Soilworks products are the industry’s top standard due to our insistence on creating high performance soil stabilization and dust control products that stand up to rigorous testing – both in the lab and in the field. Our commitment to quality and performance has led to our involvement and testing in hundreds of real-world situations. The following library of reports, presentations, specifications, approvals and other similar documents provide you, our customer, the transparency and dependable assurance that is expected from Soilworks.
CEQA
Air Quality Handbook
A GUIDE FOR ASSESSING THE AIR QUALITY IMPACTS
FOR PROJECTS SUBJECT TO CEQA REVIEW
December 2009
3433 Roberto Court, San Luis Obispo, CA 93401 • (805) 781-5912 • FAX: (805) 781-1002 info@slocleanair.org ❖ www.slocleanair.org
Table of Contents
List of Acronyms…………………………………………………………………………………………………………………….. iii
Glossary………………………………………………………………………………………………………………………………… iv
1 Projects Requiring Air Quality Review and Analysis…………………………………………………………… 1-2
1.1 Role of the SLO County APCD…………………………………………………………………………… 1-2
1.2 Projects Subject to Air Quality Analysis………………………………………………………………… 1-2
1.3 Project Information Needed for SLO County APCD Review……………………………………… 1-3
1.4 Operational Screening Criteria for Project Impacts…………………………………………………… 1-3
1.5 Preparing the Air Quality Analysis Section for CEQA Documents………………………………. 1-5
2 Assessing and Mitigating Construction Impacts…………………………………………………………………. 2-1
2.1 Construction Significance Criteria……………………………………………………………………….. 2-1
2.1.1 Special Conditions for Construction Activity………………………………………………… 2-3
2.2 Methods for Calculating Construction Emissions…………………………………………………….. 2-4
2.3 ROG, NOx, PM and GHG Combustion Mitigation Measures……………………………………… 2-6
2.3.1 Standard Mitigation Measures for Construction Equipment……………………………… 2-6
2.3.2 Best Available Control Technology (BACTt) for Construction Equipment………….. 2-7
2.3.3 Construction Activity Management Plan (CAMP) and Off-Site Mitigation………….. 2-7
2.4 Fugitive Dust Mitigation Measures………………………………………………………………………. 2-8
2.5 Mitigation Monitoring……………………………………………………………………………………… 2-10
3 Assessing and Mitigating Operational Impacts…………………………………………………………………… 3-1
3.1 Operational Significance Criteria…………………………………………………………………………. 3-1
3.2 Consistency with the SLO County APCD’s Clean Air Plan and Smart Growth Principles…. 3-1
3.3 Comparison to Standards……………………………………………………………………………………. 3-1
3.4 Comparison to SLO County APCD Operational Emission Thresholds………………………….. 3-2
3.4.1 Significance Thresholds for Project-Level Operational Emissions……………………… 3-3
3.4.2 Ozone Precursor (ROG + NOx) Emissions…………………………………………………… 3-3
3.4.3 Diesel Particulate Matter (DPM) Emissions…………………………………………………. 3-4
3.4.4 Fugitive Particulate Matter (Dust) Emissions………………………………………………… 3-4
3.4.5 Carbon Monoxide (CO) Emissions…………………………………………………………….. 3-4
3.4.6 Greenhouse Gas Emissions………………………………………………………………………. 3-5
3.5 Special Conditions……………………………………………………………………………………………. 3-5
3.5.1 Toxic Air Contaminants…………………………………………………………………………… 3-5
3.5.2 Agricultural Operations…………………………………………………………………………… 3-7
3.5.3 Fugitive Dust………………………………………………………………………………………… 3-7
3.5.4 Air Quality Nuisance Impacts……………………………………………………………………. 3-8
3.6 Methods for Calculating Project Operational Emissions……………………………………………. 3-9
3.6.1 Determining Motor Vehicle Emissions………………………………………………………. 3-10
3.6.2 Non-Vehicular Emissions From Residential and Commercial Facilities…………….. 3-11
3.6.3 Industrial Emission Sources……………………………………………………………………. 3-11
3.6.4 Health Risk Assessment…………………………………………………………………………. 3-12
3.6.5 Greenhouse Gas Emissions…………………………………………………………………….. 3-12
3.7 Operational Emission Mitigation……………………………………………………………………….. 3-12
3.7.1 Guidelines for Applying ROG, NOx and PM10 Mitigation Measures…………………. 3-13
3.7.2 Standard Mitigation Measures…………………………………………………………………. 3-14
3.7.3 Off-Site Mitigation……………………………………………………………………………….. 3-18
3.8 Evaluation of Project Changes…………………………………………………………………………… 3-19
3.9 Mitigation Monitoring……………………………………………………………………………………… 3-20
4 Technical Appendices………………………………………………………………………………………………….. 4-1
4.1 Building Permit Requirements for Facilities Potentially Subject to Air District Permits……. 4-1
4.2 ARB’s Recommendations On Siting New Sensitive Land Uses…………………………………… 4-8
4.3 APCD-Approved Dust Suppressants…………………………………………………………………….. 4-9
4.4 SLO County Naturally Occurring Asbestos Map……………………………………………………. 4-11
4.5 Construction Activity Management Plan Guidelines………………………………………………. 4-12
Tables
Table 1-1: Operational Screening Criteria for Project Air Quality Analysis(1)……………………………………….. 1-3
Table 2-1: Thresholds of Significance for Construction Operations……………………………………………………. 2-2
Table 2-2: Screening Emission Rates for Construction Operations……………………………………………………… 2-5
Table 3-1: Ambient Air Quality Standards (State and Federal)………………………………………………………….. 3-2
Table 3-2: Thresholds of Significance for Operational Emissions Impacts……………………………………………. 3-3
Table 3-3: Project Screening Distances for Nuisance Sources……………………………………………………………. 3-9
Table 3-4: Mitigation Threshold Guide………………………………………………………………………………………. 3-14
Table 3-5: Mitigation Measures……………………………………………………………………………………………….. 3-14
LIST OF ACRONYMS
ACM Asbestos Containing Material
ADT Average Daily Trips
APCD San Luis Obispo County Air Pollution Control District APS Auxiliary Power System
ARB California Air Resources Board
ATCM Air Toxics Control Measure
BACT Best Available Control Technology for Construction Equipment CAAA 1990 Clean Air Act Amendments
CAMP Construction Activity Management Plan CAP Clean Air Plan for San Luis Obispo County
CAPCOA California Air Pollution Control officers Associations CEQA California Environmental Quality Act
CNG Compressed Natural Gas
CO Carbon Monoxide
CO2 Carbon Dioxide
DEIR Draft Environmental Impact Report
DOC Diesel Oxidation Catalyst
DPM Diesel Particulate Matter
EIR Environmental Impact Report
EPA United States Environmental Protection Agency GHG Greenhouse Gases
HRA Health Risk Assessment
ITE Institute of Transportation Engineers
LNG Liquid Natural Gas
NESHAP National Emission Standard for Hazardous Air Pollutants NOA Naturally Occurring Asbestos
NOP Notice of Preparation
NOx Oxides of Nitrogen
PM Particulate Matter
PM2.5 Particulate Matter (less than 2.5 µm)
PM10 Particulate Matter (less than 10 µm)
ROG Reactive Organic Gases
SLO San Luis Obispo
TAC Toxic Air Contaminant
VDECS Verified Diesel Emission Control Systems VMT Vehicle Miles Traveled
GLOSSARY
Climate Change: Climate change refers to long-term changes in temperature, precipitation, wind patterns, and other elements of the earth’s climate system. An ever-increasing body of scientific research attributes these climatological changes to greenhouse gases (GHGs), particularly those generated from the human production and use of fossil fuels.
Diverted Trips: Diverted linked trips, as defined by Institute of Transportation Engineers (ITE), are attracted from the traffic volume on a roadway within the vicinity of the generator but require a diversion from that roadway to another roadway to gain access to the site.
Fugitive Dust: Small particles which are entrained and suspended into the air by the wind or external disturbances. Fugitive dust typically originates over an area and not a specific point. Typical sources include unpaved or paved roads, construction sites, mining operations, disturbed soil and tilled agricultural areas.
Ozone Precursors: Gaseous compounds needed to form ozone by the process of photochemistry. Photochemical air pollution (primarily ozone) is produced by the atmospheric reaction of organic substances, such as reactive organic gases (ROG) and nitrogen dioxide (NO2) under the influence of sunlight.
NO2 + ROG + Sunlight => O3
During the summer, in areas with high emissions and high ozone concentrations, ozone concentrations are very dependent on the amount of solar radiation. Ozone levels typically peak in the late afternoon, at the end of the longest period of daily solar radiation. After the sun goes down, the chemical reaction between nitrous oxide and ozone begins to dominate and ozone usually decreases.
O3 + NO => NO2 + O2
In some remote rural locations away from emission sources, ozone concentrations can remain high overnight because there are no NO sources to react with the existing ozone.
Ozone precursors are typically considered to be the combination of ROG + NOx.
Particulate Matter: Small particles that become airborne and have the potential to cause adverse health impacts. There are three general size components: 1) PM or Total Suspended Particulate (TSP) which includes all airborne particles regardless of size or source; 2) PM10 which includes airborne particles 10µm in size and smaller; and 3) PM2.5 or fine airborne particles 2.5µm and smaller.
Primary Trips: Trips made for the specific purpose of visiting the proposed facility.
Passby Trip: Trips made as an intermediate stop on the way from an origin to a destination without a route diversion.
Sensitive Receptors: Sensitive receptors are 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). The location of sensitive receptors is needed to assess toxic impacts on public health.
Smart Growth: Smart or strategic growth is an urban planning and transportation theory that concentrates growth in the center of a city to avoid urban sprawl; and advocates compact, transit-oriented, walkable, bicycle-friendly land use, including neighborhood schools, complete streets, and mixed-use development with a range of housing choices.
Verified Diesel Emission Control Strategy: Diesel vehicle or equipment exhaust retrofits that have been verified by the California Air Resources Board (ARB) that provide specified diesel particulate emission reductions when implemented in compliance with the ARB executive order for the device (www.arb.ca.gov/diesel/verdev/verdev.htm).
CEQA
Air Quality Handbook
GUIDE FOR ASSESSING THE AIR QUALITY IMPACTS FOR PROJECTS SUBJECT TO CEQA REVIEW
The purpose of this document is to assist lead agencies, planning consultants, and project proponents in assessing the potential air quality impacts from residential, commercial and industrial development. It is designed to provide uniform procedures for preparing the air quality analysis section of environmental documents for projects subject to the California Environmental Quality Act (CEQA). These guidelines define the criteria used by the San Luis Obispo County Air Pollution Control District (APCD or Air District) to determine when an air quality analysis is necessary, the type of analysis that should be performed, the significance of the impacts predicted by the analysis, and the mitigation measures needed to reduce the overall air quality impacts. The use of this document will simplify the process of evaluating and mitigating the potential air quality impacts from new development in San Luis Obispo County.
For further information on any of the topics covered in this handbook, review the APCD’s website at www.slocleanair.org or contact us directly at (805) 781-5912.
1 PROJECTS REQUIRING AIR QUALITY REVIEW AND ANALYSIS
The Air District has permit authority over many “direct” sources of air contaminants, such as power plants, gasoline stations, dry cleaners and refineries. Indirect sources are contributors to air pollution and include facilities and land uses which may not emit a significant amount of pollution themselves, but are responsible for indirect emissions, such as:
Emission impacts from both direct and indirect sources are typically identified and, if needed mitigated through the land use planning process under the guidelines and statutes of CEQA.
1.1 ROLE OF THE SLO COUNTY APCD
Under CEQA, the SLO County APCD may act as a lead, responsible or commenting agency, reviewing and commenting on projects which have the potential to cause adverse impacts to air quality. The CEQA statutes and guidelines require lead agencies to seek comments from each responsible agency and any public agency that have jurisdiction by law over resources that may be affected by a proposed project (CEQA 21153 and 15366). For many development proposals, this typically involves projects where vehicle trip generation is high enough to cause or contribute to local emission levels capable of hindering the APCD’s efforts to attain and maintain health-based air quality standards. It is in this context that local jurisdictions and planning bodies can make critical decisions that affect their future environment and that of neighboring communities as well.
Offshore activities within State waters, such as oil drilling and production, harbor dredging and cable installation are also subject to CEQA review and possible APCD permits depending on the nature of the activity.
1.2 PROJECTS SUBJECT TO AIR QUALITY ANALYSIS
In general, any proposed project with short-term construction emissions or long-term operational emissions that may exceed an APCD threshold of significance, as identified in this Handbook should be submitted to the SLO County APCD for review. If needed, the APCD will assist in refining impact evaluations and or appropriate mitigation measures. The project will be evaluated to determine the potential for significant air quality impacts, with further analysis or mitigation recommended if appropriate. Types of projects which generally fall into this category include:
The environmental documents associated with these types of projects and reviewed by the APCD include Initial Studies, Notices of Preparation (NOP), Negative Declarations, and Environmental Impact Reports (EIR), and other environmental documents prepared pursuant to CEQA and NEPA.
1.3 PROJECT INFORMATION NEEDED FOR SLO COUNTY APCD REVIEW
Early consultation with the APCD can ensure the environmental document adequately addresses air quality issues. In order to facilitate our review of the proposed project, the following information should be provided:
1.4 OPERATIONAL SCREENING CRITERIA FOR PROJECT IMPACTS
General screening criteria used by the SLO County APCD to determine the type and scope of projects requiring an air quality assessment, and/or mitigation, is presented in Table 1-1. These criteria are based on project size in an urban setting and are designed to identify those projects with the potential to exceed the APCD’s significance thresholds. Operational impacts are focused primarily on the indirect emissions (i.e., motor vehicles) associated with residential, commercial and industrial development.
Table 1-1 is based on ozone precursor emissions and is not comprehensive. It should be used for general guidance only. This table is not applicable for projects that involve heavy-duty diesel activity and/or fugitive dust emissions. A more refined analysis of air quality impacts specific to a given project is often necessary for projects exceeding the screening thresholds.
