HomeMy WebLinkAbout3 - The Bowery_PUBLIC COMMENT_RAMSEY
P: (626) 381-9248
F: (626) 389-5414
E: mitch@mitchtsailaw.com
Mitchell M. Tsai
Attorney At Law
155 South El Molino Avenue
Suite 104
Pasadena, California 91101
VIA U.S. MAIL & E-MAIL
May 11, 2020
Sarah Bernal, Recording Secretary
CITY OF SANTA ANA
20 Civic Center Plaza – M20
Santa Ana, CA 92701
Em: ecomments@santa-ana.org
Jerry C. Guevara—Assistant Planner I
CITY OF SANTA ANA, PLANNING & BUILDING AGENCY
PO Box 1988 (M-20)
Santa Ana, CA 92702
Em: jguevara@santa-ana.org
RE: City Planning Commission May 11, 2020 Meeting Agenda Item No. 3:
The Bowery Mixed-Use Project Final EIR
Dear Chairman McLoughlin, Ms. Bernal and Mr. Guevara:
On behalf of Southwest Regional Council of Carpenters (“Commenter” or
“Southwest Carpenters”), my Office is submitting these comments on the City of
Santa Ana’s (“City” or “Lead Agency”) Final Environmental Impact Report
(“FEIR”) (SCH No. 2019080011) for The Bowery Mixed-Use Project (“Project”).
The Southwest Carpenters is a labor union representing 50,000 union carpenters in six
states, including in southern California, and has a strong interest in well-ordered land
use planning and addressing the environmental impacts of development projects.
Commenters expressly reserve the right to supplement these comments at or prior to
hearings on the Project, and at any later hearings and proceedings related to this
Project. (Gov. Code § 65009(b); Pub. Resources Code § 21177(a); Bakersfield Citizens for
Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante
Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.)
Commenters incorporate by reference all comments raising issues regarding the DEIR
or the final Environmental Impact Report (“EIR”) submitted prior to certification of
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May 11, 2020
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the EIR for the Project. (Citizens for Clean Energy v City of Woodland (2014) 225 Cal. App.
4th 173, 191 [finding that any party who has objected to the Project’s environmental
documentation may assert any issue timely raised by other parties].)
Moreover, Commenters request that the Lead Agency provide notice for any and all
notices referring or related to the Project issued under the California Environmental
Quality Act (“CEQA”), Pub. Resources Code § 21000 et seq, and the California
Planning and Zoning Law (“Planning and Zoning Law”), Gov. Code §§ 65000–
65010. Pub. Resources Code §§ 21092.2, and 21167(f) and Gov. Code § 65092 require
agencies to mail such notices to any person who has filed a written request for them
with the clerk of the agency’s governing body.
The City must seriously consider proposing that the Applicant provide additional
community benefits such as requiring local hire and paying prevailing wages to benefit
the City. Moreover, it would be beneficial for the City to require the Applicant to hire
workers: (1) who have graduated from a Joint Labor Management apprenticeship
training program approved by the State of California, or have at least as many hours of
on-the-job experience in the applicable craft which would be required to graduate from
such a state approved apprenticeship training program and; (2) who are registered
apprentices in an apprenticeship training program approved by the State of California.
I. EXPERTS
This comment letter includes comments from air quality and greenhouse gas experts
Matt Hagemann, P.G., C.Hg. and Paul Rosenfeld, Ph.D. concerning the DEIR. Their
comments, attachments, and Curriculum Vitae (“CV”) are attached hereto and are
incorporated herein by reference.
Matt Hagemann, P.G., C.Hg. (“Mr. Hagemann”) has over 30 years of experience in
environmental policy, contaminant assessment and remediation, stormwater
compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA
and Superfund programs and served as EPA’s Senior Science Policy Advisor in the
Western Regional Office where he identified emerging threats to groundwater from
perchlorate and MTBE. While with EPA, Mr. Hagemann also served as Senior
Hydrogeologist in the oversight of the assessment of seven major military facilities
undergoing base closer. He led numerous enforcement actions under provisions of
the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve
hydrogeologic characterization and water quality monitoring.
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For the past 15 years, Mr. Hagemann has worked as a founding partner with SWAPE
(Soil/Water/Air Protection Enterprise). At SWAPE, Mr. Hagemann has developed
extensive client relationships and has managed complex projects that include
consultation as an expert witness and a regulatory specialist, and a manager of projects
ranging from industrial stormwater compliance to CEQA review of impacts from
hazardous waste, air quality, and greenhouse gas emissions.
Mr. Hagemann has a Bachelor of Arts degree in geology from Humboldt State
University in California and a Masters in Science degree from California State
University Los Angeles in California.
Paul Rosenfeld, Ph.D. (“Dr. Rosenfeld”) is a principal environmental chemist at
SWAPE. Dr. Rosenfeld has over 25 years’ experience conducting environmental
investigations and risk assessments for evaluating impacts on human health, property,
and ecological receptors. His expertise focuses on the fate and transport of
environmental contaminants, human health risks, exposure assessment, and ecological
restoration. Dr. Rosenfeld has evaluated and modeled emissions from unconventional
oil drilling operations, oil spills, landfills, boilers and incinerators, process stacks,
storage tanks, confined animal feeding operations, and many other industrial and
agricultural sources. His project experience ranges from monitoring and modeling of
pollution sources to evaluating impacts of pollution on workers at industrial facilities
and residents in surrounding communities.
Dr. Rosenfeld has investigated and designed remediation programs and risk
assessments for contaminated sites containing lead, heavy metals, mold, bacteria,
particular matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive
waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs,
perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual
polymers, fuel oxygenates (MTBE), among other pollutants, Dr. Rosenfeld also has
experience evaluating greenhouse gas emissions from various projects and is an expert
on the assessment of odors from industrial and agricultural sites, as well as the
evaluation of odor nuisance impacts and technologies for abatement of odorous
emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion
modeling and exposure assessments. He has served as an expert witness and testified
about pollution sources causing nuisance and/or personal injury at dozens of sites and
has testified as an expert witness on more than ten cases involving exposure to air
contaminants from industrial sources.
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Dr. Rosenfeld has a Ph.D. in soil chemistry from the University of Washington, M.S.
in environmental science from U.C. Berkeley, and B.A. in environmental studies from
U.C. Santa Barbara.
II. THE PROJECT WOULD BE APPROVED IN VIOLATION OF THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT
A. Background Concerning the California Environmental Quality Act
CEQA has two basic purposes. First, CEQA is designed to inform decision makers
and the public about the potential, significant environmental effects of a project. (14
California Code of Regulations (“CCR” or “CEQA Guidelines”) § 15002(a)(1).) “Its
purpose is to inform the public and its responsible officials of the environmental
consequences of their decisions before they are made. Thus, the EIR ‘protects not only
the environment but also informed self-government.’ [Citation.]” (Citizens of Goleta
Valley v. Board of Supervisors (1990) 52 Cal. 3d 553, 564.) The EIR has been described as
“an environmental ‘alarm bell’ whose purpose it is to alert the public and its
responsible officials to environmental changes before they have reached ecological
points of no return.” (Berkeley Keep Jets Over the Bay v. Bd. of Port Comm’rs. (2001) 91 Cal.
App. 4th 1344, 1354 (“Berkeley Jets”); County of Inyo v. Yorty (1973) 32 Cal. App. 3d 795,
810.)
Second, CEQA directs public agencies to avoid or reduce environmental damage when
possible by requiring alternatives or mitigation measures. (CEQA Guidelines
§ 15002(a)(2) and (3); see also, Berkeley Jets, 91 Cal. App. 4th 1344, 1354; Citizens of
Goleta Valley v. Board of Supervisors (1990) 52 Cal. 3d 553; Laurel Heights Improvement Ass’n
v. Regents of the University of California (1988) 47 Cal. 3d 376, 400.) The EIR serves to
provide public agencies and the public in general with information about the effect
that a proposed project is likely to have on the environment and to “identify ways that
environmental damage can be avoided or significantly reduced.” (CEQA Guidelines
§ 15002(a)(2).) If the project has a significant effect on the environment, the agency
may approve the project only upon finding that it has “eliminated or substantially
lessened all significant effects on the environment where feasible” and that any
unavoidable significant effects on the environment are “acceptable due to overriding
concerns” specified in CEQA section 21081. (CEQA Guidelines § 15092(b)(2)(A–B).)
While the courts review an EIR using an “abuse of discretion” standard, “the
reviewing court is not to ‘uncritically rely on every study or analysis presented by a
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project proponent in support of its position.’ A ‘clearly inadequate or unsupported
study is entitled to no judicial deference.’” (Berkeley Jets, supra, 91 Cal. App. 4th 1344,
1355 [emphasis added, quoting Laurel Heights, 47 Cal. 3d at 391, 409 fn. 12]. Drawing
this line and determining whether the EIR complies with CEQA’s information
disclosure requirements presents a question of law subject to independent review by
the courts. (Sierra Club v. Cnty. of Fresno (2018) 6 Cal. 5th 502, 515; Madera Oversight
Coalition, Inc. v. County of Madera (2011) 199 Cal. App. 4th 48, 102, 131.) As the court
stated in Berkeley Jets, supra, 91 Cal. App. 4th at 1355:
A prejudicial abuse of discretion occurs “if the failure to include relevant
information precludes informed decision-making and informed public
participation, thereby thwarting the statutory goals of the EIR process.
The preparation and circulation of an EIR is more than a set of technical hurdles for
agencies and developers to overcome. The EIR’s function is to ensure that
government officials who decide to build or approve a project do so with a full
understanding of the environmental consequences and, equally important, that the
public is assured those consequences have been considered. For the EIR to serve these
goals it must present information so that the foreseeable impacts of pursuing the
project can be understood and weighed, and the public must be given an adequate
opportunity to comment on that presentation before the decision to go forward is
made. (Communities for a Better Environment v. Richmond (2010) 184 Cal. App. 4th 70, 80
[quoting Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007)
40 Cal. 4th 412, 449–450].)
B. The EIR Fails to Maintain a Stable and Consistent Project Description
“[A]n accurate, stable and finite project description is the sine qua non of an
informative and legally sufficient” environmental document. (County of Inyo v. City of
Los Angeles (1977) 71 Cal. App. 3d 185, 200.) “A curtailed or distorted project
description may stultify the objectives of the reporting process” as an accurate, stable
and finite project description is necessary to allow “affected outsiders and public
decision-makers balance the proposal's benefit against its environmental cost, consider
mitigation measures, assess the advantage of terminating the proposal (i.e., the "no
project" alternative) and weigh other alternatives in the balance. (Id. at 192 – 93.)
Courts determine de novo whether an agency proceeded “in a manner required by
law” in maintaining a stable and consistent project description. (Id. at 200.)
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The FEIR makes numerous modifications to the described Project including changes
to the layout of the Project, the uses of the commercial space, landscaping and the
ratio of required parking spaces that the Project will require 2 parking spaces per
residential unit. (FEIR at 3-3.) The Project’s environmental review process is deficient
since it fails to maintain a
C. The FEIR’s Modifications to the Project Description, Environmental
Baseline, Hazards and Traffic / Transportation Analysis Require and
Recirculation
Section 21092.1 of the California Public Resources Code requires that “[w]hen
significant new information is added to an environmental impact report after notice
has been given pursuant to Section 21092 … but prior to certification, the public
agency shall give notice again pursuant to Section 21092, and consult again pursuant
to Sections 21104 and 21153 before certifying the environmental impact report” in
order to give the public a chance to review and comment upon the information.
