HomeMy WebLinkAboutSDP 78-03D; La Costa Towne Center; Site Development Plan (SDP) (2)Air Quality Technical Report
for the
La Costa Towne Center
Renovation and Expansion Project
Submitted To:
Excel La Costa, LLC
Prepared By:
SdentifirTesouix^
1328 Kaimalino Lane
SanDiego, CA 92109
October 3, 2013
Table of Contents
1.0 Introduction 4
2.0 Existing Conditions 6
2.1 Regulatory Framework 6
2.1.1 Federal Regulations 6
2.1.2 State Regulations 8
2.1.3 Local Regulations 14
2.2 Climate and Meteorology 15
2.3 Background Air Quality 16
3.0 Thresholds of Significance 17
4.0 Impacts 20
4.1 Consistency with the RAQS and SIP 20
4.2 Violation of an Air Quality Standard 23
4.2.1 Construction Impacts 23
4.4.2 Operational Impacts 30
4.3 Cumulatively Considerable Net Increase of Nonattainment Pollutants 32
4.5 Objectionable Odors 34
5.0 Conclusions 34
6.0 References 36
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Glossary of Terms and Acronyms
APCD
AQIA
AQMD
AQMP
ARB
BACM
BACT
BMPs
CAA
CAAQS
CAL1NE4
Caltrans
CCAA
CO
EPA
H2S
HARP
HI
ISCST
mg/m
NAAQS
NOx
NO2
O3
PM2.5
PM 10
ppm
PSD
RAQS
ROCs
ROG
SANDAG
SCAQMD
SCAB
SDAB
SDAPCD
SIP
SOx
SO2
TACs
Air Pollution Control District
Air Quality Impact Assessment
Air Quality Management District
Air Quality Management Plan
Califomia Air Resources Board
Best Available Control Measure
Best Available Control Technology
Best Management Practices
Clean Air Act (Federal)
Califomia Ambient Air Quality Standard
Califomia Line Source Dispersion Model (Version 4)
Califomia Department of Transportation
Califomia Clean Air Act
Carbon Monoxide
United States Environmental Protection Agency
Hydrogen Sulfide
HotSpots Analysis and Reporting Program
Hazard Index
Industrial Source Complex Short Term Model
Milligrams per Cubic Meter
Micrograms per Cubic Meter
National Ambient Air Quality Standard
Oxides of Nitrogen
Nitrogen Dioxide
Ozone
Fine Particulate Matter (particulate matter with an aerodynamic diameter of 2.5
microns or less
Respirable Particulate Matter (particulate matter with an aerodynamic diameter of
10 microns or less
Parts per million
Prevention of Significant Deterioration
San Diego County Regional Air Quality Strategy
Reactive Organic Compounds
Reactive Organic Gases
San Diego Association of Governments
South Coast Air Quality Management District
South Coast Air Basin
San Diego Air Basin
San Diego County Air Pollution Control District
State Implementation Plan
Oxides of Sulfur
Sulfur Dioxide
Toxic Air Contaminants
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T-BACT Toxics Best Available Control Technology
VOCs Volatile Organic Compounds
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1.0 Introduction
This report presents an assessment of potential air quality impacts associated with the La costa
Towne Center Renovation and Expansion Project in the City of Carlsbad, Califomia.
The commercial center, originally known as Plaza de la Costa Real, was designed and
constructed in the early 1980s in accordance with the City of Carlsbad Site Development Plan
SDP-78-3 in a C=l commercial zone. The center consists of five one- and two-story multi-
tenant retail/office buildings anchored by a 30,800 square foot (sf) Vons grocery store. The
center provides approximately 124,000 sf ofbuilding area on a 15.2-acre (gross) site.
Excel LaCosta LLC proposes to renovate and expand the center to include a revitalized
commercial center and a mix of uses, including residential units. The overall renovation and
expansion of the center, as it is envisioned to be completed, would consist of two new mixed-use
commercial/residential buildings being added to the project along with a single level of structure
parking to provide a revitalized commercial center of 127,196 sf served by 521 parking places
and 60 multi-family apartment units with 103 secure parking spaces. The overall development is
proposed in four phases. The proposal would maintain and enhance the center while maintaining
the viability of the existing tenants.
This Air Quality Technical Report includes an evaluation of existing conditions in the project
vicinity, an assessment of potential impacts associated with project construction, and an
evaluation of project operational impacts.
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TRUST
BfiNSONcS,- mini
Preliminary Submittal
07/27/2012
La Costa Towne Center - Mixed Use Concept
2.0 Existing Conditions
The following section provides information about the existing air quality regulatory framework,
climate, air pollutants and sources, and sensitive receptors in the project area.
2.1 Regulatory Framework
2.1.1 Federal Regulations
Air quality is defined by ambient air concentrations of specific pollutants identified by the
United States Environmental Protection Agency (EPA) to be of concem with respect to health
and welfare of the general public. The EPA is responsible for enforcing the Federal Clean Air
Act (CAA) of 1970 and its 1977 and 1990 Amendments. The CAA required the EPA to
establish National Ambient Air Quality Standards (NAAQS), which identify concentrations of
pollutants in the ambient air below which no adverse effects on the public health and welfare are
anticipated. In response, the EPA established both primary and secondary standards for seven
pollutants (called "criteria" pollutants). The seven pollutants regulated under the NAAQS are as
follows: ozone (O3), carbon monoxide (CO), nitrogen dioxide (NO2), respirable particulate
matter (or particulate matter with an aerodynamic diameter of 10 microns or less, PMio), fme
particulate matter (or particulate matter with an aerodynamic diameter of 2.5 microns or less,
PM2,5), sulfur dioxide (SO2), and lead (Pb). Primary standards are designed to protect human
health with an adequate margin of safety. Secondary standards are designed to protect property
and the public welfare from air pollutants in the atmosphere. Areas that do not meet the NAAQS
for a particular pollutant are considered to be "nonattainment areas" for that pollutant. The
SDAB has been designated as a moderate O3 nonattainment area for the 8-hour O3 standard. The
SDAB is in attainment for the NAAQS for all other criteria pollutants.
The following specific descriptions of health effects for each of the criteria air pollutants
associated with project construction and operations are based on EPA (EPA 2007) and the
Califomia Air Resources Board (ARB) (ARB 2005).
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Ozone. O3 is considered a photochemical oxidant, which is a chemical that is formed when
reactive organic gases (ROG) and oxides of nitrogen (NOx), both by-products of combustion,
react in the presence of ultraviolet light. O3 is considered a respiratory irritant and prolonged
exposure can reduce lung function, aggravate asthma and increase susceptibility to respiratory
infections. Children and those with existing respiratory diseases are at greatest risk from
exposure to O3.
Carbon Monoxide. CO is a product of combustion, and the main source of CO in the SDAB is
from motor vehicle exhaust. CO is an odorless, colorless gas. CO affects red blood cells in the
body by binding to hemoglobin and reducing the amount of oxygen that can be carried to the
body's organs and tissues. CO can cause health effects to those with cardiovascular disease, and
can also affect mental alertness and vision.
