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County of San Joaquin - KRC Mine Expansion Final EIR

Michael Brandman Associates H:\Client (PN-JN)\1478\14780009\9 - Final EIR\14780009_Sec99-00 Appendix Dividers.doc

Appendix C: Air Quality Reports and Output



C.1 - Air Pollutant Emissions Methodology, Calculations, and Output

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Page: 1

File Name: C:\Documents and Settings\mba\Desktop\KRC Baseline\KRC OffRoad Activity.urb924

Project Name: KRC Off-Road Analysis 2009 Baseline

Project Location: San Joaquin Valley APCD

On-Road Vehicle Emissions Based on: Version : Emfac2007 V2.3 Nov 1 2006

Off-Road Vehicle Emissions Based on: OFFROAD2007

Combined Annual Emissions Reports (Tons/Year)

Urbemis 2007 Version 9.2.4

Construction Unmitigated Detail Report:

CONSTRUCTION EMISSION ESTIMATES Annual Tons Per Year, Unmitigated

ROG NOx CO SO2 PM10 Dust PM10 Exhaust PM10 PM2.5 Dust PM2.5 Exhaust PM2.5 CO2

2009 TOTALS (tons/year mitigated) 0.50 4.70 1.72 0.00 0.00 0.18 0.18 0.00 0.17 0.17 513.09

Percent Reduction 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

2009 TOTALS (tons/year unmitigated) 0.50 4.70 1.72 0.00 0.00 0.18 0.18 0.00 0.17 0.17 513.09

ROG NOx CO SO2 PM10 Dust PM10 Exhaust PM10 PM2.5 Dust PM2.5 Exhaust

PM2.5 CO2

CONSTRUCTION EMISSION ESTIMATES

Summary Report:

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Page: 2

4.6 Excavators (454 hp) operating at a 0.57 load factor for 8 hours per day

1.2 Crawler Tractors (460 hp) operating at a 0.64 load factor for 8 hours per day

Off-Road Equipment:

4.6 Water Trucks (200 hp) operating at a 0.5 load factor for 8 hours per day

27.6 Off Highway Trucks (400 hp) operating at a 0.57 load factor for 8 hours per day

4.6 Graders (150 hp) operating at a 0.61 load factor for 8 hours per day

Total Acres Disturbed: 0

Phase: Mass Grading 8/1/2009 - 8/28/2009 - Aggregate Extraction

On Road Truck Travel (VMT): 0

20 lbs per acre-day

Fugitive Dust Level of Detail: Default

Maximum Daily Acreage Disturbed: 0

Phase Assumptions

2009 0.50 4.70 1.72 0.00 0.18 0.17 513.090.00 0.18 0.00 0.17

0.18Mass Grading 08/01/2009-08/28/2009

0.50 4.70 1.72 0.00 0.17 513.090.00 0.18 0.00 0.17

Mass Grading On Road Diesel 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Mass Grading Worker Trips 0.00 0.01 0.13 0.00 0.00 0.00 0.00 0.00 0.00 0.00 10.89

Mass Grading Dust 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Mass Grading Off Road Diesel 0.50 4.70 1.59 0.00 0.00 0.18 0.18 0.00 0.17 0.17 502.20

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Page: 3

Construction Mitigated Detail Report:

CONSTRUCTION EMISSION ESTIMATES Annual Tons Per Year, Mitigated


2009 0.50 4.70 1.72 0.00 0.18 0.17 513.090.00 0.18 0.00 0.17

0.18Mass Grading 08/01/2009-08/28/2009

0.50 4.70 1.72 0.00 0.17 513.090.00 0.18 0.00 0.17





PM10: 69% PM25: 69%

For Soil Stablizing Measures, the Equipment loading/unloading mitigation reduces emissions by:

PM10: 55% PM25: 55%

For Unpaved Roads Measures, the Manage haul road dust 2x daily watering mitigation reduces emissions by:

PM10: 44% PM25: 44%

For Unpaved Roads Measures, the Reduce speed on unpaved roads to less than 15 mph mitigation reduces emissions by:

PM10: 55% PM25: 55%

For Soil Stablizing Measures, the Apply soil stabilizers to inactive areas mitigation reduces emissions by:

The following mitigation measures apply to Phase: Mass Grading 8/1/2009 - 8/28/2009 - Aggregate Extraction

For Soil Stablizing Measures, the Water exposed surfaces 2x daily watering mitigation reduces emissions by:

PM10: 5% PM25: 5%

For Soil Stablizing Measures, the Replace ground cover in disturbed areas quickly mitigation reduces emissions by:

PM10: 84% PM25: 84%

Construction Related Mitigation Measures

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10/1/2010 4:57:18 PM

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File Name: C:\Documents and Settings\mba\Desktop\KRC Baseline\KRC Employee Trip Baseline.urb924

Project Name: KRC Employee Trips - 2009 Baseline






TOTALS (tons/year, unmitigated) 0.06 0.07 0.73 0.00 0.04 0.01 47.64

SUM OF AREA SOURCE AND OPERATIONAL EMISSION ESTIMATES

ROG NOx CO SO2 PM10 PM2.5 CO2


OPERATIONAL (VEHICLE) EMISSION ESTIMATES


Summary Report:

10/1/2010 4:57:18 PM

Page: 2

OPERATIONAL EMISSION ESTIMATES Annual Tons Per Year, Unmitigated

Aggregate Extraction 0.02 0.02 0.18 0.00 0.01 0.00 11.91

Materials Processing Facility 0.04 0.05 0.55 0.00 0.03 0.01 35.73


Source ROG NOX CO SO2 PM10 PM25 CO2

Operational Unmitigated Detail Report:

Light Truck < 3750 lbs 50.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2

Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 50.0 1.4 98.1 0.5

Vehicle Fleet Mix

Vehicle Type Percent Type Non-Catalyst Catalyst Diesel

Aggregate Extraction 10.00 1000 sq ft 1.00 10.00 67.62

Materials Processing Facility 30.00 1000 sq ft 1.00 30.00 202.86

40.00 270.48

Summary of Land Uses

Land Use Type Acreage Trip Rate Unit Type No. Units Total Trips Total VMT

Analysis Year: 2009 Season: Annual

Emfac: Version : Emfac2007 V2.3 Nov 1 2006

Does not include correction for passby trips

Does not include double counting adjustment for internal trips

Operational Settings:

10/1/2010 4:57:18 PM

Page: 3

% of Trips - Residential 32.9 18.0 49.1

Aggregate Extraction 2.0 1.0 97.0

Materials Processing Facility 2.0 1.0 97.0

% of Trips - Commercial (by land use)

Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0

Urban Trip Length (miles) 10.8 7.3 7.5 9.5 7.4 7.4

Rural Trip Length (miles) 16.8 7.1 7.9 14.7 6.6 6.6

Travel Conditions

Home-Work Home-Shop Home-Other Commute Non-Work Customer

Residential Commercial

Other Bus 0.0 0.0 0.0 100.0

Motor Home 0.0 10.0 80.0 10.0

Urban Bus 0.0 0.0 0.0 0.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Lite-Heavy Truck 8501-10,000 lbs 0.0 0.0 75.0 25.0

Heavy-Heavy Truck 33,001-60,000 lbs 0.0 0.0 0.0 100.0

Med-Heavy Truck 14,001-33,000 lbs 0.0 7.7 15.4 76.9

Lite-Heavy Truck 10,001-14,000 lbs 0.0 0.0 44.4 55.6

Vehicle Fleet Mix


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File Name: C:\Documents and Settings\mba\Desktop\KRC Baseline\KRC Onroad Hauling Baseline.urb924

Project Name: KRC On-Road Haul Trucks - 2009 Baseline






TOTALS (tons/year, unmitigated) 1.20 20.05 6.31 0.02 1.25 0.77 2,330.09






Summary Report:

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Page: 2


On-Road Hauling 1.20 20.05 6.31 0.02 1.25 0.77 2,330.09




Light Truck < 3750 lbs 0.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2



Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 0.0 1.4 98.1 0.5

Vehicle Fleet Mix


On-Road Hauling 161.80 1000 sq ft 1.00 161.80 3,171.28

161.80 3,171.28








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Page: 3


Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0


On-Road Hauling 0.0 0.0 100.0



Travel Conditions



Urban Bus 0.0 0.0 0.0 0.0

Motor Home 0.0 10.0 80.0 10.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Other Bus 0.0 0.0 0.0 100.0



Vehicle Fleet Mix


Air Pollutant Emissions Methodology, Calculations,and Output

County of San Joaquin - KRC Mine ExpansionAir Pollutant Emissions Methodology, Calculations, and Output Table of Contents

Michael Brandman Associates iiH:\Client PN-JN\1478-San Joaquin County\14780009_SJ_County-KRC_Aggregates\Air Quality-CC\C-1 Emissions Calculation Methodology.doc

Table of Contents

Section 1: Introduction .......................................................................................................11.1 - Analysis Tools ...................................................................................................11.2 - Considerations...................................................................................................11.3 - Regulatory Compliance .....................................................................................2

1.3.1 - SJVAPCD Regulation VIII ...................................................................21.3.2 - ARB’s Off-Road Rule ..........................................................................2

Section 2: Off-Road Activity Methodology ........................................................................32.1 - Resource Management Area Phasing ...............................................................32.2 - Haul Road Reclamation.....................................................................................62.3 - Construction Equipment and Hours ...................................................................62.4 - Dust Generation ..............................................................................................10

Section 3: On-Road Activity Methodology ......................................................................123.1 - Employee Trips................................................................................................123.2 - On-Road Hauling.............................................................................................12

Section 4: Baseline Development ....................................................................................154.1 - Off-Road Activity..............................................................................................154.2 - Employee Trips................................................................................................164.3 - On-Road Hauling.............................................................................................16

Section 5: Emissions Calculations ..................................................................................175.1 - Baseline Emissions..........................................................................................175.2 - Annual Construction Emissions .......................................................................175.3 - Annual Operational Emissions.........................................................................185.4 - Total Annual Emissions ...................................................................................19

List of Tables

Table 1: Mining Phases, RMAs, and Extraction Volumes ......................................................4

Table 2: Estimated Material Volume per Acre........................................................................4

Table 3: Mining and Mine Land Reclamation Schedule (Acres/Year) ....................................5

Table 4: Estimated RMA Activity by Year ..............................................................................6

Table 5: Construction Equipment and Average Activity .........................................................7

Table 6: Estimated Equipment Hours by Year .......................................................................8

Table 7: Adjusted Equipment Numbers for URBEMIS Input ..................................................9

Table 8: Data for URBEMIS Dust Generation......................................................................11

Table 9: Annual On-Road Trip Generation ..........................................................................13

Table 10: Haul Trip Distribution, Length, and Distribution ....................................................14

Table 11: Construction Equipment and Baseline Activity.....................................................15

Table 12: 2009 Baseline Emissions.....................................................................................17

Table 13: Soil Removal, Aggregate Excavation, and Reclamation Emissions .....................17

Table 14: Annual Employee Trip Emissions ........................................................................18

County of San Joaquin - KRC Mine ExpansionAir Pollutant Emissions Methodology, Calculations, and Output Table of Contents

Michael Brandman Associates iiiH:\Client PN-JN\1478-San Joaquin County\14780009_SJ_County-KRC_Aggregates\Air Quality-CC\C-1 Emissions Calculation Methodology.doc

Table 15: Annual Project-Generated On-Road Hauling Emissions......................................19

Table 16: Total Project Emissions .......................................................................................19

Table 17: Total Project Emissions Above Baseline..............................................................20

County of San Joaquin - KRC Mine ExpansionAir Pollutant Emissions Methodology, Calculations, and Output Introduction

Michael Brandman Associates 1H:\Client PN-JN\1478-San Joaquin County\14780009_SJ_County-KRC_Aggregates\Air Quality-CC\C-1 Emissions Calculation Methodology.doc

SECTION 1: INTRODUCTION

1.1 - Analysis Tools

This analysis used URBEMIS2007 v9.2.4 to perform a project-level air quality assessment.URBEMIS2007 v.9.2.4 land use model was used to estimate off-road equipment and earth-disturbingPM10 emissions, employee-trip emissions and heavy-duty on-road hauling emissions.

1.2 - Considerations

There were four main considerations in development of this methodology for air quality analysis.The first consideration is the onsite component of the Project’s construction activities. For thepurposes of this document, soil removal, excavation, and reclamation activities will be collectivelyreferred to as construction activities. Construction activities for each Resource Management Area(RMA) results soil removal prior to excavation of aggregate, excavation of aggregate, andreclamation of the RMA. In addition, internal haul roads would be constructed to link the RMAs tothe materials processing facility. Special note should be made for the following:

Construction activities would not be evenly distributed over a calendar year, and

Equipment utilized for one construction component would also be utilized for the followingconstruction component (meaning there is no duplication of equipment pieces or concurrentoperation of a large fleet).

The second consideration is the on-road component of the project. The existing materials processingfacility generates both employee trips and heavy-duty truck trips associated with on-road aggregatehauling. As with the construction activities, the employee and heavy-duty hauling activity is notdistributed evenly during the calendar year. In addition, the project would not increase the intensityof employee or heavy-duty hauling activity currently generated by the project site.

The third consideration is the regional air pollutant thresholds recommended by San Joaquin ValleyAir Pollution Control District (SJVAPCD). The SJVAPCD’s regional thresholds are in units of tonsper year. Therefore, the analysis includes emissions estimates from all components of the project’sconstruction, and determines the total emissions that may occur.

Finally, the fourth consideration is an appropriate baseline to compare the impact of the project’spotential emissions. Section 15125(a) of the CEQA Guidelines states that the environmental settings,as they exist at the time that the notice of preparation is published, will normally constitute thebaseline physical conditions by which a lead agency determines whether an impact is significant. Forfacilities with existing permits, however, appellate opinions have indicated that it was appropriate toinclude the existing permit in the environmental baseline.

County of San Joaquin - KRC Mine ExpansionAir Pollutant Emissions Methodology, Calculations, and Output Introduction


In the recent court case of Communities For a Better Environment v. South Coast Air QualityManagement District (2010) 48 Cal. App. 4th 310, (CBE v. SCAQMD), the Court further definedappropriate baseline definitions for projects with existing permits. The Court stated that SCAQMDshould not have relied on the maximum permitted emissions as its baseline (point of comparison foranalyzing project-generated impacts) for assessing the new permit. However, the Court ruled thatagencies enjoy discretion to determine how those existing physical conditions can “most realisticallybe measured.” For example, where conditions are changing quickly, the Court stated that theappropriate baseline may be the “predicted conditions” at the expected date of approval. In addition,the Court stated that “peak impacts or recurring periods of resource scarcity may be as importantenvironmentally as average conditions.”

As determined in coordination with San Joaquin County and KRC staff, the annual average of the last9 years of activity is an appropriate baseline for regional air quality impacts, in order to adequatelyreflect the annual fluctuation of volume of materials processed.

1.3 - Regulatory Compliance

1.3.1 - SJVAPCD Regulation VIIIThe unmitigated analyses include compliance with SJVAPCD Regulation VIII (Fugitive PM10

Prohibitions). Compliance with Regulation VIII is required. When reviewing the URBEMISprintouts, please note that the URBEMIS program lists any measure that reduces emissions to be“mitigation,” regardless if the measure fulfills a requirement or is truly considered mitigation byCEQA standards. The following measures were included in the analyses:

Apply soil stabilizers to inactive areas. Replace ground cover in disturbed areas quickly. Water exposed surfaces twice daily. Stabilize soil in equipment loading/unloading areas. Reduce speed on unpaved roads to less than 15 mph. Manage haul road dust by watering twice daily.

1.3.2 - ARB’s Off-Road RuleNo control devices have been placed on the off-road equipment. The company’s fleet is incompliance with the California Air Resources Board’s (ARB) Off-Road Rule as a statewide fleet;therefore, these specific equipment pieces have no certain date for retrofits to be installed. Off-roadequipment is replaced in the Equipment Data as prescribed by the company’s planned compliancewith ARB’s Off-Road Rule.

County of San Joaquin - KRC Mine ExpansionAir Pollutant Emissions Methodology, Calculations, and Output Off-Road Activity Methodology


SECTION 2: OFF-ROAD ACTIVITY METHODOLOGY

The main construction components that generate air pollutant emissions are soil removal, aggregateextraction, and reclamation. In addition, internal haul roads would be constructed to access theRMAs, and would be reclaimed at the end of the project. However, the haul roads would only begraded and compacted, not paved. Further, the quantity, duration, and timing of haul roadconstruction are unknown at this time. As the haul roads compose 10 acres, and construction activitywould occur over 10 years, emissions associated with the construction and reclamation of the of haulroads is considered negligible, and were not estimated for the project. However, reclamation of all 10acres is estimated to occur in year 2023. Therefore, emissions associated with reclamation of the haulroads are estimated.

Construction emission can vary substantially from day to day, depending on the level of activity, thespecific type of activity, and the prevailing weather conditions. The methodology developed for thepurposes of quantitative air quality analysis was based on information available at the time ofanalysis; actual equipment and activity intensity at the time of construction may vary from thatanalyzed in this document. However, a methodology must be developed to provide CEQA-appropriate emissions analysis. The methodology for each construction component is addressed inthe following subsections.

2.1 - Resource Management Area Phasing

The Amended Reclamation Plan contains an estimated volume of extraction per RMA, provided inTable 1. Table 2 contains the calculated the average volume of material to be moved per acre foreach RMA. This section does not account for internal haul road construction.

Table 3 contains the estimated timeline for aggregate extraction and reclamation for each RMA, asprovided by KRC. Based on the estimated timeline for each RMA and the average volumes of soilremoval and extraction per RMA (Table 2), MBA calculated the annual volume of soil removal andaggregate extraction, and annual acreage of reclamation activities, provided in Table 4. The analysisassumes that the project would begin in July 2009.



Table 1: Mining Phases, RMAs, and Extraction Volumes

RMA Acreage

AverageExtractionThickness1

(ft)

EstimatedCubic Yards

(millions)

OverburdenThickness

(ft)

OverallDepth2

(ft)

SoilCubic Yards

(millions)

NA-1 49.9 18.7 1.501 1.0 20 0.086

NA-2 52.7 12.3 1.046 1.0 13 0.101

NA-3 56.7 23.6 2.161 1.0 251 0.102

NA-4 31.1 9.7 0.487 1.0 11 0.054

NA-5 10.4 5.7 0.095 1.0 7 0.015

SA-1 21.9 16.6 0.584 1.0 18 0.035

SA-2 8.4 8.3 0.113 1.0 9 0.014

SA-3 18.8 8.4 0.253 1.0 9 0.037

Totals 249.9 — 6.240 — — 0.444

Notes:1 Average extraction thickness is the estimated thickness of the mineable resource and is based on subsurface

exploration such as drilling, surface exposures, and experience with the same deposit within the existing quarry.2 Overall depths are the estimated combined thickness of overburden and the average extraction thickness of the

mineable resource. Overall depths may vary within an RMA because of locally variable subsurface conditions.Source: KRC Amended Reclamation Plan, December 2009.

Table 2: Estimated Material Volume per Acre

Soil Removal Aggregate Extraction

RMA Acreage Cubic YardsCubic Yards per

Acre Cubic YardsCubic Yards per

Acre

NA-1 49.9 86,000 1,723 1,501,000 30,080

NA-2 52.7 101,000 1,917 1,046,000 19,848

NA-3 56.7 102,000 1,799 2,161,000 38,113

NA-4 31.1 54,000 1,736 487,000 15,659

NA-5 10.4 15,000 1,442 95,000 9,135

SA-1 21.9 35,000 1,598 584,000 26,667

SA-2 8.4 14,000 1,667 113,000 13,452

SA-3 18.8 37,000 1,968 253,000 13,457

Source: MBA, 2009.