(CEQA Guidelines § 15088.5.)
Significant new information includes “changes in the project or environmental
setting as well as additional data or other information” that “deprives the public of a
meaningful opportunity to comment upon a substantial adverse environmental effect
of the project or a feasible way to mitigate or avoid such an effect (including a
feasible project alternative).” (CEQA Guidelines § 15088.5(a).) Examples of
significant new information requiring recirculation include “new significant
environmental impacts from the project or from a new mitigation measure,”
“substantial increase in the severity of an environmental impact,” “feasible project
alternative or mitigation measure considerably different from others previously
analyzed” as well as when “the draft EIR was so fundamentally and basically
inadequate and conclusory in nature that meaningful public review and comment
were precluded.” (Id.)
An agency has an obligation to recirculate an environmental impact report for public
notice and comment due to “significant new information” regardless of whether the
agency opts to include it in a project’s environmental impact report. (Cadiz Land Co.
v. Rail Cycle (2000) 83 Cal.App.4th 74, 95 [finding that in light of a new expert report
disclosing potentially significant impacts to groundwater supply “the EIR should
have been revised and recirculated for purposes of informing the public and
governmental agencies of the volume of groundwater at risk and to allow the public
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and governmental agencies to respond to such information.”].) If significant new
information was brought to the attention of an agency prior to certification, an
agency is required to revise and recirculate that information as part of the
environmental impact report.
1. Recirculation is Required to Give the Public an Opportunity to
Review and Comment Upon Changes to the Project’s
Transportation Analysis
CEQA requires that an environmental document identify and discuss the significant
effects of a Project, alternatives and how those significant effects can be mitigated or
avoided. (CEQA Guidelines § 15126.2; PRC §§ 21100(b)(1), 21002.1(a).) A Court
“[w]hen reviewing whether a discussion is sufficient to satisfy CEQA, . . . the EIR (1)
includes sufficient detail to enable those who did not participate in its preparation to
understand and to consider meaningfully the issues the proposed project raises
[citation omitted], and (2) makes a reasonable effort to substantively connect a
project's air quality impacts to likely health consequences.” (Sierra Club v. County of
Fresno (2018) 6 Cal. 5th 502, 510 [citing Laurel Heights Improvement Assn. v. Regents of
University of California (1988) 47 Cal.3d 376, 405.]; see also PRC §§ 21002.1(e), 21003(b).)
The Court may determine whether a CEQA environmental document sufficiently
discloses information required by CEQA de novo as “noncompliance with the
information disclosure provisions” of CEQA is a failure to proceed in a manner
required by law. (PRC § 21005(a); see also Sierra Club v. County of Fresno (2018) 6 Cal. 5th
502, 515.) Failure to include all required information in a Draft EIR requires revision
and recirculation of the Draft EIR.
The FEIR requires revision and recirculation since the Project’s transportation analysis
was entirely redone to perform both VMT analysis as well as revised LOS analysis
based upon modifications to the Project. Since VMT analysis and transportation
analysis are required under CEQA, the failure of the DEIR to include this information
was an unlawful omission of information that requires revision and recirculation since
the DEIR was fundamentally and basically inadequate.
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2. Recirculation is Required to Give the Public an Opportunity to
Review and Comment Upon Significant New Information
Concerning On-Site Contamination
The FEIR acknowledges that the DEIR falsely claimed that the Project Site is listed as
a hazardous material site. (FEIR at 2-3.) The FEIR also acknowledges that the DEIR
failed to discuss the fact that “the Project Site may be located within a groundwater
basin that is impacted by volatile organic compounds.” (FEIR at 2-4.) The DEIR fails
to disclose “OCHA investigation data and potential risk to future receptors associated
with groundwater contamination” at the Project Site. (FEIR at 2-4.) The failure of the
DEIR to include this information was an unlawful omission of information that
requires revision and recirculation since the DEIR was fundamentally and basically
inadequate.
i. The City Failed to Consult With the California Department
of Toxic Substances Control as a Responsible Agency,
Rendering the Project’s CEQA Process Entirety Defective
and Requiring Revision and Recirculation of the Project’s
Draft Environmental Impact Report
Section 21080.4(a) of the Cal. Public Resources Code requires that a lead agency upon
determining that a CEQA environmental impact report is necessary for a project,
notify all responsible agencies, the Office of Planning and Research (“OPR”) and
trustee agencies. Within 30 days of receiving notice, a responsible or trustee agency is
expected to provide “environmental information related to the responsible or trustee
agency's area of statutory responsibility that must be included in the draft EIR.”
(Guidelines Section 15082(b) (emphasis added). see also Guidelines Section
15096(b)(2).)
However, not only did the City not consult the California Department of Toxic
Substances Control (“DTSC”) concerning the FEIR, but the City failed to consult any
responsible agencies whatsoever. The FEIR concedes that DTSC as well as the
California Integrated Waste Management Board, Santa Ana Regional Water Quality
Control Board, Orange County Fire Authority and the Orange County Health Care
Agency are all responsible agencies for the Project pursuant to Mitigation Measure
HAZ-1 and should have been consulted prior to release of the environmental impact
report. (FEIR at 2-8.)
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3. Recirculation is Required to Give the Public an Opportunity to
Review and Comment Upon Changes to the Environmental
Setting / Baseline for the Project
The FEIR makes a number of modifications to the Project’s environmental setting or
baseline, requiring revision and recirculation. In particular, the DEIR originally
required additional mitigation for noise impacts due to aviation operations near the
Project Site requiring that “all prospective residents of the Project site shall be
notified of airport related noise.” (DEIR at 1-17, tbl. 1-2; FEIR at 3-1.)This was due
to the DEIR indicating that the Project Site was located with the Airport Environs
Land Use Plan Area (“AELUP Area”) for John Wayne Airport. (DEIR at 5.7-10;
FEIR at 3-5.) However, the FEIR subsequently determined that the Project Site is
not within the AELUP Area for John Wayne Airport. This change is significant new
information requiring revision and recirculation since it is both a change in
environmental setting and indicates that the DEIR is fundamentally and basically
inadequate.
4. Recirculation is Required to Give the Public an Opportunity to
Review and Comment Upon the Project’s Aesthetic Impacts due
to Modifications to the Project’s Height and Size
The FEIR also indicates changes to the Project that will have new, significant and
previously undisclosed aesthetic impacts. In particular, the FEIR discloses that the
Project will have two parking structures, one 76 feet in height and the other 70 feet in
height. The aesthetic impact of the height and size of these parking structures were
not disclosed or otherwise analyzed in the DEIR, and therefore is significant new
information requiring revision and recirculation, as they show a previously
undisclosed environmental impact and that the DEIR was fundamentally and
basically inadequate.
5. Recirculation is Required to Give the Public an Opportunity to
Review and Comment Upon Revised Construction Energy and Air
Quality Impacts
The FEIR also indicates changes to the Project that will have new, significant
undisclosed energy and air quality impacts. The FEIR discloses that rather than
having a 24 month construction period as originally discussed, the FEIR will be
under construction for 27 months. (DEIR 5.4-5, FEIR 3-4.)
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D. The EIR Fails to Disclose Significant and Unmitigated Environmental
Impacts Relating to Air Quality
As stated above, an EIR must disclose, evaluate, and ultimately provide feasible
mitigation measures for significant environmental impacts. Here, the EIR fails to
disclose significant impacts relating to construction and operational health risks.
According to Mr. Hagemann and Dr. Rosenfeld, the DEIR finds a less than significant
impact “without conducting a quantified construction or health risk assessment” which
the DEIR incorrectly justified. Mr. Hagemann and Dr. Rosenfeld make the following
three points on the DEIR Air Quality analysis:
• the use of the LST method to determine the Projects health risk
impacts on nearby, existing sensitive receptors is incorrect. While
the LST method assesses the impact of pollutants at a local level, it
only evaluates impacts from criteria air pollutants. According to the
Final Localized Significance Threshold Methodology document
prepared by the SCAQMD, the LST analysis is only applicable to
NOx, CO, PM10, and PM2.5 emissions, which are collectively
referred to as criteria air pollutants. Because the LST method can
only be applied to criteria air pollutants, this method cannot be used
to determine whether emissions from DPM, a known human
carcinogen, will result in a significant health risk impact to nearby
sensitive receptors. As a result, health impacts from exposure to
toxic air contaminants (TACs), such as diesel particulate matter
(DPM), were not analyzed, thus leaving a gap within the DEIR’s
analysis.
• the omission of a quantified HRA is inconsistent with the most
recent guidance published by the Office of Environmental Health
Hazard Assessment (OEHHA), the organization responsible for
providing guidance on conducting HRAs in California. In February
of 2015, OEHHA released its most recent Risk Assessment
Guidelines: Guidance Manual for Preparation of Health Risk
Assessments. This guidance document describes the types of
projects that warrant the preparation of an HRA. Construction of
the Project will produce emissions of DPM, a human carcinogen,
through the exhaust stacks of construction equipment over a
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construction period of approximately 26 months (Appendix B, pp.
247). The OEHHA document recommends that all short-term
projects lasting at least two months be evaluated for cancer risks to
nearby sensitive receptors. Therefore, per OEHHA guidelines, we
recommend that health risk impacts from Project construction be
evaluated by the DEIR. Furthermore, once construction of the
Project is complete, the Project will operate for a long period of
time. As previously stated, Project operation will generate
approximately 11,546 daily vehicle trips, which will generate
additional exhaust emissions and continue to expose nearby
sensitive receptors to DPM emissions (p. 5.14-11, Table 5.14-5).
The OEHHA document recommends that exposure from projects
lasting more than 6 months be evaluated for the duration of the
project, and recommends that an exposure duration of 30 years be
used to estimate individual cancer risk for the maximally exposed
individual resident (MEIR). Even though we were not provided
with the expected lifetime of the Project, we can reasonably assume
that the Project will operate for at least 30 years, if not more.
Therefore, we recommend that health risks from Project operation
also be evaluated, as a 30-year exposure duration vastly exceeds the
2-month and 6-month requirements set forth by OEHHA. This
guidance reflects the most recent health risk policy, and as such, we
recommend that an updated assessment of health risks to nearby
sensitive receptors from Project construction and operation be
included in a revised CEQA evaluation for the Project.
• claiming a less than significant impact without conducting a
quantified HRA to nearby, existing sensitive receptors as a result of
Project construction, the DEIR fails to compare the excess health
risk to the SCAQMD’s specific numeric threshold of 10 in one
million. Thus, the DEIR cannot conclude less than significant
health risk impacts resulting from Project construction without
quantifying emissions to compare to the proper threshold.
(Hagemann at 8-10.)
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Furthermore, when Mr. Hagemann and Dr. Rosenfeld prepared a simple screening-
level HRA, the results demonstrated and provided substantial evidence there may be a
significant environmental impact. (Id. at 10-13.) Specifically, “[t]he excess cancer risk
posed to adults, children, infants, and during the third trimester of pregnancy at the
closest receptor…[is] approximately 68 in one million.” (Id. at 13.) As Mr. Hagemann
and Dr. Rosenfeld point out, this figure is well north of SCAQMD’s threshold one in
ten million. The DEIR should be amended and include an accurate analysis that
analyzes the Project’s health risks relating to air quality.
