iv. environmental impact analysis

700 University Avenue Mixed-Use Project IV.B Air Quality Draft Environmental Impact Report Page IV.B-1

IV. ENVIRONMENTAL IMPACT ANALYSIS B. AIR QUALITY

INTRODUCTION

In addition to providing original information, this section incorporates information presented in the following reports (included in Appendix IV.B):

• Off-Site Consequence Analysis/Air Quality Assessment, Levine-Fricke, March 18, 2004.

• Supplemental Off-Site Consequence Analysis/Air Quality Assessment, Levine-Fricke, March 2, 2006.

REGULATORY SETTING

The Federal Clean Air Act governs air quality in the United States and is administered by the United States Environment Protection Agency (U.S. EPA). In addition to being subject to federal requirements, air quality in California is also governed by more stringent regulations under the California Clean Air Act, which is administered by the California Air Resources Board (CARB) at the State level and by the Air Quality Management Districts at the regional and local levels. The Bay Area Air Quality Management District (BAAQMD) regulates air quality at the regional level, which includes the nine-county Bay Area.

United States Environmental Protection Agency

In addition to administering the Federal Clean Air Act, the U.S. EPA is also responsible for establishing the National Ambient Air Quality Standards, required under the 1977 Federal Clean Air Act and subsequent amendments. The U.S. EPA regulates emission sources that are under the exclusive authority of the Federal government, such as aircraft, ships, and certain types of locomotives. The agency has jurisdiction over emission sources outside state waters (e.g., beyond the outer continental shelf) and establishes various emission standards, including those for vehicles sold in states other than California.

California Air Resources Board

In California, the CARB, which became part of the California Environmental Protection Agency (CalEPA) in 1991, is responsible for meeting the state requirements of the Federal Clean Air Act, administering the California Clean Air Act, and establishing the California Ambient Air Quality Standards. The California Clean Air Act, as amended in 1992, requires all air districts in the State to endeavor to achieve and maintain the California Ambient Air Quality Standards (discussed later in this section). The CARB regulates mobile air pollution sources, such as motor vehicles. The agency is responsible for setting emission standards for vehicles sold in California and for other emission sources,

City of Berkeley May 2006


such as consumer products and certain off-road equipment. The CARB established passenger vehicle fuel specifications, which became effective on March 1996. The CARB oversees the functions of local air pollution control districts and air quality management districts, which in turn administer air quality activities at the regional and county level. It also sets fuel specifications to further reduce vehicular emissions.

Bay Area Air Quality Management District

In 1955, the California Legislature created the BAAQMD. The agency is primarily responsible for assuring that the National and State ambient air quality standards are attained and maintained in the Bay Area. The BAAQMD is also responsible for adopting and enforcing rules and regulations concerning air pollutant sources, issuing permits for stationary sources of air pollutants, inspecting stationary sources of air pollutants, responding to citizen complaints, monitoring ambient air quality and meteorological conditions, awarding grants to reduce motor vehicle emissions, conducting public education campaigns, as well as many other activities. The BAAQMD has jurisdiction over much of the nine-county Bay Area.

Mobile sources, both off-and on-road are not subject to BAAQMD authority. The BAAQMD’s rules and regulations that may apply to the proposed project are described below.

• Permitting: Rule 2-1-301 requires that any person installing, modifying, or replacing any equipment (such as boilers), the use of which may reduce or control the emission of air contaminants, shall first secure written authorization from the Air Pollution Control Officer.

• New Source Review: Rule 2-2, New Source Review applies to all new and modified sources or facilities (such as boilers) that are subject to the requirements of Rule 2-1-301. The purpose of the rule is to provide for review of such sources and to provide mechanisms by which no net increase in emissions will result.

• Prohibitory Rules: Regulation 6 pertains to particulate matter and visible emissions and limits the quantity of particulate matter emitted into the atmosphere through the establishment of limitations on emission rates, concentration, visible emissions, and opacity. This rule applies to construction projects.

• Prohibitory Rules: Regulation 11, Rule 2 pertains to demolition or renovation of facilities with asbestos containing materials. The rule establishes handling and reporting procedures to control emissions of asbestos during demolition or renovation projects.

National and State Ambient Air Quality Standards

As required by the Federal Clean Air Act, the National Ambient Air Quality Standards have been established for six major air pollutants: carbon monoxide (CO), nitrogen oxides (NOx), ozone (O3), respirable particulate matter (PM10), fine particulate matter (PM2.5), sulfur oxides (SO2), and lead. The



California Ambient Air Quality Standards apply to these same six criteria and also address sulfate (SO42-),

visibility, hydrogen sulfide (H2S), and vinyl chloride (C2H3Cl). The California Clean Air Act standards are more stringent than the Federal standards and, in the case of PM10 and SO2, far more stringent. Both Federal and State standards are summarized in Table IV.B-1. The “primary” standards have been established to protect the public health. The “secondary” standards are intended to protect the nation’s welfare and account for air pollutant effects on soil, water, visibility, materials, vegetation and other aspects of the general welfare. The National Ambient Air Quality Standards are applicable if a project is federally funded or requires federal action. The proposed project is not federally funded and does not require federal action. Additionally, the California Ambient Air Quality Standards are more stringent than the National Ambient Air Quality Standards. Thus, the California Ambient Air Quality Standards are used as the comparative standard in the analysis contained in this report.

Criteria Air Pollutants & Effect

Air quality studies generally focus on five pollutants that are most commonly measured and regulated: CO, O3, NO2, SO2, and PM10 and PM2.5.

Carbon Monoxide. CO, a colorless and odorless gas, interferes with the transfer of oxygen to the brain. It can cause dizziness and fatigue, and can impair central nervous system functions. CO is emitted almost exclusively from the incomplete combustion of fossil fuels. Automobile exhausts release approximately 70 percent of the CO in the Bay Area. A substantial amount also comes from burning wood in fireplaces and wood stoves. CO is a non-reactive air pollutant that dissipates relatively quickly, so ambient CO concentrations generally follow the spatial and temporal distributions of vehicular traffic. The highest CO concentrations measured in the Bay Area are typically recorded during the winter.