Table 1-1: Operational Screening Criteria for Project Air Quality Analysis(1)
Land Use |
Unit of Measure |
Size of Urban Project Expected to Exceed APCD Ozone Precursor Significance Thresholds(2): |
|
25 lbs/day ROG + NOx |
25 tons/year ROG + NOx |
||
LARGE RETAIL: |
|||
Free Standing Discount Store |
1,000 SF |
26 |
130 |
Free Standing Super Discount Store |
29 |
147 |
|
Discount Club |
34 |
173 |
|
Regional Shopping Center |
33 |
168 |
|
Electronic Superstore |
32 |
161 |
|
Home Improvement Store |
47 |
240 |
|
RETAIL: |
|
|
|
Strip Mall |
1,000 SF |
33 |
168 |
Hardware/Paint Store |
28 |
142 |
|
Supermarket |
14 |
79 |
|
Convenience Market (24 hrs) |
2 |
10 |
|
Convenience Market with Gas Pumps |
2 |
9 |
|
Gasoline Service Station |
Pumps |
9 |
46 |
COMMERCIAL: |
|
|
|
Land Use |
Unit of Measure |
Size of Urban Project Expected to Exceed APCD Ozone Precursor Significance Thresholds(2): |
|
25 lbs/day ROG + NOx |
25 tons/year ROG + NOx |
||
Bank with a Drive Through |
1,000 SF |
6 |
30 |
General Office Building |
87 |
445 |
|
Office Park |
76 |
387 |
|
Government Office Building |
19 |
96 |
|
Government Building/Civic Center |
46 |
234 |
|
Pharmacy Drugstore with Drive Through |
16 |
83 |
|
Pharmacy Drugstore without Drive Through |
16 |
82 |
|
Medical Office Building |
37 |
188 |
|
Hospital |
61 |
312 |
|
RESIDENTIAL: |
|||
Single Family Housing |
Dwelling Unit |
79 |
391 |
Apartment Low Rise |
106 |
520 |
|
Apartment Mid Rise |
120 |
586 |
|
Apartment High Rise |
127 |
620 |
|
Condo/Townhouse General |
106 |
521 |
|
Condo/Townhouse High Rise |
128 |
622 |
|
Mobile Home Park |
120 |
592 |
|
Retirement Community |
141 |
693 |
|
Assisted Living |
212 |
1009 |
|
EDUCATIONAL(3): |
|||
Day Care |
1,000 SF |
18 |
89 |
Elementary |
76 |
390 |
|
Junior High |
80 |
409 |
|
High School |
94 |
482 |
|
Junior College (2 years) |
857 |
4570 |
|
University (4 years) |
488 |
2604 |
|
Library |
26 |
130 |
|
Place of Worship |
138 |
714 |
|
RECREATIONAL: |
|||
City Park |
Acres |
696 |
3808 |
Racquet Club |
1,000 SF |
92 |
471 |
Racquet Club/ Health |
41 |
210 |
|
Quality Restaurant |
15 |
76 |
|
High Turnover Sit Down Restaurant |
11 |
56 |
|
Fast Food with Drive Through |
2 |
10 |
|
Fast Food without Drive Through |
3 |
14 |
|
Hotel |
Rooms |
153 |
790 |
Motel |
210 |
1097 |
|
INDUSTRIAL: |
|||
Warehouse |
1,000 SF |
246 |
1323 |
General- Light Industrial |
118 |
621 |
|
General- Heavy Industrial |
356 |
1945 |
|
Industrial Park |
125 |
665 |
|
Manufacturing |
206 |
1103 |
1.5 PREPARING THE AIR QUALITY ANALYSIS SECTION FOR CEQA DOCUMENTS
As shown in Table 1-1, use of a simple screening analysis in a Negative Declaration, or emissions calculations and appropriate mitigation measures in a Mitigated Negative Declaration may be all that is necessary for many smaller urban projects. For larger projects requiring the preparation of an EIR, a more comprehensive air quality analysis is often needed. Such an analysis should address both construction phase and operational phase impacts of the project and include the following information:
Pursuant to the requirements of California Health and Safety Code Section 42301.6 (AB 3205) and Public Resources Code Section 21151.8, subd. (a)(2), any new school or proposed industrial or commercial project site located within 1000 feet of a school must be referred to the SLO County APCD for review. Further details on requirements for projects in this category are presented in Appendix A.
project is located in close proximity to any of the listed sources a health risk screening and/or assessment should be performed to assess risk to potential residence of the development.
2 ASSESSING AND MITIGATING CONSTRUCTION IMPACTS
Use of heavy equipment and earth moving operations during project construction can generate fugitive dust and engine combustion emissions that may have substantial temporary impacts on local air quality. Fugitive dust of concern is particulate matter that is less than ten microns in size (PM10) and is not emitted from definable point sources such as industrial smokestacks. Sources include open fields, roadways, storage piles, earthwork, etc. Fugitive dust emissions results from land clearing, demolition, ground excavation, cut and fill operations and equipment traffic over temporary roads at the construction site.
Heavy-duty construction equipment is usually diesel powered. In July 1999, the ARB listed the particulate fraction of diesel exhaust as a toxic air contaminant, identifying both chronic and carcinogenic public health risks. Combustion emissions, such as nitrogen oxides (NOx), reactive organic gases (ROG), and diesel particulate matter (diesel PM), are most significant when using large, diesel-fueled scrapers, loaders, bulldozers, haul trucks, compressors, generators and other heavy equipment. Emissions from both fugitive dust and combustion sources can vary substantially from day-to-day depending on the level of activity, the specific type of operation, moisture content of soil, use of dust suppressants and the prevailing weather conditions.
Depending on the construction site location and proximity to sensitive receptors, a project that generates high levels of construction emissions, including diesel PM, may be required to perform a health risk assessment to evaluate short-term exposures to high pollutant concentrations and, if necessary, to implement mitigations measures. Mitigation requirements and the need for further analysis will be determined on a case-by-case basis, based upon emission levels and the potential risk for human exposure and effects. Diesel PM emissions may therefore be a factor in whether Best Available Control Technology (BACT) for construction equipment will be needed, even when emissions of criteria pollutants are below the Air District’s significance thresholds.
The following information will assist the user in evaluating the fugitive dust and combustion emissions from a project and in proposing appropriate mitigation measures to reduce these impacts to a level of insignificance.
2.1 CONSTRUCTION SIGNIFICANCE CRITERIA
Construction emissions must be calculated for all development projects likely to exceed the construction emissions threshold, or if the project is subject to the special conditions defined in Section 2.1.1. Details on how to conduct emission calculations are discussed in Section 2.2 below. Once the emissions have been calculated, they should then be compared to the APCD construction phase significance thresholds.
Comparison to APCD Construction Significance Thresholds
The threshold criteria established by the SLO County APCD to determine the significance and appropriate mitigation level for a project’s short-term construction emissions are presented in Table 2-1.
Most of the short-term construction mitigation strategies in Sections 2.3 and 2.4 focus on reducing fugitive dust emissions from work sites and haul vehicles, reducing combustion emissions from construction equipment, reducing asbestos (e.g., NOA) and scheduling construction activities to protect public health.
Table 2-1 provides general thresholds for determining the significance of impacts for total emissions expected from a project’s construction activities. The discussion following the table provides a more detailed explanation of the thresholds. The Air District has discretion to require mitigation for projects that will not exceed the mitigation thresholds if those projects will result in special impacts, such as the release of diesel PM emissions or asbestos near sensitive receptors.
Table 2-1: Thresholds of Significance for Construction Operations
Pollutant |
Threshold(1) |
||
Daily |
Quarterly Tier 1 |
Quarterly Tier 2 |
|
ROG + NOx (combined) |
137 lbs |
2.5 tons |
6.3 tons |
Diesel Particulate Matter (DPM) |
7 lbs |
0.13 tons |
0.32 tons |
Fugitive Particulate Matter (PM10), Dust(2) |
|
2.5 tons |
|
Greenhouse Gases (CO2, CH4) |
Not Yet Established |
Mitigation of construction activities is required when the emission thresholds are equaled or exceeded by fugitive and/or combustion emissions:
ROG and NOx Emissions
Diesel Particulate Matter (DPM) Emissions
0.13 tons/quarter threshold requires Standard Mitigation Measures, BACT for construction equipment; and,
0.32 ton/qtr threshold requires Standard Mitigation Measures, BACT, implementation of a CAMP, and off-site mitigation.
Fugitive Particulate Matter (PM10), Dust Emissions
Greenhouse Gas Emissions
– To amortize the emissions over the life of the project, calculate the total greenhouse gas emissions for the construction activities, divide it by the project life (i.e., 50 years for residential projects and 25 years for commercial projects) then add that number to the annual operational phase GHG emissions.
2.1.1 Special Conditions for Construction Activity
In addition to the construction air quality thresholds defined above, there are a number of special conditions, local regulations or state / federal rules that apply to construction activities. These conditions must be addressed in proposed construction activity.
Sensitive Receptors
The proximity of sensitive individuals (receptors) to a construction site constitutes a special condition and may require a more comprehensive evaluation of toxic diesel PM impacts and if deemed necessary by the SLO County APCD, more aggressive implementation of mitigation measures than described below in the diesel idling section. Areas were sensitive receptors are most likely to spend time include schools, parks and playgrounds, day care centers, nursing homes, hospitals, and residential dwelling unit(s).
Sensitive receptor locations for a project need to be identified during the CEQA review process and mitigation to minimize toxic diesel PM impacts need to be defined. The types of construction projects that typically require a more comprehensive evaluation include large-scale, long-term projects that occur within 1,000 feet of a sensitive receptor location(s).
Diesel Idling Restrictions for Construction Phases
The APCD recognizes the public health risk reductions that can be realized by idle limitations for both on and off-road equipment. The following idle restricting measures are required for the construction phase of projects:
Section 2485 of Title 13, the California Code of Regulations limits diesel-fueled commercial motor vehicles that operate in the State of California with gross vehicular weight ratings of greater than 10,000 pounds and licensed for operation on highways. It applies to California and non-California based vehicles. In general, the regulation specifies that drivers of said vehicles:
Signs must be posted in the designated queuing areas and job sites to remind drivers of the 5 minute idling limit. The specific requirements and exceptions in the regulation can be reviewed at the following web site: www.arb.ca.gov/msprog/truck-idling/2485.pdf.
Off-road diesel equipment shall comply with the 5 minute idling restriction identified in Section 2449(d)(3) of the California Air Resources Board’s In-Use off-Road Diesel regulation: www.arb.ca.gov/regact/2007/ordiesl07/frooal.pdf.
Signs shall be posted in the designated queuing areas and job sites to remind off-road equipment operators of the 5 minute idling limit.
Naturally Occurring Asbestos
Naturally Occurring Asbestos (NOA) has been identified as a toxic air contaminant by the California Air Resources Board (ARB). Under the ARB Air Toxics Control Measure (ATCM) for Construction, Grading, Quarrying, and Surface Mining Operations, prior to any grading activities a geologic evaluation should be conducted to determine if NOA is present within the area that will be disturbed. If NOA is not present, an exemption request must be filed with the District. If NOA is found at the site, the applicant must comply with all requirements outlined in the Asbestos ATCM. This may include development of an Asbestos Dust Mitigation Plan and an Asbestos Health and Safety Program for approval by the APCD. Technical Appendix 4.4 of this Handbook includes a map of zones throughout SLO County where NOA has been found and geological evaluation is required prior to any grading. More information on NOA can be found at http://www.slocleanair.org/business/asbestos.asp.
Asbestos Material in Demolition
Demolition activities can have potential negative air quality impacts, including issues surrounding proper handling, demolition, and disposal of asbestos containing material (ACM). Asbestos containing materials could be encountered during demolition or remodeling of existing buildings. Asbestos can also be found in utility pipes/pipelines (transite pipes or insulation on pipes). If utility pipelines are scheduled for removal or relocation or a building(s) is proposed to be removed or renovated, various regulatory requirements may apply, including the requirements stipulated in the National Emission Standard for Hazardous Air Pollutants (40CFR61, Subpart M – asbestos NESHAP). These requirements include but are not limited to: 1) notification to the APCD, 2) an asbestos survey conducted by a Certified Asbestos Inspector, and, 3) applicable removal and disposal requirements of identified ACM. More information on Asbestos can be found at http://www.slocleanair.org/business/asbestos.php.
Developmental Burning
APCD regulations prohibit developmental burning of vegetative material within SLO County.
Permits
Portable equipment and engines 50 horsepower (hp) or greater, used during construction activities will require California statewide portable equipment registration (issued by the ARB) or an Air District permit. The following list is provided as a guide to equipment and operations that may have permitting requirements, but should not be viewed as exclusive:
2.2 METHODS FOR CALCULATING CONSTRUCTION EMISSIONS
In calculating emissions for construction operations (NOx, ROG, DPM, GHG and fugitive PM), specific information about each activity and phase of the construction project is needed. Several methods are described below, each of which requires increasingly detailed information to produce more accurate results.
All assumptions, estimates, and calculation methods must be provided for SLO County APCD review. Calculation of combustion and fugitive dust emissions from construction activities should include peak daily, quarterly, annual, and total construction phase emissions of NOx, ROG, diesel PM, GHG and fugitive PM. Both the duration of the construction activities and schedule of phases are required in the evaluation. When using URBEMIS or a spreadsheet to model construction emissions, the electronic project file (not a pdf) needs to be submitted to the SLO County APCD for review along with a
summary table showing all emissions. The electronic file(s) need to be submitted to the APCD for review and shall include specific and summary emission reports, a detailed explanation of any deviations from URBEMIS defaults, and a detailed descriptions of assumptions used for the emission calculations.
It may be necessary to calculate the project’s construction impacts without knowing the exact fleet of construction equipment involved in the project. Table 2-2 contains screening construction emission rates based on the volume of soil moved and the area disturbed. This table should only be used when no other project information is available.