Nitrogen Dioxide. NO2 is also a by-product of fuel combustion, and is formed both directly as a
product of combustion and in the atmosphere through the reaction of nitrogen oxide (NO) with
oxygen. NO2 is a respiratory irritant and may affect those with existing respiratory illness,
including asthma. NO2 can also increase the risk of respiratory illness.
Respirable Particulate Matter and Fine Particulate Matter. Respirable particulate matter, or
PMio, refers to particulate matter with an aerodynamic diameter of 10 microns or less. Fine
particulate matter, or PM2 5, refers to particulate matter with an aerodynamic diameter of 2.5
microns or less. Particulate matter in this size range has been determined to have the potential to
lodge in the lungs and contribute to respiratory problems. PMio and PM2 5 arise from a variety of
sources, including road dust, diesel exhaust, combustion, tire and brake wear, construction
operations and windblown dust. PMio and PM25 can increase susceptibility to respiratory
infections and can aggravate existing respiratory diseases such as asthma and chronic bronchitis.
PM2 5 is considered to have the potential to lodge deeper in the lungs.
Sulfur dioxide. SO2 is a colorless, reactive gas that is produced from the burning of sulfur-
containing fuels such as coal and oil, and by other industrial processes. Generally, the highest
concentrations of SO2 are found near large industrial sources. SO2 is a respiratory irritant that
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can cause narrowing of the airways leading to wheezing and shortness of breath. Long-term
exposure to SO2 can cause respiratory illness and aggravate existing cardiovascular disease.
Lead. Pb in the atmosphere occurs as particulate matter. Pb has historically been emitted from
vehicles combusting leaded gasoline, as well as from industrial sources. With the phase-out of
leaded gasoline, large manufacturing facilities are the sources of the largest amounts of lead
emissions. Pb has the potential to cause gastrointestinal, central nervous system, kidney and
blood diseases upon prolonged exposure. Pb is also classified as a probable human carcinogen.
2.1.2 State Regulations
California Clean Air Act. The Califomia Clean Air Act was signed into law on September 30,
1988, and became effective on January 1, 1989. The Act requires that local air districts
implement regulations to reduce emissions from mobile sources through the adoption and
enforcement of transportation control measures. The California Clean Air Act required the
SDAB to achieve a five percent annual reduction in ozone precursor emissions from 1987 until
the standards are attained. If this reduction cannot be achieved, all feasible control measures
must be implemented. Furthermore, the California Clean Air Act required local air districts to
implement a Best Available Control Technology rule and to require emission offsets for
nonattainment pollutants.
The ARB is the state regulatory agency with authority to enforce regulations to both achieve and
maintain air quality in the state. The ARB is responsible for the development, adoption, and
enforcement of the state's motor vehicle emissions program, as well as the adoption of the
California Ambient Air Quality Standards (CAAQS). The ARB also reviews operations and
programs of the local air districts, and requires each air district with jurisdiction over a
nonattainment area to develop its own strategy for achieving the NAAQS and CAAQS. The
CAA allows states to adopt ambient air quality standards and other regulations provided they are
at least as stringent as federal standards. The ARB has established the more stringent CAAQS
for the six criteria pollutants through the Califomia Clean Air Act of 1988, and also has
established CAAQS for additional pollutants, including sulfates, hydrogen sulfide, vinyl chloride
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and visibility-reducing particles. The SDAB is currently classified as a nonattainment area under
the CAAQS for O3, PMio, and PM2 5. It should be noted that the ARB does not differentiate
between attainment of the 1-hour and 8-hour CAAQS for O3; therefore, if an air basin records
exceedances of either standard the area is considered a nonattainment area for the CAAQS for
O3. The SDAB has recorded exceedances of both the 1-hour and 8-hour CAAQS for O3. The
following specific descriptions of health effects for the additional Califomia criteria air
pollutants are based on the ARB (ARB 2001).
Sulfates. Sulfates are the fully oxidized ionic form of sulfur. In Califomia, emissions of sulfur
compounds occur primarily from the combustion of petroleum-derived fuels (e.g., gasoline and
diesel fuel) that contain sulfur. This sulfur is oxidized to sulfur dioxide (SO2) during the
combustion process and subsequently converted to sulfate compounds in the atmosphere. The
conversion of SO2 to sulfates takes place comparatively rapidly and completely in urban areas of
Califomia due to regional meteorological features. The ARB's sulfates standard is designed to
prevent aggravation of respiratory symptoms. Effects of sulfate exposure at levels above the
standard include a decrease in ventilatory function, aggravation of asthmatic symptoms and an
increased risk of cardio-pulmonary disease. Sulfates are particularly effective in degrading
visibility, and due to fact that they are usually acidic, can harm ecosystems and damage materials
and property.
Hydrogen Sulfide. H2S is a colorless gas with the odor of rotten eggs. It is formed during
bacterial decomposition of sulfur-containing organic substances. Also, it can be present in sewer
gas and some natural gas, and can be emitted as the result of geothermal energy exploitation.
Breathing H2S at levels above the standard would result in exposure to a very disagreeable odor.
In 1984, an ARB committee concluded that the ambient standard for H2S is adequate to protect
public health and to significantly reduce odor annoyance.
Vinyl Chloride. Vinyl chloride, a chlorinated hydrocarbon, is a colorless gas with a mild, sweet
odor. Most vinyl chloride is used to make polyvinyl chloride (PVC) plastic and vinyl products.
Vinyl chloride has been detected near landfills, sewage plants and hazardous waste sites, due to
microbial breakdown of chlorinated solvents. Short-term exposure to high levels of vinyl
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chloride in air causes central nervous system effects, such as dizziness, drowsiness and
headaches. Long-term exposure to vinyl chloride through inhalation and oral exposure causes
liver damage. Cancer is a major concem from exposure to vinyl chloride via inhalation. Vinyl
chloride exposure has been shown to increase the risk of angiosarcoma, a rare form of liver
cancer, in humans.
Visibility Reducing Particles. Visibility-reducing particles consist of suspended particulate
matter, which is a complex mixture of tiny particles that consists of dry solid fragments, solid
cores with liquid coatings, and small droplets of liquid. These particles vary greatly in shape, size
and chemical composition, and can be made up of many different materials such as metals, soot,
soil, dust, and salt. The CAAQS is intended to limit the frequency and severity of visibility
impairment due to regional haze. A separate standard for visibility-reducing particles that is
applicable only in the Lake Tahoe Air Basin is based on reduction in scenic quality.
Table 1 presents a summary of the ambient air quality standards adopted by the federal and
Califomia Clean Air Acts.
