HomeMy WebLinkAbout!Ch 05.04 AQ 5.4 Air Quality
Otay Ranch Village 8 West EIR
CV EIR 10-03; SCH No. 2010062093 Page 5.4-1
City of Chula Vista
November 2013
5.4 Air Quality
This section describes existing air quality conditions of the project site and the surrounding region and
evaluates the potential impacts to air quality due to the project.
As stated in Section 2.3, Purpose and Legal Authority, this EIR tiers from the 2013 GPA/GDPA SEIR (09-
01). Section 5.5, Air Quality, of the Final SEIR for the GPA/GDPA (SEIR 09-01) analyzed the existing
conditions, potential impacts, and mitigation measures related to the proposed land uses for the GPA/
GDPA area, including Village 8 West. The GPA/GDPA SEIR identified a potentially significant and
unavoidable impact related to consistency with the Regional Air Quality Strategy (RAQS) because growth
assumptions for the GPA/GDPA would exceed the growth projection in the RAQS. A significant impact
was also identified related to criteria air pollutant emissions from construction and operations of the
proposed land uses. The SEIR determined that compliance with BMPs would reduce construction
impacts to a less than significant level, but additional mitigation would be required at the project level
for operational impacts. The analysis and discussion of air quality contained in the GPA/GDPA SEIR are
incorporated by reference.
Information contained in this section is based on the Otay Ranch Village 8 West SPA Project Air Quality
Technical Report, prepared by Atkins in May 2013. The Air Quality Technical Report is included as
Appendix C of this EIR. The analysis in the air quality technical report also provides the basis for the
Village 8 West AQIP, included as part of the SPA Plan, as it relates to criteria air pollutant emissions. The
report updates the applicable information contained in the SEIR.
5.4.1 Existing Conditions
A. Regulatory Framework
1. Federal
a. Clean Air Act
The Clean Air Act (CAA) of 1970 and the CAA Amendments of 1971 required the U.S. Environmental
Protection Agency (EPA) to establish National Ambient Air Quality Standards (NAAQS) with states
retaining the option to adopt more stringent standards or to include other specific pollutants. These
standards are the levels of air quality considered safe, with an adequate margin of safety, to protect the
public health and welfare. They are designed to protect those sensitive receptors most susceptible to
further respiratory distress such as asthmatics, the elderly, very young children, people already
weakened by other disease or illness, and persons engaged in strenuous work or exercise. Healthy
adults can tolerate occasional exposure to air pollutant concentrations considerably above these
minimum standards before adverse effects are observed.
Current NAAQS are listed in Table 5.4-1. Areas that meet the ambient air quality standards are classified
as “attainment” areas while areas that do not meet these standards are classified as “non-attainment”
areas.
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Table 5.4-1 National and California Ambient Air Quality Standards
Pollutant Averaging Time
California Standards (1) Federal Standards (2)
Concentration(3) Primary (3, 4) Secondary (3, 5)
Ozone (O3) 1-hour 0.09 ppm (180 μg/m3) -- Same as Primary Standard 8-hour 0.070 ppm (137 μg/m3) 0.075 ppm (147 μg/m3)
Respirable
Particulate Matter
(PM10)
24 Hour 50 μg/m3 150 μg/m3
Same as Primary Standard Annual Arithmetic Mean 20 μg/m --
Fine Particulate
Matter (PM2.5)
24 Hour No Separate Standard 35 μg/m3
Same as Primary Standard Annual Arithmetic Mean 12 μg/m3 15 μg/m3
Carbon Monoxide
(CO)
8-hour 9 ppm (10 mg/m3) 9 ppm (10 mg/m3) None 1-hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3)
Nitrogen Dioxide
(NO2)
Annual Arithmetic Mean 0.030 ppm (57 μg/m3) 53 ppm (100 μg/m3)6 Same as Primary Standard
1-hour 0.18 ppm (470 mg/m3) 100 ppb (188 μg/m3)6 None
Sulfur Dioxide (SO2)
24 Hour 0.04 ppm (105 μg/m3) -- --
3 Hour -- -- 0.5 ppm (1300 μg/m3)7
1-hour 0.25 ppm (655 μg/m3) 75 ppb (196 μg/m3)7 --
Lead (Pb)(8)
30 Day Average 1.5 μg/m3 -- --
Calendar Quarter -- 1.5 μg/m3 Same as Primary Standard Rolling 3-Month Avg(9) -- 0.15 μg/m3
Visibility Reducing
Particles 8-hour
Extinction coefficient of 0.23
per kilometer - visibility of 10
miles or more due to particles.
No Federal Standard
Sulfates 24 Hour 25 μg/m3 No Federal Standard
Hydrogen Sulfide 1-hour 0.03 ppm (42 μg/m3) No Federal Standard
Vinyl Chloride(8) 24 Hour 0.01 ppm (26 μg/m3) No Federal Standard
ppm = parts per million; ppb = parts per billion
(1) California standards for ozone, PM10, CO, NO2, SO2 (1-hour and 24-hour), and visibility reducing particles are values that are not to be exceeded.
The standards for sulfates, lead, hydrogen sulfide, and vinyl chloride standards are not to be equaled or exceeded.
(2) National standards, other than 1-hour ozone, 8-hour ozone, 24-hour PM10, 24-hour PM2.5, and those based on annual averages, are not to be
exceeded more than once a year. The 1-hour ozone standard is attained when the expected number of days per calendar year with maximum
hourly average concentrations above the standard is equal to or less than one. The 8-hour ozone standard is attained when the 3-year average of
the annual fourth-highest daily maximum 8-hour concentrations is below 0.08 ppm. The 24-hour PM10 standard is attained when the 3-year
average of the 99th percentile 24-hour concentrations is below 150 µg/m3. The 24-hour PM2.5 standard is attained when the 3-year average of the
98th percentile 24-hour concentrations is below 65 µg/m3.
(3) Concentration expressed first in units in which it was promulgated. Equivalent units given in parenthesis are based on a reference temperature
of 25C and a reference pressure of 760 mm of mercury (1,013.2 millibar). All measurements of air quality are to be corrected to a reference
temperature of 25C and a reference pressure of 760 mm of mercury; 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) National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of
a pollutant.
(6) 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). Note that the EPA standards are in units of ppb. California standards are in units of ppm. To directly
compare the national standards to the California standards the units can be converted from ppb to ppm. In this case, the national standards of 53
ppb and 100 ppb are identical to 0.053 ppm and 0.100 ppm, respectively.
(7) On June 2, 2010, the EPA established a new 1-hour SO2 standard, effective August 23, 2010, which is based on the 3-year average of the annual
99th percentile of 1-hour daily maximum concentrations. EPA also proposed a new automated Federal Reference Method using ultraviolet
technology, but will retain the older pararosaniline methods until the new methods have adequately permeated state monitoring networks. The
EPA also revoked both the existing 24-hour SO2 standard of 0.14 ppm and the annual primary SO2 standard of 0.030 ppm, effective August 23,
2010. The secondary SO2 standard was not revised at that time; however, the secondary standard is undergoing a separate review by EPA. Note
that the new standard is in units of ppb. California standards are in units of ppm. To directly compare the new primary national standard to the
California standard the units can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.
(8) The CARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health effects
determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these
pollutants.
(9) National lead standard, rolling 3-month average: final rule signed October 15, 2008.
Source: CARB 2010a.
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The CAA (and its subsequent amendments) requires each state to prepare an air quality control plan
referred to as the State Implementation Plan (SIP). The CAA Amendments dictate that states containing
areas violating the NAAQS revise their SIPs to include extra control measures to reduce air pollution. The
SIP includes strategies and control measures to attain the NAAQS by deadlines established by the CAA.
The SIP is periodically modified to reflect the latest emissions inventories, plans, and rules and
regulations of air basins as reported by the agencies with juri sdiction over them. The EPA has the
responsibility to review all SIPs to determine if they conform to the requirements of the CAA.
2. State
a. California Clean Air Act
The federal CAA allows states to adopt ambient air quality standards and other regulations provided
that they are at least as stringent as federal standards. The California CAA was adopted in 1988 and
establishes the state’s air quality goals, planning mechanisms, regulatory strategies, and standards of
progress. CARB, a part of the California EPA (CalEPA) is responsible for the coordination and
administration of both federal and state air pollution control programs within California, including
setting the California ambient air quality standards (CAAQS). CARB also conducts research, compiles
emission inventories, develops suggested control measures, and provides oversight of local programs.
The CARB establishes emissions standards for motor vehicles sold in California, consumer products (such
as hairspray, aerosol paints, and barbecue lighter fluid), and various types of commercial equipment. It
also sets fuel specifications to further reduce vehicular emissions. The CARB also has primary
responsibility for the development of California’s SIP, for which it works closely with the federal
government and the local air districts.
In addition to standards set for the criteria pollutants, the state has set standards for sulfates, hydrogen
sulfide, vinyl chloride, and visibility-reducing particles (see Table 5.4-1); however, these are not
pollutants of concern for Village 8 West because construction and operation of the proposed land uses
would not result in emissions of these pollutants. These standards are designed to protect the health
and welfare of the populace with a reasonable margin of safety. Further, in addition to primary and
secondary CAAQS, the state has established a set of episode criteria for ozone, carbon monoxide,
nitrogen dioxide, sulfur dioxide, and particulate matter. These criteria refer to episode levels
representing periods of short-term exposure to air pollutants that actually threaten public health.
b. Toxic Air Contaminants
The public’s exposure to toxic air contaminants (TACs) is a significant public health issue in California. In
1983, the California Legislature enacted a program to identify the health effects of TACs and to reduce
exposure to these contaminants to protect the public health (AB 1807: Health and Safety Code Sections
39650-39674). The Legislature established a two-step process to address the potential health effects
from TACs. The first step is the risk assessment (or identification) phase. The second step is the risk
management (or control) phase of the process.
Diesel exhaust particulate matter emissions have since been established as TACs. Following the
identification of diesel particulate matter as an air toxic in 1998, the CARB has worked on developing
strategies and regulations aimed at reducing the risk from diesel particulate matter. The overall strategy
for achieving these reductions is found in the Risk Reduction Plan to Reduce Particulate Matter
Emissions from Diesel Fueled Engines and Vehicles (CARB 2000). A stated goal of the plan is to reduce
the cancer risk statewide arising from exposure to diesel particulate matter by 85 percent by 2020. A
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number of programs and strategies to reduce diesel particulate matter that have been or are in the
process of being developed include:
The Carl Moyer Program: This program, administered by the CARB, was initially approved in February
1999 and is regularly updated. The most recent program guidelines are the 2011 Carl Moyer Program
Guidelines, approved in April 2011 and released in January 2012. It provides grants to private
companies, public agencies, or individuals operating heavy-duty diesel engines to cover an incremental
portion of the cost of cleaner on-road, off-road, marine, locomotive, and agricultural irrigation pump
engines.
California Diesel Fuel Regulations: The California Diesel Fuel Regulations (California Code of Regulations
[CCR] Title 13, Sections 2281-2285 and CCR Title 17, Section 93114) set limits on the aromatic
hydrocarbon and sulfur content for diesel fuel marketed in California. Under these rules, starting in June
2006 in accordance with the phase-in schedule, vehicular diesel fuel must not have a sulfur content that
exceeds 15 parts per million (ppm) by weight. The regulations also specify that on or after October 1,
1993, the aromatic hydrocarbon content of vehicular diesel fuel must not exceed 10 percent by volume.
On-Road Heavy-Duty Diesel New Engine Program: This program develops strategies and regulations to
reduce diesel emissions from new on-road diesel-powered equipment. Emission control regulations
have been coordinated with the EPA and require that new engines manufactured in and subsequent to
2004 meet new emissions requirements for particulates and other pollutants.
Heavy-Duty Diesel In-Use Strategies Program: The goal of this program is to develop and implement
strategies for reducing diesel emissions from existing on and off-road diesel engines. The Retrofit
Assessment section is responsible for the development and implementation of procedures for assessing,
recommending, and approving emission control devices. The Retrofit Implementation section is
responsible for developing plans for retrofitting on- and off-road engines with emission reducing
technologies. To date plans being developed or implemented have targeted solid waste collection
vehicles, on-road heavy-duty public fleet vehicles, and fuel delivery trucks. Generally, these plans
require that a percentage of the fleet, based on age of the vehicles, be retrofitted on a predetermined
schedule.
Other programs include:
Off-Road Mobile Sources Emission Reduction Program: The goal of this program is to develop
regulations to control emissions from diesel, gasoline, and alternative-fueled off-road mobile engines.
These sources include a range of equipment from lawn mowers to construction equipment to
locomotives.