Table 3: Mining and Mine Land Reclamation Schedule (Acres/Year)

Year 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026

RMA Yr 1 Yr 2 Yr 3 Yr 4 Yr 5 Yr 6 Yr 7 Yr 8 Yr 9 Yr 10 Yr 11 Yr 12 Yr 13 Yr 14 Yr 15

NA-3 CTS Mitigation 15.0 15.0 15.0 11.7 Post Yr 6 Reclamation

NA-5 CTS Mitigation 10.4 Post Yr 3 Reclamation

NA-1 CTS Mitigation 10.0 15.0 15.5 9.9 Post Yr 7 Reclamation

NA-4 CTS Mitigation 15.0 16.1 Post Year 8 Reclamation

NA-2 CTS Mitigation 17.5 17.6 17.5 Post Year 10 Reclamation

SA-2 CTS Mitigation 8.4 Post Year 9 Reclamation

SA-1 CTS Mitigation 10.9 11.0 Post Year 11 Reclamation

SA-3 CTS Mitigation 9.0 9.8 Post Year 12 Reclamation

Phase IV(QX 94-02)

Post Year 12 Reclamation

ProcessingFacilities

Post Year 12 Reclamation

DisturbedAcres/Year

0.0 0.0 25.4 25.0 30.0 26.7 24.9 33.6 26.0 28.4 20.0 9.8 0.0 0.0 0.0

Notes:CTS = California tiger salamanderSource: San Joaquin County, 2009.



Table 4: Estimated RMA Activity by Year

Material Volumes (Cubic Yards)Year

Total AcreageDisturbed Total Soil Removal Aggregate Extraction

ReclamationActivities(Acres)

2014 25.4 41,984 666,758 0

2015 25.0 44,219 872,813 25.4

2016 30 52,836 1,023,660 25

2017 26.7 46,899 898,014 30

2018 24.9 43,107 533,416 26.7

2019 33.6 61,494 599,224 24.9

2020 26.0 47,731 424,242 33.6

2021 28.4 50,959 639,187 26

2022 20.0 35,293 416,563 28.4

2023 9.8 19,287 132,810 20

2024* 0.0 0 0 9.8

Total 249.9 443,808 6,206,687 249.9Notes:* Aggregate extraction activities complete, only reclamation activities this year.Source: MBA, 2010.

2.2 - Haul Road Reclamation

In addition to the RMA activities, the project would grade, maintain, and then reclaim approximately10 acres of onsite haul roads.

In accordance with the Amended Reclamation Plan, the 10 acres of haul roads would be reclaimedafter all mining and monitoring activities have been completed within the expansion area, estimatedto occur in year 15 (assumed 2026). Modeling assumptions for estimating emissions from haul roadreclamation are addressed in the next section.

2.3 - Construction Equipment and Hours

KRC provided the estimated fleet mix for the three main construction components as well as theaverage annual hours of operation for each piece of equipment (provided at the end of this document).However, because annual construction activities would vary from year to year, MBA calculated theaverage hours of equipment use per unit of construction activity. Because of the equipment namingconvention in URBEMIS, assumptions were made regarding the type of equipment to be modeled ascompared to the equipment list provided by KRC. The construction equipment and estimate averagehours are provided in Table 5. An on-road truck would be used for hauling extracted materials from



the RMAs to the existing materials processing facility. However, an off-highway truck equivalentwas used in the analysis because the units of activity are hours per cubic yard extracted.

Annual hours of construction equipment activity was calculated using the base activity data fromTable 5 and the annual activity from Table 4. Annual construction equipment hours are provided inTable 6. The equipment type and annual hours of operation were entered into URBEMIS to estimateannual emissions from construction activities.

The annual hours per equipment type per activity were then analyzed in order to calculate the totaltons of pollutant generation. For modeling purposes, the project hours for each constructioncomponent were assigned to occur within four weeks (20 working days) with 8-hour days. Therefore,in order to make the annual hours for each construction component in URBEMIS match the project’shours, the numbers for each piece of equipment were adjusted. The adjusted ‘daily’ equipmentnumbers are show in Table 7.

Table 5: Construction Equipment and Average Activity

Equipment Hours per

Activity ProvidedURBEMISEquivalent

HorsePower

TotalProjectHours

CubicYard Acre

Caterpillar 633EElevating Scraper Scrapers 475 3,180 0.0053 NA

Soil Removal4000 Gallon WaterTruck Water Trucks 200 3,180 0.0053 NA

John Deere 800 CLCExcavator Excavators 454 10,680 0.0015 NA

Caterpillar 140G MotorGrader Graders 150 10,680 0.0015 NA

4000 Gallon WaterTruck Water Trucks 200 10,680 0.0015 NA

Caterpillar D9L Dozer CrawlerTractor 460 2640 0.0004 NA

Extraction andInternalHauling

Hwy Truck TypeHauling Unit - 30 CY

Off-HighwayTrucks 400 64,080 0.0090 NA

Caterpillar 633EElevating Scraper Scrapers 475 3,710 NA 10.9569

4000 Gallon WaterTruck Water Trucks 200 3,710 NA 10.9569

ReclamationActivities Caterpillar D9L Dozer Crawler

Tractors 460 1,890 NA 5.5818

Notes:NA = Not ApplicableSource: KRC, 2008.



Table 6: Estimated Equipment Hours by Year

Total Hours YearEquipment 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Soil Removal

Scrapers 149 157 187 166 153 218 169 181 125 68 0

Water Trucks 149 157 187 166 153 218 169 181 125 68 0

Extraction and Internal Hauling

Excavators 999 1,308 1,534 1,345 799 898 636 958 624 199 0

Graders 999 1,308 1,534 1,345 799 898 636 958 624 199 0

Water Trucks 999 1,308 1,534 1,345 799 898 636 958 624 199 0

Crawler Tractor 247 323 379 333 198 222 157 237 154 49 0

Off-Highway Trucks 5,993 7,846 9,201 8,072 4,795 5,386 3,813 5,746 3,744 1,194 0

Reclamation Activities

Scrapers 0 149 157 187 166 153 218 169 181 125 68

Water Trucks 0 149 157 187 166 153 218 169 181 125 68

Crawler Tractors 0 94 99 118 105 97 138 107 114 79 43



Table 7: Adjusted Equipment Numbers for URBEMIS Input

Number of Equipment*Equipment 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2026

Soil Removal

Scrapers 0.9 1.0 1.2 1.0 1.0 1.4 1.1 1.1 0.8 0.4 0

Water Trucks 0.9 1.0 1.2 1.0 1.0 1.4 1.1 1.1 0.8 0.4 0

Extraction and Internal Hauling

Excavators 6.2 8.2 9.6 8.4 5.0 5.6 4.0 6.0 3.9 1.2 0

Graders 6.2 8.2 9.6 8.4 5.0 5.6 4.0 6.0 3.9 1.2 0

Water Trucks 6.2 8.2 9.6 8.4 5.0 5.6 4.0 6.0 3.9 1.2 0

Crawler Tractor 1.5 2.0 2.4 2.1 1.2 1.4 1.0 1.5 1.0 0.3 0

Off-Highway Trucks 37.5 49.0 57.5 50.5 30.0 33.7 23.8 35.9 23.4 7.5 0

Reclamation Activities

Scrapers 0 0.9 1.0 1.2 1.0 1.0 1.4 1.1 1.1 0.8 0.4

Water Trucks 0 0.9 1.0 1.2 1.0 1.0 1.4 1.1 1.1 0.8 0.4

Crawler Tractors 0 0.6 0.6 0.7 0.7 0.6 0.9 0.7 0.7 0.5 0.3Notes* Based on a 20 work-day phase, 8 hours of equipment use per day.



2.4 - Dust Generation

The annual acreages disturbed, and total soil removed and aggregate extracted (in cubic yards) fromTable 4 was used in URBEMIS to estimate construction-related dust generation from the project. TheURBEMIS default assumption that 0.25 of the total acreage of disturbance may occur on any one daywas utilized. In addition, due to the URBEMIS structure as discussed above, the “daily” amount ofsoil removed and aggregate extracted was entered as one-twentieth of the total annual volume.

The data entered into URBEMIS to estimate annual dust generation is provided in Table 8.



Table 8: Data for URBEMIS Dust Generation

Soil and Aggregate Extraction AcreageDisturbed Reclamation Activities Acres Disturbed

Year Total Maximum DailySoil Removal(Cubic Yards)

Aggregate Extraction(Cubic Yards) Total Maximum Daily

2014 25.4 6.4 41,984 666,758 0 0

2015 25.0 6.3 44,219 872,813 25.4 6.4

2016 30.0 7.5 52,836 1,023,660 25.0 6.3

2017 26.7 6.7 46,899 898,014 30.0 7.5

2018 24.9 6.2 43,107 533,416 26.7 6.7

2019 33.6 8.4 61,494 599,224 24.9 6.2

2020 26.0 6.5 47,731 424,242 33.6 8.4

2021 28.4 7.1 50,959 639,187 26.0 6.5

2022 20.0 5.0 35,293 416,563 28.4 7.1

2023 9.8 2.5 19,287 132,810 20.0 5.0

2024 — — — — 19.8* 5.0

Total 249.9 NA 443,808 6,206,687 259.9

Notes:* Includes 10 acres of haul roads.

County of San Joaquin - KRC Mine ExpansionAir Pollutant Emissions Methodology, Calculations, and Output On-Road Activity Methodology


SECTION 3: ON-ROAD ACTIVITY METHODOLOGY

Based on the project description in the EIR, there are two types of on-road trip generation from theproject and materials processing facility—employee trips and aggregate hauling trips. The materialsprocessing facility generates the aggregate hauling trips, and employee trips are generated by both thefacility and the construction activity.

Currently KRC is mining in Phase IV of the existing Reclamation Plan, leaving the final phase (PhaseV) left to excavate and process. The existing Reclamation Plan identified a range of 20 to 25 years ofoperation, commencing in 1995, with each phase lasting approximately 5 years. KRC has indicatedthat excavation in Phase IV will likely be completed in 2009 leaving an additional 5 years to excavateand process aggregate material in Phase IV or an end to excavation of material in 2014. Processingmay still be going on as aggregate material may still be stockpiled but KRC has indicated that it islikely that processing would be completed in 2015 with reclamation and reclamation monitoringcontinuing for another 3 years.

The project extends the life of the materials processing facility from the anticipated end date of 2014to 2023 (the anticipated last year of excavation). The emissions resultant from the materialsprocessing facility (employee trips and on-road aggregate hauling) prior to 2015 are associated withprocessing material consistent with the existing excavation permit and reclamation plan. Therefore,emissions prior to 2015 are not included in the air quality significance analysis, as they are acontinuation of existing emissions that would not increase as a result of the project.

The air quality analysis methodologies for each are described below. Data for this portion from theproject’s TIS was utilized to estimate air pollutant generation associated with operation of thematerials processing facility. Emissions were estimated for the 2014 through 2020, and for 2025.After year 2020, URBEMIS contains only 5-year interval model years for operational activities.

3.1 - Employee Trips

As with construction activities, employee trips would not be evenly distributed throughout the year.Based on previous KRC employment information, the materials processing facility would employ 15people, and the aggregate mining (expansion area) would employ four or five people. Therefore,during peak seasonal production, there may be 20 inbound trips and 20 outbound trips to the KRCmaterials processing facility and expansion area, one-fourth generated by the expansion area. Thisanalysis assumes that employees would use light-trucks at 50 percent with a gross vehicle weight(GVW) of <3,750 lbs and 50 percent 3,751-5,750 lbs.

3.2 - On-Road Hauling

The majority of the aggregate from the project would be transported to the Cities of Lodi andStockton and the surrounding area. As stated in the TIS, the project averaged 270 days of sale per



year between 2006 and 2007. With a permitted maximum throughput of 1,100,000 tons per year, thematerials processing facility would generate approximately 4,074 tons of aggregate for each salesday. The average truckload was calculated as 25 tons per truck. Therefore, the materials processingfacility could average 162.96 full truckloads per sales day, or 325.93 trips per day. Therefore, theaverage annual truck trips for the materials processing facility may be up to 88,000 trips.

However, as KRC has indicated that they do not plan on stockpiling, but processing the extractedmaterials as they are excavated, the annual trips was adjusted to reflect the volume of material to beextracted per year, based on truck capacity. The annual estimated on-road truck trips based on truckcapacity and annual volume is contained in Table 9. For this analysis, the annual trips were dividedby 365 for data entry into URBEMIS, which does not have a function to account for seasonal activity.

Table 9: Annual On-Road Trip Generation

Year

Volume to beExtracted

(cubic yards)

Weight to beextracted

(million tons)

EconomicWeight

(million tons)Annual Two-

Way Trips Daily Trips

2014 666,758 1.0 0.7 61,606 168.78

2015 872,813 1.3 1.0 80,644 220.94

2016* 1,023,660 1.5 1.2 88,000 241.10

2017 898,014 1.3 1.0 82,973 227.32

2018 533,416 0.8 0.6 49,285 135.03

2019 599,224 0.9 0.7 55,366 151.69

2020 424,242 0.6 0.5 39,198 107.39

2021 639,187 1.0 0.7 59,058 161.80

2022 416,563 0.6 0.5 38,489 105.45

2023 132,810 0.2 0.2 12,271 33.62

Total* 6,206,687 9.3 7.2 — —

Notes:Trips include both to and from the materials processing facility.* Extracted volume exceeds allowable throughput. Therefore, maximum capacity of the materials processing facility

was used.Source: MBA, 2010.

The TIS is estimated that trucks would travel approximately 16 miles each way between the materialsprocessing facility and the delivery site(s). The TIS states that the design vehicle expected at the sitewould include the American Association of State and Highway Transportation Officials (AASHTO)WB-67D Tractor-Trailer. Therefore, the analysis used Heavy-Heavy Trucks for 100 percent of theon-road hauling fleet (GVW 33,001-60,000 lbs). Based on the haul truck routes provided in the TIS,and the trip distribution as shown in Table 10, the weighted average trip would be 19.6 miles.



Table 10: Haul Trip Distribution, Length, and Distribution

Direction and DestinationPercent

DistributionEstimatedLength*

WeightedAverageLength

West on Peltier Road via SR-12/88, Mackville Road,and Jahant Road 11.9 12.3 1.2

West of Victor Road (SR-12) via SR-12/88 1.2 18.9 2.2

East on SR 12/88 to Calaveras County 10.1 18.7 0.2

West on Kettleman Lane Via Clements Road 11.1 15.9 1.8

West on Eight Mile Road via Clements Road,Harney Lane, and Jack Tone Road 19.8 19.9 3.9

South on SR-88 via Clements Road, Harney Lane,Eight Mile road, and Jack Tone Road 44.0 22.6 9.9

East on Comstock Road Via Clements Road 1.9 11.0 0.2

Total Weighted Average Trip Length 19.6

Notes:* West-bound trips measured to Highway 99. Calaveras direction measured to County line. Comstock Road measured

to intersection of Comstock road and Clements Road.

County of San Joaquin - KRC Mine ExpansionAir Pollutant Emissions Methodology, Calculations, and Output Baseline Development


SECTION 4: BASELINE DEVELOPMENT

Annual production and sales for the existing permitted area were provided by KRC for years 2001through 2009. Approximately 6.618 million tons of aggregate were produced over the 9-yearduration, and 6.748 million tons were sold. Therefore, the average tons per year produced by theexisting permitted area was 735,367, and 749,745 tons per year were sold.

4.1 - Off-Road Activity

At roughly 1.5 tons per excavated cubic yard of material, the baseline assumes that approximately490,245 cubic yards of material would be excavated. However, annual area of reclamation activitiesand the volume of soil removal are unknown for the baseline scenario. Therefore, emissions fromsoil removal and reclamation were not estimated for the baseline. In addition, fugitive dust was notestimated for the baseline.

The off-road equipment use rates provided in Table 5 was used to estimate the off-road equipmenthours under the baseline scenario. As described in Section 2.3, the analysis is structures withconstruction component occurring over 4 weeks (20 working days) with 8-hour days. Total annualhours and adjusted daily hours for the baseline off-road equipment is provide in Table 11.

Table 11: Construction Equipment and Baseline Activity

Equipment

Activity ProvidedURBEMISEquivalent

HorsePower

TotalBaseline

Hours

Number ofDaily

Equipment

Caterpillar 633E ElevatingScraper

Scrapers 475 NA NASoil Removal

4000 Gallon Water Truck Water Trucks 200 NA NAJohn Deere 800 CLCExcavator

Excavators 454 735.37 4.60

Caterpillar 140G MotorGrader

Graders 150 735.37 4.60

4000 Gallon Water Truck Water Trucks 200 735.37 4.60Caterpillar D9L Dozer Crawler Tractor 460 196.10 1.23

Extraction andInternal Hauling

Hwy Truck Type HaulingUnit - 30 CY

Off-HighwayTrucks

400 4,412.20 27.58

Caterpillar 633E ElevatingScraper

Scrapers 475 NA NA

4000 Gallon Water Truck Water Trucks 200 NA NA

ReclamationActivities

Caterpillar D9L Dozer CrawlerTractors

460 NA NA

County of San Joaquin - KRC Mine ExpansionAir Pollutant Emissions Methodology, Calculations, and Output Baseline Development


4.2 - Employee Trips

As stated in Section 3.1, above, and the TIS, the materials processing facility employs 15 people, andthe aggregate mining employs four or five people. Therefore, during peak seasonal production, theremay be 20 inbound and 20 outbound trips to the KRC materials processing facility and excavationareas. This analysis assumes that employees would use light-trucks, with half at a GVW of less than3,750 lbs and half at 3,751 to 5,750 lbs.

4.3 - On-Road Hauling

As discussed above, the average truckload is calculated as 25 tons per truck. Average sales of749,745 tons per year would result in 29,990 full truckloads per year, which is equal to 82 fulltruckloads per day, or 164 trips per day.

The trip distribution for sales of aggregate from the proposed expansion area would not differsubstantially from the existing trip distribution. Therefore, the baseline’s average trip length isestimated as 19.6 miles. The baseline information was input into the URBEMIS model, using year2009 emission factors to estimate baseline emissions.

County of San Joaquin - KRC Mine ExpansionAir Pollutant Emissions Methodology, Calculations, and Output Emissions Calculations


SECTION 5: EMISSIONS CALCULATIONS

5.1 - Baseline Emissions

Emissions were generated for the operational activities associated with the existing permitted facilityand current levels of aggregate production, as described in Section 4. The URBEMIS output foroperational activities is attached at the end of this document. Baseline emissions generated byemployee trips and on-road aggregate hauling are provided in Table 12.

Table 12: 2009 Baseline Emissions

Pollutant (Annual Tons)Emissions Source ROG NOX PM10 PM2.5 CO2

Employee Trips 0.06 0.07 0.04 0.01 47.64

On-Road Hauling 1.20 20.05 1.25 0.77 2,330.09

Excavation 0.50 4.70 0.18 0.17 513.09

Total Emissions 1.76 24.82 1.47 0.95 2,890.82

Notes:All employee Trips.Years 2021-2023 were interpolated from year 2020 and 2025 output.Source: MBA, 2009; URBEMIS Output.

5.2 - Annual Construction Emissions

Emissions were generated for the main construction activities associated with the project, as well aswith road construction and reclamation, as described in Section 2. The URBEMIS output forconstruction activities is attached at the end of this document. Annual emissions generated by soilremoval, aggregate excavation, and reclamation are provided in Table 13.

