3.2 - air quality - city of irvine

City of Irvine - William Lyon Homes: Vista Verde Draft EIR Air Quality

Michael Brandman Associates 3.2-1 H:\Client (PN-JN)\0006\00060034\EIR\3 - DEIR\00060034 Sec03-02 Air Quality Vista Verde.doc

3.2 - Air Quality

3.2.1 - Introduction This section describes the existing air quality conditions and potential effects from project implementation on the site and its surrounding area. Descriptions and analysis in this section are based on information contained in the Air Quality/Greenhouse Gas Assessment prepared in September 2010 by RBF Consulting, included in this Draft EIR as Appendix D. The purpose of the Air Quality/Greenhouse Gas Assessment is to evaluate potential short- and long-term air quality impacts resulting from implementation of the Vista Verde Project.

3.2.2 - Environmental Setting The Project is located in the City of Irvine in the County of Orange, and is within the South Coast Air Basin (Basin). The Basin includes all of Orange County and the non-desert portions of Los Angeles, Riverside, and San Bernardino Counties, in addition to the San Gorgonio Pass area in Riverside County.

Regional

The Project is located in a region marked with the semi-permanent high-pressure zone of the eastern Pacific. The Project is located in an area of Southern California with mild climate and tempered cool sea breezes. Occasionally there are periods of very hot weather, winter storms or Santa Ana winds. The air pollution levels in the Basin are a function of the area’s natural physical characteristics (including weather and topography), as well as man-made influences (such as development patterns and lifestyle). Factors such as wind, sunlight, temperature, humidity, rainfall, and topography all impact the accumulation and/or dispersion of pollutants throughout the Basin.

Local

The local air quality in Irvine is dependent upon the air quality in southern Orange County and the Basin as a whole. The project site specifically lies in the southern portion of the South Coast Air Basin and generally has a mild climate with sea breezes. The local air quality does not differ greatly from that of the region as a whole.

Air Quality Monitoring

The South Coast Air Quality Management District operations air quality monitoring stations throughout the Basin. The Project is located in Source Receptor Area (SRA) 20. The Costa Mesa Monitoring Station is the closest monitoring station to the project site and is located in SRA 18. The Costa Mesa Station monitors ozone (O3), carbon monoxide (CO), and (nitrogen oxides) NOX. The second closest station is the Mission Viejo Monitoring Station, which is located in SRA 19. The Mission Viejo station was used to obtain Coarse Particulate Matter (PM10) and Fine Particulate Matter (PM2.5) data. For the purposes of air quality analysis the Air Quality/Greenhouse Gas Assessment utilized data collected at the Costa Mesa and Mission Viejo monitoring stations and considered the

City of Irvine - William Lyon Homes: Vista Verde Air Quality Draft EIR

3.2-2 Michael Brandman Associates H:\Client (PN-JN)\0006\00060034\EIR\3 - DEIR\00060034 Sec03-02 Air Quality Vista Verde.doc

data to be representative of the air quality experienced on the project site. Table 3.2-1: Local Air Quality Levels shows air quality data from 2004-2008 from the monitoring stations.

Table 3.2-1: Local Air Quality Levels

Pollutant California Standard

Federal Standard Year

Maximum1 Concentration

Days (Samples)

State/Federal Std. Exceeded

Ozone (O3) (1-Hour)2

0.09 ppm for 1 hour NA

2007 2008 2009

0.082 ppm 0.094 0.087

0/0 0/0 0/0

Ozone (O3) (8-Hour)2

0.07 ppm for 8 hours

0.075 ppm for 8 hours

2007 2008 2009

0.072 ppm 0.079 0.072

2/0 5/3 3/0

Carbon Monoxide (CO)2

9.0 ppm for 8 hours

9.0 ppm for 8 hours

2007 2008 2009

3.13 ppm 1.97 2.16

0/0 0/0 0/0

Nitrogen Dioxide (NO2)2

0.18 ppm for 1 hour

0.100 ppm for 1 hour

2007 2008 2009

0.074 ppm 0.081 0.065

0/NA 0/NA 0/NA

Particulate Matter (PM10)3, 4, 5

50 µg/m3 for 24 hours


2007 2008 2009

74.0 μg/m3 42.0 41.0

3/0 0/0 0/0

Fine Particulate Matter (PM2.5)3, 5

No Separate State

Standard


2007 2008 2009

46.8 μg/m3 31.9 39.2

NA/2 NA/0 NA/1

Notes: ppm = parts per million PM10 = particulate matter 10 microns in diameter or less NM = not measured μg/m3 = micrograms per cubic meter PM2.5 = particulate matter 2.5 microns in diameter or less NA = not applicable. 1 Maximum concentration is measured over the same period as the California Standards. 2 Costa Mesa Monitoring Station located at 2850 Mesa Verde Drive East, Costa Mesa, California 92626. 3 Mission Viejo Monitoring Station located at 26081 Via Pera, Mission Viejo, California 92691. 4 PM10 exceedances are based on State thresholds established prior to amendments adopted on June 20, 2002. 5 PM10 and PM2.5 exceedances are derived from the number of samples exceeded, not days. Source: RBF Consulting, September 2010.

Information regarding various types of pollutants is briefly summarized below. Refer to the Air Quality/Greenhouse Gas Assessment for additional information regarding the pollutants discussed.

Carbon Monoxide (CO) Carbon monoxide (CO) is an odorless, colorless toxic gas that is emitted by mobile and stationary sources caused by incomplete combustion of hydrocarbons or other carbon-based fuels. In cities, as much as 95 percent of all CO emissions can be attributed to automobile exhaust.

Ozone (O3) Ozone (O3) occurs in two layers of the atmosphere. The stratospheric ozone layer extends upward from about ten to 30 miles in the atmosphere and protects the planet from the sun’s harmful



ultraviolet rays (UV-B). The other ozone is a photochemical pollutant, and needs volatile organic compounds (VOCs), Nitrogen Oxides (NOX) and sunlight to form. Thus, VOCs and NOX are ozone precursors. Exposure to high ozone levels aggravates respiratory ailments and cardiovascular disease.