Ozone. O3, a colorless toxic gas, is the chief component of urban smog. O3 enters the blood stream and interferes with the transfer of oxygen, depriving sensitive tissues in the heart and brain of oxygen. Although O3 is not directly emitted, it forms in the atmosphere through a chemical reaction between reactive organic gas (ROG) and NOx under sunlight. ROG and NOx are primarily emitted from automobiles and industrial sources. O3 is present in relatively high concentrations within the Bay Area, and the damaging effects of photochemical smog are generally related to the concentration of O3. Highest O3 concentrations occur during summer and early autumn, on days with low wind speeds or stagnant air, warm temperatures, and cloudless skies.

Nitrogen Dioxide. NO2, a reddish-brown gas, irritates the lungs. It can cause breathing difficulties at high concentrations. Like O3, NO2 is not directly emitted, but is formed through a reaction between nitric oxide (NO) and atmospheric oxygen. NO and NO2 are collectively referred to as nitrogen oxides (NOx) and are major contributors to O3 formation. NO2 also contributes to the formation of PM10 (see discussion of PM10 below).



Table IV.B-1 Ambient Air Quality Standards

National Standards (a)

Pollutant Averaging Time California Standards Primary (b,c) Secondary (b,d)

8-hour — 0.08 ppm

(176µg/m3) —

Ozone 1-hour 0.09 ppm

(180 µg/m3) 0.12 ppm

(235 µg/m3) Same as primary

8-hour 9 ppm (10 mg/m3)

9 ppm (10 mg/m3) —

Carbon monoxide 1-hour 20 ppm

(23 mg/m3) 35 ppm

(40 mg/m3) —

Annual — 0.053 ppm (100 µg/m3) Same as primary

Nitrogen dioxide 1-hour 0.25 ppm

(470 µg/m3) — —

Annual — 0.03 ppm (80 µg/m3) —

24-hour 0.04 ppm (105 µg/m3)

0.14 ppm (365 µg/m3) —

3-hour — — 0.5 ppm (1,300 µg/m3)

Sulfur dioxide

1-hour 0.25 ppm (655 µg/m3) — —

Annual

20 µg/m3

(geometric mean) 50 µg/m3

(arithmetic mean) Same as primary PM1024-hour 50 µg/m3 150 µg/m3 Same as primary Annual — 15 µg/m3 PM2.5 24-hour — 65 µg/m3

Calendar quarter — 1.5 µg/m3 Same as primary Lead 30-day average 1.5 µg/m3 — — Notes: (a) Standards, other than for ozone and those based on annual averages, are not to be exceeded more than once a

year. The ozone standard is attained when the expected number of days per calendar year with maximum hourly average concentrations above the standard is equal to or less than one.

(b) Concentrations are expressed first in units in which they were promulgated. Equivalent units given in parenthesis.

(c) Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. Each state must attain the primary standards no later than 3 years after that state’s implementation plan is approved by the EPA.

(d) Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.

Sulfur Oxides. Sulfur oxides, primarily SO2, are a product of high-sulfur fuel combustion. The main sources of SO2 are coal and oil used in power stations, in industries, and for domestic heating. SO2 is an irritant gas that attacks the throat and lungs. It can cause acute respiratory symptoms and diminished ventilator function in children. SO2 concentrations have been reduced to levels well below the state and national standards, but further reductions in emissions are needed to attain compliance with standards for PM10, of which SO2 is a contributor.



Suspended Particulate Matter. Particulate matter pollution consists of very small liquid and solid particles suspended in the air, which can include smoke, soot, dust, salts, acids, and metals. Particulate matter also forms when industry and gases emitted from motor vehicles undergo chemical reactions in the atmosphere. PM10 and PM2.5 represent fractions of particulate matter. PM10 refers to particulate matter less than 10 microns in diameter, about one/seventh the thickness of a human hair. PM2.5 refers to particulate matter that is 2.5 microns or less in diameter. Major sources of PM10 include motor vehicles; wood burning stoves and fireplaces; dust from construction, landfills, and agriculture; wildfires and brush/waste burning, industrial sources, windblown dust from open lands, and atmospheric chemical and photochemical reactions. PM2.5 results primarily from diesel fuel combustion (from motor vehicles, power generation, and industrial facilities), residential fireplaces, and wood stoves. In addition, PM2.5 is formed in the atmosphere from gases such as SO2, NOx, and volatile organic compounds (VOCs). PM10 and PM2.5 pose a greater health risk than larger-size particles. When inhaled, these tiny particles can penetrate the human respiratory system’s natural defenses and damage the respiratory tract. PM10 and PM2.5 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections. Very small particles of substances, such as lead, sulfates, and nitrates can cause lung damage directly. Whereas, larger particles tend to collect in the upper portion of the respiratory system, PM2.5 are so tiny that they can penetrate deeper into the lungs and damage lung tissues. Suspended particulates also damage and discolor surfaces on which they settle, as well as produce haze and reduce regional visibility.

Toxic Air Contaminants

Toxic air contaminants, which may have the potential to cause cancer or may pose a present or potential hazard to human health, are considered separately from the criteria pollutants in the regulatory process. Unlike criteria pollutants, there are no ambient standards for toxic air contaminants; this is partially due to the localized nature of the adverse health impacts caused by toxic air contaminant emissions. Stationary sources of toxic air contaminants are regulated directly through emission standards and risk reduction strategies implemented at the sources of the emissions. When a new source of toxic air contaminants is proposed, a health risk assessment may be needed to estimate the project’s potential health risks. Individual toxic air contaminants vary greatly in the risk they present; at a given level of exposure, one toxic air contaminant may pose a hazard that is many times greater than another. Where data are sufficient to do so, a “unit risk factor” can be developed for cancer risk. The unit risk factor expresses assumed risk to a hypothetical population in terms of the estimated number of individuals in a million who may develop cancer as the result of continuous, lifetime (70-year) exposure to 1 microgram per cubic meter (µg/m3, equal to one part per million) of the toxic air contaminant. Unit risk factors provide a standard that can be used to establish regulatory thresholds for permitting purposes. However, they are not a measure of actual health risk because actual populations do not experience the extent and duration of exposure that the hypothetical population is assumed to experience. A project that passes this risk screening is judged to have an insignificant impact on public health. If a project fails this risk screening, this does not necessarily constitute a significant impact, but the project would require further review. Further review usually consists of more detailed dispersion modeling.



