climate change impacts are assessed
against the threshold of the City’s adopted Qualified GHG Reduction Strategy in the City
Climate Action Plan. In addition, as noted above, the Project’s stationary (non-mobile)
operational emissions are also analyzed for compliance with the City’s 2035 net-zero GHG
emissions target, as it aligns with current City objectives and is consistent with and exceeds
the GHG emissions targets established under SB 32 and requirements of Executive Order
B-55-18.
2 SLO County APCD defines “area sources” emissions as non-vehicular emissions sources which include energy use, evaporative
emissions from paints and solvents, fuel combustion by small utility equipment (e.g., lawnmowers, leaf blowers), residential wood
burning, household products, and other small sources (SLO County APCD 2012).
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
In addition, GHG emissions associated with the construction and operation of the Project
were estimated using CalEEMod (Appendix D). The model quantifies direct emissions
from construction and operations (including vehicle use), as well as indirect emissions,
such as GHG emissions from energy use, solid waste disposal, vegetation planting and/or
removal, and water use.
Construction GHG Emissions
GHGs from construction projects must be quantified and amortized over the life of a
project. The amortized construction emissions must be added to the annual average
operational emissions and then compared to the operational thresholds in Section 3.5.1 of
SLO County APCD’s CEQA Air Quality Handbook—Significance Thresholds for Project-
Level Operational Emissions. To amortize the emissions over the life of a project, total
GHG emissions for the construction activities would be divided by the project life (i.e., 50
years for residential projects and 25 years for commercial projects) then added to the annual
operational phase GHG emissions.
The construction GHG analysis considers the Project’s anticipated five-year construction
schedule as well as the likely types and number of construction equipment to be used.
Construction-related GHG emissions are amortized over 25 years per SLO County APCD
methodology outlined in the CEQA Air Quality Handbook. Amortization over a 25-year
period is selected for the Project due to the proposed mix of residential and commercial
uses, as opposed to amortization of a 50-year period for solely residential projects, and
therefore provides a conservative analysis of GHG emissions.
Operational GHG Emissions
The following activities are typically associated with the operation of residential and
commercial uses, as well as senior living communities, that would contribute to the
generation of GHG emissions:
Vehicular trips. Vehicle trips generated by residential, senior living, and commercial uses
within the Project site would result in GHG emissions through combustion of fossil fuels.
Onsite use of natural gas and other fuels. For the purposes of this analysis, it is assumed
that natural gas would be used by the Specific Plan development to heat the residential and
commercial spaces; natural gas would also be utilized for water heating, cooking, laundry,
and power backup. This would result in a direct release of GHGs. Estimated emissions from
the combustion of natural gas and other fuels is based on the number of dwelling units
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3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
(single-family, multi-family, and retirement), commercial space, health care, hotel, and
recreational uses applying the default/typical consumption rates as presented in the
CalEEMod modeling output.
Electricity use. Electricity is generated by a combination of methods, which include
combustion of fossil fuels. Use of electricity for operation of the Project would contribute
to the indirect emissions associated with electricity production. Estimated emissions from
the consumption of electricity are based on the number of dwelling units (single-family,
multi-family, and retirement), commercial sf, health care, hotel, and recreational uses
applying the default/typical consumption rates as presented in the CalEEMod modeling
output.
Water use and wastewater generation. The amount of water used and wastewater generated
by a Project has indirect GHG emissions as a result of the energy used to supply, distribute,
and treat water and wastewater. In addition to the indirect GHG emissions associated with
energy use, wastewater treatment can result in the emission of both CH4 and NOx depending
on the treatment method. Estimated emissions from potable water demand are based on
CalEEMod default emissions factors and use-specific water demands that were calculated in
the Water Supply Assessment prepared for the Project (Appendix K). Estimated emissions
from the generation of wastewater is based on the number of residential and senior
(independent and assisted) dwelling units, commercial space, and water consumption rates
as presented in the CalEEMod modeling output.
Solid waste. Emissions calculated for solid waste reflect the indirect GHG emissions
associate with waste that is disposed of at a landfill. GHG emissions associated with the
decomposition of waste are quantified based on amount of degradable organic carbon
generated by the total residential and senior (independent and assisted) dwelling units,
commercial space, health care, hotel, and recreational uses proposed by the Project.
3.3.3.3 Project Impacts and Mitigation Measures
This section discusses the potential air quality and GHG-related impacts associated with
the construction and operation of the Project. Air quality and GHG emissions impacts
associated with the Project are summarized in Table 3.3-5 below.
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Table 3.3-5. Summary of Project Impacts
Air Quality Impacts Mitigation Measures Residual Significance
AQ-1. The Project would result in potentially
significant construction-related emissions,
including dust and air pollutant emissions.
MM AQ-1
MM AQ-2
MM AQ-3
Less than Significant
with Mitigation
AQ-2. The Project would result in potentially
significant long-term operational emissions.
MM AQ-4 Significant and
Unavoidable
AQ-3. Release of toxic diesel emissions or
naturally occurring asbestos during
construction of the Project could expose
sensitive receptors to emissions-related
health risks.
No Mitigation Required Less than Significant
AQ-4. The Project would be consistent with
the City’s Climate Action Plan, but would
result in potentially significant GHG
emissions during construction and operation
which would be inconsistent with other state
and local goals for reducing GHG emissions.
MM AQ-4
MM AQ-5
MM AQ-6
Significant and
Unavoidable
AQ-5. The Project is potentially inconsistent
with the SLO County APCD’s Clean Air
Plan.
MM AQ-2
MM TRANS-5
MM TRANS-8
MM TRANS-9
MM TRANS-10
Significant and
Unavoidable
Impact AQ-1 The Project would result in potentially significant construction-related
emissions, including dust and air pollutant emissions (Less than
Significant with Mitigation).
Within each Project implementation phase, construction would consist of site preparation,
grading, building construction, and paving. Substantial grading and earthmoving would be
required to shape the site, realign Froom Creek, and raise the elevation of the Lower Area
and Madonna Froom Ranch above the 100-year flood elevation. Project construction would
generate significant construction air pollutant emissions, including fugitive dust (PM10 and
PM2.5) associated with grading and exhaust from heavy construction vehicles. During
building construction, ROGs would be released during the application and drying of paints
and architectural coatings.
Site preparation and grading would involve substantial earthmoving activities and heavy
equipment use. Phase 1 (Installation of Project Infrastructure and Stormwater Management
System) would involve rough grading and earthmoving activities associated with
installation of private roads, public utility connections, LOVR frontage improvements, and
the stormwater management system (including realignment of Froom Creek and
Froom Ranch Specific Plan 3.3-27
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
development of the proposed offsite stormwater detention basin). At the same time, grading
of the Lower Area and Upper Terrace, in anticipation of later development under Phases 2
and 3, as well as rough grading of Madonna Froom Ranch, would occur, as fill from each
phase would be balanced across the site. During this overlapping grading period,
approximately 31,800 cubic yards (cy) of fill materials would be balanced onsite, while
220,000 cy of fill rock material would be imported to the site to raise the Lower Area by 1
foot above the 100-year flood elevation. In addition, the realignment of Froom Creek would
require delivery of approximately 2,300 cy of rock material for bank stabilization and
erosion protection along the creek. The extensive amounts of grading would require large
amounts of use of heavy diesel grading equipment and approximately 15,832 heavy haul
truck trips in order to haul fill and rock material to the site, resulting in large quantities of
NOx, CO, and particulate matter emissions. For purposes of this analysis and consistent
with the Phasing schedule identified in Section 2.6.1, Construction Phasing and
Implementation, peak grading activities are assumed to occur for an approximate eight-
month period from May 2020 to December 2020.
After completion of grading activities for the Lower Area, Phase 2 (Development of
Villaggio Lower Area) would involve installation of private roadway and utility
infrastructure, the emergency access road to Mountainbrook Church, as well as
construction of the Lower Area senior residential community development. following
completion of grading activities within the Upper Terrace Construction of Phase 3,
following completion of grading activities within the Upper Terrace, would involve the
development of residential uses and non-residential ancillary components of the Villaggio
Upper Terrace, as well as the public park within Madonna Froom Ranch. Phase 4
(Development of Madonna Froom Ranch) would involve the development of the
residential and commercial components of Madonna Froom Ranch. See Table 2-7 in
Section 2.6.2, Construction Activities for details on construction phases and approximate
grading amounts.
Construction pollutant emissions, such as NOx and PM10, would be generated through the
use of heavy-duty construction equipment and through vehicle trips generated by
construction workers traveling to and from the Project site. The majority of the Project’s
ROG emissions would be generated from the application of architecture coatings, including
paints, stains, and other finishes that off-gas ROGs during the drying/curing process.
