HomeMy WebLinkAboutAttachment 8P - CEQA Energy ReviewAZ Office CA Office
4960 S. Gilbert Road, Ste 1-461 1197 Los Angeles Avenue, Ste C-256
Chandler, AZ 85249 Simi Valley, CA 93065
p. (602) 774-1950 p. (805) 426-4477
www.mdacoustics.com
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February 6, 2023
Mr. Steven Schwarz
VWP-OP Nirvana Owner, LLC
2390 E. Camelback Rd., Ste. 305
Phoenix, AZ 85016
Subject: Chula Vista Nirvana Business Park – CEQA Energy Review,
821 Main Street, City of Chula Vista, CA
Dear Mr. Schwarz:
MD Acoustics, LLC (MD) has completed a CEQA energy review for the proposed Chula Vista Self Storage
project located at 821 Main Street between Nirvana Avenue and Heritage Road in the City of Chula Vista,
San Diego County, California. The project proposes to develop the 13.31-acre site with three warehouse
buildings totaling 158,416 square feet and one three-story self-storage building totaling 140,802 square
feet.
1.0 Existing Energy Conditions
Overview
California’s estimated annual energy use as of 2019 included:
• Approximately 277,704 gigawatt hours of electricity; 1
• Approximately 2,136,907 million cubic feet of natural gas per year (for the year 2018)2;and
• Approximately 23.2 billion gallons of transportation fuel (for the year 2015)3.
As of 2019, the year of most recent data currently available by the United States Energy Information
Administration (EIA), energy use in California by demand sector was:
• Approximately 39.3 percent transportation;
• Approximately 23.2 percent industrial;
• Approximately 18.7 percent residential; and
• Approximately 18.9 percent commercial.4
1California Energy Commission. Energy Almanac. Total Electric Generation. [Online] 2020.
https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2019-total-system-electric-generation.
2Natural Gas Consumption by End Use. U.S. Energy Information Administration. [Online] August 31, 20020.
https://www.eia.gov/dnav/ng/ng_cons_sum_dcu_SCA_a.htm.
3California Energy Commission. Revised Transportation Energy Demand Forecast 2018-2030. [Online] April 19, 2018. https://www.energy.ca.gov/assessments/
4U.S. Energy Information Administration. California Energy Consumption by by End-Use Sector.
California State Profile and Energy Estimates.[Online] January 16, 2020 https://www.eia.gov/state/?sid=CA#tabs-2
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California's electricity in-state generation system generates approximately 200,475 gigawatt-hours each
year. In 2019, California produced approximately 72 percent of the electricity it uses; the rest was imported
from the Pacific Northwest (approximately 9 percent) and the U.S. Southwest (approximately 19 percent).
Natural gas is the main source for electricity generation at approximately 42.97 percent of the total in-state
electric generation system power as shown in Table 1.
Table 1: Total Electricity System Power (California 201 9)
Fuel Type
California
In-State
Generation
(GWh)
Percent of
California
In-State
Generation
Northwest
Imports
(GWh)
Southwest
Imports
(GWh)
Total
Imports
(GWh)
Percent
of
Imports
California
Power
Mix
(GWh)
Percent
California
Power
Mix
Coal 248 0.12% 219 7,765 7,985 10.34% 8,233 2.96%
Natural Gas 86,136 42.97% 62 8,859 8,921 11.55% 95,057 34.23%
Nuclear 16,163 8.06% 39 8,743 8,782 11.37% 24,945 8.98%
Oil 36 0.02% 0 0 0 0.00% 36 0.01%
Other (Petroleum
Coke/Waste Heat) 411 0.20% 0 11 11 0.01% 422 0.15%
Large Hydro 33,145 16.53% 6,387 1,071 7,458 9.66% 40,603 14.62%
Unspecified
Sources of Power 0 0.00% 6,609 13,767 20,376 26.38% 20,376 7.34%
Renewables 64,336 32.09% 10,615 13,081 23,696 30.68% 88,032 31.70%
Biomass 5,851 2.92% 903 33 936 1.21% 6,787 2.44%
Geothermal 10,943 5.46% 99 2,218 2,318 3.00% 13,260 4.77%
Somall Hydro 5,349 2.67% 292 4 296 0.38% 5,646 2.03%
Solar 28,513 14.22% 282 5,295 5,577 7.22% 34,090 12.28%
Wind 13,680 6.82% 9,038 5,531 14,569 18.87% 28,249 10.17%
Total 200,475 100.00% 23,930 53,299 77,229 100.00% 277,704 100.00%
Notes:
1 Source: California Energy Commission. 2019 Total System electric Generation. https://www.energy.ca.gov/data-reports/energy-almanac/california-
electricity-data/2019-total-system-electric-generation
A summary of and context for energy consumption and energy demands within the State is presented in
“U.S. Energy Information Administration, California State Profile and Energy Estimates, Quick Facts”
excerpted below:
• California was the seventh-largest producer of crude oil among the 50 states in 2018, and, as of
January 2019, it ranked third in oil refining capacity.
• California is the largest consumer of jet fuel among the 50 states and accounted for one-fifth of
the nation’s jet fuel consumption in 2018.
• California’s total energy consumption is the second-highest in the nation, but, in 2018, the State’s
per capita energy consumption ranked the fourth-lowest, due in part to its mild climate and its
energy efficiency programs.
• In 2018, California ranked first in the nation as a producer of electricity from solar, geothermal,
and biomass resources and fourth in the nation in conventional hydroelectric power generation.
• In 2018, large- and small-scale solar PV and solar thermal installations provided 19% of
California’s net electricity generation5.
5State Profile and Energy Estimates. Independent Statistics and Analysis. [Online] [Cited: January 16, 2020.] http://www.eia.gov/state/?sid=CA#tabs2.
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As indicated above, California is one of the nation’s leading energy‐producing states, and California per
capita energy use is among the nation’s most efficient. Given the nature of the proposed project, the
remainder of this discussion will focus on the three sources of energy that are most relevant to the project—
namely, electricity and natural gas for building uses, and transportation fuel for vehicle trips associated with
the proposed project.
Electricity and Natural Gas
Electricity and natural gas would be provided to the project by San Diego Gas & Electric (SDG&E). SDG&E
provides electrical and natural gas service to the project area through State‐regulated utility contracts.
SDG&E provides electric energy service to 3.6 million people located in most of San Diego County and
the southern portion of Orange County, within a service area encompassing approximately 4,100 square
miles.6 The delivery of electricity involves a number of system components, including substations and
transformers that lower transmission line power (voltage) to a level appropriate for on‐site distrib ution
and use. The electricity generated is distributed through a network of transmission and distribution lines
commonly called a power grid. In 2020, SDG&E provided 17,445 Gigawatt‐hours per year of electricity.7
Table 2 identifies SDG&E’s specific proportional shares of electricity sources in 2019. As shown in Table
2, the 2019 SDG&E Power Mix has renewable energy at 31.3 percent of the overall energy resources, of
which biomass and waste is at 2 percent, solar energy is at 17 percent, and wind power is at 13 percent;
other energy sources include natural gas at 24 percent and unspecified sources at 44 percent.