Nitrogen Dioxide (NO2) Nitrogen oxides (NOX) are a family of highly reactive gases that are a primary precursor to the formation of ground-level O3. NO2 (which is often used interchangeably with NOX) is a reddish-brown gas that may cause breathing difficulties when it reaches high levels. Peak readings of NO2 are caused by a high concentration of combustion sources such as motor vehicle engines, power plants, refineries, and other industrial operations.

NO2 can irritate and damage the lungs, and lower resistance to respiratory infections. The health effects of short-term exposure to NO2 are unclear; however, chronic exposure could aggravate eyes and mucus membranes and may cause pulmonary dysfunction.

Coarse Particulate Matter (PM10) PM10 refers to suspended particulate matter, which is smaller than ten microns or ten one-millionths of a meter. PM10 is caused by road dust, diesel soot, combustion products, construction operations, and dust storms. PM10 scatters light and significantly reduces visibility. Additionally, these particulates penetrate the lungs and have the potential to damage the respiratory tract. Based upon requirements set forth in the Children’s Environmental Health Protection Act (SB 25), in June of 2003 CARB adopted amendments to the statewide 24-hour particular matter standards.

Fine Particulate Matter (PM2.5) Fine particulate matter is referred to as PM2.5 is 2.5 microns in diameter or less. State and Federal standards for fine particulate matter have been created due to health concerns about impacts on infants, children, the elderly, and those with pre-existing cardiopulmonary disease. In 1997, the EPA announced new PM2.5 standards, which were challenged in court and were eventually upheld. On June 20, 2002, CARB adopted amendments for statewide annual ambient particulate matter air quality standards.

Volatile Organic Compounds (VOCs or Reactive Organic Gases [ROG]) Hydrocarbons are organic gases that are formed solely of hydrogen and carbon. There are several subsets of organic gases including reactive organic gases (ROGs) and volatile organic compounds (VOCs). Both ROGs and VOCs are emitted from the incomplete combustion of hydrocarbons or other carbon-based fuels. The major sources of hydrocarbons are combustion engine exhaust, oil refineries, and oil-fueled power plants; other common sources are petroleum fuels, solvents, dry cleaning solutions, and paint (via evaporation).

Lead (Pb) In the Basin, atmospheric lead is generated almost entirely by the combustion of leaded gasoline. The Basin has achieved attainment for lead under both State and federal standards. Exceedances of the



State air quality standard for lead (monthly average concentration of 1.50 μg/m3) are confined to densely populated areas, where vehicle traffic is greatest. Lead was not monitored at the nearby monitoring locations.

Sensitive Receptors Sensitive populations (sensitive receptors) are more susceptible to the effects of air pollution than is the general population. Land uses considered sensitive receptors include residences, schools, playgrounds, childcare centers, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement homes. Table 3.2-2, Sensitive Receptors, lists the distances and locations of sensitive receptors within one mile of the Project. Sensitive receptors within one mile of the Project site are the existing residences to the north, east, south, and west. The closest sensitive receptors to the Project site are residential units located approximately 12-25 feet west of the Project site.

Table 3.2-2: Sensitive Receptors

Type Name Distance from

Project Site (feet) Direction from Project

Site

12-25 West

100 North

100 East Residential Residential Uses

100 South

Rancho San Joaquin Middle School 340 North

Concordia University, Irvine 1,607 South

University Park Elementary 3,807 West Schools

Village Montessori School 3,692 West

Lutheran Bible Institute 715 Southeast Churches

Pacific SW District Lutheran Church 2,415 Southwest

Dave Robins Park 32 Southwest

William R. Mason Regional Park 570 South Parks

University Community Park 2,860 West

Source: RBF Consulting, September 2010.

3.2.3 - Regulatory Setting Regulatory oversight for air quality in the Basin rests with the following agencies: the U.S. Environmental Protection Agency (EPA) Region, the South Coast Air Quality Management District (SCAQMD) and the California Air Resources Board (CARB). Each agency and its role are discussed in more detail below.



Federal

At the federal level, the U.S. Environmental Protection Agency (EPA) Region IX office has regulatory oversight regarding the air quality in the Basin. The EPA implements the Federal Clean Air Act (FCAA). The FCAA was enacted in 1955 and establishes the National Ambient Air Quality Standards (NAAQS), which identify levels of air quality for “criteria” pollutants. Criteria pollutants are those that are at a level that is considered to be the maximum level of ambient (background) air pollutants that is considered safe. The criteria pollutants are ozone (O3), carbon monoxide (CO), nitrogen dioxide (NO2, which is a form of nitrogen oxides [NOx]), sulfur dioxide (SO2, which is a form of sulfur oxides [SOx]), particulate matter less than 10 and 2.5 microns in diameter (PM10 and PM2.5, respectively), and lead (Pb). These criteria pollutants are listed in Table 3.2-3, National and California Ambient Air Quality Standards.

State

At the state level, the California Air Resources Board (CARB) has regulatory oversight regarding the air quality in the Basin. The air quality policy in California is administered by CARB. In 1969, California Ambient Air Quality Standards (CAAQS) were established pursuant to the Mulford-Carrell Act. Refer to Table 3.2-3 which includes both CAAQS and National Ambient Air Quality Standards (NAAQS). California’s standards are generally more stringent and apply to more pollutants than the NAAQS (such as visibility reducing particles, hydrogen sulfide and sulfates).