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Table 1
Ambient Air Quality Standards
POLLUTANT AVERAGE
TIME
CALIFORNIA STANDARDS NATIONAL STANDARDS
POLLUTANT AVERAGE
TIME Concentration Method Primary Secondary Method
Ozone
(O3)
1 hour 0.09 ppm
(176 Mg/m') Ultraviolet
Photometry
~ ~ Ethylene
Chemiluminescence
Ozone
(O3) 8 hour 0.070 ppm
(137 Mg/m')
Ultraviolet
Photometry 0.075 ppm
(147 ug/m')
0.075 ppm
(147uK/m')
Ethylene
Chemiluminescence
Carbon
Monoxide
(CO)
8 hours 9.0 ppm
(10 mg/m')
Non-Dispersive
Infrared
Spectroscopy
(NDIR)
9 ppm
(10 mg/m')
Non-Dispersive
Infrared
Spectroscopy
(NDIR)
Carbon
Monoxide
(CO) 1 hour 20 ppm
(23 mg/m')
Non-Dispersive
Infrared
Spectroscopy
(NDIR)
35 ppm
(40 mg/m')
Non-Dispersive
Infrared
Spectroscopy
(NDIR)
Nitrogen
Dioxide
(NO2)
Annual
Average
0.030 ppm
(56 ug/m') Gas Phase
Chemiluminescence
0.053 ppm
(100 ug/m') ~ Gas Phase
Chemiluminescence
Nitrogen
Dioxide
(NO2) 1 hour 0.18 ppm
(338 ug/m')
Gas Phase
Chemiluminescence 0.100 ppm
(188 ug/m') ~
Gas Phase
Chemiluminescence
Sulfur Dioxide
(SO2)
24 hours 0.04 ppm
(105 ug/m')
Ultraviolet
Fluorescence
~ -
Pararosaniline Sulfur Dioxide
(SO2) 3 hours — Ultraviolet
Fluorescence -0.5 ppm
(1300 ug/m') Pararosaniline Sulfur Dioxide
(SO2)
1 hour 0.25 ppm
(655 ug/m')
Ultraviolet
Fluorescence
75 ppb
(196 ug/m') ~
Pararosaniline
Respirable
Particulate
Matter
(PMio)
24 hours 50 ug/m'
Gravimetric or Beta
Attenuation
150 ug/m' 150 ug/m' Inertial Separation and
Gravimetric Analysis
Respirable
Particulate
Matter
(PMio) Annual
Arithmetic
Mean
20 ug/m'
Gravimetric or Beta
Attenuation
--
Inertial Separation and
Gravimetric Analysis
Fine
Particulate
Matter
(PMjs)
Annual
Arithmetic
Mean
12 ug/m' Gravimetric or Beta
Attenuation
15 ug/m^ ~
Inertial Separation and
Gravimetric Analysis
Fine
Particulate
Matter
(PMjs) 24 hours ~
Gravimetric or Beta
Attenuation
35 ug/m' ~
Inertial Separation and
Gravimetric Analysis
Sulfates 24 hours 25 ug/m' Ion Chromatography -~ -
Lead
30-day
Average 1.5 ug/m'
Atomic Absorption
~ ~
Atomic Absorption Lead
Calendar
Quarter ~ Atomic Absorption 1.5 ug/m' 1.5 ug/m' Atomic Absorption Lead
3-Month
Rolling
Average
~
Atomic Absorption
0.15 ug/m' 0.15 ug/m'
Atomic Absorption
Hydrogen Sulfide 1 hour 0.03 ppm
(42 ug/m')
Ultraviolet
Fluorescence -~ -
Vinyl Chloride 24 hours 0.010 ppm
(26 ug/m') Gas Chromatography ~ ~ ~
ppm= parts per million; ug/m' = micrograms per cubic meter; mg/m'= milligrams per cubic meter
Source: Califomia Air Resources Board, www.arb ca.gov. 2012, http;//www.arb.ca.gov/research/aaqs/aaqs2.pdf
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Toxic Air Contaminants. In 1983, the Califomia Legislature enacted a program to identify the
health effects of Toxic Air Contaminants (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.
The State of Califomia has identified diesel particulate matter as a TAC. Diesel particulate
matter is emitted from on- and off-road vehicles that utilize diesel as fuel. Following
identification of diesel particulate matter as a TAC in 1998, the ARB has worked on developing
strategies and regulations aimed at reducing the emissions and associated risk from diesel
particulate matter. The overall strategy for achieving these reductions is found in the Risk
Reduction Plan to Reduce Particulate Matter from Diesel-Fueled Engines and Vehicles (State of
California 2000). A stated goal of the plan is to reduce the cancer risk statewide arising from
exposure to diesel particulate matter by 75 percent by 2010 and by 85 percent by 2020. As an
ongoing process, the ARB reviews air contaminants and identifies those that are classified as
TACs. The ARB also continues to establish new programs and regulations for the control of
TACs, including diesel particulate matter, as appropriate.
Air Quality Implementation Plans. The local air pollution control district (APCD) has the
primary responsibility for the development and implementation of rules and regulations designed
to attain the NAAQS and CAAQS, as well as the permitting of new or modified sources,
development of air quality management plans, and adoption and enforcement of air pollution
regulations. The San Diego APCD is the local agency responsible for the administration and
enforcement of air quality regulations in San Diego County.
The APCD and the San Diego Association of Govemments (SANDAG) are responsible for
developing and implementing the clean air plan for attainment and maintenance of the ambient
air quality standards in the SDAB. The San Diego County Regional Air Quality Strategy
(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 2009 (APCD 2009). The RAQS
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outlines APCD's plans and control measures designed to attain the state air quality standards for
O3. The RAQS does not address the state air quality standards for PMio or PM2 5. The APCD
has also developed the air basin's input to the State Implementation Plan (SIP), which is required
under the Federal Clean Air Act for areas that are out of attainment of air quality standards. The
SIP includes the APCD's plans and control measures for attaining the O3 NAAQS. The SIP is
also updated on a triennial basis. The latest SIP update was submitted by the ARB to the EPA in
1998, and the APCD is in the process of updating its SIP to reflect the new 8-hour O3 NAAQS.
To that end, the APCD has developed its Eight-Hour Ozone Attainment Plan for San Diego
County (hereinafter referred to as the Attainment Plan) (APCD 2007). The Attainment Plan
forms the basis for the SIP update, as it contains documentation on emission inventories and
trends, the APCD's emission control strategy, and an attainment demonstration that shows that
the SDAB will meet the NAAQS for O3. Emission inventories, projections, and trends in the
Attainment Plan are based on the latest O3 SIP planning emission projections compiled and
maintained by ARB. Supporting data were developed jointiy by stakeholder agencies, including
ARB, the APCD, the South Coast Air Quality Management District (SCAQMD), the Southern
California Association of Governments (SCAG), and SANDAG. Each agency plays a role in
collecting and reviewing data as necessary to generate comprehensive emission inventories. The
supporting data include socio-economic projections, industrial and travel activity levels,
emission factors, and emission speciation profiles. These projections are based on data
submitted by stakeholder agencies including projections in municipal General Plans.
The ARB compiles annual statewide emission inventories in its emission-related information
database, the Califomia Emission Inventory Development and Reporting System (CEIDARS).