Natural gas is delivered through a nation‐wide network of high‐pressure transmission pipelines. In 2020,
SDG&E provided 505.2 Million Therms of natural gas.8
The following summary of natural gas resources and service providers, delivery systems, and associated
regulation is excerpted from information provided by the California Public Utilities Commission (CPUC).
The CPUC regulates natural gas utility service for approximately 11 million customers that receive natural
gas from Pacific Gas and Electric (PG&E), Southern California Gas (SoCalGas), San Diego Gas & Electric
(SDG&E), Southwest Gas, and several smaller investor-owned natural gas utilities. The CPUC also
regulates independent storage operators Lodi Gas Storage, Wild Goose Storage, Central Valley
Storage and Gill Ranch Storage.
California's natural gas utilities provide service to over 11 million gas meters. SoCalGas and PG&E
provide service to about 5.9 million and 4.3 million customers, respectively, while SDG&E provides
service to over 800, 000 customers. In 2018, California gas utilities forecasted that they would deliver
about 4740 million cubic feet per day (MMcfd) of gas to their customers, on average, under normal
weather conditions.
6 https://www.sdge.com/more-information/our-company
7 Obtained from http://www.ecdms.energy.ca.gov/elecbyutil.aspx
8 Obtained from http://www.ecdms.energy.ca.gov/gasbyutil.aspx
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The vast majority of California's natural gas customers are residential and small commercial customers,
referred to as "core" customers. Larger volume gas customers, like electric generators and industrial
customers, are called "noncore" customers. Although very small in number relative to core customers,
noncore customers consume about 65% of the natural gas delivered by the state's natural gas utilities,
while core customers consume about 35%.
The PUC regulates the California utilities' natural gas rates and natural gas services, including in -state
transportation over the utilities' transmission and distribution pipeline systems, storage, procurement,
metering and billing.
Most of the natural gas used in California comes from out-of-state natural gas basins. In 2017, for
example, California utility customers received 38% of their natural gas supply from basins located in the
U.S. Southwest, 27% from Canada, 27% from the U.S. Rocky Mountain area, and 8% from production
located in California.”9
Table 2: SDG&E 2019 Power Content Mix
Energy Resources 2019 SDG&E Power Mix
Eligible Renewable1 31.3%
Biomass & Biowaste 2%
Geothermal 0%
Eligible Hydroelectric 0%
Solar 17%
Wind 13%
Coal 0%
Large Hydroelectric 0%
Natural Gas 24%
Nuclear 0%
Other 0%
Unspecified Sources of
power2 44%
Total 100%
Notes:
Source: 'https://www.sdge.com/sites/default/files/documents/FINAL_S2010027_DecOnsert20.pdf
(1) The eligible renewable percentage above does not reflect RPS compliance, which is determined using a
different methodology.
(2) Unspecified sources of power means electricity from transactions that are not traceable to specific
generation sources.
Transportation Energy Resources
The project would attract additional vehicle trips with resulting consumption of energy resources,
predominantly gasoline and diesel fuel. Gasoline (and other vehicle fuels) are commercially‐provided
commodities and would be available to the project patrons and employees via commercial outlets.
9California Public Utilities Commission. Natural Gas and California. http://www.cpuc.ca.gov/natural_gas/
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The most recent data available shows the transportation sector emits 40 percent of the total greenhouse
gases in the state and about 84 percent of smog-forming oxides of nitrogen (NOx).10,11 About 28 percent
of total United States energy consumption in 2019 was for transporting people and goods from one place
to another. In 2019, petroleum comprised about 91 percent of all transportation energy use, excluding
fuel consumed for aviation and most marine vessels.12 In 2020, about 123.49 billion gallons (or about
2.94 billion barrels) of finished motor gasoline were consumed in the United States, an average of about
337 million gallons (or about 8.03 million barrels) per day.13
2.0 Regulatory Background
Federal and state agencies regulate energy use and consumption through various means and programs. On
the federal level, the United States Department of Transportation, the United States Department of Energy,
and the United States Environmental Protection Agency are three federal agencies with substantial
influence over energy policies and programs. On the state level, the PUC and the California Energy
Commissions (CEC) are two agencies with authority over different aspects of energy. Relevant federal and
state energy‐related laws and plans are summarized below.
Federal Regulations
Corporate Average Fuel Economy (CAFE) Standards
First established by the U.S. Congress in 1975, the Corporate Average Fuel Economy (CAFE) standards
reduce energy consumption by increasing the fuel economy of cars and light trucks. The National Highway
Traffic Safety Administration (NHTSA) and U.S. Environmental Protection Agency (USEPA) jointly administer
the CAFE standards. The U.S. Congress has specified that CAFE standards must be set at the “maximum
feasible level” with consideration given for: (1) technological feasibility; (2) economic practicality; (3) effect
of other standards on fuel economy; and (4) need for the nation to conserve energy.14
Issued by NHTSA and EPA in March 2020 (published on April 30, 2020 and effective after June 29, 2020),
the Safer Affordable Fuel-Efficient Vehicles Rule would maintain the CAFE and CO2 standards applicable
in model year 2020 for model years 2021 through 2026. The estimated CAFE and CO2 standards for
model year 2020 are 43.7 mpg and 204 grams of CO2 per mile for passenger cars and 31.3 mpg and 284
grams of CO2 per mile for light trucks, projecting an overall industry average of 37 mpg, as compared to
46.7 mpg under the standards issued in 2012.15
10 CARB. California Greenhouse Gas Emissions Inventory – 2020 Edition. https://www.arb.ca.gov/cc/inventory/data/data.htm
11 CARB. 2016 SIP Emission Projection Data. https://www.arb.ca.gov/app/emsinv/2017/emseic1_query.php?F_DIV=-
4&F_YR=2012&F_SEASON=A&SP=SIP105ADJ&F_AREA=CA
12 US Energy Information Administration. Use of Energy in the United States Explained: Energy Use for Transportation.
https://www.eia.gov/energyexplained/?page=us_energy_transportation
13 https://www.eia.gov/tools/faqs/faq.php?id=23&t=10
14 https://www.nhtsa.gov/lawsregulations/corporate-average-fuel-economy.
15 National Highway Traffic Safety Administration (NHTSA) and U.S. Environmental Protection Agency (USEPA), 2018. Federal Register / Vol. 83, No. 165 / Friday,
August 24, 2018 / Proposed Rules, The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks 2018.
Available at: https://www.epa.gov/regulations-emissions-vehicles-and-engines/safer-affordable-fuel-efficient-safe-vehicles-final-rule.
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Intermodal Surface transportation Efficiency Act of 1991 (ISTEA)
The Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) promoted the development of inter‐
modal transportation systems to maximize mobility as well as address national and local interests in air
quality and energy. ISTEA contained factors that Metropolitan Planning Organizations (MPOs) were to
address in developing transportation plans and programs, including some energy‐related factors. To meet
the new ISTEA requirements, MPOs adopted explicit policies defining the social, economic, energy, and
environmental values guiding transportation decisions.