Federal, state, and local regulations and guidelines govern the level of analysis necessary for sources which appear to have the potential for high toxic air contaminant emissions. The state Air Toxics Hot Spots Program and the BAAQMD Risk Management Policy require public notification, reporting, and risk assessments for facilities that have the potential to emit toxic air contaminants that may cause substantial health risks. Many sources of toxic air contaminants such as gasoline stations and dry cleaning businesses emit in levels that are below the thresholds for public notification and reporting and would not be expected to cause substantial health risks.

The state has also adopted various regulations such as Title 13 California Code of Regulations Section 1956.1-1956.4, 1956.8 and Title 13 California Code of Regulations Section 2420 et seq., to reduce diesel emissions in the overall fleet of diesel-fueled vehicles. These regulations include new standards for diesel fuel, emissions standards, and inspection and maintenance requirements. In particular, the reformulated fuel requirements that have already been adopted by CalEPA and CARB are expected to reduce, but not eliminate, mobile source toxic air contaminant emissions. The major concern with air toxics from diesel exhaust is along heavily traveled transportation corridors and around permanent facilities, such as truck depots and distribution centers, with a high concentration of diesel-fueled vehicles. For this reason, the state is taking an active role in devising new standards for these vehicles, for the fuel itself, and for alternative fuels.

CARB has addressed this issue by preparing and approving the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles (Risk Reduction Plan) (approved on September 28, 2000). This plan represents the state’s comprehensive blueprint to substantially reduce diesel particulate emissions throughout the state. The plan contains the following components:

• New regulatory standards for all new on-road, off-road, and stationary diesel-fueled engines and vehicles to reduce diesel PM emissions by about 90 percent overall from current levels;

• New retrofit requirements for existing on-road, off-road, and stationary diesel-fueled engines and vehicles where determined to be technically feasible and cost effective; and

• New phase 2 diesel fuel regulations to reduce the sulfur content levels of diesel fuel to no more than 15 parts per million to provide the quality of diesel fuel needed by the advanced diesel PM emission controls.

The Risk Reduction Plan shows that on-road mobile sources comprise a good portion of the past, existing, and future (through 2010) diesel PM10 emission inventory within the state. Therefore, the risks associated with on-road diesel vehicles have been addressed by the state and will be substantially reduced by statewide programs over the next decade.



Bay Area Clean Air Plan

The BAAQMD along with the other regional agencies (i.e., Association of Bay Area Governments [ABAG] and the Metropolitan Transportation Commission [MTC]) has prepared an Ozone Attainment Plan to address the National Ambient Air Quality Standards for O3. A Carbon Monoxide Maintenance Plan was also prepared in 1994 to demonstrate how the National Ambient Air Quality Standards for carbon monoxide standard will be maintained. Another plan, the Bay Area Clean Air Plan, was prepared to address the more stringent requirements of the California Clean Air Act with respect to O3. This plan includes a comprehensive strategy to reduce emissions from stationary, area, and mobile sources. The plan objective is to indicate how the region would make progress toward attaining the stricter State air quality standards, as mandated by the California Clean Air Act. The plan is designed to achieve a region-wide reduction of O3 precursor pollutants through the expeditious implementation of all feasible measures. Air quality plans addressing the California Clean Air Act are developed about every three years. The latest plan (Bay Area 2000 Clean Air Plan) was prepared in 2000. The plan proposes implementation of transportation control measures and programs such as Spare the Air. Some of these measures or programs rely on local governments for implementation.

A key element in air quality planning is to make reasonably accurate projections of future human activities that are related to air pollutant emissions. Most important is vehicle activity. The BAAQMD uses population projections made by ABAG and vehicle use trends made by the MTC to formulate future air pollutant emission inventories. The basis for these projections comes from land use planning documents prepared by cities and counties. In order to provide the best plan to reduce air pollution in the Bay Area, accurate projections from local governments are necessary. When general plans are not consistent with these projections, they cumulatively reduce the effectiveness of air quality planning in the region.

ENVIRONMENTAL SETTING

Climate and Topography

The climate in the Bay Area is mainly characterized by warm dry summers with abundant sunshine and cool moist winters with variable cloudiness. The proximity of the Pacific Ocean and San Francisco Bay has a moderating influence on the area’s climate. The major large-scale weather feature controlling the climate is a large high-pressure system located in the eastern Pacific Ocean, known as the Pacific High. The strength and position of the Pacific High varies seasonally. It is strongest and located off the west coast of the United States during summer. Large-scale atmospheric subsidence associated with the Pacific High, produces an elevated temperature inversion along the West Coast. The base of this inversion is usually located from 1,000 to 3,000 feet above mean sea level, depending on the warmth of the air column, intensity of subsidence and the prevailing weather condition. Vertical mixing is often limited to the base of the inversion, trapping air pollutants in the lower atmosphere. Marine air trapped below the base of the inversion is often condensed into fog or stratus clouds by the cool Pacific Ocean.



This condition is typical of the warmer months of the year from roughly May through October. Stratus clouds usually form offshore and move into Bay Area during the evening hours when onshore winds are strongest and solar heating begins to wane. As the land warms the following morning when onshore winds are weakest, the clouds often dissipate, except along the immediate coast. The stratus then redevelops and moves inland late in the day. Otherwise, clear skies and dry conditions prevail during summer.