Table 2-2: Screening Emission Rates for Construction Operations
Pollutant |
Grams/Cubic Yard of Material Moved |
Lbs/Cubic Yard of Material Moved |
Diesel PM |
2.2 |
0.0049 |
Reactive Organic Gases (ROG) |
9.2 |
0.0203 |
Oxides of Nitrogen (NOx) |
42.4 |
0.0935 |
Fugitive Dust (PM10) |
0.75 tons/acre/month of construction activity (assuming 22 days of operation per month) |
ROG, NOx, DPM Source: Bay Area Air Quality Management District CEQA Guidelines, December 1999, Table 7
PM10 Source: EPA-AP-42 (January 1995) and Index of Methodologies by Major Category Section 7.7 Building Construction Dust, California Air Resources Board, August 1997
The next level of specificity in defining project construction emissions involves the use of URBEMIS. This software contains emission factors for a variety of construction equipment. It will automatically generate default values for the parameters listed below.
URBEMIS will not automatically calculate off-site hauling trips and associated emissions. If soil or demolition materials will need to be hauled off-site or materials will be imported, cubic yards of material and the number of truck trips will need to be entered into the model. The trip length associated with hauling also needs to be entered into the model along with a detailed explanation of the trip length.
Specific truck emission factors for the hauling fleet should to be included in the simulation. If the specific fleet is unknown at time of modeling, then a defensible worst case set of hauling fleet emission factors shall be used. This hauling component is an important step and is often overlooked resulting in under estimation of emissions.
If more detailed information regarding the construction phase of the project is known, the construction phases and default values can be modified in this step to more accurately reflect the anticipated emissions from the project.
A component of URBEMIS, the construction calculator, allows project specific equipment data to be used to calculate emissions. The use of the construction calculator is recommended for those projects that are in the final phase of planning when the actual fleet mix and construction schedule is defined to validate
previous emission estimates and finalize mitigation measures. The following variables can be defined for each piece of construction equipment:
More detailed information about URBEMIS can be found at www.urbemis.com
2.3 ROG, NOX, PM AND GHG COMBUSTION MITIGATION MEASURES
Construction mitigation measures are designed to reduce emissions (ROG, NOx, DPM, PM10 and GHG) from heavy-duty construction equipment and may include emulsified fuels, catalyst and filtration technologies, engine replacement, new alternative fueled trucks, and implementation of Construction Activity Management Plans (CAMP). The mitigation measures for construction activity fall into three separate sections:
– Construction Activity Management Plans (CAMP)
– Retrofit Devices and Alternative Fuels
– Repowers
Measure Applicability
Measures should be applied as necessary to reduce construction impacts below the significance thresholds listed in Table 2-1. Construction equipment mitigation measures and construction activity management practices have been shown to significantly reduce emissions while maintaining overall equipment performance and project scheduling needs. Project proponents shall determine daily and quarterly construction phase impacts and define mitigation that will be implemented if impacts are expected to exceed the SLO County APCD’s construction phase thresholds of significance.
The following list of standard and specific mitigation measures shall be incorporate into project conditions depending on the level of impacts. Ozone precursors (ROG + NOx) are to be combined and compared to the SLO County APCD’s construction phase significance thresholds. Applying the BACT for construction equipment or implementing a Construction Activity Management Plan is required when the Quarterly Tier 2 construction significance thresholds of 6.3 tons per quarter ROG + NOx or 0.32 tons per quarter diesel PM are exceeded.
2.3.1 Standard Mitigation Measures for Construction Equipment
The standard mitigation measures for reducing nitrogen oxides (NOx), reactive organic gases (ROG), and diesel particulate matter (DPM) emissions from construction equipment are listed below:
2.3.2 Best Available Control Technology (BACT) for Construction Equipment
If the estimated ozone precursor emissions from the actual fleet for a given construction phase are expected to exceed the APCD threshold of significance after the standard mitigation measures are factored into the estimation, then BACT needs to be implemented to further reduce these impacts. The BACT measures can include:
2.3.3 Construction Activity Management Plan (CAMP) and Off-Site Mitigation
If the estimated construction emissions from the actual fleet are expected to exceed either of the APCD Quarterly Tier 2 thresholds of significance after the standard and BACT measures are factored into the estimation, then an APCD approved CAMP (see Technical Appendix 4.5 for CAMP Guidelines) and off- site mitigation need to be implemented in order to reduce potential air quality impacts to a level of insignificance.
CAMP
The CAMP should be submitted to the APCD for review and approval prior to the start of construction and should include, but not be limited to, the following elements:
Off-Site Mitigation
It is important for the developer, lead agency, and SLO County APCD to work closely together whenever off-site mitigation is triggered. Off-site emission reductions can result from either stationary or mobile sources, but should relate to the on-site impacts from the project in order to provide proper “nexus” for the air quality mitigation. For example, NOx emissions from a large grading project could be reduced by re-powering heavy-duty diesel construction equipment, thereby reducing the amount of NOx generated from that equipment. An off-site mitigation strategy should be developed and agreed upon by all parties at least three months prior to the issuance of grading permits.
The current off-site mitigation rate is $16,000 per ton1 of ozone precursor emission (NOx + ROG) over the APCD threshold calculated over the length of the expected exceedance. The applicant may use these funds to implement APCD approved emission reduction projects near the project site or may pay that funding level plus an administration fee (2009 rate is 10%) to the APCD to administer emission reduction projects in close proximity to the project. The applicant shall provide this funding at least two (2) months prior to the start of construction to help facilitate emission offsets that are as real-time as possible.
Examples off-site mitigation strategies include, but are not limited to, the following:
2.4 FUGITIVE DUST MITIGATION MEASURES
Fugitive dust is particulate matter that is less than ten micros in size (PM10) and is not emitted from defined point sources such as industrial smokestacks. Sources include open fields, graded or excavated areas, roadways, storage piles, etc.
All fugitive dust sources shall be managed to ensure that dust emissions are adequately controlled to below the 20% opacity limit identified in the APCD Rule 401 Visible Emissions and to ensure that dust is not emitted offsite. Projects shall implement one of the following fugitive dust mitigation sets to both minimize fugitive dust emissions and associated complaints that could result in a violation of the APCD Rule 402 Nuisance. The correct fugitive dust mitigation set for a given project depends on the project scale or proximity to sensitive receptors. The project proponent may propose other measures of equal or better effectiveness as replacements by contacting the APCD Panning Division.
Fugitive Dust Mitigation Measures: Short List
Projects with grading areas that are less than 4-acres and that are not within 1,000 feet of any sensitive receptor shall implement the following mitigation measures to minimize nuisance impacts and to significantly reduce fugitive dust emissions:
1 The value used to calculate off-site mitigation is based on the ARB approved Carl Moyer Grant Program and is updated on a periodic basis. The Carl Moyer cost effectiveness value as of 2009 is $16,000 per ton.
Fugitive Dust Mitigation Measures: Expanded List
Projects with grading areas that are greater than 4-acres or are within 1,000 feet of any sensitive receptor shall implement the following mitigation measures to minimize nuisance impacts and to significantly reduce fugitive dust emissions:
2.5 MITIGATION MONITORING
The APCD may conduct site visits to ensure that the construction phase air quality mitigation measures identified in the project’s CEQA documents/conditions of approval were fully implemented. The lead agency may also review project mitigation for consistency with project conditions. Beyond verifying mitigation implementation, this monitoring can result in compliance requirements if mitigation measures are not sufficiently being implemented.
3 ASSESSING AND MITIGATING OPERATIONAL IMPACTS
Air pollutant emissions from urban development can result from a variety of sources, including motor vehicles, wood burning appliances, natural gas and electric energy use, combustion-powered utility equipment, paints and solvents, equipment or operations used by various commercial and industrial facilities, heavy-duty equipment and vehicles and various other sources. The air quality impacts that result from operational activities of a development project should be fully evaluated and quantified as part of the CEQA review process. The methods for evaluating and mitigating operational impacts from residential, commercial and industrial sources are discussed below.
3.1 OPERATIONAL SIGNIFICANCE CRITERIA
The APCD has established four separate categories of evaluation for determining the significance of project impacts. Full disclosure of the potential air pollutant and/or toxic air emissions from a project is needed for these evaluations, as required by CEQA:
3.2 CONSISTENCY WITH THE SLO COUNTY APCD’S CLEAN AIR PLAN AND SMART GROWTH PRINCIPLES
A consistency analysis with the Clean Air Plan is required for a Program Level environmental review, and may be necessary for a Project Level environmental review, depending on the project being considered. Program-Level environmental reviews include but are not limited to General Plan Updates and Amendments, Specific Plans, Regional Transportation Plans and Area Plans. Project-Level environmental reviews which may require consistency analysis with the Clean Air Plan and Smart/Strategic Growth Principles adopted by lead agencies include: subdivisions, large residential developments and large commercial/industrial developments. The project proponent should evaluate if the proposed project is consistent with the land use and transportation control measures and strategies outlined in the Clean Air Plan. If the project is consistent with these measures, the project is considered consistent with the Clean Air Plan.
3.3 COMPARISON TO STANDARDS
State and federal ambient air quality standards are established to protect public health and welfare from the adverse impacts of air pollution; these standards are listed in Table 3-1. Industrial and large commercial projects are sometimes required to perform air quality dispersion modeling if the SLO County APCD determines that project emissions may have the potential to cause an exceedance of these standards. In such cases, models are used to calculate the potential ground-level pollutant concentrations resulting from the project. The predicted pollutant levels are then compared to the applicable state and federal standards. A project is considered to have a significant impact if its emissions are predicted to cause or contribute to a violation of any ambient air quality standard. In situations where the predicted standard violation resulted from the application of a “screening-level” model or calculation, it may be appropriate to perform a more refined modeling analysis to accurately estimate project impacts. If a refined analysis is not available or appropriate, then the impact must be mitigated to a level of insignificance or a finding of overriding considerations must be made by the permitting agency.
Table 3-1: Ambient Air Quality Standards (State and Federal)
Pollutant |
Averaging Time |
California Standard (1) |
Federal Standard (2) |
|
Ozone |
1 Hour |
0.09 ppm |
|
|
8 Hour |
0.070 ppm |
0.075 ppm |
||
Carbon Monoxide |
8 Hour |
9.0 ppm |
9 ppm |
|
1 Hour |
20 ppm |
35 ppm |
||
Nitrogen Dioxide |
Annual Arithmetic Mean |
0.030 ppm |
0.053 ppm |
|
1 Hour |
0.18 ppm |
|
||
Sulfur Dioxide |
Annual Arithmetic Mean |
|
0.030 ppm |
|
24 Hour |
0.04 ppm |
0.14 ppm |
||
3 Hour |
|
0.5 ppm (secondary) |
||
1 Hour |
0.25 ppm |
|
||
Respirable Particulate Matter |
PM10 |
Annual Arithmetic Mean |
20 mg/m3 |
|
24 Hour |
50 mg/m3 |
150 mg/m3 |
||
Fine Particulate Matter |
PM2.5 |
Annual Arithmetic Mean |
12 mg/m3 |
15.0 mg/m3 |
24 Hour |
|
35 mg/m3 |
||
Hydrogen Sulfide |
1 Hour |
0.03 ppm |
|
|
Vinyl Chloride |
24 Hour |
0.01 ppm |
|
|
Sulfates |
24 Hour |
25 mg/m3 |
|
|
Lead |
|
30 day average: 25 mg/m3 |
Rolling 3-month average:0.15 mg/m3
Calendar quarter: 1.5 mg/m3 |
|
Visibility Reducing Particles |
8 Hour |
Extinction coefficient of 0.23 per kilometer – visibility of ten miles or more due to particles when relative humidity is less than 70 percent. Method: Beta Attenuation and Transmittance through Filter Tape. |
|
3.4 COMPARISON TO SLO COUNTY APCD OPERATIONAL EMISSION THRESHOLDS
Emissions which exceed the designated threshold levels are considered potentially significant and should be mitigated.
A Program Level environmental review, such as for a General Plan, Specific Plan or Area Plan however, does not require a quantitative air emissions analysis at the project scale. A qualitative analysis of the air quality impacts should be conducted instead, and should be generated for each of the proposed alternatives to be considered. The qualitative analysis of each alternative should be based upon criteria such as prevention of urban sprawl and reduced dependence on automobiles. A finding of significant
impacts can be determined qualitatively by comparing consistency of the project with the Transportation and Land Use Planning Strategies outlined in the APCD’s Clean Air Plan. Refer to Section 3.2 for more information.
Section 3.7 of this document provides guidance on the type of mitigation recommended for varying levels of impact and presents a sample list of appropriate mitigation measures for different types of projects.
3.4.1 Significance Thresholds for Project-Level Operational Emissions
The threshold criteria established by the SLO County APCD to determine the significance and appropriate mitigation level for long-term operational emissions from a project are presented in Table 3-2.
Table 3-2: Thresholds of Significance for Operational Emissions Impacts
Pollutant |
Threshold(1) |
|
Daily |
Annual |
|
Ozone Precursors (ROG + NOx)(2) |
25 lbs/day |
25 tons/year |
Diesel Particulate Matter (DPM)(2) |
1.25 lbs/day |
|
Fugitive Particulate Matter (PM10), Dust |
25 lbs/day |
25 tons/year |
CO |
550 lbs/day |
|
Greenhouse Gases (CO2, CH4) |
Not Yet Established |
Most of the long-term operational mitigation strategies suggested in Section 3.7 focus on methods to reduce vehicle trips and travel distance, including site design standards which encourage pedestrian and bicycle-friendly, transit-oriented development. In addition, the recommendations include design strategies for residential and commercial buildings that address energy conservation and other concepts to reduce total project emissions. These recommendations are not all inclusive and are provided as examples among many possibilities.
3.4.2 Ozone Precursor (ROG + NOx) Emissions
+ NOx emissions) no ozone mitigation measures are necessary. The Lead Agency will prepare the appropriate, required environmental document(s).
