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3 - The Bowery_PUBLIC COMMENT_RAMSEY
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3 - The Bowery_PUBLIC COMMENT_RAMSEY
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19 <br /> <br />4. The District and/or other officials may conduct periodic site inspections to determine <br />compliance. Nothing in this mitigation shall supersede other District, state or federal rules or <br />regulations. <br />Use of Spray Equipment with Greater Transfer Efficiencies <br />Various coatings and adhesives are required to be applied by specified methods such as electrostatic <br />spray, high-volume, low-pressure (HVLP) spray, roll coater, flow coater, dip coater, etc. in order to <br />maximize the transfer efficiency. Transfer efficiency is typically defined as the ratio of the weight of <br />coating solids adhering to an object to the total weight of coating solids used in the application process, <br />expressed as a percentage. When it comes to spray applications, the rules typically require the use of <br />either electrostatic spray equipment or HVLP spray equipment. The SCAQMD is now able to certify HVLP <br />spray applicators and other application technologies at efficiency rates of 65 percent or greater.47 <br /> <br />These measures offer a cost-effective, feasible way to incorporate lower-emitting equipment into the <br />Project’s construction fleet, which subsequently reduces construction emissions. A revised EIR must be <br />prepared to include additional mitigation measures, as well as include an updated air quality assessment <br />to ensure that the necessary mitigation measures are implemented to reduce construction emissions. <br />Furthermore, the updated EIR needs to demonstrate commitment to the implementation of these <br />measures prior to Project approval to ensure that the Project’s construction-related emissions are <br />reduced to the maximum extent possible. Feasible Mitigation Measures Available to Reduce Operational Emissions <br />Our analysis demonstrates that the Project’s air quality and GHG emissions may result in a potentially <br />significant impact. In an effort to reduce the Project’s operational emissions, we identified several <br />mitigation measures that are applicable to the Project. Feasible mitigation measures can be found in <br />CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures, which attempt to reduce GHG levels, as <br />well as reduce criteria air pollutants, such as particulate matter emissions.48 Therefore, to reduce the <br />Project’s operational emissions, consideration of the following measures should be made. <br />• Integrate affordable and below market rate housing <br />• Energy-related mitigation: <br />o Install programmable thermostat timers <br />o Establish onsite renewable energy systems, including solar power and wind power <br />o Limit outdoor lighting requirements <br />o Reduce unnecessary outdoor lighting by utilizing design features such as limiting the <br />hours of operation of outdoor lighting. <br />o Provide education on energy efficiency to residents, customers, and/or tenants. Provide <br />information on energy management services for large energy users. <br />o Meet “reach” goals for building energy efficiency and renewable energy use. <br />o Limit the use of outdoor lighting to only that needed for safety and security purposes. <br /> <br />47 http://www.aqmd.gov/home/permits/spray-equipment-transfer-efficiency <br />48 http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf
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