Emissions were calculated based on a typical construction equipment list and default
CalEEMod emission factors. Each construction phase of the Project would last for more
3.3-28 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
than 90 days and would result in overlapping construction phases totaling five years of
construction. Therefore, SLO County APCD quarterly thresholds (rather than daily
thresholds) were used to determine the significance level of construction emissions.
Maximum short-term emission estimates from construction of the Project are provided in
Table 3.3-6. Detailed construction emissions and calculation assumptions are provided in
Appendix D.
Table 3.3-6. Short-term Construction Emissions (Unmitigated)
ROG NOx ROG +
NOx CO SO2 PM10
DPM
(Exhaust
PM2.5)
Peak Daily Emissions
(lbs/day)
180.81 191.01 371.82 109.68 0.27 30.51 7.23
Peak Quarterly
Emissions (tons/qtr) 1
1.09 5.46 8.152 3.16 0.07 0.91 0.21
APCD Daily
Thresholds (lbs/day)
-- -- 137 -- -- -- 7
APCD Quarterly
Thresholds – Tier 1
(tons/qtr)
-- -- 2.5 -- -- 2.5 0.13
Above Threshold? -- -- YES -- -- NO YES
APCD Quarterly
Thresholds – Tier 2
(tons/qtr)
-- -- 6.3 -- -- -- 0.32
Above Threshold? -- -- YES -- -- -- NO
1 tons/qtr calculated based on maximum annual emissions divided by four (i.e., one quarter of a year).
2 tons/qtr for ROG + NOx emissions calculated in CalEEMod.
See Appendix D for CalEEMod worksheets.
Modeled emissions for the Project were found to be above SLO County APCD daily and
Tier 1 and Tier 2 Quarterly thresholds for construction emissions of ROG and NOx, and
above SLO County APCD Daily and Tier 1 Quarterly thresholds for DPM. Therefore,
Project construction emissions are considered potentially significant.
Mitigation Measures
MM AQ-1 A Construction Activity Management Plan (CAMP) shall be included as
part of Project grading and building plans and shall be submitted to SLO
County APCD and to the City for review and approval prior to the start of
construction. The plan shall include but not be limited to the following
elements:
Froom Ranch Specific Plan 3.3-29
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
1. A Dust Control Management Plan that encompasses the following dust
control measures:
• Reduce the amount of disturbed area where possible;
• Water trucks or sprinkler trucks shall be used during
construction to keep all areas of vehicle movement damp enough
to prevent dust from leaving the site and from exceeding the
APCD’s limit of 20 percent opacity for greater than 3 minutes in
any 60-minute period. At a minimum, this would require twice-
daily applications. Increased watering frequency would be
required when wind speeds exceed 15 miles per hour (mph).
Reclaimed water or the onsite water well (non-potable) shall be
used when possible. The contractor or builder shall consider the
use of a SLO County APCD-approved dust suppressant where
feasible to reduce the amount of water used for dust control;
• All dirt stock-pile areas shall be sprayed daily as needed;
• Permanent dust control measures identified in the approved
Project revegetation and landscape plans of any development
within the Specific Plan area should be implemented as soon as
possible following completion of any soil disturbing activities;
• Exposed ground areas that are planned to be reworked at dates
greater than one month after initial grading shall be sown with a
fast germinating native grass seed and watered until vegetation
is established;
• All disturbed soil areas not subject to revegetation shall be
stabilized using approved chemical soil binders, jute netting, or
other methods approved in advance by SLO County APCD;
• All roadways, driveways, sidewalks, etc. to be paved should be
completed as soon as possible. In addition, building pads should
be laid as soon as possible after grading unless seeding or soil
binders are used;
• Vehicle speed for all construction vehicles shall not exceed 15
mph on any unpaved surface at the construction site;
• All trucks hauling dirt, sand, soil, or other loose materials are to
be covered or shall maintain at least 2 feet of freeboard in
accordance with California Vehicle Code Section 23114;
• Designate access points and require all employees,
subconsultants, and others to use them. Install and operate a
“track-out prevention device” where vehicles enter and exit
unpaved roads onto paved streets. The track-out prevention
device can be any device or combination of devices that are
effective at preventing track-out, located at the point of
3.3-30 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
intersection of any unpaved area and a paved road. If utilized,
rumble strips or steel plate devices shall be cleaned periodically.
If paved roadways accumulate tracked-out soils, the track-out
prevention device shall be modified or replaced to prevent track-
out;
• Sweep streets at the end of each day if visible soil material is
carried onto adjacent paved roads. Water sweepers with
reclaimed water should be used where feasible;
• All of these fugitive dust mitigation measures shall be shown on
grading and building plans; and
• The contractor or builder shall designate a person or persons to
monitor the fugitive dust control emissions and enhance the
implementation of the measures as necessary to minimize dust
complaints, reduce visible emissions below 20 percent opacity,
and to prevent transport of dust offsite. Their duties shall include
holiday and weekend periods when work may not be in progress.
The name and telephone number of such persons shall be
provided to SLO County APCD Compliance Division prior to the
start of any grading, earthwork or demolition.
2. Implementation of the following BACT for diesel-fueled construction
equipment. The BACT measures shall include:
• Use of at least Tier 3 off-road equipment and 2010 on-road
compliant engines;
• Repowering equipment with the cleanest engines available; and
• Installing California Verified Diesel Emission Control
Strategies.
3. Implementation of the following standard air quality measures to
minimize diesel emissions:
• Maintain all construction equipment in proper tune according
to manufacturer’s specifications;
• Fuel all off-road and portable diesel-powered equipment with
CARB-certified motor vehicle diesel fuel (non-taxed version
suitable for use off-road).
• Use on-road heavy-duty trucks that meet the CARB’s 2007 or
cleaner certification standard for on-road heavy-duty diesel
engines and comply with the State On-Road Regulation;
• Construction or trucking companies with fleets that do not have
engines in their fleet that meet the engine standards identified in
the above two measures (e.g. captive or NOx exempt area fleets)
may be eligible by proving alternative compliance;
Froom Ranch Specific Plan 3.3-31
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
• On- and off-road diesel equipment shall not be allowed to idle
for more than five minutes. Signs shall be posted in the
designated queuing areas to remind drivers and operators of the
five-minute idling limit;
• Diesel idling within 1,000 feet of sensitive receptors is not
permitted;
• Staging and queing areas shall not be loated within 1,000 feet
of sensitive receptors;
• Electrify equipment when feasible;
• Substitute gasoline-powered in place of diesel-powered
equipment, where feasible; and,
• Use alternatively fueled construction equipment onsite where
feasible, such as compressed natural gas (CNG), liquefied
natural gas (LNG), propane or biodiesel.
4. Tabulation of on- and off-road construction equipment (age, horse-
power, and miles and/or hours of operation);
5. Schedule construction truck trips during non-peak hours (as determined
by the Public Works Director) to reduce peak hour emissions; and
6. Limit the length of the construction work-day period to 8 hours max.
Plan Requirements and Timing. The CAMP shall be submitted to SLO
County APCD and to the City for review and approval prior to issuance of
grading and construction permits and recordation of the final VTM. All
required fugitive dust and emissions control measures shall be noted on all
grading and building plans and all construction activities shall adhere to
measures throughout all grading, hauling, and construction activities. The
contractor or builder shall provide the City Community Development
Director and SLO County APCD with the name and contact information for
an assigned onsite dust and emissions control monitor(s) who has the
responsibility to: a) assure all dust control requirements are complied with
including those covering weekends and holidays, b) order increased
watering as necessary to prevent transport of dust offsite, and c) attend the
pre-construction meeting. The dust monitor shall be designated prior to
grading permit issuance for each Project phase. The dust control
components apply from the beginning of any grading or construction
throughout all development activities until occupancy is issued and
landscaping is successfully installed.
3.3-32 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Monitoring. City staff shall ensure measures are depicted on the CAMP
and all submitted grading and construction plans for each Project phase. The
Applicant shall be responsible for compliance during construction
activities, including holidays or weekends when work may not be in
progress. City grading and building inspectors shall spot check and ensure
compliance onsite.
MM AQ-2 To reduce ROG and NOx levels during the architectural coating phase, low
or no Volatile Organic Compound (VOC)-emission paint shall be used with
levels of 50 grams per liter (g/L) or less (Odorless, Zero VOC Paint). The
schedule for architectural coatings application shall be extended, limiting
the daily coating activity to a level determined acceptable by SLO County
APCD.
Plan Requirements and Timing. The Applicant shall verify the measures
through written documentation submitted to the City and SLO County
APCD for review and approval. Measures shall be indicated on all building
and construction plans and submitted to SLO County APCD and to the City
for review and approval prior to issuance of building permits and
recordation of the final VTM.