As winter approaches, the Pacific High becomes weaker and shifts south, allowing both low and high pressure systems associated with the polar jet stream to affect the region. Low pressure systems are usually accompanied by frontal systems that produce periods of cloudiness, strong shifting winds, and precipitation. The number of days with precipitation can vary greatly from year to year, resulting in a wide range of annual precipitation totals. High pressure systems are also common in winter and can produce cool stagnant conditions. Radiation fog and haze are common during extended winter periods where high pressure systems influence the weather.

Air Pollution Potential

The clear skies with relatively warm conditions that are typical in summer combine with localized air pollutant emissions to elevate ozone levels. Air quality standards for ozone traditionally are exceeded when relatively stagnant conditions occur for periods of several days during the warmer months of the year. Weak wind flow patterns combined with strong inversions substantially reduces normal atmospheric mixing. Key components of ground-level ozone formation are sunlight and heat; therefore, significant ozone formation only occurs during the months from late spring through early fall. Pollution potential in the area could be high if there were sufficient sources of air contaminants nearby. Prevailing winds during the summer and fall can transport and trap ozone precursors from the more urbanized portions of the Bay Area. The surrounding mountains up slope and downslope flows may also re-circulate pollutants already present, contributing to the buildup of air pollution. Light winds and stable conditions during the late fall and winter contribute to the buildup of particulate matter from motor vehicles, agriculture, and wood burning in fireplaces and stoves.

Air Monitoring Data

To identify ambient concentrations of the six criteria pollutants, the BAAQMD operates over 30 air quality monitoring stations throughout the Bay Area. The Oakland Alice Street Monitoring Station is closest to the project site, approximately 6 miles from the site. This station monitors the levels of O3 and CO. The closest station to the project site that monitors PM10, PM2.5, and NOx is the Livermore 793 Rincon Avenue Station.

Table IV.B-2 lists the concentrations registered and the violations of State and Federal pollutant standards that have occurred at the Alice Street Monitoring Station and the 793 Rincon Avenue Station based on 2002 through 2004 data from CARB. As shown in the table, the monitoring station registered did not measure any exceedance of the State or Federal one-hour or 8-hour standard for O3. The State standard



for PM10 was exceeded twice in the year 2002. No exceedances of the State standard for PM10 have occurred since 2002, and the Federal standard has not been exceeded in the past three years. No exceedances of the Federal standard for PM2.5 occurred between 2002 and 2004 and the State standard has not been exceeded in the past three years. The monitoring station has registered no exceedances of the Federal standard for CO or the State standard for NOx in the past three years.

Table IV.B-2 Ambient Pollutant Concentrations Registered at the Oakland-Alice Street Monitoring and Livermore -

793 Rincon Avenue Station Year

Pollutant Standards1, 2 2002 2003 2004 Ozone – 1-hour Maximum concentration monitored (ppm) 0.053 0.081 0.080 Number of days exceeding federal standard >0.12 ppm 0 0 0 Number of days exceeding state standard >0.09 ppm 0 0 0 Ozone – 8-hour Maximum concentration monitored (ppm) 0.043 0.054 0.057 Number of days exceeding federal standard >0.08 ppm 0 0 0 Suspended Particulate Matter (PM10) – 24-hour Maximum concentration monitored (µg/m3) 65.9 32.7 48.8 Number of samples exceeding federal standard >150 µg/m3 0 0 0 Number of samples exceeding state standard >50 µg/m3 2 0 0 Suspended Particulate Matter (PM2.5) – 24-hour Maximum concentration monitored (µg/m3) 61.6 42.0 40.8 Number of samples exceeding federal standard >65 µg/m3 0 0 0 Carbon Monoxide – 8-hour Maximum concentration monitored (ppm) 3.34 2.78 2.64 Number of samples exceeding federal standard >9 ppm 0 0 0 Nitrogen Dioxide – 1-hour Maximum concentration monitored (ppm) 0.079 0.065 0.063 Number of samples exceeding state standard >0.25 ppm 0 0 0 Source: California Air Resources Board, “Top 4 Measurements and Days Above the Standard,” http://www.arb.ca.gov/adam/cgi-bin/db2www/adamtop4b.d2w/Branch, October 28, 2005. 1 Parts by volume per million of air (ppm) or micrograms per cubic meter of air (µg/m3). 2 Federal and state standards are for the same time period as the maximum concentration measurement unless

otherwise indicted.

Attainment Status

The Federal Clean Air Act, as amended, and the California Clean Air Act of 1988 provide the legal framework for attaining and maintaining ambient air quality standards. Both the federal and state acts require that the CARB designate “nonattainment areas” – portions of California where federal or state

http://www.arb.ca.gov/adam/cgi-bin/db2www/adamtop4b.d2w/Branch



ambient air quality standards are not met. Where a pollutant exceeds standards, air quality management plans must be formulated that demonstrate how the standards will be achieved. These laws also provide the basis for the implementing agencies to develop mobile and stationary source performance standards.

The BAAQMD adopted the Bay Area ’91 Clean Air Plan to implement the requirements of the California Clean Air Act of 1988. Since the state ozone standard and the state PM10 standard are exceeded in the Bay Area region, the BAAQMD adopted the 2000 Clean Air Plan on December 20, 2000, and submitted it to the CARB as required by the California Clean Air Act. The 2000 Clean Air Plan includes a control strategy review to ensure that the plan continues to include “all feasible measures” to reduce ozone. No state plan is required to meet state PM10 measures.