The Transportation Equity Act of the 21st Century (TEA-21)
The Transportation Equity Act for the 21st Century (TEA‐21) was signed into law in 1998 and builds upon
the initiatives established in the ISTEA legislation, discussed above. TEA‐21 authorizes highway, highway
safety, transit, and other efficient surface transportation programs. TEA‐21 continues the program structure
established for highways and transit under ISTEA, such as flexibility in the use of funds, emphasis on
measures to improve the environment, and focus on a strong planning process as the foundation of good
transportation decisions. TEA‐21 also provides for investment in research and its application to maximize
the performance of the transportation system through, for example, deployment of Intelligent
Transportation Systems, to help improve operations and management of transportation systems and
vehicle safety.
State Regulations
Integrated Energy Policy Report (IEPR)
Senate Bill 1389 requires the California Energy Commission (CEC) to prepare a biennial integrated energy
policy report that assesses major energy trends and issues facing the State’s electricity, natural gas, and
transportation fuel sectors and provides policy recommendations to conserve resources; protect the
environment; ensure reliable, secure, and diverse energy supplies; enhance the state’s economy; and
protect public health and safety. The Energy Commission prepares these assessments and associated policy
recommendations every two years, with updates in alternate years, as part of the Integrated Energy Policy
Report.
The 2019 Integrated Energy Policy Report (2019 IEPR) was adopted February 20, 2020, and continues to
work towards improving electricity, natural gas, and transportation fuel energy use in California. The
2019 IEPR focuses on a variety of topics such as decarbonizing buildings, integrating renewables, energy
efficiency, energy equity, integrating renewable energy, updates on Southern Califo rnia electricity
reliability, climate adaptation activities for the energy sector, natural gas assessment, transportation
energy demand forecast, and the California Energy Demand Forecast.16
The 2020 IEPR was adopted March 23, 2021 and identifies actions the state and others can take to ensure
a clean. Affordable, and reliable energy system. In 2020, the IEPR focuses on California’s transportation
16 California Energy Commission. Final 2019 Integrated Energy Policy Report. February 20, 2020. https://www.energy.ca.gov/data-
reports/reports/integrated-energy-policy-report/2019-integrated-energy-policy-report
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future and the transition to zero-emission vehicles, examines microgrids, lessons learned form a decade
of state-supported research, and stakeholder feedback on the potential of microgrids to contribute to a
lean and resilient energy system; and reports on California’s energy demand outlook, updated to reflect
the global pandemic and help plan for a growth in zero -emission plug in electric vehicles.17
State of California Energy Plan
The CEC is responsible for preparing the State Energy Plan, which identifies emerging trends related to
energy supply, demand, conservation, public health and safety, and the maintenance of a healthy economy.
The Plan calls for the state to assist in the transformation of the transportation system to improve air quality,
reduce congestion, and increase the efficient use of fuel supplies with the least environmental and energy
costs. To further this policy, the plan identifies a number of strategies, including assistance to public agencies
and fleet operators and encouragement of urban designs that reduce vehicle miles traveled and
accommodate pedestrian and bicycle access.
California Building Standards Code (Title 24)
California Building Energy Efficiency Standards (Title 24, Part 6)
The California Building Energy Efficiency Standards for Residential and Nonresidential Buildings (California
Code of Regulations, Title 24, Part 6) were adopted to ensure that building construction and system design
and installation achieve energy efficiency and preserve outdoor and indoor environmental quality. The
current California Building Energy Efficiency Standards (Title 24 standards) are the 2019 Title 24 standards,
which became effective on January 1, 2020. The 2019 Title 24 standards include efficiency improvements
to the lighting and efficiency improvements to the non-residential standards include alignment with the
American Society of Heating and Air-Conditioning Engineers.
All buildings for which an application for a building permit is submitted on or after January 1, 2020 must
follow the 2019 standards. The 2016 residential standards were estimated to be approximately 28 percent
more efficient than the 2013 standards, whereas the 2019 residential standards are estimated to be
approximately 7 percent more efficient than the 2016 standards. Furthermore, once rooftop solar electricity
generation is factored in, 2019 residential standards are estimated to be approximately 53 percent more
efficient than the 2016 standards. Under the 2019 standards, nonresidential buildings are estimated to be
approximately 30 percent more efficient than the 2016 standards. Energy efficient buildings require less
electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases
greenhouse gas emissions.
California Building Energy Efficiency Standards (Title 24, Part 11)
The 2019 California Green Building Standards Code (California Code of Regulations, Title 24, Part 11),
commonly referred to as the CALGreen Code, went into effect on January 1, 2020. The 2019 CALGreen
Code includes mandatory measures for non-residential development related to site development;
17 California Energy Commission. Final 2020 Integrated Energy Policy Report. March 23, 2020. https://www.energy.ca.gov/data-reports/reports/integrated-
energy-policy-report/2020-integrated-energy-policy-report-update
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energy efficiency; water efficiency and conservation; material conservation and resource efficiency; and
environmental quality.
The Department of Housing and Community Development (HCD) updated CALGreen through the 2 019
Triennial Code Adoption Cycle. HCD modified the best management practices for stormwater pollution
prevention adding Section 5.106.2; added sections 5.106.4.1.3 and 5.106.4.1.5 in regard to bicycle
parking; amended section 5.106.5.3.5 allowing future charging spaces to qualify as designated parking
for clean air vehicles; updated section 5.303.3.3 in regard to showerhead flow rates; amended section
5.304.1 for outdoor potable water use in landscape areas and repealed s ections 5.304.2 and 5.304.3;
and updated Section 5.504.5.3 in regard to the use of MERV filters in mechanically ventilated buildings.
Senate Bill 100
Senate Bill 100 (SB 100) requires 100 percent of total retail sales of electricity in California to come from
eligible renewable energy resources and zero-carbon resources by December 31, 2045. SB 100 was
adopted September 2018.
The interim thresholds from prior Senate Bills and Executive Orders would also remain in effect. These
include Senate Bill 1078 (SB 1078), which requires retail sellers of electricity, including investor-owned
utilities and community choice aggregators, to provide at least 20 percent of their supply from renewable
sources by 2017. Senate Bill 107 (SB 107) which changed the target date to 2010. Executive Orde r S-14-
08, which was signed on November 2008 and expanded the State’s Renewable Energy Standard to 33
percent renewable energy by 2020. Executive Order S-21-09 directed the CARB to adopt regulations by
July 31, 2010 to enforce S-14-08. Senate Bill X1-2 codifies the 33 percent renewable energy requirement
by 2020.
Senate Bill 350
Senate Bill 350 (SB 350) was signed into law October 7, 2015, SB 350 increases California’s renewable
electricity procurement goal from 33 percent by 2020 to 50 percent by 2030. This will increase the use of
Renewables Portfolio Standard (RPS) eligible resources, including solar, wind, biomass, geothermal, and
others. In addition, SB 350 requires the state to double statewide energy efficiency savings in electricity and
natural gas end uses by 2030. To help ensure these goals are met and the greenhouse gas emission
reductions are realized, large utilities will be required to develop and submit Integrated Resource Plans
(IRPs). These IRPs will detail how each entity will meet their customers resource needs, reduce greenhouse
gas emissions and ramp up the deployment of clean energy resources.