Table 13: Soil Removal, Aggregate Excavation, and Reclamation Emissions

Pollutant (Annual Tons)Year ROG NOx PM10 PM2.5 CO2

2014 0.56 4.35 3.17 0.78 721.14

2015 0.72 5.34 4.27 1.03 979.57

2016 0.80 5.55 4.96 1.18 1,147.01

2017 0.68 4.39 4.42 1.04 1,017.97

2018 0.40 2.46 2.79 0.65 630.95

2019 0.43 2.46 3.15 0.73 710.49

2020 0.31 1.69 2.40 0.54 537.20



Table 13 (cont.): Soil Removal, Aggregate Excavation, and Reclamation Emissions


2021 0.42 2.27 3.26 0.74 748.10

2022 0.29 1.57 2.24 0.51 506.83

2023 0.11 0.59 0.86 0.20 183.77

2024* 0.01 0.05 0.12 0.03 10.76

Notes:* Internal haul road reclamation.Source: MBA, 2009; URBEMIS Output

5.3 - Annual Operational Emissions

The URBEMIS output for employee trips are presented in Table 14. Annual on-road haulingemissions are presented in Table 15. Operational emissions were not estimated for 2024, as noexcavation activity or on-road hauling are anticipated for that year. Total annual on-road emissionsare presented in Table 15.

Table 14: Annual Employee Trip Emissions

Pollutant (Annual Tons)Year ROG NOX PM10 PM2.5 CO2

2014 0.05 0.05 0.04 0.01 47.87

2015 0.05 0.04 0.04 0.01 47.89

2016 0.04 0.04 0.04 0.01 47.92

2017 0.04 0.04 0.04 0.04 47.95

2018 0.04 0.04 0.04 0.01 47.97

2019 0.04 0.04 0.04 0.01 48.00

2020 0.03 0.03 0.04 0.01 48.03

2021 0.03 0.03 0.04 0.01 47.75

2022 0.02 0.02 0.04 0.01 47.47

2023 0.02 0.02 0.04 0.01 47.19

Notes:All employee Trips.Years 2021-2023 were interpolated from year 2020 and 2025 output.Source: MBA, 2009; URBEMIS Output.



Table 15: Annual Project-Generated On-Road Hauling Emissions


2014 0.85 12.20 0.97 0.50 2,430.61

2015 1.01 14.03 1.20 0.59 3,181.76

2016 1.00 13.43 1.24 0.58 3,472.01

2017 0.86 11.12 1.12 0.49 3,273.64

2018 0.47 5.81 0.63 0.27 1,944.57

2019 0.48 5.76 0.69 0.27 2,184.49

2020 0.31 3.63 0.47 0.18 1,546.53

2021 0.45 5.12 0.70 0.26 2,330.09

2022 0.43 4.75 0.68 0.25 2,330.09

2023 0.40 4.39 0.67 0.23 2,330.09

Notes:Years 2021-2024 were interpolated from year 2020 and 2025 output.Source: MBA, 2009; URBEMIS Output.

5.4 - Total Annual Emissions

Total project emissions are provided in Table 16. The projected increase above baseline emissions isprovided in Table 17. It should be noted that the baseline does not include soil removal, reclamation,or dust-generation for off-road construction activity, as discussed in Section 4.

Table 16: Total Project Emissions


2014 1.46 16.60 4.18 1.29 3,199.62

2015 1.78 19.41 5.51 1.63 4,209.22

2016 1.84 19.02 6.24 1.77 4,666.94

2017 1.58 15.55 5.58 1.57 4,339.56

2018 0.91 8.31 3.46 0.93 2,623.49

2019 0.95 8.26 3.88 1.01 2,942.98

2020 0.65 5.35 2.91 0.73 2,131.76

2021 0.89 7.41 4.00 1.01 3,125.94

2022 0.74 6.34 2.96 0.77 2,884.39



Table 16 (cont.): Total Project Emissions


2023 0.53 5.00 1.57 0.44 2,561.05

2024 0.01 0.05 0.12 0.03 10.76

Notes:Years 2021-2024 are interpolated from year 2020 and 2025 URBEMIS output.Source: MBA, 2009; URBEMIS Output.

Table 17: Total Project Emissions Above Baseline


2014 * * 2.71 0.34 308.8

2015 0.02 * 4.04 0.68 1,318.4

2016 0.08 * 4.77 0.82 1,776.12

2017 * * 4.11 0.62 1,448.74

2018 * * 1.99 * *

2019 * * 2.41 0.06 52.16

2020 * * 1.44 * *

2021 * * 2.53 0.06 235.12

2022 * * 1.49 * *

2023 * * 0.1 * *

2024 * * * * *

Notes:* = Not Applicable, baseline was not exceeded by the project’s emissionsYears 2021-2024 are interpolated from year 2020 and 2025 URBEMIS output.Source: MBA, 2009; URBEMIS Output.

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File Name: C:\Documents and Settings\mba\Desktop\URBEMIS\2014-2018 KRC Off-Road Analysis.urb924

Project Name: KRC Off-Road Analysis 2014-2018






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2017 TOTALS (tons/year unmitigated) 0.68 4.39 2.48 0.00 60.96 0.17 61.13 12.73 0.16 12.89 1,017.97

2016 TOTALS (tons/year mitigated) 0.80 5.55 2.85 0.00 4.76 0.20 4.96 0.99 0.18 1.18 1,147.01


2017 TOTALS (tons/year mitigated) 0.68 4.39 2.48 0.00 4.25 0.17 4.42 0.89 0.16 1.04 1,017.97







2016 TOTALS (tons/year unmitigated) 0.80 5.55 2.85 0.00 68.25 0.20 68.45 14.25 0.18 14.44 1,147.01






PM2.5 CO2


Summary Report:

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2014 0.56 4.35 1.89 0.00 43.26 9.15 721.1443.10 0.16 9.00 0.15

40.13Mass Grading 08/01/2014-08/28/2014

0.54 4.14 1.79 0.00 8.49 693.3239.98 0.16 8.35 0.14





3.13Fine Grading 07/01/2014-07/28/2014

0.03 0.21 0.09 0.00 0.66 27.823.12 0.01 0.65 0.01

Fine Grading On Road Diesel 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Fine Grading Worker Trips 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.46

Fine Grading Dust 0.00 0.00 0.00 0.00 3.12 0.00 3.12 0.65 0.00 0.65 0.00

Fine Grading Off Road Diesel 0.03 0.21 0.09 0.00 0.00 0.01 0.01 0.00 0.01 0.01 27.35

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2015 0.72 5.34 2.51 0.00 58.68 12.40 979.5758.48 0.20 12.21 0.18

52.31Mass Grading 08/01/2015-08/28/2015

0.65 4.84 2.29 0.00 11.05 909.3652.13 0.18 10.89 0.17





3.25Fine Grading 07/01/2015-07/28/2015

0.03 0.22 0.10 0.00 0.68 30.913.24 0.01 0.68 0.01





3.13Fine Grading 01/01/2015-01/28/2015

0.03 0.28 0.13 0.00 0.66 39.303.12 0.01 0.65 0.01





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2016 0.80 5.55 2.85 0.00 68.45 14.44 1,147.0168.25 0.20 14.25 0.18

61.33Mass Grading 08/01/2016-08/28/2016

0.73 5.04 2.61 0.00 12.94 1,067.5361.15 0.18 12.77 0.17




Mass Grading Off Road Diesel 0.73 5.03 2.46 0.00 0.00 0.18 0.18 0.00 0.16 0.16 1,044.80

3.88Fine Grading 07/01/2016-07/28/2016

0.03 0.24 0.11 0.00 0.82 37.093.87 0.01 0.81 0.01





3.25Fine Grading 01/01/2016-01/28/2016

0.03 0.28 0.13 0.00 0.69 42.393.24 0.01 0.68 0.01





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2017 0.68 4.39 2.48 0.00 61.13 12.89 1,017.9760.96 0.17 12.73 0.16

53.80Mass Grading 08/01/2017-08/28/2017

0.61 3.90 2.24 0.00 11.34 936.5853.65 0.15 11.21 0.14





3.44Fine Grading 07/01/2017-07/28/2017

0.02 0.18 0.09 0.00 0.72 30.913.44 0.01 0.72 0.01





3.88Fine Grading 01/01/2017-01/28/2017

0.04 0.30 0.15 0.00 0.82 50.493.87 0.01 0.81 0.01





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Onsite Cut/Fill: 2099 cubic yards/day; Offsite Cut/Fill: 0 cubic yards/day

Fugitive Dust Level of Detail: Low

Off-Road Equipment:


Phase: Fine Grading 7/1/2014 - 7/28/2014 - Soil Removal

Maximum Daily Acreage Disturbed: 6.4

Total Acres Disturbed: 25.4

Phase Assumptions

2018 0.40 2.46 1.50 0.00 38.78 8.16 630.9538.69 0.09 8.08 0.08

32.17Mass Grading 08/01/2018-08/28/2018

0.35 2.05 1.30 0.00 6.77 555.7432.09 0.08 6.70 0.07





3.17Fine Grading 07/01/2018-07/28/2018

0.02 0.17 0.09 0.00 0.67 30.913.16 0.01 0.66 0.01





3.45Fine Grading 01/01/2018-01/28/2018

0.03 0.24 0.12 0.00 0.73 44.313.44 0.01 0.72 0.01





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1 Scrapers (475 hp) operating at a 0.72 load factor for 8 hours per day

Off-Road Equipment:

1 Water Trucks (200 hp) operating at a 0.5 load factor for 8 hours per day








Phase: Fine Grading 1/1/2016 - 1/28/2016 - Reclamation








0.9 Scrapers (475 hp) operating at a 0.72 load factor for 8 hours per day





Off-Road Equipment:




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Off-Road Equipment:

















Off-Road Equipment:








Off-Road Equipment:


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Off-Road Equipment:
















Off-Road Equipment:


Off-Road Equipment:







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49 Off Highway Trucks (400 hp) operating at a 0.57 load factor for 8 hours per day


2 Crawler Tractors (460 hp) operating at a 0.64 load factor for 8 hours per day

Off-Road Equipment:



Off-Road Equipment:












Off-Road Equipment:









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30 Off Highway Trucks (400 hp) operating at a 0.57 load factor for 8 hours per day

5 Graders (150 hp) operating at a 0.61 load factor for 8 hours per day

Off-Road Equipment:


5 Excavators (454 hp) operating at a 0.57 load factor for 8 hours per day










Off-Road Equipment:







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2014 0.56 4.35 1.89 0.00 3.17 0.78 721.143.00 0.16 0.63 0.15

2.94Mass Grading 08/01/2014-08/28/2014

0.54 4.14 1.79 0.00 0.72 693.322.79 0.16 0.58 0.14





0.23Fine Grading 07/01/2014-07/28/2014

0.03 0.21 0.09 0.00 0.05 27.820.22 0.01 0.05 0.01






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2015 0.72 5.34 2.51 0.00 4.27 1.03 979.574.08 0.20 0.85 0.18

3.81Mass Grading 08/01/2015-08/28/2015

0.65 4.84 2.29 0.00 0.92 909.363.63 0.18 0.76 0.17





0.23Fine Grading 07/01/2015-07/28/2015

0.03 0.22 0.10 0.00 0.05 30.910.23 0.01 0.05 0.01





0.23Fine Grading 01/01/2015-01/28/2015

0.03 0.28 0.13 0.00 0.06 39.300.22 0.01 0.05 0.01





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2016 0.80 5.55 2.85 0.00 4.96 1.18 1,147.014.76 0.20 0.99 0.18

4.44Mass Grading 08/01/2016-08/28/2016

0.73 5.04 2.61 0.00 1.06 1,067.534.26 0.18 0.89 0.17




Mass Grading Off Road Diesel 0.73 5.03 2.46 0.00 0.00 0.18 0.18 0.00 0.16 0.16 1,044.80

0.28Fine Grading 07/01/2016-07/28/2016

0.03 0.24 0.11 0.00 0.06 37.090.27 0.01 0.06 0.01





0.24Fine Grading 01/01/2016-01/28/2016

0.03 0.28 0.13 0.00 0.06 42.390.23 0.01 0.05 0.01





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2017 0.68 4.39 2.48 0.00 4.42 1.04 1,017.974.25 0.17 0.89 0.16

3.89Mass Grading 08/01/2017-08/28/2017

0.61 3.90 2.24 0.00 0.92 936.583.74 0.15 0.78 0.14





0.25Fine Grading 07/01/2017-07/28/2017

0.02 0.18 0.09 0.00 0.06 30.910.24 0.01 0.05 0.01





0.28Fine Grading 01/01/2017-01/28/2017

0.04 0.30 0.15 0.00 0.07 50.490.27 0.01 0.06 0.01





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2018 0.40 2.46 1.50 0.00 2.79 0.65 630.952.70 0.09 0.56 0.08

2.31Mass Grading 08/01/2018-08/28/2018

0.35 2.05 1.30 0.00 0.54 555.742.24 0.08 0.47 0.07





0.23Fine Grading 07/01/2018-07/28/2018

0.02 0.17 0.09 0.00 0.05 30.910.22 0.01 0.05 0.01





0.25Fine Grading 01/01/2018-01/28/2018

0.03 0.24 0.12 0.00 0.06 44.310.24 0.01 0.05 0.01





PM10: 5% PM25: 5%


PM10: 55% PM25: 55%


The following mitigation measures apply to Phase: Fine Grading 7/1/2014 - 7/28/2014 - Soil Removal

PM10: 84% PM25: 84%



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PM10: 84% PM25: 84%


PM10: 5% PM25: 5%



PM10: 44% PM25: 44%


PM10: 55% PM25: 55%

PM10: 44% PM25: 44%


PM10: 55% PM25: 55%


PM10: 69% PM25: 69%


PM10: 55% PM25: 55%



The following mitigation measures apply to Phase: Fine Grading 1/1/2015 - 1/28/2015 - Reclamation

PM10: 69% PM25: 69%


PM10: 44% PM25: 44%



PM10: 55% PM25: 55%


PM10: 69% PM25: 69%


PM10: 84% PM25: 84%


PM10: 5% PM25: 5%

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PM10: 55% PM25: 55%


PM10: 69% PM25: 69%


PM10: 84% PM25: 84%


PM10: 5% PM25: 5%




PM10: 44% PM25: 44%


PM10: 55% PM25: 55%



PM10: 84% PM25: 84%


PM10: 5% PM25: 5%

PM10: 55% PM25: 55%





PM10: 44% PM25: 44%


PM10: 55% PM25: 55%


PM10: 55% PM25: 55%


PM10: 69% PM25: 69%

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PM10: 44% PM25: 44%


PM10: 55% PM25: 55%


PM10: 55% PM25: 55%


PM10: 69% PM25: 69%



PM10: 5% PM25: 5%




PM10: 84% PM25: 84%


PM10: 55% PM25: 55%


PM10: 69% PM25: 69%


PM10: 84% PM25: 84%


PM10: 5% PM25: 5%

PM10: 84% PM25: 84%


PM10: 5% PM25: 5%



PM10: 44% PM25: 44%


PM10: 55% PM25: 55%

4/22/2010 5:22:41 PM

Page: 21




PM10: 84% PM25: 84%

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PM10: 69% PM25: 69%


PM10: 5% PM25: 5%


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4/22/2010 5:22:41 PM

Page: 22


PM10: 5% PM25: 5%


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4/22/2010 5:22:41 PM

Page: 23

PM10: 5% PM25: 5%


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PM10: 69% PM25: 69%


4/22/2010 5:44:49 PM

Page: 1

File Name: C:\Documents and Settings\mba\Desktop\URBEMIS\2019-2024 KRC Off-Road Analysis.urb924

Project Name: KRC Off-Road Analysis 2019-2023

















PM2.5 CO2


Summary Report:

4/22/2010 5:44:49 PM

Page: 2












4/22/2010 5:44:49 PM

Page: 3

2019 0.43 2.46 1.67 0.00 43.92 9.24 710.4943.83 0.10 9.15 0.09

36.27Mass Grading 08/01/2019-08/28/2019

0.37 2.04 1.44 0.00 7.63 624.8336.19 0.08 7.56 0.07





4.48Fine Grading 07/01/2019-07/28/2019

0.03 0.21 0.11 0.00 0.94 43.274.47 0.01 0.93 0.01





3.17Fine Grading 01/01/2019-01/28/2019

0.03 0.21 0.11 0.00 0.67 42.393.16 0.01 0.66 0.01





4/22/2010 5:44:49 PM

Page: 4

2020 0.31 1.69 1.25 0.00 33.68 7.08 537.2033.62 0.06 7.02 0.05

25.73Mass Grading 08/01/2020-08/28/2020

0.25 1.27 1.01 0.00 5.40 442.7025.68 0.04 5.36 0.04





3.47Fine Grading 07/01/2020-07/28/2020

0.02 0.15 0.09 0.00 0.73 34.003.47 0.01 0.72 0.00





4.48Fine Grading 01/01/2020-01/28/2020

0.04 0.27 0.16 0.00 0.94 60.504.47 0.01 0.93 0.01





4/22/2010 5:44:49 PM

Page: 5

2021 0.42 2.27 1.71 0.00 45.69 9.60 748.1045.61 0.08 9.52 0.07

38.49Mass Grading 08/01/2021-08/28/2021

0.37 1.90 1.50 0.00 8.09 666.7138.42 0.07 8.02 0.06





3.72Fine Grading 07/01/2021-07/28/2021

0.02 0.15 0.09 0.00 0.78 34.003.72 0.01 0.78 0.00





3.47Fine Grading 01/01/2021-01/28/2021

0.03 0.21 0.12 0.00 0.73 47.403.47 0.01 0.72 0.01





4/22/2010 5:44:49 PM

Page: 6

2022 0.29 1.57 1.16 0.00 31.43 6.60 506.8331.38 0.06 6.55 0.05

25.12Mass Grading 08/01/2022-08/28/2022

0.24 1.24 0.98 0.00 5.28 434.7025.08 0.04 5.24 0.04





2.59Fine Grading 07/01/2022-07/28/2022

0.02 0.11 0.06 0.00 0.54 24.732.58 0.00 0.54 0.00





3.72Fine Grading 01/01/2022-01/28/2022

0.03 0.21 0.12 0.00 0.78 47.403.72 0.01 0.78 0.01





4/22/2010 5:44:49 PM

Page: 7

2024 0.01 0.05 0.03 0.00 1.64 0.34 10.761.64 0.00 0.34 0.00

1.64Fine Grading 01/01/2024-01/28/2024

0.01 0.05 0.03 0.00 0.34 10.761.64 0.00 0.34 0.00





2023 0.11 0.59 0.45 0.00 12.08 2.54 183.7712.06 0.02 2.52 0.02

8.10Mass Grading 08/01/2023-08/28/2023

0.08 0.40 0.34 0.00 1.70 140.618.09 0.01 1.69 0.01





1.39Fine Grading 07/01/2023-07/28/2023

0.01 0.04 0.02 0.00 0.29 8.871.39 0.00 0.29 0.00





2.59Fine Grading 01/01/2023-01/28/2023

0.02 0.15 0.09 0.00 0.54 34.302.58 0.01 0.54 0.00





4/22/2010 5:44:50 PM

Page: 8






Off-Road Equipment:

Off-Road Equipment:







Off-Road Equipment:













Phase Assumptions

4/22/2010 5:44:50 PM

Page: 9


Off-Road Equipment:

























Off-Road Equipment:

4/22/2010 5:44:50 PM

Page: 10




Off-Road Equipment:













Off-Road Equipment:









Off-Road Equipment:


4/22/2010 5:44:50 PM

Page: 11



Off-Road Equipment:
















Off-Road Equipment:

Off-Road Equipment:








4/22/2010 5:44:50 PM

Page: 12




Off-Road Equipment:











Off-Road Equipment:














4/22/2010 5:44:50 PM

Page: 13













Off-Road Equipment:





Off-Road Equipment:



Off-Road Equipment:








4/22/2010 5:44:50 PM

Page: 14




2019 0.43 2.46 1.67 0.00 3.15 0.73 710.493.05 0.10 0.64 0.09

2.60Mass Grading 08/01/2019-08/28/2019

0.37 2.04 1.44 0.00 0.60 624.832.52 0.08 0.53 0.07





0.32Fine Grading 07/01/2019-07/28/2019

0.03 0.21 0.11 0.00 0.07 43.270.31 0.01 0.07 0.01





0.23Fine Grading 01/01/2019-01/28/2019

0.03 0.21 0.11 0.00 0.05 42.390.22 0.01 0.05 0.01







4/22/2010 5:44:50 PM

Page: 15

2020 0.31 1.69 1.25 0.00 2.40 0.54 537.202.34 0.06 0.49 0.05

1.83Mass Grading 08/01/2020-08/28/2020

0.25 1.27 1.01 0.00 0.41 442.701.79 0.04 0.37 0.04





0.25Fine Grading 07/01/2020-07/28/2020

0.02 0.15 0.09 0.00 0.06 34.000.24 0.01 0.05 0.00





0.32Fine Grading 01/01/2020-01/28/2020

0.04 0.27 0.16 0.00 0.07 60.500.31 0.01 0.07 0.01





4/22/2010 5:44:50 PM

Page: 16

2021 0.42 2.27 1.71 0.00 3.26 0.74 748.103.18 0.08 0.66 0.07

2.75Mass Grading 08/01/2021-08/28/2021

0.37 1.90 1.50 0.00 0.62 666.712.68 0.07 0.56 0.06





0.26Fine Grading 07/01/2021-07/28/2021

0.02 0.15 0.09 0.00 0.06 34.000.26 0.01 0.05 0.00





0.25Fine Grading 01/01/2021-01/28/2021

0.03 0.21 0.12 0.00 0.06 47.400.24 0.01 0.05 0.01





4/22/2010 5:44:50 PM

Page: 17

2022 0.29 1.57 1.16 0.00 2.24 0.51 506.832.19 0.06 0.46 0.05

1.79Mass Grading 08/01/2022-08/28/2022

0.24 1.24 0.98 0.00 0.41 434.701.75 0.04 0.37 0.04





0.18Fine Grading 07/01/2022-07/28/2022

0.02 0.11 0.06 0.00 0.04 24.730.18 0.00 0.04 0.00





0.27Fine Grading 01/01/2022-01/28/2022

0.03 0.21 0.12 0.00 0.06 47.400.26 0.01 0.05 0.01





4/22/2010 5:44:50 PM

Page: 18

2024 0.01 0.05 0.03 0.00 0.12 0.03 10.760.11 0.00 0.02 0.00

0.12Fine Grading 01/01/2024-01/28/2024

0.01 0.05 0.03 0.00 0.03 10.760.11 0.00 0.02 0.00





2023 0.11 0.59 0.45 0.00 0.86 0.20 183.770.84 0.02 0.18 0.02

0.58Mass Grading 08/01/2023-08/28/2023

0.08 0.40 0.34 0.00 0.13 140.610.56 0.01 0.12 0.01





0.10Fine Grading 07/01/2023-07/28/2023

0.01 0.04 0.02 0.00 0.02 8.870.10 0.00 0.02 0.00





0.19Fine Grading 01/01/2023-01/28/2023

0.02 0.15 0.09 0.00 0.04 34.300.18 0.01 0.04 0.00





4/22/2010 5:44:50 PM

Page: 19


PM10: 55% PM25: 55%


PM10: 69% PM25: 69%



PM10: 5% PM25: 5%



PM10: 44% PM25: 44%


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4/22/2010 5:44:50 PM

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4/22/2010 5:44:50 PM

Page: 25

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4/22/2010 5:44:50 PM

Page: 26

5/18/2009 8:23:34 AM

Page: 1

File Name: S:\Projects\14780009 KRC Aggregates\Reference Library\Air Quality\Modeling\KRC Employee Trip Analysis.urb924

Project Name: KRC Employee Trips












Summary Report:

C Meier

Year

2014

5/18/2009 8:23:34 AM

Page: 2







Light Truck < 3750 lbs 50.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2

Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 50.0 1.4 98.1 0.5

Vehicle Fleet Mix




40.00 270.48








5/18/2009 8:23:34 AM

Page: 3





Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0



Travel Conditions



Other Bus 0.0 0.0 0.0 100.0

Motor Home 0.0 10.0 80.0 10.0

Urban Bus 0.0 0.0 0.0 0.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0





Vehicle Fleet Mix


5/18/2009 8:23:54 AM

Page: 1














Summary Report:

C Meier

Year

2015

5/18/2009 8:23:54 AM

Page: 2







Light Truck < 3750 lbs 50.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2

Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 50.0 1.4 98.1 0.5

Vehicle Fleet Mix




40.00 270.48








5/18/2009 8:23:54 AM

Page: 3





Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0



Travel Conditions



Other Bus 0.0 0.0 0.0 100.0

Motor Home 0.0 10.0 80.0 10.0

Urban Bus 0.0 0.0 0.0 0.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0





Vehicle Fleet Mix


5/18/2009 8:24:21 AM

Page: 1














Summary Report:

C Meier

Year

2016

5/18/2009 8:24:21 AM

Page: 2







Light Truck < 3750 lbs 50.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2

Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 50.0 1.4 98.1 0.5

Vehicle Fleet Mix




40.00 270.48








5/18/2009 8:24:21 AM

Page: 3





Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0



Travel Conditions



Other Bus 0.0 0.0 0.0 100.0

Motor Home 0.0 10.0 80.0 10.0

Urban Bus 0.0 0.0 0.0 0.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0





Vehicle Fleet Mix


5/18/2009 8:24:44 AM

Page: 1














Summary Report:

C Meier

Year

2017

5/18/2009 8:24:44 AM

Page: 2







Light Truck < 3750 lbs 50.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2

Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 50.0 1.4 98.1 0.5

Vehicle Fleet Mix




40.00 270.48








5/18/2009 8:24:44 AM

Page: 3





Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0



Travel Conditions



Other Bus 0.0 0.0 0.0 100.0

Motor Home 0.0 10.0 80.0 10.0

Urban Bus 0.0 0.0 0.0 0.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0





Vehicle Fleet Mix


5/18/2009 8:25:07 AM

Page: 1














Summary Report:

C Meier

Year

2018

5/18/2009 8:25:07 AM

Page: 2







Light Truck < 3750 lbs 50.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2

Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 50.0 1.4 98.1 0.5

Vehicle Fleet Mix




40.00 270.48








5/18/2009 8:25:07 AM

Page: 3





Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0



Travel Conditions



Other Bus 0.0 0.0 0.0 100.0

Motor Home 0.0 10.0 80.0 10.0

Urban Bus 0.0 0.0 0.0 0.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0





Vehicle Fleet Mix


5/18/2009 8:25:32 AM

Page: 1














Summary Report:

C Meier

Year

2019

5/18/2009 8:25:32 AM

Page: 2







Light Truck < 3750 lbs 50.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2

Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 50.0 1.4 98.1 0.5

Vehicle Fleet Mix




40.00 270.48








5/18/2009 8:25:32 AM

Page: 3





Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0



Travel Conditions



Other Bus 0.0 0.0 0.0 100.0

Motor Home 0.0 10.0 80.0 10.0

Urban Bus 0.0 0.0 0.0 0.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0





Vehicle Fleet Mix


5/18/2009 8:25:54 AM

Page: 1














Summary Report:

C Meier

Year

2020

5/18/2009 8:25:54 AM

Page: 2







Light Truck < 3750 lbs 50.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2

Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 50.0 1.4 98.1 0.5

Vehicle Fleet Mix




40.00 270.48








5/18/2009 8:25:54 AM

Page: 3





Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0



Travel Conditions



Other Bus 0.0 0.0 0.0 100.0

Motor Home 0.0 10.0 80.0 10.0

Urban Bus 0.0 0.0 0.0 0.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0





Vehicle Fleet Mix


5/18/2009 8:26:34 AM

Page: 1














Summary Report:

C Meier

Year

2025

5/18/2009 8:26:34 AM

Page: 2







Light Truck < 3750 lbs 50.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2

Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 50.0 1.4 98.1 0.5

Vehicle Fleet Mix




40.00 270.48








5/18/2009 8:26:34 AM

Page: 3





Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0



Travel Conditions



Other Bus 0.0 0.0 0.0 100.0

Motor Home 0.0 10.0 80.0 10.0

Urban Bus 0.0 0.0 0.0 0.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0





Vehicle Fleet Mix


4/23/2010 8:17:28 AM

Page: 1

File Name: C:\Documents and Settings\mba\Desktop\KRC\URBEMIS\KRC On-Road Haul Analysis.urb924

Project Name: KRC On-Road Haul Trucks












Summary Report:

4/23/2010 8:17:29 AM

Page: 2


On-Road Hauling 0.85 12.20 4.11 0.02 0.97 0.50 2,430.61




Light Truck < 3750 lbs 0.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2



Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 0.0 1.4 98.1 0.5

Vehicle Fleet Mix



168.78 3,308.09








4/23/2010 8:17:29 AM

Page: 3


Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0





Travel Conditions



Urban Bus 0.0 0.0 0.0 0.0

Motor Home 0.0 10.0 80.0 10.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Other Bus 0.0 0.0 0.0 100.0



Vehicle Fleet Mix


4/23/2010 8:19:06 AM

Page: 1














Summary Report:

4/23/2010 8:19:06 AM

Page: 2


On-Road Hauling 1.01 14.03 4.82 0.03 1.20 0.59 3,181.76




Light Truck < 3750 lbs 0.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2



Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 0.0 1.4 98.1 0.5

Vehicle Fleet Mix



220.94 4,330.42








4/23/2010 8:19:06 AM

Page: 3


Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0





Travel Conditions



Urban Bus 0.0 0.0 0.0 0.0

Motor Home 0.0 10.0 80.0 10.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Other Bus 0.0 0.0 0.0 100.0



Vehicle Fleet Mix


4/23/2010 1:32:10 PM

Page: 1

File Name: C:\Documents and Settings\mba\Desktop\URBEMIS\KRC On-Road Haul Analysis.urb924













Summary Report:

4/23/2010 1:32:10 PM

Page: 2


On-Road Hauling 1.00 13.43 4.72 0.03 1.24 0.58 3,472.09




Light Truck < 3750 lbs 0.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2



Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 0.0 1.4 98.1 0.5

Vehicle Fleet Mix



241.10 4,725.56








4/23/2010 1:32:10 PM

Page: 3


Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0





Travel Conditions



Urban Bus 0.0 0.0 0.0 0.0

Motor Home 0.0 10.0 80.0 10.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Other Bus 0.0 0.0 0.0 100.0



Vehicle Fleet Mix


4/23/2010 8:22:09 AM

Page: 1














Summary Report:

4/23/2010 8:22:09 AM

Page: 2


On-Road Hauling 0.86 11.12 4.00 0.03 1.12 0.49 3,273.64




Light Truck < 3750 lbs 0.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2



Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 0.0 1.4 98.1 0.5

Vehicle Fleet Mix



227.32 4,455.47








4/23/2010 8:22:09 AM

Page: 3


Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0





Travel Conditions



Urban Bus 0.0 0.0 0.0 0.0

Motor Home 0.0 10.0 80.0 10.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Other Bus 0.0 0.0 0.0 100.0



Vehicle Fleet Mix


4/23/2010 8:23:15 AM

Page: 1














Summary Report:

4/23/2010 8:23:15 AM

Page: 2


On-Road Hauling 0.47 5.81 2.14 0.02 0.63 0.27 1,944.57




Light Truck < 3750 lbs 0.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2



Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 0.0 1.4 98.1 0.5

Vehicle Fleet Mix



135.03 2,646.59








4/23/2010 8:23:15 AM

Page: 3


Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0





Travel Conditions



Urban Bus 0.0 0.0 0.0 0.0

Motor Home 0.0 10.0 80.0 10.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Other Bus 0.0 0.0 0.0 100.0



Vehicle Fleet Mix


4/23/2010 8:24:06 AM

Page: 1














Summary Report:

4/23/2010 8:24:06 AM

Page: 2


On-Road Hauling 0.48 5.76 2.18 0.02 0.69 0.27 2,184.49




Light Truck < 3750 lbs 0.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2



Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 0.0 1.4 98.1 0.5

Vehicle Fleet Mix



151.69 2,973.12








4/23/2010 8:24:06 AM

Page: 3


Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0





Travel Conditions



Urban Bus 0.0 0.0 0.0 0.0

Motor Home 0.0 10.0 80.0 10.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Other Bus 0.0 0.0 0.0 100.0



Vehicle Fleet Mix


4/23/2010 8:25:19 AM

Page: 1














Summary Report:

4/23/2010 8:25:19 AM

Page: 2


On-Road Hauling 0.31 3.63 1.41 0.01 0.47 0.18 1,546.53




Light Truck < 3750 lbs 0.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2



Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 0.0 1.4 98.1 0.5

Vehicle Fleet Mix



107.39 2,104.84








4/23/2010 8:25:19 AM

Page: 3


Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0





Travel Conditions



Urban Bus 0.0 0.0 0.0 0.0

Motor Home 0.0 10.0 80.0 10.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Other Bus 0.0 0.0 0.0 100.0



Vehicle Fleet Mix


4/23/2010 2:09:28 PM

Page: 1














Summary Report:

4/23/2010 2:09:28 PM

Page: 2


On-Road Hauling 0.47 5.48 2.12 0.02 0.71 0.27 2,330.09




Light Truck < 3750 lbs 0.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2



Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 0.0 1.4 98.1 0.5

Vehicle Fleet Mix



161.80 3,171.28








4/23/2010 2:09:28 PM

Page: 3


Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0





Travel Conditions



Urban Bus 0.0 0.0 0.0 0.0

Motor Home 0.0 10.0 80.0 10.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Other Bus 0.0 0.0 0.0 100.0



Vehicle Fleet Mix


4/23/2010 1:33:57 PM

Page: 1














Summary Report:

4/23/2010 1:33:57 PM

Page: 2


On-Road Hauling 0.36 3.66 1.56 0.02 0.64 0.21 2,330.09




Light Truck < 3750 lbs 0.0 4.1 88.5 7.4

Light Auto 0.0 1.9 97.9 0.2



Med Truck 5751-8500 lbs 0.0 1.7 98.3 0.0

Light Truck 3751-5750 lbs 0.0 1.4 98.1 0.5

Vehicle Fleet Mix



161.80 3,171.28








4/23/2010 1:33:57 PM

Page: 3


Trip speeds (mph) 35.0 35.0 35.0 35.0 35.0 35.0





Travel Conditions



Urban Bus 0.0 0.0 0.0 0.0

Motor Home 0.0 10.0 80.0 10.0

School Bus 0.0 0.0 0.0 100.0

Motorcycle 0.0 71.8 28.2 0.0

Other Bus 0.0 0.0 0.0 100.0



Vehicle Fleet Mix




C.2 - Climate Change Analysis Report

Climate Change Analysis ReportKnife River Corporation Mine Expansion

San Joaquin County, California

Prepared for:

San Joaquin County1810 E. Hazelton Avenue

Stockton, CA 95205209.468.3154

Contact: Rick Griffin, Senior Planner

Prepared by:

Michael Brandman Associates2000 “O” Street, Suite 200

Sacramento, CA 95811916.447.1100

Contact: Chryss Meier, Air Quality Specialist

April 26, 2010

San Joaquin County - KRC Mine ExpansionClimate Change Analysis Report Table of Contents

Michael Brandman Associates iiiH:\Client PN-JN\1478-San Joaquin County\14780009_SJ_County-KRC_Aggregates\Air Quality-CC\C-2 14780009 CC.doc

TABLE OF CONTENTS

Acronyms and Abbreviations.............................................................................................vSection 1: Introduction .......................................................................................................1

1.1 - Executive Summary...........................................................................................11.2 - Project Description.............................................................................................1

1.2.1 - Soil Removal.......................................................................................51.2.2 - Excavation and Hauling.......................................................................51.2.3 - Reclamation ........................................................................................6

Section 2: Setting................................................................................................................92.1 - Environmental Setting........................................................................................9

2.1.1 - Greenhouse Gases .............................................................................92.1.2 - Emissions Inventory and Trends .......................................................112.1.3 - Potential Environmental Effects.........................................................13

2.2 - Regulatory Environment ..................................................................................142.2.1 - Federal..............................................................................................142.2.2 - State .................................................................................................152.2.3 - San Joaquin Valley Air Pollution Control District (SJVAPCD) ............22

2.3 - Emissions Trading and Carbon Offset Programs .............................................252.3.1 - Emissions Trading Programs ............................................................252.3.2 - Carbon Trading Programs.................................................................25

Section 3: Thresholds of Significance.............................................................................27Section 4: Impact Analysis ...............................................................................................29

4.1 - Greenhouse Gas Inventories ...........................................................................294.1.1 - Construction-Generated ....................................................................304.1.2 - On-Road Mobile ................................................................................314.1.3 - Project Baseline ................................................................................334.1.4 - Total Project Inventory ......................................................................33

4.2 - Significance Analysis .......................................................................................354.2.1 - Greenhouse Gas Emissions..............................................................354.2.2 - Consistency with Applicable Plan......................................................35

Section 5: References.......................................................................................................39

LIST OF TABLES

Table 1: Mining Phases, RMAs, and Extraction Volumes ......................................................3

Table 2: Mining and Mine Land Reclamation Schedule (Acres/Year) ....................................4

Table 3: Greenhouse Gases ...............................................................................................10

Table 4: California GHG Inventory 2000–2006....................................................................12

Table 5: Mining GHG Inventory 2000-2006 .........................................................................13

Table 6: Scoping Plan Capped and Uncapped Industrial Measures ....................................20

Table 7: Soil Removal, Aggregate Excavation, and Reclamation Emissions .......................31

Table 8: Annual Employee Trip Emissions ..........................................................................32

Table 9: Annual On-Road Hauling Emissions......................................................................32

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Table 10: Baseline Emissions .............................................................................................33

Table 11: Total Project-Generated Emissions .....................................................................34

Table 12: Project-Generated Emissions Above Baseline ....................................................34

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ACRONYMS AND ABBREVIATIONS

°C degrees Centigrade°F degrees FahrenheitAB Assembly BillARB California Air Resources Control BoardCAFE Corporate Average Fuel EconomyCAPCOA California Air Pollution Control Officers AssociationCAT Climate Action Team (Report)CCAP Climate Change Action PlanCCX Chicago Climate ExchangeCEQA California Environmental Quality ActCFC chlorofluorocarbonsCH4 methaneCO2 carbon dioxideEIR Environmental Impact ReportEMFAC EMission FACtors ModelEPA Environmental Protection AgencyGHG greenhouse gasGWP Global Warming PotentialHFC hydrofluorocarbonsHFE hydrofluorinated ethersIPCC Intergovernmental Panel on Climate ChangeKRC Knife River CorporationMTCO2e metric tons of carbon dioxide equivalentMMTCO2e million metric tons of carbon dioxide equivalentNF3 nitrogen trifluorideNHTSA National Highway Traffic Safety AdministrationNOx nitrogen oxidesN2O nitrous oxideO3 ozoneOAL Office of Administrative LawOPR Governor’s Office of Planning and ResearchPFC perfluorocarbonsppm parts per millionppt parts per trillionPRC Public Resources CodeRF radiative forcingRGGI Regional Greenhouse Gas Initiative

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RMA Resource Management AreaRTAC Regional Targets Advisory CommitteeSB Senate BillSF6 sulfur hexafluorideSJVAPCD San Joaquin Valley Air Pollution Control DistrictSJVCE San Joaquin Valley Carbon ExchangeTIS Traffic Impact StudyU.S. United StatesVOC Volatile Organic CompoundWm-2 watts per square meter

San Joaquin County - KRC Mine ExpansionClimate Change Analysis Report Introduction

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SECTION 1: INTRODUCTION

1.1 - Executive Summary

This document assesses the impact of the Knife River Corporation (KRC) Mine Expansion (project)on climate change. The proposed project includes aggregate excavation on approximately 249 acresand haul road construction on approximately 10 acres.