Emission projections for past and future years were generated using the Califomia Emission
Forecasting System (CEFS), developed by ARB to project emission trends and track progress
towards meeting emission reduction goals and mandates. CEFS utilizes the most current growth
and emissions control data available and agreed upon by the stakeholder agencies to provide
comprehensive projections of anthropogenic (human activity-related) emissions for any year
from 1975 through 2030. Local air districts are responsible for compiling emissions data for all
point sources and many stationary area-wide sources. For mobile sources, CEFS integrates
emission estimates from ARB's EMFAC2007 and OFFROAD models. SCAG and SANDAG
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incorporate data regarding highway and transit projects into their Travel Demand Models for
estimating and projecting vehicle miles traveled (VMT) and speed. The ARB's on-road
emissions inventory in EMFAC2007 relies on these VMT and speed estimates. To complete the
inventory, estimates of biogenic (naturally occurring) emissions are developed by ARB using the
Biogenic Emissions Inventory Geographic Information System (BEIGIS) model.
Because the ARB 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 as part of the development of General Plans, projects that propose development that is
consistent with the growth anticipated by the general plans would be consistent with the RAQS
and the Attainment Plan. 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 and the Attainment Plan. 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.
2.1.3 Local Regulations
In San Diego County, the SDAPCD is the regulatory agency that is responsible for maintaining
air quality, including implementation and enforcement of state and federal regulations. The
project site is located in the City of Carlsbad. The City of Carlsbad has not adopted specific
regulations to govern air quality. The Open Space and Conservation Element of the City's
General Plan (City of Carlsbad 2006) includes policies that ensure the City's continuing support
and coordination with local, state, and federal agencies to improve the air quality within the
region.
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2.2 Climate and Meteoroloav
The project site 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. The
high pressure cell also creates two types of temperature inversions that may act to degrade local
air quality. Figure 2 provides a graphic representation of the prevailing winds in the project
vicinity, as measured al MCAS Miramar. which is the closest meteorological monitoring station
to the site, and provides general wind trends in the Couniy.
Subsidence inversions occur during the warmer months as descending air associated wilh the
Pacific high pressure cell comes into conlact with cool marine air. The boundary between Ihc
two layers of air creates a temperature inversion that traps pollutants. The other type of
inversion, a radiation inversion, develops on winter nights when air near the ground cools by
heat radiation and air aloft remains warm. The shallow inversion layer formed between these
two air masses also can Irap pollutants. As the pollutants become more concentrated in thc
atmosphere, photochemical reactions occur lhat produce ozone, commonly known as smog.
Windrose -mir95.asc
I I Calm hours
r~] <1.54mfe
I 1.54 - 3.09 m/s
CI] 3.09-5:14 m/s
[O. 5.14-8 23 m/s
O823.io.eo..
f~1 - 10 80 m/s
Figure 2. Wind Rose, MCAS Miramar
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2.3 Background Air Qualitv
The APCD operates a network of ambient air monitoring stations throughout San Diego County.
The purpose of the monitoring stations is to measure ambient concentrations of the pollutants
and determine whether the ambient air quality meets the CAAQS and the NAAQS. The nearest
ambient monitoring station to the project site is the Camp Pendleton monitoring station, which
measures O3, NO2, and PM2,5. The closest monitoring station to the project site that measures
PMio and CO is the Escondido monitoring site. The data from Escondido provide a conservative
estimate of background concentrations, because Escondido is located inland of Carlsbad and is
subject to pollutant transport and higher traffic congestion and other sources not present at the
project site. SO2 is not considered a pollutant of concern within the San Diego Air Basin and is
not monitored in the northem half of the County. Ambient concentrations of pollutants over the
last five years are presented in Table 2.
The Kearny Mesa monitoring station measured exceedances of the state 1 -hour ozone standard
and the state and federal 8-hour ozone standards in the period from 2009 through 2011. The
NAAQS was exceeded once in 2009 and once in 2011; the 8-hour CAAQS was exceeded three
times each year. The annual CAAQS for PMio was exceeded in 2009 and 2011. The data from
the monitoring station indicates that air quality is in attainment of all other air quality standards.
Table 2
Ambient Background Concentratic
(ppm unless otherwise indicated'
tns
Pollutant Averaging
Time
2009 2010 2011 CAAQS NAAQS Monitoring Station
Ozone 8 hour 0.076 0.078 0.071 0.070 0.075 Camp Pendleton
1 hour 0.090 0.092 0.085 0.09 -Camp Pendleton
PM,„ Annual 24.6 21.0 18.8 20 ug/m' ~ Escondido
24 hour 74 43 40 50 ug/m' 150 ug/m' Escondido
PM2,5 Annual 11.0 10.5 10.3 12 ug/m' 15 pg/m' Camp Pendleton
24 hour 29.5 27.3 27.4 ~ 35 ug/m' Camp Pendleton
NO2 Annual 0.010 0.008 0.007 0.030 0.053 Camp Pendleton
1 hour 0.068 0.081 0.066 0.18 0.100 Camp Pendleton
CO 8 hour 3.4 2.5 2.3 9.0 9 Escondido
1 hour 4.4 3.9 3.5 20.0 35 Escondido
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3.0 Thresholds of Significance
The State of Califomia has developed guidelines to address the significance of air quality
impacts based on Appendix G of the State CEQA Guidelines which provides guidance that a
project would have a significant environmental impact if it would:
1. Conflict or obstruct the implementation of the San Diego Regional Air Quality Strategy
(RAQS) or applicable portions of the State Implementation Plan (SIP);
2. Resuh in emissions that would violate any air quality standard or contribute substantially
to an existing or projected air quality violation;
3. Resuh in a cumulatively considerable net increase of PM|o or exceed quantitative
thresholds for O3 precursors, oxides of nitrogen (NOx) and volatile organic compounds
(VOCs);
4. Expose sensitive receptors (including, but not limited to, schools, hospitals, resident care
facilities, or day-care centers) to substantial pollutant concentrations; or
5. Create objectionable odors affecting a substantial number of people.
To determine whether a project would (a) result in emissions that would violate any air quality
standard or contribute substantially to an existing or projected air quality violation; or (b) result
in a cumulatively considerable net increase of PMio or exceed quantitative thresholds for O3
precursors, oxides of nitrogen (NOx) and volatile organic compounds (VOCs), project emissions
may be evaluated based on the quantitative emission thresholds established by the San Diego
APCD. As part of its air quality permitting process, the APCD has established thresholds in
Rule 20.2 for the preparation of Air Quality Impact Assessments (AQIA).
For CEQA purposes, these screening criteria can be used as numeric methods to demonstrate that
a project's total emissions would not result in a significant impact to air quality. Since APCD
does not have AQIA thresholds for emissions of VOCs, the use of the threshold for VOCs from
the City of San Diego's Significance Thresholds (City of San Diego 2007) is appropriate. The
screening thresholds are included in the table below.