Assembly Bill 32
In 2006 the California State Legislature adopted Assembly Bill 32 (AB 32), the California Global Warming
Solutions Act of 2006. AB 32 requires CARB, to adopt rules and regulations that would achieve GHG
emissions equivalent to statewide levels in 1990 by 2020 through an enforceable statewide emission cap
which will be phased in starting in 2012. Emission reductions shall include carbon sequestration projects
that would remove carbon from the atmosphere and best management practices that are technologically
feasible and cost effective.
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Assembly Bill 1493/Pavley Regulations
California Assembly Bill 1493 enacted on July 22, 2002, required CARB to develop and adopt regulations
that reduce GHGs emitted by passenger vehicles and light duty trucks. In 2005, the CARB submitted a
“waiver” request to the EPA from a portion of the federal Clean Air Act in order to allow the State to set
more stringent tailpipe emission standards for CO2 and other GHG emissions from passenger vehicles and
light duty trucks. On December 19, 2007 the EPA announced that it denied the “waiver” request. On January
21, 2009, CARB submitted a letter to the EPA administrator regarding the State’s request to reconsider the
waiver denial. The EPA approved the waiver on June 30, 2009.
Executive Order S-1-07/Low Carbon Fuel Standard
Executive Order S-1-07 was issued in 2007 and proclaims that the transportation sector is the main source
of GHG emissions in the State, since it generates more than 40 percent of the State’s GHG emissions. It
establishes a goal to reduce the carbon intensity of transportation fuels sold in the State by at least ten
percent by 2020. This Order also directs CARB to determine whether this Low Carbon Fuel Standard (LCFS)
could be adopted as a discrete early-action measure as part of the effort to meet the mandates in AB 32.
On April 23, 2009 CARB approved the proposed regulation to implement the low carbon fuel standard and
began implementation on January 1, 2011. The low carbon fuel standard is anticipated to reduce GHG
emissions by about 16 MMT per year by 2020. CARB approved some amendments to the LCFS in December
2011, which were implemented on January 1, 2013. In September 2015, the Board approved the re-
adoption of the LCFS, which became effective on January 1, 2016, to address procedural deficiencies in the
way the original regulation was adopted. In 2018, the Board approved amendments to the regulation, which
included strengthening and smoothing the carbon intensity benchmarks through 2030 in-line with
California's 2030 GHG emission reduction target enacted through SB 32, adding new crediting opportunities
to promote zero emission vehicle adoption, alternative jet fuel, carbon capture and sequestration, and
advanced technologies to achieve deep decarbonization in the transportation sector.
The LCFS is designed to encourage the use of cleaner low-carbon transportation fuels in California,
encourage the production of those fuels, and therefore, reduce GHG emissions and decrease petroleum
dependence in the transportation sector. Separate standards are established for gasoline and diesel fuels
and the alternative fuels that can replace each. The standards are “back-loaded”, with more reductions
required in the last five years, than during the first five years. This schedule allows for the development of
advanced fuels that are lower in carbon than today’s fuels and the market penetration of plug-in hybrid
electric vehicles, battery electric vehicles, fuel cell vehicles, and flexible fuel vehicles. It is anticipated that
compliance with the low carbon fuel standard will be based on a combination of both lower carbon fuels
and more efficient vehicles.
Reformulated gasoline mixed with corn-derived ethanol at ten percent by volume and low sulfur diesel fuel
represent the baseline fuels. Lower carbon fuels may be ethanol, biodiesel, renewable diesel, or blends of
these fuels with gasoline or diesel as appropriate. Compressed natural gas and liquefied natural gas also
may be low carbon fuels. Hydrogen and electricity, when used in fuel cells or electric vehicles are also
considered as low carbon fuels for the low carbon fuel standard.
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Executive Order N-79-20.
Executive Order N-79-20 was signed into law on September 23, 2020 and mandates 100 percent of in-state
sales of new passenger cars and trucks be zero-emission by 2035; 100 percent of medium- and heavy-duty
vehicles in the state be zero-emission vehicles by 2045 for all operations where feasible and by 2035 for
drayage trucks; and to transition to 100 percent zero-emission off-road vehicles and equipment by 2035
where feasible.
California Air Resources Board
CARB’s Advanced Clean Cars Program
Closely associated with the Pavley regulations, the Advanced Clean Cars emissions control program was
approved by CARB in 2012. The program combines the control of smog, soot, and GHGs with requirements
for greater numbers of zero-emission vehicles for model years 2015–2025. The components of the
Advanced Clean Cars program include the Low-Emission Vehicle (LEV) regulations that reduce criteria
pollutants and GHG emissions from light- and medium-duty vehicles, and the Zero-Emission Vehicle (ZEV)
regulation, which requires manufacturers to produce an increasing number of pure ZEVs (meaning battery
electric and fuel cell electric vehicles), with provisions to also produce plug-in hybrid electric vehicles (PHEV)
in the 2018 through 2025 model years.18
Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling
The Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling (Title 13,
California Code of Regulations, Division 3, Chapter 10, Section 2435) was adopted to reduce public exposure
to diesel particulate matter and other air contaminants by limiting the idling of diesel-fueled commercial
motor vehicles. This section applies to diesel-fueled commercial motor vehicles with gross vehicular weight
ratings of greater than 10,000 pounds that are or must be licensed for operation on highways. Reducing
idling of diesel-fueled commercial motor vehicles reduces the amount of petroleum-based fuel used by the
vehicle.
Regulation to Reduce Emissions of Diesel Particulate Matter, Oxides of Nitrogen, and other Criteria
Pollutants, form In-Use Heavy-Duty Diesel-Fueled Vehicles
The Regulation to Reduce Emissions of Diesel Particulate Matter, Oxides of Nitrogen and other Criteria
Pollutants, from In-Use Heavy-Duty Diesel-Fueled Vehicles (Title 13, California Code of Regulations, Division
3, Chapter 1, Section 2025) was adopted to reduce emissions of diesel particulate matter, oxides of nitrogen
(NOX) and other criteria pollutants from in-use diesel-fueled vehicles. This regulation is phased, with full
implementation by 2023. The regulation aims to reduce emissions by requiring the installation of diesel soot
filters and encouraging the retirement, replacement, or repower of older, dirtier engines with newer
emission-controlled models. The newer emission controlled models would use petroleum-based fuel in a
more efficient manner.
18 California Air Resources Board, California’s Advanced Clean Cars Program, January 18, 2017. www.arb.ca.gov/msprog/acc/acc.htm.
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Sustainable Communities Strategy
The Sustainable Communities and Climate Protection Act of 2008, or Senate Bill 375 (SB 375), coordinates
land use planning, regional transportation plans, and funding priorities to help California meet the GHG
reduction mandates established in AB 32.