If all feasible mitigation measures are incorporated into the project and emissions can be reduced to less than 25 lbs/day, then the Lead Agency will prepare the appropriate, required environmental document(s).
If all feasible mitigation measures are incorporated into the project and emissions are still greater than 25 lbs/day, then an ENVIRONMENTAL IMPACT REPORT should be prepared. Additional mitigation measures, including off-site mitigation, may be required depending on the level and scope of air quality impacts identified in the EIR.
3.4.3 Diesel Particulate Matter (DPM) Emissions
Diesel particulate matter (DPM) is seldom emitted from individual projects in quantities which lead to local or regional air quality attainment violations. DPM is, however, a toxic air contaminant and carcinogen, and exposure DPM may lead to increased cancer risk and respiratory problems. Certain industrial and commercial projects may emit substantial quantities of DPM through the use of stationary and mobile on-site diesel-powered equipment as well diesel trucks and other vehicles that serve the project.
Projects that emit more than 1.25 lbs/day of DPM need to implement on-site Best Available Control Technology measures. If sensitive receptors are within 1,000 feet of the project site, a Health Risk Assessment (HRA) may also be required. Sections 3.5.1 and 3.6.4 of this Handbook provide more background on HRAs in conjunction with CEQA review. Guidance on the preparation of a HRA may be found in the CAPCOA report HEALTH RISK ASSESSMENT FOR PROPOSED LAND USE PROJECTS
which can be downloaded from the CAPCOA website at www.capcoa.org.
3.4.4 Fugitive Particulate Matter (Dust) Emissions
Projects which emit more than 25 lbs/day or 25 tons/year of fugitive particulate matter need to implement permanent dust control measures to mitigate the emissions below these thresholds or provide suitable off-site mitigation approved by the APCD. Operational fugitive dust emissions from a proposed project are calculated using the URBEMIS model discussed in Section 3.6.1. Typical sources of operational emissions included the following:
Any of the above referenced land uses or activities can result in dust emissions that exceed the APCD significance thresholds, cause violations of an air quality standard, or create a nuisance impact in violation of APCD Rule 402 Nuisance. In all cases where such impacts are predicted, appropriate fugitive dust mitigation measures shall be implemented.
3.4.5 Carbon Monoxide (CO) Emissions
Carbon monoxide is a colorless, odorless, tasteless gas emitted during combustion of carbon-based fuels. While few land use projects result in high emissions of CO, this pollutant is of particular concern when emitted into partially or completely enclosed spaces such as parking structures and garages. Projects which emit more than 550 lbs/day of carbon monoxide (CO) and occur in a confined or semi-confined space (e.g., parking garage or enclosed indoor stadium) must be modeled to determine their significance. In confined or semi-confined spaces where vehicle activity occurs, CO modeling is required. If modeling shows the potential to violate the State CO air quality standard, mitigation or project redesign is required to reduce CO concentrations to a level below the health-based standard.
3.4.6 Greenhouse Gas Emissions
The SLO County APCD has not yet established significance thresholds for greenhouse gas emissions from project operations. Nonetheless, GHGs (CO2 and CH4) from all projects subject to CEQA must still be quantified and mitigated to the extent feasible. The California Office of Planning and Research has provided the following direction for the assessment and mitigation of GHG emissions:
3.5 SPECIAL CONDITIONS
Projects may require additional assessments as described in the following section.
3.5.1 Toxic Air Contaminants
Health Risk Assessments
If a project has the potential to emit toxic or hazardous air pollutants, or is located in close proximity to sensitive receptors, impacts may be considered significant due to increased cancer risk for the affected population, even at a very low level of emissions. Such projects may be required to prepare a risk assessment to determine the potential level of risk associated with their operations. The SLO County APCD should be consulted on any project with the potential to emit toxic or hazardous air pollutants. Pursuant to the requirements of California Health and Safety Code Section 42301.6 (AB 3205) and Public Resources Code Section 21151.8, subd. (a)(2), any new school, or proposed industrial or commercial project site located within 1000 feet of a school must be referred to the SLO County APCD for review.
Further details on requirements for projects in this category are presented in Section 4.1.
In April of 2005, the California ARB issued the AIR QUALITY AND LAND USE HANDBOOK: A COMMUNITY HEALTH PERSPECTIVE(Land Use Handbook). The ARB has determined that emissions from sources such as roadways and distribution centers and, to a lesser extent gas stations, certain dry cleaners, marine ports and airports as well as refineries can lead to unacceptably high health risk from diesel particulate matter and other toxic air contaminants (TACs). Groups such as children and the elderly, as well as long-term residential occupants, are particularly at risk from toxic exposure.
In July 2009, the California Air Pollution Control officers Associations (CAPCOA) adopted a guidance document HEALTH RISK ASSESSMENTS FOR PROPOSED LAND USE PROJECTSto provide uniform direction on how to assess the health risk impacts from and to proposed land use projects. The CAPCOA guidance document focuses on how to identify and quantify the potential acute, chronic, and cancer impacts of sources under CEQA review. It also outlines the recommended procedures to identify when a project should undergo further risk evaluation, how to conduct the health risk assessment (HRA), how to engage the public, what to do with the results from the HRA, and what mitigation measures may be appropriate for various land use projects.
As defined in the CAPCOA guidance document there are basically two types of land use projects that have the potential to cause long-term public health risk impacts:
Air districts across California are uniform in their recommendation to use the significance thresholds that have been established under each district’s “Hot Spots” and permitting programs. The APCD has defined the excess cancer risk significance threshold at 10 in a million for Type A projects in SLO County; and,
a CEQA health risk threshold of 89 in-a-million for the analysis of projects proposed in close proximity to toxic sources. This value represents the population weighted average health risk caused by ambient background concentrations of toxic air contaminants in San Luis Obispo County. The APCD recommends Health Risk screening and, if necessary, Health Risk Assessment (HRA) for any residential or sensitive receptor development proposed in proximity to toxic sources.
If a project is located near a sensitive receptor (e.g., school, hospital, dwelling unit(s), etc.), it may be considered significant even if other criteria do not apply. The health effects of a project’s emissions may be more pronounced if they impact a considerable number of children, elderly, or people with compromised respiratory or cardiac conditions.
Diesel PM
In October of 2000, the ARB issued and adopted the Diesel Risk Reduction Plan to reduce particulate matter emissions from diesel-fueled engines and vehicles. This plan identified that 70% of the airborne toxic risk in California is from diesel particulate matter.
The plan called for a 90% reduction in this Toxic Air Contaminant by 2020 through:
At a minimum, fleets must meet the diesel emission reduction requirements that have been adopted in the State’s Diesel Risk Reduction Plan. These fleets may also be required to provide additional mitigation depending on the project’s emissions and location.
Asbestos / Naturally Occurring Asbestos
Naturally occurring asbestos (NOA) has been identified by the state Air Resources Board as a toxic air contaminant. Serpentine and ultramafic rocks are very common throughout California and may contain naturally occurring asbestos. The SLO County APCD has identified areas throughout the County where NOA may be present (see Technical Appendix 4.4). Under the ARB’s Air Toxic Control Measure (ATCM) related to quarrying, and surface mining operations, a geologic evaluation is required to determine if NOA is present prior to any grading activities at a project site located in the candidate area.
If NOA is found at the site the applicant must comply with all requirements outlined in the Asbestos ATCM for Quarrying, and Surface Mining Operations. These requirements may include but are not limited to:
If NOA is not present, an exemption request must be filed with the Air District. More information on NOA can be found at http://www.slocleanair.org/business/asbestos.asp.
3.5.2 Agricultural Operations
Wineries, Tasting Rooms and Special Events
Reactive organic gas emissions (ethanol) generated during wine fermentation and storage, as well as emissions from equipment used in wine production, can cause significant air quality impacts. Thus, the emissions for new or modified winery operations and activities should be evaluated and appropriate mitigation specified when necessary. New or expanding wineries with storage capacity of 26,000 gallons per year or more may also require a Permit to Operate from the APCD.
Wine production facilities can also generate nuisance odors during various steps of the process. Proven methods for handling wastewater discharge and grape skin waste need to be incorporated into the winery practices to minimize the occurrence of anaerobic processes that mix with ambient air which can result in offsite nuisance odor transport. Odor complaints could result in a violation of the SLO County APCD Rule 402 Nuisance.
Agricultural Burns
Agricultural operations must obtain an APCD Agricultural Burn Permit to burn dry agricultural vegetation on Permissive Burn Days. The ARB provides educational handbooks on agricultural burning (English and Spanish) to growers which are available at the following websites:
-www.arb.ca.gov/cap/handbooks/agburningsmall.pdf
-www.arb.ca.gov/cap/handbooks/agburningspanishsmall.pdf.
3.5.3 Fugitive Dust
Fugitive dust can come from many sources, such as unpaved roads, equestrian facilities and confined animal feeding operations. Dust emissions from the operational phase of a project should be managed to ensure they do not impact offsite areas and do not exceed the 20% opacity limit identified in SLO County APCD Rule 401 Visible Emissions. A list of approved dust control suppressants is available in Technical Appendix 4.3. The approved suppressants must be reapplied at a frequency that ensures dust emissions will not exceed the limits stated above. Any chemical or organic material used for stabilizing solids shall not violate the California State Water Quality Control Board standards for use as a soil stabilizer. Any dust suppressant must not be prohibited for use by the US Environmental Protection Agency, the California Air Resources Board, or other applicable law, rule, or regulation.
Equestrian Facilities
Another potential source of fugitive dust can come from equestrian facilities, which may be a nuisance to local residents. To minimize nuisance impacts and to reduce fugitive dust emissions from equestrian facilities the following mitigation measures should be incorporated into the project:
Reclaimed (non-potable) water shall be used whenever possible;
holidays and weekend. The name and telephone number of such persons shall be provided to the Air District prior to operation of the arena.
Dirt Roads and Unpaved Areas
When a project is accessed by unpaved roads and or has unpaved driveways or parking areas, a PM10 emission estimate needs to be conducted using the URBEMIS model. When the model’s emission estimate demonstrates an exceedance of the 25 lbs of PM10/day or 25 tons of PM10/year APCD thresholds, the following mitigation is required:
For the unpaved road leading to the project location, implement one of the following:
To improve the dust suppressant’s long-term efficacy, the applicant shall also implement and maintain design standards to ensure vehicles that use the on-site unpaved road are physically limited (e.g., speed bumps) to a posted speed limit of 15 mph or less.
If the project involves a city or county owned and maintained road, the applicant shall work with the Public Works Department to ensure road standards are followed. The applicant may propose other measures of equal effectiveness as replacements by contacting the APCD Planning Division.
Special Event Mitigation
When a special event is accessed by unpaved roads and or has unpaved driveways or parking areas, a PM10 emission estimate must to be conducted using the URBEMIS model. If the model shows an exceedance of the 25 lbs/day of PM10 significance threshold, the following mitigation is required on the day(s) of the special event:
The applicant may propose alternative measures of equal effectiveness by contacting the APCD Planning Division.
3.5.4 Air Quality Nuisance Impacts
If a project has the potential to cause an odor or other nuisance problem which could impact a considerable number of people, then it may be considered significant. A project may emit a pollutant in concentrations that would not otherwise be significant except as a nuisance. Odor impacts on residential areas and other sensitive receptors warrant the closest scrutiny, but consideration should also be given to
other land uses where people may congregate, such as recreational facilities, work sites and commercial areas.
When making a determination of odor significance, determine whether the project would result in an odor source located next to potential receptors within the distances indicated in Table 3-3. The Lead Agency should evaluate facilities not included in Table 3-3 or projects separated by greater distances than indicated in Table 3-3 if warranted by local conditions or special circumstances. The list is provided as a guide and, as such, is not all-inclusive.
If a project is proposed within the screening level distances in Table 3-3, the APCD Enforcement Division should be contacted for information regarding potential odor problems. For projects that involve new receptors located near an existing odor source(s), an information request should be submitted to the SLO County APCD to review the inventory of odor complaints for the nearest odor emitting facility(ies) during the previous three years. For projects involving new receptors to be located near an existing odor source where there is currently no nearby development, and for new odor sources locating near existing receptors, the information request and analysis should be based on a review of odor complaints for similar facilities.
Table 3-3: Project Screening Distances for Nuisance Sources
PROJECT SCREENING DISTANCES |
|
Type of Operation |
Project Screening Distance |
Asphalt Batch Plant |
1 mile |
Chemical Manufacturing |
1 mile |
Coffee Roaster |
1 mile |
Composting Facility |
1 mile |
Fiberglass Manufacturing |
1 mile |
Food Processing Facility |
1 mile |
Oil Field |
1 mile |
Painting/Coating Operations (e.g. auto body shops) |
1 mile |
Petroleum Refinery |
2 miles |
Rendering Plant |
1 mile |
Sanitary Landfill |
1 mile |
Transfer Station |
1 mile |
Wastewater Treatment Plant |
1 mile |
Note: This list is provided as a guide and is not all-inclusive.
For a project that will be located near an existing odor source the project should be identified as having a significant odor impact, if it will be as close or closer to the any location that has experienced: 1) more than one confirmed complaint per year averaged over a three year period, or 2) three unconfirmed complaints per year averaged over a three year period.
If a proposed project is determined to result in potential odor problems, mitigation measures should be identified. For some projects, add-on controls or process changes, such as carbon absorption, incineration or an engineering modification to stacks/vents, can reduce odorous emissions. In many cases, however, the most effective mitigation strategy is the provision of a sufficient distance, or buffer zone, between the source and the receptor(s).
The SLO County APCD should be consulted whenever any of these additional special conditions may be applicable for a proposed project.
3.6 METHODS FOR CALCULATING PROJECT OPERATIONAL EMISSIONS
Operational phase air pollutant emissions from urban development can result from a variety of sources, including motor vehicles, wood burning appliances, natural gas and electric energy use, combustion- powered utility equipment, paints and solvents, equipment or operations used by various commercial and industrial facilities, construction and demolition equipment and operations, and various other sources.