In 1988, the California Clean Air Act (CCAA) was approved. The CCAA requires that each local air district prepare and maintain an Air Quality Management Plan (AQMP) to achieve compliance with CAAQS. The Air Quality Management Plan serves as the basis for the preparation of California’s State Implementation Plan (SIP). CARB designates areas in California as either attainment or nonattainment for each criteria pollutant based on whether the California Ambient Air Quality Standards have been achieved. Under the California Clean Air Act, areas are designated as nonattainment for a pollutant if air quality data shows that a State standard for the pollutant was violated at least once during the previous three calendar years. Exceedances that are affected by highly irregular or infrequent events are not considered to be violations of a State standard.

Regional

At the regional level, the South Coast Air Quality Management District (SCAQMD) has regulatory oversight regarding air quality in the Basin.

The 2007 Air Quality Management Plan for the South Coast Air Basin (2007 AQMP), adopted in June 2007, proposes policies and measures to achieve federal and state standards for improved air quality in the Basin. The Environmental Protection Agency, California Air Resources Board, local governments, Southern California Association of Governments, and the South Coast Air Quality Management District are the primary agencies that implement the Air Quality Management Plan programs.



Table 3.2-3: National and California Ambient Air Quality Standards

California1 Federal2 Pollutant Averaging Time Standard3 Attainment Status Standard4 Attainment Status

1 Hour 0.09 ppm (180 μg/m3) Nonattainment NA5 NA5 Ozone (O3)

8 Hours 0.07 ppm (137 μg/m3) Unclassified 0.075 ppm (147 μg/m3) Nonattainment

24 Hours 50 μg/m3 Nonattainment 150 μg/m3 Nonattainment Particulate Matter

(PM10) Annual Arithmetic Mean 20 μg/m3 Nonattainment NA6 Nonattainment

24 Hours No Separate State Standard 35 μg/m3 Unclassified Fine Particulate Matter (PM2.5)

Annual Arithmetic Mean 12 μg/m3 Nonattainment 15 μg/m3 Nonattainment

8 Hours 9.0 ppm (10 mg/m3) Attainment 9 ppm (10 mg/m3) Attainment Carbon Monoxide (CO) 1 Hour 20 ppm (23 mg/m3) Attainment 35 ppm (40 mg/m3) Attainment

Annual Arithmetic Mean 0.030 ppm (56 μg/m3) NA 0.053 ppm (100 μg/m3) Attainment Nitrogen Dioxide

(NO2)7 1 Hour 0.18 ppm (338 μg/m3) Attainment 0.100 ppm NA

30 days average 1.5 μg/m3 Attainment N/A NA Lead (Pb)

Calendar Quarter N/A NA 1.5 μg/m3 Attainment

Annual Arithmetic Mean N/A NA 0.030 ppm (80 μg/m3) Attainment

24 Hours 0.04 ppm (105 μg/m3) Attainment 0.14 ppm (365 μg/m3) Attainment

3 Hours N/A NA N/A Attainment Sulfur Dioxide (SO2)

1 Hour 0.25 ppm (655 μg/m3) Attainment 75 ppb NA



Table 3.2-3 (cont.): National and California Ambient Air Quality Standards

California1 Federal2 Pollutant Averaging Time Standard3 Attainment Status Standard4 Attainment Status

Visibility-Reducing Particles

8 Hours (10 a.m. to 6 p.m., PST)

Extinction coefficient = 0.23 km@<70% RH Unclassified

Sulfates 24 Hour 25 μg/m3 Attainment

Hydrogen Sulfide 1 Hour 0.03 ppm (42 μg/m3) Unclassified

Vinyl Chloride 24 Hour 0.01 ppm (26 μg/m3) Unclassified

No Federal

Standards

μg/m3 = micrograms per cubic meter; ppm = parts per million; ppb = parts per billion; km = kilometer(s); RH = relative humidity; PST = Pacific Standard Time; N/A = Not Applicable. Notes: 1 California standards for ozone, carbon monoxide (except Lake Tahoe), sulfur dioxide (1- and 24-hour), nitrogen dioxide, suspended particulate matter-PM10 and visibility-reducing

particles, are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations. In 1990, the California Air Resources Board identified vinyl chloride as a toxic air contaminant, but determined that there was not sufficient available scientific evidence to support the identification of a threshold exposure level. This action allows the implementation of health-protective control measures at levels below the 0.010 ppm ambient concentration specified in the 1978 standard.

2 National standards (other than ozone, particulate matter and those based on annual averages or annual arithmetic mean) are not to be exceeded more than once a year. EPA also may designate an area as attainment/unclassifiable, if: (1) it has monitored air quality data that show that the area has not violated the ozone standard over a three-year period; or (2) there is not enough information to determine the air quality in the area. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard.

3 Concentration is expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 mm of mercury. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 mm of mercury (1,013.2 millibar); ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.

4 National Primary Standards: The levels of air quality necessary, with an adequate margin of safety, to protect the public health. 5 The Federal 1-hour ozone standard was revoked on June 15, 2005 in all areas except the 14 8-hour ozone nonattainment Early Action Compact (EAC) areas. 6 The Environmental Protection Agency revoked the annual PM10 standard in 2006 (effective December 16, 2006). 7 To attain this standard, the 3-year average of the 98th percentile of the daily maximum 1-hour average at each monitor within an area must not exceed 0.100 ppm (effective January 22,

2010). Source: RBF Consulting, September 2010.



As detailed in the Air Quality/Greenhouse Gas Assessment for the Project, the 2007 AQMP includes new information on key elements such as:

• Current air quality;

• Improved emission inventories;

• An overall control strategy comprised of: Stationary and Mobile Source Control Measures, SCAQMD, State and Federal Stationary and Mobile Source Control Measures, and the SCAG Regional Transportation Strategy and Control Measures;

• New attainment demonstration for PM2.5 and O3;

• Milestones to the Federal Reasonable Further Progress Plan; and • Preliminary motor vehicle emission budgets for transportation conformity purposes.