Monitoring. City shall verify measures with the Applicant and SLO County
APCD. City staff shall ensure measures are depicted on all building and
construction plans. City building inspectors shall perform site inspections
to ensure compliance.
MM AQ-3 An offsite mitigation strategy shall be developed and agreed upon by the
Applicant, City, and SLO County APCD at least three months prior to the
issuance of grading permits. Offsite mitigation strategies may be in the form
of cash payment, circulation improvements above the Project’s fair share,
or funding for ongoing transit improvements. The Applicant shall provide
appropriate funding necessary to offset the Project’s residual construction-
related ROG+NOx emissions beyond SLO County APCD’s daily threshold
at least two months prior to the start of construction to help facilitate
emission offsets that are as real-time as possible. Cash payment of offsite
mitigation fees shall be calculated based on the most current ARB-approved
Carl Moyer Guidelines at the time of commencement of each Project phase.
Offsite mitigation strategies shall include one or more of the following:
Froom Ranch Specific Plan 3.3-33
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
• Develop or improve park-and-ride lots;
• Fund a program to buy and scrap older, higher emission passenger and
heavy-duty vehicles;
• Retrofit or repower heavy-duty construction equipment, or on-road
vehicles;
• Subsidize vanpool programs;
• Contribute to funding of new bike lanes;
• Replace/repower San Luis Obispo Regional Transit Authority
(SLORTA) transit buses;
• Purchase Verified Diesel Emission Control Strategies (VDECS) for
transit buses or construction fleets; and
• Fund expansion of existing SLORTA transit services.
Plan Requirements and Timing. The Applicant shall prepare and submit
the offsite mitigation strategy to SLO County APCD for review and to the
City for approval at least three months prior to the issuance of grading
permits for Phase 1 construction. The Applicant shall provide any necessary
funding to SLO County APCD at least two months prior to the start of
construction.
Monitoring. SLO County APCD and City staff shall ensure offsite
mitigation measures are appropriate. If the Applicant elects to pay
mitigation fees, SLO County APCD shall verify the receipt of funding to
the City. If the Applicant elects to provide improvements, proposed
improvements shall be approved by the City and SLO County APCD prior
to implementation. City and SLO County APCD staff shall monitor
proposed improvements to ensure compliance.
Residual Impact
The Project would be required to implement MM AQ-1 through -3 which are consistent with
standards mitigation measures for construction equipment, application of BACT, and
implementation of a CAMP. MM AQ-1 and -2 consist of quantifiable emissions reduction
measures which would reduce construction-related air quality impacts from ROG, NOx, and
DPM emissions below SLO County APCD Tier 2 quarterly thresholds. Despite
implementation of these measures, ROG and NOx emission would continue to exceed SLO
County APCD daily and Tier 1 quarterly thresholds (see Table 3.3-7). As such, the Project
is required to implement MM AQ-3, requiring that the Project Applicant fund or implement
3.3-34 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
a range of improvements intended to mitigate Project emissions offsite, or pay the SLO
County APCD’s standard mitigation fee. Though the mitigation strategies and associated
emissions reductions outlined in MM AQ-3 cannot be quantified for the Project, SLO County
APCD deems the measures effective in reducing Project emissions to a level of
insignificance. Residual impacts would be less than significant.
Table 3.3-7. Short-Term Construction Emissions (Mitigated)
ROG NOx ROG +
NOx CO SO2 PM10
DPM
(Exhaust
PM2.5)
Peak Daily Emissions
(lbs/day)
59.96 120.79 180.75 129.09 0.27 17.74 4.35
Peak Quarterly
Emissions (tons/qtr)1
0.38 3.43 5.002 3.71 <0.01 0.51 0.13
APCD Daily
Thresholds (lbs/day)
-- -- 137 -- -- -- 7
APCD Quarterly
Thresholds – Tier 1
(tons/qtr)
-- -- 2.5 2.5 0.13
Above Threshold? -- -- YES -- -- NO NO
APCD Quarterly
Thresholds – Tier 2
(tons/qtr)
-- -- 6.3 -- -- -- 0.32
Above Threshold? -- -- NO -- -- NO NO
1 tons/qtr calculated based on maximum annual emissions divided by four (i.e., one quarter of a year).
2 tons/qtr for ROG + NOx emissions calculated in CalEEMod.
See Appendix D for CalEEMod worksheets.
Impact AQ-2 The Project would result in potentially significant long-term
operational emissions (Significant and Unavoidable).
Operational emissions from the Project include those generated by vehicle trips (mobile
emissions), the use of natural gas (energy emissions), use of consumer products and
appliances, and the use of landscaping maintenance equipment (area source emissions).
Maximum daily operational emissions of the Project were estimated using CalEEMod.
While the Project would not exceed annual emissions thresholds, projected maximum daily
emissions for the Project would be above the established APCD daily thresholds for
operational emissions of ROG + NOx (see Table 3.3-8). Project operational emissions are
therefore considered potentially significant.
Froom Ranch Specific Plan 3.3-35
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-8. Long-Term Operational Emissions (Unmitigated)
ROG NOx ROG +
NOx CO SO2 PM10 DPM
Total Daily Operational Emissions
Area (lbs/day) 24.27 0.60 24.87 51.96 <0.01 0.28 0.28
Energy (lbs/day) 0.38 3.35 3.73 2.16 0.02 0.26 0.26
Mobile (lbs/day) 6.70 23.85 29.80 67.42 0.21 20.47 0.17
Total (lbs/day) 31.35 27.80 58.4 121.54 0.23 21.01 0.72
Threshold (lbs/day) - - 25 550 - 25 1.25
Above Threshold? - - YES NO - NO NO
Total Annual Operational Emissions
Area (tons/year) 4.40 0.10 4.50 8.57 <0.01 0.05 0.05
Energy (tons/year) 0.07 0.61 0.68 0.39 <0.01 0.05 0.05
Mobile (tons/year) 1.05 3.99 5.04 11.06 0.03 3.35 0.03
Total (tons/year) 5.52 4.70 10.22 20.02 0.03 3.45 0.13
Threshold (tons/year) - - 25 - - 25 -
Above Threshold? - - NO - - NO
Note: Values in this table are rounded for reporting purposes.
See Appendix D for CalEEMod worksheets.
Mitigation Measures
MM AQ-4 Consistent with standard mitigation measures set forth by SLO County
APCD, Projects generating more than 50 lbs/day of combined ROG + NOx
shall implement all feasible measures within Table 3-5 of the Air Quality
Handbook. The following mitigation measures shall apply to the Project
(Table 3.3-9).
Requirements and Timing. The Applicant shall include the mitigation
measures in Table 3-5 of the 2012 SLO County APCD CEQA Air Quality
Handbook (as amended by the 2017 Clarification Memorandum), as
indicated in the column “How the Project Will Include This Measure” in
Table 3.3-9, above. All feasible standard mitigation measures shall be
included in the FRSP prior to approval of the final FRSP and these measures
shall also be included on the final VTM prior to recordation. City staff shall
ensure the above measures are incorporated into the FRSP, final VTM, and
building plans prior to permit issuance.
3.3-36 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-9. Mitigation Measures from APCD CEQA Air Quality Handbook
Measure
#
Land
Use1
Measure
Type2 Mitigation Measure Pollutant
Reduced3 Phase How the Project Will
Include This Measure
1 R SD Install gas or electric
fireplace in place of
U.S. EPA-certified Tier
2 residential wood
burning appliances.
GHG, O, P D The Project does not
propose any wood
burning appliances.
2 C, R SD, T Design and build high-
density, compact
development within the
urban core or URL to
encourage alternative
transportation (walk,
bike, bus, etc.).
GHG, O, P D The Project would
include residential and
commercial development
within the URL and
would provide access to
transit and non-vehicular
transportation; however,
the Project site lies on the
southern edge of the City
and is not located within
an urban core area. To
encourage alternative
transportation, the Project
shall provide a range of
transit options and
incentives to employees
and residents of
Villaggio, and
commercial and
residential developments
within Madonna Froom.
3 C, I,
R
SD, T Provide a pedestrian-
friendly and
interconnected
streetscape with good
access to/from the
development for
pedestrians, bicyclists,
and transit users to
make alternative
transportation more
convenient,
comfortable and safe
(may include:
appropriate
signalization and
signage; safe routes to
school; linking cul-de-
sacs and dead ends;
orienting buildings
towards streets with
automobile parking in
the rear, etc.).
GHG, O, P D The Draft FRSP includes
guidelines for
incorporating pedestrian
walkways, outdoor
seating, and landscape
areas where possible.
Public commercial
collector roads shall be
connected to adjacent
development to allow
pedestrian and bicyclist
access, and public
pedestrian trails will
connect public roads to
the existing trail system
in the Irish Hills Natural
Reserve.