The amount and type of emissions produced, and their potential to cause significant impacts, depends on the type and level of development proposed. The following sections describe the recommended methods generally used to calculate emissions from motor vehicles, congested intersections and roadways, non- vehicular sources at residential and commercial facilities, and industrial point and area sources.
Calculation and mitigation of construction emissions are described separately in Chapter 2.
Submittals describing project assessments must include spreadsheets with project calculations and a description of calculations so that the APCD can verify project quantification. Calculations must be based on San Luis Obispo County default conditions unless the default settings are not representative of the project (see below). The project report must clearly state assumptions and sample calculations.
3.6.1 Determining Motor Vehicle Emissions
Motor vehicles are a primary source of long-term emissions from many residential, commercial, institutional, and industrial land uses. These land uses often do not emit significant amounts of air pollutants directly, but cause or attract motor vehicle trips that do produce emissions. Such land uses are referred to as indirect sources.
Motor vehicle emissions associated with indirect sources should be calculated for projects which exceed the screening criteria listed in Table 1-1. Calculations should be performed using the latest version of URBEMIS; this software incorporates the most recent vehicle emission factors from the EMFAC model (i.e., EMission FACtors) provided by the California Air Resources Board (ARB), and trip generation factors published by the Institute of Transportation Engineers (ITE). The latest version of this program should always be used and can be downloaded free of charge at www.urbemis.com.
URBEMIS is a planning tool for estimating vehicle travel, fuel use and resulting emissions related to land use projects throughout California. The model calculates emissions of ROG, CO, CO2, NOx, and GHGs as well as dust and exhaust PM10 from vehicle use associated with new or modified development such as shopping centers, housing, commercial services and industrial land uses. The model does not calculate emissions associated with idling, so for projects with significant idling (e.g., drive-through operations) further calculations are warranted to quantify the project’s full motor vehicle impacts. The model also does not fully calculate the GHG emissions associated with electricity and water usage.
URBEMIS includes many default values for parameters such as
Many of these values are specific to SLO County. When modeling project emissions with URBEMIS, the user must specify that the project is located in SLO County so that the appropriate default values are used for the modeling. Motor vehicle-related defaults should not be changed without justification for doing so; documentation and rationale for any changes made should be provided to APCD as part of the air quality report. Defaults that need to be evaluated and modified based on the project location and specifications include:
the URBEMIS Year and Vehicle Fleet component. Examples include large commercial retail with heavy on-road truck use and heavy industry.
In general, the total distance of dirt road driving (miles) shall be divided by the county average one way trip distance of 13 miles to determine the percentages of paved and unpaved road distances to be entered into the URBEMIS Operational Road Dust Settings, Entrained Road Dust Emissions tab. In the Unpaved Road Dust Emission tab, the California ARB Emission Factor for PM needs to be selected – this factor is preferred by SLO County APCD and air districts throughout California.
If the project has a total distance of unpaved road greater than 13 miles, the actual distance of the dirt road should be compared to the total trip length to determine the percentages of paved and unpaved road distances. In addition, the Trip Length in the URBEMIS Operational Trip Characteristics section needs to be changed to the total length of a one way trip for the project.
URBEMIS reports submitted as part of a CEQA evaluation need to include the following:
3.6.2 Non-Vehicular Emissions from Residential and Commercial Facilities
Non-vehicular emission sources associated with most residential and commercial development include energy use to power lights, appliances, heating and cooling equipment, evaporative emissions from paints and solvents, fuel combustion by lawnmowers, leaf blowers and other small utility equipment, residential wood burning, household products, and other small sources. Collectively, these are referred to as “area sources” and are important from a cumulative standpoint even though they may appear insignificant when viewed individually, The URBEMIS model provides emissions estimations from area sources based on land use types; however it underestimates all emissions associated with electricity use and water consumption.
One URBEMIS default area source value which has a significant impact on project emissions and may need to be changed is hearth fuel combustion – it is enabled by default and should be disabled or modified if the project excludes wood-burning devices.
3.6.3 Industrial Emission Sources
From an emissions standpoint, industrial facilities and operations are typically categorized as being “point” or “area” sources. Point sources are stationary and generally refer to a site that has one or more emission sources at a facility with an identified location (e.g., power plant, refinery, etc.). Area sources can be:
Emissions from new, modified or relocated point sources are directly regulated through the APCD Rule 204 New Source Review requirements and facility permitting program. A general list of the type of sources affected by these requirements is provided in Section 4.1. New development that includes these source types should be forwarded to the SLO County APCD for a determination of APCD permitting and control requirements. Through the CEQA analysis, all air quality impacts are evaluated including the stationary point, area and mobile sources. While a specific piece of equipment or process may be covered by an APCD permit it is not excluded from the CEQA evaluation process.
3.6.4 Health Risk Assessment
Health risk is a common metric used by air quality and health scientists to describe the potential for an individual or group of people (population) in a given area to suffer serious health effects from long-term or short-term exposure to one or more toxic air contaminants (TACs). In July 2009, the California Air Pollution Control officers Association (CAPCOA) released a guidance document titled HEALTH RISK ASSESSMENT FOR LAND USE PROJECTS, which is available for download at www.capcoa.org.
Attachment 1 of the CAPCOA document provides specific guidance on how to model emissions of toxic substances from various source types to determine the potential cancer risk as well as acute and chronic non-cancer health risks for nearby receptors.
A screening-level and/or refined health risk assessment (HRA) may be required for projects which may result in the exposure of sensitive receptors (e.g., school, hospital, dwelling unit(s), etc.) to TACs.
Projects which involve the siting of either the TAC source itself or sensitive receptors in close proximity to a TAC should be evaluated for risk exposure. Various tools are available to perform a screening analysis from stationary sources impacting receptors (Type A projects).
For projects being impacted by existing sources (Type B projects), a distance table screening tool is available in the ARB Land Use Handbook which provides recommended buffer distances associated with types of most common toxic air contaminant sources (see Technical Appendix 4.2).
If a screening risk assessment shows that the potential risk exceeds the APCD’s thresholds, then a more refined analysis may be required. The assessment should include the evaluation of both mobile and stationary sources. Risk assessments are normally prepared in a tiered manner, where progressively more input data is collected to refine the results. The refined analysis for the project should provide more accurate information for decision makers.
3.6.5 Greenhouse Gas Emissions
To quantify GHG emissions from a proposed development, the APCD recommends using URBEMIS for mobile sources and a partial characterization of area source impacts. This model is limited in its capabilities to assess the full GHG impacts such as from idling, energy usage and water consumption. In certain cases (e.g., drive-through restaurants), the use of alternative methodologies to quantify GHG impacts will be required. Please consult APCD Planning Division staff for current calculation methods.
3.7 OPERATIONAL EMISSION MITIGATION
Emissions from motor vehicles that travel to and from residential, commercial, and industrial land uses can generally be mitigated by reducing vehicle activity through site design (e.g., transit oriented design, infill, mixed use, etc.), implementing transportation demand management measures, using clean fuels and vehicles, and/or off-site mitigation. In addition, area source operational emissions from energy consumption from land uses can be mitigated by improving energy efficiencies, conservation measures and use of alternative energy sources. The mitigation measures in this section are intended to reduce
emissions of ROG, NOx, Diesel PM (DPM), Dust PM, and GHGs. The following three categories best capture the types of mitigation measures that can reduce air quality impacts from project operations:
3.7.1 Guidelines for Applying ROG, NOx and PM10 Mitigation Measures
In general, projects which do not exceed the 25 lb/day ROG+NOx threshold do not require mitigation. For projects which exceed this threshold, the SLO County APCD has developed a list of mitigation strategies for residential, commercial and industrial projects. Alternate mitigation measures may be suggested by the project proponent if the APCD-suggested measures are not feasible. Project mitigation recommendations should follow the guidelines listed below and summarized in Table 3-4:
Table 3-4: Mitigation Threshold Guide
Combined ROG+NOx or PM10 Emissions (lbs/day) |
Mitigation Measures Recommended |
|
Residential, Commercial or Industrial |
Off-Site Mitigation |
|
< 25 |
None |
None |
25 – 29 |
8 |
* |
30 – 34 |
14 |
* |
35 – 50 |
18 |
* |
³ 50 |
All Feasible |
* |
³ 25 ton/yr |
All Feasible |
Yes |
* Will be dependent on the effectiveness of the mitigation measures, location of project and high vehicle dependent development. Examples of projects potentially subject to off-site mitigation include: rural subdivisions, drive-through applications, commercial development located far from urban core.
3.7.2 Standard Mitigation Measures
The recommended standard air quality mitigation measures have been separated according to land use (i.e., residential, commercial and industrial), measure type (i.e., site design, energy efficiency and transportation) and pollutant reduced (i.e., ozone, particulate, diesel PM, and GHGs). Any project generating 25 lbs/day or more of ROG + NOx or PM10 should select the applicable number of mitigation measure as outlined above from Table 3-5 to reduce the air quality impacts from the project below the significance thresholds. This table also provides recommended mitigations for diesel PM and GHG emissions. For projects that exceed the DPM threshold (i.e., 1.25 lbs/day) due to significant diesel vehicle activity (e.g., mining operations, distribution facilities, etc), project emissions must be recalculated to demonstrate that the project emissions are below the APCD DPM threshold of significance when mitigation measures are included.
Table 3-5: Mitigation Measures
LAND USE Residential (R) Commercial (C) Industrial (I) |
Measure Type |
MITIGATION MEASURE |
POLLUTANT REDUCED Ozone (O) Particulate (P) Diesel Particulate Matter (DPM) Greenhouse Gas (GHG) |
R, C, I |
Site design, Transportation |
Improve job / housing balance opportunities within communities. |
O, P, GHG |
R, C, I |
Site design |
Orient buildings toward streets with automobile parking in the rear to promote a pedestrian-friendly environment. |
O, P, GHG |
R, C, I |
Site design |
Provide a pedestrian-friendly and interconnected streetscape to make walking more convenient, comfortable and safe (including appropriate signalization and signage). |
O, P, GHG |
R, C, I |
Site design |
Provide good access to/from the development for pedestrians, bicyclists, and transit users. |
O, P, GHG |
R, C, I |
Site design |
Incorporate outdoor electrical outlets to encourage the use of electric appliances and tools. |
O, P, GHG |
R, C, I |
Site design |
Provide shade tree planting in parking lots to reduce evaporative emissions from parked vehicles. Design should provide 50% tree coverage within 10 years of construction |
O P GHG |
LAND USE Residential (R) Commercial (C) Industrial (I) |
Measure Type |
MITIGATION MEASURE |
POLLUTANT REDUCED Ozone (O) Particulate (P) Diesel Particulate Matter (DPM) Greenhouse Gas (GHG) |
|
|
using low ROG emitting, low maintenance native drought resistant trees.2 |
|
R, C, I |
Site design |
Pave and maintain the roads and parking areas |
P |
R, C, I |
Site design |
Driveway design standards (e.g., speed bumps, curved driveway) for self-enforcing of reduced speed limits for unpaved driveways. |
P |
R, C, I |
Site design |
Use of an APCD-approved suppressant on private unpaved roads leading to the site, unpaved driveways and parking areas; applied at a rate and frequency that ensures compliance with APCD Rule 401, visible emissions and ensures offsite nuisance impacts do not occur. |
P |
R, C |
Site design |
Development is within 1/4 mile of transit centers and transit corridors. |
O, P, GHG |
R, C |
Site design |
Design and build compact communities in the urban core to prevent sprawl. |
O, P, GHG |
R, C |
Site design |
Increase density within the urban core and urban reserve lines. |
O, P, GHG |
R, C |
Site design |
For projects adjacent to high-volume roadways or railroad idling zones, design project to include provide effective buffer zone between the source and the receptor. |
DPM |
R, C |
Site design |
For projects adjacent to high-volume roadways, plant vegetation3 between receptor and roadway. |
DPM, P |
R |
Site design |
No residential wood burning appliances. |
O, P, GHG |
R, C, I |
Site design, Transportation |
Incorporate traffic calming modifications to project roads, such as narrower streets, speed platforms, bulb-outs and intersection designs that reduce vehicles speeds and encourage pedestrian and bicycle travel. |
O, P, GHG |
R, C, I |
Site design, Transportation |
Increase number of connected bicycle routes/lanes in the vicinity of the project. |
O, P, GHG |
R, C, I |
Site design, Transportation |
Provide easements or land dedications and construct bikeways and pedestrian walkways. |
O, P, GHG |
R, C, I |
Site design, Transportation |
Link cul-de-sacs and dead-end streets to encourage pedestrian and bicycle travel to adjacent land uses. |
O, P, GHG |
R, C, I |
Site design, Transportation |
Project is located within one-half mile of a ‘Park and Ride’ lot or project installs a ‘Park and Ride’ lot with bike lockers in a location of need defined by SLOCOG. |
O, P, GHG |
C, I |
Site design, Transportation |
Provide onsite housing for employees. |
O, P, GHG |
C, I |
Site design, Transportation |
Implement on-site circulation design elements in parking lots to reduce vehicle queuing and improve the pedestrian environment. |
O, P, GHG |
C, I |
Site design, Transportation |
Provide employee lockers and showers. One shower and 5 lockers for every 25 employees are recommended. |
O, P, GHG |
C, I |
Site design, Transportation |
Parking space reduction to promote bicycle, walking and transit use. |
O, P, GHG |
R |
Site design |
Tract maps resulting in parcels of one-half acre or les shall orient at least 75% of all lot lines to create easy due south orientation of future structures. |
GHG |
R |
Site design |
Trusses for south-facing portions of roofs shall be designed to handle dead weight loads of standard solar-heated water and photovoltaic panels. Roof design shall include sufficient south- facing roof surface, based on structures size and use, to accommodate adequate solar panels. For south facing roof pitches, the closest standard roof pitch to the ideal average |