In 2006, Governor Arnold Schwarzenegger signed AB 32 (CA 2006), which charged the CaliforniaAir Resources Board (ARB) with developing regulations on how the State would address climatechange (also known as “global warming”). The California Air Resource Board (ARB) adopted theClimate Change Proposed Scoping Plan (Scoping Plan) in December 2008 to address how the Statewould attain the emission reduction goals contained in AB 32. Newly adopted CaliforniaEnvironmental Quality Act (CEQA) Guidelines Amendments provide guidance for addressinggreenhouse gases (GHGs) in CEQA document. In addition, the San Joaquin Valley Air PollutionControl District has adopted recommended guidance for assessing a project’s significance forgreenhouse gas emissions during CEQA analysis.

The project will emit GHG emissions during internal haul road construction, aggregate extraction,and reclamation. In addition, the project would contribute GHG emissions from employee trips. Theproject would generate a total of 29,662 metric tons of carbon dioxide equivalent (MTCO2e) over itslifetime. At year 2020, AB 32’s target year, the project would generate approximately 1,934MTCO2e. As stated in the inventory analysis, the emission factors used for the analysis are constantin future years, although ARB recognizes a need to reconcile those emission factors with thecalculations used to develop the statewide GHG inventories. Based on increased engine efficienciesin future years, it is reasonable to conclude that the project’s future year inventories areoverestimated.

The GHG emissions emitted by the project would result in a less than significant impact to climatechange. The project would not hinder or delay California’s implementation of AB 32 or conflict withthe ARB’s Scoping Plan.

1.2 - Project Description

The project applicant, KRC, is seeking the approval of a Quarry Excavation Permit and AmendedReclamation Plan for an area encompassing approximately 2,107 acres in northeastern San JoaquinCounty.

The project consists of Quarry Excavation Permit (Permit) and an Amended Reclamation Plan. Thetwo project components apply to different physical areas of the project site. KRC currently operatesan existing permitted quarry (existing excavation area) and materials processing facility on the project

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site. The permit would apply to the proposed quarry expansion area, as detailed below. However, theAmended Reclamation Plan covers the entire project area, which consists of the expansion area,existing excavation area, and materials processing facility.

The project involves aggregate resource extraction on approximately 249.9 acres and an additional 10acres of roads and other disturbed areas within the expansion area. The total disturbed area to bereclaimed includes the extraction and roadways in the project for an estimated total of 259.9 acres.No changes, additions, or increase in activity of the processing facility is proposed as part of theproject.

Mining will occur in eight Resource Management Areas (RMAs) as shown in the KRC MineExpansion Environmental Impact Report’s (EIR’s) Exhibit 3-3 (MBA 2010a). Each RMA isdesigned to minimize or avoid sensitive aquatic environmental habitats and wetland features, therebycreating discontinuous and separate mining areas. Approved mine land reclamation in accordancewith the California Surface Mining and Reclamation Act will begin immediately following thecompletion of aggregate extraction within each RMA. Detailed descriptions of each RMA areprovided in EIR Section 3, Project Description (MBA 2010a).

All aggregate extraction will occur within the limits of the quarry. Aggregate processing will occur atKRC’s existing materials processing facility west of the project area. Excavated material would beprocessed (crushed, screened, and sorted) at the existing processing facilities. All haul roads,conveyor systems, water distribution systems, and truck and equipment maintenance facilities arewithin the existing boundaries of KRC’s current permitted area.

Quarry and processing operations are expected to occur over a period of 10 years of the 15-yearpermit. KRC anticipates operations to occur periodically, year-round. The highest amount of activitywill be in the summer and fall. About 0.50 to 1.3 million tons of aggregate would be mined eachyear.

Principal operations conducted at each RMA within the quarry will include soil removal, aggregateexcavation and hauling, and reclamation. Each of these operations is discussed in detail below. Theproposed quarry operation will employ 6 to 10 full-time employees. The maximum daily output fromthe quarry is approximately 5,000 tons. The RMAs (Table 1) represent the applicant’s overalldevelopment plan based on land holdings, lease agreements, and forecasted aggregate production.



Table 1: Mining Phases, RMAs, and Extraction Volumes

RMA* AcreageAverage

ExtractionThickness

(ft)

EstimatedCubic Yards

(millions)

OverburdenThickness

(ft)

OverallDepth

(ft)

SoilCubic Yards

(millions)

NA-1 49.9 18.7 1.501 1.0 19.7 0.086

NA-2 52.7 12.3 1.046 1.0 13.3 0.101

NA-3 56.7 23.6 2.161 1.0 24.6 0.102

NA-4 31.1 9.7 0.487 1.0 10.7 0.054

NA-5 10.4 5.7 0.095 1.0 6.7 0.015

SA-1 21.9 16.6 0.584 1.0 17.6 0.035

SA-2 8.4 8.3 0.113 1.0 9.3 0.014

SA-3 18.8 8.4 0.253 1.0 9.4 0.037

Totals 249.9 103.3 6.24 8.0 111.3 0.444

Notes:* Each RMA is discussed in detail below.Source: San Joaquin County, 2008.

Based on anticipated production requirements, the RMAs will be mined and reclaimed according tothe schedule in Table 2. The mining schedule includes concurrent mining in multiple RMAs toproduce a balanced aggregate feed for final product production and to meet contractual obligationwith landowners.



Table 2: Mining and Mine Land Reclamation Schedule (Acres/Year)

Year 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026

RMA Yr 1 Yr 2 Yr 3 Yr 4 Yr 5 Yr 6 Yr 7 Yr 8 Yr 9 Yr 10 Yr 11 Yr 12 Yr 13 Yr 14 Yr 15

NA-3 CTS Mitigation 15.0 15.0 15.0 11.7 Post-Year 6 Reclamation

NA-5 CTS Mitigation 10.4 Post-Year 3 Reclamation

NA-1 CTS Mitigation 10.0 15.0 15.5 9.9 Post-Year 7 Reclamation

NA-4 CTS Mitigation 15.0 16.1 Post-Year 8 Reclamation

NA-2 CTS Mitigation 17.5 17.6 17.5 Post-Year 10 Reclamation

SA-2 CTS Mitigation 8.4 Post-Year 9 Reclamation

SA-1 CTS Mitigation 10.9 11.0 Post-Year 11 Reclamation

SA-3 CTS Mitigation 9.0 9.8 Post-Year 12 Reclamation

Phase IV(QX 94-02)

Post-Year 12 Reclamation

ProcessingFacilities

Post-Year 12 Reclamation

DisturbedAcres/Year

0.0 0.0 25.4 25.0 30.0 26.7 24.9 33.6 26.0 28.4 20.0 9.8 0.0 0.0 0.0

Notes:CTS = California tiger salamanderSource: San Joaquin County, 2009



1.2.1 - Soil RemovalTopsoil from all RMAs will be salvaged for use in the mine land reclamation process. It is estimatedthat approximately 444,000 cubic yards of topsoil material will be available for reclamation.

Topsoil will be removed from each RMA in 10- to 20-acre increments (unless the RMA is 10 acres orless) to minimize the amount of exposed aggregate and reduce dust and potential erosion. The upper12 inches of the surface will be removed using a scraper. The topsoil will be stockpiled in areas thatwill not interfere with mining or ongoing reclamation activities, and where potential runoff from thestockpiles is retained within the mined area. Stockpiles would generally be 6.25 acres and would notexceed 4 feet in thickness. Most soils will only be stockpiled for a period of 1 year before beingreplaced for reclamation.

Topsoil stockpiles will be seeded with an approved seed mix for erosion control and to maintain soilfertility.

1.2.2 - Excavation and HaulingNew onsite haul roads would be graded, watered, and maintained with berms for traffic safety. The20 acres of haul roads will be reclaimed after all mining and monitoring activities have beencompleted.

Excavation will be performed using track-mounted excavators. The excavator will be the primarypiece of equipment used to remove material from the quarry surfaces and load trucks. As necessary, afront-end loader will be used to place soil material in stockpiles for later use in reclamation. Truckswill be used to haul aggregate from the quarry to KRC’s existing materials handling and processingfacilities (not part of this project).

Concurrent with each excavation phase, the project involves loading aggregate material using track-mounted excavators into rubber-tired trucks for transport to an existing aggregate processing facility.Aggregate processing includes crushing, screening, and washing. Processed material is conveyed tovarious storage piles and loaded into haul trucks for transport to offsite locations. Components of thisprocess are described in more detail below.

Offsite Aggregate Processing: The existing materials processing plant crushes, screens, and sortsthe aggregate into various size fractions that are sold for various purposes such as ready-mix concrete,base rock, fill, and other construction products. Existing processing facilities are located west of theproposed expansion area and include the aggregate processing and washing plant. All of the rawaggregate that is excavated as part of the project would be transported via haul tracks to the existingprocessing facilities, where the clean aggregate is crushed and screened to produce various sizes andmix specifications. The materials processing facility is designed to accept a feed rate of 500 tons perhour.

San Joaquin County - KRC Mine ExpansionIntroduction Climate Change Analysis Report


On-Road Truck Access: At maximum annual aggregate product production, the project is expectedto generate an average of approximately 163 outgoing truckloads per day (KDA 2009). Outgoingtruckloads are spread out during the day, with more loads leaving the facility during the morninghours and fewer in the afternoon. The existing driveway from Brandt Road would continue to beused as the site entrance and exit. Haul trucks would exit at Brandt Road and travel west towardsClements Road, then north or south. Haul routes are described in further detail later in this section.

Equipment staging and parking would be located near the existing maintenance office buildinglocated south of the existing processing facilities and west of the expansion area.

Dust Control

A water truck equipped with spray bars will be used to dampen unpaved roads for dust control. Amotor grader would be used periodically to smooth the road surface and to incorporate dampened soilinto the roadbed. During site preparation and grading, two water trucks equipped with spray bars willprovide dust suppression by watering internal roads and areas in advance of stripping. Sitepreparation, stripping, and grading would be conducted primarily during the wet season when the soilmoisture is at its highest. The San Joaquin Valley Air Pollution Control District (SJVAPCD) Rule8020 (Fugitive Dust Requirements for control of fine particulate matter equal to or less than 10microns [PM10] from Construction, Demolition, Excavation and Extraction Activities) will applyduring the project’s grading phase.

The mining operation will also be regulated by SJVAPCD Rule 8020. Dust suppression for theoperations would include the watering of mining areas and haul roads by water trucks as necessary toreduce dust. Approximately 20,000 gallons of water per day would be used for dust suppression. Inthe mining operations, a water truck at the pit face and along the haul roads would apply the water.Spray bars would be located at the feed hopper and if necessary at the field conveyor transfer points.

1.2.3 - ReclamationReclamation begins following completion of mining activities in each RMA, and is conducted inaccordance with the approved mine land reclamation plan. Mine land reclamation is conducted toreclaim land disturbed by the mining operation, including the quarry areas, permanent slopes, haulroads, and—ultimately—those areas occupied by the mining office and truck scales. Access roadswill be retained into the RMAs and through the mining property for access to adjoining properties andto portions of the property owner’s land that are not a part of the mining plan. Existing water wellswill be retained and available for agricultural irrigation, restoration, and reclamation activities and asa source of water for livestock.

Reclamation work, consisting primarily of the redistribution of stockpiled overburden and topsoil,will begin by the end of the first year of mining. Topsoil would be temporarily stockpiled duringmining activities and would be spread over the disturbed areas as mining proceeds. Redistributedtopsoil will naturally regenerate annual grassland vegetation. Natural revegetation will be



supplemented with the application of a seed mix. Grass seeding will occur in the fall prior to theonset of fall rain. Hydro mulching or weed-free straw may be used in conjunction with grass seedingto insure successful germination rates and provide temporary erosion control.

Plant vitality will be monitored for a 3-year period following planting. Vegetation diversity willresult from using the seed mix specified in Section III-G of the Reclamation Plan. Satisfactoryreclamation will occur when the vegetation coverage on the disturbed mine land meets therequirements of the Reclamation Plan.

All reclamation will be monitored for a period of 3 years after mining is completed.

San Joaquin County - KRC Mine ExpansionClimate Change Analysis Report Setting


SECTION 2: SETTING

2.1 - Environmental Setting

Climate change is a change in the average weather of the earth that may be measured by changes inwind patterns, storms, precipitation, and temperature. These changes are assessed using historicalrecords of temperature changes that have occurred in the past, such as during previous ice ages.Many of the concerns regarding climate change use this data to extrapolate a level of statisticalsignificance specifically focusing on temperature records from the last 150 years (the Industrial Age)that differ from previous climate changes in rate and magnitude.

The United Nations Intergovernmental Panel on Climate Change (IPCC) constructed several emissiontrajectories of GHGs needed to stabilize global temperatures and climate change impacts. The IPCCpredicted that global mean temperature change from 1990 to 2100, given six scenarios, could rangefrom 1.1 degrees Centigrade (°C) to 6.4°C. Regardless of analytical methodology, global averagetemperatures and sea levels are expected to rise under all scenarios (IPCC 2007a).

In California, climate change may result in consequences such as the following:

A reduction in the quality and supply of water to the State from the Sierra snow pack; Increased risk of large wildfires; Reductions in the quality and quantity of certain agricultural products; Exacerbation of air quality problems; A rise in sea levels resulting in the displacement of coastal businesses and residences; Damage to marine ecosystems and the natural environment; An increase in infections, disease, asthma, and other health-related problems; and A decrease in the health and productivity of California’s forests (CCCC 2006).

2.1.1 - Greenhouse GasesGases that trap heat in the atmosphere are GHGs. The effect is analogous to the way a greenhouseretains heat. Common GHGs include water vapor, carbon dioxide, methane, nitrous oxides,chlorofluorocarbons, hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, ozone, and aerosols.Natural processes and human activities emit GHGs. The presence of GHGs in the atmosphere affectsthe earth’s temperature. Without the natural heat-trapping effect of GHG, the earth’s surface wouldbe about 34°C cooler (CAT 2006). However, it is believed that emissions from human activities,such as electricity production and vehicle use, have elevated the concentration of these gases in theatmosphere beyond the level of naturally occurring concentrations.

The global warming potential (GWP) is the potential of a gas or aerosol to trap heat in theatmosphere. The GWP of a gas is essentially a measurement of the GHG compared with the

San Joaquin County - KRC Mine ExpansionSetting Climate Change Analysis Report


reference gas, carbon dioxide; carbon dioxide has a GWP of 1. The GHGs of concern from theproject are summarized in Table 3.

Individual GHG compounds have varying GWP and atmospheric lifetimes. The calculation of thecarbon dioxide equivalent is a consistent methodology for comparing GHG emissions, since itnormalizes various GHG emissions to a consistent metric. Methane’s warming potential of 21indicates that methane has a 21 times greater warming affect than carbon dioxide on a molecule permolecule basis. A carbon dioxide equivalent is the mass emissions of an individual GHG multipliedby its GWP.

Table 3: Greenhouse Gases

Greenhouse Gas Description and Physical Properties Sources

Water Vapor Water vapor is the most abundant, important,and variable GHG. In the atmosphere, itmaintains the climate necessary for life.

Sources include evaporation from theocean and other water bodies,sublimation of ice and snow, andtranspiration from plants.

Ozone (O3) Ozone is a short-lived local GHG andphotochemical pollutant. Tropospheric ozonechanges contribute to radiative forcing on aglobal scale. GWPs for short-lived GHGs,such as ozone and aerosols, are not defined bythe IPCC.

Ozone is formed from reactions ofozone precursors (nitrogen oxides[NOx] and volatile organiccompounds [VOC]) and sunlight inthe atmosphere. VOC and NOx areemitted from automobiles, solvents,and fuel combustion.

Aerosols Aerosols are particulate matter suspended inthe air. They are short-lived and remain in theatmosphere for about a week. Aerosols warmthe atmosphere by absorbing heat and cool theatmosphere by reflecting light, with radiativeforcing (RF) cooling effects of -1.2 Wm-2.There is a low scientific understanding of theRF of individual aerosols, such as blackcarbon. Black carbon can cause warmingfrom deposition on snow (+0.1 Wm-2) andfrom suspensions in air (+0.2 Wm-2). A GWPof 761 for black carbon has been identified ina journal article. Global cooling potentials forother aerosols in a metric similar to the GWPare not available.

Sulfate aerosols are emitted whenfuel containing sulfur is burned.Black carbon (or soot) is emittedduring biomass burning andincomplete combustion of fossil fuels(such as diesel fuel).

Methane (CH4) Methane is a flammable gas and is the maincomponent of natural gas. GWP = 21.

A natural source of methane is fromthe anaerobic decay of organicmatter. Methane is extracted fromgeological deposits (natural gasfields). Other sources are fromlandfills, fermentation of manure, andcattle.

Nitrous oxide (N2O) Nitrous oxide is also known as laughing gasand is a colorless GHG. GWP = 310.

Microbial processes in soil and water,fuel combustion, and industrialprocesses.



Table 3 (cont.): Greenhouse Gases

Greenhouse Gas Description and Physical Properties Sources

Carbon dioxide(CO2)

Carbon dioxide is an odorless, colorless,natural GHG. GWP = 1.

Carbon dioxide is emitted fromnatural and anthropogenic sources.Natural sources includedecomposition of dead organicmatter; respiration of bacteria, plants,animals, and fungus; evaporationfrom oceans; and volcanicoutgassing. Anthropogenic sourcesare from burning coal, oil, naturalgas, and wood. The concentration in2005 was 379 ppm, which is anincrease of about 1.4 ppm per yearsince 1960.

Chlorofluorocarbons(CFCs)

CFCs are gases formed synthetically byreplacing all hydrogen atoms in methane orethane with chlorine and/or fluorine atoms.CFCs are nontoxic, nonflammable, insoluble,and chemically unreactive in the troposphere(the level of air at the earth’s surface). GWPsrange from 3,800 to 8,100.

CFCs were first synthesized in 1928for use as refrigerants, aerosolpropellants, and cleaning solvents.They destroy stratospheric ozone;therefore, the Montreal Protocol onSubstances that Deplete the OzoneLayer stopped their production in1987.

Hydrofluorocarbons(HFCs)

The HFCs with the largest measuredatmospheric concentrations are HFC-23 andHFC-134a (10 ppt) and HFC-152a (1 ppt).GWPs: HFC-23 = 11,700, HFC-134a = 1,300,HFC-152a = 140.

HFCs are synthetic manmadechemicals that are used as asubstitute for CFCs in applicationssuch as automobile air conditionersand refrigerants.

Perfluorocarbons(PFCs)

PFCs have stable molecular structures andonly break down by ultraviolet rays about 60kilometers above Earth’s surface. Because ofthis, PFCs have very long lifetimes, between10,000 and 50,000 years. GWPs range from6,500 to 9,200.

Two main sources of PFCs areprimary aluminum production andsemiconductor manufacturing.

Sulfur hexafluoride Sulfur hexafluoride is an inorganic, odorless,colorless, and nontoxic, nonflammable gas.Concentrations in the 1990s were about 4 ppt.It has the highest GWP of any gas evaluated,23,900.

It is manmade and used for insulationin electric power transmissionequipment, in the magnesiumindustry, in semiconductormanufacturing, and as a tracer gas.

Notes:ppm = parts per million; ppt = parts per trillion (measure of concentration in the atmosphere); GWP = global warmingpotentialSource: IPCC 2007a.

2.1.2 - Emissions Inventory and TrendsInternational and NationalIn 2004, total worldwide GHG emissions were estimated to be 20,135 million metric tons of carbondioxide equivalent (MMTCO2e), excluding emissions/removals from land use, land use change, and



forestry (UNFCCC 2006). (Sinks, or removal processes of GHG, plays an important role in the GHGinventory as forest and other land uses absorb carbon.) In 2004, GHG emissions in the U.S. were7,074.4 MMTCO2e (EPA 2006). In 2005, total U.S. GHG emissions were 7,260.4 MMTCO2e, a16.3-percent increase from 1990 emissions, while U.S. gross domestic product has increased by 55percent over the same period (EPA 2007). Emissions rose from 2004 to 2005, increasing by 0.8percent. The main causes of the increase are believed to be (1) strong economic growth in 2005,leading to increased demand for electricity, and (2) an increase in the demand for electricity due towarmer summer conditions (EPA 2007). However, a decrease in demand for fuels due to warmerwinter conditions and higher fuel prices moderated the increase in emissions.

