HomeMy WebLinkAboutAvila Ranch DEIR Public Comment received 1-18-17 (Air Pollution Control District)RECEIVED
CITY OF SAN LUIS OBISPO
JAN 18 2017
COMMUNITY DEVELOPMENT
From: Ingrid Schumann <
Date: January 18, 2017 at 3:36:52 PM PST
To:
Cc: Melissa Guise < , Rubi Rajbanshi <
Subject: Avila Ranch Development Plan
Hello: I have attached the signed electronic version of the above referenced comment letter to meet
the project deadline. Your hard copy, along with any applicable attachments, will be sent to you US
mail. If you have any questions or comments, please do not hesitate to call our office. Thank -you.
Best, Ingrid
Ingrid Schumann
Air Pollution Control District
slocleanair.ore
Ingrid Schumann
Air Pollution Control District
3433 Roberto Court
San Luis Obispo CA 93401
slocleanair.org
SLOCOUNTY
January 18, 2017
Air Pollution Control District
San Luis Obispo County
John Rickenbach
City of San Luis Obispo
919 Palm St.
San Luis Obispo, CA 93401-3218
Subject: Avila Ranch Development Plan
Dear Mr. Rickenbach:
Thank you for including the San Luis Obispo County Air Pollution Control District (APCD) in
the environmental review process. We have completed our review of the Avila Ranch
Development Plan. The project applicant proposes the adoption of a development plan
and related action to permit a mix of residential uses (68.23 acres), neighborhood
commercial (3.34 acres), open space/park uses (71.30 acres) and associated roadways
(7.03 acres). The proposed project would result in construction of approximately 720
residential units and 15,000 square feet of leasable neighborhood commercial space
concentrated in the eastern portion of the project site.
The following are APCD comments that are pertinent to this project.
GENERAL COMMENTS
As a commenting agency in the California Environmental Quality Act (CEQA) review process
for a project, the APCD assesses air pollution impacts from both the construction and
operational phases of a project, with separate significant thresholds for each. Please
addressihe action items contained in this letter that are highlighted,.,by bold and
underlined text.
Construction Emission
On Page 3.3-25 the statement is made:
"APCD recommended conditions also include the implementation of a Construction
Activity Management Plan (CAMP), would minimize construction -related air quality
impacts and would reduce both ROG and NOx emissions and DPM emissions below the
APCD quarterly thresholds, making impacts significant and unavoidable."
If the measures implemented as part of a CAMP reduce ROG + NOx or DPM to levels below
the APCD thresholds, then the project would be considered less th n significant. As
pointed out in the CEQA handbook page 2-7 under the section on the CAMP, emissions can
be lowered by adjusting schedules, scheduling construction truck trips and limiting the
length of the construction work -day.
805 781.5912 805 781 1002 - slocleanair org 3433 Roberto Court, San Luis Obispo, CA 93401
Avila Ranch Development Plan
January 17, 2017
Page 2 of 4
Page 3.3-25 and Page 3.3-28
The Construction Activity Management Plan should be submitted to the APCD for review and
approval, not just review. APCD recarnmends the text in the DE I_ Rb_emodified _to.refl._ect this
chance.
Page 3.3-26
Under the Dust Control Management Plan bullet #2, APCD recommends adding the following
language to the mitigation measure.
Since water use is a concern, due to drouP-ht_condition5.the contractor or builder shall
consider the use f a nAP—CD-av u t smpamsant wb-qreJgA5Jb1e to r du the amount
ofvynter used for dus control.
Page 3.3-27
The construction emissions as outlined in Table 3.3-7, will exceed the 2.5 ton/qrt threshold of
ROG+NOx and the 0.13 tons/qtr threshold for DPM. When these quarterly thresholds are exceeded,
APCD recommends Best Available Control Technology (BACT) be implemented. MM AQ -1 a (2) page
3.3-27 lists proposed BACT measures for the project, but does not include the following measure:
use of Tier 3 and TierA-off--road equipment and 2010 on -road compliant engines APCD
recommends i mea5ure b added to thelist
Page 3.3-29
MMA AQ -1 b addresses architectural coating activities. APCD recomrnen_d�L In addition to using
low VOC paints th_e .projec _proponent n i er extending coating applicatigna by 1i iti g the
daft coating act vitieL to reduce daily and quarterly emialions
Page 3.3-30
Under the Residual Impact the following statement is made:
'The projected construction emissions for both ROG and NOx emissions and DPM emission after
implementation of mitigation were found to be above the established APCD Tier 1 Quarterly
thresholds, therefore residual impacts are significant and unavoidable. "
If the project proponent implements all recommended mitigation measures, offsite mitigation (as
proposed in MM—A01-c1 and uses Tier 3 and Fier 4 canstruction_equipment to reduce, DPM
onsite to below the threshold then the APCD would consider the erect impacts to be
signiff4ant but mWeable.