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Table 3
SCREENING-LEVEL CRITERIA FOR AIR QUALITY IMPACTS
Pollutant Total Emissions
ConstTMCtiop Enaissions
Lb. per Day
Respirable Particulate Matter (PMio) 100
Fine Particulate Matter (PM2 5) 100
Oxides of Nitrogen (NOx) 250
Oxides of Sulfur (SOx) 250
Carbon Monoxide (CO) 550
Volatile Organic Compounds
(VOCs)'
137
Operational Emissions
Lb. Per Hour Lb. per Day Tons per Year
Respirable Particulate Matter (PMio) — 100 15
Fine Particulate Matter (PM2 5) — 100 15
Oxides of Nitrogen (NOx) 25 250 40
Oxides of Sulfur (SOx) 25 250 40
Carbon Monoxide (CO) 100 550 100
Lead and Lead Compounds ... 3.2 0.6
Volatile Organic Compounds (VOC)^ — 137 15
The thresholds listed in Table 3 represent screening-level thresholds that can be used to evaluate
whether project-related emissions could cause a significant impact on air quality. Emissions
below the screening-level thresholds would not cause a significant impact. In the event that
emissions exceed these thresholds, modeling would be required to demonstrate that the project's
total air quality impacts result in ground-level concentrations that are below the State and Federal
Ambient Air Quality Standards, including appropriate background levels. For nonattainment
pollutants (ozone, with ozone precursors NOx and VOCs, and PMio), if emissions exceed the
thresholds shown in Table 3, the project could have the potential to result in a cumulatively
considerable net increase in these pollutants and thus could have a significant impact on the
ambient air quality.
In addition to impacts from criteria pollutants, project impacts may include emissions of
pollutants identified by the state and federal government as toxic air contaminants (TACs) or
Hazardous Air Pollutants (HAPs). In San Diego County, APCD Regulation XII establishes
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acceptable risk levels and emission control requirements for new and modified facilities that may
emit additional TACs. Under Rule 1210, emissions of TACs that result in a cancer risk of
10 in 1 million or less and a health hazard index of one or less would not be required to notify
the public of potential health risks. If a project has the potential to result in emissions of any
TAC or HAP which result in a cancer risk of greater than 10 in 1 million, the project would be
deemed to have a potentially significant impact.
With regard to evaluating whether a project would have a significant impact on sensitive
receptors, air quality regulators typically define sensitive receptors as schools (Preschool-12"^
Grade), hospitals, resident care facilities, or day-care centers, or other facilities that may house
individuals with health conditions that would be adversely impacted by changes in air quality.
Any project which has the potential to directly impact a sensitive receptor located within 1 mile
and results in a health risk greater than 10 in 1 million would be deemed to have a potentially
significant impact.
APCD Rule 51 (Public Nuisance) also prohibits emission of any material which causes nuisance
to a considerable number of persons or endangers the comfort, health or safety of any person. A
project that proposes a use which would produce objectionable odors would be deemed to have a
significant odor impact if it would affect a considerable number of offsite receptors.
The impacts associated with construction and operation of the project were evaluated for
significance based on these significance criteria.
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4.0 Impacts
The La Costa Towne Center Renovation and Expansion Project would result in both construction
and operational impacts. Construction impacts include emissions associated with the
renovations, demolition of existing structures, and construction new structures, multi-family
units, and paving/landscaping improvements. Operational impacts include emissions associated
with the project, including traffic, at full buildout.
4.1 Consistencv with the RAQS and SIP
The Proposed Project would have a significant impact if it conflicts with or obstructs
implementation of the applicable air quaiity plans (the RAQS and SIP).
As discussed in Section 2.1, the SIP is the document that sets forth the state's strategies for
attaining and maintaining the NAAQS. The APCD is responsible for developing the San Diego
portion of the SIP, and has developed an attainment plan for attaining the 8-hour NAAQS for O3.
The RAQS sets forth the plans and programs designed to meet the state air quality standards.
Through the RAQS and SIP planning processes, the APCD adopts rules, regulations, and
programs designed to achieve attainment of the ambient air quality standards and maintain air
quality in the SDAB.
Conformance with the RAQS and SIP determines whether a Project will conflict with or obstruct
implementation of the applicable air quality plans. The basis for the RAQS and SIP is the
distribution of population in the San Diego region as projected by SANDAG. Growth
forecasting is based in part on the land uses established by the General Plan.
The Project would create more flexibility for the retail portion of the site and allow an anchor
tenant that will serve the daily needs and convenience of the local neighborhood. Furthermore,
the Project will include multi-family residential uses at the site, which meets the goals of the
RAQS and SIP in creating mixed-use developments that reduce vehicle trips.
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The RAQS and SIP address air emissions and impacts from industrial sources, area-wide
sources, and mobile sources. The programs also consider transportation control measures and
indirect source review. Industrial sources are typically stationary air pollution sources that are
subject to APCD rules and regulations, and over which the APCD has regulatory authority.
Area-wide sources include sources such as consumer products use, small utility engines, hot
water heaters, and furnaces. Both the ARB and the APCD have authority to regulate these
sources and have developed plans and programs to reduce emissions from certain types of area-
wide sources. Mobile sources are principally emissions from motor vehicles. The ARB
establishes emission standards for motor vehicles and establishes regulations for other mobile
source activities including off-road vehicles.
Both the RAQS and SIP address emissions of ozone precursors (ROG and NOx), as the SDAB is
classified as a basic nonattainment area for the NAAQS and a nonattainment area for the
CAAQS. The RAQS and SIP do not address particulate matter. The California CAA requires an
air quality strategy to achieve a 5% average annual ozone precursor emission reduction when
implemented or, if that is not achievable, an expeditious schedule for adopting every feasible
emission control measure under air district purview (California Health and Safety Code (H&SC)
Section 40914). The current RAQS represents an expeditious schedule for adopting feasible
control measures, since neither San Diego nor any air district in the State has demonstrated
sustained 5% average annual ozone precursor reductions.
Most of the control measures adopted in the RAQS apply to industrial sources and specific
source categories. There are no specific rules and regulations that apply to construction or
operational sources associated with the Project; however, off-road equipment and on-road
vehicles involved in construction would be required to comply with ARB emission standards.
In 1992 SANDAG adopted Transportation Control Measures for the Air Quality Plan which set
forth 11 tactics aimed at reducing traffic congestion and motor vehicle emissions within the
SDAB. For each of these tactics, the Transportation Control Measures evaluated the potential
emissions reductions on a region-wide basis. The tactics include the following:
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Commute travel reduction program
High school, college, and university travel reduction program
Goods movement/truck operation program
Non-commute travel reduction program
Transit improvements and expansion
Vanpool program
High occupancy vehicle lanes
Park and ride facilities
Bicycle facilities
Traffic flow improvements
Indirect source control program
The tactic that is most applicable to the proposed Project is the indirect source control program.
The Transportation Control Measures adopted by SANDAG identified job-housing balance,
mixed use, and transit corridor development as criteria for indirect source control. As part of
job-housing balance, SANDAG indicated that land use policies and programs shall be
established to attract appropriate employers to residential areas and to encourage appropriate
housing in and near industrial and business areas. Mixed use development should be designed to
maximize walking and minimize vehicle use by providing housing, employment, education,
shopping, recreation and any support facilities within convenient proximity.