E. The City’s Final Environmental Impact Report Does Not Adequately
Describe the Project
Generally, an adequate EIR must be "prepared with a sufficient degree of analysis to
provide decisionmakers with information which enables them to make a decision
which intelligently takes account of environmental consequences." (Dry Creek Citizens
Coalition v. County of Tulare (1999) 70 Cal. App. 4th 20, 26.) And while a project’s
description can account for needed flexibility to respond to changing project
conditions, the description, in any event, needs to be accurate and specific enough to
make a reasonable assessment of its sufficiency. (See Citizens for a Sustainable Treasure
Island v City & County of San Francisco (2014) 227 Cal. App. 4th 1036, 1053.) A project
description that omits integral components of the project may result in an EIR that
fails to disclose all of the impacts of the project. (Santiago County Water Dist. v. County of
Orange (1981) 118 Cal. App. 3d 818, 829 [project description for sand and gravel mine
omitted water pipelines serving project].)
As part of the CEQA Guidelines provisions governing the environmental setting, the
Guidelines require an EIR to discuss any inconsistencies between the proposed project
and applicable general plans, specific plans, and regional plans. (CEQA Guidelines
§ 15125(d).) An "applicable" plan is a plan that has already been adopted and thus
legally applies to a project; draft plans need not be evaluated. (Chaparral Greens v. City of
Chula Vista (1996) 50 Cal. App. 4th 1134, 1145 fn. 2.) The purpose of the required
analysis is to identify inconsistencies that the lead agency should address.
The Project site has an existing General Plan land use designation of Professional and
Administrative Office (PAO), and a zoning designation of Light Industrial (M-1). The
Project seeks to change these designations through amendments to District Center
(DC) and Specific Development (SD), respectively, to allow for a primarily residential
mixed-use development.
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If there is an inconsistency with the applicable land use plans that will not be amended,
as of now, there is no way for anyone to make that determination. (See, generally, The
Highway 68 Coalition v. County of Monterey (2017) 14 Cal. App. 5th 883, 896 [consistency
of development permit and development plan with general plan]; Clover Valley Found. v.
City of Rocklin (2011) 197 Cal. App. 4th 200, 239 [consistency of development project
with general plan]; No Oil, Inc. v. City of Los Angeles (1987) 196 Cal. App. 3d 223
[consistency of zoning ordinance with general plan]; Mitchell v. County of Orange (1985)
165 Cal. App. 3d 1185 [consistency of specific plan with general plan].)
The DEIR’s project description states that it is requesting to change the site’s land use
designations, but fails to specifically identify what provisions those new designations
may include and what will change from the existing land use regime. Importantly, the
request for a zoning amendment to SD is vague and lacks detail sufficient to allow for
any real comparison to the site’s underlying and applicable land use designations. The
SD for the site should outline all standards for buildings, height, setbacks, lot coverage,
minimum unit sizes, landscaping, parking, signs, fences, or other features. This
information cannot be found in the DEIR which merely requests the change to a SD
from M-1 zoning without any commitment to details. For example:
• states the setbacks from Warner Avenue will be 12-feet and 20-feet from Red
Hill Avenue, with “courtyard and landscape areas [providing] additional
setbacks…”
• “The proposed setbacks along N. Main Street and Edgewood Road would be
greater than the minimum setbacks required in the M-1 zone.”
(DEIR at 5.9-40.)
What are the remaining setback requirements? What are the landscaping requirements?
How will parking requirements be determined or will it be consistent with other DC
mixed-use developments? None of these important and required specifications are
provided in the DEIR. For all these reasons, the Project’s description is inadequate and
should be revised with additional detail.
F. The Final EIR Impermissibly Defers the Development of Environmental
Mitigation Measures
CEQA mitigation measures proposed and adopted into an environmental impact
report are required to describe what actions that will be taken to reduce or avoid an
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environmental impact. (CEQA Guidelines § 15126.4(a)(1)(B) [providing “[f]ormulation
of mitigation measures should not be deferred until some future time.”].) While the
same Guidelines section 15126.5(a)(1)(B) acknowledges an exception to the rule
against deferrals, but such exception is narrowly proscribed to situations where
“measures may specify performance standards which would mitigate the significant
effect of the project and which may be accomplished in more than one specified way.”
(Id.) Courts have also recognized a similar exception to the general rule against deferral
of mitigation measures where the performance criteria for each mitigation measure is
identified and described in the EIR. (Sacramento Old City Ass’n v. City Council (1991) 229
Cal. App. 3d 1011.)
Impermissible deferral can occur when an EIR calls for mitigation measures to be
created based on future studies or describes mitigation measures in general terms but
the agency fails to commit itself to specific performance standards. (Preserve Wild Santee
v. City of Santee (2012) 210 Cal. App. 4th 260, 281 [city improperly deferred mitigation
to butterfly habitat by failing to provide standards or guidelines for its management];
San Joaquin Raptor Rescue Center v. County of Merced (2007) 149 Cal. App. 4th 645, 671
[EIR failed to provide and commit to specific criteria or standard of performance for
mitigating impacts to biological habitats]; see also Cleveland Nat'l Forest Found. v San
Diego Ass'n of Gov'ts (2017) 17 Cal. App. 5th 413, 442 [generalized air quality measures
in the EIR failed to set performance standards]; California Clean Energy Comm. v City of
Woodland (2014) 225 Cal. App. 4th 173, 195 [agency could not rely on a future report
on urban decay with no standards for determining whether mitigation required];
POET, LLC v. State Air Resources Bd. (2013) 218 Cal. App. 4th 681, 740 [agency could
not rely on future rulemaking to establish specifications to ensure emissions of
nitrogen oxide would not increase because it did not establish objective performance
criteria for measuring whether that goal would be achieved]; Gray v. County of Madera
(2008) 167 Cal. App. 4th 1099, 1119 [rejecting mitigation measure requiring
replacement water to be provided to neighboring landowners because it identified a
general goal for mitigation rather than specific performance standard]; Endangered
Habitats League, Inc. v. County of Orange (2005) 131 Cal. App. 4th 777, 794 [requiring
report without established standards is impermissible delay].)
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1. The DEIR Defers Development of Hazardous Materials Mitigation
Measures
The DEIR’s HAZ-1 mitigation measure is impermissibly deferred because the
proposed mitigation is to develop a Soil Management Plan in the future which “would
detail hazardous materials excavation and disposal methods and requirements pursuant
to [the applicable codes] that regulates the removal, transportation, and disposal of
hazardous waste…” (DEIR at 5.7-22; DEIR at 5.7-30 (no specification for how
contaminated soil will be removed); 5.9-25-26.) The DEIR fails to provide a specific
plan or how compliance with any applicable code will sufficiently mitigate a known
hazard on the site. The Project site “contains 900 cubic yards of contaminated soil that
would require excavation and disposal.” (Id.) The mitigation measures for HAZ-2 are
similarly deferred due to the same reliance on a Soil Management Plan to remove
contaminants that has not been formulated.
The DEIR needs to specify the removal plan and how code compliance will ensure
safe removal of contaminants.
2. The DEIR Impermissibly Defers Development of Noise Mitigation Measures
The Project is located near low-density residential housing and other nearby sensitive
receptors which would be directly impacted by construction noise. The DEIR, in MM
NOI-1 proposes a construction noise mitigation program that would include noise
barriers, noise-reduction devices on construction equipment, distanced placement of
noise-generating devices, and notice to nearby residents regarding noise at new
construction phases. All of these proposed items are impermissibly deferred for
specific formulation at a later date. (See DEIR at 4.9-14-15.)
First, the noise barriers that are proposed “could consist of materials such as ¾-inch
thick plywood.” There is no way to evaluate the sufficiency of the barrier with this
description. The Project calls for, generally, “feasible noise-reduction devices” but does
not specify what these devices will be. It calls for stationary noise sources to “be
located as far away from noise-sensitive land uses as feasible” without detailing how
that would or could be determined, or how placement will be decided for
effectiveness.
Second, MM NOI-2 calls for the applicant to retain a specialist to review the project
plans and incorporate specific measures to mitigate noise that generally will reduce
noise levels below specific levels, but fails to provide any specific of such a plan in the
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DEIR that could be evaluated for adequacy. All of these measures should provide
additional details so that they may be evaluated and were impermissibly deferred.
G. The DEIR Fails to Support Its Findings with Substantial Evidence
When new information is brought to light showing that an impact previously discussed
in the DEIR but found to be insignificant with or without mitigation in the DEIR’s
analysis has the potential for a significant environmental impact supported by
substantial evidence, the EIR must consider and resolve the conflict in the evidence.
(See Visalia Retail, L.P. v. City of Visalia (2018) 20 Cal. App. 5th 1, 13, 17; see also Protect
the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal. App. 4th 1099,
1109.) While a lead agency has discretion to formulate standards for determining
significance and the need for mitigation measures—the choice of any standards or
thresholds of significance must be “based to the extent possible on scientific and
factual data and an exercise of reasoned judgment based on substantial evidence.
(CEQA Guidelines § 15064(b); Cleveland Nat'l Forest Found. v. San Diego Ass'n of Gov'ts
(2017) 3 Cal. App. 5th 497, 515; Mission Bay Alliance v. Office of Community Inv. &
Infrastructure (2016) 6 Cal. App. 5th 160, 206.) And when there is evidence that an
impact could be significant, an EIR cannot adopt a contrary finding without providing
an adequate explanation along with supporting evidence. (East Sacramento Partnership for
a Livable City v. City of Sacramento (2016) 5 Cal. App. 5th 281, 302.)
In addition, a determination that regulatory compliance will be sufficient to prevent
significant adverse impacts must be based on a project-specific analysis of potential
impacts and the effect of regulatory compliance. In Californians for Alternatives to Toxics v.
Department of Food & Agric. (2005) 136 Cal. App. 4th 1, the court set aside an EIR for a
statewide crop disease control plan because it did not include an evaluation of the risks
to the environment and human health from the proposed program but simply
presumed that no adverse impacts would occur from use of pesticides in accordance
with the registration and labeling program of the California Department of Pesticide
Regulation. (See also Ebbetts Pass Forest Watch v Department of Forestry & Fire Protection
(2008) 43 Cal. App. 4th 936, 956 (fact that Department of Pesticide Regulation had
assessed environmental effects of certain herbicides in general did not excuse failure to
assess effects of their use for specific timber harvesting project).)
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1. The DEIR’s Noise Impact Analysis is Not Supported by Substantial
Evidence
The DEIR incorrectly concludes, without substantial evidence, that the proposed
Project will not have a substantial impact relating to noise on its future residents or
workers in the area. The Project Applicant and City conducted no on-site study to
determine aircraft noise levels from John Wayne Airport at the site and rely solely on
the fact that the Project is located outside the 60 decibel or higher contour zone for
the airport to conclude there will be no significant noise impact. This analysis fails
because it needs to include site-specific facts and application relating to the actual
aircraft noise levels and their effects.1 A more detailed analysis of this issue can be
found below under section III of this comment letter.