Froom Ranch Specific Plan 3.3-37
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-9. Mitigation Measures from APCD CEQA Air Quality Handbook
(Continued)
Measure
#
Land
Use1
Measure
Type2 Mitigation Measure Pollutant
Reduced3 Phase How the Project Will
Include This Measure
4 C, I,
R
SD, T Provide shade over 50
% of parking spaces to
reduce evaporative
emissions from parked
vehicles.
O D Shade trees are to be
provided as part of the
Project per City
requirement. The
Applicant shall amend the
Draft FRSP to require
shade trees are provided
so a minimum of 50 % of
proposed parking spaces
are shaded.
5 C, I,
R
SD, T Reduce fugitive dust
from roads and parking
areas with the use of
paving or other
materials.
P D No unpaved roads,
driveways, or parking
areas are proposed as part
of the Project.
6 C, I,
R
SD, T Implement driveway
design standards (e.g.,
speed bumps, curved
driveway) for self-
enforcement of reduced
speed limits on
unpaved driveways.
P D The City has a
requirement that the
design speeds in local and
collector roads not exceed
25 mph. Bulb-outs, traffic
circles, chicanes, and
other features are also
included in the Project.
There are no unpaved
roads or driveways in the
development.
7 C, I,
R
SD, T Use an APCD-
approved suppressant
on private unpaved
roads leading to the
site, unpaved driveways
and parking areas,
applied at a rate and
frequency that ensure
compliance with APCD
Rule 401: Visible
Emissions, and ensures
offsite nuisance impacts
do not occur.
P O No unpaved roads,
driveways, or parking
areas are proposed as part
of the Project.
8 C, I,
R
SD, T Incorporate traffic
calming modifications
to Project roads to
reduce vehicle speeds
and increase pedestrian
and bicycle usage and
safety.
GHG, O, P D City has a requirement
that the design speeds in
local and collector roads
not exceed 25 mph. Bulb-
outs, traffic circles,
chicanes, and other
features are included.
There are no unpaved
3.3-38 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-9. Mitigation Measures from APCD CEQA Air Quality Handbook
(Continued)
Measure
#
Land
Use1
Measure
Type2 Mitigation Measure Pollutant
Reduced3 Phase How the Project Will
Include This Measure
roads or driveways in the
development.
9 C, I,
R
SD, T Work with SLOCOG to
create, improve, or
expand a nearby ‘Park-
and-Ride’ lot with car
parking and bike
lockers in proportion to
the size of the Project.
GHG, O, P D The Project Applicant
shall work with SLOCOG
to improve or expand
nearby ‘Park-and- Ride’
lots within the City, such
as the ‘Park–and-Ride’ lot
located at the Calle
Joaquin hotel
development.
10 C SD, T Implement onsite
circulation design
elements in parking lots
to reduce vehicle
queuing and improve
the pedestrian
environment.
GHG, O, P D The Applicant shall
amend the Draft FRSP to
require onsite circulation
design in parking lots to
reduce vehicle queueing
and improve the
pedestrian environment.
11 C, I SD, T Provide employee
lockers and showers to
promote bicycle and
pedestrian use. One
shower and five lockers
for every 25 employees
is recommended.
GHG, O, P D The Applicant shall
amend the Draft FRSP to
require workplaces
provide employee lockers
and showers consistent
with this measure and the
City Zoning Regulations.
12 C, I,
R
SD, T Increase bicycle
accessibility and safety
in the vicinity of the
Project; for example:
provide interconnected
bicycle routes/lanes or
construction of
bikeways.
GHG, O, P D The Project includes a
number of improvements
to pedestrian and bicyclist
environment. MM
TRANS-5, -8, -9, and -10
requiring installation of
protected bike lanes along
Tank Farm Road and
LOVR and would ensure
consistency with this
measure.
13 C, I,
R
SD, T Exceed Cal Green
standards by 25 % for
providing onsite bicycle
parking: both short-
term racks and long-
term lockers, or a
locked room with
standard racks and
access limited to
bicyclists only.
GHG, O, P D The Applicant shall
amend the Draft FRSP to
require onsite bicycle
parking consistency with
this measure and the City
Zoning Regulations.
Froom Ranch Specific Plan 3.3-39
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-9. Mitigation Measures from APCD CEQA Air Quality Handbook
(Continued)
Measure
#
Land
Use1
Measure
Type2 Mitigation Measure Pollutant
Reduced3 Phase How the Project Will
Include This Measure
14 C, I,
R
SD, T Develop recreational
facility (e.g., parks,
trails, gym, pool, etc.)
within 0.25 mile from
site.
GHG, O, P D The Project includes
development of various
facilities to meet the
recreational needs of the
residents of Villaggio.
The Project also includes
the development of a 2.9-
acre neighborhood park
within the Project site.
15 C, I,
R
SD, T If the project is located
on an established transit
route, provide
improved public transit
amenities (e.g., covered
transit turnouts, direct
pedestrian access,
bicycle racks, covered
bench, smart signage,
route information
displays, lighting, etc.).
GHG, O, P D The Project site is located
along LOVR and
residential development is
less than 0.25 mile from
bus stops for Transit Line
2A and the Laguna
Tripper. The Project
would include installation
of a new transit stop for
these routes to improve
public transit amenities
and access.
16 C, I,
R
T Provide bicycle-share
program for
development.
GHG, O, P O The Applicant shall work
with Public Works to
amend the Draft FRSP to
include a hub/node of the
City’s bicycle share
network at the Project
site. The
infrastructure/operation of
the site shall be the
responsibility of the
developer.
17 C, I T Require 15 % of fleet
vehicles to be zero
emission vehicles.
DPM, GHG,
O
O The Project does not
propose any commercial
or industrial use types
which would utilize fleet
vehicles; however, future
uses may include the use
of shuttles (i.e.
hotel/airport shuttle). The
Applicant shall amend the
Draft FRSP to require the
use of zero emission
vehicles for 15 percent of
all proposed shuttle or
group-transport vehicles.
3.3-40 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-9. Mitigation Measures from APCD CEQA Air Quality Handbook
(Continued)
Measure
#
Land
Use1
Measure
Type2 Mitigation Measure Pollutant
Reduced3 Phase How the Project Will
Include This Measure
18 C, I T Project includes
alternative fuel fleet
vehicle(s).
DPM, GHG,
O
O The Project does not
propose any commercial
or industrial use types
which would utilize fleet
vehicles; however, future
uses may include the use
of shuttles (i.e.
hotel/airport shuttle). The
Applicant shall amend the
Draft FRSP to require the
use of alternative fuel
shuttle or group-transport
vehicles.
19 C, I,
R
T Provide neighborhood
EV/car-share program
for the development.
GHG, O O The Applicant shall
amend the Draft FRSP to
require provision of
neighborhood electric
vehicles/car-share
programs for the
development, consistent
with MM AQ-5.
20 C, I,
R
T Provide dedicated
parking for carpools,
vanpools, and/or high-
efficiency vehicles to
meet or exceed Cal
Green Tier 2.
GHG, O, P O The Applicant shall
amend the Draft FRSP to
require the provision of
dedicated parking for
carpools, vanpools, and
high-efficiency vehicles
in exceedance of Cal
Green Tier 2 standards.
21 C, I T Provide vanpool,
shuttle, mini bus
service (alternative
fueled preferred).
GHG, O, P O The FRSP shall be
amended to include
measures for encouraging
and incentivizing
residents and employees
of the proposed
development participate
in the San Luis Obispo
Regional Rideshare
program. The Applicant
or developer of the FRSP
shall also provide car-
share opportunities and
promote carpool,
vanpool, and EV vehicles.
See also MM AQ-6.
22 C, I,
R
T Work with SLO
Regional Rideshare to
educate occupants with
alternative
GHG, O, P O The FRSP shall be
amended to include
measures for encouraging
Froom Ranch Specific Plan 3.3-41
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-9. Mitigation Measures from APCD CEQA Air Quality Handbook
(Continued)
Measure
#
Land
Use1
Measure
Type2 Mitigation Measure Pollutant
Reduced3 Phase How the Project Will
Include This Measure
transportation and
smart commute
information (e.g.,
transportation board,
electronic kiosk, new
hire packets, web
portal, newsletters,
social media, etc.).
and incentivizing
residents and employees
of the proposed
development participate
in the San Luis Obispo
Regional Rideshare
program. See also MM
AQ-6.
23 C, I T Provide child care
facility onsite. GHG, O, P O The Applicant shall
amend the Draft FRSP to
include policies for the
provision of child care
facilities onsite.