Proposed Rule 2301

The SCAQMD is considering whether to adopt Proposed Rule 2301 (PR 2301) Control of Emissions from New or Redevelopment Projects. This new rule would require projects in the Basin to obtain discretionary approval based on their annual NOX emissions. The goal of PR 2301 is to reduce construction and operational NOX emissions from new and redevelopment projects. This reduction would be required through a discretionary process and approval of a Compliance Plan administered by the SCAQMD if projects generate NOX beyond certain thresholds. For projects meeting or exceeding the operational NOX threshold, a Compliance Plan must be approved by the SCAQMD before publication of a Notice of Availability of an EIR or negative declaration. As presently drafted, Compliance Plan approval will be required for projects with the following operational emissions:

• Effective January 1, 2010, projects exceeding 10.0 tons per year of NOX. • Effective January 1, 2011, projects exceeding 4.0 tons per year of NOX. • Effective January 1, 2012, projects exceeding 2.0 tons per year of NOX.

Southern California Association of Governments At the regional level, the Southern California Association of Governments (SCAG) is the planning agency for Los Angeles, Orange, Ventura, Riverside, San Bernardino, and Imperial Counties. SCAG serves as a forum for regional issues relating to transportation, the economy, community development, and the environment. SCAG is the Federally designated metropolitan planning organization (MPO) for the Southern California region and is the largest metropolitan planning organization in the United States. The Regional Comprehensive Plan and Guide for the region prepared by SCAG includes Growth Management and Regional Mobility chapters that form the basis for the land use and transportation control portions of the 2007 Air Quality Management Plan. SCAG is responsible under the Federal Clean Air Act for determining conformity of projects, plans, and programs with the SCAQMD.



Greenhouse gas emissions are discussed in Section 3.4 of this document.

3.2.4 - Thresholds of Significance According to the CEQA Guidelines’ Appendix G Environmental Checklist, to determine whether impacts to air quality are significant environmental effects, the following questions are analyzed and evaluated. Would the project:

a) Conflict with or obstruct implementation of the applicable air quality plan?

b) Violate any air quality standard or contribute substantially to an existing or projected air quality violation?

c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)?

d) Expose sensitive receptors to substantial pollutant concentrations?

e) Create objectionable odor affecting a substantial number of people? 3.2.5 - Project Impacts Air Quality Plan

Impact AQ-1 Would the Project conflict with or obstruct implementation of the applicable air quality plan?

Impact Analysis In considering whether the Project obstructs implementation of applicable air quality plans, South Coast Air Quality Management District thresholds are taken into consideration. As detailed in the Air Quality/Greenhouse Gas Assessment for the project, under CEQA the South Coast Air Quality Management District (SCAQMD) is an expert commenting agency on air quality within its jurisdiction. The CEQA Air Quality Handbook provides significance thresholds for both construction and operation of projects within the SCAQMD jurisdictional boundaries. If the SCAQMD thresholds are exceeded, a potentially significant impact could result, however ultimately the lead agency determines the thresholds of significance for impacts. If a project proposes development in excess of the established thresholds, as outlined in Table 3.2-4, South Coast Air Quality Management District Emissions Thresholds, a significant air quality impact may occur and additional analysis is warranted to fully assess the significance of impacts.



Table 3.2-4: South Coast Air Quality Management District Emissions Thresholds

Pollutant (lbs/day) Phase

ROG NOX CO SOX PM10 PM2.5

Construction 75 100 550 150 150 55

Operational 55 55 550 150 150 55


According to the CEQA Air Quality Handbook, project analysis in consideration of the following criteria is required in order to determine consistency with SCAQMD and SCAG policies:

1. Would the project result in any of the following: - An increase in the frequency or severity of existing air quality violations; or - Cause or contribute to new air quality violations; or - Delay timely attainment of air quality standards or the interim emissions reductions

specified in the AQMP.

2. Would the project exceed the assumptions utilized in preparing the AQMP? - Consistency with the population, housing, and employment growth projections; - Project mitigation measures; and - Appropriate incorporation of AQMP land use planning strategies.

With respect to the first criterion, SCAQMD methodologies require that an air quality analysis for a project include forecasts of project emissions in a regional context during short-term construction and long-term operations.

The Air Quality/Greenhouse Gas Assessment reviewed the Project in light of the two criteria listed above, each of which is discussed in more detail below.

Criteria 1 The Air Quality/Greenhouse Gas Assessment analyzed the project’s pollutant emissions relative to localized pollutant concentrations and used that as the basis for evaluation project consistency. Localized concentrations of CO, NOX, PM10, and PM2.5 have been analyzed for the project. SO2 emissions would be negligible during construction and long-term operations, and therefore would not have the potential to cause or affect a violation of the SO2 ambient air quality standard.

Particulate matter is the primary pollutant of concern during construction activities, and therefore the project’s PM10 and PM2.5 emissions during construction were analyzed. Results of the analysis indicate that the increases in PM10 and PM2.5 emissions are below applicable Localized Significance Thresholds.



The project’s maximum potential NOX and CO daily emissions during construction were analyzed. The maximum estimate of localized concentrations for these two criteria pollutants would remain below their respective SCAQMD Localized Significance Thresholds. Thus, the analysis concluded that CO and NOX concentrations would not exceed California or National standards, and potential impacts would therefore be less than significant. This project does not introduce any substantial stationary source emissions, thus CO is the preferred benchmark pollutant for assessing local area air quality impacts from post-construction motor vehicle operations. Based on the analysis, no violations of the State or federal CO standards would occur.

Criteria 1 Summary: The Air Quality/Greenhouse Gas Assessment states that overall, the Project would result in less than significant impacts regarding localized concentrations of pollutants during project construction and operations. Thus, the project meets the first AQMP consistency criterion (Air Quality/Greenhouse Gas Assessment, page 24).