In 1998, the Bay Area was redesignated as nonattainment for the federal ozone standards. Under the EPA’s direction, the EPA prepared and submitted the Bay Area Ozone Attainment Plan in June 1999. This attainment plan was partially rejected by EPA. The parts of the attainment plan that were disapproved include ozone attainment assessment, consistency of regional transportation plans and programs with air quality attainment plans, and the Reasonably Available Control Measure demonstration. In response to EPA’s disapproval of the 1999 attainment plan, a Bay Area 2001 Ozone Attainment Plan (Final Plan) was prepared in June 2001 by the BAAQMD, the MTC, and the ABAG. This 2001 plan was initially rejected by the CARB prior to its submittal to the EPA. Addenda to this plan were presented to the CARB on November 1, 2001, approved, and submitted to EPA. On February 14, 2002, the EPA determined that the motor vehicle emission budgets in the Bay Area's 2001 Ozone Attainment Plan were adequate for conformity purposes. On October 31, 2003, the EPA proposed a finding of attainment for the Bay Area for the federal 1-hour ozone standard.

Sensitive Receptors

Some groups of people are more affected by air pollution than others. CARB has identified the following people who are most likely to be affected by air pollution: children under 14, the elderly over 65, athletes, and people with cardiovascular and chronic respiratory diseases. These groups are classified as sensitive receptors. Locations that may contain a high concentration of these sensitive population groups include residential areas, hospitals, daycare facilities, elder care facilities, elementary schools, and parks. No sensitive receptors are located in proximity to the project site.

ENVIRONMENTAL IMPACTS

Thresholds of Significance

In accordance with Appendix G of the CEQA Guidelines, the proposed project would have a significant environmental impact if it would:

• Conflict with or obstruct implementation of the applicable air quality plan;



• Violate any air quality standard or contribute substantially to an existing or projected air quality violation;

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

• Expose sensitive receptors to substantial pollutant concentrations;

• Create objectionable odors affecting a substantial number of people.

As stated previously, the project site is located within the jurisdiction of the BAAQMD. The BAAQMD CEQA Guidelines recommends analytical methodologies and provides evaluation criteria for determining the level of significance for project impacts within its jurisdiction. The BAAQMD’s evaluation criteria for determining air quality impacts provide defined screening thresholds for pollutant emissions. Projects that would generate emissions below the defined thresholds are considered to have a less-than-significant impact on air quality; projects that exceed the screening thresholds must provide further analysis such as district-approved air dispersion modeling to refute (or validate) a determination of significance or must acknowledge a potentially significant air quality impact. The screening thresholds for air quality impacts from the BAAQMD CEQA Guidelines are presented below.

Construction Emissions

According to the BAAQMD CEQA Guidelines, PM10 is the pollutant of greatest concern with respect to construction activities. Construction emissions of PM10 can vary greatly depending upon the level of activity, construction equipment, local soils, and weather conditions, among other factors. As a result, the BAAQMD CEQA Guidelines specifies, “[t]he District’s approach to CEQA analyses of construction impacts is to emphasize implementation of effective and comprehensive control measures rather than detailed quantification of emissions.” Therefore, the determination of significance with respect to construction emissions should be based on a consideration of the control measures to be implemented. If all the applicable control measures for PM10 indicated in the BAAQMD CEQA Guidelines would be implemented, then air pollutant emissions from construction activities would be considered less than significant. If a project would not implement all applicable control measures, construction emissions would be considered a significant impact.

Operational Emissions

The BAAQMD recommends that individual project’s impacts involving direct and/or indirect operational emissions that exceed the following thresholds be considered significant:

• 80 pounds per day (ppd) of ROG



• 80 ppd of NOx

• 80 ppd of PM10

Direct emissions are those that are emitted on a site and include stationary sources and on-site mobile equipment. Examples of land uses and activities that generate direct emissions are industrial operations and sources subject to an operating permit by the BAAQMD. Indirect emissions come from mobile sources that access the project site but generally emit off site. For many types of land-use development projects, the principal sources of air pollutant emissions are the motor vehicle trips generated by the project.

Local CO Concentrations

Indirect CO emissions are considered significant if they will contribute to a violation of the State standards for CO (9 ppm averaged over 8 hours and 20 ppm over 1 hour). CO emissions are localized, and typically analyzed in terms of their impacts to specific roadway segments or intersections. Construction equipment exhaust contains CO and ozone precursors. However, these exhaust emissions are included in the emission inventory that is the basis for regional air quality plans, and are not expected to impede attainment and maintenance of ozone and CO standards in the Bay Area. In addition, as mentioned before, although State standards for PM2.5 exist, area designations have not yet been determined. As a result, State plans for addressing PM2.5 emissions are not yet in place and air quality management districts do not include these emissions in their analyses of construction impacts.

BAAQMD requires CO modeling for projects in which: 1) project vehicle emissions of CO would exceed 550 ppd, 2) project traffic would affect intersections or roadway segments operating at level of service (LOS) D, E, or F, or would cause a decline to LOS D, E, or F, or 3) project traffic would increase traffic volumes on nearby roadways by 10 percent or more (unless the increase in traffic volume is less than 100 vehicles per hour). If necessary, a simplified CO modeling analysis will be used to determine localized CO concentrations. If modeling demonstrates that the source would not cause a violation of the State standard at existing or reasonably foreseeable receptors, the project would not have a significant impact on local air quality.

Odors

Odors would be considered significant if the project would result in a frequent exposure of members of the public to objectionable odors. According to the BAAQMD, typical uses that may result in significant odor impacts include wastewater treatment plant, sanitary landfill, transfer station, composting facility, petroleum refinery, asphalt batch plant, chemical manufacturing, fiberglass manufacturing, painting/coating operations, rendering plant, and coffee roasters.




Projects that have the potential to emit toxic air contaminants could also result in significant air quality impacts. As stated in the BAAQMD CEQA Guidelines, a project that emits toxic air contaminants and exceeds the following criteria is considered to have a significant air quality impact:

• Probability of contracting cancer for the Maximally Exposed Individual exceeds 10 in one million;1 or

• Ground-level concentrations of non-carcinogenic toxic air contaminants would result in a hazard index greater than one (1) for the Maximally Exposed Individual.2

Cumulative Impacts

According to the BAAQMD CEQA Guidelines, any project that would individually have a significant air quality impact would also have a significant cumulative air quality impact. For a project that does not individually have a significant air quality impact, the BAAQMD requires that a determination of cumulative impacts be based on an evaluation of the consistency of the proposed project with the local general plan and of the general plan with the regional air quality plan. The appropriate regional air quality plan for this analysis is the 2000 Clean Air Plan. If a project is proposed in a city or county with a general plan that is consistent with the Clean Air Plan, and the project is consistent with that general plan, the project would not have a significant cumulative impact. If the city or county general plan is not consistent with the Clean Air Plan, or the project is not consistent with the general plan, quantitative analysis is required to determine whether the impact is significant.