24 C, I T Implement programs to
reduce employee
vehicle miles traveled
(e.g. incentives, SLO
Regional Rideshare trip
reduction program,
vanpools, onsite
employee housing,
alternative schedules
(e.g., 9–80, 4–10,
telecommuting, satellite
work sites etc.).
GHG, O, P O The Project is required to
implement mitigation
programs and strategies to
reduce employee VMT
and mobile-source
emissions. Refer to MM
TRANS-5, -8, -9, -10,
MM AQ-6.
25 C, I T Provide a lunchtime
shuttle to reduce single
occupant vehicle trips
and/or coordinate
regular food truck
visits.
GHG, O, P O The Applicant shall
amend the Draft FRSP to
include policies for
provision of lunchtime
shuttles or to encourage
foot truck visits to the
Project site to reduce trips
associated with onsite
commercial businesses, as
feasible.
26 C T Provide delivery
service in clean fueled
vehicles.
GHG, O, P O The Applicant shall
amend the Draft FRSP to
require delivery-based
commercial uses that may
be developed to utilize
clean fueled vehicles, as
feasible.
27 C T At community event
centers (i.e.,
amphitheaters, theaters,
and stadiums), provide
free valet bicycle
parking.
GHG, O, P O The Project does not
propose development of
any community event
centers or other
communal gathering
areas.
3.3-42 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-9. Mitigation Measures from APCD CEQA Air Quality Handbook
(Continued)
Measure
#
Land
Use1
Measure
Type2 Mitigation Measure Pollutant
Reduced3 Phase How the Project Will
Include This Measure
28 C, I T Implement a “No
Idling” vehicle program
which includes signage,
enforcement, etc.
DPM, GHG,
O
O The Applicant shall
amend the Draft FRSP to
include programs and
policies requiring
implementation of a “No
Idling” vehicle program
for commercial
development which shall
include standards for
signage and enforcement.
29 R T Provide free-access
telework terminals
and/or wi-fi access in
multi-family projects.
GHG, O, P O The Applicant shall
amend the Draft FRSP to
include programs and
policies requiring
provision of free-access
telework terminals and/or
wi-fi access in multi-
family development.
30 C, I T Meet or exceed Cal
Green Tier 2 standards
for providing EV
charging infrastructure.
GHG, O, P D The FSRP includes
Program 4.7.2f, which
states that individual
garages are to be “electric
vehicle-ready” and shared
parking areas for
apartments shall
incorporate EV charging
stations. In addition,
compliance with City
Zoning Regulations
regarding EV parking
spaces shall be required.
31 C, I T Install 1 or more level 2
or better EV charging
stations.
GHG, O, P D The Draft FRSP includes
Program 4.7.2f, which
states that individual
garages are to be “electric
vehicle-ready” and shared
parking areas for
apartments shall
incorporate EV charging
stations. In addition,
compliance with City
Zoning Regulations
regarding EV parking
spaces shall be required.
32 C, I,
R
EE Meet or exceed Cal
Green Tier 1 standards
for building energy
efficiency.
GHG, O D The Applicant shall
amend the Draft FRSP to
include programs and
policies for ensuring new
Froom Ranch Specific Plan 3.3-43
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-9. Mitigation Measures from APCD CEQA Air Quality Handbook
(Continued)
Measure
#
Land
Use1
Measure
Type2 Mitigation Measure Pollutant
Reduced3 Phase How the Project Will
Include This Measure
development, at a
minimum, meets Cal
Green Tier 2 standards
for building efficiency.
33 C, I,
R
EE Meet or exceed Cal
Green Tier 2 standards
for building energy
efficiency.
GHG, O D The Applicant shall
amend the Draft FRSP to
include programs and
policies for ensuring new
development, at a
minimum, meets Cal
Green Tier 2 standards
for building efficiency.
34 C, I,
R
EE Meet or exceed Cal
Green Tier 2 standards
for utilizing recycled
content materials.
GHG D The Applicant shall
amend the Draft FRSP
Program 4.7.4a to require,
at a minimum, use of
recycled content materials
consistent with Cal Green
Tier 2 standards.
35 C, I,
R
EE Meet or exceed Cal
Green Tier 2 standards
for reducing cement use
in concrete mix as
allowed by local
ordinance and
conditions.
GHG D The Applicant shall
amend the Draft FRSP to
include a policy for
ensuring construction of
the Project, at a
minimum, meets Cal
Green Tier 2 standards
for reducing cement use
in concrete mix. Recipe
for cement mix shall be
verified by the City prior
to Project construction
and subject to inspection
by City permit
compliance staff.
36 C, I,
R
EE All built-in appliances
shall be Energy Star
certified or equivalent.
GHG D The Draft FRSP includes
Program 4.7.3a, which
requires that all new
residential units shall
incorporate high-
efficiency Energy Star
compliant appliances.
37 C, I,
R
EE Utilize onsite
renewable energy
systems (e.g., solar,
wind, geothermal,
biomass and/or bio-gas)
to offset at least 10 %
of energy use.
GHG D The Project is required to
comply with MM AQ-5,
requiring the Draft FRSP
be amended to include
measures necessary to
reduce Project operational
3.3-44 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-9. Mitigation Measures from APCD CEQA Air Quality Handbook
(Continued)
Measure
#
Land
Use1
Measure
Type2 Mitigation Measure Pollutant
Reduced3 Phase How the Project Will
Include This Measure
stationary-source
emissions, including
utilization of 100 %
carbon-free energy.
38 C, I,
R
EE Meet or exceed Cal
Green Tier 2 standards
for the use of
greywater, rainwater or
recycled water.
GHG D The Applicant shall
amend the Draft FRSP to
include programs or
policies requiring the use
of greywater, rainwater,
or recycled water by an
amount which, at a
minimum, meets Cal
Green Tier 2 standards.
39 C, I,
R
EE Provide and require the
use of battery powered
or electric landscape
maintenance equipment
for new development.
GHG, O D The Applicant shall
amend the Draft FRSP to
include programs or
policies requiring the use
of battery powered or
electric landscape
maintenance equipment.
40 C, I,
R
EE Meet or exceed Cal
Green Tier 2 standards
for using shading, trees,
plants, cool roofs, etc.
to reduce “heat island”
effect.
GHG D The Applicant shall
amend the Draft FRSP to
include programs or
policies requiring the use
of shading, trees, plants,
cool roofs, and other
measures to reduce “heat
island” effect, at a
minimum, meets Cal
Green Tier 2 standards.
41 C, I,
R
EE Design roof trusses to
handle dead weight
loads of standard solar-
heated water and
photovoltaic panels.
GHG, O D The Applicant shall
amend the Draft FRSP to
include programs and
policies requiring the
design of roof trusses to
handle dead weight loads
of standard solar-heated
water and photovoltaic
panels.
EV – Electric Vehicle
SLOCOG - San Luis Obispo Council of Governments
Froom Ranch Specific Plan 3.3-45
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Monitoring. City staff shall ensure measures are listed on final plans
submitted for review and approval by the City. City staff shall work with
the Applicant to ensure that these strategies are implemented. The City shall
conduct periodic site visits to ensure compliance, in consultation with the
SLO County APCD.
Residual Impact
For unmitigated projects that result in emissions of 50 lbs/day or more of combined ROG
and NOx, SLO County APCD CEQA Air Quality Handbook recommends that all feasible
standard mitigation measures be implemented as part of the Project to ensure that impacts
would be less than significant, based on a list included as Table 3-5 in that document. The
list covers a large range of activities and would reduce impacts either through site design
or increasing the energy efficiency of the Project, but focuses primarily on reducing
mobile-source emissions through implementing transportation strategies to reduce VMT.
In many cases, adherence to the Project design guidelines and other required mitigation
identified in this EIR would implement many of these measures.
Mitigation Measure AQ-2 summarizes the list of appropriate mitigation measures, and
indicates which of these are to be incorporated by the Applicant in accordance with the
2012 APCD CEQA Air Quality Handbook (as amended by the 2017 Clarification
Memorandum). Many of these measures would be incorporated as policies of the FRSP for
which future development would be required to implement and would manifest as site
design measures that would reduce area source emissions. Measures identified in MM AQ-
2 emphasize transportation strategies to reduce VMT and associated mobile-source NOx
emissions. Incorporation of this mix of measures would be feasible for the Project, and
would substantially reduce operational ROG and NOx emissions. However, it is noted that
many measures listed in MM AQ-2 do not contain quantifiable air quality emissions
reductions for programs such as the FRSP. While implementation of these measures can
feasibly reduce ROG and NOx, the Project’s estimated emissions after implementation of
these measures cannot reasonably be quantified, and long-term operational residual
impacts are conservatively considered significant and unavoidable due to potential
continued exceedance of maximum daily emissions thresholds.