Heavy-Duty Vehicle Inspection and Periodic Smoke Inspection Program: This program provides
periodic inspections to ensure that truck and bus fleets do not emit excessive amounts of smoke.
Lower-Emission School Bus Program: Under this program, and in coordination with the California
Energy Commission, the CARB is developing guidelines to provide criteria for the purchase of new school
buses and the retrofit of existing school buses to reduce particulate matter emissions.
As an ongoing process, the CARB continues to establish new programs and regulations for the control of
diesel particulate emissions as appropriate. The continued development and implementation of these
programs and policies ensures that public exposure to diesel particulate matter will continue to decline.
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c. California Health and Safety Code Section 41700
This section of the Health and Safety Code states that a person shall not discharge from any source
whatsoever quantities of air contaminants or other material that cause injury, detriment, nuisance, or
annoyance to any considerable number of persons or to the public, or that endanger the comfort,
repose, health, or safety of any of those persons or the public, or that cause, or have a natural tendency
to cause, injury or damage to business or property. This regulation also applies to sources of
objectionable odors.
d. California Building Standards Code Title 24, Part 6
Title 24, Part 6 of the California Building Standards Code regulates energy uses including space heating
and cooling, hot water heating, and ventilation. The energy code allows new buildings to meet a
performance standard that allows a builder to choose the most cost effective energy saving measures to
meet the standard from a variety of measures including added insulation, improved HVAC systems, and
more efficient water heating and lighting systems. New construction and major renovations must
demonstrate their compliance with the current Energy Code through submission and approval of a Title
24 Compliance Report to the local building permit review authority and the California Energy
Commission. The Code is updated periodically to incorporate and consider new energy efficiency
technologies and methodologies as they become available. The most recent amendments to the Code,
known as Title 24 2008, or the 2008 Energy Code, became effective January 1, 2010. At a minimum,
residential buildings must achieve a 15 percent reduction in their combined space heating, cooling and
water heating energy compared to the Title 24 2005 standards.
3. Local
a. San Diego County Regional Air Quality Strategy and State Implementation Plan
The San Diego Air Pollution Control District (SDAPCD) is the local agency responsible for the
administration and enforcement of air quality regulations for San Diego County. The SDAPCD regulates
most air pollutant sources, except for motor vehicles, marine vessels, aircrafts, and agricultural
equipment, which are regulated by the CARB or the EPA. State and local government projects, as well as
projects proposed by the private sector, are subject to SDAPCD requirements if the sources are
regulated by the SDAPCD. Additionally, the SDAPCD, along with the CARB, maintains and operates
ambient air quality monitoring stations at numerous locations throughout San Diego County. These
stations are used to measure and monitor criteria and toxic air pollutant levels in the ambient air.
The SDAPCD and SANDAG are responsible for developing and implementing the clean air plan for
attainment and maintenance of the ambient air quality standards in the San Diego Air Basin (SDAB). The
San Diego County RAQS was initially adopted in 1991, and is updated on a triennial basis. The RAQS was
updated in 1995, 1998, 2001, 2004, and most recently in April 2009. The RAQS outlines the SDAPCD’s
plans and control measures designed to attain the state air quality standards for ozone. The SDAPCD has
also developed the SDAB’s input to the SIP, which is required under the federal CAA for pollutants that
are designated as being in non-attainment of national air quality standards for the basin.
The RAQS relies on information from CARB and SANDAG, including mobile and area source emissions, as
well as information regarding projected growth in the county, to project future emissions and then
establish the strategies necessary for the reduction of emissions through regulatory controls. The CARB
mobile source emission projections and SANDAG growth projections are based on population and
vehicle trends and land use plans developed by the cities and by the County of San Diego as part of the
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development of the County’s General Plan. As such, projects that propose development that is
consistent with the growth anticipated by the general plans would be consistent with the RAQS. In the
event that a project would propose development which is less dense than anticipated within the general
plan, the project would likewise be consistent with the RAQS. If a project proposes development that is
greater than that anticipated in the general plan and SANDAG’s growth projections, the project might be
in conflict with the RAQS and SIP, and might have a potentially significant impact on air quality.
The SIP relies on the same information from SANDAG to develop emission inventories and emission
reduction strategies that are included in the attainment demonstration for the air basin. The SIP also
includes rules and regulations that have been adopted by the SDAPCD to control emissions from
stationary sources. These SIP-approved rules may be used as a guideline to determine whether a
project’s emissions would have the potential to conflict with the SIP and thereby hinder attainment of
the NAAQS for ozone.
b. City of Chula Vista General Plan and Growth Management Ordinance
Included in the Chula Vista General Plan is the Growth Management Ordinance. Air quality is identified
as an important part of the quality of life in Chula Vista and one of the stated policies of the element
(Policy GM 4.4) adapts city regulations to meet federal and state air quality standards. In addition, the
Growth Management Ordinance (Municipal Code Section 19.09.050B) requires an AQIP be prepared for
all major development projects (50 dwelling units or greater) as part of the SPA Plan process. The AQIP
for the project must comply with the city AQIP guidelines. Copies of AQIP Guidelines are available at the
City of Chula Vista Planning and Building Department.
c. City of Chula Vista General Plan
The Environmental Element of the Chula Vista General Plan contains Objective E 6 and it multiple
supporting policies to improve local air quality by minimizing the production and emission of air
pollutants and TACs, and limit the exposure of people to such pollutants. Policies include encouraging
compact development (E 6.1), facilitating transit (E 6.2), avoiding siting sensitive receptors near major
toxic sources (E 6.4 and E 6.10), developing strategies to minimize carbon monoxide hot spots that
address all modes of transportation (E 6.11); and siting industries in a way that minimizes the potential
impacts of poor air quality on homes, schools, hospitals, and other land uses where people congregate
(E 6.15).
d. City of Chula Vista Green Building Ordinance
The City of Chula Vista has adopted Green Building Standards (CVMC Chapter 15.12) and Energy
Efficiency Standards (CVMC Section 15.26.030) that require increased energy efficiency of 15 percent
beyond the 2008 Title 24, Part 6 energy requirements. No building permit shall be issued for any project
subject to city requirements until the Building Official has determined that the plans and specifications
submitted for the building permit are in compliance with the green building and energy efficiency
standards.
e. Otay Ranch General Development Plan
Part II, Chapter 6, Section C of the GDP establishes goals to minimize the adverse impacts of
development on air quality including creating a safe and efficient multi-modal transportation network
which minimizes the number and length of single passenger vehicle trips.
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■ Objective: Minimize the number and length of single passenger vehicle trips to and from
employment and commercial centers to achieve an average of 1.5 persons per passenger
vehicle during weekday commute hours.
■ Policies:
Encourage, as appropriate, alternative transportation incentives offered to employees,
alternative work hour programs, alternative transportation promotional materials,
information on car pool and van pool matching services, transit pass information, space for
car-pool and van-pool-riders-wanted advertisements, information about transit and rail
service, as well as information about bicycle facilities, routes, storage, and location of
nearby shower and locker facilities.
Promote telecommuting and teleconferencing programs and policies in employment
centers.
Establish or participate in education-based commute programs, which minimize the number
and length of single passenger vehicle trips.
Provide on-site amenities in commercial and employment centers to include childcare
facilities, post offices, banking services, cafeterias/delis/restaurants, etc.
f. SDAPCD Particulate Matter Reduction Measures
In addition to the RAQS and SIP, the SDAPCD adopted the “Measures to Reduce Particulate Matter in
San Diego County” report in December 2005. This report is based on particulate matter reduction
measures adopted by CARB. The SDAPCD evaluated CARB's list of measures and found that the majority
were already being implemented in San Diego County. As a result of the evaluation, SDAPCD proposed
measures for further evaluation to reduce particulate emissions from residential wood combustion and
from fugitive dust from construction sites and unpaved roads. The SDAPCD requires that construction
activities implement the measures listed in Rule 55 to minimize fugitive dust emissions. Rule 55 requires
the following:
1. No person shall engage in construction or demolition activity in a manner that discharges visible
dust emissions into the atmosphere beyond the property line for a period or periods
aggregating more than 3 minutes in any 60-minute period.
2. Visible roadway dust as a result of active operations, spillage from transport trucks, erosion, or
track-out/carry-out shall be minimized by the use of any of the equally effective trackout/carry-
out and erosion control measures listed in Rule 55 that apply to the project or operation. These
measures include track-out grates or gravel beds at each egress point; wheel-washing at each
egress during muddy conditions; soil binders, chemical soil stabilizers, geotextiles, mulching, or
seeding; watering for dust control; and using secured tarps or cargo covering, watering, or
treating of transported material for outbound transport trucks. Visible roadway dust must be
removed at the conclusion of each work day when active operations cease, or every 24 hours for
continuous operations.
g. Other APCD Rules and Regulations
The SDAPCD adopted Rule 67, Architectural Coatings, in December 2001, which establishes volatile
organic compounds (VOC) content limits for architectural coatings. Additionally, APCD Rule 1210
implements the public notification and risk reduction requirements of the State Air Toxics “Hot Spots”
Act, and requires facilities to reduce risks to acceptable levels within five years. Rule 1200 establishes
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acceptable risk levels, and emission control requirements for new and modified facilities that may emit
additional TACs. Rule 51 also prohibits nuisances, including objectionable odors.
5.4.2 Existing Air Quality
A. Climate
Regional climate and local meteorological conditions influence ambient air quality. Village 8 West is
located in the SDAB. The climate of the SDAB is dominated by a semi-permanent high-pressure cell
located over the Pacific Ocean. This cell influences the direction of prevailing winds (westerly to
northwesterly) and maintains clear skies for much of the year. It also drives the dominant onshore
circulation and helps create two types of temperature inversions, subsidence and radiation, that
contribute to local air quality degradation.
Subsidence inversions occur during warmer months, as descending air associated with the Pacific high-
pressure cell comes into contact with cool marine air. The boundary between the two layers of air
represents a temperature inversion that traps pollutants below it. Radiation inversions typically develop
on winter nights with low wind speeds, when air near the ground cools by radiation, and the air aloft
remain warm. A shallow inversion layer that can trap pollutants is formed between the two layers.
In the vicinity of the project area, the nearest climatological monitoring station that provides
precipitation data is located at the lower Otay Reservoir, approximately three miles east of the project
site. The normal precipitation in the lower Otay Reservoir area is 11 inches annually, occurring primarily
from December through March (WRCC 2011a). Temperature is recorded at the monitoring station
located in the community of Bonita, north of the Otay Ranch area. The normal daily maximum
temperature in Bonita is 81 °F in August, and the normal daily minimum temperature is 40°F in
December and January (WRCC 2011b).
B. Health Effects Related to Air Pollutants
Federal and state laws regulate the air pollutants emitted into the ambient air by stationary and mobile
sources. These regulated air pollutants are known as “criteria air pollutants” and are categorized as
primary and secondary pollutants. Primary air pollutants are those that are emitted directly from
sources. Carbon monoxide, VOC, nitrogen oxides (NOx), sulfur dioxide (SO2), and most fine particulate
matter including lead and fugitive dust (PM10 and PM2.5) are primary air pollutants. Of these, carbon
monoxide, sulfur dioxide, PM10, and PM2.5 are criteria pollutants. VOCs and nitrogen oxides are criteria
pollutant precursors that go on to form secondary criteria pollutants through chemical and
photochemical reactions in the atmosphere. Ozone and nitrogen dioxide are the principal secondary
pollutants. Diesel particulate matter is a mixture of particles and is a component of diesel exhaust. The
EPA lists diesel exhaust as a mobile source air toxic due to the cancer and non-cancer health effects
associated with exposure to whole diesel exhaust.
The following is a description of each of the primary and secondary criteria air pollutants and their
known health effects.
Carbon Monoxide (CO) is an odorless, colorless, and toxic gas. Because it is impossible to see, taste, or
smell the toxic fumes, carbon monoxide can kill people before they are aware that it is in their homes.
At lower levels of exposure, carbon monoxide causes mild effects that are often mistaken for the flu.
These symptoms include headaches, dizziness, disorientation, nausea, and fatigue. The effects of carbon
monoxide exposure can vary greatly from person to person depending on age, overall health, and the
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concentration and length of exposure (EPA 2010a). The major sources of carbon monoxide in the SDAB
are on-road vehicles, aircraft, and off-road vehicles and equipment.
Volatile Organic Compounds (VOCs) are defined as any compound of carbon, excluding carbon
monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate,
which participates in atmospheric photochemical reactions. VOCs consist of non-methane hydrocarbons
and oxygenated hydrocarbons. Hydrocarbons are organic compounds that contain only hydrogen and
carbon atoms. Non-methane hydrocarbons are hydrocarbons that do not contain the un-reactive
hydrocarbon, methane. Oxygenated hydrocarbons are hydrocarbons with oxygenated functional groups
attached.