In 2006, emissions in the U.S. were 7,054.2 MMTCO2e, which is a decrease from 2005 emissions.The decrease in emissions from 2005 is attributable to (1) reduced electricity demand for heating inthe winter and cooling in the summer, (2) rising fuel prices in the transportation sector leading todecreased fuel use, and (3) the increased use of natural gas and renewable energy (EPA 2008).

StateCalifornia is the second largest contributor in the U.S. of GHGs and the sixteenth largest in the world(CEC 2006). In 2004, California produced 500 MMTCO2e (CEC 2007), including importedelectricity and excluding combustion of international fuels and carbon sinks or storage, which isapproximately 7 percent of U.S. emissions. The major source of GHGs in California istransportation, contributing 41 percent of the State’s total GHG emissions (CEC 2006). Electricitygeneration is the second largest source, contributing 22 percent of the State’s GHG emissions (CEC2006). The inventory for California’s GHG emissions between 2000 and 2006 is presented in Table4. Mining is a subset of the Industrial sector. The Industrial sector decreased its emissions fromapproximately 24 percent of the total inventory in 2000 to approximately 21 percent by 2006. Theemissions inventory for mining subsectors is presented in Table 5.

Table 4: California GHG Inventory 2000–2006

Emissions MMTCO2eMain Sector* 2000 2001 2002 2003 2004 2005 2006

Agriculture & Forestry 20.91 21.12 24.34 24.48 24.78 25.20 26.25

Commercial 12.98 12.58 14.46 13.07 13.15 12.97 13.25

Electricity Generation (Imports) 42.97 52.38 50.61 56.29 58.59 54.92 49.92

Electricity Generation (In State) 60.76 64.66 51.56 49.77 58.08 52.45 56.99

Industrial 107.93 105.47 107.44 106.41 100.99 100.51 103.00

Not Specified 8.75 9.60 10.47 11.33 12.20 12.90 13.52

Residential 32.20 30.45 30.22 29.88 31.54 30.94 31.12



Table 4 (cont.): California GHG Inventory 2000-2006

Emissions MMTCO2eMain Sector* 2000 2001 2002 2003 2004 2005 2006

Transportation 171.94 174.62 181.32 178.90 183.03 185.82 185.77

Total 458.45 470.89 470.42 470.12 482.35 475.70 479.80

Notes:* Excludes Military Sector.Source: ARB 2009.

Table 5: Mining GHG Inventory 2000-2006

Emissions MMTCO2eSector Subsector

2000 2001 2002 2003 2004 2005 2006

Coal 0.00 0.01 0.00 0.00 0.00 0.00 0.00

Metals 0.54 0.25 0.25 0.26 0.27 0.26 0.23

Mining

Non Metals 0.33 0.03 0.04 0.07 0.09 0.08 0.09

Total Mining 0.87 0.31 0.32 0.34 0.36 0.34 0.32

Total Industrial* 107.94 105.48 107.45 106.41 100.99 100.51 103.00

Notes:* Total Mining may differ from summation of the subsectors as a result of rounding.Source: ARB 2009.

In total, mining contributed less than 1 percent of the total Industrial GHG inventory, decreasing fromapproximately 0.8 percent in 2000 to nearly 0.3 percent in 2006. Of the mining subsectors, metalsmining generated the highest share of GHGs, followed by non-metals, then coal mining. The projectfalls under the non-metals subsector of mining. Non metal mining contributed less than 0.1 percentof the statewide GHG inventory, decreasing from 0.07 percent in 2000 to 0.02 percent in 2006 (ARB2009).

2.1.3 - Potential Environmental EffectsWorldwide, average temperatures are likely to increase by 1.8 °C to 4°C, or approximately 3 degreesFahrenheit (°F) to 7°F by the end of the 21st century (IPCC 2007a). However, a global temperatureincrease does not translate to a uniform increase in temperature in all locations on the earth. Regionalclimate changes are dependent on multiple variables, such as topography. One region of the Earthmay experience increased temperature, increased incidents of drought and similar warming effects,whereas another region may experience a relative cooling. According to the IPCC’s Working GroupII Report, climate change impacts to North America may include diminishing snowpack, increasingevaporation, exacerbated shoreline erosion, exacerbated inundation from sea level rising, increasedrisk and frequency of wildfire, increased risk of insect outbreaks, increased experiences of heat



waves, and rearrangement of ecosystems, as species and ecosystem zones shift northward and tohigher elevations (IPCC 2007b).

For California, climate change has the potential to incur/exacerbate the following environmentalimpacts (CAT 2006):

Reduced precipitation; Changes to precipitation and runoff

patterns; Reduced snowfall (precipitation occurring

as rain instead of snow); Earlier snowmelt; Decreased snowpack; Increased agricultural demand for water; Intrusion of seawater into coastal aquifers;

Increased agricultural growing season; Increased growth rates of weeds, insect

pests and pathogens; Inundation of low-lying coastal areas by

sea level rise; Increased incidents and severity of

wildfire events; and, Expansion of the range and increased

frequency of pest outbreaks.

Although certain environmental effects are widely accepted to be a potential hazard to certainlocations, such as rising sea level for low-laying coastal areas, it is currently infeasible to predict allenvironmental effects of climate change on any one location.

2.2 - Regulatory Environment

2.2.1 - FederalThe U.S. Environmental Protection Agency (EPA) currently does not regulate GHG emissions frommotor vehicles. Massachusetts v. EPA (Supreme Court Case 05-1120) was argued before the UnitedStates Supreme Court on November 29, 2006, in which it was petitioned that EPA regulate fourGHGs, including carbon dioxide, under Section 202(a)(1) of the Clean Air Act. A decision was madeon April 2, 2007, in which the Supreme Court held that petitioners have a standing to challenge theEPA and that the EPA has statutory authority to regulate emissions of GHGs from new motorvehicles.

On April 17, 2009, the EPA released a proposed finding that determined climate change poses a riskto public health. EPA held a 60-day public comment period, which ended June 23, 2009, andreceived over 380,000 public comments. These included both written comments as well as testimonyat two public hearings in Arlington, Virginia and Seattle, Washington. On December 7, 2009, theEPA Administrator signed two distinct findings regarding greenhouse gases under Section 202(a) ofthe Clean Air Act:

Endangerment Finding: The Administrator finds that the current and projected concentrationsof the six key well-mixed greenhouse gases—carbon dioxide (CO2), methane (CH4), nitrousoxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride



(SF6)—in the atmosphere threaten the public health and welfare of current and futuregenerations.

Cause or Contribute Finding: The Administrator finds that the combined emissions of thesewell-mixed greenhouse gases from new motor vehicles and new motor vehicle enginescontribute to the greenhouse gas pollution, which threatens public health and welfare.

These findings do not themselves impose any requirements on industry or other entities. However,this action is a prerequisite to finalizing the EPA’s proposed GHG standards for light-duty vehicles,which were jointly proposed by EPA and the Department of Transportation’s National HighwaySafety Administration on September 15, 2009. The two findings were published in the FederalRegister Docket ID No. EPA-HQ-OAR-2009-0171. The final rule is effective January 14, 2010.

EPA has issued the Final Mandatory Reporting of Greenhouse Gases Rule that requires reporting ofGHG emissions from large sources and suppliers in the United States. Under the rule (effectiveDecember 29, 2009), suppliers of fossil fuels or industrial greenhouse gases, manufacturers ofvehicles and engines, and facilities that emit 25,000 metric tons or more per year of GHG emissionsare required to submit annual reports to EPA. The gases covered by the proposed rule are CO2, CH4,N2O, HFC, PFC, SF6, and other fluorinated gases including nitrogen trifluoride (NF3) andhydrofluorinated ethers (HFE).

On September 15, 2009, EPA and the Department of Transportation’s National Highway TrafficSafety Administration (NHTSA) proposed a new national program that would reduce greenhouse gasemissions and improve fuel economy for all new cars and trucks sold in the United States. EPAproposed the first-ever national GHG emissions standards under the Clean Air Act, and NHTSAproposed Corporate Average Fuel Economy (CAFE) standards under the Energy Policy andConservation Act. This proposed national program would allow automobile manufacturers to build asingle light-duty national fleet that satisfies all requirements under both federal programs and thestandards of California and other states.

2.2.2 - StateThere has been significant legislative and regulatory activities that affect climate change andgreenhouse in California, as discussed below.

Title 24. Although it was not originally intended to reduce GHGs, California Code of RegulationsTitle 24 Part 6: California’s Energy Efficiency Standards for Residential and NonresidentialBuildings, was first adopted in 1978 in response to a legislative mandate to reduce California’senergy consumption. The standards are updated periodically to allow consideration and possibleincorporation of new energy efficient technologies and methods. The latest amendments were madein October 2005 and currently require new homes to use half the energy they used only a decade ago.The 2005 standards are in effect through July 31, 2009. The 2008 standards became effective on



August 1, 2009. The requirement for when the 2008 standards must be followed is dependent onwhen the application for the building permit is submitted. Energy efficient buildings require lesselectricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHGemissions.

AB 1493. California Assembly Bill 1493 (Pavley), enacted on July 22, 2002, required the ARB todevelop and adopt regulations that reduce GHGs emitted by passenger vehicles and light duty trucks.Regulations adopted by the ARB apply to 2009 and later model year vehicles. The ARB estimatesthat the regulation would reduce climate change emissions from the light-duty passenger vehicle fleetby an estimated 18 percent in 2020 and by 27 percent in 2030 (ARB 2004). On June 30, 2009, EPAgranted a waiver of Clean Air Act preemption to California for the State’s GHG emission standardsfor motor vehicles beginning with the 2009 model year. The waiver was published in the FederalRegister on July 8, 2009.

Executive Order S-3-05. California Governor Arnold Schwarzenegger announced on June 1, 2005,through Executive Order S-3-05, the following reduction targets for GHG emissions:

By 2010, reduce GHG emissions to 2000 levels; By 2020, reduce GHG emissions to 1990 levels; and By 2050, reduce GHG emissions to 80 percent below 1990 levels (CA 2005).

The 2050 reduction goal represents what scientists believe is necessary to reach levels that willstabilize the climate. The 2020 goal was established to be an aggressive, but achievable, mid-termtarget. To meet these targets, the Governor directed the Secretary of the California EPA to lead aClimate Action Team (CAT) made up of representatives from the Business, Transportation, andHousing Agency; the Department of Food and Agriculture; the Resources Agency; the ARB; theEnergy Commission; and the Public Utilities Commission. The CAT’s Report to the Governor in2006 contains recommendations and strategies to help ensure the targets in Executive Order S-3-05are met (CAT 2006).

The Governor signed Executive Order S-01-07 on January 18, 2007. The order mandates that astatewide goal shall be established to reduce the carbon intensity of California’s transportation fuelsby at least 10 percent by 2020. It also requires that a Low Carbon Fuel Standard for transportationfuels be established for California.

SB 1368. In 2006, the State Legislature adopted Senate Bill 1368 (SB 1368), which wassubsequently signed into law by the Governor. SB 1368 directs the California Public UtilitiesCommission to adopt a performance standard for GHG emissions for the future power purchases ofCalifornia utilities. SB 1368 seeks to limit carbon emissions associated with electrical energyconsumed in California by forbidding procurement arrangements for energy longer than 5 years fromresources that exceed the emissions of a relatively clean, combined cycle natural gas power plant.



Because of the carbon content of its fuel source, a coal-fired plant cannot meet this standard becausesuch plants emit roughly twice as much carbon as natural gas, combined cycle plants. Accordingly,the new law will effectively prevent California’s utilities from investing in, otherwise financiallysupporting, or purchasing power from new coal plants located in or out of the State. Thus, SB 1368will lead to lower GHG emissions associated with California’s energy demand, as SB 1368 willeffectively prohibit California utilities from purchasing power from out-of-state producers that cannotsatisfy the performance standard for GHG emissions required by SB 1368.

SB 97 was passed in August 2007 and added Section 21083.05 to the Public Resources Code (PRC).The code states “(a) On or before July 1, 2009, the Office of Planning and Research (OPR) shallprepare, develop, and transmit to the Resources Agency guidelines for the mitigation of GHGemissions or the effects of GHG emissions as required by this division, including, but not limited to,effects associated with transportation or energy consumption. (b) On or before January 1, 2010, theResources Agency shall certify and adopt guidelines prepared and developed by the OPR pursuant tosubdivision (a).” Section 21097 was also added to the PRC. It provides CEQA protection fortransportation projects funded by the Highway Safety, Traffic Reduction, Air Quality, and PortSecurity Bond Act of 2006 or projects funded by the Disaster Preparedness and Flood PreventionBond Act of 2006, in stating that the failure to adequately analyze the effects of GHGs would notviolate CEQA. However, the CEQA protection section of SB 97 remained in effect only untilJanuary 1, 2010.

CEQA Amendments. As required by SB 97, the Governor’s OPR prepared and transmittedrecommended Amendments to the CEQA Guidelines for greenhouse gas emissions to the CaliforniaNatural Resources Agency on April 13, 2009. After a public comment period, the Natural ResourcesAgency proposed revisions to the text of the Proposed Guidelines Amendments. The NaturalResources Agency provided additional public comment time on the revised text. The NaturalResources Agency adopted the CEQA Guidelines Amendments with minor, non-substantial changes.

The Natural Resources Agency transmitted the Adopted Amendments and the entire rulemaking fileto the Office of Administrative Law (OAL) on December 31, 2009. The Office of AdministrativeLaw reviewed the Adopted Amendments and the Natural Resources Agency’s rulemaking file. TheAdopted Amendments were filed with the Secretary of State, and became effective March 18, 2010.

The CEQA Amendments provide guidance to public agencies regarding the analysis and mitigation ofthe effects of GHG emissions in draft CEQA documents. The CEQA Amendments fit within theexisting CEQA framework by amending existing CEQA Guidelines to reference climate change.

A new section, CEQA Guidelines Section 15064.4, was added to assist agencies in determining thesignificance of GHG emissions. The new section allows agencies the discretion to determine whethera quantitative or qualitative analysis is best for a particular project. Importantly, however, little



guidance is offered on the crucial next step in this assessment process—how to determine whether theproject’s estimated GHG emissions are significant or cumulatively considerable.

Also amended were CEQA Guidelines Sections 15126.4 and 15130, which address mitigationmeasures and cumulative impacts respectively. GHG mitigation measures are referenced in generalterms, but no specific measures are championed. The revision to the cumulative impact discussionrequirement (Section 15130) simply directs agencies to analyze GHG emissions in an EIR when aproject’s incremental contribution of emissions may be cumulatively considerable, however it doesnot answer the question of when emissions are cumulatively considerable.

Section 15183.5 permits programmatic GHG analysis and later project-specific tiering, as well as thepreparation of GHG Reduction Plans. Compliance with such plans can support a determination that aproject’s cumulative effect is not cumulatively considerable, according to proposed Section15183.5(b).

In addition, the amendments revised Appendix F of the CEQA Guidelines, which focuses on EnergyConservation, and Appendix G, which includes the sample Environmental Checklist Form. TheChecklist was amended to include the following questions:

Would the project generate GHG emissions, either directly or indirectly, that may have asignificant impact on the environment?

And,

Would the project conflict with any applicable plan, policy or regulation of an agencyadopted for the purpose of reducing the emissions of GHG?

AB 32. In 2006, the California State Legislature enacted AB 32, the California Global WarmingSolutions Act of 2006. AB 32 focuses on reducing GHG emissions in California. GHGs, as definedunder AB 32, include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons,and sulfur hexafluoride. AB 32 requires that GHGs emitted in California be reduced to 1990 levelsby the year 2020. ARB is the state agency charged with monitoring and regulating sources ofemissions of GHGs that cause global warming in order to reduce emissions of GHGs.

The ARB Governing Board approved the 1990 GHG emissions level of 427 MMTCO2e on December6, 2007. Therefore, in 2020, emissions in California are required to be at or below 427 MMTCO2e.

Under the current “business as usual” scenario, statewide emissions are increasing at a rate ofapproximately 1 percent per year as noted below.

1990: 427 MMTCO2e 2004: 480 MMTCO2e



2008: 495 MMTCO2e 2020: 596 MMTCO2e

Under AB 32, the ARB published its Final Expanded List of Early Action Measures to ReduceGreenhouse Gas Emissions in California (ARB 2007). Discrete early action measures are currentlyunderway or are enforceable by January 1, 2010. Early action measures are regulatory or non-regulatory and are currently in progress or to be initiated by the ARB in the 2007 to 2012 timeframe.The ARB has 44 early action measures that apply to the transportation, commercial, forestry,agriculture, cement, oil and gas, fire suppression, fuels, education, energy efficiency, electricity, andwaste sectors. Of those early action measures, nine are considered discrete early action measures, asthey are regulatory and enforceable by January 1, 2010. The ARB estimates that the 44recommendations are expected to result in reductions of at least 42 MMTCO2e by 2020, representingapproximately 25 percent of the 2020 target.

CEQA is only mentioned once in the Early Action Measures report. The California Air PollutionControl Officer’s Association suggested that ARB work with local air districts on approaches toreview GHG impacts under the CEQA process, including significance thresholds for GHGs forprojects and to develop a process for capturing reductions that result from CEQA mitigations. ARB’sresponse to this recommendation in the report is as follows: “the Governor’s Office of Planning andResearch is charged with providing statewide guidance on CEQA implementation. With respect toquantifying any reductions that result from project-level mitigation of GHG emissions, we would liketo see air districts take a lead role in tracking such reductions in their regions” (ARB 2007).

The ARB Board approved the Climate Change Proposed Scoping Plan (Scoping Plan) in December2008. The Scoping Plan “proposes a comprehensive set of actions designed to reduce overall GHGemissions in California, improve our environment, reduce our dependence on oil, diversify our energysources, save energy, create new jobs, and enhance public health” (ARB 2008). The measures in theScoping Plan will be developed over the next 2 years through rule development at the ARB and otheragencies, and are expected to be in place by 2012.

As noted in the Scoping Plan, the projected total business-as-usual emissions for year 2020 (estimatedas 596 MMTCO2e) must be reduced approximately 29 percent to achieve the ARB’s approved 2020emission target of 427 MMTCO2e. The Scoping Plan identifies recommended measures for multipleGHG emission sectors and the associated emission reductions needed to achieve the year 2020emissions target—each sector has a different emission reduction target. Most of the measures targetthe transportation and electricity sectors. As stated in the Scoping Plan, the key elements of thestrategy for achieving the 2020 GHG target include:

Expanding and strengthening existing energy efficiency programs as well as building andappliance standards;

Achieving a statewide renewables energy mix of 33 percent;



Developing a California cap-and-trade program that links with other Western Climate Initiativepartner programs to create a regional market system;

Establishing targets for transportation-related GHG emissions for regions throughoutCalifornia and pursuing policies and incentives to achieve those targets;

Adopting and implementing measures pursuant to existing State laws and policies, includingCalifornia’s clean car standards, goods movement measures, and the Low Carbon FuelStandard; and

Creating targeted fees, including a public goods charge on water use, fees on high globalwarming potential gases, and a fee to fund the administrative costs of the State’s long-termcommitment to AB 32 implementation.

In addition, the Proposed Scoping Plan differentiates between ‘capped’ and ‘uncapped’ strategies.‘Capped’ strategies are subject to the proposed cap-and-trade program. The Scoping Plan states thatthe inclusion of these emissions within the cap-and trade program will help ensure that the year 2020emission targets are met despite some degree of uncertainty in the emission reduction estimates forany individual measure. Implementation of the capped strategies is calculated to achieve a sufficientamount of reductions by 2020 to achieve the emission target contained in AB 32. “Uncapped”strategies that will not be subject to the cap-and-trade emissions caps and requirements, and areprovided as a margin of safety by accounting for additional GHG emission reductions. The ScopingPlan contains capped and uncapped measures aimed at reducing emissions from the Industrial Sector.As shown in Table 6, the recommended Industrial sector measures mainly apply to the oil and gasindustry.