Criteria 2 SCAQMD’s second criterion for determining project consistency focuses on whether or not the Project exceeds the assumptions utilized in preparing the forecasts presented in the Air Quality Management Plan (AQMP). Determining whether a project exceeds the assumptions reflected in the AQMP involves the evaluation of the three criteria outlined below. The following discussion provides an analysis of each of these criteria.

1. Is the project consistent with the population, housing, and employment growth projections upon which the AQMP forecasted emission levels are based?

A project is consistent with the AQMP in part, if it is consistent with the population, housing, and employment assumptions that were used in the development of the AQMP. Three sources of data form the basis for the projections of air pollutant emissions in the 2007 AQMP: the General Plan, SCAG’s Growth Management Chapter of the Regional Comprehensive Plan and Guide (RCPG), and SCAG’s 2007 Regional Transportation Plan (RTP). Although the Project requires a General Plan Amendment and Zone Change, it is less intense from an emissions standpoint and would result in fewer impacts (e.g., traffic generation) than the previous elementary school use assumed in the 2007 AQMP. Refer to Section 6, Alternatives to the Proposed Project, for additional information. The Project would comply with the goals and policies within the General Plan, which are intended to guide development in Irvine. The Project is consistent with the types, intensity, and patterns of land use envisioned for the site vicinity in the RCPG. The level of growth anticipated from the Project are consistent with the population and employment forecasts for the Subregion as adopted by SCAG. The South Coast Air Quality Management District has incorporated these same projections into the Air Quality Management Plan; thus, the Project would be consistent with the projections in the AQMP.



2. Does the project implement all feasible air quality mitigation measures?

As demonstrated in the impact analysis that follows, the Project would result in less than significant operational air quality impacts, and with implementation of feasible construction phase mitigation measures would result in less than significant construction air quality impacts. Compliance with mitigation measures identified by the SCAQMD would be required as identified in the analysis below. Compliance with mitigation measure identified by SCAQMD would be required so that, per Criteria 2, the proposed project implements all feasible air quality mitigation measures. Compliance with SCAQMD mitigation measures ensures that the proposed project does not conflict with or obstruct implementation of the applicable air quality plan. As such, the Project meets this AQMP consistency criterion.

3. To what extent is project development consistent with the land use policies set forth in the AQMP?

The Project is located in an already developed portion of the City and by virtue of its location and design, exhibits many attributes that have a positive direct and indirect benefit with regard to the reduction of traffic congestion. Additionally, the Project proposes connectivity to the public transit network in the City, which would encourage pedestrian activity, alternative transit usage, and would reduce vehicle trips.

Criteria 2 Summary: As discussed in the Air Quality/Greenhouse Gas Assessment, the Project would not result in a long-term impact on the region’s ability to meet State and federal air quality standards. The Project’s long-term influence would also be consistent with the goals and policies of the AQMP and, therefore, is considered consistent with the SCAQMD’s Air Quality Management Plan.

Level of Significance Before Mitigation Less than significant

Mitigation Measures No mitigation measures are required

Level of Significance After Mitigation Less than significant



Regulatory Standard

Impact AQ-2 Would the Project violate any air quality standard or contribute substantially to an existing or projected air quality violation?

Impact Analysis Short-Term Emissions Grading and construction operations will generate short-term air quality impacts. Construction equipment would include tractors, graders, dozers, water trucks, pavers, rollers, cement mixers, cranes and loaders. As detailed in the Air Quality/Greenhouse Gas Assessment, the short-term air quality analysis takes into consideration the following temporary construction-related project impacts:

• Clearing, grading, excavating, and using heavy equipment or trucks creating large quantities of fugitive dust, and thus PM10;

• Heavy equipment required for grading and construction generates and emits diesel exhaust emissions; and

• The vehicles of commuting construction workers and trucks hauling equipment would generate and emit exhaust emissions.

Fugitive Dust Emissions Fugitive dust (PM10 and PM2.5) from grading and construction will be short-term because those activities will cease once the project has been built. The greatest amount of fugitive dust will be generated during site excavation and grading. The URBEMIS 2007 computer model was used to calculate PM10 and PM2.5 fugitive dust as part of the site grading emissions. Table 3.2-5, Construction Air Emissions shows the estimated amount of pollutants generated during construction of the project. The table shows that even without mitigation, the PM10 and PM2.5 levels during construction do not exceed the South Coast Air Quality Management District Thresholds. Mitigation is recommended because the Basin has non-attainment status for PM10 and PM2.5. The application of Mitigation Measure AQ-1, which requires adherence to SCAQMD Rule 403 and other dust control techniques will substantially lessen PM10 and PM2.5 emissions. The maximum mitigated particulate matter concentration would be reduced from 164.28 pounds per day (lbs/day) to 13.3 lbs/day for PM10. For PM2.5, the maximum mitigated particulate matter concentration would be reduced from 36.64 lbs/day to 5.45 lbs/day. The SCAQMD thresholds for PM10is 150 lbs/day and for PM2.5 is 55 lbs/day.

Levels are below the SCAQMD thresholds in the absence of specific dust reduction measures, mitigation has been recommended as the Basin has non-attainment status for PM10 and PM2.5.



Table 3.2-5: Construction Air Emissions

Pollutant (pounds/day)1 Emissions Source

ROG NOX CO SO2 PM10 PM2.5

2011

Unmitigated Emissions 11.40 65.88 48.49 0.02 164.28 35.64

Mitigated Emissions2,3 11.40 65.88 48.49 0.02 13.3 5.45

SCAQMD Thresholds 75 100 550 150 150 55

Is Threshold Exceeded After Mitigation? No No No No No No

2012





2013





Notes: 1. Emissions were calculated using the URBEMIS 2007 version 9.2.4 Computer Model, as recommended by the

SCAQMD. 2. The reduction/credits for construction emission mitigations are based on mitigation included in the URBEMIS 2007

version 9.2.4 computer model and as typically required by the SCAQMD through Rule 403. The mitigation includes the following: properly maintain mobile and other construction equipment; replace ground cover in disturbed areas quickly; water exposed surfaces twice daily; cover stock piles with tarps; water all haul roads twice daily; and limit speeds on unpaved roads to 15 miles per hour.