Impact AQ-3 Project development could result in the release of toxic diesel emissions
or naturally occurring asbestos which could expose sensitive receptors
to emissions-related health risks (Less than Significant).
3.3-46 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Toxic Diesel Emissions
The Project would generate DPM emissions from construction activities. DPM is listed as
a TAC by the CARB. CARB identifies high-volume freeways and roads (highways, urban
roads carrying 100,000 vpd, and rural roads carrying 50,000 vpd), dry cleaners, and large
gasoline stations as potential sources of TACs. SLO County APCD has a threshold for
construction and operational DPM emissions, but not specifically for mobile-source DPMs
for human health effects. The potential for TACs to have an effect on sensitive receptors
would occur if the Project would generate TACs in quantities that may have an adverse
effect on sensitive receptors.
SLO County APCD defines sensitive uses or receptors as people that have an increased
sensitivity to air pollution or environmental contaminants, which include schools, parks
and playgrounds, day care centers, nursing homes, hospitals, and residential dwelling units
(SLO County APCD 2012). The proposed development area in the Upper Terrace area of
the site is located as close as 325 feet away and would be accessed from the Mountainbrook
Church facility to the south. Mountainbrook Church does not provide day care or long-
term child care facilities that may expose children under the age of 16 to extended periods
of DPMs during construction. Further, guests of the hotels along Calle Joaquin are not
considered sensitive receptors to air pollutants, as these guests would not reside in these
hotels for extended periods of time. Thus, the nearest sensitive receptor to the Project site
is the Pacific Beach High School located approximately 0.27 mile to the northeast, which
would be substantially removed and separated from the site by urban development.
Therefore, Project construction would not significantly endanger the health of existing
nearby sensitive receptors to air emissions.
Project construction would generate DPM emissions due to operation of heavy construction
equipment. For purposes of this analysis, it is assumed that Project phasing would allow
the Lower Area of Villaggio to be occupied as early as 2022. Occupancy would precede
later construction phases of the Upper Terrace and Madonna Froom Ranch. While mass
grading of the site would be complete by 2022, fine grading and vertical construction of
the Upper Terrace and Madonna Froom Ranch would continue between 2022 and 2025,
which would generate emissions from trucks and construction equipment. Independent
living senior residences, the Villaggio Health Care Administration building, and senior
assisted living facilities occupied in 2022 would be considered sensitive receptors to air
emissions, including TACs and DPMs from Project construction. Grading, onsite transport
of cut material between the Upper Terrace and Madonna Froom Ranch areas, and import
Froom Ranch Specific Plan 3.3-47
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
of offsite fill to the Madonna Froom Ranch Area would have the potential to generate DPM
emissions from heavy construction equipment and heavy haul trucks (15,832 haul truck
trips).
To protect future residents in the Lower Area from construction emissions of Phase 3 and
Phase 4 (see Section 2.0, Project Description), the Project would strategically schedule
grading of the Upper Terrace (Phase 3) to occur at the same time as grading activities
associated with Phase 1 and 2. All major grading and earthmoving, including balancing
soils within the Project site, would occur prior to occupancy of any units within the Specific
Plan area. Once occupancy begins, the Project would reroute construction trips to the Upper
Terrace, including any heavy haul or materials delivery trips, along Calle Joaquin to the
Mountainbrook Church driveway and parking lot instead of through the local roads
constructed to serve the Project. This circulation approach would move potential sources
of DPM emissions offsite and away from sensitive receptors residing onsite within the
Villaggio Lower Area once it is constructed. This proposed construction phasing would
therefore reduce potential for exposure of sensitive elderly populations to the most
intensive construction activities and DPM emissions associated with development under
the Project.
Naturally Occurring Asbestos
The Project would result in excavation and grading of serpentine soils in the Upper Terrace,
which may release NOA into the air. The Applicant-prepared geological reports indicate
that asbestos-containing serpentine rock is present beneath topsoil in the Upper Terrace
(Appendix G). Since the Project site lies within an area with the potential to contain NOA
per the SLO County APCD NOA map, compliance with the NOA ATCM would be
required. The NOA ATCM requires submittal of a geologic evaluation determining
whether serpentine rock is present on a project site, and if so, to what extent (less or more
than 1 acre). Depending on the results of the geologic evaluation, the Project would be
required to file an exemption request form (if no serpentine is present), a Mini Dust Control
Measure Plan (if less than 1 acre of serpentine is present), or an Asbestos Dust Control
Measure Plan (if more than 1 acre of serpentine is present). Presuming the Project would
disturb more than 1 acre of serpentine, the Project would be required to submit a geologic
evaluation and Asbestos Dust Control Measure Plan to SLO County APCD for approval.
The Project would comprise residential and commercial uses, which are considered uses
that would not generate substantial amounts of TACs and would not pose a significant risk
to sensitive receptors in the Project vicinity. The Project site is not located adjacent to any
3.3-48 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
existing industrial uses (e.g., construction material companies, machine shops, construction
vehicle staging areas) that may generate additional diesel particulates through the idling of
large diesel equipment or construction vehicles. Additionally, according to the 2005
CARB’s Air Quality and Land Use Handbook, a buffer of 500 feet between residences and
a major freeway, and more than 50 feet from a typical gasoline station, should be
maintained. U.S. 101 is located approximately 2,330 feet to the south of the Project site,
and no gasoline stations are located in the immediate (50 feet or less) vicinity of the Project
site. Therefore, the Project is not expected to expose sensitive receptors to substantial levels
of TACs following completion of Project construction.
There are no existing sensitive receptors on the Project site or vicinity that would be
significantly exposed to Project construction emissions and future sensitive receptors
would be protected from exposure to significant construction emissions through Project
phasing. Proposed areas of development within the Specific Plan area are also not located
adjacent (i.e., within 500 feet) to a freeway producing significant DPMs or a gasoline
station (i.e., 50 feet). Though the Project site overlies potentially NOA in serpentine areas
underlying the Upper Terrace, SLO County APCD standards require a geologic evaluation
and an Asbestos Dust Control Measure Plan for approval prior to grading. Therefore,
impacts to sensitive receptors due to air emission health risks would be less than
significant.
Impact AQ-4 The Project would be consistent with the City’s Climate Action Plan,
but would result in potentially significant GHG emissions during
construction and operation (Less than Significant with Mitigation).
The Project would generate GHG emissions during construction, including heavy
equipment, and operation, including energy and vehicle use. Analysis of environmental
impacts from GHG emission considers both quantified and qualified analysis herein.
Construction GHG Emissions
Construction activities for the Project are assumed to occur over a period of approximately
five years for the purposes of this analysis. Based on CalEEMod estimates, construction
activities for the Project would generate an estimated 7,684.95 MT of CO2e (see Table 3.3-
10). Amortized over a 25-year period (consistent with APCD methodology), construction
of the Project would generate approximately 307.40 MT of CO2e per year.
Froom Ranch Specific Plan 3.3-49
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Table 3.3-10. Estimated Construction GHG Emissions (Unmitigated)
Year Annual Emissions MT CO2e
2020 2,733.52
2021 1,444.27
2022 896.58
2023 1,691.60
2024 918.98
Total 7,684.95
Amortized over 25 years 307.40
Operational GHG Emissions
Operational GHG emissions would be generated from area, energy use, solid waste, water
use, and transportation. Total operational emissions would be approximately 5,773.50 MT
CO2e/yr (see Table 3.3-11). Combined with construction emissions amortized over a 25-
year period (307.40 MT CO2e), total GHG emissions for the Project would be
approximately 6,080.90 MT CO2e/yr. Based on a new resident population of 1,231, the
Project is estimated to result in 4.9 MT CO2e/SP/yr.
Table 3.3-11. Estimated Operational GHG Emissions (Unmitigated)
Emission Source Annual Emissions MT CO2e
Area 14.35
Energy Use 2,235.08
Mobile 3,128.70
Water Use 253.18
Solid Waste 142.19
Total 5,773.50
Amortized Construction Emissions 307.40
Total Project GHG Emissions 6,080.90
Project Population (Residents) 1,231
Per Capita Emissions 4.9
The City’s Climate Action Plan is designed as a Qualified GHG Reduction Strategy,
consistent with CEQA Guidelines Section 15183.5(b). The Project’s consistency with the
City’s Climate Action Plan goals, actions, and strategies is described below:
• Buildings Goal: Reduce energy-related emissions by promoting greater energy
efficiency at the point of final use in buildings.
3.3-50 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
o The Project is consistent with the buildings actions and strategies by its
inclusion of goals, policies, and programs in Chapter 4, Design Guidelines, of
the Draft FRSP for promoting greater energy efficiency, inclusion of alternative
energy systems, use of energy-efficient types of lighting, and incorporation of
high-efficiency Energy Star compliant appliances.