Table 6: Scoping Plan Capped and Uncapped Industrial Measures

MeasureNumber Measure Description Estimated Reduction

(MMTCO2e in 2020)

I-1 Energy Efficiency and Co-benefits Audits for Large Industrial Sources1 TBD

I-2 Oil and Gas Extraction GHG Emissions Reduction 0.20

I-3 GHG Leak Reduction from Oil and Gas Transmission 0.90

I-4 Refinery Flare Recovery Process Improvements 0.33

I-5 Removal of Methane Exemption from Existing Refinery Regulations 0.01

Notes:1 Facilities emitting more than 0.5 MMTCO2e per year.Source: ARB 2008

SB 375 passed the Senate on August 30, 2008 and was signed by the Governor on September 30,2008. According to SB 375, the transportation sector is the largest contributor of GHG emissions,which emits over 40 percent of the total GHG emissions in California. Automobiles and light trucksalone contribute almost 30 percent. SB 375 indicates that GHGs from automobiles and light trucks



can be reduced by new vehicle technology but significant reductions from changed land use patternsand improved transportation are necessary. SB 375 states, “Without improved land use andtransportation policy, California will not be able to achieve the goals of AB 32.” SB 375 does thefollowing: (1) it requires metropolitan planning organizations to include sustainable communitystrategies in their regional transportation plans for reducing GHG emissions, (2) it aligns planning fortransportation and housing, and (3) it creates specified incentives for the implementation of thestrategies. Concerning CEQA, SB 375, Section 21159.28 states that CEQA findings determinationsfor certain projects are not required to reference, describe, or discuss (1) growth inducing impacts; or(2) any project-specific or cumulative impacts from cars and light-duty truck trips generated by theproject on global warming or the regional transportation network if the project:

1. Is in an area with an approved sustainable communities strategy or an alternative planningstrategy that the ARB accepts as achieving the GHG emission reduction targets;

2. Is consistent with that strategy (in designation, density, building intensity, and applicablepolicies); and

3. Incorporates the mitigation measures required by an applicable prior environmentaldocument.

Pursuant to SB 375, the Board appointed a Regional Targets Advisory Committee (RTAC) onJanuary 23, 2009 to provide recommendations on factors to be considered and methodologies to beused in ARB’s target setting process. The RTAC is required to provide its recommendations in areport to ARB by September 30, 2009. ARB must propose draft targets by June 30, 2010, and adoptfinal targets by September 30, 2010.

Non Legislative

Governor’s Office of Planning and Research. The OPR published a technical advisory on CEQAand Climate Change, as required under SB 97, on June 19, 2008. The guidance did not include asuggested threshold, but stated that the OPR has asked ARB to “recommend a method for settingthresholds which will encourage consistency and uniformity in the CEQA analysis of GHG emissionsthroughout the state.” The OPR does recommend that CEQA analyses include the followingcomponents:

Identify GHG emissions Determine significance Mitigate impacts

The OPR has also started tracking environmental documents that contain GHG analysis andmitigation measures. The website www.ceqamap.com contains the list of documents in electronicform and is maintained by CEQAdocs.com.



CAPCOA. On January 8, 2008, the California Air Pollution Control Officers Association(CAPCOA) released a paper to provide a common platform of information and tools for publicagencies. The disclaimer states that it is not a guidance document but a resource to enable localdecision makers to make the best decisions they can in the face of incomplete information during aperiod of change. The paper indicates that it is an interim resource and does not endorse anyparticular approach. It discusses three groups of potential thresholds, including a no significancethreshold, a threshold of zero, and a non-zero threshold (CAPCOA 2008). The non-zero quantitativethresholds as identified in the paper range from 900 to 50,000 metric tons per year. The CAPCOApaper also identified non-zero qualitative thresholds.

The Scoping Plan states that, “The 2020 goal was established to be an aggressive, but achievable,mid-term target, and the 2050 GHG emissions reduction goal represents the level scientists believe isnecessary to reach levels that will stabilize climate” (ARB 2008, page 4). The 2050 goal is inExecutive Order S-3-05.

Attorney General. The Office of the California Attorney General maintains a list of CEQAMitigations for Global Warming Impacts on its website. The Attorney General’s Office has listedsome examples of types of mitigations that local agencies may consider to offset or reduce globalwarming impacts from a project. The Attorney General’s Office states that the lists are examples andnot intended to be exhaustive but instead are provided as measures and policies that could beundertaken. Moreover, the measures cited may not be appropriate for every project, so the AttorneyGeneral suggests that the lead agency should use its own informed judgment in deciding whichmeasures it would analyze, and which measures it would require, for a given project. The mitigationmeasures are divided into two groups: generally applicable measures and general plan measures.The Attorney General presents “generally applicable” measures in the following areas:

Energy efficiency Renewable energy Water conservation and efficiency Solid waste measures Land use measures Transportation and motor vehicles Carbon offsets

However, this project does not involve the development of a general plan, nor does it contain the landuses targeted by the Attorney General’s measures.

2.2.3 - San Joaquin Valley Air Pollution Control District (SJVAPCD)Climate Change Action Plan

On December 17, 2009, the SJVAPCD Governing Board adopted Guidance for Valley Land-useAgencies in Addressing GHG Emission Impacts for New Projects under CEQA, and the policy



District Policy – Addressing GHG Emission Impacts for Stationary Source Projects Under CEQAWhen Serving as the Lead Agency.

The SJVAPCD’s approach is intended to streamline the process of determining if project-specificgreenhouse gas emissions would have a significant effect. Projects exempt from the requirements ofCEQA, and projects complying with an approved plan or mitigation program would be determined tohave a less than significant cumulative impact. Such plans or programs must be specified in law oradopted by the public agency with jurisdiction over the affected resources and have a certified FinalCEQA document.

Best Performance Standards would be established according to performance-based determinations.Projects complying with Best Performance Standards would not require specific quantification ofgreenhouse gas emissions and would be determined to have a less than significant cumulative impactfor greenhouse gas emissions. Projects not complying with Best Performance Standards wouldrequire quantification of greenhouse gas emissions and demonstration that greenhouse gas emissionshave been reduced or mitigated by 29 percent, as targeted by ARB’s AB 32 Scoping Plan.Furthermore, quantification of greenhouse gas emissions would be required for all projects for whichthe lead agency has determined that an Environmental Impact Report is required, regardless ofwhether the project incorporates Best Performance Standards.

For stationary source permitting projects, Best Performance Standards means “The most stringent ofthe identified alternatives for control of greenhouse gas emissions, including type of equipment,design of equipment and operational and maintenance practices, which are achieved-in-practice forthe identified service, operation, or emissions unit class.” For development projects, BestPerformance Standards means “Any combination of identified greenhouse gas emission reductionmeasures, including project design elements and land use decisions that reduce project-specificgreenhouse gas emission reductions by at least 29 percent as compared to business as usual.” TheSJVAPCD proposes to create a list of all approved Best Performance Standards to help in thedetermination as to whether a proposed project has reduced its greenhouse gas emissions by 29percent. No timeline has been established for the development of said list.

San Joaquin Valley Carbon ExchangeThe SJVAPCD initiated work on the San Joaquin Valley Carbon Exchange in November 2008. Thepurpose of the carbon exchange is to quantify, verify, and track voluntary greenhouse gas emissionsreductions generated within the San Joaquin Valley. To investigate the various issues concerning thedevelopment of a mechanism to register greenhouse gas emission reductions, the SJVAPCD formed atechnical workgroup consisting of SJVAPCD staff, land use agency representatives, industryrepresentatives, agricultural representatives, environmental group representatives, and other interestedparties. The workgroup met several times in public meetings during late 2008 and early 2009 todiscuss several areas of concern regarding a greenhouse gas emission reduction registration program,including:



The differences between the upcoming AB 32 cap and trade program and a greenhouse gasemission reduction registration program.

Potential uses of registered greenhouse gas emission reductions. Registered greenhouse gasemission reductions could possibly be used to provide mitigation in the CEQA process, as ameans to comply with a greenhouse gas cap and trade program, or other purposes.

A review of other greenhouse gas emission reduction registration programs currently inexistence, including the Chicago Climate Exchange, New York Climate Exchange, NortheastClimate Exchange, Climate Action Reserve, and South Coast Air Quality ManagementDistrict’s SoCal Climate Solutions Exchange.

Required elements of a District-administered greenhouse gas emission reduction registrationprogram, including the establishment of criteria for greenhouse gas emission reductionregistration, the use of ARB protocols, and the requirement to quantify some emissionreductions.

The advantages and disadvantages of development of a greenhouse gas emission reductionregistration program.

Alternatives to the development of a District-administered greenhouse gas emission reductionregistration program were discussed, including the District’s possible role in California ClimateAction Reserve as an emission reduction project verifier and/or providing technical assistanceto project proponents quantify and mitigate their projects greenhouse gas emissions as part ofthe CEQA process.

While the Climate Change Action Plan indicated that the greenhouse gas emission reduction programwould be called the San Joaquin Valley Carbon Exchange, SJVAPCD staff has proposed toincorporate a method to register voluntary greenhouse gas emission reductions into its existing Rule2301 - Emission Reduction Credit Banking through amendments of the rule.

In its present draft form, the amendments to Rule 2301 would provide a mechanism to preservevoluntary, high-quality greenhouse gas emission reductions. The draft rule will allow the use ofregistered greenhouse gas emission reductions for any purpose and will not impose any restrictions ontheir use. The draft amendments to Rule 2301 will allow greenhouse gas emission reductions that fallinto two different categories to be registered with the SJVAPCD: non-protocol greenhouse gasemission reductions and protocol-based greenhouse gas emission reduction credits.

The non-protocol based reductions would be quantified using the criteria in Rule 2301; i.e., that theemission reductions be real, enforceable, permanent, surplus, and quantifiable. Emission reductionswould not be required to be additional; in other words, greenhouse gas emission reductions that occuras a collateral benefit of another requirement may qualify for registration, provided they are surplusof existing regulations. Emission Reduction Credits quantified without ARB-approved protocols



could likely be retired as one possible method to provide mitigation for a project’s greenhouse gasemissions as part of the CEQA process, if approved by the lead agency.

ARB approved greenhouse gas emission reduction project protocols include detailed procedures onhow to quantify emission reductions for specific project types and specific criteria to ensure that theemission reductions are additional. To date, there are three ARB-approved greenhouse gas emissionreduction project protocols: forestry preservation, urban forestry, and manure management.

The SJVAPCD has held two workshops on the proposed rule in May and June 2009. The SJVAPCDstaff expects to present the final rule to the Governing Board the first quarter of 2010.

2.3 - Emissions Trading and Carbon Offset Programs

Current and future emissions trading programs as well as carbon-offset programs are discussedbelow.

2.3.1 - Emissions Trading ProgramsAn emissions trading (or cap and trade) program is an approach for controlling emissions byproviding economic incentives for reducing emissions. Typically, a limit (or cap) is placed on thequantity of GHGs that can be emitted per year. The source emitters are then issued permits by thegoverning authority for a certain allowance of emissions. Source emitters can reduce their ownemissions and sell the excess or they can continue to emit high levels and purchase credits fromanother facility (a trade). There are several uncertainties regarding trading programs. Allowancesneed to be set at proper levels when a cap and trade program is initialized. Another uncertainty isdeciding who is regulated (power plants, the transportation sector, etc.).

2.3.2 - Carbon Trading ProgramsFuture carbon trading programs in the United States are being developed and are in operation.

Western Climate Initiative

The Western Climate Initiative was launched on February 26, 2007. Current partners includeArizona, British Columbia, California, Manitoba, Montana, New Mexico, Ontario, Oregon, Quebec,Utah, and Washington. Members of the Initiative plan on collaborating to identify, evaluate, andimplement ways to reduce GHGs in the states collectively and to achieve related co-benefits. Amulti-state registry will track, manage, and credit entities that reduce GHGs. The Initiative publishedits regional GHG reduction goals on August 22, 2007, which include a reduction of 15 percent below2005 levels by 2020 (WCI 2007). The WCI prepared design recommendations for the WCI RegionalCap-and-Trade Program (WCI 2008).

Regional Greenhouse Gas Initiative

The Regional Greenhouse Gas Initiative (RGGI) is the first mandatory, market-based effort in theUnited States to reduce GHG emissions. Ten Northeastern and Mid-Atlantic states will cap and then



reduce carbon dioxide emissions from the power sector 10 percent by 2018 (RGGI 2009). States willsell emission allowances through auctions and invest proceeds in consumer benefits: energyefficiency, renewable energy, and other clean energy technologies.

Chicago Climate Exchange

The Chicago Climate Exchange (CCX) operates North America’s only cap and trade system for allsix GHGs, with global affiliates and projects worldwide (CCX 2009). The commodity traded at CCXis the CFI contract, each of which represents one MTCO2e. Trading volumes have increased sincethe CCX was established in 2003. The price of a CFI has ranged from $1 to $4.50 per MTCO2e. Theprice on January 21, 2009 was $2.

Cap and Trade Program in California

California is exploring the possibility of a cap and trade system for GHGs. The Market AdvisoryCommittee to the ARB published recommendations for designing a mandatory GHG cap and tradesystem for California (MAC 2007), as follows:

The program should eventually include all major GHG-emitting sectors of the economy in thecap-and-trade program.

To address emissions associated with imported electricity within a state-based cap-and-tradeprogram, the Committee recommends a “first-seller approach.” Under this approach, the entitythat first sells electricity in the state is responsible to meet the compliance obligationestablished under the GHG cap-and-trade program.

The Committee recommends a combined approach in which some share of allowances isallocated free of charge initially, while the remaining allowances are auctioned. Thepercentage of allowances auctioned should then increase over time.

The Committee recommends that California’s cap-and-trade program recognize offsetsgenerated both within and outside the state’s borders.

California should encourage linkages with other mandatory GHG cap–and- trade systems.

The Committee recommends the use of very stringent criteria for determining whetheractivities qualify as offsets. (MAC 2007)

The program could include the upstream transportation sector, which would regulate petroleumrefiners and importers of refined products. It could also cover the distribution of natural gas.

San Joaquin Valley Carbon Exchange

As discussed above, the SJVAPCD is developing the SJVCE Program, and expects to present thefinal rule to the Governing Board the first quarter of 2010.

San Joaquin County - KRC Mine ExpansionClimate Change Analysis Report Thresholds of Significance


SECTION 3: THRESHOLDS OF SIGNIFICANCE

CEQA requires that Lead Agencies inform decision makers and the public regarding potentialsignificant environmental effects of proposed projects and feasible ways that environmental damagecan be avoided or reduced, through feasible mitigation measures and/or project alternatives. TheLead Agencies must also disclose the reasons why a project is approved if significant environmentaleffects are involved (CEQA Guidelines Section 15002). CEQA also requires Lead Agencies toevaluate potential environmental effects based on, to the fullest extent possible, scientific and factualdata (CEQA Guidelines Section 15064[b]). Significance conclusions must be based on substantialevidence, which includes facts, reasonable assumptions predicated upon facts, and expert opinionsupported by facts (CEQA Guidelines Section 15064f (5)).

The thresholds to be used for this project are as follows:

Would the project:

(a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significantimpact on the environment?

(b) Conflict with any applicable plan, policy or regulation of an agency adopted for the purposeof reducing the emissions of greenhouse gases?

Pursuant to CEQA Guidelines 15064(h)(3), a Lead Agency may determine that a project’sincremental contribution to a cumulative effect is not cumulatively considerable if the project wouldcomply with the requirements in a previously approved plan or mitigation program that providesspecific requirements that will avoid or substantially lessen the cumulative problem within thegeographic area in which the project is located.

There is currently no specific numeric threshold for GHG emissions, above which a project would beconsidered to have a significant impact on the environment. The SJVAPCD’s guidance for assessingGHG emissions is not used to determine significance for the first impact criterion, as the guidancewas developed to address development-type projects (such as residential or commercial projects) andstationary sources—the project is neither. Therefore, the guidance is not applicable to the project.

For the second impact criterion, the County of San Joaquin does not have an applicable plan, policy,or regulation adopted to reduce the emissions of greenhouse gases. Therefore, project consistencywith the adopted Scoping Plan will be used to determine whether the project generates greenhousegas emissions, either directly or indirectly, that may have a significant impact on the environment.

As discussed in the Regulatory Section, ARB adopted the Climate Change Scoping Plan (ScopingPlan), which outlines actions recommended to obtain that the emission reduction goals contained inAB 32. The Scoping Plan states, “The 2020 goal was established to be an aggressive, but achievable,

San Joaquin County - KRC Mine ExpansionThresholds of Significance Climate Change Analysis Report


mid-term target, and the 2050 greenhouse gas emissions reduction goal represents the level scientistsbelieve is necessary to reach levels that will stabilize climate” (ARB 2008, page 4). The year 2020goal of AB 32 corresponds with the mid-term target established by S-3-05, which aims to reduceCalifornia’s fair-share contribution of greenhouse gases in 2050 to levels that will stabilize theclimate. The goal of reducing emissions by 80 percent by the year 2050 is not used in this analysis.To obtain those emission reductions, substantial emission reductions would need to occur inCalifornia, such as a conversion of alternative energy generation, conversion to electric and/or zeroemission motor vehicles, and substantial changes to land use patterns and transportation. It is not theobjective of this project to implement those things. In addition, there is currently no framework ormethodology to analyze project-level contributions to climate change in relation to the 2050 emissionreduction goal.

San Joaquin County - KRC Mine ExpansionClimate Change Analysis Report Impact Analysis


SECTION 4: IMPACT ANALYSIS

4.1 - Greenhouse Gas Inventories

The threshold of significance used in this report is based on AB 32; therefore, this analysis isrestricted to GHGs identified by AB 32, which include carbon dioxide, methane, nitrous oxide,hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.

The project would generate a variety of GHGs during construction and operation, including severaldefined by AB 32, such as carbon dioxide, methane, and nitrous oxide.

The project may also emit GHGs that are not defined by AB 32. For example, the project maygenerate aerosols. Aerosols are short-lived GHGs, as they remain in the atmosphere for about oneweek. Black carbon is a component of aerosol. A couple of studies have indicated that black carbonhas a high global warming potential; however, the IPCC states that it has a low level of scientificcertainty (IPCC 2007a). Water vapor could be emitted from evaporated water used for landscaping,but this is not a significant impact because water vapor concentrations in the upper atmosphere areprimarily due to climate feedbacks rather than emissions from project-related activities. The projectwould emit nitrogen oxides and volatile organic compounds, which are ozone precursors. Ozone is aGHG; however, unlike the other GHGs, ozone in the troposphere is relatively short-lived and can bereduced in the troposphere daily.

Certain GHGs defined by AB 32 would not be emitted by the project. Perfluorocarbons and sulfurhexafluoride are typically used in industrial applications, none of which would be used by the project.Therefore, it is not anticipated that the project would emit perfluorocarbons or sulfur hexafluoride.

An inventory of GHG emissions generated by the project is presented below. The emissions areestimated and are converted to metric tons of MTCO2e using the formula:

MTCO2e = (tons of gas) x GWP x (0.9072 metric tons of gas)

Construction-generated and on-road mobile emissions were calculated using the methodologyprovided in the KRC Mine Expansion Air Quality Analysis (MBA 2010b). The on-road mobileinventory used the current version of the EMission FACtors model (EMFAC2007), and the off-roadmobile inventory used the OFFROAD model for base emission factors. Both the EMFAC andOFFROAD Models develop CO2 and CH4 emission estimates; however, they are not currently usedas the basis for ARB’s official GHG inventory, which is based on fuel usage information.