+Q,perational Phase Emission
As outline in the CEQA Handbook, APCD has two thresholds (25 lbs/day and 25 tons/yr.) for
operational phase criteria pollutants (ROG, NOx, PM 10). The CEQA analysis for operational phase
emissions should include both; this was not done in the DEIR. APCQ staff recommend thath
summary table 'be updated to inciude annual operational phase emissions and compare them
to the £ A _ thresholds.
Avila Ranch Development Plan
January 17, 2017
Page 3of4
Page 3.3-32
MMAQ-2b states:
"Consistent with standard mitigation measures set forth by the APCD, projects generating more
than 50 lbs./day of combined ROG + NOx or PM,o shall implement all feasible measures with
Table 3-5 of the Air Quality Handbook. The following mitigation measure shall apply to the
project."
The table that follows this statement, Table 3.3-9, is entitled "potentially appropriate Mitigation
Measures from APCD CEQA Air Quality Handbook ". If theesg-measures are going to be intarpQs-ated
into the prroigct._as indicated in the DEIR. ACD recommends the words " potentiall
pro rn ia4' be removed from the title.
Page 3.3-38
Under Requirement and Timing the following statement is made;
"The Applicant shall include the mitigation measure in table 3.3-10 above"
The table above this section, which lists the mitigation measures is 3.3-9 not 3.3-1-0. This
refer_ence_sho_uld be corrected.
Page 3.3-39
Under Residual Impact the following statement is made:
"Therefore, long term operational residual impacts are significant and unavoidable."
Pursuant to the CEQA Handbook (Table 3-4), if a project's operational phase emissions for criteria
pollutants exceeds 50 lbs./day, all feasible mitigation measures should be incorporated into the
project. Depending on the type of project, off site mitigation may be required. This project will
exceed the 25 Ib/day threshold for (ROG +NOx and PM10) but not the 25 tons/yr. Therefore; since
the project is located within the urban reserve line; incorporates the land use and transportation
control measures and strategies outlined in the Clean Air Plan; and incorporates a list of applicable
mitigation measures, APC[3_would, consi h-e-art impArrtts_sign ficant bum m izaWe!
Pages 3.3-39 and 3.3-40
Under the Air Toxic section, with regards to the construction DPM, APCD staff agree that utilization
of clean Tier 3 and Tier 4 construction equipment should be implemented to reduce diesel
emissions onstie from the project. gPCD recommends, as ,part of the construction mitigation. a
measure begdc� d� quire Tier 3 and Tier 4 -equipment to reduce the DPM to below the
threshold of 0.13 tonslgrt Compliance with this measure should also be demonatnitedinAft
CAMP It should be noted that due to the toxic -nature of DPM emissions must be mitfizated
on site.
Page 3.3-41
Under the GHG analysis, the construction emissions were amortized over a 25 -year period. It should
be noted (CEQA Handbook, page 2-2), a project life of 50 years, not 25 years, should be used for
residential projects. This will not significantly lower the annual GHG emissions from the project;
therefore, no further action is required.
Avila Ranch Development Plan
January 17, 2017
Page 4of4
GHG Pursuant to the CEQA Handbook, an environmental document that relies on a greenhouse gas
reduction plan for an impact analysis, must identify those requirements specified in the plan that
apply to the project. If those requirements are not otherwise binding and enforceable, they should
be incorporated as mitigation measures applicable to the project. It was not clear in the DEIR which
measures would be binding and enforceable; therefore, AP.CD recommends measures that are
not binding be called out specifically as mitigation measures.
Page 3.3-45
Regarding consistency with the Clean Air Plan, since the population projections in the Clean Air Plan
end in 2015, APCD feels it is more appropriate to focus on the consistency with the Transportation
and Land Use strategies in the Clean Air Plan. As stated above, this project is located within the
urban reserve line; incorporates the land use and transportation control measures and strategies
outlined in the Clean Air Plan; and incorporates a list of applicable mitigation measures for
operational phase emissions. Therefore, the 61![D would consider the Qroject impacts
significant but mitl$able.
Again, thank you for the opportunity to comment on this proposal. If you have any questions or
comments, feel free to contact me at (805) 781-5912.
Sincerely,
Melissa Guise
Air Quality Specialist
MAG/ihs
HAP LAN\CEQA\Project Review\3000\3900\3919-213919-2.docx