• Renewable Energy Goal: Use cleaner and renewable energy sources.
o The Project is consistent with the renewable energy actions and strategies by its
inclusion of goals, policies, and programs in Chapter 4, Design Guidelines, of
the Draft FRSP for inclusion of alternative energy systems in development over
5,000 sf in size.
• Transportation and Land Use Goal: Improve transportation options.
o The Project is consistent with the transportation and land use elements and
strategies within the Climate Action Plan with development of pedestrian and
bicycle facilities along the public street system, dedicated pedestrian pathways,
extension of Class II bike lanes along LOVR, and installation of a transit stop
at the Project site entrance along LOVR. At full buildout of the Project, the
homes and businesses in Madonna Froom Ranch and Villaggio would be
interconnected to the rest of the City through a dense street pattern, sidewalks,
local and regional bikeways and nearby transit.
• Water Goal: Reduce and reuse water consumed by the community.
o The Project is consistent with the water actions and strategies by its inclusion
of policies and programs oriented towards reducing average daily potable
water; and its inclusion of progressive stormwater treatment and management
improvements through bioretention swales, runoff treatment and filtration,
permeable paving, and other integrated treatment detention/retention systems.
Outdoor landscaping irrigation demand for the Project site, including irrigation
needed to establish or maintain vegetation in the proposed stormwater detention
basin and realigned Froom Creek corridor, will be met entirely with non-potable
recycled water.
• Solid Waste Goal: Prevent, reduce, reuse, and recycle solid waste to minimize the
amount of waste being sent to the landfill.
Froom Ranch Specific Plan 3.3-51
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
o The Project is consistent with the solid waste actions and strategies by being
compliant with the City’s proactive waste management practices that reduce
waste-related GHG emissions.
• Parks and Open Space Goal: Maintain natural areas and plant trees and green
spaces.
o The Project is consistent with the parks and open space actions and strategies
by its inclusion of 59.0 acres of onsite open space in accordance with General
Plan LUE Policy 8.1.6, which includes a 2.9-acre neighborhood park that is
within 0.25 mile of any residential unit and the realigned Froom Creek corridor.
• Government Operations Goal: Reduce GHG emissions from government
operations to 1990 levels using a mix of strategies, including: conservation, clean
energy, efficiency upgrades, recycling, and alternative transportation incentives for
employee commute.
o The Project is consistent with the government operations actions and strategies
by the inclusions discussed above.
All applicable actions and measures identified in the City’s Climate Action Plan must be
incorporated as binding and enforceable components of the Project for it to be found
consistent with the Climate Action Plan. Based on initial analysis of Project consistency
above, the Project would be consistent with the goals of the Climate Action Plan.
However, as described above under the GHGs and Climate Change CEQA Thresholds
discussion under Section 3.3.3.1, the City’s Climate Action Plan is specific to the goals of
AB 32 and does not consider, nor is in compliance with, the 2030 GHG reduction targets
mandated under SB 32. Therefore, the Project is also analyzed against the SLO County
APCD GHG thresholds, reduced by 40 percent to align with SB 32, and CARB and AEP
guidance on SB 32 compliance. Compared to SB 32-compliant thresholds for land
development, a Bright Line Threshold of 690 MT CO2e, or an efficiency threshold of 2.65
MT of CO2e/SP/yr, the Project’s estimated 6,080.9 MT CO2e total and 4.9 MT CO2e/SP/yr
emissions are considered inconsistent with the basic goals, objectives, and emissions
reduction strategies of the state’s adopted GHG laws. The Project is also considered
inconsistent with the City’s current goal for achieving citywide net-zero carbon emissions
by the year 2035, which reflects the City’s intent to achieve the emissions and carbon
reduction requirements of SB 32 and Executive Order B-55-18. Project emissions are
therefore considered potentially significant due to inconsistency with adopted state and
local goals and regulations for reducing GHG emissions.
3.3-52 Froom Ranch Specific Plan
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
Mitigation Measures
MM AQ-4 shall apply.
MM AQ-5 The Applicant shall revise the Draft FRSP to include measures necessary
to reduce Project operational stationary-source GHG emissions to achieve
net zero emissions, consistent with the City’s 2035 net-zero GHG emissions
target. These measures shall include Best Available Mitigation strategies
for reducing operational emissions, including but not limited to the
following:
• Electrical power for the entirety of Project operations including but not
limited to illumination, heating, cooling, and ventilation shall be
provided by alternative or carbon-free energy sources according to the
following priority: 1) on-grid power with 100-percent renewable or
carbon-free source (a planned product of Monterey Bay Community
Power available to the City in 2020), or 2) a combination of grid power
and on site renewable generation to achieve annual zero net electrical
energy usage, or 3) purchase of carbon offsets of any portion of power
not from renewable or carbon-free sources. As a first priority, carbon-
free sourced energy shall be purchased from Monterey Bay Community
Power.
• For new buildings, onsite solar photovoltaic systems shall be required,
and retrofitted buildings shall be encouraged to install onsite solar
photovoltaic systems to offset energy demand, regardless of building
size.
• All proposed commercial and health care facilities shall exceed the
minimum standards of Title 24, Part 11 (Cal Green) by adopting all or
some elements of Cal Green Tier 1 and 2 voluntary elective measures
to increase energy efficiency in new buildings, remodels and additions.
These measures shall prioritize upgrading lighting (e.g., using light-
emitting diode [LED] lights), heating and cooling systems, appliances,
equipment and control systems to be more energy efficient.
Requirements and Timing. The Applicant shall include the above measure
in the Final FRSP prior to approval and shall include the above measure on
the final VTM prior to recordation. Plans submitted for building permits
Froom Ranch Specific Plan 3.3-53
Draft EIR
3.3 AIR QUALITY AND GREENHOUSE GAS EMISSIONS
shall incorporate Best Management Strategies, and for the selected Best
Management Strategies, the Applicant shall work with City and SLO
County APCD staff to calculate estimated stationary-source emissions to
ensure achievement of net-zero stationary source operational emissions for
the Project. City and SLO County APCD staff shall ensure the above
measures are incorporated into the FRSP, final VTM, and building plans
prior to permit issuance.
Monitoring. City staff shall ensure measures are listed on final plans
submitted for review and approval by the City. City and SLO County APCD
staff shall work with the Applicant to ensure that these strategies are
implemented. The City shall verify compliance in consultation with the
SLO County APCD.
MM AQ-6 The Applicant shall revise the FRSP to include measures necessary to
reduce the Project’s operational, mobile-source emissions, and VMT to the
maximum extent feasible, including, but not limited to the following:
• Rideshare and Employee Ridership Programs: The FRSP shall be
amended to include measures for encouraging and incentivizing
residents and employees of the proposed development participate in the
San Luis Obispo Regional Rideshare program.
• Senior Shuttle Service: Villaggio shall provide clean fuel shuttle
services or coordinate with existing shuttle services such as Dial-A-Ride
and the Senior Go! Shuttle to provide curb-to-curb shuttle service for
residents of the Villaggio Life Community Plan.
• All Electric Small Vehicles: The FRSP shall require all personal small
vehicles (e.g., golf carts) be 100 percent electric powered.
• Car Share: Provide car-sharing opportunities within the Villaggio Life
Community Plan and Madonna Froom Ranch areas.
• Promote Carpools, Vanpools, and Electric Vehicle (EV) Vehicles:
Provide dedicated parking for carpools, vanpools, and high-efficiency
vehicles in exceedance of Cal Green Tier 2 standards.
• Offsite EV Improvements: Work with SLO County APCD to expand or
fund the expansion of EV charging stations throughout the City.
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Requirements and Timing. The Applicant shall include all feasible Best
Management Strategies as part of the final FRSP and final VTM. For the
selected Best Management Strategies, the Applicant shall work with City
and SLO County APCD staff to calculate estimated mobile-source
emissions to ensure emissions are reduced to the maximum extent feasible.
City and SLO County APCD staff shall ensure the above measures are
incorporated into the FRSP and final VTM prior to recordation.
Monitoring. City staff shall ensure measures are listed on the final VTM
submitted for review and approval by the City. City and SLO County APCD
staff shall work with the Applicant to ensure that these strategies are
implemented. The City shall verify compliance in consultation with the
SLO County APCD.
Residual Impact
Implementation of MM AQ-4 and -5 would ensure stationary-source operational emissions
of the Project are reduced to 0 MT CO2e/yr, consistent with the City’s intent to achieve
carbon neutrality by 2035, consistent with the purpose and intent of SB 32 to further reduce
statewide GHG emissions, and consistent with Executive Order B-55-18 requiring
attainment of statewide carbon neutrality by 2045. Similarly, MM AQ-4 and -6 would
reduce Project mobile-source emissions to the maximum extent feasible for the proposed
development. However, given the reduction in emissions from the combination of onsite
and offsite mitigation strategies cannot be directly quantified, implementation of these
mitigation would generally demonstrate compliance with adopted state and local policies
for reducing GHG emissions, but potential remains for mobile-source GHG emissions to
result in inconsistencies with established state and local GHG reduction strategies.