Air Quality Issues Not Analyzed Further

As discussed in the Initial Study (included in Appendix I), the Bay Area Air Basin is currently in attainment for all criteria pollutants. As such, the proposed project would not result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). No further analysis of this issue is required.

As discussed in the Initial Study, according to the BAAQMD CEQA Guidelines, the types of projects that commonly result in odor impacts include: wastewater treatment plant, sanitary landfills, transfer stations, composting facilities, petroleum refineries, asphalt batch plants, chemical manufacturing, fiberglass

1 A Maximally Exposed Individual is a hypothetical off-site person, usually at or near the site boundary, who would receive the maximum exposure from a facility’s operations.

2 A hazard index measures the potential for non-cancer health effects. It is the ratio of the estimated exposure level to the Reference Exposure Level, which is the level at or below which no adverse health effects are anticipated.



manufacturing, auto body shops, rendering plants, and coffer roasters. The proposed project does not include any of these uses and would not create objectionable odors that would affect a substantial number of people. In addition, the Project will comply with all health and safety codes and will be regularly serviced by refuse and recycling collection services. Therefore, project impacts related to odors would be less than significant, and no further analysis of this issue is required.

Project Impacts

Construction/Demolition Emissions

The proposed project would involve the demolition of the existing structures on the site and construction of a mixed-use development. During the construction phase of development of the proposed project, on-site stationary sources, heavy-duty construction vehicles, construction worker vehicles, and energy use would generate emissions. In addition to construction vehicle emissions, fugitive dust would also be generated during grading and construction activities. Dust is generated when grading equipment breaks down surface materials. The resulting dust, which includes PM10, is subsequently entrained into the air by wind and vehicle tires. Although much of this airborne dust would settle out on or near the project site, smaller particles would remain in the atmosphere, increasing existing particulate levels within the surrounding area. Sensitive receptors that could be affected by construction include the existing residential areas near the project site. Although the project’s construction-related emissions would be temporary in duration, in the absence of control measures, the emissions could be substantial. Without the implementation of dust control measures, impacts related to construction emissions could be potentially significant.

Mitigation Measures (Construction/Demolition Emissions)

Because the proposed project would result in temporary, significant air quality impacts during construction, the following mitigation measure is required to reduce these impacts to a less-than-significant level:

IV.B-1: The project sponsors shall require that the following practices be implemented by including them in the contractor construction documents:

a. Water all active construction areas at least twice daily.

b. Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at least two feet of freeboard.

c. Pave, apply water three times daily, or apply non-toxic soil stabilizers on all unpaved access roads, parking areas, and staging areas at the construction sites.

d. Sweep (with water sweepers) all paved access roads, parking areas, and staging areas at the construction site as needed.



e. Sweep (with water sweepers) public streets adjacent to construction sites if visible soil material is carried onto the streets as needed.

f. Hydroseed or apply non-toxic soil stabilizers to inactive construction areas (previously graded areas inactive for ten days or more).

g. Enclose, cover, water twice daily, or apply non-toxic soil binders to exposed stockpiles (dirt, sand, etc.).

h. Limit traffic speeds on unpaved roads to 15 miles per hour.

i. Install sandbags or other erosion control measures to prevent silt runoff to public roadways.

j. Install wheel washers for all exiting trucks or wash off the tires or tracks of all trucks and equipment leaving the construction site.

k. Install wind breaks at the windward sides of the construction areas.

l. Suspend excavation and grading activities when wind (as instantaneous gusts) exceeds 25 miles per hour.

Operational Emissions

Regional Emissions – Daily Emissions of ROG, NOx, and PM10

Operational emissions associated with the ultimate development and operation of the proposed project would result primarily from increased vehicular trips to and from the mixed-use development. Other sources of emissions associated with the project would include area source emissions, such as the use of natural gas for water heaters and cooking appliances. The predicted mobile source and area source emissions associated with project operation were calculated using the URBEMIS 2002 computer model distributed for use by the CARB and recommended for use by the BAAQMD. The average daily indirect and direct emissions associated with the proposed project are presented in Table IV.B-3 and are compared with the BAAQMD project-specific recommended thresholds of significance for the sources of pollutants. As shown in the table, the project would not generate average daily direct and indirect emissions of ROG, NOx, or PM10 that would exceed BAAQMD-recommended thresholds. Therefore, regional emissions associated with the proposed project would be less than significant.



Table IV.B-3 Air Pollutant Emissions from Project Operations (lbs/day)

Operational Activity ROG NOx PM10

Project Operational Emissions 12.65 16.66 14.98 Significance Threshold 80 80 80

Significant Impact? No No No URBEMIS results are included in Appendix IV.B. Source: CAJA, 2005.

Mitigation Measures (Regional Emissions)

Because no significant impacts related to regional emissions would occur, no mitigation measures are required.

CO Emissions

The BAAQMD recommends that CO modeling be performed for projects in which traffic would affect intersections or roadway segments operating at LOS D, E, or F, or would cause a decline to LOS D, E, or F. As a result, CO modeling was performed for the following five roadway intersections:

• 4th Street / Hearst Avenue

• 6th Street/University Avenue

• 6th Street /Hearst Avenue

• University Avenue/San Pablo Avenue

• 6th Street/Addison Street

For this analysis, CO concentrations were calculated based on a simplified CALINE4 screening procedure developed by the BAAQMD. This methodology assumes worst-case conditions (i.e., wind direction is parallel to the primary roadway, 90° to the secondary road; wind speed of less than one meter per second; and a high level of atmospheric stability or lack of change) and provides a screening of maximum, worst-case CO concentrations. Maximum CO concentrations were calculated for peak-hour traffic volumes at the intersections noted above under existing conditions, existing plus project, and cumulative conditions. Results are presented below in Tables IV.B-4 and IV.B-5.