It should be noted that there are no CAAQS or NAAQS for VOCs because they are not classified as
criteria pollutants. They are regulated, however, because a reduction in VOC emissions reduces certain
chemical reactions that contribute to the formulation of ozone. VOCs are also transformed into organic
aerosols in the atmosphere, which contribute to higher PM10 levels and lower visibility. Although health-
based standards have not been established for VOCs, health effects can occur from exposures to high
concentrations because of interference with oxygen uptake. In general, higher concentrations of VOCs
are suspected to cause eye, nose, and throat irritation; headaches; loss of coordination; nausea; and
damage to the liver, kidneys, and central nervous system (EPA 1999).
The major sources of VOCs in the SDAB are on-road motor vehicles and solvent evaporation. Benzene, a
VOC and known carcinogen, is emitted into the air from gasoline service stations (fuel evaporation),
motor vehicle exhaust, tobacco smoke, and from burning oil and coal. Benzene is also sometimes used
as a solvent for paints, inks, oils, waxes, plastic, and rubber. It is used in the extraction of oils from seeds
and nuts. It is also used in the manufacture of detergents, explosives, dyestuffs, and pharmaceuticals.
Short-term (acute) exposure of high doses of benzene from inhalation may cause dizziness, drowsiness,
headaches, eye irritation, skin irritation, and respiratory tract irritation. At higher levels,
unconsciousness can occur. Long-term (chronic) occupational exposure of high doses by inhalation has
caused blood disorders, including aplastic anemia and lower levels of red blood cells (EPA 1999).
Nitrogen Oxides (NOx) are a byproduct of fuel combustion and serve as integral components in the
process of photochemical smog production. The two major forms of nitrogen oxides are nitric oxide
(NO) and nitrogen dioxide (NO2). Nitric oxide is a colorless, odorless gas formed from atmospheric
nitrogen and oxygen when combustion takes place under high temperature and/or high pressure.
Nitrogen dioxide is a reddish-brown, irritating gas formed by the combination of nitric oxide and oxygen.
Nitrogen oxides act as an acute respiratory irritant and increases susceptibility to respiratory pathogens.
Nitrogen oxides are also an ozone precursor. A precursor is a directly emitted air contaminant that,
when released into the atmosphere, forms, causes to be formed, or contributes to the formation of a
secondary air contaminant for which a NAAQS has been adopted, or whose presence in the atmosphere
will contribute to the violation of one or more NAAQS. When nitrogen oxide and VOCs are released in
the atmosphere, they chemically react with one another in the presence of sunlight to form ozone.
While the EPA’s NAAQS covers this entire family, nitrogen dioxide is the component of greatest interest
and the indicator for the larger group of nitrogen oxides.
Ozone is one of a number of substances called photochemical oxidants that are formed when VOCs and
nitrogen oxides (both byproducts of the internal combustion engine) react with sunlight. Ozone is
present in relatively high concentrations in the SDAB, and the damaging effects of photochemical smog
are generally related to ozone concentrations. Ozone may pose a health threat to those who already
suffer from respiratory diseases as well as healthy people. Additionally, ozone has been tied to crop
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damage, typically in the form of stunted growth and pre-mature death. Ozone can also act as a
corrosive, resulting in property damage such as the embitterment of rubber products.
Lead (Pb) is a solid heavy metal that can exist in air pollution as an aerosol particle component. An
aerosol is a collection of solid, liquid, or mixed-phase particles suspended in the air. Lead was first
regulated as an air pollutant in 1976. Leaded gasoline was first marketed in 1923 and was used in motor
vehicles until around 1970. The exclusion of lead from gasoline helped to decrease emissions of lead in
the United States from 219,000 to 4,000 tons per year between 1970 and 1997. Even though leaded
gasoline has been phased out in most countries, some, such as Egypt and Iraq, still use at least some
leaded gasoline (United Nations Environment Programme 2010). Lead ore crushing, lead-ore smelting,
and battery manufacturing are currently the largest sources of lead in the atmosphere in the United
States. Other sources include dust from soils contaminated with lead-based paint, solid waste disposal,
and physical weathering of surfaces containing lead. The mechanisms by which lead can be removed
from the atmosphere (sinks) include deposition to soils, ice caps, oceans, and inhalation.
Lead accumulates in bones, soft tissue, and blood and can affect the kidneys, liver, and nervous system.
The more serious effects of lead poisoning include behavioral disorders, mental retardation, and
neurological impairment. Low levels of lead in fetuses and young children can result in nervous system
damage, which can cause learning deficiencies and low intelligence quotients. Lead may also contribute
to high blood pressure and heart disease. Lead concentrations once exceeded the state and national air
quality standards by a wide margin but have not exceeded these standards at any regular monitoring
station since 1982. Lead is no longer an additive to normal gasoline, which is the main reason that
concentration of lead in the air is now much lower. The project would not emit lead; therefore, lead has
been eliminated from further review in this analysis.
Sulfur Dioxide is a colorless, pungent gas. At levels greater than 0.5 ppm, the gas has a strong odor,
similar to rotten eggs. Sulfuric acid is formed from sulfur dioxide and is an aerosol particle component
that may lead to acid deposition. Acid deposition into water, vegetation, soil, or other materials can
harm natural resources and materials. Sulfur oxides include sulfur dioxide and sulfur trioxide. Although
sulfur dioxide concentrations have been reduced to levels well below state and national standards,
further reductions are desirable because sulfur dioxide is a precursor to sulfates. Sulfates are a
particulate formed through the photochemical oxidation of sulfur dioxide. Long-term exposure to high
levels of sulfur dioxide can cause irritation of existing cardiovascular disease, respiratory illness, and
changes in the defenses in the lungs. When people with asthma are exposed to high levels of sulfur
dioxide for short periods of time during moderate activity, effects may include wheezing, chest
tightness, or shortness of breath.
Particulate Matter consists of finely divided solids or liquids such as soot, dust, aerosols, fumes, and
mists. Two forms of fine particulate, also known as fugitive dust, are now recognized. Course particles
(PM10) include that portion of the particulate matter with an aerodynamic diameter of 10 microns (i.e.,
10 one-millionths of a meter or 0.0004 inch) or less. Fine particles (PM2.5) have an aerodynamic diameter
of 2.5 microns, that is 2.5 one-millionths of a meter or 0.0001 inch or less. Particulate discharge into the
atmosphere results primarily from industrial, agricultural, construction, and transportation activities;
however, wind action on the arid landscape also contributes substantially to the local particulate
loading. Both PM10 and PM2.5 may adversely affect the human respiratory system, especially in those
people who are naturally sensitive or susceptible to breathing problems.
Fugitive dust poses primarily two public health and safety concerns. The first concern is that of
respiratory problems attributable to the suspended particulates in the air. The second concern is that of
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motor vehicle accidents caused by reduced visibility during severe wind conditions. Fugitive dust may
also cause significant property damage during strong windstorms by acting as an abrasive material agent
(similar to sandblasting activities). Finally, fugitive dust can result in a nuisance factor due to the soiling
of proximate structures and vehicles.
Diesel particulate matter is a mixture of many exhaust particles and gases that is produced when an
engine burns diesel fuel. Many compounds found in diesel exhaust are carcinogenic, including 16 that
are classified as possibly carcinogenic by the International Agency for Research on Cancer. Diesel
particulate matter includes the particle-phase constituents in diesel exhaust. Some short-term (acute)
effects of diesel exhaust include eye, nose, throat, and lung irritation and exposure can cause coughs,
headaches, light-headedness, and nausea. Diesel exhaust is a major source of ambient fugitive dust
pollution as well, and numerous studies have linked elevated fugitive dust levels in the air to increased
hospital admission, emergency room visits, asthma attacks, and premature deaths among those
suffering from respiratory problems (OEHHA 2001). Diesel particulate matter in the SDAB poses the
greatest cancer risk of all the toxic air pollutants.
C. Ambient Air Pollutant Levels
The SDAPCD operates a network of ambient air monitoring stations throughout San Diego County. The
purpose of the monitoring stations is to measure ambient concentrations of air pollutants and
determine whether the ambient air quality meets the NAAQS and the CAAQS. The closest ambient
monitoring station is the Otay Mesa Station, approximately four miles from Village 8 West. However,
this station is located in a heavy industrial area that does not accurately reflect the existing conditions in
the project area. The next closest station is the Chula Vista station, located approximately five miles
from the project site, which better represents the development in surrounding areas. Table 5.4-2
presents a summary of the ambient pollutant concentrations monitored at the Chula Vista station
during 2009 through 2011.
As shown in Table 5.4-2, the 1-hour ozone concentration exceeded the state standard once per year in
2009 and 2010, and was not exceed in 2011. The 8-hour ozone concentration exceeded the state
standard in 2009 and 2010, and the federal standard in 2010. The daily PM10 concentration exceeded
the state standard in 2009, but not in 2010 or 2011. The federal standard was not exceeded during this
period. The federal 24-hour PM2.5 standard was violated once in 2009 but not in 2010 or 2011.
Neither the state nor federal standards for carbon monoxide, nitrogen dioxide, or sulfur dioxide were
exceeded at any time during the years 2009 through 2011. The federal annual average nitrogen dioxide
standard has not been exceeded since 1978 and the California 1-hour standard has not been exceeded
since 1988 (SDAPCD 2007a). With one exception during October 2003, the SDAB has not violated the
state or federal standards for carbon monoxide since 1990 (SDAPCD 2007a).
D. Attainment Status
The classifications for ozone non-attainment range in magnitude from marginal, moderate, serious,
severe, and extreme. A pollutant is designated unclassified if the data are incomplete and do not
support a designation of attainment or non-attainment. The SDAB federal and state attainment status is
shown in Table 5.4-3. The SDAB is currently designated as a non-attainment area for the state standard
for PM10, PM2.5, 1-Hour and 8-Hour ozone, and the Federal 8-Hour Standard for ozone.
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Table 5.4-2 Air Quality Monitoring Data
Pollutant Monitoring Station 2009 2010 2011
Carbon Monoxide (CO)
Maximum 8-hour concentration (ppm)
Chula Vista
1.43 1.56 --(1)
Days above state or federal standard (>9.0 ppm) 0 0 --(1)
Nitrogen Dioxide (NO2)
Peak 1-hour concentration (ppm)
Chula Vista
0.065 0.050 0.057
Days above state 1-hour standard (0.18 ppm) 0 0 0
Ozone (O3)
Maximum 1-hour concentration (ppm)
Chula Vista
0.098 0.107 0.083
Days above 1-hour state standard (>0.09 ppm) 1 1 0
Maximum 8-hour concentration (ppm) 0.075 0.083 0.057
Days above 8-hour state standard (>0.07 ppm) 3 3 0
Days above 8-hour federal standard (>0.075 ppm) 0 2 0
Sulfur Dioxide (SO2)
Maximum 24-hour concentration (ppm)
Chula Vista
0.003 0.002 0.002
Days above 24-hour state standard (>0.04 ppm) 0 0 0
Days above 24-hour federal standard (>0.14 ppm) 0 0 0
Respirable Particulate Matter (PM10)
Peak 24-hour concentration (g/m3)
Chula Vista
58 45 46
Days above state standard (>50 g/m3) 2 0 0
Days above federal standard (>150 g/m3) 0 0 0
Fine Particulate Matter (PM2.5)
Peak 24-hour concentration (g/m3)
Chula Vista
43.7 22.7 27.9
Days above federal standard (>35 g/m3) 1 0 0
(1) Insufficient data was available to CARB to determine the value
ppm = parts per million, g/m3 = micrograms per cubic meter
Source: CARB 2012
Table 5.4-3 Attainment Status for the San Diego Air Basin
Pollutant State Status Federal Status
Carbon Monoxide (CO) Attainment Attainment
Nitrogen Dioxide (NO2) Attainment Attainment
Ozone (1-hour) Serious Non-attainment --(1)
Ozone (8-hour) Serious Non-Attainment Non-attainment
Lead (Pb) Attainment Attainment
Sulfur Dioxide (SO2) Attainment Attainment
Respirable Particulate Matter (PM10) Non-attainment Unclassified
Fine Particulate Matter (PM2.5) Non-attainment Attainment\Unclassified
(1) The federal 1-hour ozone standard was revoked in 2005 and is no longer in effect for California.