3. Refer to Appendix D’s, Air Modeling Data, for assumptions used in this analysis, including quantified emissions reduction by mitigation measures.


Construction Equipment and Worker Vehicle Exhaust Exhaust emissions from construction activities include emissions associated with the transport of machinery and supplies to and from the Project site, emissions produced onsite as the equipment is used, and emissions from trucks transporting materials to/from the site. As detailed in the table above, construction equipment and worker vehicle exhaust emissions would be below the established SCAQMD thresholds. Therefore, air quality impacts from equipment and vehicle exhaust emission would be less than significant.

ROG Emissions In addition to gaseous and particulate emissions, the application of asphalt and surface coatings creates ROG emissions, which are O3 precursors. The greatest ROG emissions would be generated



during the application of architectural coatings on the buildings. As required by law, all architectural coatings for the Project structures would comply with SCAQMD Regulation XI, Rule 1113 – Architectural Coating1. Rule 1113 provides specifications on painting practices and regulates the ROG content of paint. Mitigation Measure AQ-2 requires the use of high-pressure-low-volume (HPLV) paint applicators with a minimum transfer efficiency of at least 50 percent, using pre-painted construction materials, and constructing buildings with materials that do not require painting to ensure the application of architectural coating does not exceed the SCAQMD’s significance criteria for ROG. Based on the modeling, the project would not result in an exceedance of ROG emissions, and therefore would be considered less than significant; however, mitigation is recommended because the Basin has non-attainment status for O3.

Asbestos Asbestos is a naturally occurring fibrous mineral that is a human health hazard when it becomes airborne. The most common type of asbestos is chrysotile, but other types such as tremolite and actinolite are also found in California. Asbestos is classified as a human carcinogen by State, Federal, and international agencies. In 1986, the California Air Resources Board identified asbestos as a toxic air contaminant.

Asbestos can be released from serpentinite and ultramafic rocks when the rock is broken or crushed, causing the asbestos fibers to potentially become airborne, causing air quality and human health hazards. According to the Department of Conservation Division of Mines and Geology, A General Location Guide for Ultramafic Rocks in California - Areas More Likely to Contain Naturally Occurring Asbestos Report (dated August 2000), the Project is not located in an area where naturally occurring asbestos (NOA) is likely to be present. Therefore, impacts associated with naturally occurring asbestos are considered less than significant. As discussed in the Initial Study in Appendix A, asbestos-containing materials (ACM) have been identified in the former school buildings on the site. Prior to demolition and removal of the existing school building, abatement of ACM will be required in accordance with federal and state regulations, and impacts would be less than significant.

Long-Term Emissions Long-term air quality impacts consist of mobile source emissions generated from Project-related traffic and from stationary source emissions. The Air Quality/Greenhouse Gas Assessment analyzed operation-related air quality impacts for build-out conditions.

Mobile Source Emissions Mobile sources are emissions from motor vehicles, which include tailpipe and evaporative emissions. ROGs, NOX, SO2, and PM10 are all pollutants of regional concern. CO tends to be a localized pollutant, because it disperses rapidly at the source.

1 South Coast Air Quality Management District, http://www.aqmd.gov/rules/reg/reg11_tofc.html,

November 10, 2004.



RBF Consulting prepared the Vista Verde Project Traffic Impact Analysis (December 2010). Project-generated vehicle emissions were estimated using the URBEMIS 2007 computer model, which predicts ROGs, CO, NOX, SO2, PM10, and PM2.5 emissions from motor vehicle traffic associated with new or modified land uses. Project trip generation rates were based on the project Traffic Impact Analysis, which utilized City’s Irvine Transportation Analysis Model (ITAM). The resultant trip generation forecast in the Traffic Impact Analysis was 632 daily trips.

Table 3.2-6, Long-Term Operational Emissions, shows the anticipated mobile emissions. As depicted in the table below, emissions generated by vehicle traffic associated with the Project would not exceed the established SCAQMD thresholds. Thus, the Project will have a less than significant impact regarding long-term operational emissions.

Table 3.2-6: Long-Term Operational Emissions

Pollutant (pounds/day)¹ Project ROG NOX CO SOX PM10 PM2.5

Mobile Source 4.29 5.81 58.25 0.02 11.03 2.15

Area Source Emissions² 4.24 1.11 3.41 0.00 0.01 0.01

Total Emissions 8.53 6.92 56.66 0.07 11.04 2.16


Thresholds Exceeded? No No No No No No

Notes: 1 Based on URBEMIS 2007 modeling results, worst-case seasonal emissions for area and mobile emissions have been

modeled. 2 Area Source emissions exclude the use of fireplaces and wood burning stoves. Source: RBF Consulting, September 2010.

Area Source Emissions The Project would create electrical and heating demands, which will result in the combustion of natural gas. As depicted in Table 3.2-6 above, area source emissions (which exclude the use of fireplaces and wood burning stoves) generated directly by the project would not exceed SCAQMD thresholds. Thus, a less than significant impact would result.

Level of Significance Before Mitigation Less than significant impact for short-term and long-term emissions

Mitigation Measures Although the 2012 and 2013 unmitigated PM10 and PM2.5 and the 2011 PM2.5 levels during construction do not exceed the South Coast Air Quality Management District thresholds, Mitigation Measure AQ-1 for short-term fugitive dust emissions is recommended because the Basin has non-attainment status for PM10 and PM2.5. Similarly, although ROG levels during construction do not exceed SCAQMD thresholds, Mitigation Measure AQ-2 for short-term ROG emissions is recommended, as ROG is an ozone (O3) precursor, and the Basin has non-attainment status for O3.