The La Costa Towne Center Project meets the criteria of the RAQS, SIP, and SANDAG's
Transportation Control Measures as it provides a mix of housing and commercial at the site. The
project has been designed to meet mixed use designation, which will allow pedestrian access to
office and retail space. Accordingly the proposed Project is consistent with the applicable air
quality plans, and would not result in a significant impact.
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4.2 Violation of an Air Qualitv Standard
The Proposed Project would have a significant impact if it violates any air quality standard
or contributes substantially to an existing or projected air quality vioiation.
To address this significance threshold, an evaluation of emissions associated with both the
construction and operational phases of the Project was conducted.
4.2.1 Construction Impacts
Emissions of pollutants such as fugitive dust and heavy equipment exhaust that are generated
during construction are generally highest near the construction site. Emissions from the
construction of the project were estimated using the CalEEMod Model (ENVIRON 2013).
The project is proposed to be constructed in four phases. The proposed development phases are
as follows:
Phase 1 Development (South Buildings Renovation): Existing Buildings 7760 and 7770 are to
be renovated and updated. Work will include a minor building addition to the 7760 Building, the
addition of an accessible path of travel from Building 7770, across 7760 and the entry drive to a
sidewalk connection to El Camino Real. Nominal landscape and hardscape improvements are
also proposed at Building 7760. Phase 1 is anticipated to commence construction in December
2012 and be completed in the spring of 2013.
Phase 2 Development (Shop Building Removal): The single story 7740 Building is to be
demolished and the existing parking lot extended out to El Camino Real. Phase 2 building
demolition is anticipated to commence in spring 2013.
Phase 3 Development (Site and Shop Buildings Enhancements): Existing Buildings 7720
and 7740 exterior will be updated with cosmetic exterior fa9ade work to update the architecture.
New signage will be installed, and the existing parking lot area will be updated. New
landscaping and irrigation to current City standards will be provided. New landscaping,
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hardscape, and paving areas will be graded, including a new expanded and enhanced pedestrian
plaza at the 7750 Building. Phase 3 is anticipated to commence in 2013 and be completed by
late summer 2013.
Phase 4 Development (New Mixed Use Buildings and Structured Parking): Phase 4
development anticipates the demolition and reconstruction of the northern third of the center to
provide a new mixed use development. Two new mixed use buildings and a single level parking
garage below grade will be constructed. The construction will include approximately 49,000 sf
of retail space and 60 multi-family residential units. It is anticipated that this phase of the work
will commence in late summer 2013, and be completed in 12 months. This phase will include
5.4 acres of grading and 54,600 cubic yards of export.
The CalEEMod Model provides default assumptions regarding horsepower rating, load factors
for heavy equipment, and hours of operation per day. Default assumptions within the CalEEMod
Model and assumptions for similar projects were used to represent operation of heavy
construction equipment. In addition to calculating emissions from heavy construction
equipment, the CalEEMod Model contains calculation modules to estimate emissions of fugitive
dust, based on the amount of earthmoving or surface disturbance required; emissions from
heavy-duty truck trips or vendor trips during construction activities; emissions from construction
worker vehicles during daily commutes; emissions of ROG from paving using asphalt; and
emissions of ROG during application of architectural coatings. As part of the project design
features, it was assumed that standard dust control measures (watering three times daily; using
soil stabilizers on unpaved roads) and architectural coatings that comply with SDAPCD Rule
67.0 (assumed to meet a VOC content of 100 g/l for interior surfaces and 150 g/1 for exterior
surfaces) would be used during construction.
Tables 4a through 4d provide the detailed emission estimates for each phase of construction as
calculated with the CalEEMod Model for each of the construction phases of the project.
Appendix A provides CalEEMod Model outputs showing the construction calculations. As
shown in the tables, emissions of criteria pollutants during construction would be below the
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thresholds of significance for all project construction phases. Project criteria pollutant emissions
during construction would be temporary. Impacts during construction are less than significant.
Table 4a
Maximum Daily Estimated Construction Emissions - Phase 1
La Costa Towne Center Renovation and Expansion Project
Emission Source VOCs NOx CO SO, PMio PM25
lbs/day
Building Construction
Off Road Diesel 5.02 30.06 18.30 0.03 2.06 1.99
Worker Trips 0.23 0.07 0.67 0.00 0.08 0.02
TOTAL 5.25 30.13 18.97 0.03 2.14 2.01
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No No No No
Paving
Asphalt Offgassing 0.00 -----
Off Road Diesel 2.09 19.26 11.55 0.01 1.47 1.36
Worker Trips 0.28 0.08 0.78 0.00 0.18 0.01
TOTAL 2.37 19.34 12.33 0.01 1.65 1.37
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No No No No
Architectural Coatings
Off Road Diesel 0.49 2.96 1.94 0.00 0.27 0.27
Architectural
Coatings Emissions 0.08
Worker Trips 0.11 0.03 0.30 0.00 0.04 0.01
TOTAL 0.68 2.99 2.24 0.00 0.31 0.28
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No No
Maximum Daily
Emissions — Phase
1' 10.15 59.19 37.56 0.05 4.18 3.91
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No No No No
Maximum emissions occur during building construction.
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Table 4b
Maximum Daily Estimated Construction Emissions - Phase 2
La Costa Towne Center Renovation and Expansion Project
Emission Source VOCs NOx CO SO, PM,„ PM25
lbs/day
Demolition
Fugitive Dust ----0.27 0.04
Off Road Diesel 1.86 16.02 11.06 0.01 1.16 1.11
On Road Diesel 0.26 1.36 0.87 0.00 0.09 0.05
Worker Trips 0.17 0.06 0.61 0.00 0.08 0.02
TOTAL 2.29 17.44 12.54 0.01 1.60 1.22
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No A^o No A^o No
Grading
Fugitive Dust ----0.30 0.16
Off Road Diesel 1.86 16.02 11.06 0.01 1.16 1.11
Worker Trips 0.17 0.06 0.61 0.00 0.08 0.02
TOTAL 2.03 16.08 11.67 0.01 1.54 1.29
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No iVo No No No No
Paving
Off Road Diesel 1.71 15.25 9.40 0.01 1.14 1.05
Worker Trips 0.31 0.10 1.10 0.00 0.15 0.04
TOTAL 2.02 15.35 10.50 0.01 1.29 1.09
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No A^o No
Maximum Daily
Emissions - Phase
2' 2.30 17.43 12.54 0.02 1.60 1.29
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No No No
Maximum emissions for VOCs occur during paving; maximum emissions for NOx, CO, SOx, and PMio occur during demolition; maximum
emissions for PM2 s occur during grading.