The year 2025 was used as the date for CO emissions under cumulative conditions, which includes the future approved projects assumed in Section IV-I, Traffic/Transportation. In many cases, future or cumulative CO emissions are lower than existing CO levels because vehicle emissions are projected to



improve in efficiency in the future and reduce CO emissions. Traffic conditions may also improve in the future at some intersections because of traffic improvement measures, thus reducing concentrated CO emissions. Based on the CALINE4 computer-modeling results (Tables IV.B- and IV.B-5), local CO concentrations do not exceed state or national ambient air quality standards. Therefore, emissions of CO associated with the project would not result in a significant air quality impact.

Table IV.B-4

Summary of Localized CO Analysis (1-hour) 1-Hour CO Concentrations (ppm)

Intersection Existing 2005 Existing Plus

Project Cumulative w/Project

4th Street / Hearst Avenue 3.0 2.9 2.1

6th Street/University Avenue 3.9 3.6 3.0

6th Street/Hearst Avenue 3.3 3.1 2.8

University Avenue/San Pablo Avenue 3.9 3.6 3.0

6th Street/Addison Street 3.3 3.2 2.8 1-Hour Ambient Air Quality Standard 20.0 20.0 20.0

Source: CAJA, November 2005. Notes: Concentrations are based on CALINE4 outputs that are adjusted with anticipated background CO concentrations of 1.4 ppm (1-hr). CALINE4 print outs are included in Appendix IV.B.

Table IV.B-5

Summary of Localized CO Analysis (8-hour) 8-Hour CO Concentrations (ppm)

Intersection Existing 2005 Existing Plus

Project Cumulative w/Project

4th Street / Hearst Avenue 3.4 3.4 3.2

6th Street/University Avenue 4.0 3.9 3.4

6th Street/Hearst Avenue 3.6 3.5 3.3 University Avenue/San Pablo Avenue 4.0 3.8 3.4

6th Street/Addison Street 3.6 3.6 3.3 8-Hour Ambient Air Quality Standard 9.0 9.0 9.0

Source: CAJA, November 2005. Notes: Concentrations are based on CALINE4 outputs that are adjusted with anticipated background CO concentrations of 1.0 pm (8-hr). CALINE4 print outs are included in Appendix IV.B.



Mitigation Measures (CO Emissions)

Because no significant impacts related to CO emissions would occur, no mitigation measures are required.


According to Appendix E of the BAAQMD CEQA Guidelines, toxic air contaminants may be produced by a variety of sources, including industrial facilities such as refineries, chemical plants and chrome platers; commercial facilities such as dry cleaners and gasoline stations; and motor vehicles. Toxic air contaminants associated with motor vehicles are generally a result of diesel exhaust emissions associated with truck or bus operations. According to the BAAQMD CEQA Guidelines, any project with the potential to expose sensitive receptors or the general public to toxic air contaminants would be deemed to have a significant impact.

In order to evaluate the worst-case scenario for potential exposure of future residents to toxic air contaminants, a human health risk assessment was conducted by Levine-Fricke.3 The purpose of this analysis and assessment was to evaluate the potential health impact that neighboring industries, transportation modes and rights-of-way near the project site. The off-site consequence analysis focused on releases of toxic emissions generated by rail transport, truck traffic, and manufacturing operations and gasoline dispensing stations. Levine Fricke monitored existing baseline air quality in the immediate vicinity of the project site and compared the baseline data with 24-hour ambient air quality standard levels established by the EPA. A risk assessment also compared residential risk exposures to standards established by federal and state Occupational Safety and Health Administration and threshold limit values established by the American Conference of Governmental Industrial Hygienists. Levine-Fricke’s cancer risk monitoring efforts assessed the acrolein and particulate matter (PM2.5) levels that would occur at the site over a 24-hour period. As part of the worst-case approach, all particulates measuring 2.5 microns or smaller (PM2.5) were assumed to represent diesel exhaust. The health risk focused on indoor air quality impacts because outdoor pollutant concentrations would generally be lower than indoor pollutant concentrations due to the dilution effect that occurs outdoors.

The estimated non-cancer health risks were calculated using the “Hazard Quotient” derived from standard exposure assumptions and the Regional Air Quality Control Board reference dose. The non-cancerous health risks at the project site including concentrations of non-carcinogenic toxic air contaminants were measured at a hazard index rating of 0.02, well below the significance threshold of hazard index of 1.0.

The total estimated cancer risk for the project was compared to the risk range that the U.S. EPA considers safe and protective of public health (one-in-one million to one-in-ten-thousand excess cancer incidents).

3 Refer to Off-Site Consequence Analysis/Air Quality Assessment, Levine-Fricke, March 18, 2004, included in Appendix IV.B.



The results indicate that, under several extremely conservative assumptions (e.g., 18 hours per day exposure, 350 days/year, total PM2.5 is diesel exhaust, indoor air diesel concentration is the same as outdoor PM2.5 concentration), the estimated cancer risk is 1x10-4for children and 9x10-5 for adults, which is above the regulatory target goal for residential exposures. Based on the lack of detection of acrolein in the air samples, it is unlikely that 100 percent of the PM2.5 particulates are from diesel exhaust. However, the worst-case scenario indicates that the impact of particulates would pose a human health risk that exceeds current standards.

The project applicant has indicated that air filtration systems, which include the use of High Efficiency Particulate Air (HEPA) filters, would be installed in the North and South Buildings to reduce the exposure to PM2.5. According to Levine-Fricke, the HEPA filters have a collection efficiency of approximately 99 percent and would reduce the cancer risk at the site to an acceptable human health risk.4 Therefore, project impacts related to toxic air contaminants would be less than significant.