MM AQ-1 During clearing, grading, earth moving, or excavation operations, excessive fugitive dust emissions shall be controlled by regular watering or other dust preventive measures using the following procedures, as specified in the South Coast Air Quality Management District’s Rules and Regulations.

• All material excavated or graded shall be sufficiently watered to prevent excessive amounts of dust. Watering shall occur at least three times daily with complete coverage, preferably in the late morning and after work is done for the day;

• Dust control techniques shall be consistent with SCAQMD Rule 403; • All material transported on- or off-site shall be either sufficiently watered or

securely covered to prevent excessive amounts of dust; • During construction activities, trackout devices shall be installed at all project

entrances; • The area disturbed by clearing, grading, earth moving, or excavation operations

shall be minimized so as to prevent excessive amounts of dust; • Visible dust beyond the property line emanating from the project shall be prevented

to the maximum extent feasible; and • These control techniques shall be indicated in project specifications. Compliance

with this measure shall be subject to periodic site inspections by the City. MM AQ-2 The following measures shall be implemented to reduce ROG emissions resulting

from application of architectural coatings:

• Contractors shall use high-pressure-low-volume (HPLV) paint applicators with a minimum transfer efficiency of at least 50 percent;

• Coatings and solvents that will be utilized have a volatile organic compound content lower than required under South Coast Air Quality Management District Rule 1113; and

• To the extent feasible, construction/building materials shall be composed of pre-painted materials.

Level of Significance After Mitigation Less than significant with mitigation incorporated.



Criteria Pollutant

Impact AQ-3 Would the Project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)?

Impact Analysis Cumulative Short-term Emissions The Project will comply with SCAQMD Rule 403 requirements and all feasible mitigation measures will be implemented. Rule 403 requires that fugitive dust be controlled with the best available control measures in order to reduce dust so that it does not remain visible in the atmosphere beyond the property line of the Project. In addition, the Project would comply with adopted 2007 Air Quality Management Plan emissions control measures.

Per SCAQMD rules and mandates, as well as the CEQA requirement that significant impacts be mitigated to the extent feasible, these same requirements (i.e., Rule 403 compliance, the implementation of all feasible mitigation measures, and compliance with adopted Air Quality Management Plan emissions control measures) would also be imposed on construction projects throughout the Basin, which would include related projects.

As detailed in the Air Quality/Greenhouse Gas Assessment, compliance with SCAQMD rules and regulations, as well as implementation of Mitigation Measures AQ-1 and AQ-2, would reduce the project’s construction-related impacts to a less than significant level. It can be reasonably inferred that the project-related construction emissions, in combination with those from other projects in the area, would not substantially deteriorate the local air quality and thus, a less than significant impact would occur.

Cumulative Long-term Emissions The SCAQMD does not recommend quantified analysis of cumulative construction or operational emissions, and does not provide separate methodologies/thresholds of significance to assess cumulative construction or operational impacts. However, if individual development projects generate operational emissions that exceed the SCAQMD recommended daily thresholds, project-specific impacts would also cause a cumulative considerable increase in emissions for those pollutants for which the Basin is in non-attainment.

As illustrated in Table 3.2-6, Long-Term Operational Emissions, long-term air quality impacts (from mobile and stationary source emissions) would not exceed established SCAQMD thresholds for SOX, ROG, CO, NOX, PM10, PM2.5, and CO. The Project would not exceed the SCAQMD’s thresholds of significance for regional criteria pollutants and as a result, the Project would not result in a cumulatively considerable net increase of any non-attainment criteria pollutant. Therefore, cumulative operational impacts associated with project operations would be less than significant.



Level of Significance Before Mitigation Potentially significant as the Basin has non-attainment status for O3, PM10 and PM2.5,Mitigation Measures.

Refer to Mitigation Measures AQ-1 and AQ-2, which are recommended to reduce the Project’s cumulative short-term contribution of criteria pollutants. No additional mitigation measures are required.

Level of Significance After Mitigation Less than significant.

Sensitive Receptors

Impact AQ-4 Would the Project expose sensitive receptors to substantial pollutant concentrations?

Impact Analysis Sensitive receptors are defined as facilities or land uses that include members of the population that are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. Examples of these sensitive receptors are residences, schools, hospitals, and daycare centers. Sensitive receptors within one mile of the Project site are identified in Table 3.2-2 Sensitive Receptors. To identify impacts to sensitive receptors, the South Coast Air Quality Management District (SCAQMD) recommends addressing localized significance thresholds for construction and operations impacts, as well as a carbon monoxide hot-spots analysis. Refer to the sections below where each of these topics is addressed.

Localized Significance Thresholds (LST) The SCAQMD LST methodology provides Localized Significance Thresholds for project sizes of one, two, and five acres, and for distances to sensitive receptors of 25, 50, 100, 200, and 500 meters. The SCAQMD recommends that any project over five acres should perform air quality dispersion modeling to assess impacts to nearby sensitive receptors. Due to the fact that the Project is approximately eight and a half acres in size and that about five acres would be disturbed on a daily basis, a Localized Significance Threshold analysis was performed for a five-acre project. The Localized Significance Thresholds operational analysis was performed for a five acre project to demonstrate the minimal extent of project-related air quality impacts to sensitive receptors. The project is located in Source Receptor Area (SRA) 20, Central Orange County Coastal.

The closest sensitive receptors to the project site are approximately 12-25 feet west of the project site. The nearby residents may be potentially affected by air pollutant emissions generated during onsite construction activities. Since the nearest sensitive receptor is within 25 meters, the localized significance threshold value of 25 meters was utilized. Localized significance thresholds are derived based on the location of the activity (i.e., the source/receptor area), the emission rates of NOX, CO, PM10, and PM2.5, and the distance to the nearest exposed individual.