Senate Bill 375 (SB 375) was adopted September 2008 and aligns regional transportation planning efforts,
regional GHG emission reduction targets, and land use and housing allocation. SB 375 requires Metropolitan
Planning Organizations (MPO) to adopt a sustainable communities strategy (SCS) or alternate planning
strategy (APS) that will prescribe land use allocation in that MPOs Regional Transportation Plan (RTP). CARB,
in consultation with each MPO, will provide each affected region with reduction targets for GHGs emitted
by passenger cars and light trucks in the region for the years 2020 and 2035. These reduction targets will be
updated every eight years but can be updated every four years if advancements in emissions technologies
affect the reduction strategies to achieve the targets. As of 2018, the 2020 and 2035 targets were set at 15
percent and 19 percent, respectively. CARB is also charged with reviewing each MPO’s sustainable
communities strategy or alternate planning strategy for consistency with its assigned targets.
Renewables Portfolio Standard (RPS) Program
California's RPS program was established in 2002 by Senate Bill (SB) 1078 with the initial requirement
that 20% of electricity retail sales must be served by renewable resources by 2017. The program was
accelerated in 2015 with SB 350 which mandated a 50% RPS by 2030. SB 350 includes interim annual RPS
targets with three-year compliance periods and requires 65% of RPS procurement to be derived from
long-term contracts of 10 or more years. In 2018, SB 100 was signed into law, which again increases the
RPS to 60% by 2030 and requires all the state's electricity to come from carbon-free resources by 204519.
San Diego Gas & Electric procured 42 percent of its power from renewable resources, which is above the
State’s statutory and Commission’s RPS program requirements20.
City Regulations
Final Environmental Impact Report for the City of Chula Vista General Plan Update
MM 5.8-1 The City shall continue to implement the Energy Strategy and Action Plan, that addresses
demand side management, energy efficient and renewable energy outreach programs for
businesses and residents, energy acquisition, power generation, and distributed energy
resources and legislative actions, and continue to implement the CO2 Reduction Plan to
lessen the impacts on energy.
19 Renewables Portfolio Standard (RPS) Program. 2021. https://www.cpuc.ca.gov/rps/.
20 Substitute Sheets to Update Draft 2021 Renewables Portfolio Standard Procurement Plan. September 13, 2021.
https://www.sdge.com/sites/default/files/regulatory/SDGE%202021%20Draft%20RPS%20Plan%20Update%20PUBLIC%20VERSION%20for%20posting%20to%20
website.pdf.
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3.0 Evaluation Criteria and Methodology
Evaluation Criteria
CEQA Energy Questions
In compliance with Appendix G of the State CEQA Guidelines, this report analyzes the project’s anticipated
energy use to determine if the project would:
a) Would the project result in potentially significant environmental impact due to wasteful, inefficient,
or unnecessary consumption of energy resources, during project construction or operation?
b) Would the project conflict with or obstruct a state or local plan for renewable energy or energy
efficiency?
In addition, Appendix F of the State CEQA Guidelines states that the means of achieving the goal of energy
conservation includes the following:
• Decreasing overall per capita energy consumption;
• Decreasing reliance on fossil fuels such as coal, natural gas and oil; and
• Increasing reliance on renewable energy sources.
Appendix F of the State CEQA guidelines also states that the environmental impacts from a project can
include:
• The project’s energy requirements and its energy use efficiencies by amount and fuel type for each
stage of the project including construction, operation, maintenance and/or removal. If appropriate,
the energy intensiveness of materials may be discussed.
• The effects of the project on local and regional energy supplies and on requirements for additional
capacity.
• The effects of the project on peak and base period demands for electricity and other forms of
energy.
• The degree to which the project complies with existing energy standards.
• The effects of the project on energy resources.
• The project’s projected transportation energy use requirements and its overall use of efficient
transportation alternatives.
Methodology
Information from the CalEEMod 2022.1 Daily and Annual Outputs contained in the Chula Vista Self-Storage
Air Quality/Greenhouse Gas/Health Risk Assessment Impact Study (air quality/greenhouse gas/health risk
assessment analysis) prepared for the proposed project by MD (2023), was utilized for this analysis. The
CalEEMod outputs detail project related construction equipment, transportation energy demands, and
facility energy demands.
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4.0 Energy Review
Construction Energy Demand
The construction schedule is anticipated to begin no earlier than early June 2023 and be completed in
2025 and be completed in one phase.21 Staging of construction vehicles and equipment will occur on -
site.
Construction Equipment Electricity Usage Estimates
As stated previously, electrical service will be provided by SDG&E. The focus within this section is the
energy implications of the construction process, specifically the power cost from on -site electricity
consumption during construction of the proposed project. Based on the 2017 National Construction
Estimator, Richard Pray (2017)22, the typical power cost per 1,000 square feet of building construction
per month is estimated to be $2.32. The project plans to develop the site with three industrial buildings
totaling 158,418 square feet and one three-story self-storage building totaling 140,802 square feet over the
course of approximately 24 months. Based on Table 3, the total power cost of the on-site electricity
usage during the construction of the proposed project is estimated to be approximately $16,660.57.
Furthermore, SDG&E’s service rate for schedule is approximately $0.24 per kWh of electricity for the
proposed industrial project.23 As shown in Table 3, the total electricity usage from Project construction
related activities is estimated to be approximately 70,298 kWh.
Table 3: Project Construction Power Cost and Electricity Usage
Power Cost (per 1,000 square foot
of building per month of
construction)
Total Building
Size (1,000
Square Foot)
Construction
Duration
(months)
Total Project
Construction
Power Cost
$2.32 299.220 24 $16,660.57
Cost per kWh
Total Project Construction
Electricity Usage (kWh)
$0.24 70,298
*Assumes the project will be under Schedule TOU-A rate under SDG&E and, to be conservative, uses the
lower anticipated cost per kWh. Source: https://www.sdge.com/sites/default/files/regulatory/3-1-
21%20Small%20Commercial%20Total%20Rates%20Table.pdf
Construction Equipment Fuel Estimates
Fuel consumed by construction equipment would be the primary energy resource expended over the
course of project construction. Fuel consumed by construction equipment was evaluated with the
following assumptions:
• Construction schedule of approximately 24 months
21 Per the project applicant, the project is to be operational in mid 2025. Therefore, the estimated construction timeline was generated based on CalEEMod default
construction timelines for each phase of construction and a completion date of June 2025.
22 Pray, Richard. 2017 National Construction Estimator. Carlsbad : Craftsman Book Company, 2017.
23 Assumes the project will be under Schedule TOU-A rate under SDG&E and, to be conservative, uses the lower anticipated cost per kWh. Source:
https://www.sdge.com/sites/default/files/regulatory/3-1-21%20Small%20Commercial%20Total%20Rates%20Table.pdf
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• All construction equipment was assumed to run on diesel fuel
• Typical daily use of 8 hours, with some equipment operating from ~6 -7 hours
• Aggregate fuel consumption rate for all equipment was estimated at 18.5 bhp-hr/gal (from
CARB’s 2017 Emissions Factors Tables and fuel consumption rate factors as shown in Table D -21
of the Moyer Guidelines:
(https://ww2.arb.ca.gov/sites/default/files/2020-06/2017_cmpgl.pdf).