Required mitigation would ensure the Project achieves compliance with adopted
regulations and Citywide objectives and stationary-source operational emissions are
reduced to 0 MT CO2e/yr. Nevertheless, impacts would be significant and unavoidable due
to continued potential for exceedance of GHG emissions thresholds as a result of Project
mobile-source emissions.
Impact AQ-5 The Project is potentially inconsistent with the SLO County APCD’s
2001 Clean Air Plan (Significant and Unavoidable).
Consistency analysis with local and regional plans, such as the Clean Air Plan, is required
under CEQA. Consistency with the Clean Air Plan means that stationary and vehicle
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emissions associated with the Project are accounted for in the Clean Air Plan’s growth
assumptions.
According to the County APCD’s guidelines, a project may result in significant air quality
impacts if it is inconsistent with the assumptions in the SLO County APCD Clean Air Plan.
Consistency with the SLO County APCD Clean Air Plan is evaluated based on three
criteria:
1) Are the population projections used in the plan or project equal to or less than
those used in the most recent Clean Air Plan for the same area?
The Project would include 174 multi-family units, 404 independent and assisted
senior housing units, 51 beds for memory care and skilled nursing, and up to
100,000 sf of mixed commercial uses. This development would increase the City’s
population by approximately 1,231 people. The Clean Air Plan’s population
estimate for the City is 48,499 by 2015, and 305,854 for the County by 2015 (SLO
County APCD 2001). According to 2018 estimates by the California State
Department of Finance, the City population estimate is 46,548 and the County
population estimate is 280,101 (California Department of Finance 2018). The
City’s General Plan population estimates are just marginally under the Clean Air
Plan’s projected population estimates. The increase of approximately 1,231 persons
by the Project is within the population projections under the Clean Air Plan.
The City’s LUE Policy 8.1.5 indicates the specific plan for the area including the
Project site should provide a variety of housing types and affordability levels, with
performance standards stating a minimum of 200 dwelling units, and maximum of
350 dwelling units. This is inconsistent with the land uses and intensities proposed
by the Project, which proposes a total of 174 multi-family units and 404
independent and assisted senior housing units. This is above the maximum range
of units due to the inclusion of high-density and senior housing. The LUE
objectives are intended to ensure that the Project site is developed primarily with a
compact mixed-use project and includes provisions for onsite and offsite open
space/resource protection. The Project is consistent with the population projections
anticipated by the LUE (see Section 3.11, Population and Housing). However, as
indicated in the LUCE Update EIR, population estimates cannot be directly
compared as the Clean Air Plan only projects population estimates until 2015. In
addition, as described in Impact AQ-2 above, the Project would result in significant
and unavoidable operational air quality impacts generated by area, energy, and
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mobile emissions; therefore, the Project is potentially inconsistent with the Clean
Air Plan.
2) Is the rate of increase in vehicle trips and miles traveled less than or equal to the
rate of population growth for the same area?
The population growth from the Project would exceed the Clean Air Plan
projections. As described in Section 3.13, Transportation and Traffic, the City’s
model forecast for the Project is 46,894 daily VMT, an increase of approximately
3 percent within the City sphere of influence and 0.4 percent within the County.
The VMT generated per household for the Project is forecasted at 69 daily VMT
per household. Although the Project would have a VMT below the regional
average, the VMT per household for the Project is forecasted to be approximately
28 percent higher than the average for the City’s sphere of influence. The rate of
increase in vehicle trips and miles traveled would exceed the Clean Air Plan
projections for the Project site; therefore, the Project would be potentially
inconsistent with the Clean Air Plan.
3) Have all applicable land use and Transportation Control Measures (TCMs) and
strategies from the Clean Air Plan been included in the plan or project to the
maximum extent feasible?
The transportation goal of the Clean Air Plan is to reduce the growth of vehicle
trips and VMT to the rate of population growth within the County. TCMs are
controls that help reduce emissions resulting from motor vehicles, by reducing
vehicle use and facilitating the use of alternative transportation options. There are
a total of nine TCMs located in the Clean Air Plan which include the following:
• T-1B Campus Trip Reduction Program
• T-1C Voluntary Commute Options Program
• T-2A Local Transit Systems Improvements
• T-2B Regional Public Transit Improvements
• T-3 Bicycling and Bikeway Enhancements
• T-4 Park–and-Ride Lots
• T-5 Motor Vehicle Inspection and Control Programs
• T-6 Traffic Flow Improvements, and
• T-8 Teleworking, Teleconferencing and Telelearning.
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T-1B and T-5 are not applicable to the Project as the Project does not include a
college campus or smog check program. T-1C and T-8 are applicable to the
commercial uses of the Project site. The Project will include one bus stop along
LOVR fronting the site with associated transit service, which will be consistent
with T-2A and T-2B after Project buildout; however, during early phases of Project
development, transit services may not be fully in place (see Section 3.13,
Transportation and Traffic, for further analysis of this issue). T-3 is included in the
Project and supports T-1C. T-6 is also included in the Project.
Land use strategies in the Clean Air Plan include planning compact communities, providing
for mixed land use, balancing jobs and housing, circulation management, and
communication, coordination and monitoring. Each of the five land use strategies are
applicable to and would be implemented by the Project.
The Project could hinder the County’s ability to maintain attainment of the state O3
standard, because the emissions reductions projected in the Clean Air Plan may not be met.
The anticipated population growth and increase in vehicle trips is potentially inconsistent
with the Clean Air Plan; therefore, impacts are considered potentially significant.
Mitigation Measures
MM AQ-2 shall apply.
MM TRANS-5 shall apply.
MM TRANS-8 shall apply.
MM TRANS-9 shall apply.
MM TRANS-10 shall apply.
Residual Impact
In accordance with the 2012 APCD CEQA Air Quality Handbook and 2017 Clarification
Memo, all feasible mitigation measures must be incorporated into the Project, which
emphasize transportation strategies for reducing Project operational VMT. Implementation
of MM TRANS-5, -8, -9, and -10 would ensure facilities serving pedestrians and bicycles
in Project vicinity would be provided prior to occupancy of the first unit of Villaggio’s
Lower Area, which would result in consistency with SLO County APCD’s Clean Air Plan
Goal T-2A. However, as described above, the Project is not fully consistent with overall
land use planning principles contained in the Clean Air Plan due to continued exceedance
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of population growth, vehicle trip, and VMT projections for the region. Therefore, residual
impacts would be significant and unavoidable.
Cumulative Impacts
Air Quality Emissions
The Project, in combination with any approved, pending, and proposed development within
the City, would further contribute to the increase in development and associated generation
of air quality-related emissions. The SCCAB is currently in state non-attainment for PM10
and O3, for which NOx and ROGs are a precursor. As the Project would result in significant
and unavoidable impacts associated with long-term operational emissions, particularly for
NOx and ROGs, the Project would generate air quality emissions for criteria pollutants
within an air basin that is under state non-attainment; therefore, the Project would
contribute cumulatively and considerably to air quality emissions throughout the City and
region.
Further, as analyzed in the LUCE Update EIR, full buildout under the LUCE would not be
consistent with the 2001 Clean Air Plan. Cumulative impacts related to this increase in air-
quality emissions resulting from the Project would therefore be cumulatively considerable
and significant and unavoidable.
GHG Emissions
The Project, in combination with any approved, pending, and proposed development
presented in Table 3.0-1 of Section 3.0.3, Cumulative Impact Analysis, would further
contribute to the increase the generation of GHG emissions. Analysis of GHG emissions
and climate change are cumulative in nature because impacts are caused by cumulative
global emissions and accumulation of GHGs in the atmosphere. Additionally, climate
change impacts related to GHG emissions do not necessarily occur in the same area as the
Project is located. As indicated in Impact AQ-4, the Project’s construction and operational
stationary-source emissions would be reduced to as close to 0 MT CO2e/yr as feasible with
implementation of MM AQ-4 through MM AQ-6. Implementation of these measures
would demonstrate consistency with the City and statewide objectives for reducing GHG
emissions; however, mobile-source emissions continue to have potential to result in
exceedance of established GHG emissions thresholds and state and local GHG reduction
strategies due to inability to ensure associated emissions are quantifiably reduced.
Therefore, the Project’s contribution to cumulative levels of GHGs would be cumulatively
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considerable and cumulative impacts from GHG emissions and climate change would be
significant and unavoidable.
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