Localized Construction Emissions Table 3.2-7, Summary of Localized Significance of Construction Emissions below shows the construction-related emissions for NOX, CO, PM10, and PM2.5 compared to the localized significance thresholds for Source Receptor Area 20, Central Orange County Coastal, at a distance of 25 meters for a five-acre site. The distance of 25 meters and the site size of 5 acres are utilized in the analysis because, per the Air Quality/Greenhouse Gas Assessment prepared for the Project, the South Coast Air Quality Management District (SCAQMD) Localized Significance Threshold (LST) methodology provides Localized Significance Thresholds for project sizes of one, two, and five acres, and for distances to sensitive receptors of 25, 50, 100, 200, and 500 meters. As detailed in the Air Quality/Greenhouse Gas Assessment prepared for the Project, although the project area is approximately 8.5 acres, construction activities would disturb approximately five acres per day; therefore, the Localized Significance Thresholds construction analysis was performed for a five acre project.

Table 3.2-7 presents construction year 2011 mitigated emissions, which represent the greatest emissions levels during the construction period. Emissions would be reduced with implementation of Mitigation Measures AQ-1 and AQ-2. Additionally, Mitigation Measure AQ-3 would limit grading activities to a maximum disturbed area of five acres per day to ensure construction emissions remain below the Localized Significance Thresholds for particulate matter. As shown below, mitigated construction emissions would not exceed the localized significance thresholds. Therefore, localized significance construction impacts would be less than significant with implementation of Mitigation Measures AQ-1 through AQ-3.

Table 3.2-7: Summary of Localized Significance of Construction Emissions

Pollutant (pounds/day)1 Emissions Source NOX CO PM10 PM2.5

Total Mitigated Emissions 65.88 48.49 13.30 5.45

Localized Significance Threshold2 197 1,711 14 9

Is Threshold Exceeded? No No No No

Notes: 1 Emissions calculated using the URBEMIS 2007 Version 9.2.4 Computer Model as recommended by the South Coast

Air Quality Management District. 2 The Local Significance Threshold was determined using Appendix C of the SCAQMD Final Localized Significant

Threshold Methodology guidance document for pollutants NOX, CO, PM10, and PM2.5. The Localized Significance Threshold is based on the project acreage (approximately five acres disturbed per day), the source receptor area (SRA 20), and distance to nearest sensitive receptor (25 meters).


Localized Operational Emissions. Localized operational emissions represent the maximum emissions from a project (excluding mobile source emissions) that would not cause or contribute to an exceedance of the most stringent applicable Federal or State ambient air quality standard, and are developed based on the ambient concentrations of that pollutant for each source receptor area. As indicated in Table 3.2-8, Summary of Localized Significance of Operational Emissions, the localized area source emissions from the



Project would not exceed the SCAQMD localized thresholds. Therefore, localized emissions from operation of the Project would be less than significant.

Table 3.2-8: Summary of Localized Significance of Operational Emissions

Pollutant (pounds/day)1 Operational Phase NOX CO PM10 PM2.5

Area Source Emissions2 1.11 3.41 0.01 0.01

Localized Significance Threshold3 197 1,711 4 2

Thresholds Exceeded? No No No No

Notes: 1 Emissions calculated using the URBEMIS 2007 Version 9.2.4 Computer Model as recommended by the South Coast

Air Quality Management District. 2 Emissions are area source only because the LST methodology does not evaluate localized impacts from mobile

sources traveling over the roadways. 3 The Local Significance Threshold was determined using Appendix C of the SCAQMD Final Localized Significant

Threshold Methodology guidance document for pollutants NOX, CO, PM10, and PM2.5. The Localized Significance Threshold is based on the project acreage (model conservatively uses 5 acres), the source receptor area (SRA 20), and distance to nearest sensitive receptor (25 meters).


Carbon Monoxide Hot-Spots Carbon monoxide emissions are a function of vehicle idling time, meteorological conditions, and traffic flow. The South Coast Air Quality Management District requires a quantified assessment of CO hotspot when a project increases the volume to capacity ratio (also called the intersection capacity utilization) by 0.02 (two percent) for any intersection with an existing level of service (LOS) D or worse. As detailed in the Vista Verde Project Traffic Impact Analysis, prepared by RBF Consulting, the Project does not involve an intersection with a LOS D or worse and would not increase the volume to capacity ratio by 0.02 percent for an intersection with a LOS D or worse. Additionally, the Project would not degrade a study intersection from LOS C or better to a LOS D or worse. Thus, the Project does not trigger the requirements for a CO microscale hotspot analysis and impacts would be less than significant in this regard.

Level of Significance Before Mitigation Potentially significant localized construction emissions impact. Less than significant localized operational emissions impact.

Mitigation Measures Refer to Mitigation Measures AQ-1 and AQ-2 and Mitigation Measure AQ-3 below.

MM AQ-3 Site disturbance and grading activities shall be limited to no more than five acres per day. This limitation shall be shown on the grading plan and verified by the Community Development Director prior to the issuance of a grading permit.




Objectionable Odor

Impact AQ-5 Would the Project create objectionable odor affecting a substantial number of people?

Impact Analysis According to the SCAQMD CEQA Air Quality Handbook, land uses associated with odor complaints typically include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding. The Project does not include any uses identified by the SCAQMD as being associated with odors.

Construction activity associated with the Project may generate odors from heavy-duty equipment exhaust. Construction-related odors would be short-term in nature and cease upon project completion. A potential long-term source of odors would be the new trash receptacles for the project. However, residential trash receptacles typically do not generate odors that affect a substantial number of people. Additionally, per City of Irvine regulations for the collection of solid waste, all new trash receptacles are required to have lids, which would limit odors emanating from the receptacles. Impacts to existing adjacent land uses are considered less than significant given the project size and the City of Irvine regulations.

Level of Significance Before Mitigation Less than significant.

Mitigation Measures No mitigation measures are required.


3.2 - air quality - city of irvine

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