2. The DEIR Finding That the Project’s Conflict with the John Wayne Airport
Environs Land Use Plan (LU-2) and that the Project Would Not Result in
Excessive Noise for a Project Subject to an Airport Land Use Plan (HAZ-
5) is Mitigated to Less Than Significant Levels is Not Supported by
Substantial Evidence
The Project has the potential to expose residents of the Project to significant aviation
noise conflicts with the John Wayne Airport Environs Land Use Plan Policies 3.2.1
and 3.2.4; as well as a conflict with the City of Santa Ana’s General Plan Goals 1,
Policy 1.3 (DEIR at 5.7-26, 5.9-22.) The Project site is 2 miles from John Wayne
Airport and within that airport’s flight path. Although the EIR theorizes without
supporting evidence that impacts may be insignificant because the site is outside the 60
CNEL contour for excessive noise, it nevertheless also proposes that the Project will
comply with Title 24 of the California Code on interior noise levels, which could (again
theoretically) ensure a less than significant impact with mitigation. This mitigation
measure is impermissibly deferred because there is no project-specific analysis relating
to how compliance with the noise code sections will sufficiently mitigate potential
noise impacts on residents.
The DEIR needs to specify how code compliance will ensure safe and insignificant
noise levels for residents and works on the site.
3. The DEIR’s Aesthetics Analysis is Not Supported by Substantial Evidence
1 See The Bowery, Noise Impact Analysis, Dec. 3, 2019. Available at
https://ceqanet.opr.ca.gov/2019080011/3/Attachment/jsSwJ-.
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The DEIR concludes that would not have a significant aesthetic impact as to emitting
substantial light or glare based upon stated future compliance with the Santa Ana
Municipal Code that provides for building lighting specifications. However, the Project
fails to analyze how compliance with the Code will adequately mitigate the substantial
new source of light the Project will create. The DEIR states that Santa Ana Municipal
Code sections 41-611.1 and 41-1304 “provides specifications for shielding lighting
away from adjacent uses and intensity of security lighting.” But how will this mitigate
the significant impact on aesthetics for the Project? And just because the Project will
comply with the City’s lighting regulations does not mean that the amount of light
created for a project of this magnitude, in a currently non-residential area, will be
adequately mitigated. California law requires a project-specific application and analysis;
and the Project fails to provide a project-specific analysis of how code compliance
translates to sufficient mitigation
4. The DEIR’s Air Quality Analysis is Not Supported by Substantial
Evidence
According to Mr. Hagemann and Dr. Rosenfeld, the DEIR’s air quality analysis
is fundamentally flawed because the input parameters used with CalEEMod
provided in Appendix B to the DEIR “were not consistent with information
disclosed in the DEIR.” (Hagemann at 2.) As a result, “the Project’s construction
and operational emissions are underestimated” and a new EIR should be
prepared. (Id.)
i. Unsubstantiated changes were made to vehicle
emissions factors
The first flaw in the input parameters, according to Mr. Hagemann and Dr. Rosenfeld,
is that “vehicle emissions factors used to estimate the proposed Project’s operational
emissions were changed from the CalEEMod default values without proper
justification.” (Id.) Unverified and manually inputted values were used in the model
which cannot be relied upon. (Id.)
ii. Pass-by trip percentages utilized in the model are
inconsistent with the Traffic Impact Analysis
Second, “the Project’s CalEEMod output files […] are inconsistent with the pass-by
trip percentages indicated by the Traffic Impact Analysis…” (Id.) According to the
information provided by Mr. Hagemann and Dr. Rosenfeld, and because the
information provided is inconsistent, “the model may underestimate the Project’s
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mobile-related operational emissions and should not be relied upon to determine
Project significance.” (Id. at 3.)
iii. Saturday and Sunday trip rates are incorrect.
Third, Mr. Hagemann and Dr. Rosenfeld’s review of the Project’s DEIR also revealed
that “the total daily trips calculated for Saturday and Sunday were underestimated for
each of the proposed land uses.” (Id. at 3-4.) The DEIR actually indicates that the
number of vehicle trips is higher than the input parameter figures used in CalEEMod
and thus the trip estimates are incorrect and cannot be relied upon. (Id. at 5.)
iv. Commercial-work trip length inputs are unjustified
Fourth, “the commercial-work (C-W) trip length was manually increased in
[CalEEMod]…” and the DEIR fails to provide any justification for this increase. (Id. at
5.) Because no rationale or justification was provided—the model cannot be relied
upon.
v. Pass-by and diverted trip percentages are unjustified
Lastly, the DEIR’s “pass-by and diverted trip percentages used in [CalEEMod]
were manually altered” and so the DEIR “underestimates the Project’s
operational emissions.” (Id. at 5; additional detail on p. 6.) According to Mr.
Hagemann and Dr. Rosenfeld, it is clear that “the model overestimates the
existing land use’s mobile-related operational emissions and should not be relied
upon to determine Project significance.” (Id.) The new values provided in the
DEIR were not adequately justified either because the reduction in pass-by and
diverted trips is not substantiated. (Id. at 6.)
For all of the above reasons, the DEIR’s air quality analysis is flawed because it is not
supported by substantial evidence. The EIR should be amended to adequately reflect
the true input parameters so that a reasonably accurate estimate of air quality impacts
can be analyzed and mitigated.
H. The City Failed to Include All Relevant Projects in its Cumulative
Impacts Transportation/Traffic Analysis
An EIR’s discussion of cumulative impacts is required by CEQA Guidelines
§15130(a). The determination of whether there are cumulative impacts in any issue
area should be determined based on an assessment of the project's incremental effects
“viewed in connection with the effects of past projects, the effects of other current
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projects, and the effects of probable future projects.” (CEQA Guidelines
§15065(a)(3); Banning Ranch Conservancy v. City of Newport Beach (2012) 211 Cal. App. 4th
1209, 1228; see also CEQA Guidelines §15355(b).)
A cumulative impacts analysis must include all “past, present, and probably future
projects producing related or cumulative impacts” or “[a] summary of projections
contained in an adopted local, regional or statewide plan, or related planning
document.” (CEQA Guidelines 15130(b)(1-2)). A probable future project should be
considered once the environmental review for the project is underway. (San Franciscans
for Reasonable Growth v. City & County of San Francisco (1984) 151 Cal. App. 3d 61.)
The City identified eleven projects in Santa Ana, eight in Irvine, five in Tustin,
and two in Newport Beach when calculating the cumulative impacts for its
transportation analysis. While a list approach is acceptable under CEQA, the list
must include all past, present, and probably future projects that could contribute
to the Project’s impacts. This cumulative impact analysis is flawed and should be
updated to include, at least, the potential impacts of the Congregate Care Facility
and Staybridge Hotel in Irvine.2 The Congregate Care Facility is a 424,113 square
foot facility located just two miles south of the Project site; and the 200+ room
Staybridge Hotel will be located just one mile west of the Project site. The
Congregate Care Facility project has already been approved by the City of Irvine;
and the Staybridge Hotel is currently under construction. Both projects should
be considered in the City’s CEQA analysis.
I. The DEIR Fails to Describe or Adopt Feasible Mitigation Measures
A fundamental purpose of an EIR is to identify ways in which a proposed
project's significant environmental impacts can be mitigated or avoided. (Pub.
Resources Code §§21002.1(a), 21061.) To implement this statutory purpose, an
EIR must describe feasible mitigation measures that can minimize the project's
significant environmental effects. (CEQA Guidelines §§15121(a), 15126.4(a).) "A
gloomy forecast of environmental degradation is of little or no value without
pragmatic, concrete means to minimize the impacts and restore ecological
2 The location and development stage of these projects may be found at
https://cityofirvine.maps.arcgis.com/apps/MapTour/index.html?appid=0429065850
ec4dcab5ba5856a497f42a.
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equilibrium." (Environmental Council of Sacramento v. City of Sacramento (2006) 142
Cal. App. 4th 1018, 1039.)
1. The Project Is Required to Adopt Additional Feasible Mitigation Measures
to Mitigation Construction Emissions
According to Mr. Hagemann and Dr. Rosenfeld, the following feasible
mitigation measures should also be considered and implemented to alleviate the
significant impact of construction-related emissions for the Project:
• Diesel Control Measures recommended by the Northeast Diesel
Collaborative (NEDC);
• Repowering or replacing older construction equipment engines;
• Installation of retrofit devices on existing construction equipment;
• Use of electric and hybrid construction equipment;
• Implementation of a construction vehicle tracking system; and
• Use of spray equipment with greater transfer efficiencies.
(Hagemann at 14-19.)
2. The Project is Required to Adopt Feasible Additional Mitigation Measures to
Mitigate Operational Emissions
Second, the Project DEIR estimated the annual GHG emissions to be 9,861.60
megatons per year (MT CO2e/year), which far exceeds the SCAQMD Tier 3 mixed-
use threshold of 3,000 MT CO2e/year. (Hagemann at 14.) In order to mitigate this
impact, the Project merely proposes implementing sustainable design features under
Title 24/CalGreen standards—but much more can and should be considered for the
Project. following mitigation measures for GHG emissions are feasible but were not
considered or implemented for the Project, including:
• Integrate affordable and below market rate housing;
• Energy-related mitigation:
Install programmable thermostat timers;
Establish onsite renewable energy systems, including solar power
and wind power;
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Limit outdoor lighting requirements;
Reduce unnecessary outdoor lighting by utilizing design features
such as limiting the hours of operation of outdoor lighting;
Provide education on energy efficiency to residents, customers,
and/or tenants;
Provide information on energy management services for large
energy users;
Meet “reach” goals for building energy efficiency and renewable
energy use;
Limit the use of outdoor lighting to only that needed for safety and
security purposes;
Require use of electric or alternatively fueled sweepers with HEPA
filters;
Include energy storage where appropriate to optimize renewable
energy generation systems and avoid peak energy use; and
Prohibit gas powered landscape equipment and implement electric
yard equipment compatibility.
• Transportation-related mitigation:
Provide EV parking;
Require residential area parking permits;
Implement ride-sharing, vanpool, shuttle, bike-sharing programs;
Provide bike parking near transit;
Provide local shuttles;
Implement area or cordon pricing; and
Install a park-and-ride lot.
• Water-related mitigation:
Install an infiltration basin to provide an opportunity for 100% of
the storm water to infiltrate on-site;
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May 11, 2020
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Install a system to reutilize gray water;
Use locally-sourced water supply; and
Plant native and drought-resistant trees and vegetation.
• Develop and follow a “green streets guide” that requires:
Use of minimal amounts of concrete and asphalt; and
Use of groundcovers rather than pavement to reduce heat
reflection.
• Implement Project design features such as:
Shade HVAC equipment from direct sunlight;
Install high-albedo white thermoplastic polyolefin roof membrane;
Install formaldehyde-free insulation;
Use recycled-content gypsum board; and
Require all buildings to become “LEED” and “WELL” certified.
• Plant low-VOC emitting shade trees, e.g., in parking lots to reduce
evaporative emissions from parked vehicles;
• Increase in insulation such that heat transfer and thermal bridging
is minimized;
• Limit air leakage through the structure and/or within the heating
and cooling distribution system;
• Installation of dual-paned or other energy efficient windows; and
• Installation of automatic devices to turn off lights where they are
not needed.
(Hagemann at 14-19.)