O, GHG |
2 Trees must be maintained for life of project
3 Certain types of vegetation provide maximum effectiveness. Vegetation must be maintained over the life of the project.
LAND USE Residential (R) Commercial (C) Industrial (I) |
Measure Type |
MITIGATION MEASURE |
POLLUTANT REDUCED Ozone (O) Particulate (P) Diesel Particulate Matter (DPM) Greenhouse Gas (GHG) |
|
|
solar exposure shall be used. |
|
R, C, I |
Energy efficiency |
Increase the building energy rating by 20% above Title 24 requirements. Measures used to reach the 20% rating cannot be double counted. |
O, GHG |
R, C, I |
Energy efficiency |
Plant drought tolerant, native shade trees along southern exposures of buildings to reduce energy used to cool buildings in summer.4 |
O, GHG |
R, C, I |
Energy efficiency |
Utilize green building materials (materials which are resource efficient, recycled, and sustainable) available locally if possible. |
O, DPM, GHG |
R, C, I |
Energy efficiency |
Install high efficiency heating and cooling systems. |
O GHG |
R, C, I |
Energy efficiency |
Orient 75 percent or more of homes and/or buildings to be aligned north / south to reduce energy used to cool buildings in summer. |
O GHG |
R, C, I |
Energy efficiency |
Design building to include roof overhangs that are sufficient to block the high summer sun, but not the lower winter sun, from penetrating south facing windows (passive solar design). |
O, GHG |
R, C, I |
Energy efficiency |
Utilize high efficiency gas or solar water heaters. |
O, P, GHG |
R, C, I |
Energy efficiency |
Utilize built-in energy efficient appliances (i.e. Energy Star®). |
O, P GHG |
R, C, I |
Energy efficiency |
Utilize double-paned windows. |
O, P, GHG |
R, C, I |
Energy efficiency |
Utilize low energy street lights (i.e. sodium). |
O, P, GHG |
R, C, I |
Energy efficiency |
Utilize energy efficient interior lighting. |
O, P, GHG |
R, C, I |
Energy efficiency |
Utilize low energy traffic signals (i.e. light emitting diode). |
O, P, GHG |
R, C, I |
Energy efficiency |
Install door sweeps and weather stripping (if more efficient doors and windows are not available). |
O, P, GHG |
R, C, I |
Energy efficiency |
Install energy-reducing programmable thermostats. |
O, P, GHG |
R, C, I |
Energy efficiency |
Participate in and implement available energy-efficient rebate programs including air conditioning, gas heating, refrigeration, and lighting programs. |
O, P, GHG |
R, C, I |
Energy efficiency |
Use roofing material with a solar reflectance values meeting the EPA/DOE Energy Star® rating to reduce summer cooling needs. |
O, P, GHG |
R, C, I |
Energy efficiency |
Utilize onsite renewable energy systems (e.g., solar, wind, geothermal, low-impact hydro, biomass and bio-gas). |
O, P, GHG |
R, C, I |
Energy efficiency |
Eliminate high water consumption landscape (e.g., plants and lawns) in residential design. Use native plants that do not require watering and are low ROG emitting. |
O, GHG |
R, C, I |
Energy efficiency |
Provide and require the use of battery powered or electric landscape maintenance equipment for new development. |
O, GHG |
C, I |
Energy efficiency |
Use clean engine technologies (e.g., alternative fuel, electrification) engines that are not subject to regulations. |
O, DPM, GHG |
R, C, I |
Transportation |
Provide and maintain a kiosk displaying transportation information in a prominent area accessible to employees and patrons. |
O, P, GHG |
4 Trees must be maintained for the life of the project
LAND USE Residential (R) Commercial (C) Industrial (I) |
Measure Type |
MITIGATION MEASURE |
POLLUTANT REDUCED Ozone (O) Particulate (P) Diesel Particulate Matter (DPM) Greenhouse Gas (GHG) |
R, C, I |
Transportation |
Develop recreational facility (e.g., parks, gym, pool, etc.) within one-quarter of a mile from site. |
O, P, GHG |
R, C, I |
Transportation |
If the project is located on an established transit route, provide improved public transit amenities (i.e., covered transit turnouts, direct pedestrian access, covered bench, smart signage, route information displays, lighting etc.). |
O, P, GHG |
R, C, I |
Transportation |
Project provides a display case or kiosk displaying transportation information in a prominent area accessible to employees or residents. |
O, P, GHG |
R, C, I |
Transportation |
Provide electrical charging station for electric vehicles. |
O, P, GHG |
R, C, I |
Transportation |
Provide neighborhood electric vehicles / car share program for the development. |
O, P, GHG |
R, C, I |
Transportation |
Provide bicycle-share program for development. |
O, P, GHG |
R, C, I |
Transportation |
Provide preferential parking / no parking fee for alternative fueled vehicles or vanpools. |
O, P, GHG |
R, C, I |
Transportation |
Provide bicycle lockers for existing ‘Park and Ride’ lots where absent or insufficient. |
O, P, GHG |
R C I |
Transportation |
Provide vanpool, shuttle, mini bus service (alternative fueled preferred). |
O, P, DPM, GHG |
C, I |
Transportation |
Provide secure on-site bicycle indoor storage, lockers, or racks. |
O, P, GHG |
C, I |
Transportation |
For large developments, provide day care facility on site. |
O, P, GHG |
C, I |
Transportation |
Provide on-site bicycle parking both short term (racks) and long term (lockers, or a locked room with standard racks and access limited to bicyclist only) to meet peak season maximum demand. One bike rack space per 10 vehicle/employee space is recommended. |
O, P, GHG |
C, I |
Transportation |
On-site eating, refrigeration and food vending facilities |
O, P, GHG |
C, I |
Transportation |
Implement a Transportation Choice Program to reduce employee commute trips. The applicant shall work with Rideshare for free consulting services on how to start and maintain a program. |
O, P, GHG |
C, I |
Transportation |
Provide incentives (e.g., bus pass, “Lucky Bucks”, etc.) to employees to carpool/vanpool, take public transportation, telecommute, walk bike, etc. |
O, P, GHG |
C, I |
Transportation |
Implement compressed work schedules (i.e., 9–80s or 4–10s). |
O, P, GHG |
C, I |
Transportation |
Implement a telecommuting program. |
O, P, GHG |
C, I |
Transportation |
Implement a lunchtime shuttle to reduce single occupant vehicle trips. |
O, P, GHG |
C, I |
Transportation |
Include teleconferencing capabilities, such as web cams or satellite linkage, which will allow employees to attend meetings remotely without requiring them to travel out of the area. |
O, P, DPM, GHG |
C, I |
Transportation |
If the development is or contains a grocery store or large retail facility, provide customers home delivery service in clean fueled vehicles |
O, P, DPM, GHG |
C, I |
Transportation |
At community event centers (i.e., amphitheaters, theaters, and stadiums) provide valet bicycle parking. |
O, P, GHG |
C, I |
Transportation |
Implement a “No Idling” program for heavy-duty diesel vehicles, which includes signage, citations, etc. |
DPM, GHG |
C, I |
Transportation |
Develop satellite work sites. |
O, GHG |
C, I |
Transportation |
Require the installation of electrical hookups at loading docks and the connection of trucks equipped with electrical hookups to eliminate the need to operate diesel-powered TRUs at the |
DPM, GHG |
LAND USE Residential (R) Commercial (C) Industrial (I) |
Measure Type |
MITIGATION MEASURE |
POLLUTANT REDUCED Ozone (O) Particulate (P) Diesel Particulate Matter (DPM) Greenhouse Gas (GHG) |
|
|
loading docks. |
|
C, I |
Transportation |
If not required by other regulations (ARB’s on-road or off- road diesel), restrict operation to trucks with 2007 model year engines or newer trucks. |
O, DPM, GHG |
C, I |
Transportation |
If not required by other regulations (ARB’s on-road or off- road diesel), require or provide incentives to use diesel particulate filters for truck engines. |
DPM |
R |
Transportation |
Provide storage space in garage for bicycle and bicycle trailers, or covered racks / lockers to service the residential units. |
O, P, GHG |
R |
Transportation |
Provide free-access telework terminals and/or wi-fi access in multi-family projects. |
O, P, GHG |
C |
Transportation |
Develop core commercial areas within 1/4 to 1/2 miles of residential housing or industrial areas. |
O, P, GHG |
3.7.3 Off-Site Mitigation
Operational phase emissions from large development projects that cannot be adequately mitigated with on-site mitigation measures alone will require off-site mitigation in order to reduce air quality impacts to a level of insignificance if emissions cannot be adequately mitigated with on-site mitigation measures alone. Whenever off-site mitigation measures are deemed necessary, it is important that the developer, lead agency and APCD to work together to develop and implement the measures to ensure successful outcome. This work should begin at least six months prior to issuance of occupancy permits for the project.
The first step in determining whether off-site mitigation is required is to compare the estimated operational phase emissions to the APCD significance thresholds. If the sum of ROG + NOx emissions exceeds 25 tons/year, off-site mitigation will be required. Off-site mitigation may also be required for development projects were emissions exceed the 25 lb/day threshold. Examples of projects potentially subject to off-site mitigation include rural subdivisions, drive-through facilities and commercial development located far from the urban core.
If off-site mitigation is required, potential off-site mitigation measures may be proposed and implemented by the project proponent following APCD approval of the appropriateness and effectiveness of the proposed measure(s). Alternatively, the project proponent can pay a mitigation fee based on the amount of emission reductions needed to bring the project impacts below the applicable significance threshold.
The APCD shall use these funds to implement a mitigation program to achieve the required reductions. The following outlines how to calculate the amount of off-site mitigation fees required for a given project:
Off-site emission reductions can result from either stationary or mobile sources, but should relate to the on-site impacts from the project in order to provide proper “nexus” for the air quality mitigation. For example, NOx emissions from increased vehicle trips from a large residential development could be reduced by funding the expansion of existing transit services in close proximity to the development project to reduce NOx emissions. An off-site mitigation strategy should be developed and agreed upon by all parties prior to the start of construction.
The off-site mitigation strategies include but are not limited to the list provided below:
3.8 EVALUATION OF PROJECT CHANGES
If the scope or project description is modified after final project approval, the project will need to be re- evaluated by the APCD to determine if additional air quality impacts will result from the proposed modifications. If additional impacts are expected, the cumulative impacts from the total project must be evaluated.
5 Cost-effectiveness is a measure of the dollars needed to reduce a ton of emissions. The cost-effectiveness used to calculate off-site mitigation is based on the Carl Moyer Grant Program and is updated on a periodic basis. The Carl Moyer cost effectiveness value as of 2009 is $16,000 per ton. There will be a 10% administration fee charged for grant administration.
3.9 MITIGATION MONITORING
In order to ensure the operational phase air quality mitigation measures and project revisions identified in the EIR or mitigated negative declarations are implemented, the APCD may conduct site visits to ensure that the mitigation measures are fully implemented. The lead agency may also review project mitigation for consistency with project conditions. Beyond verifying mitigation implementation, this monitoring can result in compliance requirements if mitigation measures are not sufficiently being implemented.
4 TECHNICAL APPENDICES
4.1 BUILDING PERMIT REQUIREMENTS FOR FACILITIES POTENTIALLY SUBJECT TO AIR DISTRICT PERMITS
The San Luis Obispo County Air Pollution Control District (APCD) regulates stationary sources of air pollution such as factories, industrial sites, and gasoline stations. APCD regulations apply to many manufacturing and industrial procedures as well as such things as evaporative compounds, gasoline, paint, odors, incineration, smoke and open burning.
Government Code section 65850.2 identifies certain air pollution information that cities and counties are required to collect for new building and development projects. Sections 42301.6 to 42301.9 (AB 3205) of the California Health & Safety Code address the release of hazardous air contaminants near schools, and discuss requirements for air district permits for new or modified facilities.
The following overview describes how the law may affect you.
Under the law, final certificates of occupancy may not be issued unless certain requirements are met. One of the requirements is that all applicants must comply with APCD permit regulations, or make a showing to the APCD that the permit regulations do not apply to their particular project.
A questionnaire will accompany all building permit application packets distributed by City and County Planning and Building Departments. This questionnaire pertains to facility location and equipment, processes, and materials which may require an APCD permit This questionnaire should be completed and returned to the Planning and Building Department for initial screening and processing. If an APCD permit is required, and if air emissions occur within 1000 ft. of a school,
focused notification of nearby residents and student’s parents may be required.
All planning and building departments have a description of typical facility types, processes, and equipment that require an APCD Permit to Operate. The table at the back of the attached questionnaire provides a list of these facilities. Operations which usually require an APCD Permit include:
– Solvent cleaners (degreasers)
– Coating of metal parts and products
– Printing and coating operations
– Auto body shops
– Paint spray booths
– Storage of organic liquids
– Wood furniture and cabinet coating
– Air pollution control equipment
– Gasoline stations or any gasoline dispensing facility
– Sandblasting
– Equipment which handles asbestos, beryllium, benzene, hexavalent chromium, mercury, or vinyl chloride.
– Other solvent uses
It should be noted that all residential construction is exempt from these requirements.
If you are unsure whether or not your project is subject to permit requirements, the necessary information can be obtained by contacting the APCD and describing the proposed project. APCD staff can then determine if an application must be filed.
Under the California Health and Safety Code, there are specific requirements which must be met by both the APCD and existing or proposed commercial or industrial facilities near a school.
Upon receipt of the facility operations questionnaire, the APCD will evaluate it for equipment or processes requiring a permit and for proximity to sensitive receptors. This initial screening will occur within fourteen (14) days of
receipt of the questionnaire. The APCD will notify the applicant and the planning agency if further action is necessary under the law and/or the APCD permit process. If no further action is required, then the APCD will sign off on the questionnaire and returning it to the Planning Agency. If hazardous materials may be used at the facility, APCD will also forward it to the Environmental Health Department or, for projects located within the City of San Luis Obispo, the San Luis Obispo Fire Department. If additional action is required under the law or the APCD permitting process, a description of required actions will be included in the letter sent to the planning department and the applicant.