Source: CARB 2011, EPA 2011a
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E. Sensitive Receptors and Locations
CARB defines sensitive receptors as residences, schools, day care centers, playgrounds, and medical
facilities, or other facilities that may house individuals with health conditions that would be adversely
affected by changes in air quality. Village 8 West is currently undeveloped and no sensitive receptors are
located on the site. The sensitive receptors closest to the project site include the following:
1. Olympian High School, approximately 100 feet east of the northeast corner of the project site;
2. Wolf Canyon Elementary school, approximately 875 feet (0.2 mile) northeast of the project site;
3. Residences located approximately 1,500 feet (0.3 mile) northeast of the project site; and
4. Residences located 1,750 feet (0.3 mile) north of the project site.
5.4.3 Thresholds of Significance
According to Appendix G of the CEQA Guidelines and the City of Chula Vista, implementation of the
project would result in a significant adverse impact if it would:
■ Threshold 1: Violate any air quality standard or contribute substantially to an existing or
projected air quality violation.
The City of Chula Vista has not established specific numeric thresholds related to criteria air
pollutants. The City relies on the significance thresholds established by the South Coast Air
Quality Management District (SCAQMD). For this analysis, the calculated emissions of the
project are compared to the SCAQMD thresholds of significance for criteria pollutants for
individual projects, provided in Table 5.4-4. If the thresholds are exceeded by a proposed
project, then the impact is considered significant.
■ Threshold 2: Expose sensitive receptors to substantial pollutant concentrations.
■ Threshold 3: Create objectionable odors affecting a substantial number of people.
■ Threshold 4: Result in a conflict with, or obstruct implementation of, the RAQS or SIP.
■ Threshold 5: Be inconsistent with General Plan, GDP, or other relevant objectives and policies
regarding air quality thereby resulting in a significant physical impact.
Table 5.4-4 SCAQMD Thresholds of Significance for Criteria Air Pollutants
Pollutant
Construction Emissions
(pounds/day)
Operation Emissions
(pounds/day)
Carbon Monoxide (CO) 550 550
Reactive organic gases (ROG)(1) 75 55
Nitrogen Oxides (NOx) 100 55
Sulfur Oxides (SOx) 150 150
Respirable Particulate Matter (PM10) 150 150
Fine Particulate Matter (PM2.5) 55 55
(1) Reactive organic gases are also sometimes referred to as volatile organic compounds.
Source: SCAQMD 2010
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5.4.4 Impact Analysis
A. Threshold 1: Violate any air quality standard or contribute substantially to an
existing or projected air quality violation.
Construction and operational criteria air pollutant emissions that would be generated by
implementation of the project are discussed below.
1. Construction
The air quality technical report prepared for the 2013 GPA/GDPA SEIR determined that potential
impacts related to construction would be less than significant because development would be required
to comply with standard dust minimizing practices. However, construction emissions and estimated
emission reductions from the BMPs were not quantified because the timing of future development and
the specific construction details could not have been known at the programmatic level. For these
reasons, the 2013 GPA/GDPA SEIR air quality report does not quantify the potential impacts of
construction of the Village 8 West SPA Plan and TM. Additionally, the report does not provide the
construction assumptions used to determine the potential impacts of construction of the project.
Therefore, the project-specific analysis was conducted (Atkins 2013) to estimate the criteria pollutant
emissions that would result from construction of the project.
Air pollutant emission sources during project construction would include exhaust and particulate
emissions generated from construction equipment; fugitive dust from soil disturbance during site
preparation, grading, and excavation activities; and volatile compounds that evaporate during site
paving and painting of the structures. Village 8 West is approximately 300 acres; however, only 261
acres of the site would be disturbed by onsite construction. The remaining onsite area consists of areas
designated for open space. An additional 1.95 acres would be disturbed for installation of the off-site
improvements and 4.57 acres would be graded on the City of San Diego reservoir property, for a total
disturbance area of approximately 268 acres.
Development within Village 8 West would include single-family residences, multi-family residences,
mixed-use commercial development, a community purpose facility, a middle school, and elementary
school, and parks. Construction would occur in sequential development phases, and take a minimum of
eight years to complete, although full buildout of the project is not expected until 2030. For the
purposes of modeling the worst-case daily construction scenario for one phase, the analysis years used
for construction were 2013-2015. This is conservative because increasingly stringent air quality
regulations on construction equipment would result in fewer emissions in later years. Village 8 West
would be constructed in five development phases, as shown in Figure 3-16, and would include the
following components:
■ The Orange phase would develop a maximum of 351 multi-family residential units, 117 single-
family units, a town square, and 174,000 square feet of commercial space in primarily the
western portion of the site.
■ The Blue phase would develop a maximum of 284 single-family residential units in the
southwestern area of the site.
■ The Yellow phase would include a maximum of 765 multi-family units, 126,000 square feet of
commercial land use, a community park, and a middle school in the northern portion of the site.
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■ The Purple phase would develop a maximum of 220 single-family residential units and a
neighborhood park in the southeast portion of the site.
■ The Green phase would develop 313 multi-family residences, a community purpose facility, and
an elementary school in the eastern portion of the site.
The sequencing of phases would be determined by market conditions. However, it is assumed that the
Orange and Blue phases would be constructed prior to the Yellow, Green, and Purple phases because
the Orange and Blue phases require blasting.
Regional impacts for construction are assessed using the Urban Emissions Model (URBEMIS 2007,
version 9.2.4) distributed by the CARB. The URBEMIS 2007 model uses EMFAC 2007 emission factors for
vehicle traffic and Off-Road 2007 for construction equipment. The construction activities, scheduling,
grading quantities, and the construction equipment list (including size of equipment engines and load
factor) described below were provided by the project applicant. Project development would be
constructed in sequential phases starting in 2013, and to be conservative, the most intensive
development phase was used for the worst-case daily construction emissions. A complete listing of the
assumptions used in the analysis and model output is provided in Appendix C.
Each phase of project development would include the following construction activities: mass grading,
trenching for utilities and underground improvements, paving and surface improvement, building
construction, and exterior architectural coating, as shown in Table 5.4-5. The off-site improvements
would also require grading, trenching, and paving. For the purpose of isolating emissions from each type
of construction activity, it is assumed that the construction activities within one development phase
would occur consecutively, with no overlap. However, approximately nine months prior to completion
of one development phase, grading could potentially begin for the next phase. Any of the construction
activities in subsequent development phases would have the potential to overlap with the building
construction activities of the previous phase.
Table 5.4-5 Approximate Duration of Project Construction Activities Per Development Phase
Construction Activity Duration
Mass Grading 3 months
Trenching 2 months
Surface Improvements 2 months
Building Construction and Coating 2 years
Grading in each phase would occur over a three-month period. The phases are generally similar in area;
therefore, it assumed than the same amount of grading would occur in each phase. This analysis
assumes that a limit of 20 acres per day would be disturbed and/or graded. A total of 4.7 million cubic
yards would be graded as a result of the project and replaced within the disturbance area, or 940,000
cubic yards in each phase. It is assumed that a maximum of 35,000 cubic yards of material would be
graded each day. All cut material would be used on site and no hauling of material off site would be
required. The Orange and Blue phases of construction would involve blasting during the grading
operations and would require additional construction equipment compared to the Yellow, Green, and
Purple phases, including a rock drill, crushing unit, and rock spread. Use of this equipment is included in
the daily emission calculation for the grading activity. Typical grading equipment that would be used for
grading in all phases would include tractors, excavators, graders, and water trucks.
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Approximately two months would be required for installation of the utilities in each phase. The most
intensive utility installation activity that would require heavy equipment is trenching. Trenching
activities would typically require excavators, dump trucks, dozers, backhoes, a nd water trucks. Paving
and surface improvements would be required for approximately 12 percent of the project area (31
acres). Approximately six acres would be paved during each phase and would be accomplished in
approximately two months. Approximately two acres would be required for the off-site improvements
during one phase of development. A maximum of approximately 8 acres would be paved during one
phase. Typical construction equipment required for paving would include graders, pavers, and rollers.
Because building construction within Village 8 West would be completed by multiple developers,
multiple areas of the site may be under construction at one time. Building construction activities are
estimated to last a minimum of approximately two years and would typically require dump trucks,
concrete trucks, excavators, backhoes, and water trucks. It is assumed that architectural coating
activities would occur simultaneously with the building construction activities; therefore, the coating
activities would also last approximately two years. The Yellow phase is projected to require the most
and greatest diversity of development, including the highest number of residential units, almost one half
of the proposed commercial development, the largest proposed recreational use, and a middle school.
Therefore, the land uses proposed in the Yellow phase were used to determine maximum daily
emissions from architectural coating and building construction. Construction of the off-site
improvements is also included in the worst-case construction scenario. The URBEMIS 2007 model does
not take into account the additional construction standards adopted by the CARB after 2007. For
example, beginning in 2008, heavy-duty diesel engines were required to be shut down when idling more
than five minutes at any location within California. Therefore, actual project emissions may be less than
calculated by the URBEMIS 2007 model.
Table 5.4-6 summarizes the maximum daily emissions of grading (assuming a maximum of 20 acres per
day), trenching, paving, construction, and coating in comparison with the thresholds of significance (as
mentioned earlier, the Yellow phase was chosen as the basis for the worst case daily emissions). As
shown in Table 5.4-6, when considering the typical scenario of each construction phase occurring
consecutively with no overlap, project related emissions would be below the significance thresholds
during the underground utility (trenching) and building construction and coating activities. Construction
of the project would exceed the significance thresholds for nitrogen oxides, PM10, and PM2.5 during
grading, and the nitrogen oxide threshold during surface improvements (paving). Impacts to air quality
resulting from grading and surface improvement activities during each development phase would be
potentially significant.
Additionally, any of the construction activities of a subsequent development phase would have the
potential to overlap with building construction activities in the previous development phase. For
example, if the Blue phase is constructed after the Orange phase, the earlier construction activities, such
as grading, in the Blue phase would potentially overlap with the later construction activities, such as
building construction and architectural coating in the Orange phase. Although it is unlikely, it is possible
that all four categories of construction activities could occur simultaneously on the site within different
development phases. To estimate this worst-case scenario, Table 5.4-6 provides the total amount of
emissions that would occur if all types of construction activities occur simultaneously on one day. Since
other development phases would be less intensive than the Yellow phase, the total emissions shown in
Table 5.4-6 represent a conservative estimate.
As indicated by the maximum combined daily emissions provided in Table 5.4-6, simultaneous
construction activities would combine to exceed the significance thresholds for nitrogen oxides, VOCs,
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PM10, and PM2.5 emissions. Therefore, simultaneous construction activities between development
phases would potentially worsen significant impacts during construction.
Table 5.4-6 Maximum Daily Emissions per Construction Activity
Construction Activity
Pollutant Emissions (pounds/day)
CO VOC NOX SOX PM10 PM2.5
Mass Grading(1) 174 44 379 0 4,345 918
Trenching(2) 22 6 51 0 2 2
Surface Improvements (paving)(3) 52 15 121 0 5 4
Building Construction and Coating Phases(4) 161 36 81 0 4 3
Combined Daily Total for all Construction Activities 409 101 632 0 4,356 927
Significance Threshold 550 75 100 150 150 55
Significant Impact? No Yes Yes No Yes Yes
Bold = Exceeds significance threshold
CO = carbon monoxide; VOC = volatile organic compound; NOx = nitrogen oxides; SOx = sulfur oxides;
PM10 = respirable particulate matter; PM2.5 = fine particulate matter
Modeling assumptions: Emissions are based on assumptions for the Yellow development phase, plus additional equipment
added to account for blasting within the Blue and Orange phases, and off-site improvements. Worst-case construction
activities for the Yellow development phases were assumed to occur during 2013-2015.
(1) Assumes a three-month period and a maximum land disturbance of 20 acres per day. A total of approximately 268 acres
would be disturbed over five development phases. A total of 4.7 million cubic yards would be graded and replaced within
the disturbance area, or 940,000 cubic yards in each phase. All cut material would be used on site and no hauling of
material off site would be required. Equipment list for grading includes an excavator, two graders, four heavy-duty trucks,
five dozers, 12 scrapers, and two water trucks. A drill rig, crushing unit, and tractor would be required for blasting in the
Orange and Blue phases and are included in the modeled equipment list.
(2) Assumes a two-month period. Equipment list includes two excavators, two dump trucks, a dozer, two backhoes, and a
water truck.
(3) Assumes a two-month period. Paving and surface improvements would be required for approximately 12 percent of the
SPA area (31 acres), or six acres per phase. Assumes an additional two acres for off-site improvements. Equipment list
includes a grader, a paver, a roller, and 27 dump trucks and concrete trucks.
(4) Assumes a two-year period and architectural coating activities would occur simultaneously with the building construction
activities. Assumes building construction would require a total of 11 dump trucks and concrete trucks, an excavator, a
backhoe, and a water truck. Calculations are based on the Yellow phase, which includes development of 765 multi-family
units, 126,000 square feet of commercial land use, a community park, and a middle school. Assumes model defaults for
low VOC coating (250 grams of VOC per liter or less).