All of the above measures are feasible to reduce the significant impacts to air quality
and GHG emissions; and the DEIR’s failure to consider or implement any of the
above measures if a violation of CEQA Guidelines §§15121(a), 15126.4(a). The DEIR
needs to be amended as a result.
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III. THE PROJECT VIOLATES THE STATE PLANNING AND ZONING
LAW AS WELL AS THE CITY’S GENERAL PLAN
A. Background Regarding the State Planning and Zoning Law
Each California city and county must adopt a comprehensive, long-term general plan
governing development. (Napa Citizens for Honest Gov. v. Napa County Bd. of Supervisors
(2001) 91 Cal. App.4th 342, 352, citing Gov. Code §§ 65030, 65300.) The general
plan sits at the top of the land use planning hierarchy (See DeVita v. County of Napa
(1995) 9 Cal. App. 4th 763, 773), and serves as a “constitution” or “charter” for all
future development. (Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Cal.
App. 3d 531, 540.)
General plan consistency is “the linchpin of California’s land use and development
laws; it is the principle which infused the concept of planned growth with the force
of law.” (See Debottari v. Norco City Council (1985) 171 Cal. App. 3d 1204, 1213.)
State law mandates two levels of consistency. First, a general plan must be internally
or “horizontally” consistent: its elements must “comprise an integrated, internally
consistent and compatible statement of policies for the adopting agency.” (See Gov.
Code § 65300.5; Sierra Club v. Bd. of Supervisors (1981) 126 Cal. App. 3d 698, 704.) A
general plan amendment thus may not be internally inconsistent, nor may it cause the
general plan as a whole to become internally inconsistent. (See DeVita, 9 Cal. App.
4th at 796 fn. 12.)
Second, state law requires “vertical” consistency, meaning that zoning ordinances and
other land use decisions also must be consistent with the general plan. (See Gov.
Code § 65860(a)(2) [land uses authorized by zoning ordinance must be “compatible
with the objectives, policies, general land uses, and programs specified in the
[general] plan.”]; see also Neighborhood Action Group v. County of Calaveras (1984) 156
Cal. App. 3d 1176, 1184.) A zoning ordinance that conflicts with the general plan or
impedes achievement of its policies is invalid and cannot be given effect. (See Lesher,
52 Cal. App. 3d at 544.)
State law requires that all subordinate land use decisions, including conditional use
permits, be consistent with the general plan. (See Gov. Code § 65860(a)(2);
Neighborhood Action Group, 156 Cal. App. 3d at 1184.)
A project cannot be found consistent with a general plan if it conflicts with a general
plan policy that is “fundamental, mandatory, and clear,” regardless of whether it is
City of Santa Ana – The Bowery
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consistent with other general plan policies. (See Endangered Habitats League v. County of
Orange (2005) 131 Cal. App. 4th 777, 782-83; Families Unafraid to Uphold Rural El Dorado
County v. Bd. of Supervisors (1998) 62 Cal. App. 4th 1332, 1341-42 [“FUTURE”].)
Moreover, even in the absence of such a direct conflict, an ordinance or development
project may not be approved if it interferes with or frustrates the general plan’s policies
and objectives. (See Napa Citizens, 91 Cal. App. 4th at 378-79; see also Lesher, 52 Cal.
App. 3d at 544 [zoning ordinance restricting development conflicted with growth-
oriented policies of general plan].)
A. Changing the Project Site’s General Plan Designation to a District Center
conflict with the City’s General Plan
Here, the Project proposes a General Plan Land Use Amendment that would change
the land use designation from PAO for professional or administrative offices to
District Center (DC) to allow for a mixed-use residential development.
The Project’s mixed-use, primarily residential, development plans for the construction
of a multi-building project with approximately 80 residential units on each acre of the
site. The maximum allowable units for a DC zone is 90 units per acre. A DC land use
designation, according to the City of Santa Ana’s General Plan – Land Use Element, is:
(1) reserved for “major activity areas in the City”; (2) designed to “serve as anchors
to the City’s commercial corridors…”; and (3) “are to be developed with an urban
character that includes a mixture of highrise office, commercial, and residential uses
which provide shopping, business, cultural education, recreation, entertainment, and
housing opportunities.”3
The proposed change is inconsistent with the General Plan’s guidance on designation
of DCs because the Project site area (and the entire surrounding area within the City),
off Red Hill Avenue and east of SR-55, is exclusively designated for light industrial and
commercial use and is not connected to any of the City’s existing commercial
corridors, and is not a major activity area in the City relating to urban life in any
respect.4 (DEIR at 3-5, Figure 3-2.) The Project site area is surrounded by open spaces
and office parks, and would not be consistent with the character of any existing DC in
the City of Santa Ana. DCs are reserved for mixed-use developments that seek to be
3 City of Santa Ana, General Plan – Land Use Element, p. 60. Available at
https://www.santa-ana.org/sites/default/files/pb/general-plan/LandUse.pdf.
4 Id. at A-25, Exhibit A-5. This exhibit of the City’s General Plan maps the existing District
Centers of Santa Ana.
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integrated within the fabric of existing Santa Ana urban life—not on the outskirts of
the City within an office park zone that is disconnected from major activity centers.
The fact that the proposed Project will be located adjacent to the City of Tustin’s
Legacy Specific Plan area does not save the proposed change in land use designation
either. This area is current massively underdeveloped, and as the Applicant points out,
will only meet the current character of the site’s existing land use designation for
commercial use. (DEIR at 5.9-13.) And in any event, any result of the building up of
the Legacy Area in the future will not connect the Project to any of the City’s major
activity areas. The Applicant cannot depend on contingent plans in other cities to
support its proposed change.
The proposed change to a DC is not consistent with the language or intent of the
City’s General Plan and should be revised.
B. The DEIR’s Proposed Zoning Change to a Specific Development
District Conflicts with the City’s General Plan.
The Applicant also seeks to amend the site’s zoning designation from M1-Light
Industrial to a Specific Development District (SD). This zoning change would conflict
with the City’s General Plan because the Project site is not appropriate for a General
Plan amendment to a DC and thus the underlying zoning change would also be
inappropriate. SDs are designed to facilitate certain types of development within
suitable DCs.5
C. The Proposed Land Use Amendments Conflict with Orange County’s
Land Use Plan for John Wayne Airport
California requires every county with an airport that includes use by a scheduled airline,
or where the airport is operated for the benefit of the general public, to establish an
airport land use commission (ALUC). The purpose of the ALUC is to provide for
orderly development and expansion of airports and adoption of "land use measures
that minimize the public's exposure to excessive noise and safety hazards within areas
around public airports to the extent that these areas are not already devoted to
incompatible uses." (Cal. P.U.C. §21670(a).) ALUCs cannot exempt a city or county's
specific plan (i.e., the portion of the locality's general plan affecting land in the vicinity
of an airport) from compliance with the ALUC's more stringent compatibility
5 City of Santa Ana, General Plan – Housing Element, p. 57. Available at https://www.santa-
ana.org/sites/default/files/Housing%20Element.pdf.
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standards for land use and development density. (87 Ops. Cal. Atty. Gen. 102 (2004).)
However, Cal. P.U.C. §21676 provides a procedure for resolving such conflicts. All
general or specific plans, zoning ordinances, building regulations, or modifications that
purport to affect land within the planning boundaries of an ALUC must be submitted
by the city, county, or regional authority proposing the action to review by the ALUC.
If the ALUC finds that there is an inconsistency between its ALUCP and the proposed
regulation, the ALUC must notify the local agency of its determination. The local
agency must then hold a public hearing on the matter and may override the
determination of the ALUC only by a two-thirds vote of its legislative body and after
specified findings are made. (Gov. Code §65302.3; Cal. P.U.C. §21676.)
The proposed Project is a mere 2.2 miles southwest of John Wayne Airport (JWA) and
within its planning area boundaries. If any part of the Project conflicts with JWA’s
Airport Environs Land Use Plan (AELUP; hereafter “JWA AELUP”), the City shall
seek review to obtain approval. Here, the proposed change in land use is inconsistent
with the JWA AELUP. The record does not contain substantial evidence that future
residents would not be adversely affected by aircraft noise. (DEIR at 5.9-22.) Policy
3.2.1 under the JWA AELUP finds an inconsistency with any proposed land use that
will put residents in a position “so that they are affected adversely by aircraft noise.”6
An adverse noise impact under the JWA AELUP is defined under a “reasonable
person” standard found in the Noise Standards for California Airports.
The DEIR concludes that there would be no adverse impact as a result of aircraft
noise, but not as a result of any field study the Applicant or City performed on the site.
This conclusion is based solely on the fact that the site is “located outside the airport’s
60 CNEL contours.” (DEIR at 5.7-26; Noise Impact Analysis at 1.) As the DEIR
admits, residential land uses are only “normally consistent” with areas just beyond 60
CNEL contours. The Orange County Airport Land Use Commission also strongly
recommended in its NOP comments that no residential units should be built on the
proposed Project site, or at least a significantly reduced number to adequately mitigate
the noise impacts. (DEIR at 5.9-3.) This indicates further information is needed to
assess the actual decibel level on-site and whether that meets a reasonable person
standard as defined in the Noise Standards for California Airports.
6 JWA AELUP, p. 21, available at
http://www.ocair.com/commissions/aluc/docs/jwa_aelup-april-17-2008.pdf.
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IV. CONCLUSION
Commenters request that the City revise and recirculate the Project’s environmental
impact report to address the aforementioned concerns. If the City has any questions or
concerns, feel free to contact my Office.
Sincerely,
__________________________
Mitchell M. Tsai
Attorneys for Southwest Regional
Council of Carpenters
ATTACHED:
Air Quality and GHG Expert, Matt Hagemann, P.G., C.Hg. – C.V. (Exhibit A);
Air Quality and GHG Expert, Paul Rosenfeld, P.G., C.Hg. – C.V. (Exhibit B);
Letter and attachments from Hagemann to Mitchell M. Tsai re Comments on The
Bowery Mixed-Use Project (Exhibit C);
California Air Pollution Control Officers Association (CAPCOA) Report: Quantifying
Greenhouse Gas Mitigation Measures (Exhibit D).
EXHIBIT A
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
mhagemann@swape.com
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
Industrial Stormwater Compliance
CEQA Review
Education:
M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.
B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.
Professional Certifications:
California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:
Matt has 30 years of experience in environmental policy, contaminant assessment and remediation,
stormwater compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA and
Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional
Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with
EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major
military facilities undergoing base closure. He led numerous enforcement actions under provisions of
the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve hydrogeologic
characterization and water quality monitoring. For the past 15 years, as a founding partner with SWAPE,
Matt has developed extensive client relationships and has managed complex projects that include
consultation as an expert witness and a regulatory specialist, and a manager of projects ranging from
industrial stormwater compliance to CEQA review of impacts from hazardous waste, air quality and
greenhouse gas emissions.
Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present);
• Geology Instructor, Golden West College, 2010 – 2104, 2017;
• Senior Environmental Analyst, Komex H2O Science, Inc. (2000 ‐‐ 2003);
2
• Executive Director, Orange Coast Watch (2001 – 2004);
• Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989–
1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000);
• Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 –
1998);
• Instructor, College of Marin, Department of Science (1990 – 1995);
• Geologist, U.S. Forest Service (1986 – 1998); and
• Geologist, Dames & Moore (1984 – 1986).