Furthermore, if the principal of a school contacts the APCD to request an investigation of odors or possible air pollution sources as the cause of illness among school children, within 24 hours the APCD must respond and notify the city or county official responsible for administering hazardous materials policy and the fire department having jurisdiction over the school.
For construction of new schools, any person or agency preparing an Environmental Impact Report for a proposed school site must consult with the city, county, and the APCD to identify facilities within one-quarter mile of the proposed school site which may emit hazardous air emissions, or have the potential to explode or catch fire. The city, county, and APCD have 30 days to provide this information to the person or agency seeking it. This requirement is spelled out in the Public Resources Code Sec. 21151.8, Subd.(a) (4).
This handout provides answers to commonly asked questions about new building permit and occupancy requirements. If you need additional information regarding these requirements, please call
(805) 781- 5912.
Under certain conditions, the law requires the APCD to take action when there is a reasonable threat of release of a hazardous air contaminant. APCD action is required if:
When the release of a hazardous air contaminant is forecast, the APCD must notify the agency responsible for administering the hazardous materials policy. In addition, the APCD may respond to this reasonable threat of release by:
FACILITY OPERATIONS QUESTIONNAIRE
For the Incorporated and Unincorporated Areas of San Luis Obispo County
State law (AB 3205) requires an applicant for a commercial/industrial development project, building permit or occupancy permit to provide information to the Air Pollution Control District (APCD) indicating whether hazardous materials or certain equipment or processes will be used in or at the facility. Such uses may require a permit from the APCD and/or a Hazardous Materials Business Plan. This law prohibits a City or County from issuing a final certificate of occupancy until the applicant or future building occupant has complied with the provisions of the law. The law may also impose certain public noticing requirements for a facility that handles hazardous materials and is located within 1,000 feet of the outer boundary of a school (kindergarten through 12th grade). Additional information explaining the requirements of this law is attached to this form.
TO DETERMINE WHETHER YOUR BUSINESS IS SUBJECT TO THESE REQUIREMENTS, PLEASE COMPLETE THIS QUESTIONNAIRE:
Business Name (Doing Business As): |
Contact Person: Phone ( ) |
|
Mailing Address: City State Zip |
||
Nearest Cross Streets: |
||
YES NO
LISTED ON THE ATTACHED LIST? (If YES forward to Air Pollution Control District.) □ □
LISTED ON THE ATTACHED LIST? (If YES forward to Air Pollution Control District.) □ □ |
||
Briefly Describe Nature of the Intended Business Activity: |
||
Name of Owner or Authorized Agent: Title: |
||
I declare under penalty of perjury that, to the best of my knowledge and belief, the responses made herein are true and correct: |
Agency Project ID Number: . |
|
Signature of Owner or Authorized Agent:
Signed: Date: |
Multiple or Unknown Occupants □ Check if Applicable |
|
FOR PLANNING DEPARTMENT USE ONLY
YES NO Forwarded to APCD for processing: □ □ Planning Dept. Official Date |
||
FOR APCD USE ONLY
YES NO FORWARDED TO: YES NO APCD permit required □ □ ENV. HEALTH □ □ Potential hazardous materials □ □ S.L.O. CITY FIRE □ □ Within 1000’ of a school □ □ Public notice required □ □ |
||
PROCESSED AND RETURNED TO PLANNING DEPARTMENT BY:
Air Pollution Control District Official Date |
FINAL CHECK-OFF
Planning Department Official Date |
|
PERMIT CATEGORIES
Businesses with the following equipment, operations or materials will require clearance from the Air Pollution Control District before obtaining a Certificate of Occupancy. Businesses which store, handle, or use hazardous materials will require clearance from the San Luis Obispo City Fire Department or San Luis Obispo County Environmental Health before obtaining a Certificate of Occupancy.
CHEMICALS
Ethylene Oxide Sterilizers Acid Chemical Milling Evaporators, Dryers, and Stills Processing Organic Materials Dry Chemical Mixing and storage
COATINGS AND SURFACE PREPARATION
Abrasive Blasting Equipment Coating and Painting (not house-
painting)
Paint, Stain, and Ink Manufacturing Printers
COMBUSTION
Piston Internal Combustion Engines (50 hp or larger)
Incinerators and Crematories
Boilers and Heaters (2 million BTU/hr or larger)
ELECTRONICS
Solder Levelers
Wave Solder Machines Vapor Degreasers Fume Hood Scrubbers Electrolytic Plating
Silicone Chip Manufacturing
FOOD
Smokehouses
Feed and Grain Mills Coffee Roasters
Bulk Flour and Grain Storage
METALS
Metal Melting Devices Hot Dip Galvanizing
Cadmium or Chrome Plating Chromic Acid Anodizing
PETROLEUM FUELS MARKETING
Gasoline and Alcohol Bulk Plants and Terminals
Gasoline and Alcohol Fuel Dispensing
ROCK AND MINERAL
Hot Asphalt Batch Plants
Sand, Rock, and Aggregate Plants Concrete Batch, Concrete Mixers, and Silos
Brick Manufacturing
SOLVENT USE
Vapor and Cold Degreasing Solvent and Extract Dryers Dry Cleaning
OTHER
Asphalt Roofing Tanks Aqueous Waste Neutralization Landfill Gas Flare or Recovery
Systems
Waste Disposal and Reclamation Units
Grinding Booths and Rooms
Oil Field Exploration or Production Plastic/Fiberglass Manufacturing Soil Aeration/Reclamation
Storage of Organic Liquids Powder Coating
Fiberglass Chopper Guns Waste Water Treatment Works
EXAMPLES OF HAZARDOUS MATERIALS
Ammonia
Acids and Bases Chlorine Compressed Gases Corrosives Cryogenic Fluids Explosives Fertilizers
Flammable Liquids and Solids
Gasoline
Hazardous Material Mixtures Herbicides
Industrial Cleaners Infectious/Biological Materials Oxidizing Materials
Paint Thinners Paints Pesticides
Petroleum Products Poisons
Pyrophoric/Hypergolic Materials Radioactives
Solvents Waste Oils
Water Reactives Welding Gases
NOTE: Other equipment not listed here that is capable of emitting air contaminants may require a San Luis Obispo County Air Pollution Control District Permit. If there are any questions, contact the APCD at (805) 781-5912. For information on Hazardous Materials located within the City of San Luis Obispo contact the San Luis Obispo Fire Department at (805) 781- 7380. All other areas contact County Environmental Health at (805) 781-5544.
IF YOU INSTALL AND/OR OPERATE EQUIPMENT WITHOUT A REQUIRED PERMIT, YOU MAY BE SUBJECT TO LEGAL ACTION AND PENALTIES OF UP TO $50,000 PER DAY FOR EACH DAY OF VIOLATION
TIMELINE AND IMPLEMENTATION PROCESS
APCD reviews the Questionnaires received from the Planning Department. Within 14 days, one of the following determinations will be made:
If the answer to Question #1 is YES, and the facility is not located within 1000 feet of a school, then the project is exempt from further processing under AB3205, but IS subject to APCD permitting requirements. As a result, the APCD will take the following actions:
Within 7 days of receipt of the questionnaire from the Planning Department, the APCD will:
– Review the Questionnaire to determine if the source stores, handles or uses hazardous materials (Question #2 on the form). If the answer to that question is YES, then APCD completes the appropriate sections of the questionnaire and forwards it to either the City of San Luis Obispo Fire Department (if project is within the City limits), or Environmental Health (all other areas). A memo to County Planning will be sent summarizing action taken.
– If Hazardous Materials storage, usage or handling is not proposed on-site, APCD Planning Staff will indicate that on the questionnaire. The “APCD Permit Required” box will be checked “YES”, and the form returned to the Planning Department.
The APCD Engineering Staff sends a letter to the project applicant indicating that this project IS subject to APCD permit. Accompanying this letter will be an ATC (Authority to Construct) application, and other explanatory information.
Upon receipt of an ATC application, the APCD has 30 days to determine if the application is complete. A letter of completeness (or incompleteness) is sent to the applicant prior to the end of the 30-day period. If the application is incomplete, the APCD will request additional information in the aforementioned letter. If the application is complete, then the APCD will issue a completeness letter indicating that they have 180 days to issue an ATC.
After project construction is completed, the applicant must indicate in writing to the APCD that construction is complete. A field inspection will then be conducted by APCD staff to determine compliance with applicable APCD Rules and Regulations. Upon verification of compliance, a Permit-to- Operate (PTO) for the subject facility is issued by the APCD.
If the answer to Questions #1 is YES, and the facility is within 1000 feet of a school, the proposed project will be subject to the APCD permitting process and AB3205 Public Noticing Requirements. The APCD will perform the following actions:
Within 7 days of receipt of the questionnaire from the Planning Department, the APCD will:
– Review the Questionnaire to determine if the source stores, handles or uses hazardous materials (Question #2 on the form). If the answer to that question is YES, then APCD completes the appropriate sections of the questionnaire and forwards it to either the City of San Luis Obispo Fire Department (if project is within the City limits), or Environmental Health (all other areas). A memo to County Planning will be sent summarizing action taken.
– If Hazardous Materials storage, usage, or handling is not proposed on-site, APCD Planning Staff will indicate as such on the questionnaire.
The APCD Engineering Staff sends a letter to the project applicant indicating that this project IS subject to APCD permit and AB3205 Public Noticing requirements. Accompanying this letter will be an ATC application, a description of public noticing requirements and other explanatory information.
Upon receipt of an ATC application, the APCD has 30 days to determine if the application is complete. A letter of completeness (or incompleteness) is sent to the applicant prior to the end of the 30-day period. If the application is incomplete, the APCD will request additional information in the aforementioned letter.
When the APCD has deemed the ATC application complete, the applicant will then be required to comply with the public noticing requirements of the California Health and Safety Code, Section 42301.6.
Compliance with the public noticing requirements must be demonstrated prior to APCD action on the ATC application. These requirements are as follows:
– The Air Pollution Control Officer (APCO) shall, at the expense of the permit applicant, distribute (or mail) a public notice to the parents or guardians of children enrolled in ANY school that is located within 1/4 mile of the proposed project site, and to each address within a 1000 ft. radius of the proposed source. An assessor’s parcel map will be used to determine the area encompassing addresses within the 1000 ft. radius of the proposed project.
– The public noticing period extends for 30 days, and MUST begin at least 30 days prior to the APCD taking final action on the ATC application for the proposed project. This notice may be combined with any other notice on the project or permit, which is required by law. The APCO shall review and consider all public comments received during the 30 days after the notice is distributed, and shall include written responses to the comments in the permit application file prior to taking final action on the application.
State law requires the APCD to approve or deny the ATC within 180 days of the date on which the A/C application was deemed complete. The public noticing period and the APCD response to public comments MUST occur within this time period. The APCD cannot issue the ATC until public noticing requirements for AB3205 have been satisfied.
After project construction is completed, the applicant must indicate in writing to the APCD that construction is complete. A field inspection will then be conducted by APCD staff to determine compliance with applicable APCD Rules and Regulations. Upon verification of compliance, a PTO or the subject facility is issued by the APCD.
4.2 ARB’S RECOMMENDATIONS ON SITING NEW SENSITIVE LAND USES 6
Source Category |
Advisory Recommendations |
Freeways and high- traffic roads |
100,000 vehicles/day, or rural roads with 50,000 vehicles per day. |
Distribution centers |
(TRUs) per day, or where TRU unit operations exceed 300 hours per week).
and other new sensitive land uses near entry and exit points. |
Railyards |
|
Ports |
risks. |
Refineries |
local air districts and other local agencies to determine an appropriate separation. |
Chrome platers |
|
Dry cleaners using perchloroethylene |
the local air district.
|
Gasoline dispensing facilities |
typical gas dispensing facilities. |
6
4.3 APCD-APPROVED DUST SUPPRESSANTS
The following list of dust control suppressants are approved by the SLO County APCD. The approved suppressants must be reapplied at a frequency that ensures that fugitive dust emissions are adequately controlled to below the 20% opacity limit identified in the APCD Rule 401 Visible Emissions and to ensure that dust is not emitted offsite. If fugitive dust is not adequately controlled, emissions could result in complaints and a violation of APCD Rule 402 Nuisance. The APCD will consider products that are not listed on a case-by- case bases; provide product specifics to APCD by contacting the APCD Planning Division at (805) 781-5912.
Suppressants are often used in combination with other APCD recommended control methods to minimize fugitive dust emissions. Other methods include:
1) Paving and then maintaining to applicable standards thus replacing need for suppressants and other control methods;
2) Implementing and maintaining design standards to ensure vehicles speeds on unpaved areas are physically limited to a posted speed limit of 15 mph or less; and
3) For special events, site parking areas in grass or low cut dense vegetative areas that are adequately irrigated to minimize fugitive dust emissions.
SLO County APCD used a 2002 San Joaquin Valley APCD [1] list of dust suppressants as the starting point for the list presented below. Products that could not be readily found were removed from the list. This SLO County APCD list also streamlines the SJVAPCD list by removing hygroscopic products and all but one of the petroleum based products from the SJVAPCD list. A petroleum based method (chipseal) and three polymer products (Dust Binder, Gorilla-Snot®, and Soiltac®) were added to the list.
Any chemical or organic material used for stabilizing solids shall not violate the California State Water Quality Control Board standards for use as a soil stabilizer. Any dust suppressant must not be prohibited for use by the US Environmental Protection Agency, the California Air Resources Board, or other applicable law, rule, or regulation.