Source: URBEMIS 2007. See Appendix C for data sheets.
The blasting operations in the Orange and Blue phases would also generate fugitive dust. The URBEMIS
2007 model takes into account emissions from construction equipment required for blasting, but does
not include particulate emissions that would result from use of explosives. Therefore, fugitive dust
emissions during grading of the Orange and Blue phases would be higher than estimated on the days
that blasting occurs. However, blasting activities would only occur on a few days. Additionally, the
project would result in significant particulate matter emissions during grading with or without blasting;
therefore, mitigation is already required to minimize dust. However, because blasting would contribute
to the potentially significant particulate matter impact from grading activities on the days that it would
occur, specific dust-minimizing measures to be applied during blasting activities would be required.
Dust from construction activities would also have the potential to impact sensitive biological resources
in the MSCP Preserve area to the south of the project area. Dust has the potential to disrupt plant
vitality in the short-term. Potential impacts to the MSCP Preserve would primarily result from
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construction of the off-site improvements and the single-family residences near the southern area of the
site. Impacts would cease once construction is complete. However, the Biological Resources Report
prepared for Village 8 West (URS 2012) determined that potential indirect impacts to biological
resources, including dust from construction, would be potentially significant.
2. Operation
Operational impacts are also assessed using the URBEMIS 2007 model. The model estimates daily
regional emissions from vehicle and stationary sources of pollutants that would result from
implementation of the project at full buildout. Mobile source emissions were calculated using an ADT
estimate of 26,104 trips provided in the traffic impact analysis (Appendix B) and the estimated vehicle
trip length for Village 8 West of 4.62 miles that was determined in conjunction with SANDAG, as
discussed in Section 5.10, Global Climate Change. Area sources of air emissions include natural gas
combustion from water and space heating, landscape equipment, consumer products, and architectural
coatings. All air quality modeling output files are provided in Appendix C.
To estimate the most conservative estimate for operational air quality emissions, the project
assumptions for the full buildout year (2030) were used in the analysis. The full buildout condition
represents the greatest amount of vehicle trips and land use development. The major source of long-
term operational air quality impacts from the project would be emissions produced from project-
generated vehicle trips. Vehicle trip generation is based on the project traffic study, which was prepared
by RBF Consulting (2013). The projected ADT rate for the project is 26,104 trips. The vehicle trip
emissions account for internal capture from mixed-use development and the reduction in vehicle trips
compared to similar developments that do not provide access to transit. Two bus stops are proposed in
the Village 8 West Town Center, one along west-bound Main Street and one along east-bound Main
Street. The projected ADT also takes into account the TDM program included in the SPA Plan. The TDM
includes strategies to reduce vehicle trips and miles traveled and to design a multi-modal transportation
system, and establishes a Transportation Management Association to provide transportation services in
a particular area to reduce vehicle miles and implement other TDM strategies. Pollutant emissions from
vehicles were calculated using the EMFAC 2007 emission factors that are used in URBEMIS 2007.
In addition to vehicle trips, the project would emit pollutants from on-site area sources, such as burning
natural gas for space and water heating, including fireplaces; landscape maintenance equipment;
consumer products; and periodic repainting of interior and exterior surfaces (architectural coatings). The
area source assumptions include a 15 percent increased efficiency beyond the URBEMIS default Title 24
standards (2005) to reflect the 2008 Title 24 standards. This assumption is conservative because
required compliance with the Chula Vista Green Building Standards (CVMC Chapter 15.12) and Energy
Efficiency Standards (CVMC Section 15.26.030) would improve energy efficiency beyond the 2008 Title
24 standards.
The vehicular and area source emissions associated with operation of the project are summarized in
Table 5.4-7. As shown in this table, the project would exceed the daily regional thresholds for nitrogen
oxides, VOCs, and PM10 during operation of the development in Village 8 West. Therefore, a significant
impact would occur. The air quality technical report for the 2013 GPA/GDPA SEIR estimated emissions
that would result from the increase in building potential accommodated by the GPA/GDPA compared to
the previous GDP, including the increase in building potential in Village 8 West. The findings in this
report are consistent with the 2013 GPA/GDPA SEIR conclusion that significant impacts would occur.
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Table 5.4-7 Operation Maximum Daily Emissions
Emissions Source
Pollutant Emissions (pounds/ day)
CO VOC NOx SOx PM10 PM2.5
Vehicular Sources (1) 368 40 31 1 201 39
Area Sources
Natural Gas (2) 20 3 34 0 0 0
Hearth (fireplaces)(3) 1 0 4 0 0 0
Landscape 38 6 0 0 0 0
Consumer Products 0 105 0 0 0 0
Architectural Coatings(4) 0 15 0 0 0 0
Total Emissions 427 169 69 1 201 39
Significance Thresholds 550 55 55 150 150 55
Significant Impact? No Yes Yes No Yes No
Bold = Exceeds significance threshold
CO = carbon monoxide; VOC = volatile organic compounds; NOx = nitrogen oxides; SOx = sulfur oxides;
PM10 = respirable particulate matter; PM2.5 = fine particulate matter
Modeling assumptions: Calculations assume the full development of project at buildout (2030). Output is for summer
emissions, with the exception of hearth emissions, where winter emissions were added to the daily emissions for a worst-case
condition.
(1) Based on an ADT of 26,104 trips and an estimated vehicle trip length of 4.62 miles, which accounts for internal capture
from mixed-use development, the reduction in vehicle trips compared to similar developments that do not provide access
to transit, and the TDM program in the Village 8 West SPA Plan. A four percent vehicular emission reduction for VOC, NOx,
CO, and PM10 emissions was applied for traffic light synchronization based on the SCAQMD CEQA Air Quality Handbook
(1993).
(2) Assumes buildings comply with 15% above 2005 Title 24 standards.
(3) Assumes 15 percent of homes would have fireplaces, consistent with assumptions of the GPA/GDPA SEIR. No wood
burning fireplaces would be allowed.
(4) Includes the use of low VOC coatings (250 grams of VOC per liter or less).
Source: CARB 2007. See Appendix C for data sheets.
B. Threshold 2: Expose sensitive receptors to substantial pollutant
concentrations.
CARB defines sensitive receptors as residences, schools, day care centers, playgrounds, and medical
facilities, or other facilities that may house individuals with health conditions that would be adversely
affected by changes in air quality. The two primary pollutants of concern regarding health effects for
land development are carbon monoxide and diesel particulates.
1. Carbon Monoxide Hot Spots
Areas with high vehicle density, such as congested intersections and parking garages, have the potential
to create high concentrations of carbon monoxide, known as carbon monoxide hot spots. An air quality
impact is considered significant if carbon monoxide emissions create a hot spot where either the
California 1-hour standard of 20 ppm or the federal and State eight-hour standard of 9.0 ppm is
exceeded. This typically occurs at severely congested intersections (LOS E or worse).
The air quality technical report for the 2013 GPA/GDPA SEIR determined that carbon monoxide hot
spots would not occur as a result of development under the GPA/GDPA because the SDAB is in
attainment of both the federal and state carbon monoxide standards, background carbon monoxide
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concentrations are well below federal and state limits, and all studied intersections in the traffic report
prepared for the GPA/GDPA SEIR are projected to operate at LOS D or better.
Localized carbon monoxide concentrations are evaluated by using the CALINE4 microscale dispersion
model, in accordance with the Caltrans Transportation Project-Level Carbon Monoxide Protocol, in
combination with EMFAC 2007 emission factors. CALINE4 modeling output files are provided in
Appendix C. The traffic study prepared for Village 8 West (RBF 2013) used project-level trip generation
analysis and distribution to evaluate the intersections in the project vicinity that would carry the
majority of project traffic. The traffic study analyzed the Existing Plus Project scenario, as well as three
interim scenarios (2015, 2020, 2025) and full project buildout (2030). The traffic study concluded that
within each analysis scenario, some intersections would operate at an LOS E or F. Intersections that
operate at an LOS E or F have the potential to generate carbon monoxide hot spots. In some locations,
the interim scenario resulted in a more congested intersection than the full buildout scenario, due to
differences in project trip distribution as roadway improvements are implemented. To estimate the
most conservative conditions for the hot spot analysis, carbon monoxide concentrations were analyzed
at the most congested intersection for each analysis scenario that would experience the longest delays:
■ Existing (2010) Plus Full Project Buildout: Main Street/Magdalena Avenue – LOS F (PM peak
hour), 164 second delay
■ 2015 Plus Phased Project Buildout: Olympic Boulevard/I-805 northbound on-ramp – LOS F
(AM peak hour), 116 second delay
■ 2020 Plus Phased Project Buildout: Olympic Boulevard/I-805 northbound on-ramp – LOS F
(AM peak hour), 117 second delay
■ 2025 Plus Phased Project Buildout: Birch Road/Eastlake Boulevard – LOS F (PM peak hour),
454 second delay
■ 2030 Plus Full Project Buildout: Main Street/Magdalena Avenue – LOS F (PM peak hour),
144 second delay
The California Line Source (CALINE 4) model was used to estimate the potential carbon monoxide impact
at the above intersections during the most congested peak hour. Receptor locations were set 30 feet
from the roadway centerline at the intersection, although actual receptor locations are generally at a
greater distance. Carbon monoxide emission factors were generated using the EMFAC 2007 model,
using the carbon monoxide emission factor associated with the appropriate analysis year for the total
vehicle mix during conditions in January at a temperature of 40 °F and 50 percent relative humidity. The
assumed vehicle speed is 5 miles per hour. An ambient 1-hour carbon monoxide concentration of 2.0
ppm was used to reflect ambient conditions, based on the data reported at the Chula Vista air quality
monitoring station. This concentration estimate is conservative for future years, since carbon monoxide
ambient concentrations have been showing a generally downward trend based on historical data. Table
5.4-8 displays the estimated carbon monoxide concentrations at the nearest receptor from the affected
intersections. See Appendix C for model output data sheets.
The highest estimated 1-hour carbon monoxide concentration would be 3.5 ppm at the Olympic
Parkway/I-805 northbound on-ramp intersection during the 2015 Plus Phased Project Buildout scenario.
This would not exceed the California 1-hour standard of 20 ppm or the federal 1-hour standard of 35
ppm. Based on an urban persistence factor of 0.7 (for an urban area), the maximum cumulative 8-hour
carbon monoxide concentration at the intersection would be 2.4 ppm, which is below the 9 ppm
California and federal 8-hour standard. The carbon monoxide concentrations at all of the remaining
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intersections under each scenario are also below the state and federal standards. Therefore, potential
carbon monoxide impacts are less than significant.
Table 5.4-8 Estimated Carbon Monoxide Concentrations
Analysis Scenario Intersection
1-Hour CO
Concentration (ppm)
8-Hour CO
Concentration (ppm) Impact?
Existing + Full Project Buildout Main Street/Magdalena Avenue 2.8 2.0 No
2015 + Phased Project Buildout Olympic Parkway/I-805
northbound on-ramp 3.5 2.4 No
2020 + Phased Project Buildout Olympic Parkway/I-805
northbound on-ramp 3.1 2.2 No
2025 + Phased Project Buildout Birch Road/Eastlake Parkway 3.0 2.1 No
2030 + Full Project Buildout Main Street/Magdalena Avenue 2.9 2.1 No
Significance Threshold 20.0 (State) /
35.0 (Federal)
9.0 (State and
Federal)
CO = carbon monoxide
See Appendix C for model output sheets.
Modeling assumptions: One-hour carbon monoxide concentrations were calculated using the worst-case wind angle scenario in
the CALINE 4 model. Receptor locations were set 30 feet from the roadway centerline. Carbon monoxide emission factors were
generated using the EMFAC 2007 model, using the carbon monoxide emission factor associated with the appropriate analysis
year for the total vehicle mix during conditions in January at a temperature of 40 °F and 50 percent relative humidity. The
assumed vehicle speed is 5 miles per hour. An ambient 1-hour carbon monoxide concentration of 2.0 ppm was used to reflect
ambient conditions. The 8-Hour carbon monoxide concentration is based on a persistence factor of 0.7 for urban uses (Caltrans
1997).
Source: CALINE 4 using EMFAC 2007 emission factors.
2. Toxic Air Contaminants
The Chula Vista General Plan addresses the siting of sensitive receptors to avoid exposure to TACs .
Objective E-6 in the General Plan is to improve local air quality by minimizing the production and
emission of air pollutants and TACs, and limit the exposure of people to such pollutants. This objective
includes the following policies related to TACs:
■ Policy E 6.4: Avoid siting new or re-powered energy-generation facilities and other major toxic
air emitters within 1,000 feet of a sensitive receiver or the placement of a sensitive receiver
within 1,000 feet of a major toxic emitter.