Senior Regulatory and Litigation Support Analyst:
With SWAPE, Matt’s responsibilities have included:
• Lead analyst and testifying expert in the review of over 300 environmental impact reports
and negative declarations since 2003 under CEQA that identify significant issues with regard
to hazardous waste, water resources, water quality, air quality, greenhouse gas emissions,
and geologic hazards. Make recommendations for additional mitigation measures to lead
agencies at the local and county level to include additional characterization of health risks
and implementation of protective measures to reduce worker exposure to hazards from
toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at more than 150 industrial
facilities.
• Expert witness on numerous cases including, for example, perfluorooctanoic acid (PFOA)
contamination of groundwater, MTBE litigation, air toxins at hazards at a school, CERCLA
compliance in assessment and remediation, and industrial stormwater contamination.
• Technical assistance and litigation support for vapor intrusion concerns.
• Lead analyst and testifying expert in the review of environmental issues in license applications
for large solar power plants before the California Energy Commission.
• Manager of a project to evaluate numerous formerly used military sites in the western U.S.
• Manager of a comprehensive evaluation of potential sources of perchlorate contamination in
Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the
review of releases of gasoline to sources drinking water at major refineries and hundreds of gas
stations throughout California.
With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony
by the former U.S. EPA Administrator and General Counsel.
• Senior researcher in the development of a comprehensive, electronically interactive chronology
of MTBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology
of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking
water treatment, results of which were published in newspapers nationwide and in testimony
against provisions of an energy bill that would limit liability for oil companies.
• Research to support litigation to restore drinking water supplies that have been contaminated by
MTBE in California and New York.
3
• Expert witness testimony in a case of oil production‐related contamination in Mississippi.
• Lead author for a multi‐volume remedial investigation report for an operating school in Los
Angeles that met strict regulatory requirements and rigorous deadlines.
• Development of strategic approaches for cleanup of contaminated sites in consultation with
clients and regulators.
Executive Director:
As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange
County beaches from multiple sources of contamination including urban runoff and the discharge of
wastewater. In reporting to a Board of Directors that included representatives from leading Orange
County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection
of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the
development of countywide water quality permits for the control of urban runoff and permits for the
discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including
Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business
institutions including the Orange County Business Council.
Hydrogeology:
As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to
characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point
Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army
Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of
monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and
groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory
analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation
development through work on four national U.S. EPA workgroups, including the Superfund
Groundwater Technical Forum and the Federal Facilities Forum.
At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of
groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to
show zones of vulnerability, and the results were adopted and published by the State of Hawaii and
County of Maui.
As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the
Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included
the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for
the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities
through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted
4
public hearings, and responded to public comments from residents who were very concerned
about the impact of designation.
• Reviewed a number of Environmental Impact Statements for planned major developments,
including large hazardous and solid waste disposal facilities, mine reclamation, and water
transfer.
Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance
with Subtitle C requirements.
• Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste.
• Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed
the basis for significant enforcement actions that were developed in close coordination with U.S.
EPA legal counsel.
• Wrote contract specifications and supervised contractor’s investigations of waste sites.
With the National Park Service, Matt directed service‐wide investigations of contaminant sources to
prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the
Clean Water Act to control military, mining, and landfill contaminants.
• Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and
Olympic National Park.
• Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico
and advised park superintendent on appropriate response actions under CERCLA.
• Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a
national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while
serving on a national workgroup.
• Co‐authored two papers on the potential for water contamination from the operation of personal
watercraft and snowmobiles, these papers serving as the basis for the development of nation‐
wide policy on the use of these vehicles in National Parks.
• Contributed to the Federal Multi‐Agency Source Water Agreement under the Clean Water
Action Plan.
Policy:
Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection
Agency, Region 9.
Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the
potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking
water supplies.
• Shaped EPA’s national response to these threats by serving on workgroups and by contributing
to guidance, including the Office of Research and Development publication, Oxygenates in
Water: Critical Information and Research Needs.
• Improved the technical training of EPAʹs scientific and engineering staff.
• Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in
negotiations with the Administrator and senior management to better integrate scientific
5
principles into the policy‐making process.
• Established national protocol for the peer review of scientific documents.
Geology:
With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for
timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical
models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource
protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the
city of Medford, Oregon.
As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later
listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern
Oregon. Duties included the following:
• Supervised year‐long effort for soil and groundwater sampling.
• Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.
Teaching:
From 1990 to 1998, Matt taught at least one course per semester at the community college and university
levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in
environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater
contamination.
• Served as a committee member for graduate and undergraduate students.
• Taught courses in environmental geology and oceanography at the College of Marin.
Matt is currently a part time geology instructor at Golden West College in Huntington Beach, California
where he taught from 2010 to 2014 and in 2017.
Invited Testimony, Reports, Papers and Presentations:
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public
Environmental Law Conference, Eugene, Oregon.
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.
EPA Region 9, San Francisco, California.
Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and
Public Participation. Brownfields 2005, Denver, Coloradao.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las
Vegas, NV (served on conference organizing committee).
6
Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at
schools in Southern California, Los Angeles.
Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE
Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.
Presentation to the Ground Water and Environmental Law Conference, National Groundwater
Association.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust,
Phoenix, AZ (served on conference organizing committee).
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy
of Sciences, Irvine, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a
tribal EPA meeting, Pechanga, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a
meeting of tribal repesentatives, Parker, AZ.
Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water
Supplies. Invited presentation to the Inter‐Tribal Meeting, Torres Martinez Tribe.
Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.
Invited presentation to the U.S. EPA Region 9.
Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited
presentation to the California Assembly Natural Resources Committee.
Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of
the National Groundwater Association.
Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a
meeting of the National Groundwater Association.
Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address
Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental
Journalists.
Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater
(and Who Will Pay). Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage
Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and
State Underground Storage Tank Program managers.
7
Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished
report.
Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.
Unpublished report.
Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage
Tanks. Unpublished report.
Hagemann, M.F., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related
to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.
VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft
Usage. Water Resources Division, National Park Service, Technical Report.
Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright
Society Biannual Meeting, Asheville, North Carolina.
Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund
Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.
Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air
Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.
Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic
Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui,
October 1996.
Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu,
Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air
and Waste Management Association Publication VIP‐61.
Hagemann, M.F., 1994. Groundwater Ch ar ac te r i z a t i o n and Cl ean up a t Closing Military Bases
in California. Proceedings, California Groundwater Resources Association Meeting.
Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater
Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of
Groundwater.
Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐
contaminated Groundwater. California Groundwater Resources Association Meeting.
8
Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of
Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.
Other Experience:
Selected as subject matter expert for the California Professional Geologist licensing examinations,
2009‐2011.
EXHIBIT B
SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.
Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: prosenfeld@swape.com
Paul E. Rosenfeld, Ph.D. Page 1 of 10 June 2019
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling
Principal Environmental Chemist Risk Assessment & Remediation Specialist
Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.
M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.
B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment.
Professional Experience
Dr. Rosenfeld has over 25 years’ experience conducting environmental investigations and risk assessments for
evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and
transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.
Rosenfeld has evaluated and modeled emissions from unconventional oil drilling operations, oil spills, landfills,
boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, and many other industrial
and agricultural sources. His project experience ranges from monitoring and modeling of pollution sources to
evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities.
Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites
containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents,
pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, perchlorate,
asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among
other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is
an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance
impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld
directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about
pollution sources causing nuisance and/or personal injury at dozens of sites and has testified as an expert witness on
more than ten cases involving exposure to air contaminants from industrial sources.
Paul E. Rosenfeld, Ph.D. Page 2 of 10 June 2019
Professional History:
Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner
UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher)
UCLA School of Public Health; 2003 to 2006; Adjunct Professor
UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator
UCLA Institute of the Environment, 2001-2002; Research Associate
Komex H2O Science, 2001 to 2003; Senior Remediation Scientist
National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor
Anteon Corp., San Diego, 2000-2001; Remediation Project Manager
Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager
Bechtel, San Diego, California, 1999 – 2000; Risk Assessor
King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist
Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist
Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist
Publications:
Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil
Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48
Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property
Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C.,
(2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated
Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.
Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.
Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and
Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.
Procedia Environmental Sciences. 113–125.
Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and
Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal
of Environmental Health. 73(6), 34-46.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living
near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air
Pollution, 123 (17), 319-327.
Paul E. Rosenfeld, Ph.D. Page 3 of 10 June 2019
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid
Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two
Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins
And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527-
000530.
Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near
a Former Wood Treatment Facility. Environmental Research. 105, 194-197.
Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for
Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.
Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater,
Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.
Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food,
Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science
and Technology. 49(9),171-178.
Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme
For The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC)
2004. New Orleans, October 2-6, 2004.
Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities,
and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science
and Technology, 49( 9), 171-178.
Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from
Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.
Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using
High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management
Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.
Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water
Soil and Air Pollution. 127(1-4), 173-191.
Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal
of Environmental Quality. 29, 1662-1668.
Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor
emissions and microbial activity. Water Environment Research. 73(4), 363-367.
Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and
Biosolids Odorants. Water Environment Research, 73, 388-393.
Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.
Water Environment Research. 131(1-4), 247-262.
Paul E. Rosenfeld, Ph.D. Page 4 of 10 June 2019
Chollack, T. and P. Rosenfeld. (1998). Compost Amendment Handbook For Landscaping. Prepared for and
distributed by the City of Redmond, Washington State.
Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).
Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users
Network, 7(1).
Rosenfeld, P. E. (1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids
Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.
Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters
thesis reprinted by the Sierra County Economic Council. Sierra County, California.
Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third
World. Bachelors Thesis. University of California.
Presentations:
Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile
organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American
Chemical Society. Lecture conducted from Santa Clara, CA.
Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.;
Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water.
Urban Environmental Pollution. Lecture conducted from Boston, MA.
Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse,
R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis,
Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.
Rosenfeld, P.E. (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS)
Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United
States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting, Lecture conducted
from Tuscon, AZ.
Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United
States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the
United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting. Lecture
conducted from Tuscon, AZ.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (20-22 July, 2009). Dioxin and furan blood lipid concentrations in
populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air
Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and
Management of Air Pollution. Lecture conducted from Tallinn, Estonia.
Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing
Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from
University of Massachusetts, Amherst MA.
Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A
Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23rd Annual International
Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst
MA.
Paul E. Rosenfeld, Ph.D. Page 5 of 10 June 2019
Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment
Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water. Lecture conducted
from University of Massachusetts, Amherst MA.
Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3-
Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting . Lecture
conducted from San Diego, CA.
Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala,
Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And
Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on
Halogenated Persistent Organic Pollutants – DIOXIN2006. Lecture conducted from Radisson SAS Scandinavia
Hotel in Oslo Norway.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And
Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting &
Exposition. Lecture conducted from Boston Massachusetts.
Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel,
Philadelphia, PA.
Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human
Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton
Hotel, Irvine California.
Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA
Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.
Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater
Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.
Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from
Sheraton Oceanfront Hotel, Virginia Beach, Virginia.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related
Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference.
Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human
Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and
Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability
and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental
Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.
Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.
Lecture conducted from Phoenix Arizona.
Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.
Meeting of tribal representatives. Lecture conducted from Parker, AZ.
Paul E. Rosenfeld, Ph.D. Page 6 of 10 June 2019
Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.
Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento,
California.
Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh
International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical
Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus
Conference. Water Supply and Emerging Contaminants.. Lecture conducted from Hyatt Regency Phoenix Arizona.
Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California
CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.
Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA
Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and
Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water
Association. Lecture conducted from Barcelona Spain.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.
Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association . Lecture
conducted from Barcelona Spain.
Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.
Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington..
Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a
Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from
Indianapolis, Maryland.
Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water
Environment Federation. Lecture conducted from Anaheim California.
Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted
from Ocean Shores, California.
Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery
Association. Lecture conducted from Sacramento California.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur
Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th
Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue
Washington.
Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil
Science Society of America. Lecture conducted from Salt Lake City Utah.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from
Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.
Rosenfeld, P.E., C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from
Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.
Paul E. Rosenfeld, Ph.D. Page 7 of 10 June 2019
Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur
Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th
Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue
Washington.
Rosenfeld, P.E., C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three
Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim
California.
Teaching Experience:
UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science
100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on
the health effects of environmental contaminants.
National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New
Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage
tanks.
National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1,
2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.
California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San
Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.
UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation
Technologies focusing on Groundwater Remediation.
University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry,
Organic Soil Amendments, and Soil Stability.
U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.
Academic Grants Awarded:
California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.
Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.
Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.
Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.
King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of
Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on
VOC emissions. 1998.
Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of
polymers and ash on VOC emissions from biosolids. 1997.
James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered
Poplar trees with resistance to round-up. 1996.
United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the
Tahoe National Forest. 1995.
Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts
in West Indies. 1993
Paul E. Rosenfeld, Ph.D. Page 8 of 10 June 2019
Deposition and/or Trial Testimony:
In the United States District Court For The District of New Jersey
Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.
Case No.: 2:17-cv-01624-ES-SCM
Rosenfeld Deposition. 6-7-2019
In the United States District Court of Southern District of Texas Galveston Division
M/T Carla Maersk, Plaintiffs, vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido”
Defendant.
Case No.: 3:15-CV-00106 consolidated with 3:15-CV-00237
Rosenfeld Deposition. 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica
Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants
Case No.: No. BC615636
Rosenfeld Deposition, 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica
The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants
Case No.: No. BC646857
Rosenfeld Deposition, 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado
Bells et al. Plaintiff vs. The 3M Company et al., Defendants
Case: No 1:16-cv-02531-RBJ
Rosenfeld Deposition, 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112th Judicial District
Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants
Cause No 1923
Rosenfeld Deposition, 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa
Simons et al., Plaintiffs vs. Chevron Corporation, et al., Defendants
Cause No C12-01481
Rosenfeld Deposition, 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois
Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants
Case No.: No. 0i9-L-2295
Rosenfeld Deposition, 8-23-2017
In The Superior Court of the State of California, For The County of Los Angeles
Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC
Case No.: LC102019 (c/w BC582154)
Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division
Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants
Case Number: 4:16-cv-52-DMB-JVM
Rosenfeld Deposition: July 2017
Paul E. Rosenfeld, Ph.D. Page 9 of 10 June 2019
In The Superior Court of the State of Washington, County of Snohomish
Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants
Case No.: No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial, March 2017
In The Superior Court of the State of California, County of Alameda
Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants
Case No.: RG14711115
Rosenfeld Deposition, September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants
Case No.: LALA002187
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Jerry Dovico, et al., Plaintiffs vs. Valley View Sine LLC, et al., Defendants
Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Doug Pauls, et al.,, et al., Plaintiffs vs. Richard Warren, et al., Defendants
Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.
Civil Action N0. 14-C-30000
Rosenfeld Deposition, June 2015
In The Third Judicial District County of Dona Ana, New Mexico
Betty Gonzalez, et al. Plaintiffs vs. Del Oro Dairy, Del Oro Real Estate LLC, Jerry Settles and Deward
DeRuyter, Defendants
Rosenfeld Deposition: July 2015
In The Iowa District Court For Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant
Case No 4980
Rosenfeld Deposition: May 2015
In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida
Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.
Case Number CACE07030358 (26)
Rosenfeld Deposition: December 2014
In the United States District Court Western District of Oklahoma
Tommy McCarty, et al., Plaintiffs, v. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City
Landfill, et al. Defendants.
Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014
Paul E. Rosenfeld, Ph.D. Page 10 of 10 June 2019
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.
Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants
Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition: October 2012
In the United States District Court of Southern District of Texas Galveston Division
Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and
on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.
Case 3:10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants
Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013
EXHIBIT C
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
mhagemann@swape.com
Paul E. Rosenfeld, PhD
(310) 795-2335
prosenfeld@swape.com
May 11, 2020
Mitchell M. Tsai
155 South El Molino Avenue
Suite 104
Pasadena, CA 91101
Subject: Comments on the Bowery Mixed-Use Project (SCH No. 2019090011)
Dear Mr. Tsai,
We have reviewed the January 2020 Draft Environmental Impact Report (“DEIR”) for the Bowery Mixed-
Use Project (“Project”) located in the City of Santa Ana (“City”). The Project proposes to demolish three
existing buildings totaling 212,121-square feet in order to construct 1,150 multi-family residential units
and 80,000-square feet of commercial retail/restaurant space, including an 18,000-square foot retail
shopping center, 5,000-square foot fast casual restaurant, 25,000-square foot quality restaurant,
25,000-square foot high turnover sit down restaurant, 5,000-square foot fast food restaurant, and
2,000-square foot coffee/donut shop. The Project also proposes to construct 183,363-square feet of
open space and recreation amenities and 2,355 parking spaces on the 14.58-acre site.
Our review concludes that the DEIR fails to adequately evaluate the Project’s Air Quality, Health Risk,
and Greenhouse Gas impacts. As a result, emissions and health risk impacts associated with construction
and operation of the proposed Project are underestimated and inadequately addressed. An updated EIR
should be prepared to adequately assess and mitigate the potential air quality and health risk impacts
that the project may have on the surrounding environment.
Air Quality Unsubstantiated Input Parameters Used to Estimate Project Emissions
The DEIR’s air quality analysis relies on emissions calculated with CalEEMod.2016.3.2.1 CalEEMod
provides recommended default values based on site-specific information, such as land use type,
1 CAPCOA (November 2017) CalEEMod User’s Guide, http://www.aqmd.gov/docs/default-
source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4.
2
meteorological data, total lot acreage, project type and typical equipment associated with project type.
If more specific project information is known, the user can change the default values and input project-
specific values, but the California Environmental Quality Act (CEQA) requires that such changes be
justified by substantial evidence.2 Once all of the values are inputted into the model, the Project's
construction and operational emissions are calculated, and "output files" are generated. These output
files disclose to the reader what parameters were utilized in calculating the Project's air pollutant
emissions and make known which default values were changed as well as provide justification for the
values selected.3
Review of the Project’s air modeling demonstrates that the DEIR underestimates emissions associated
with Project activities. As previously stated, the DEIR’s air quality analysis relies on air pollutant
emissions calculated using CalEEMod. When we reviewed the Project’s CalEEMod output files, provided
in Appendix B to the DEIR, we found that several of the values inputted into the model were not
consistent with information disclosed in the DEIR. As a result, the Project’s construction and operational
emissions are underestimated. An updated EIR should be prepared to include an updated air quality
analysis that adequately evaluates the impacts that construction and operation of the Project will have
on local and regional air quality.
Unsubstantiated Changes to Vehicle Emission Factors
The vehicle emission factors used to estimate the proposed Project’s operational emissions were
changed from the CalEEMod default values without proper justification. As a result, the model should
not be relied upon to determine Project significance.
According to the Project’s CalEEMod output files, 1,185 of the vehicle emission factors were manually
changed from their default values (Appendix B, pp. 114-158, 196-240, 277-321, 338-382). As previously
stated, the CalEEMod User Guide requires that any non-default values inputted must be justified.4
According to the “User Entered Comments & Non-Default Data” table, the justification provided for
these changes is: “EMFAC2017” (Appendix B, pp. 110, 193, 277, 338). However, EMFAC2017 refers to an
entire database, not a specific set of vehicle emission factors or calculations. The “User Entered
Comments & Non-Default Data” table or the DEIR should have specified which input parameters were
used to obtain the vehicle emission factors inputted in the model. As a result, we cannot verify these
values, and the model should not be relied upon to determine Project significance.
Use of Incorrect Trip Purpose Percentages in Proposed Land Use Model
Review of the Project’s CalEEMod output files demonstrates that the pass-by trip percentages utilized in
the model are inconsistent with the pass-by trip percentages indicated by the Traffic Impact Analysis
(TIA), provided as Appendix K to the DEIR. As a result, the model underestimates the Project’s
operational emissions.
2 Ibid, p. 1, 9.
3 Supra, fn 1, p. 11, 12 – 13. A key feature of the CalEEMod program is the “remarks” feature, where the user
explains why a default setting was replaced by a “user defined” value. These remarks are included in the report.
4 Supra, fn 1, p. 7, 13.
3
CalEEMod separates the operational trip purposes into three categories: primary, diverted, and pass-by
trips. According to Appendix A of the CalEEMod User’s Guide, the primary trips utilize the complete trip
lengths associated with each trip type category. Diverted trips are assumed to take a slightly different
path than a primary trip and are assumed to be 25% of the primary trip lengths. Pass-by trips are
assumed to be 0.1 miles in length and are a result of no diversion from the primary route.5 Review of the
Project’s CalEEMod output files demonstrates that the trip purpose percentages are inconsistent with
the trip purpose percentages indicated by the DEIR (see excerpt below) (Appendix B, pp. 330, 391).
As you can see in the excerpt above, the model assumes a 3% pass-by percentage for the apartment
land use, 17% for the fast food restaurant without drive-through, 69% for the fast food with drive-
through, 79% for the high turnover (sit down restaurant), 76% for quality restaurant, and 76% for
regional shopping center. However, these values are inconsistent with the pass-by trips indicated by the
DEIR. Based on the DEIR’s Proposed Project Trip Generation table, the apartment and parking land uses
are not expected to generate any pass-by trips, the fast food restaurant without drive through is
expected to generate 17%, the fast food restaurant with drive-through is expected to generate 31%, the
high turnover (sit down) restaurant is expected to generate 21%, the quality restaurant is expected to
generate 22%, and the regional shopping center/retail land use is expected to generate 24% (5.14-11,
Table 5.14-5). By including primary trip percentages that are inconsistent with information provided in
the DEIR, the model may underestimate the Project’s mobile-related operational emissions and should
not be relied upon to determine Project significance.
Use of Incorrect Saturday and Sunday Trip Rates
Review of the Project’s CalEEMod output files demonstrates that the Saturday and Sunday trip rates
inputted into the model are incorrect. The number of daily trips, including pass-by trips, are indicated in
the DEIR (see excerpt below) (p. 5.14-11, Table 5.14-5).
• the apartment land use is estimated to generate 6,092 daily trips;
• the high-turnover sit down restaurant is expected to generate 2,740 daily trips;
• the retail land use is expected to generate 636 daily trips;
• the quality restaurant is expected to generate 2,067 daily trips;
• the fast casual restaurant is expected to generate 1,564 daily trips;
5 “CalEEMod User’s Guide, Appendix A: Calculation Details for CalEEMod.” SCAQMD, available at:
http://www.aqmd.gov/docs/default-source/caleemod/caleemod-appendixa.pdf?sfvrsn=2, p. 20
4
• the fast-food restaurant without drive-through window is expected to generate 1,693 daily
trips; and
• the coffee/donut shop without drive-through window is expected to generate 1,607 trips.