• Diesel fuel would be the responsibility of the equipment operators/contractors and would be
sources within the region.
• Project construction represents a “single-event” for diesel fuel demand and would not require
on-going or permanent commitment of diesel fuel resources during long term operation.
Using the CalEEMod data input from the air quality/greenhouse gas/health risk assessment analysis (MD
Acoustics 2023), the project’s construction phase would consume electricity and fossil fuels as a single
energy demand, that is, once construction is completed their use would cease. CARB’s 201 7 Emissions
Factors Tables show that on average aggregate fuel consumption (gasoline and diesel fuel) would be
approximately 18.5 bhp-hr-gal. Table 4 shows the results of the analysis of construction equipment.
Table 4: Construction Equipment Fuel Consumption Estimates
Phase
Number
of Days Offroad Equipment Type Amount
Usage
Hours
Horse
Power
Load
Factor
HP
hrs/day
Total Fuel
Consumption
(gal diesel
fuel)1,2,3
Site
Preparation
14 Rubber Tired Dozers 3 8 367 0.4 3,523 2,666
14 Earthmovers/Tractors/
Loaders/Backhoes 4 8 84 0.37 995 753
Grading
41 Excavators 2 8 36 0.38 219 485
41 Graders 1 8 148 0.41 485 1,076
41 Rubber Tired Dozers 1 8 367 0.4 1,174 2,603
41 Scrapers 2 8 423 0.48 3,249 7,200
41 Earthmovers/Tractors/
Loaders/Backhoes 2 8 84 0.37 497 1,102
Building
Construction
408 Cranes 1 7 367 0.29 745 16,430
408 Forklifts 3 8 82 0.2 394 8,680
408 Generator Sets 1 8 14 0.74 83 1,828
408 Earthmovers/Tractors/
Loaders/Backhoes 3 7 84 0.37 653 14,394
408 Welders 1 8 46 0.45 166 3,652
Paving
27 Pavers 2 8 81 0.42 544 794
27 Paving Equipment 2 8 89 0.36 513 748
27 Rollers 2 8 36 0.38 219 319
Architectural
Coating 27 Air Compressors 1 6 37 0.48 107 156
CONSTRUCTION FUEL DEMAND (gallons of diesel fuel) 60,221
Notes:
1Using Carl Moyer Guidelines Table D-21 Fuel consumption rate factors (bhp-hr/gal) for engines less than 750 hp.
(Source: https://ww2.arb.ca.gov/sites/default/files/2020-06/2017_cmpgl.pdf)
2Totals may not add up precisely to rounding.
3Total Fuel Consumption = (Number of Days x Amount x Usage Hours x Horsepower x Load Factor) / 18.5 bhp-hr-gal
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As presented in Table 4, project construction activities would consume an estimated 60,221 gallons of
diesel fuel. As stated previously, project construction would represent a “single‐event” diesel fuel
demand and would not require on‐going or permanent commitment of diesel fuel resources for this
purpose.
Construction Worker Fuel Estimates
It is assumed that all construction worker trips are from light duty autos (LDA) along area roadways. With
respect to estimated VMT, the construction worker trips would generate an estimated 642,668 VMT.
Data regarding project related construction worker t rips were based on CalEEMod 2022.1 model
defaults.
Vehicle fuel efficiencies for construction workers were estimated in the air quality/greenhouse
gas/health risk assessment analysis (MD Acoustics 2023) using information generated using CARB’s
EMFAC model (see Appendix A for details). An aggregate fuel efficiency of 32.12 miles per gallon (mpg)
was used to calculate vehicle miles traveled for construction worker trips. Table 5 shows that an
estimated 20,008 gallons of fuel would be consumed for construction worker trips.
Table 5: Construction Worker Fuel Consumption Estimates
Phase
Number of
Days
Worker
Trips/Day
Trip
Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Site Preparation 14 17.5 12 2940 32.12 92
Grading 41 20 12 9,840 32.12 306
Building Construction 408 126 12 616,896 32.12 19,206
Paving 27 15 12 4,860 32.12 151
Architectural Coating 27 25.1 12 8,132 32.12 253
Total Construction Worker Fuel Consumption 20,008
Notes:
1Assumptions for the worker trip length and vehicle miles traveled are consistent with CalEEMod 2022.1 defaults.
Construction Vendor/Hauling Fuel Estimates
Tables 6 and 7 show the estimated fuel consumption for vendor and hauling during building construction
and architectural coating. With respect to estimated VMT, the vendor and hauling trips would generate
an estimated 158,293 VMT. Data regarding project related construction vendor and hauling trips were
based on CalEEMod 2022.1 model defaults.
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Table 6: Construction Vendor Fuel Consumption Estimates (MHD Trucks)1
Phase
Number
of Days
Vendor
Trips/Day
Trip
Length
(miles)
Vehicle Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Site Preparation 14 0 7.63 0 8.39 0
Grading 41 0 7.63 0 8.39 0
Building Construction 408 49 7.63 152,539 8.39 18,181
Paving 27 0 7.63 0 8.39 0
Architectural Coating 27 0 7.63 0 8.39 0
Total Construction Vendor Fuel Consumption 18,181
Notes:
1 Assumptions for the vendor trip length and vehicle miles traveled are consistent with CalEEMod 2022.1 defaults.
Table 7: Construction Hauling Fuel Consumption Estimates (HHD Trucks)1
Phase
Number of
Days
Hauling
Trips/Day
Trip
Length
(miles)
Vehicle
Miles
Traveled
Average
Vehicle Fuel
Economy
(mpg)
Estimated Fuel
Consumption
(gallons)
Site Preparation 14 1.07 20 300 6.48 46
Grading 41 0 20 0 6.48 0
Building Construction 408 0 20 0 6.48 0
Paving 27 10.1 20 5,454 6.48 842
Architectural Coating 27 0 20 0 6.48 0
Total Construction Hauling Fuel Consumption 888
Notes:
1Assumptions for the hauling trip length and vehicle miles traveled are consistent with CalEEMod 2022.1 defaults.
For the architectural coatings it is assumed that the contractors would be responsible for bringing
coatings and equipment with them in their light duty vehicles. Therefore, vendors delivering
construction material during building construction or hauling debris from the site during site preparation
would use medium to heavy duty vehicles with an average fuel consumption of 8.39 mpg for medium
heavy duty trucks and 6.48 mpg for heavy heavy duty trucks (see Appendix A for details). Tables 6 and 7
show that an estimated 19,069 gallons of fuel would be consumed for vendor and hauling trips.
Construction Energy Efficiency/Conservation Measures
Construction equipment used over the approximately 24-month construction phase would conform to
CARB regulations and California emissions standards and is evidence of related fuel efficiencies.
Construction of the proposed industrial development would require the typical use of energy resources.
There are no unusual project characteristics or construction processes that would require the use of
equipment that would be more energy intensive than is used for comparable activities; or equipment
that would not conform to current emissions standards (and related fuel e fficiencies). Equipment
employed in construction of the project would therefore not result in inefficient wasteful, or
unnecessary consumption of fuel.