■ Policy E 6.10: The siting of new sensitive receivers within 500 feet of highways resulting from
development or redevelopment projects shall require the preparation of a health risk
assessment as part of the CEQA review of the project. Attendant health risks identified in the
assessment shall be feasibly mitigated to the maximum extent practicable, in accordance with
CEQA, in order to help ensure that applicable federal and state standards are not exceeded.
The CARB’s Air Quality and Land Use Handbook: A Community Health Perspective lists land uses that are
considered major air toxic emitters. These land uses are generally industrial and processing land uses
that require a permit from the SDAPCD to operate, including chrome plating facilities, refineries, rail
yards, and distribution centers. The SPA Plan proposes residential, mixed-use, school, and park land
uses. It does not propose any major toxic emitters. However, CARB does consider dry cleaning facilities
and gas stations to be stationary sources of TAC emissions that should not be located near sensitive
receptors. Based on CARB siting recommendations within the Air Quality and Land Use Handbook, a
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detailed health risk assessment should be conducted for proposed sensitive receptors within 300 feet of
a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater), 50
feet of a “typical” gas station (a facility with a throughput of less 3.6 million gallons per year), or within
300 feet of a dry cleaning facility that uses perchloroethlyene (CARB 2005). Although the SPA Plan would
include primarily residential and commercial uses, the proposed land uses may allow the development
of gas stations and dry cleaning facilities, as these are common uses within mixed -use and resident-
serving development. Dry cleaning facilities and gas stations are allowable in the Town Center, subject
to a conditional use permit. However, only storefront dry cleaning facilities or facilities that do not use
perchloroethlyene are allowable in the Town Center, subject to a conditional use permit. Due to physical
size constraints, large gas stations with a throughput of 3.6 million gallons per year or more would not
be permitted within the compact Town Center. Development of a typical-sized gas station in Village 8
West would be possible, but would be subject to the CARB siting recommendations and would not be
allowed within 50 feet of a sensitive receptor. Additionally, new sources of TAC emissions such as gas
stations are required to obtain authority to construct and operate from the SDAPCD, at which time
location-specific details are analyzed. Sources must comply with established criteria, as established in
SDAPCD Rule 1200, requiring demonstration that risks are below thresholds and that sources are
constructed and operated with appropriate controls. Provided that new sources of TAC emissions
proposed within Village 8 West comply with SDAPCD standards, the impact associated with risk of toxic
exposure to sensitive receptors is considered less than significant.
The 2005 GPU EIR lists the Otay Landfill as a major toxic emitter, and therefore new sensitive uses such
as residences should not be located within 1,000 feet of this facility. The health risk assessment included
in the technical appendices for the Final EIR for the Otay Landfill Development and Expansion Plan
indicated that the incremental excess cancer risk of 10 in 1 million was limited to an area within 1,000
feet of the landfill (County of San Diego 2000). The proposed residences in Village 8 West would be
located more than 2 miles east of the Otay Landfill. Therefore, potential impacts associated with TACs
from the Otay Landfill are considered less than significant.
Exposure to diesel particulate matter generated by traffic on roadways is also a concern identified in the
Chula Vista General Plan and CARB Air Quality and Land Use Handbook. City and CARB guidelines
indicate that siting new sensitive land uses within 500 feet of a freeway should be avoided. CARB also
recommends siting sensitive land uses more than 500 feet from urban roads with 100,000 vehicles per
day. The air quality report prepared for the GPA/GDPA SEIR determined that significant impacts from
diesel particulate matter would not occur because the GPA/GDPA area, including Village 8 West, lies
outside of the land use avoidance guidelines established by the CARB for roadways generating more that
100,000 vehicle trips per day (I-805 and SR-905).
The nearest sensitive receptors to these roadways would be the single-family residences proposed at
the southern end of the project site. The nearest roadway, SR-905, is located approximately 1.5 miles
south of the project site and is outside of the avoidance guidelines. SR-125 would carry less than
100,000 trips per day. Additionally, this roadway is located approximately 2,000 feet east of the project
site. SR-125 would not result in significant diesel particulate matter concentrations at the project site.
The traffic impact analysis prepared for the project does not identify any roadway segments that would
carry more than 100,000 vehicles per day at build-out of the project (RBF 2013). Consequently, the
project lies well outside of the land use avoidance guidelines established by the CARB, thus impacts
related to toxic air emissions would be less than significant.
Sensitive receptors may also be exposed to diesel particulate matter emissions from land uses that
attract large numbers of diesel trucks or buses, such as distribution centers or regional transit centers.
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The SPA Plan does not include any distribution centers. Commercial land uses would intermittently
attract diesel trucks for the delivery of goods. However, in 2004, the CARB adopted an Airborne Toxic
Control Measure (ATCM) to limit heavy-duty diesel motor vehicle idling in order to reduce public
exposure to diesel particulate matter and other TACs and their pollutants. The measure applies to
diesel-fueled commercial vehicles with gross vehicle weight ratings greater than 10,000 pounds that are
licensed to operate on highways, regardless of where they are registered. The measure does not allow
diesel fueled commercial vehicles to idle for more than five minutes at any given time. This measure
may be enforced by either the Chula Vista Police Department or the SDAPCD.
Potential localized air toxic impacts from on-site sources of diesel particulate matter would be minimal
since only a limited number of heavy-duty trucks would access the project site. The trucks that would
frequent the area would not idle for extended periods of time. Village 8 West does not include a transit
center; Metropolitan Transit System buses would intermittently briefly idle at the proposed bus stops in
the Town Center to load and unload passengers. The Metropolitan Transit System buses are subject to
the CARB’s Public Transit Bus Fleet Rule and Emission Standards for New Urban Buses (CCR Title 13,
Section 1956). This rule includes requirements for transit agencies to include alternative-fuel buses in
their fleet, meet fleet-wide nitrogen oxides and diesel particulate matter emissions reduction
requirements, and zero-emissions bus purchase requirements. As older buses are phased out under the
CARB program, new buses would either be alternatively fueled or powered by diesel engines with
limited diesel particulate matter emissions. In the meantime, fleet-wide emissions standards would
reduce exposure to emissions from older buses by reducing their use or installation of retrofits to
reduce emissions. Therefore, required compliance with existing CARB regulations would reduce
potential impacts related to commercial deliveries and bus service to a less than significant level.
Diesel particulate matter would result from operation of construction equipment. As shown in Table 5.4-
6, construction of Village 8 West would result in significant particulate matter emissions during grading
activities, including fugitive dust and diesel emissions from construction equipment. However, diesel
particulate matter is considered to have a long-term health effect (eight years or more) (CalEPA 2003).
Grading would be a short-term event (a total of 15 months over five phases) and would be spaced
throughout the project area. Diesel particulate emissions from construction would be substantially
reduced following completion of grading. Additionally, the majority (98 percent) of particulate matter
emissions during grading are from fugitive dust. Emissions of particulate matter from diesel sources
during grading would be well below the significance thresholds. Therefore, emissions would not result in
a significant long-term health risk to surrounding receptors.
C. Threshold 3: Based Create objectionable odors affecting a substantial
number of people.
Offensive odors can present a nuisance to the general public, but seldom result in permanent physical
damage. Offensive odors may cause agitation, anger, and concern to the public, especially in residential
neighborhoods located near major sources of odor.
Construction associated with implementation of the project could result in minor amounts of odor
compounds associated with diesel heavy equipment exhaust. However, construction equipment would
be operating at various locations throughout the project site and construction would not take place all
at once. The use of architectural coatings and solvents may also emit odors from the evaporation of
VOC. SDAPCD Rule 67 limits the amount of VOC from coatings and solvents, and the project would
incorporate the use of low-VOC coatings. In addition, construction near existing sensitive receptors
would be temporary. Therefore, consistent with the findings of the air quality technical report for the
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2013 GPA/GDPA SEIR, impacts associated with nuisance odors during project construction would not be
significant.
The CARB’s Air Quality and Land Use Handbook identifies a list of the most common sources of odor
complaints received by local air districts. Typical sources of odor complaints include facilities such as
sewage treatment plants, landfills, recycling facilities, petroleum refineries, and livestock operations.
The project proposes the development of residential, commercial, school, and park land uses.
Residential development does not typically result in a source of nuisance odors associated with
operation. The project does not propose any specific new sources of odor that could affect sensitive
receptors. The mixed-use Town Center would potentially result in residences located near commercial
land uses with the potential to generate some odors, such as refuse containers or kitchen exhaust vents
for restaurants. However, these odor sources would be required to comply with SDAPCD Rule 51, which
prohibits nuisance odors.
The Otay Landfill, located approximately two miles west of the project area, is considered to be a major
odor-generating facility in Chula Vista. This facility has the potential to produce odors that can be
detected outside of the landfill boundary. Odor control practices are in place at all landfills, and odor
control is under the purview of the SDAPCD. Landfill odor control practices include application of odor
absorbing materials or collecting and treating gases from the landfill before they are released into the
surrounding community.
The 2005 GPU EIR included a summary of the health risk assessment that was conducted to support the
Final EIR prepared for the Otay Landfill Development and Expansion Plan (County of San Diego 2000). As
part of the expansion, the landfill was also upgraded to include control odor facilities, such as installing
flares to dispose of excess landfill gases. This assessment also included an evaluation of nuisance odor
issues. The analysis indicated that a buffer of 1,000 feet should be used as a screening threshold for
health risk and nuisance odor impacts. The EIR included mitigation measure 5.11-2 that requires that no
residential use be permitted within 1,000 feet of the Otay Landfill while the landfill was open and
operating, unless a project-specific analysis is completed demonstrating that odor effects are below the
odor thresholds for common compounds emitted by the landfill. One such compound is hydrogen
sulfide, which has an odor threshold of 0.0045 ppm.
The distance between the landfill and the proposed residences within Village 8 West (two miles) is
beyond the screening distance (1,000 feet) established by the 2005 GPU EIR as resulting in a significant
impact. However, even at a distance of two miles, it is possible that odors from the Otay Landfill may be
detected occasionally (depending on wind direction or other meteorological factors) by the proposed
residents of Village 8 West. Facilities that cause nuisance odors are subject to enforcement action by the
SDAPCD. Regarding odor impacts, the California Health and Safety Code Section 41700 and SDAPCD Rule
51 prohibit emissions from any source whatsoever in such quantities of air contam inants or other
material, which cause injury, detriment, nuisance, or annoyance to the public health or damage to
property. The SDAPCD responds to odor complaints by investigating the complaint determining whether
the odor violates SDAPCD Rule 51. The inspector takes enforcement action if the source is not in
compliance with the SDAPCD rules and regulations (SDAPCD 2010). In the event of enforcement action,
odor-causing impacts must be mitigated by appropriate means to reduce the impacts to sensitive
receptors to less than significant. Such means include shutdown of odor sources or requirements to
control odors using add-on equipment.
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Therefore, consistent with the air quality technical report for the 2013 GPA/GDPA SEIR, the project
would not create or result in objectionable odors that may affect a substantial number of people, and
odor impacts are less than significant.
D. Threshold 4: Result in a conflict with, or obstruct implementation of, the RAQS
or SIP.
The air quality plans relevant to this discussion are the SIP and RAQS. The SIP includes strategies and
tactics to be used to attain and maintain acceptable air quality in the SDAB based on the NAAQS; while
the RAQS includes strategies for the Basin to meet the CAAQS. Consistency with the RAQS is typically
determined by two standards. The first standard is whether the project would exceed growth
assumptions contained in the RAQS. If the project would exceed the RAQS growth assumptions, the
second standard is whether the project would increase the frequency or severity of existing air quality
violations, contribute to new violations, or delay the timely attainment of air quality standards or
interim reductions as specified in the RAQS.
The RAQS rely on information from the CARB and SANDAG, including mobile and area source emissions,
as well as information regarding projected growth in the County of San Diego, to forecast future
emissions and then determine the strategies necessary for the reduction of emissions through
regulatory controls. The CARB mobile source emissions projections and the SANDAG growth projections
are based on population and vehicle use trends and land use plans developed by the cities and the
County as part of the development of their respective general plans. As such, projects that propose
development consistent with, or less than, the growth projections anticipated by a general plan would
be consistent with the RAQS. The growth projections in the RAQS, most recently updated in 2009, are
based on the 2030 Regional Transportation Plan prepared by SANDAG (2003). For Village 8 West, the
Chula Vista General Plan is the document governing future land use that was considered as part of
SANDAG’s projections. The growth projections for the city in the Chula Vista General Plan and the 2005
GPU EIR, adopted in December 2005, are consistent with the projections in the 2030 Regional
Transportation Plan. However, the General Plan was amended in 2013. The amendment increased the
number of units in Village 8 West by 494 units. This project is consistent with the General Plan as
amended but since the RAQS have not yet been updated to be consistent with the General Plan, this
project is inconsistent with the RAQS. Because the project would conflict with the growth assumptions
of the RAQS, it is subject to the second criterion for determining consistency with the RAQS: whether
the project would increase the frequency or severity of existing air quality violations, co ntribute to new
violations, or delay the timely attainment of air quality standards or interim reductions as specified in
the RAQS.