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Table 4c
Maximum Daily Estimated Construction Emissions - Phase 3
La Costa Towne Center Renovation and Expansion Project
Emission Source VOCs NOx CO SO, PMio PM2.5
lbs/day
Building Construction
Off Road Diesel 1.58 17.16 8.65 0.01 1.00 0.92
Vendor Trips 0.16 0.72 0.76 0.00 0.05 0.03
Worker Trips 0.17 0.06 0.61 0.00 0.08 0.02
TOTAL 1.91 17.94 10.02 0.01 1.13 0.97
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No No No
Paving
Asphalt Offgassing 0.00 -----
Off Road Diesel 1.34 12.19 7.40 0.00 0.94 0.86
Worker Trips 0.09 0.03 0.31 0.00 0.04 0.01
TOTAL 1.43 12.22 7.71 0.00 0.98 0.87
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No A^o iVo No
Architectural Coatings
Off Road Diesel 0.49 2.96 1.94 0.00 0.27 0.27
Architectural
Coatings Emissions 9.55
Worker Trips 0.03 0.01 0.12 0.00 0.02 0.00
TOTAL 10.07 2.97 2.06 0.00 0.29 0.27
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? A^o No No No A^o
Maximum Daily
Emissions - Phase
3' 13.42 33.12 19.80 0.03 2.40 2.12
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No No No No
Maximum emissions occur during simultaneous building construction, paving, and architectural coatings application.
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Table 4d
Maximum Daily Estimated Construction Emissions - Phase 4
La Costa Towne Center Renovation and Expansion Project
Emission Source VOCs NOx CO SO, PM,o PM3.5
lbs/day
Demolition
Fugitive Dust ----0.27 0.04
Off Road Diesel 8.27 91.93 66.73 0.07 4.57 4.25
On Road Diesel 0.27 1.41 0.90 0.00 0.10 0.05
Worker Trips 0.26 0.08 0.92 0.00 0.12 0.03
TOTAL 8.80 93.42 68.55 0.07 5.06 4.37
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No No No No
Mass Grading
Fugitive Dust ----2.47 1.31
Off Road Diesel 6.22 67.32 44.23 0.05 3.74 3.44
On Road Diesel 13.12 68.25 43.68 0.12 4.64 2.52
Worker Trips 0.26 0.08 0.92 0.00 0.12 0.03
TOTAL 19.60 135.65 88.83 0.17 10.97 7.30
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No No A^o No
Building Construction
Off Road Diesel 5.24 46.84 25.78 0.04 2.95 2.77
Vendor Trips 0.64 2.89 3.03 0.00 0.21 0.11
Worker Trips 1.28 0.41 4.54 0.00 0.61 0.17
TOTAL 7.16 50.14 33.35 0.04 3.77 3.05
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? A^o A^o No No A^o No
Paving
Asphalt Offgassing 0.00 -----
Off Road Diesel 3.69 33.93 19.68 0.03 2.59 2.38
Worker Trips 0.26 0.08 0.92 0.00 0.12 0.03
TOTAL 3.95 34.01 20.60 0.03 2.71 2.41
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? A^o No A^o No No No
Architectural Coatings
Off Road Diesel 0.45 2.77 1.92 0.00 0.24 0.24
Architectural
Coatings Emissions 64.27
Worker Trips 0.24 0.08 0.82 0.00 0.12 0.03
TOTAL 64.96 2.85 2.74 0.00 0.36 0.27
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No No No A^o No
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Table 4d
Maximum Daily Estimated Construction Emissions - Phase 4
La Costa Towne Center Renovation and Expansion Project
Emission Source VOCs NOx CO SO, PM,o PM25
lbs/day
Maximum Daily
Emissions - Phase
4' 75.29 229.09 157.38 0.23 16.04 11.67
Significance
Thresholds 137 250 550 250 100 55
Above Thresholds? No No A^o No No A^o
Maximum emissions for VOCs occur during simultaneous building construction, paving, and architectural coatings application; maximum
emissions for all other pollutants occur during simultaneous demolition and mass grading.
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4.4.2 Operational Impacts
Operational impacts associated with the La Costa Towne Center Renovation and Expansion
Project would include impacts associated with vehicular traffic, as well as area sources such as
energy use, consumer products use, and architectural coatings use for maintenance purposes.
The La Costa Towne Center is currently operational, and includes approximately 98,800 sf of
retail uses and 25,580 sf of office uses. According to the Traffic Impact Analysis for the La
Costa Towne Center (Urban Systems Associates 2012), the existing site generates 14,890
average daily trips (ADT). According to the Traffic Impact Analysis, upon buildout, the project
will generate 15,682 ADT for a net increase of 791 ADT.
Table 5 presents a summary of the emissions calculated for the existing conditions and proposed
project. Because the project involves renovation of an existing site, the project's operations will
result in an incremental change in emissions. To address the incremental increase, the
CalEEMod Model was run for both the existing conditions and for the proposed project at
buildout. The incremental change was calculated by subtracting the existing emissions from the
emissions attributable to the proposed project. For existing conditions, the model was run for the
year 2012 (current conditions). It was assumed that the first year of full occupancy would be
2014. Thus the project would result in a decrease in emissions from existing conditions. The
reasons for the decrease are that (a) the CalEEMod Model takes into account decreases in
emissions associated with the County-wide vehicle fleet due to increasingly stringent emission
standards and phase-out of older vehicles; and (b) the project will include a mix of uses and
improved design features that will reduce emissions from vehicles through trip reduction and
from energy use and other area sources through implementation of energy efficiency standards
for the new buildings.
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Table 5
Operational Emissions
ROG NOx CO SO, PM,„ PM„
Existing Site
Summer Day, Lbs/day
Area Sources 3.37 0.00 0.01 0.00 0.00 0.00
Energy Use 0.02 0.20 0.17 0.00 0.02 0.02
Vehicular Emissions 135.81 122.28 593.81 0.81 25.46 8.98
TOTAL 139.20 122.48 594.00 0.81 25.47 9.00
Winter Day, Lbs/day
Area Sources 3.37 0.00 0.01 0.00 0.00 0.00
Energy Use 0.02 0.20 0.17 0.00 0.02 0.02
Vehicular Emissions 160.27 129.93 646.03 0.77 25.48 9.01
TOTAL 163.66 130.14 646.22 0.77 25.50 9.02
Proposed Project
Summer Day, Lbs/day
Area Sources 5.43 0.06 5.08 0.00 0.03 0.03
Energy Use 0.04 0.37 0.24 0.00 0.03 0.03
Vehicular Emissions 113.20 101.87 488.29 0.78 23.61 7.86
TOTAL 118.67 102.30 493.61 0.79 23.67 7.92
Winter Day, Lbs/day
Area Sources 5.43 0.06 5.08 0.00 0.03 0.03
Energy Use 0.04 0.37 0.24 0.00 0.03 0.03
Vehicular Emissions 133.18 108.05 538.40 0.75 23.63 7.88
TOTAL 138.64 108.48 543.72 0.75 23.68 7.93
Proposed Project Net Increase (Decrease)
Net Increase, Summer
Day (20.52) (20.19) (100.38) (0.03) (1.80) (1.08)
Net Increase, Winter
Day (25.01) (21.65) (102.49) (0.03) (1.82) (L09)
Significance Thresholds 137 250 550 250 100 55
Above Thresholds? A^o No No No No No
Based on the estimates of the emissions associated with Project operations, the emissions would
decrease from existing levels, and would be below the significance thresholds.