The current version of EMFAC applies a single CO2 factor that is unchanged throughout future years.ARB did not find technology enhancements for vehicles affect change in CO2 output. This isprimarily because CO2 is calculated stoichiometrically based on carbon content of fuel.

San Joaquin County - KRC Mine ExpansionImpact Analysis Climate Change Analysis Report


In addition, EMFAC does not include reductions of the carbon content of the fuels in future years.Since CO2 is calculated on carbon content of fuel, it is assumed that the Executive Order S-1-07, theLow Carbon Fuel Standard (issued on January 18, 2007) that calls for a reduction of at least 10percent in the carbon intensity of California’s transportation fuels by 2020, will be implemented, andall diesel vehicles will be using the lower carbon fuel and the resultant CO2 emissions will beproportionally reduced.

Similarly, the OFFROAD model does not modify the CO2 emission factors by year. In addition, theOFFROAD model does not reflect newer in-use rules and regulations, such as the In-Use Off-RoadDiesel Vehicle regulation. ARB is working towards reconciling the emission estimates from the fuelusage approach and the models.

Future-year inventories of exhaust-generated emissions (both on and off-road mobile) show areduction of pollutants on a per-activity basis. Therefore, it is reasonable to assume that the EMFACand OFFROAD models overestimate GHG emissions in future years.

4.1.1 - Construction-GeneratedThe project would emit GHGs from upstream emission sources and direct sources (combustion offuels from worker vehicles and construction equipment). An upstream emission source (also knownas life cycle emissions) refers to emissions that were generated during the manufacture of products tobe used for construction of the project. The upstream emissions were not estimated because they arenot within the control of the project and to do so would be speculative at this time. Additionally, theCAPCOA White Paper on CEQA & Climate Change supports this conclusion by stating, “The fulllife-cycle of GHG [greenhouse gas] emissions from construction activities is not accounted for . . .and the information needed to characterize [life-cycle emissions] would be speculative at the CEQAanalysis level” (CAPCOA 2008). Therefore, pursuant to CEQA Guidelines Sections 15144 and15145, upstream/life cycle emissions are speculative and no further discussion is necessary.

GHG emissions from construction were estimated using URBEMIS using the methodology describedin EIR Appendix C.1. The amount of CO2 was calculated for soil removal, aggregate excavation, andreclamation activities.

The inventory for soil removal, aggregate excavation, and reclamation activities are shown in Table 7below. Emissions of nitrous oxide and methane are negligible. The emissions are from all phases ofconstruction. As shown below, construction-generated emissions vary year to year, but decreasetowards the end of the life of the project. Soil removal, aggregate excavation, and reclamationactivities would generate approximately 6,526 metric tons of CO2 over the life of the project. Thetotal emissions may not equal a straight addition of the annual emissions due to rounding.



Table 7: Soil Removal, Aggregate Excavation, and Reclamation Emissions

Carbon Dioxide EmissionsYear

Tons MTCO2e

2014 721 654

2015 980 889

2016 1,147 1,041

2017 1,018 924

2018 631 572

2019 710 645

2020 537 487

2021 748 679

2022 507 460

2023 184 167

2024* 11 10

Total 7,194 6,526

Notes:* Internal haul road reclamationEmissions are rounded to the nearest ton.MTCO2e = metric tons of carbon dioxide equivalent, converted from tons by multiplying by 0.9072 and the globalwarming potential of 1.Source: MBA 2010b.

4.1.2 - On-Road MobileThere are two types of on-road trip generation from the project and materials processing facility—employee trips and aggregate hauling trips. The materials processing facility generates the aggregatehauling trips, and employee trips are generated by both the facility and the construction activity.

The air quality analysis methodologies for each are described below. Data from the project’s TIS,hauling capacity, and annual excavation quantities were utilized to estimate air pollutant generationassociated with operation of the materials processing facility. Emissions were estimated for the 2014through 2020, and for 2025. After year 2020, URBEMIS contains only 5-year interval model yearsfor operational activities. Therefore, emissions for 2021, 2022, and 2023 were interpolated using2020 and 2025 emissions.

All On-Road Emissions

The emissions of carbon dioxide from all worker vehicles are shown in Table 8 below. Emissions ofcarbon dioxide from the on-road hauling of aggregate are shown in Table 9. Emissions of nitrousoxide and methane are negligible. Total employee-generated CO2 emissions would slightly increasebetween 2009 and 2020, then decrease after 2020. The total increase between 2009 and 2020 is lessthan 0.5 metric ton CO2. For on-road aggregate hauling, the emissions modeling shows variation in



annual CO2 emissions, which is directly resultant from the volume of materials to be excavated andhauled that year. Please note that due to rounding, the total emissions may not equal a straight-addition of the annual emissions.

Table 8: Annual Employee Trip Emissions


Tons MTCO2e

2014 48 43

2015 48 43

2016 48 43

2017 48 44

2018 48 44

2019 48 44

2020 48 44

2021 48 43

2022 47 43

2023 47 43

Total Employee Trips 478 434

Notes:All Employee trips includedYears 2021-2023 were interpolated from year 2020 and 2025 output.Emissions are rounded to the nearest ton.MTCO2e = metric tons of carbon dioxide equivalent, converted from tons by multiplying by 0.9072 and the globalwarming potential of 1.Source: MBA 2010b.

Table 9: Annual On-Road Hauling Emissions


Tons MTCO2e

2014 2,431 2,205

2015 3,182 2,886

2016 3,472 3,150

2017 3,274 2,970

2018 1,945 1,764

2019 2,184 1,982

2020 1,547 1,403



Table 9 (cont.): Annual On-Road Hauling Emissions


Tons MTCO2e

2021 2,330 2,114

2022 2,330 2,114

2023 2,330 2,114

Notes:Years 2021-2023 were interpolated from year 2020 and 2025 output.Emissions are rounded to the nearest ton.MTCO2e = metric tons of carbon dioxide equivalent, converted from tons by multiplying by 0.9072 and the globalwarming potential of 1.Source: MBA 2010b.

4.1.3 - Project BaselineNo changes, additions, or increase in annual activity of the materials processing facility is proposed aspart of the project. The project would extend the life of the aggregate processing facility toaccommodate additional resources. As the project would extend the life of an existing permittedfacility, a baseline was prepared to estimate emissions from the existing excavation and operationalactivities resulting from the existing permitted site. The baseline was developed from the averageactivity of the last 9 years (2001 through 2009). The emissions calculation methodology fordeveloping the baseline emissions is detailed in Appendix C-1.

Emissions were generated for the operational activities associated with the existing permitted facilityand current levels of aggregate production, as described in Appendix C.1. Baseline emissionsgenerated by employee trips, on-road aggregate hauling, and excavation activities are provided inTable 10.

Table 10: Baseline Emissions


Tons MTCO2e

Employee Trips 48 43

On-Road Hauling 2,330 2114

Excavation 513 465

Total Emissions 2,891 2,623Source: MBA, 2010; URBEMIS Output.

4.1.4 - Total Project InventoryThe total project-generated CO2 inventory is provided in Table 11. Please note that due to rounding,the total emissions may not equal a straight-addition of the annual emissions.



Table 11: Total Project-Generated Emissions

Year Carbon DioxideEmissions (tons) Emissions (MTCO2e)

2014 3,200 2,903

2015 4,209 3,819

2016 4,667 4,234

2017 4,340 3,937

2018 2,623 2,380

2019 2,943 2,670

2020 2,132 1,934

2021 3,126 2,836

2022 2,884 2,617

2023 2,561 2,323

2024 11 10

Total 32,696 29,662

Notes:Years 2021-2024 were interpolated from year 2020 and 2025 output.Emissions are rounded to the nearest ton.MTCO2e = metric tons of carbon dioxide equivalent, converted from tons by multiplying by 0.9072 and the globalwarming potential of 1.Source: MBA 2010b.

As shown in the table, estimated project-generated emissions vary between approximately 11 and4,667 MTCO2e per year. The main source of GHG emissions is on-road hauling. At year 2020, theproject would generate approximately 1,934 MTCO2e, or approximately 0.0003 percent of the State’sprojected business as usual emissions.

Table 12 contains a comparison of the project emissions in relation to the baseline emissions. Someyears would generate more greenhouse gas emissions than the baseline, other years less. Overall, theproject emissions profile does not represent a significant departure or increase above the existingbaseline. The project would not increase the rate of emissions from the project site, but only extendthe life of the existing facilities. Therefore, the project’s generation of greenhouse gas emissions areless than significant.

Table 12: Project-Generated Emissions Above Baseline


2014 309 280

2015 1,318 1,196



Table 12 (cont.): Project-Generated Emissions Above Baseline


2016 1,776 1,611

2017 1,449 1,314

2018 -268 -243

2019 52 47

2020 -759 -689

2021 235 213

2022 -7 -6

2023 -330 -300

2024 -2,880 -2,613Notes:Years 2021-2024 were interpolated from year 2020 and 2025 output.Emissions are rounded to the nearest ton.MTCO2e = metric tons of carbon dioxide equivalent, converted from tons by multiplying by 0.9072 and the globalwarming potential of 1.Source: MBA 2010b.

As stated previously, the EMFAC and OFFROAD models do not adjust the CO2 emission factors forfuture years. Therefore, it is reasonable to assume that the emissions estimates provided above arehigher than what would result from the adjusted EMFAC and OFFROAD models that ARB iscurrently developing.

4.2 - Significance Analysis

4.2.1 - Greenhouse Gas EmissionsAs provided in the emissions analysis above, the project emissions profile does not represent asignificant departure or increase above the existing baseline. The project would not increase the rateof emissions from the project site, but would only extend the life of the existing facilities. Therefore,the project’s generation of greenhouse gas emissions are less than significant.

SignificanceLess than significant

4.2.2 - Consistency with Applicable PlanAs discussed in Section 3, Thresholds of Significance, the significance for this criterion is based onwhether or not the project would significantly hinder or delay California’s ability to implement theARB’s Scoping Plan.



Project History

The project area has been used continuously for aggregate extraction and processing since before1990. Annual production records are not available for the materials processing facility prior toKRC’s purchase of the facility in 1993. The maximum daily output from the quarry is approximately5,000 tons. The proposed project would not change the annual activity of the existing materialsprocessing facility. The volume of aggregate extracted and processed varies by year-to-year,depending upon market conditions. However, the difference between sequential years is notdramatic. Therefore, it is reasonable to assume that in 1990, the materials processing facility operatedat a relatively similar rate to the 1993 and post-1993 volumes.

Project Location

The project site is located close to the major destinations of the produced aggregate, Lodi andStockton. Lodi is located approximately 13 miles west of the materials processing facility, andStockton is approximately 20 miles southwest of the facility. According to the Traffic Impact Studyprepared by KD Anderson and Associates, approximately 64 percent of the on-road hauling tripstravel to the Stockton area, while just over 12 percent travel to the Lodi area. In all, the aggregatedeliveries remain local to the project area. Consistent with the methodology contained in the AirQuality Analysis Report (MBA 2010b), the average on-road haul trip length was estimated to be 19.6miles.

Project Inventory

The project will emit GHG emissions during internal haul road construction, aggregate extraction,and reclamation. In addition, the project would contribute GHG emissions from employee trips. Asshown above, the project would generate 29,662 MTCO2e over the life of the project. At year 2020,AB 32’s target year, the project would generate approximately 1,934 MTCO2e. As stated in theinventory analysis, the emission factors used for the analysis are constant in future years althoughARB recognizes a need to reconcile those emission factors with the calculations used to develop thestatewide GHG inventories. Based on increased engine efficiencies in future years, it is reasonable toconclude that the project’s future year inventories are overestimated.

Project TypeAs a non-metals mining project, the project is not in a major GHG-contributing sector, as described inthe Scoping Plan. Mining contributed less than 0.3 percent of the total industrial inventory between2001 and 2006, and approximately than 0.07 percent of the total statewide inventory in the sameperiod. Non-metals mining is the second-largest sub sector of mining, following metals mining. Asof 2006, non-metals mining generated approximately 0.02 percent of the total statewide GHGinventory.

In addition, the Scoping Plan’s recommended measures mainly target reductions in the transportationand electricity sectors. Implementation of certain Scoping Plan measures may obliquely affect the



project, such as the low carbon fuel standard (as discussed above). However, none of the measuresare directly applicable to the project. Therefore, “early implementation” of recommended measures isnot applicable to the project.

Significance

Less than significant.

AB 32 requires that California’s emissions be reduced to 1990 levels by the year 2020. Theemissions in the State of California are projected to be 596 MMTCO2e in 2020 and the estimatedemissions in 1990 were 427 MMTCO2e. Although some GHGs can remain in the atmosphere forlong periods, AB 32 does not regulate concentrations.

The project would not significantly hinder or delay the State’s ability to meet the reduction targetscontained in AB 32 for the following reasons:

The project is considered a part of the non-metals subset of the mining subsector, in theindustrial sector. The recommended measures in the adopted Scoping Plan are not applicableto the project. Therefore, there are not any specific benchmark or percentage reductionsapplicable to the project.

The project would emit approximately 1,934 MTCO2e in 2020, a very low level of emissions.

The project would result in continuation of an existing land use that was operational in 1990,and likely operated at a similar level in 1990. Because of increased efficiencies in future yearengines, the project would likely result in less GHG emissions per unit of activity in 2020 thancurrent year or 1990.

San Joaquin County - KRC Mine ExpansionClimate Change Analysis Report References


SECTION 5: REFERENCES

The following references were used in the preparation of this analysis and are referenced in the textand/or were used to provide the author with background information necessary for the preparation ofthresholds and content.

ARB 2009 California Air Resources Board. Greenhouse Gas Emission Inventory - QueryTool for Years 2000 to 2006 (Version 2): Included Emissions and Sinks.Website: http://www.arb.ca.gov/app/ghg/2000_2006/ghg_sector.php. AccessedMay 25, 2009.

ARB 2008 California Air Resources Board. 2008. Climate Change Scoping Plan, aframework for change as approved December 2008. December. Website:www.arb.ca.gov/cc/scopingplan/document/scopingplandocument.htm.

ARB 2007 California Air Resources Board. Expanded List of Early Action Measures toReduce Greenhouse Gas Emissions in California Recommended for BoardConsideration. October 2007. Website: www.arb.ca.gov/cc/ccea/meetings/ea_final_report.pdf. Accessed January 21, 2009.

ARB 2004 California Air Resources Board. 2004. Fact Sheet, Climate Change EmissionControl Regulations. December 10.

CA 2006 State of California. August 31, 2006. Assembly Bill No. 32. Website:www.arb.ca.gov/cc/docs/ab32text.pdf. Accessed January 21, 2009.

CA 2005 State of California, Executive Order S-3-05. June 1, 2005. Website:www.dot.ca.gov/hq/energy/ExecOrderS-3-05.htm. Accessed January 21, 2009.

CAPCOA 2008 California Air Pollution Control Officers Association. January 2008. CEQA &Climate Change, Evaluating and Addressing Greenhouse Gas Emissions fromProjects Subject to the California Environmental Quality Act. www.capcoa.org/,Accessed January 21, 2009.

CAT 2006 State of California, Environmental Protection Agency, Climate Action Team.March 2006. Climate Action Team Report to Governor Schwarzenegger and theCalifornia Legislature. Website: www.climatechange.ca.gov/climate_action_team/reports/index.html. Accessed January 21, 2009.

CCCC 2006 California Climate Change Center. Our Changing Climate, Assessing the Risks toCalifornia: A Summary Report from the California Climate Change Center. July

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2006. CEC-500-2006-077. Website: www.climatechange.ca.gov/publications/biennial_reports/index.html. Accessed January 21, 2009.

CCX 2009 Chicago Climate Exchange. 2009. Overview. Website:www.chicagoclimateexchange.com/content.jsf?id=821. Accessed in January2009.

CEC 2007 California Energy Commission. January 23, 2007. Memorandum RegardingRevisions to the 1990 to 2004 Greenhouse Gas Inventory Report, Published inDecember 2006. Website: http://www.energy.ca.gov/2006publications/CEC-600-2006-013/2007-01-23_GHG_INVENTORY_REVISIONS.PDF. AccessedJanuary 21, 2009.

CEC 2006 California Energy Commission. December 2006. Inventory of CaliforniaGreenhouse Gas Emissions and Sinks: 1990 to 2004. Staff Final Report. CEC-600-2006-013-SF. Website: www.energy.ca.gov/2006publications/CEC-600-2006-013/CEC-600-2006-013-SF.PDF. Accessed January 22, 2009.

EPA 2008 U.S. Environmental Protection Agency. Inventory of U.S. Greenhouse gasEmissions and Sinks: 1990-2006. April 2008. USEPA #430-R-08-005. Website:www.epa.gov/climatechange/emissions/usinventoryreport.html. AccessedJanuary 22, 2009.

EPA 2007 U.S. Environmental Protection Agency. Inventory of U.S. Greenhouse GasEmissions and Sinks: 1990-2005. Executive Summary. April 2007. USEPA#430-R-07-002. Website: www.epa.gov/climatechange/emissions/usgginv_archive.html. Accessed January 22, 2009.

EPA 2006 U.S. Environmental Protection Agency, Office of Atmospheric Programs. April2006. The U.S. Inventory of Greenhouse Gas Emissions and Sinks: Fast Facts.Website: http://epa.gov/climatechange/emissions/downloads06/06FastFacts.pdf.Accessed January 21, 2009.

IPCC 2007a Intergovernmental Panel on Climate Change, 2007: Summary for Policymakers.In: Climate Change 2007: The Physical Science Basis. Contribution of WorkingGroup I to the Fourth Assessment Report of the Intergovernmental Panel onClimate Change (Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B.Averyt, M. Tignor and H.L. Miller [eds.]). Cambridge University Press:Cambridge, United Kingdom and New York, NY, USA.

IPCC 2007b Parry, M.L., O.F. Canziani, J.P. Palutikof, et al. 2007: Technical Summary.Climate Change 2007: Impacts, Adaptations and Vulnerability. Contribution of

San Joaquin County - KRC Mine ExpansionClimate Change Analysis Report References


Working Group II to the Fourth Assessment Report of the IntergovernmentalPanel on Climate Change, M.L. Parry, O.F. Canziani, J.P. Palutikof, P.J. van derLinden and C.E. Hanson, Eds., Cambridge University Press, Cambridge, UK, pp.23-78.

KDA 2009 KD Anderson & Associates. 2009. Traffic Impact Study for the KRC AggregatesProject. April 9.

MAC 2007 Market Advisory Committee for the California Air Resources Board.Recommendations for Designing a Greenhouse Gas Cap-and-Trade System forCalifornia. June 30, 2007. Website: www.energy.ca.gov/2007publications/ARB-1000-2007-007/ARB-1000-2007-007.PDF. Accessed January 21, 2009.

MBA 2010a Michael Brandman Associates. KRC Mine Expansion Environmental ImpactReport.

MBA 2010b Michael Brandman Associates. KRC Mine Expansion Air Quality AnalysisReport.

RGGI 2009 Regional Greenhouse Gas Initiative. 2009. Website: www.rggi.org/home.Accessed in January 2009.

UNFCCC 2006 United Nations Framework Convention on Climate Change. 2006. GreenhouseGas Emissions Data, Predefined Queries, Annex I Parties - greenhouse gas totalwithout LULUCF (land use, land-use change, and forestry). Website:http://unfccc.int/ghg_emissions_data/predefined_queries/items/3841.php.Accessed January 22, 2009.

WCI 2008 Western Climate Initiative. 2008. Design Recommendations for the WCIRegional Cap-and-Trade Program. Website: www.westernclimateinitiative.org/ewebeditpro/items/O104F20432.PDF. Accessed January 21, 2009.

WCI 2007 Western Climate Initiative. August 22, 2007. Statement of Regional Goal.Website: http://www.westernclimateinitiative.org/ewebeditpro/items/O104F13006.pdf. Accessed January 21, 2009.