The city has experienced violations of the state and federal ozone, state PM10, and state and federal
PM2.5 ambient air quality standards between 2008 and 2010. The SDAB is currently designated as a
nonattainment area for the state standard for PM10, PM2.5, 1-Hour and 8-Hour ozone, and the federal 8-
Hour standard for ozone. The project would allow residential, mixed use, school, and park uses. It is not
anticipated that development constructed as a result of the project would result in significant stationary
sources that would result in any air quality violations. As shown in Table 5.4-7, PM10, and PM2.5
unmitigated emissions from area sources are less than significant; however, emissions of VOCs, an
ozone precursor, would be significant.
Additionally, the project would also have the potential to result in air pollutant emissions from increased
traffic on area roadways that may lead to air quality violations, consistent with the conclusion in the
2013 GPA/GDPA SEIR air quality technical report. As shown in Table 5.4-7, pollutant emissions from
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vehicular emissions alone would exceed the thresholds for PM10. Additionally, construction of the
project would result in temporary significant emissions of nitrogen oxides, VOCs, PM10, and PM2.5.
Operational and construction emissions would be significant and unavoidable, even with
implementation of BMPs and other mitigation in measures 5.4-1, 5.4-2, and 5.4-3. Therefore, consistent
with the conclusion of the 2013 GPA/GDPA SEIR air quality technical report, emissions from the project
may lead to air quality violations.
The project would be consistent with all applicable transportation and area source control measures
proposed in the RAQS to reduce emissions in the region, as shown in Table 5.4-9. However,
implementation of the project would exceed the growth projections in the RAQS and would exceed the
significant thresholds for ozone precursors and particulate matter during construction and operation.
Therefore, impacts related to consistency with applicable air quality plans would be potentially
significant.
Table 5.4-9 Project Consistency with RAQS Control Measures
RAQS Control
Measure Project Consistency
Transit
Improvements
Village 8 West would be transit ready for future extension of transit service into the area. Transit service
would consist of bus service, including Rapid Bus Service. The bus system would provide local connections
between residential, employment, and major activity centers within Village 8 West and Otay Ranch, as well
as regional connections. Additionally, Rapid Bus Service has a higher level of service with more frequent
headways and is designed to be faster and easier for riders to use than traditional bus service. Two
potential transit stops are proposed on the project site.
Park-and-Ride
Facilities
The SPA Plan and TM does not specifically propose park and ride facilities; however, the SPA Plan is
designed to provide transit stops in easily accessible areas and provide bicycle and pedestrian connections
to transit stops so the transit riders would not need to drive to transit stops.
Bicycle Facilities Within the Town Center, on-street bike lanes would be provided. Main vehicular thoroughfares would
include dedicated, striped, on-street Class II bike lanes. Local streets would not provide dedicated lanes for
bicycles; however, the traffic volumes on parkway residential streets would be low enough to
accommodate bicycles as well as vehicles. A village pathway that currently terminates at the south end of
Magdalena Avenue would be extended through the project site and would provide a multi-use trail. A
greenbelt trail would ultimately connect to the Salt Creek Trail as part of the Otay Valley Regional Park
system.
Smart Growth
Development
SANDAG’S Smart Growth Concept Map identifies Village 8 West as a Community Center to provide low to
mid-rise residential and commercial buildings within one quarter mile of a transit center. The SPA Plan is
consistent with this concept. The project promotes smart growth principles such as mixed-use
development, a range of housing choices, walkability, proximity to employment centers, environmentally
sensitive design, providing adequate infrastructure, and by providing a variety of transportation choices.
Pedestrian
Facilities
The pedestrian circulation network includes an interconnected system of village pathways, sidewalks, and
rural trails. All streets in Village 8 West would include a sidewalk or trail. Multiple pathways would be
provided through parks, the Town Center, and multi-family neighborhoods to provide direct pedestrian
connections between the various transects in Village 8 West and to adjacent villages.
Traffic Calming
Practices
The SPA Plan and TM would implement several traffic calming measures including urban couplets;
intersection bulb-outs; narrow, multi-modal streets; and a circulation pattern design with multiple
connections to more evenly distribute traffic.
Support Bus Rapid
Transit
Bus Rapid Transit is the highest level of transit service being considered for the Otay Ranch area. Village 8
West supports extension of the transit system by providing accessible transit stops and accommodating
reserved transit lanes on project roadways.
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E. Threshold 5: Be inconsistent with General Plan, GDP, or other relevant
objectives and policies regarding air quality thereby resulting in a significant
physical impact.
Table 5.4-10 evaluates the consistency of the project with the applicable General Plan policies and Table
5.4-11 evaluates the project’s consistency with the GDP goals and objectives. As shown in these tables,
the project would be consistent with the General Plan and GDP policies that pertain to air quality.
Table 5.4-10 Project Consistency with Applicable General Plan Air Quality Policy
Applicable Policies Evaluation of Consistency
Objective E 6: Improve local air quality by minimizing the
production and emission of air pollutants and toxic air
contaminants and limit the exposure of people to such
pollutants.
Policy E 6.1: Encourage compact development featuring a mix
of uses that locate residential areas within reasonable walking
distance to jobs, services, and transit.
Policy E 6.2: Promote and facilitate transit system
improvements in order to increase transit use and reduce
dependency on the automobile.
Policy E 6.6: Explore incentives to promote voluntary air
pollutant reductions, including incentives for developers who go
above and beyond applicable requirements and for facilities
and operations that are not otherwise regulated.
Policy E 6.7 Encourage innovative energy conservation practices
and air quality improvements in new development and
redevelopment projects consistent with AQIP guidelines or its
equivalent, pursuant to the Growth Management Ordinance.
Consistent. The project would be consistent with this objective
and supporting policies because the SPA Plan encourages
compact development surrounding a mixed-use town center
with transit service. The Town Center would include high-
density housing and would be surrounded by lower density
housing. Pedestrian and bicycle facilities would be provided to
connect all areas to the Town Center and promote transit use.
Mitigation measures 5.4-2 and 5.4-3 include construction best
management practices and dust minimizing practices that go
beyond the typical city dust-minimizing practices for
construction. The SPA Plan includes an AQIP to minimize the
project’s impact on air quality. The SPA Plan proposes a land use
plan to minimize vehicle trips, which would conserve energy
and protect air quality.
Table 5.4-11 Project Consistency with Applicable GDP Air Quality Policy
Applicable Policies Evaluation of Consistency
Part II, Chapter 6 – Air Quality
Goal: Minimize the adverse impacts of development on air
quality.
Consistent. The Village 8 West SPA Plan encourages job/housing
balance, transit access, and alternative travel modes to
minimize criteria air pollutant emissions. The SPA Plan has been
designed to offer residents numerous alternative methods of
transportation, including public transit and pedestrian paths,
which connect residential neighborhoods to the Town Center as
well as to other areas outside of the villages. A mix of uses
promotes walking and decreases car trips and air pollution.
Additionally, the Village 8 West AQIP has incorporated
mitigation measures 5.4-1, 5.4-2, and 5.4-3 to further minimize
criteria air pollutant emissions.
Goal: Land development patterns which minimize the adverse
impacts of development on air quality.
Objective: Encourage mixed use development to promote
linking of trips, reduce trip length and encourage alternative
mode usage.
Consistent. The SPA Plan has been designed with a mixed use
town center in accordance with village concepts that promote a
jobs/housing balance and alternatives to automobile use. The
convenient village pedestrian path system and internal streets,
which are designed to accommodate bicycles, will encourage
alternate modes of travel. Additionally, all areas within the
project area would be linked by sidewalks or pedestrian trails.
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Table 5.4-11 Project Consistency with Applicable GDP Air Quality Policy (continued)
Applicable Policies Evaluation of Consistency
Policy: Villages should have a mixed-use village core area where
higher density residential, civic, and park uses are interspersed
with neighborhood commercial and office development.
Policy: Locate sensitive receptors, such as schools, day care
facilities and similar uses away from emissions generating uses.
Policy: Minimize "drive-in" establishments to reduce emissions
from idling vehicles.
Consistent. Mitigation measure 5.4-4 requires compliance with
CARB guidelines for siting sensitive receptors. Drive-in
establishments would be limited to the Town Center and
subject to a conditional use permit. Transit stops would be
centrally located in the Town Center and accessible to bicyclists
and pedestrians. The SPA Plan includes design guidelines for
well-designed transit stops, sidewalks, benches, landscaping,
street furniture and bicycle storage.
Policy Arterials and transit stops should be linked by a network
of sidewalks and bike paths.
Policy: Transit facilities should be located near village cores,
proximate to park-and-ride facilities, the EUC and allow
sufficient space reserved for bus stops, and pedestrian waiting
areas, including sidewalks, benches, landscaping, street
furniture and bicycle storage.
Policy: Transit stops should be within 1/4 mile of village core
residential areas and within 1/8 mile of village core activity
centers.
Policy: Locate employment centers close to housing, transit and
HOV lane corridors.
Objective: Minimize particulate emissions, which are the result
of the construction process.
Policy: Minimize particulate emission during construction to
control fugitive dust.
Policy: Minimize simultaneous operation of multiple
construction vehicles and equipment, use low polluting
construction equipment.
Policy: Manage unpaved roads to minimize particulate
emissions during the construction and development activities,
and during interim agricultural/off road activities.
Consistent. Mitigation measure 5.4-1, 5.4-2, and 5.4-3 would
implement the BMPs recommended in these policies and
additional BMPs to minimize particulate emissions.
5.4.5 Level of Significance Prior to Mitigation
A. Air Quality Violations
Implementation of the project would have the potential to result significant criteria pollutant emissions
during construction and operation.
B. Sensitive Receptors
The project would have the potential to result in the exposure of sensitive receptors to TACs during
operation if the project does not comply with CARB siting criteria.
C. Air Quality Plans
Implementation of the project would conflict with applicable air quality plans.
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D. Objectionable Odors
No significant impacts related to objectionable odors have been identified for implementation of the
project.
E. Consistency with Air Quality Policies
The project would be consistent with applicable General Plan and GDP policies related to air quality.
5.4.6 Mitigation Measures
A. Air Quality Violations
The following mitigation measures would minimize criteria pollutant emissions during construction. The
1993 Program EIR for the GDP (EIR 90-01) includes land use policies, siting/design policies, and
transportation-related management actions to mitigate operational emissions (Ogden 1992 ). All
applicable measures have already been incorporated into the SPA Plan, such as provision of bike lanes,
providing services near residences, and providing transit support facilities such as bus stops, as listed in
Chapter 3, Project Description.
Mitigation measure GDP EIR-1 from the 1993 Program EIR for the GDP (is included below as mitigation
measure 5.4-1. Mitigation measure 5.5.5-1 from the 2013 GPA/GDPA SEIR (SEIR 09-01) is included below
as mitigation measure 5.4-2. Mitigation measures 5.4-1 through 5.4-3 would reduce impacts related to
emissions of nitrogen oxides, PM10, and PM2.5 during construction. Mitigation measure 5.4-1 lists the
BMPs recommended in the Otay Ranch GDP Final Program EIR to reduce construction emissions.
Mitigation measure 5.4-1 lists the BMPs recommended by the city in the 2005 GPU EIR and the 2013
GPA/GDPA SEIR for reducing fugitive dust emissions during grading. Mitigation measure 5.4-3 includes
additional project-specific measures to reduce nitrogen oxides, PM10, and PM2.5 emissions during all
construction activities. These measures would also minimize potential indirect impacts to sensitive
biological resources from dust. Future construction activities would also be required to comply with
SDAPCD Rule 55 requirements for grading and the SDAPCD Rule 67 requirements for low VOC coatings.
The following mitigation measures are also required in the AQIP, which incorporated the analysis in the
air quality technical report (Appendix C).