Mitigation Measures (Toxic Air Contaminants)

Because no significant impacts related to toxic air contaminants have been identified, no mitigation measures are required.

Cumulative Impacts

According to the BAAQMD CEQA Guidelines, any project that would individually have a significant air quality impact would also have a significant cumulative air quality impact. As stated above the project would not result in a project-specific air quality impact. Therefore, the determination of cumulative impacts should be based on an evaluation of the consistency of the proposed project with the local general plan and of the general plan with the regional air quality plan. As discussed in Section IV.G, Land Use & Planning, the project is consistent with the City of Berkeley General Plan (General Plan). According to the BAAQMD, to evaluate local plan consistency with the Clean Air Plan, the Lead Agency should consider the following:

• The plan’s consistency with population and vehicle use projections in the Clean Air Plan;

• The extent to which the plan implements applicable Clean Air Plan transportation control measures; and

• Whether the plan provides buffer zones around sources of odors and toxics (if necessary).

4 Supplemental Off-Site Consequence Analysis/Air Quality Assessment, Levine-Fricke, March 2, 2006.



Consistency with the Clean Air Plan

Clean Air Plan projections are based on analysis and forecasts of air pollutant emissions throughout the entire region (i.e., nine-county Bay Area). The forecasts rely on projections of population and employment made by the ABAG that are based on land use projections made by local jurisdictions through the general plan process). The EIR prepared for the General Plan in 2001 concluded that because the General Plan would allow employment and population growth that would generate additional air emissions and that would not be consistent with the population and vehicle-miles-traveled assumptions in the Clean Air Plan, General Plan impacts related to inconsistency with the Clean Air Plan would be temporarily significant and unavoidable. The EIR continues to state that upon approval of the General Plan, the City of Berkeley would provide BAAQMD with the information necessary to revise the district’s significance criteria to acknowledge the ABAG Regional Housing Needs Determination, released in June 2000. At this time, ABAG would have provided new “Fair Share” population estimates to BAAQMD. Since preparation of the EIR, the City’s General Plan has been approved, and the current Clean Air Plan takes into consideration the land use assumptions in the General Plan. For these reasons, the General Plan is consistent with the current Clean Air Plan.

Implementation of Transportation Control Measures

Table IV.B-6 identifies the policies found in the Transportation, Housing, and Land Use Elements of the General Plan that implement applicable Clean Air Plan transportation control measures.

Table IV.B-6 Implementation of Clean Air Plan Transportation Control Measures in the General Plan

Transportation Control Measure1

Description Relevant General Plan Policies2

Support voluntary employer-based trip-reduction programs

Provide assistance to regional and local ridesharing organizations.

T-2 Public Transportation Improvements T-3 Eco Pass City Program T-10 Trip Reduction T-11 City of Berkeley T-12 Education and Enforcement T-13 Major Public Institutions T-14 Private Employers T-35 Downtown and Southside Parking Management T-36 Satellite Parking Facilities T-38 Inter-jurisdictional Coordination






Improve Bicycle Access and Facilities

Improve and expand bicycle lane system by providing bicycle access in plans for all new road construction or modifications. Designate a staff person as a Bicycle Program manager. Develop and implement comprehensive bicycle plans. Encourage employers and developers to provide bicycle access and facilities.

T-10 Trip Reduction T-11 City of Berkeley T-13 Major Public Institutions T-14 Private Employers T-25 Street Maintenance T-30 Infrastructure T-30A T-41 bicycle Planning T-42 Bicycle Network T-43 Bicycle Safety T-44 Bicycle Promotions T-45 Bicycle Funding

Local Clean Air Plans, Policies, and Programs

Incorporate air quality beneficial policies and programs into local planning and development activities, with a particular focus on subdivision, zoning and site design measures that reduce the number and length of single-occupant automobile trips

T-16 Access by Proximity T-17 Measure S Traffic and Development Capacity Advisory Measure T-20 Air Quality Impacts H-15 Transit Oriented New Construction

Pedestrian Travel Review/revise general/specific plan policies to promote development patterns that encourage walking and circulation policies that emphasize pedestrian travel and modify zoning ordinances to include pedestrian-friendly design standards. Include pedestrian improvements in capital improvements programs. Designate a staff person as a Pedestrian program Manager.

LU-18 LU-28 LU-29 T-12 Education and Enforcement T-16 Access by Proximity T-17 Measure S Traffic and Development Capacity Advisory Measure T-19 Automobile Congestion T-46 Create a Pedestrian plan T-48 Sidewalks and Pedestrian Paths T-49 Pedestrian Priority T-50 Pedestrian Safety






T-51 Intersections with Severe or High Collision Rates T-52 Pathways

Promote Traffic Calming Measures

Include traffic calming strategies in the transportation and land use elements of general and specific plans. Include traffic calming strategies in capital improvements programs.

T-21 neighborhood Protection and Traffic Calming T-22 Speed Limits T-23 Traffic Circles and Roundabouts T-30 Infrastructure Improvements

1 BAAQMD CEQA Guidelines, December 1999. 2 City of Berkeley General Plan Draft EIR, 2001.

Buffers

The West Berkeley Plan, which is an amendment to the General Plan and is a guide to development in West Berkeley, includes a regulation that establishes heavy manufacturing/residential buffer requirements. The intent of the regulation is to maintain a minimum distance of 150 feet between residential and heavy manufacturing uses in order to mitigate environmental impacts, such as noise, odor, vibration and glare, which would interfere with reasonable residential uses and to provide a workable environment for manufacturers.

Considering the reasons discussed above, the General Plan is consistent with the current Clean Air Plan. Therefore, cumulative air quality impacts would be less than significant.

Mitigation Measures (Cumulative Impacts)

Because no significant cumulative impacts related to air quality have been identified, no mitigation measures are required.

LEVEL OF SIGNIFICANCE AFTER MITIGATION

Impacts related to air quality would be less than significant.

iv. environmental impact analysis

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