Projects involving traffic impacts may result in the formation of locally high concentrations of
CO, known as CO "hot spots." To verify that the project would not cause or contribute to a
violation of the CO standard, a screening evaluation of the potential for CO "hot spots" was
conducted. The Caltrans ITS Transportation Project-Level Carbon Monoxide Protocol (Caltrans
1998) were followed to determine whether a CO "hot spof is likely to form due to project-
generated traffic. In accordance with the Protocol, CO "hot spots" are typically evaluated when
(a) the LOS of an intersection or roadway decreases to a LOS E or worse; (b) signalization
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and/or channelization is added to an intersection; and (c) sensitive receptors such as residences,
commercial developments, schools, hospitals, etc. are located in the vicinity of the affected
intersection or roadway segment.
The Traffic Impact Analysis evaluated whether or not there would be a decrease in the level of
service at the intersections affected by the Project. Based on the analysis, no intersections would
experience a degradation in LOS to LOS E or F due to project traffic. Accordingly, the project
would not result in CO "hot spots", and no significant impact would result.
4.3 Cumulatively Considerable Net Increase of Nonattainment Pollutants
The Proposed Project would have a significant impact if it results in a cumulatively
considerable net increase of any criteria pollutant for which the project region is
nonattainment under an applicable federal or state ambient air quality standard (including
releasing emissions which exceed quantitative thresholds for ozone precursors.
As discussed in Section 2.0, the SDAB is considered a nonattainment area for the 8-hour
NAAQS for O3, and is considered a nonattainment area for the CAAQS for O3, PMio, and PM2 5.
An evaluation of emissions of nonattainment pollutants was conducted in Section 4.2, and it was
determined that emissions of all nonattainment pollutants would be below the screening-level
thresholds.
The region surrounding the La Costa Towne Center is already developed; the project provides
infill development. Because the project provides infill development, it would not be anticipated
to increase vehicle trips in the region; rather, the project would serve the needs of providing local
retail to the community. Furthermore, the project would result in a decrease in emissions from
existing conditions. The project would therefore not result in a cumulatively considerable
increase emissions of ozone precursors (NOx and VOCs).
It is unlikely that several projects within the immediate vicinity of the La Costa Towne Center
Project; however, should construction occur simultaneously, standard dust control measures
would ensure that cumulative impacts would not result. Cumulative impacts are less than
significant.
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4.4 Exposure of Sensitive Receptors to Substantial Pollutant Concentrations
The Proposed Project would have a significant impact if it exposes sensitive receptors
(including, but not limited to, schools, hospitals, resident care facilities, parks, or day-care
centers) to substantial pollutant concentrations.
The threshold concems whether the project could expose sensitive receptors to substantial
pollutant concentrations of TACs. If a project has the potential to result in emissions of any
TAC which result in a cancer risk of greater than 10 in 1 million or substantial non-cancer risk,
the project would be deemed to have a potentially significant impact.
Air quality regulators typically define sensitive receptors as schools (Preschool-12* Grade),
hospitals, resident care facilities, or day-care centers, or other facilities that may house
individuals with health conditions that would be adversely impacted by changes in air quality.
Residential land uses may also be considered sensitive receptors. The nearest sensitive receptors
to the site are the residents located to the east of the project site, approximately 0.1 miles from
the project.
Emissions of TACs are attributable to temporary emissions from construction emissions, and
minor emissions associated with diesel truck traffic used for deliveries at the site. Truck traffic
may result in emissions of diesel particulate matter, which is characterized by the State of
California as a toxic air contaminant (TAC). Certain types of projects are recommended to be
evaluated for impacts associated with TACs. In accordance with the SCAQMD's "Health Risk
Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions
for CEQA Air Quality Analysis" (SCAQMD 2003), projects that should be evaluated for diesel
particulate emissions include truck stops, distribution centers, warehouses, and transit centers
which diesel vehicles would utilize and which would be sources of diesel particulate matter from
heavy-duty diesel trucks. A mixed-use project such as the La Costa Towne Center Project would
not attract a disproportionate amount of diesel trucks and would not be considered a source of
TAC emissions. Based on the CalEEMod Model, heavy-duty diesel trucks would account for
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only 0.9 percent of the total trips associated with the project. Impacts to sensitive receptors from
TAC emissions would therefore be less than significant.
4.5 Objectionable Odors
The Proposed Project would have a significant impact if it creates objectionable odors
affecting a substantial number of people.
Project construction could result in minor amounts of odor compounds associated with diesel
heavy equipment exhaust. These compounds would be emitted in various amounts and at
various locations during construction. Sensitive receptors located in the vicinity of the
construction site include the residences to the east of the site. Odors are highest near the source
and would quickly dissipate offsite; any odors associated with construction would be temporary.
The Project is a mixed-use development and would not include land uses that would be sources
of nuisance odors. Thus the potential for odor impacts associated with the project is less than
significant
5.0 Conclusions
As discussed in Section 4.0, impacts are less than significant. Standard dust control measures
will be employed during construction, as discussed in the City of Carlsbad General Plan. These
standard dust control measures include the following:
Control fugitive dust by regular watering, paving construction roads, or other dust
preventive measures;
Maintain equipment engines in proper tune;
Seed and water until vegetation cover is grown;
Spread soil binders;
Wet the area down, sufficient enough to form a crust on the surface with repeated
soakings, as necessary, to maintain the crust and prevent dust pick-up by the wind;
Street sweeping, should silt be carried over to adjacent public thoroughfares;
Use water trucks or sprinkler systems to keep all areas where vehicles move damp
enough to prevent dust raised when leaving the site;
Wet down areas in the late morning and after work is completed for the day;
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• Use of low sulphur fuel (0.5% by weight) for construction equipment.
These dust control measures will reduce the amount of fugitive dust generated during
construction. In addition to dust control measures, architectural coatings applied to interior and
exterior surfaces will be required to meet the ROG limitations of SDAPCD Rule 67.0, which
limits the ROG content of most coatings to 100 grams/liter.
In summary, the proposed project would result in emissions of air pollutants for both the
construction phase and operational phase of the project. The air quality impact analysis
evaluated the potential for adverse impacts to the ambient air quality due to construction and
operational emissions. Construction emissions would include emissions associated with fugitive
dust, heavy construction equipment and construction worker commuting to and from the site.
The project would employ dust control measures such as watering to control emissions during
construction and use of low-ROG paints. Emissions are less than the significance thresholds for
all pollutants during construction.
Operational emissions would include emissions associated with office and retail operations,
including area sources, energy use, and vehicle traffic. As discussed in Section 4.0, the impacts
would be below the significance thresholds for all pollutants. Impacts from project-related
traffic were evaluated to assess whether the project could result in CO "hot spots" due to project-
related traffic. Impacts are less than significant.
Emissions of TACs or odors would not result in a significant impact to the project, and project
emissions of TACs and odors would be less than significant.
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