CARB has adopted the Airborne Toxic Control Measure to limit heavy-duty diesel motor vehicle idling in
order to reduce public exposure to diesel particulate matter and other Toxic Air Contaminants.
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Additionally, as required by California Code of Regulations Title 13, Motor Vehicles, section 2449(d)(3)
Idling, limits idling times of construction vehicles to no more than five minutes, thereby minimizing or
eliminating unnecessary and wasteful consumption of fuel due to unproductive idling of construction
equipment. Enforcement of idling limitations is realized through periodic site inspections cond ucted by
City building officials, and/or in response to citizen complaints. Compliance with these measures would
result in a more efficient use of construction-related energy and would minimize or eliminate wasteful
or unnecessary consumption of energy. Idling restrictions and the use of newer engines and equipment
would result in less fuel combustion and energy consumption.
Operation Energy Demand
Energy consumption in support of or related to project operations would include transportation energy
demands (energy consumed by employee and patron vehicles accessing the project site) and facilities
energy demands (energy consumed by building operations and site maintenance activities).
Transportation Fuel Consumption
The largest source of operational energy use would be vehicle operation of employees and truck trips. The
site is located is in an urbanized area along Main Street east of the 805 Freeway. Furthermore, there are
existing transit services, provided by San Diego Metropolitan Transit System (SDMTS), approximately one
mile walking distance of the proposed Project site. The nearest transit service is SDMTS Routes 703 and
704, with a stop along Brandywine Avenue and Auto Park Drive.
Using the CalEEMod output from the air quality/greenhouse gas/health risk assessment analysis (MD
Acoustics 2023), it is assumed that an average one-way trip for autos and light trucks was assumed to be
9.5 miles and 3- 4-axle trucks were assumed to travel an average of 7.3 miles24. To be conservative, it
was assumed that vehicles would operate 365 days per year. Table 8 shows the estimated annual fuel
consumption for all classes of vehicles from autos to heavy- heavy trucks.25 The proposed project would
generate approximately 1,549 trips per day.26 The vehicle fleet mix was used from the CalEEMod output
from the air quality/greenhouse gas/health risk assessment analysis (MD Acoustics 2023). Table 8 shows
that an estimated 625,108 gallons of fuel would be consumed per year for the operation of the proposed
project.
24 CalEEMod default distance for H-W (home-work) or C-W (commercial-work) is 9.5 miles; 7.3 miles for H-O (home-other) or C-O (commercial-other). CalEEMod
default distances are based on land use type and location of the project. While it is possible trips could be significantly larger than these estimates, there is no
aspect of the project which would suggest consistent above average trips lengths compared to the average warehouse use in CalEEMod.
25 Average fuel economy based on aggregate mileage calculated in EMFAC 2017 for opening year (2022). See Appendix A for EMFAC output.
26 Per traffic study from Linscott, Law and Greenspan
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Table 8: Estimated Vehicle Operations Fuel Consumption
Vehicle Type Vehicle Mix
Number
of
Vehicles
Average
One-Way
Trip
(miles)1
Daily
VMT
Average
Fuel
Economy
(mpg)
Total
Gallons
per Day
Total Annual
Fuel
Consumption
(gallons)2
Light Auto Automobile 786 9.5 7,466 32.12 232.45 84,844
Light Truck Automobile 88 9.5 838 26.41 31.73 11,580
Light Truck Automobile 252 9.5 2,395 26.62 89.95 32,832
Medium Truck Automobile 168 9.5 1,593 20.43 77.99 28,467
Light Heavy Truck 2-Axle Truck 34 9.5 323 11.46 28.16 10,278
Light Heavy Truck 10,000 lbs + 2-Axle Truck 9 9.5 84 11.86 7.07 2,582
Medium Heavy Truck 3-Axle Truck 12 7.3 90 8.39 10.71 3,907
Heavy Heavy Truck3 4-Axle Truck 200 40 8,000 6.48 1234.57 450,617
Total 1,549 -- 20,788 -- 1712.62 --
Total Annual Fuel Consumption 625,108
Notes:
1Based on the size of the site and relative location, heavy heavy truck trips were assumed to regional and all other trips were assumed to be local.
2Totals may not add up precisely due to rounding.
3Heavy heavy duty truck trips increased from CalEEMod defaults of 0.63% to approximately 3% of all trips to account for additional industrial trips.
Trip generation and VMT generated by the proposed project are consistent with other similar industrial uses
of similar scale and configuration as reflected respectively in the (Not So) Brief Guide of Vehicular Traffic
Generation Rates for the San Diego Region (April, 2002). That is, the proposed project does not propose
uses or operations that would inherently result in excessive and wasteful vehicle trips and VMT, nor
associated excess and wasteful vehicle energy consumption. Furthermore, the state of California consumed
approximately 4.2 billion gallons of diesel and 15.1 billion gallons of gasoline in 2015.27,28 Therefore, the
increase in fuel consumption from the proposed project is insignificant in comparison to the State’s demand.
Therefore, project transportation energy consumption would not be considered inefficient, wasteful, or
otherwise unnecessary.
Facility Energy Demands (Electricity and Natural Gas)
Building operation and site maintenance (including landscape maintenance) would result in the
consumption of electricity and natural gas (provided by SDG&E). Operation of the proposed project
would involve the use of energy for heating, cooling and equipme nt operation. These facilities would
comply with all applicable California Energy Efficiency Standards and 2019 CALGreen Standards.
The annual natural gas and electricity demands were provided per the CalEEMod output f rom the air
quality and greenhouse gas analysis (MD Acoustics 2023) and are provided in Table 9.
27 https://www.energy.ca.gov/data-reports/energy-almanac/transportation-energy/california-gasoline-data-facts-and-statistics
28 https://www.energy.ca.gov/data-reports/energy-almanac/transportation-energy/diesel-fuel-data-facts-and-statistics
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Table 9: Project Annual Operational Energy Demand Summary1
Natural Gas Demand kBTU/year
Unrefrigerated Warehouse - No Rail 4,388,697
Total 4,388,697
Electricity Demand kWh/year
Unrefrigerated Warehouse - No Rail 1,304,586
Parking Lot 250,320
Total 1,554,906
Notes:
1Taken from the CalEEMod 2022.1 annual output in the Chula Vista Self -Storage Air Quality and Greenhouse Gas Impact
Study prepared for the proposed project by MD Acoustics (2023).
As shown in Table 9, the estimated electricity demand for the proposed project is approximately
1,554,906 kWh per year. In 2020, the non-residential sector of the County of San Diego consumed
approximately 11,658 million kWh of electricity.29 In addition, the estimated natural gas consumption
for the proposed project is approximately 4,388,697 kBTU per year. In 2020, the non-residential sector
of the County of San Diego consumed approximately 202 million therms of gas.30 Therefore, the increase
in both electricity and natural gas demand from the proposed project is insignificant compared to the
County’s 2020 non-residential sector demand. It is noted that gas is only being stubbed out to the project
sites, and it will be the tenant’s choice to use gas. Some tenants may prefer to be an all -electric facility,
in which case the gas consumption figures noted here are a worst-case scenario.