5.4-1 Short-term Air Quality Violations Reduction Measures. The following techniques to reduce
construction emissions shall be implemented during all construction activities:
i. Minimize simultaneous operation of multiple construction equipment units (i.e., phase
construction to minimize impacts).
ii. Use low pollutant-emitting construction equipment.
iii. Use electrical construction equipment as practical.
iv. Use catalytic reduction for gasoline-powered equipment.
v. Use injection timing retard for diesel-powered equipment.
vi. Water the construction area twice daily to minimize fugitive dust.
vii. Stabilize (for example hydroseed) graded areas as quickly as possible to minimize fugitive
dust.
viii. Pave permanent roads as quickly as possible to minimize dust.
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5.4-2 Dust Control Measures. Mitigation of PM10 impacts requires active dust control during
construction. As a matter of standard practice, the City of Chula Vista shall require the following
standard construction measures be included on all grading plans to the satisfaction of the City
Engineer, and shall be implemented during construction to the extent applicable:
i. All unpaved construction areas shall be sprinkled with water or other acceptable San Diego
Air Pollution Control District dust control agents twice daily during dust-generating activities
to reduce dust emissions. Additional watering or acceptable Air Pollution Control District
dust control agents shall be applied during dry weather or on windy days until dust
emissions are not visible.
ii. Trucks hauling dirt and debris shall be properly covered to reduce windblown dust and spills.
iii. A 20-mile-per-hour speed limit on unpaved surfaces shall be enforced.
iv. On dry days, dirt and debris spilled onto paved surfaces shall be swept up immediately to
reduce re-suspension of particulate matter caused by vehicle movement. Approach routes
to construction sites shall be cleaned daily of construction-related dirt in dry weather.
v. On-site stockpiles of excavated material shall be covered or watered.
vi. Disturbed areas shall be hydroseeded, landscaped, or developed as quickly as possible and
as directed by the city and/or Air Pollution Control District to reduce dust generation.
vii. To the maximum extent feasible:
a. Heavy-duty construction equipment with modified combustion/fuel injection systems
for emissions control shall be utilized during grading and construction activities.
b. Catalytic reduction for gasoline-powered equipment shall be used.
viii. Equip construction equipment with pre-chamber diesel engines (or equivalent) together
with proper maintenance and operation to reduce emissions of nitrogen oxides, to the
extent available and feasible.
ix. Electrical construction equipment shall be used to the extent feasible.
x. The simultaneous operations of multiple construction equipment units shall be minimized
(i.e., phase construction to minimize impacts).
5.4-3 Construction Best Management Practices. During all construction activities for the project, the
project applicant shall ensure implementation of the following best management practices to
reduce the emissions of nitrogen oxides and fugitive dust (PM10 and PM2.5). Prior to issuance of a
grading permit, the following best management practices shall be included on all grading plans
to the satisfaction of the City Engineer and shall be implemented during construction to the
extent applicable:
i. All construction equipment shall be outfitted with best available control technology devices
certified by the California Air Resources Board. A copy of each unit’s best available control
technology documentation shall be provided at the time of mobilization of each applicable
unit of equipment.
ii. Approach routes to the site shall be cleaned daily of construction-related dirt.
iii. Apply chemical stabilizer or pave the last 100 feet of internal travel path within the
construction site prior to public road entry.
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iv. Install wheel washers or rumble plates adjacent to a paved apron prior to any vehicle entry
on public roads.
v. Remove any visible track-out into traveled public streets within 30 minutes of occurrence.
vi. Wet wash the construction access point at the end of each workday if any vehicle travel on
unpaved surfaces has occurred.
vii. Provide sufficient perimeter erosion control to prevent washout of silty material onto public
roads.
viii. General contractors shall maintain and operate construction equipment so as to minimize
exhaust emissions. During construction, trucks and vehicles in loading and unloading queues
should turn their engines off when not in use to reduce vehicle emissions. Construction
emissions should be phased and scheduled to avoid emissions peaks and shall be
discontinued during second stage smog alerts.
ix. During construction, site grading activities within 500 feet of a school in operation shall be
discontinued or all exposed surfaces shall be watered to minimize dust transport off site to
the maximum degree feasible, when the wind velocity is greater than 15 miles per hour in
the direction of the school.
x. During blasting, utilize control measures to minimize fugitive dust. Control measures may
include, but are not limited to, blast enclosures, vacuum blasters, drapes, water curtains, or
wet blasting.
B. Sensitive Receptors
5.4-4 San Diego Air Pollution Control District Toxic Air Contaminants Emission Criteria Compliance.
Prior to approval of the building permit for any uses that are regulated for toxic air contaminant
emissions by the San Diego Air Pollution Control District, the project applicant shall demonstrate
to the satisfaction of the Development Services Director (or their designee) that the use
complies with established criteria (such as those established by San Diego Air Pollution Control
District Rule 1200 and California Air Resources Board). Specifically, gas stations would not be
allowed to be constructed within 50 feet of a sensitive receptor, in compliance with the
California Air Resources Board siting recommendations.
C. Objectionable Odors
No mitigation measures are required.
D. Air Quality Plans
Mitigation measures 5.4-1, 5.4-2, and 5.4-3 would also minimize impacts related to conflicts with air
quality plans but not to a level below significance.
E. Consistency with Air Quality Policies
No mitigation measures are required.
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5.4.7 Level of Significance After Mitigation
A. Air Quality Violations
1. Construction
The 2013 GPA/GDPA SEIR determined that construction emissions from implementation of the
GPA/GDPA would be reduced to a less than significant level with implementation of the measures listed
in mitigation measure 2005 GPU EIR 5.11-1 and GPA/GDPA SEIR 5.5.5.1. However, construction
emissions and emissions reductions were not quantified because no specific construction details were
available at the programmatic level of analysis. Additionally, the GPA/GDPA SEIR mitigation measures
only addressed fugitive dust emissions (PM10 and PM2.5). Construction of the project would also result in
significant emissions of nitrogen oxides during grading, and additional significant emissions of nitrogen
oxides and VOCs would result from simultaneous construction activities.
The Otay Ranch GDP Final Program EIR and GPA/GDPA SEIR do not quantify the emissions reductions
associated with the recommended BMPs. However, the URBEMIS 2007 provides emission reductions for
some of the BMPs required in the mitigation measures. Table 5.4-12 summarizes the construction
related emissions for a single phase of Village 8 West with implementation of mitigation measures 5.4-1,
5.4-2, and 5.4-3. Implementation of these mitigation measures would reduce significant emissions of
nitrogen oxides, PM10, and PM2.5 during grading and significant nitrogen oxides emissions during surface
improvements, but not to a less than significant level.
Additionally, simultaneous construction activities would still have the potential to result in exceedances
of the significance thresholds for nitrogen oxides, VOCs, PM10, and PM2.5. Additional available mitigation
measures to reduce emissions would require the use of electric powered earth movers or aqueous
diesel fuel. Use of electric power earth movers is not feasible because a large enough power source that
would be needed to supply energy to such large equipment is not available on the site. A commitment
to use aqueous diesel fuel is currently not feasible because this fuel is not widely used or available in San
Diego County. However, the project would incorporate electrically powered tools and smaller
equipment that would be served by hard wired temporary power sources until more permanent power
sources are available. If a reliable source of diesel aqueous fuel becomes available, it would be used
during project construction. Use of an alternative fuel type of such as natural gas or propane instead of
electricity is not a feasible alternative because these fuels would increase nitrogen oxides and VOC
emissions. Therefore, construction emissions would remain significant and unavoidable.
2. Operation
The applicable measures of the Otay GDP Final Program EIR mitigation measures have already been
incorporated into the SPA Plan, such as provision of bike lanes, providing services near residences, and
providing transit support facilities such as bus stops. There are no other feasible mitigation measures
available at the project level to reduce vehicular emissions other than reducing vehicle trips.
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Table 5.4-12 Mitigated Construction Maximum Daily Emissions by Activity (pounds/day)
Construction Activity
Pollutant Emissions (pounds/day)
CO VOC NOX SOX PM10 PM2.5
Unmitigated Emissions
Mass Grading Total Emissions(1) 174 44 379 0 4,345 918
Trenching(2) 22 6 51 0 2 2
Surface Improvements (paving)(3) 52 15 121 0 5 4
Building Construction and Coating Phases(4) 161 36 81 0 4 3
Combined Daily Total for all Construction Activities (unmitigated) 409 101 632 0 4,356 927
Mitigated Emissions(5)
Mass Grading Total Emissions(1) 174 44 323 0 2,460 522
Trenching(2) 22 6 44 0 1 1
Surface Improvements (paving)(3) 52 15 103 0 4 3
Building Construction and Coating Phases(4) 161 36 72 0 4 3
Combined Daily Total for all Construction Activities (mitigated) 409 101 542 0 2,469 529
Significance Threshold 550 75 100 150 150 55
Significant Impact? No Yes Yes No Yes Yes
Bold = Exceeds significance threshold
CO = carbon monoxide; VOC = reactive organic gases; NOx = nitrogen oxides; SOx = sulfur oxides;
PM10 = respirable particulate matter; PM2.5 = fine particulate matter
Modeling assumptions: Emissions are based on assumptions for the Yellow phase, plus additional equipment added to account
for blasting within the Blue and Orange phases, and off-site improvements. Worst-case construction activities for the Yellow
phase were assumed to occur during 2013-2015.
(1) Assumes a three-month period and a maximum land disturbance of 20 acres per day. A total of approximately 268 acres
would be disturbed over five development phases. A total of 4.7 million cubic yards would be graded and replaced within the
disturbance area, or 940,000 cubic yards in each phase. All cut material would be used on site and no hauling of material off
site would be required. Equipment list for grading includes an excavator, two graders, four heavy-duty trucks, five dozers, 12
scrapers, and two water trucks. A drill rig, crushing unit, and tractor would be required for blasting in the Orange and Blue
phases and are included in the modeled equipment list.
(2) Assumes a two-month period. Equipment list includes two excavators, two dump trucks, a dozer, two backhoes, and a water
truck.
(3) Assumes a two-month period. Paving and surface improvements would be required for approximately 12 percent of the
project area (31 acres), or six acres per phase. Assumes an additional two acres for off-site improvements. Equipment list
includes a grader, a paver, a roller, and 27 dump trucks and concrete trucks.
(4) Assumes a two-year period and architectural coating activities would occur simultaneously with the building construction
activities. Assumes building construction would require a total of 11 dump trucks and concrete trucks, an excavator, a
backhoe, and a water truck. Based on the Yellow phase, which includes development of 765 multi-family units, 126,000
square feet of commercial land use, a community park, and a middle school. Assumes model defaults for low VOC coating
emissions (250 grams of VOC per liter or less).
(5) Assumes use of diesel particulate filters and diesel oxidation catalysts for all equipment. Due to a calculation error in the
URBEMIS 2007 model, the total reduction in PM10 and PM2.5 emissions that would occur as result of watering exposed
surfaces, applying chemical stabilizers, and replacing ground cover cannot be calculated because the URBEMIS 2007 model
overestimates the reduction in emissions. SCAQMD recommends application of the single highest control measure. Watering
twice daily was applied for the project. Additionally, emission reductions estimates are not available for all of the BMPs.
Emissions would likely be reduced compared to these estimates, but not to a less than significant level.
Source: CARB 2007. See Appendix C for data sheets.
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The project trip generation rates account for the approximately 40 percent reduction in vehicle trips
that would occur as a result of the mixed-use areas, transit use, and availability of pedestrian and bicycle
facilities proposed as part of the SPA Plan. In addition, future vehicular emissions may be lower than
estimated due to increasingly stringent California fuel efficiency requirements. Some measures cannot
be implemented at the SPA level, such as providing video-conference facilities in work places or
requiring flexible work schedules. Additionally, there are no feasible mitigation measures currently
available to reduce area sources of emissions without regulating the purchases of individual consumers.
Operation emissions of nitrogen oxides, VOCs, and PM10 would be significant and unavoidable.
Mitigation measure 5.4-4 ensures that any use within Village 8 West that emits TACs would comply with
SDAPCD criteria, and therefore impacts would be less than significant after mitigation.
B. Sensitive Receptors
With the implementation of mitigation measure 5.4-4 identified above, air quality impacts related to
sensitive receptors would be reduced to below a level of significance.
C. Objectionable Odors
Impacts would be less than significant without mitigation.
D. Air Quality Plans
Mitigation measures 5.4-1, 5.4-2, and 5.4-3 would reduce construction emissions of nitrogen oxides,
VOC, PM10, and PM2.5. However, even with implementation of all feasible mitigation measures,
construction and operational impacts would exceed the significance thresholds and contribute to
potential air quality violations. Further, the project is inconsistent with the RAQS. Therefore, impacts
related to consistency with applicable air quality plans would also be significant and unavoidable,
consistent with the conclusion of the GPA/GDPA SEIR air quality analysis.
E. Consistency with Air Quality Policies
Impacts would be less than significant without mitigation.