Suppressant Category |
Suppressant Sub-Category |
Product Common Name |
Company |
Product Web Link |
Adhesives |
Lignosulfonate |
|
California-Fresno Oil Co. (209) 486-0220 |
www.calfresno.com |
|
Dallas Roadway Products, Inc. SALS Roadway Products (972) 758-7454 |
www.dallasroadway.com www.salsroadproducts.com |
||
|
Georgia Pacific (866) 447-2436, (800) 283-5547 |
www.gp.com/chemical |
||
|
Prince Minerals, Inc. (646) 747-4200 |
www.princeminerals.com/products/dust_control.php |
||
|
EnviroTech Services (800) 369-3878 |
www.envirotechservices.com |
||
|
Jim Good Marketing (805) 746-3783 |
– |
||
Calcium Lignosulfonate |
|
Prince Minerals, Inc. (646) 747-4200 |
www.princeminerals.com/products/dust_control.php |
|
|
Quatsino Navigation Co. Ltd (916) 442-9089 |
http://www.bellmarine.com/Dustac.htm |
||
|
|
|
|
|
Petroleum Emulsions |
– |
|
PennzSuppress® Dust Suppressant American Refining Group, Inc. (814) 368-1200 |
www.arb.ca.gov/eqpr/pennzoil/pennzoil.htm |
|
|
|
|
|
Polymer |
– |
|
Desert Mountain (505) 598-5730 |
www.desertmtncorp.com |
|
Monterey AgResources (559) 499-2100 |
www.montereyagresources.com |
||
|
Earth Chem, Inc. (800) 764-5726 |
www.earthchem.com |
||
|
Enviroseal Corporation (800) 775-9474 |
www.enviroseal.com/ldc.htm |
||
|
Reclamare Co. (206) 824-2385 |
– |
Suppressant Category |
Suppressant Sub-Category |
Product Common Name |
Company |
Product Web Link |
|
|
|
PolyPavement Company (323) 954-2240 |
www.polypavement.com |
|
Environmental Soil Systems, Inc. (800) 368-4115 |
– |
||
|
Trans Western Chemicals, Inc. (562) 942-1833 |
www.soilseal.com |
||
|
Midwest Industrial Supply, Inc. (800) 321-0699 |
www.arb.ca.gov/eqpr/midwest.htm |
||
|
Hercules Soiloc (800) 815-7668 |
– |
||
|
Soilworks, LLC (800) 545-5420 |
www.Soilworks.com |
||
|
Fluid Sciences, LLC (888) 356-7847 |
www.fluidsciences.com |
||
|
Base Seal International, Inc. (800) 729-6985 |
www.baseseal.com |
||
|
|
|
|
|
Oil-Rock Binding Agent |
– |
|
– |
– |
[1] Re: www.valleyair.org/busind/comply/PM10/Products%20Available%20for%20Controlling%20PM10%20Emissions.htm
[2] “Pre-certified” by the California Air Resources Board; www.arb.ca.gov/eqpr/eqpr.htm
[3] Though chipseal is typically used as a sealant for paved roads, it can also be an effective dust suppressant on unpaved private roads. Project proponents accept liability of potential vehicle or property damage associated with this dust control method.
4.4
SLO COUNTY NATURALLY OCCURRING ASBESTOS MAP
4.5 CONSTRUCTION ACTIVITY MANAGEMENT PLAN GUIDELINES
A Construction Activity Management Plan (CAMP) may be required by the Air Pollution Control District (APCD) for construction projects that will result in significant particulate matter (PM) and/or nitrogen oxide (NOx) emission impacts, such as potentially high emissions of fugitive dust or NOx, or emissions in areas where potential nuisance concerns are present. The purpose of the CAMP is to specifically define the mitigation measures that will be employed as the project moves forward, in order to ensure all requirements are accounted for in the project budget, included in the contractor bid specifications, and are fully implemented throughout project construction.
The following information is provided as a guide for development of the CAMP. Specific implementation of mitigation measures will vary from project to project. The CAMP is a comprehensive mitigation plan and will need to specifically identify all of the mitigation measures to be implemented for the project. The following is a list of potential mitigation measures to include in the CAMP. The CAMP must be submitted to the APCD for approval prior to the start of the project.
Prior to commencement of any construction activities (e.g., site preparation, grading or construction activities) the applicant will notify the appropriate planning agency and the APCD, by letter, of the status of the air quality measures outlined in the CAMP. The letter will state the following: 1) the controls that will be implemented; 2) the reasons why any unimplemented measures are considered infeasible and the measures incorporated to substitute for these measures; 3) when scheduled construction activities will be initiated to allow for APCD inspection of the mitigation measures.
The proximity of the project to the nearest residence and to the nearest sensitive receptor
(e.g. school, daycare, hospital or senior center) needs to be documented and the mitigation measures outlined in the CAMP need to be tailored accordingly to provide adequate protection to any nearby sensitive receptors. (e.g. of mitigation measures: Locate construction staging areas away from sensitive receptors such that exhaust and other construction emissions do not enter the fresh air intakes to buildings, air conditioners, and windows).
A person or persons must be designated to monitor the CAMP implementation. This person will be responsible for compliance with the CAMP. Their duties shall include holidays and weekend periods when work may not be in progress. Depending on the site location, a certified visible emissions monitor may be required. The name and telephone number of such persons shall be provided to the APCD prior to the start of any construction activities.
Construction activities can generate fugitive dust, which could be a nuisance to local residents and businesses in close proximity to the proposed construction site. Dust complaints could result in a violation of the APCD’s 402 “Nuisance” Rule. The following is a list of measures that may be required throughout the duration of the construction activities:
All PM10 mitigation measures required should be shown on grading and building plans. In addition, the contractor or builder should designate a person or persons to monitor the dust control program and to order increased watering, as necessary, to prevent transport of dust offsite. Their duties shall include holidays and weekend periods when work may not be in progress. The name and telephone number of such persons shall be provided to the APCD prior to land use clearance for map recordation and finished grading of the area.
The Attorney General requires GHG impact evaluation and the implementation of feasible mitigation at the project level. As such, the project’s Mitigated Negative Declaration should evaluate the project’s carbon dioxide (CO2) emissions as well as other GHG sources converted to carbon dioxide equivalents and should identify feasible mitigation that the project shall implement. The project’s overall GHG impact evaluation should include:
For the construction phase (operational phase as well) feasible GHG mitigation measures to be implemented should be identified from the California Air Pollution Control Officer Association’s (CAPCOA) January 2008 published document entitled “CEQA and Climate Change” or from other proven energy efficiency measures. The document is available online at: www.capcoa.org/CEQA/CAPCOA%20White%20Paper.pdf
In some cases where the available measures are marginally effective, off-site GHG mitigation fees are appropriate.
To mitigate air quality impacts from the emissions of construction equipment engines, the APCD has project proponents apply various emission reduction methods depending on the magnitude of the project. Below are the methods used:
Standard Control Measures for Construction Equipment
The standard mitigation measures for reducing nitrogen oxide (NOx), reactive organic gases (ROG), and diesel particulate matter (Diesel PM) emissions from construction equipment are listed below:
– Maintain all construction equipment in proper tune according to manufacturer’s specifications;
– Fuel all off-road and portable diesel powered equipment with ARB certified motor vehicle diesel fuel (non-taxed version suitable for use off-road);
– Use diesel construction equipment meeting ARB’s Tier 2 certified engines or cleaner off-road heavy- duty diesel engines, and comply with the State off-Road Regulation;
– Use on-road heavy-duty trucks that meet the ARB’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 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;
– All on and off-road diesel equipment shall not idle for more than 5 minutes. Signs shall be posted in the designated queuing areas and or job sites to remind drivers and operators of the 5 minute idling limit;
– Diesel idling within 1,000 feet of sensitive receptors is not permitted;
– Staging and queuing areas shall not be located 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 on-site where feasible, such as compressed natural gas (CNG), liquefied natural gas (LNG), propane or biodiesel.
Best Available Control Technology (BACT) for Construction Equipment
If the estimated construction phase ozone precursor emissions from the actual fleet for a given Phase are expected to exceed the APCD’s threshold of significances after the standard mitigation measures are factored into the estimation, then BACT needs to be implemented to further reduce these impacts. The BACT measures can include:
– Further reducing emissions by expanding use of Tier 3 and Tier 4 off-road and 2010 on-road compliant engines;
– Repowering equipment with the cleanest engines available; and
– Installing California Verified Diesel Emission Control Strategies. These strategies are listed at: http://www.arb.ca.gov/diesel/verdev/vt/cvt.htm
– Implementing a design measure to minimize emissions from on and off-road equipment associated with the construction phase. This measure should include but not be limited to the following elements:
– Limit the amount of cut and fill to 2,000 cubic yards per day;
– Limit the length of the construction work-day period; and,
– Phase construction activities.
Offsite Mitigation for Construction Equipment
If the estimated construction phase ozone precursor emissions from the actual fleet for a given Phase are expected to exceed the APCD’s 6 tons/quarter threshold of significance
after the standard and BACT measures are factored into the estimation, then off-site mitigation is appropriate. The current mitigation rate is $16,000 per ton of ozone precursor emission (NOx + ROG) over the APCD threshold evaluated over the length of the expected exceedance. The applicant may use these funds to implement APCD approved emission reduction projects near the project site or may pay that funding level plus a 15% administration fee to the APCD for the APCD to implement emission reduction projects in close proximity to the project. The applicant shall provide this funding at least two (2) months prior to the start of the project to help facilitate emission offsets that are real-time as possible.
– Implement an APCD approved Trip Reduction Program to reduce construction worker commute trips, which includes carpool matching, vanpooling, transit use, etc. Monitor
worker use of alternative transportation throughout the project to ensure compliance.
The CAMP should include a section that addresses complaints and complaint handling. At a minimum this section shall include the following:
– The person(s) responsible for addressing and resolving all complaints regarding the construction activity and their contact information is:
▪ Name(s)
▪ Company and Title(s)
▪ Phone numbers and physical address.
– A hotline telephone number shall be established and publicized to help facilitate rapid complaint identification and resolution. In addition, Prop 65 notification with regard to
toxic diesel emissions shall to be made.
– An action plan section shall be outlined that includes additional measures or modifications to existing mitigation measures in the event of complaints.
– All complaints shall be reported immediately to the APCD.
Portable equipment, 50 horsepower (hp) or greater, used during construction activities may
require California statewide portable equipment registration (issued by the California Air Resources Board) or an APCD permit. Operational sources may also require APCD permits.
The following list is provided as a guide to equipment and operations that may have permitting requirements, but should not be viewed as exclusive. For a more detailed listing, refer to
page A-5 in the APCD’s CEQA Handbook.
– Power screens, conveyors, diesel engines, and/or crushers.
– Portable generators 50 hp or greater
– Chemical product processing and or manufacturing
– Electrical generation plants or the use of standby generator
– Food and beverage preparation (primarily coffee roasters)
– Furniture and fixture products
– Metal industries, fabrication
– Small scale manufacturing
– Auto and vehicle repair and painting facilities
– Fuel dealers
– Dry cleaning
– Pipelines
– Public utility facilities
– Boilers
– IC Engines
– Sterilization units(s) using ethylene oxide and incinerator(s)
– Cogeneration facilities
– Unconfined abrasive blasting operations
– Concrete batch plants
– Rock and pavement crushing
– Tub grinders trommel screens
To minimize potential delays, prior to the start of the project, please contact the APCD
Engineering Division at (805) 781-5912 for specific information regarding permitting requirements.
Naturally Occurring Asbestos
If the project site is located in a candidate area for Naturally Occurring Asbestos (NOA), which
has been identified as a toxic air contaminant by the California Air Resources Board (ARB) the following requirements apply. Under the ARB Air Toxics Control Measure (ATCM) for Construction, Grading, Quarrying, and Surface Mining Operations, prior to any construction activities at the site, the project proponent shall ensure that a geologic evaluation is conducted to determine if NOA is present within the area that will be disturbed. If NOA is not present, an exemption request must be filed with the APCD. If NOA is found at the site the applicant must comply with all requirements outlined in the Asbestos ATCM. This may include development of an Asbestos Dust Mitigation Plan and an Asbestos Health and Safety Program for approval by the APCD. Please refer to the APCD web page at http://www.slocleanair.org/business/asbestos.asp for more information or contact the APCD Enforcement Division at (805) 781-5912.
Demolition of Asbestos Containing Materials
Demolition activities can have potential negative air quality impacts, including issues surrounding proper handling, demolition, and disposal of asbestos containing material (ACM). Asbestos containing materials could be encountered during demolition or remodeling of existing buildings. Asbestos can also be found in utility pipes/pipelines (transite pipes or insulation on pipes). If utility pipelines are scheduled for removal or relocation; or building(s) are removed or renovated this project may be subject to various regulatory jurisdictions, including the requirements stipulated in the National Emission Standard for Hazardous Air Pollutants (40CFR61, Subpart M – asbestos NESHAP). These requirements include but are not limited to:
1) notification requirements to the APCD, 2) asbestos survey conducted by a Certified Asbestos Inspector, and, 3) applicable removal and disposal requirements of identified ACM. Please contact the APCD Enforcement Division at (805) 781-5912 for further information.
Lead During Demolition
Demolition of structures coated with lead based paint is a concern for the APCD. Improper demolition can result in the release of lead containing particles from the site. Sandblasting or removal of paint by heating with a heat gun can result in significant emissions of lead. Therefore, proper abatement of lead before demolition of these structures must be performed in order to prevent the release of lead from the site.
Depending on removal method, an APCD permit may be required. Contact the APCD Engineering Division at (805) 781-5912 for more information. Approval of a lead work plan by the APCD is required and must be submitted ten days prior to the start of the demolition. Contact the APCD Enforcement Division at (805) 781-5912 for more information. For additional information regarding lead removal, please contact Cal- OSHA at (805) 654-4581.
H:PLANCEQACEQA Handbook2009Final_draft_2009.v02.doc
Copyright Soilworks, LLC 2003-. All Rights Reserved. Soilworks®, Soiltac®, Gorilla-Snot®, and Durasoil®are registered trademarks of Soilworks, LCC.
Copyright Soilworks, LLC 2003-. All Rights Reserved. Soilworks®, Soiltac®, Gorilla-Snot®, and Durasoil® are registered trademarks of Soilworks, LCC.