Energy use in buildings is divided into energy consumed by the built environment and energy consumed
by uses that are independent of the construction of the building such as in plug -in appliances. In
California, the California Building Standards Code Title 24 governs energy consumed by the built
environment, mechanical systems, and some types of fixed lighting. Non-building energy use, or “plug-
in” energy use can be further subdivided by specific end-use (refrigeration, cooking, appliances, etc.).
Furthermore, the proposed project energy demands in total would be comparable to other industrial
projects of similar scale and configuration. Therefore, the project facilities’ energy demands and energy
consumption would not be considered inefficient, wasteful, or otherwise unnecessary.
Renewable Energy and Energy Efficiency Plan Consistency
Plan Consistency
Regarding federal transportation regulations, the project site is located in an already developed area.
Access to/from the project site is from existing roads. These roads are already in place so the project
would not interfere with, nor otherwise obstruct intermodal transportation plans or projects that may
be proposed pursuant to the ISTEA because SANDAG is not planning for intermodal facilities in the
project area.
29 California Energy Commission, Electricity Consumption by County. https://ecdms.energy.ca.gov/elecbycounty.aspx
30 California Energy Commission, Gas Consumption by County. http://ecdms.energy.ca.gov/gasbycounty.aspx
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Regarding the State’s Energy Plan and compliance with Title 24 CCR energy efficiency sta ndards, the
applicant is required to comply with the California Green Building Standard Code requirements for
energy efficient buildings and appliances as well as utility energy efficiency programs implemented by
SDG&E.
Regarding the State’s Renewable Energy Portfolio Standards, the project would be required to meet or
exceed the energy standards established in the California Green Building Standards Code, Title 24, Part
11 (CALGreen). CalGreen Standards require that new buildings reduce water consumption , employ
building commissioning to increase building system efficiencies, divert construction waste from landfills,
use LED lighting, and install low pollutant-emitting finish materials.
As shown in the air quality, greenhouse gas, and health risk analysis (MD Acoustics 2023), the proposed
project is also consistent with the reduction strategies of the City of Chula Vista Climate Action Plan
(CAP).
Site Conditions for Renewable Energy Usage
On-site renewable energy sources have been considered. Geothermal energy, the use of heat naturally
present in shallow soil or in groundwater or rock to provide building heating/cooling and to heat water,
requires the installation of a heat exchanger consisting of a network of below -ground pipes to convey
heated or cooled air to a building. The presence of natural-occurring methane and hydrogen sulfide
gases, in the soil beneath the project site and in the project area, associated with underlying and nearby
oil and gas fields, requires the implementation of a Gas Mitigation and Monitoring System to ensure
subsurface gases do not pose a significant health or safety risk, and makes the construction and
operation of a heat exchanger for project buildings infeasible. Installation of a heat exchanger would
also require additional excavation compared to the project, which could increase impacts on
paleontological resources.
Although methane is a renewable derived biogas, it is not available on the project site in commercially
viable quantities or form (i.e., a form that could be used without further treatment), and its extraction
and treatment for energy purposes would result in secondary impacts.
Wind power represents variable-energy, or intermittent, resources that are generally used to augment,
but not replace, natural gas-fired energy power generation, since reliability of energy availability and
transmission is necessary to meet demand, which is constant . The Energy Information Administration
(EIA) states that “Good places for wind turbines are where the annual average wind speed is at least 9
miles per hour (mph).”31 The annual average wind speed in Chula Vista is approximately 7 miles per hour
with a maximum monthly windspeed of 8 miles per hour in December.32 Therefore, wind power would
not be a feasible solution at this location.
31 U.S. Energy Information Administration. Wind explained. March 30, 2022. https://www.eia.gov/energyexplained/wind/where-
wind-power-is-
harnessed.php#:~:text=Wind%20power%20plants%20require%20careful%20planning&text=Good%20places%20for%20wind%2
0turbines,)%20for%20utility%2Dscale%20turbines.
32 Weather Spark. Climate and Average Weather Year Round in Chula Vista. 2022. https://weatherspark.com/y/1804/Average-
Weather-in-Chula-Vista-California-United-States-Year-Round.
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With respect to other on-site renewable energy sources, because of the Project’s location, there are no
local sources of energy from the following sources: biodiesel, biomass hydroelectric and small hydro,
digester gas, fuel cells, landfill gas, municipal solid waste, ocean thermal, ocean wave, and tidal current
technologies, or multi-fuel facilities using renewable fuels.
Future Renewable Energy Usage
The project will include pre-installed conduit and an engineered roof for future solar energy panels. At
this time, the tenants are unknown, so the feasibility of installing rooftop solar at the time of the
completion of warehouse construction and beginning of operation (anticipated build -out year is 2025)
will depend on the tenant’s needs. Factors evaluated will include the cost of the solar system, tax
incentives, rebates, or incentives from the electricity provider, how much power the system will produce,
and the utility cost of electricity.
Additionally, while natural gas lines would be connected to the project, future tenants may de cide to not
use natural gas and only power the project with electricity. As shown in Table 2, 31.3% of the power
provided by SDG&E was from renewable sources in 2019, which would further renewable energy usage
for the project.
5.0 Conclusions
As supported by the preceding analyses, neither construction nor operation of the Project would result
in wasteful, inefficient, or unnecessary consumption of energy, or wasteful use of energy resources. The
proposed project does not include any unusual project characteristics or construction processes that
would require the use of equipment that would be more energy intensive than is used for comparable
activities and is an industrial project that is not proposing any additional features that would require a
larger energy demand than other industrial projects of similar scale and configuration. As the proposed
project is consistent with the existing General Plan land use designation, the energy demands of the
project are anticipated to be accommodated within the context of available resources and energy
delivery systems. The project would therefore not cause or result in the need for additional energy
producing or transmission facilities. The project would not engage in wasteful or inefficient uses of
energy and aims to achieve energy conservations goals within the State of California.
The Project has been designed in compliance with California’s Energy Efficiency Standards and 201 9
CALGreen Standards. These measures include but are not limited to the use of water conserving
plumbing, the use of LED lighting, and water-efficient irrigation systems. The Project would not conflict
with or obstruct a state or local plan for renewable energy or energy efficiency; therefore, impacts would
be less than significant.
MD is pleased to provide this CEQA Energy review. If you have any questions regarding this analysis, please
don’t hesitate to call us at (805) 426-4477.
Sincerely,
MD Acoustics, LLC
Chula Vista Nirvana Business Park
CEQA Energy Review
821 Main Street, City of Chula Vista, CA
MD Acoustics, LLC 22
JN: 06232106_Energy Letter Report _2.6.23
Mike Dickerson, INCE Tyler Klassen, EIT
Principal Air Quality Specialist
MD Acoustics, LLC 23
JN: 06232106_Energy Letter Report _2.6.23
Appendix A
CARB EMFAC 2017