However, review of the Project’s CalEEMod output files reveals that the total daily trips calculated for
Saturday and Sunday were underestimated for each of the proposed land uses (see excerpt below)
(Appendix B, pp. 329, 390).
5
As you can see in the excerpt above, the total number of vehicle trips for Saturday and Sunday are lower
than those indicated by the DEIR for the apartments, fast food restaurant with and without drive
through, high turnover (sit down) restaurant, quality restaurant, and regional shopping center. Thus, the
trip rates inputted into the model for these land uses are underestimated and as a result, the model
incorrectly estimates the Project’s operational mobile-source emissions.
Unsubstantiated Reduction in Commercial-Work Trip Length in Existing Model
Review of the Project’s CalEEMod output files demonstrates that the commercial-work (C-W) trip length
was manually increased in the model without adequate justification. As a result, the model may
underestimate the Project’s operational emissions.
Review of the Project’s CalEEMod output files demonstrates that the Project’s C-W trip length was
manually increased from the default value of 16.60 miles to 40 miles (see excerpt below) (Appendix B,
pp. 562, 620).
As previously stated, the CalEEMod User Guide requires that any non-default values inputted must be
justified.6 However, review of the “User Entered Comments & Non-Default Data” table demonstrates
that this change was not justified or even addressed. The DEIR and associated appendices also fail to
address this reduction. As a result, we cannot verify that this trip length is accurate and, as a result, the
model should not be relied upon to determine Project significance.
Use of Incorrect Trip Purpose Percentages in Existing Model
Review of the Project’s CalEEMod output files demonstrates that the pass-by and diverted trip
percentages used in the model were manually altered without sufficient justification. As a result, the
model underestimates the Project’s operational emissions.
6 Supra, fn 1, p. 7, 13.
6
CalEEMod separates the operational trip purposes into three categories: primary, diverted, and pass-by
trips. According to Appendix A of the CalEEMod User’s Guide, the primary trips utilize the complete trip
lengths associated with each trip type category. Diverted trips are assumed to take a slightly different
path than a primary trip and are assumed to be 25% of the primary trip lengths. Pass-by trips are
assumed to be 0.1 miles in length and are a result of no diversion from the primary route.7 Review of the
Project’s CalEEMod output files demonstrates that all of the trips were assumed to be primary, with
pass-by and diverted trips artificially reduced to zero (see excerpt below) (Appendix B, pp. 446, 504, 562,
620).
As you can see in the excerpt above, the diverted and pass-by trips were manually reduced to zero,
while the primary trips were increased to 100 percent in the model. As previously stated, the CalEEMod
User’s Guide requires that any non-default values inputted into the model must be justified.8 According
to the “User Entered Comments & Non-Default Data” table, the justification provided for these changes
is: “Trip Rates based on information provided in the Trip Generation” (Appendix B, pp. 401, 459, 517,
575). However, the trip generation indicated in the DEIR fails to substantiate the reduction of pass-by or
diverted trips in the existing model. Thus, the model overestimates the existing land use’s mobile-
related operational emissions and should not be relied upon to determine Project significance. Failure to Implement All Feasible Mitigation to Reduce Emissions
The DEIR determines that the Project’s operational VOC emissions would exceed the applicable
SCAQMD threshold (see excerpt below) (p. 5.2-17, Table 5.2-8).
7 “CalEEMod User’s Guide, Appendix A: Calculation Details for CalEEMod.” SCAQMD, available at:
http://www.aqmd.gov/docs/default-source/caleemod/caleemod-appendixa.pdf?sfvrsn=2, p. 20
8 Supra, fn 1, p. 7, 13.
7
The DEIR goes on to claim,
“As shown, emissions from operation of the proposed Project would exceed the threshold of
significance for VOCs. The majority of VOC emissions would be derived from consumer products
and mobile activity. Consumer products include cleaning supplies, kitchen aerosols, cosmetics
and toiletries, the use of which cannot be controlled by the City. Likewise, vehicular emissions
cannot be controlled by either the Project applicant or the City. There are no feasible mitigation
measures that would reduce VOC emissions to below the SCAQMD threshold. Therefore,
operational emissions would be significant and unavoidable” (p. 5.2-16).
However, while we agree that the Project would result in a significant VOC impact, the DEIR’s conclusion
that these impacts are “significant and unavoidable” is incorrect. According to the California
Environmental Quality Act (CEQA),
“CEQA requires Lead Agencies to mitigate or avoid significant environmental impacts associated
with discretionary projects. Environmental documents for projects that have any significant
environmental impacts must identify all feasible mitigation measures or alternatives to reduce
the impacts below a level of significance. If after the identification of all feasible mitigation
measures, a project is still deemed to have significant environmental impacts, the Lead Agency
can approve a project, but must adopt a Statement of Overriding Consideration to explain why
8
further mitigation measures are not feasible and why approval of a project with significant
unavoidable impacts is warranted.” 9
As you can see, an impact can only be labeled as significant and unavoidable after all available, feasible
mitigation is considered. However, as previously stated, the DEIR determines that “[t]here are no
feasible mitigation measures that would reduce VOC emissions to below the SCAQMD threshold” (p.
5.2-16). However, this is incorrect, and as a result, mitigation measures should be identified and
incorporated, such as those suggested in the section of this letter titled “Feasible Mitigation Measures
Available to Reduce Operational Emissions,”10 in order to reduce the Project’s air quality impacts to the
maximum extent possible. Until all feasible mitigation is reviewed and incorporated into the Project,
impacts from operational VOC cannot be considered significant and unavoidable. Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated
The DEIR concludes that the Project’s construction and operational health risk impacts would be less
than significant without conducting a quantified construction or operational health risk assessment
(HRA). More specifically, the DEIR attempts to justify this claim by stating:
“According to SCAQMD LST methodology, LSTs would apply to the operational phase of a
proposed project, if the project includes stationary sources, or attracts mobile sources that may
spend long periods queuing and idling at the site (e.g., transfer facilities and warehouse
buildings). The proposed project does not include such uses, and thus, due to the lack of
significant stationary source emissions, no long-term localized significance threshold analysis is
needed” (Appendix B, pp. 49).
The DEIR goes on to state,
“Results of the LST analysis indicate that, with application of mitigation, the Project will not
exceed the SCAQMD localized significance thresholds during construction. Therefore, sensitive
receptors would not be exposed to substantial criteria pollutant concentration during Project
construction. Results of the LST analysis indicate that the Project will not exceed the SCAQMD
localized significance thresholds during operational activity...Therefore, sensitive receptors
would not be exposed to substantial pollutant concentrations as the result of Project
operations” (Appendix B, pp. 54).
However, these justifications and subsequent less than significant impact finding are incorrect for
several reasons.
First, the use of the LST method to determine the Projects health risk impacts on nearby, existing
sensitive receptors is incorrect. While the LST method assesses the impact of pollutants at a local level, it
only evaluates impacts from criteria air pollutants. According to the Final Localized Significance
Threshold Methodology document prepared by the SCAQMD, the LST analysis is only applicable to NOx,
9 http://www.valleyair.org/transportation/GAMAQI_3-19-15.pdf, p. 115 of 125
10 See section titled “Feasible Mitigation Measures Available to Reduce Operational Emissions” on p. 19 of this
comment letter. These measures would effectively reduce operational VOC emissions.
9
CO, PM10, and PM2.5 emissions, which are collectively referred to as criteria air pollutants.11 Because the
LST method can only be applied to criteria air pollutants, this method cannot be used to determine
whether emissions from DPM, a known human carcinogen, will result in a significant health risk impact
to nearby sensitive receptors. As a result, health impacts from exposure to toxic air contaminants
(TACs), such as diesel particulate matter (DPM), were not analyzed, thus leaving a gap within the DEIR’s
analysis.
Second, the omission of a quantified HRA is inconsistent with the most recent guidance published by the
Office of Environmental Health Hazard Assessment (OEHHA), the organization responsible for providing
guidance on conducting HRAs in California. In February of 2015, OEHHA released its most recent Risk
Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments.12 This guidance
document describes the types of projects that warrant the preparation of an HRA. Construction of the
Project will produce emissions of DPM, a human carcinogen, through the exhaust stacks of construction
equipment over a construction period of approximately 26 months (Appendix B, pp. 247). The OEHHA
document recommends that all short-term projects lasting at least two months be evaluated for cancer
risks to nearby sensitive receptors.13 Therefore, per OEHHA guidelines, we recommend that health risk
impacts from Project construction be evaluated by the DEIR. Furthermore, once construction of the
Project is complete, the Project will operate for a long period of time. As previously stated, Project
operation will generate approximately 11,546 daily vehicle trips, which will generate additional exhaust
emissions and continue to expose nearby sensitive receptors to DPM emissions (p. 5.14-11, Table 5.14-
5). The OEHHA document recommends that exposure from projects lasting more than 6 months be
evaluated for the duration of the project, and recommends that an exposure duration of 30 years be
used to estimate individual cancer risk for the maximally exposed individual resident (MEIR).14 Even
though we were not provided with the expected lifetime of the Project, we can reasonably assume that
the Project will operate for at least 30 years, if not more. Therefore, we recommend that health risks
from Project operation also be evaluated, as a 30-year exposure duration vastly exceeds the 2-month
and 6-month requirements set forth by OEHHA. This guidance reflects the most recent health risk policy,
and as such, we recommend that an updated assessment of health risks to nearby sensitive receptors
from Project construction and operation be included in a revised CEQA evaluation for the Project.
Third, by claiming a less than significant impact without conducting a quantified HRA to nearby, existing
sensitive receptors as a result of Project construction, the DEIR fails to compare the excess health risk to
11 “Final Localized Significance Threshold Methodology.” SCAQMD, Revised July 2008, available at:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/localized-significance-thresholds/final-lst-
methodology-document.pdf.
12 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: http://oehha.ca.gov/air/hot_spots/hotspots2015.html
13 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf, p. 8-18
14 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf, p. 8-6, 8-15
10
the SCAQMD’s specific numeric threshold of 10 in one million.15 Thus, the DEIR cannot conclude less
than significant health risk impacts resulting from Project construction without quantifying emissions to
compare to the proper threshold. Screening-Level Assessment Indicates Significant Impact
In an effort to demonstrate the potential risk posed by Project construction and all Project operation to
nearby sensitive receptors, we prepared a simple screening-level HRA. The results of our assessment, as
described below, provide substantial evidence that the Project’s construction and operational DPM
emissions may result in a potentially significant health risk impact not previously identified by the DEIR.
In order to conduct our screening level risk assessment, we relied upon AERSCREEN, which is a screening
level air quality dispersion model. 16 The model replaced SCREEN3, and AERSCREEN is included in the
OEHHA 17 and the California Air Pollution Control Officers Associated (CAPCOA)18 guidance as the
appropriate air dispersion model for Level 2 health risk screening assessments (“HRSAs”). A Level 2 HRSA
utilizes a limited amount of site-specific information to generate maximum reasonable downwind
concentrations of air contaminants to which nearby sensitive receptors may be exposed. If an
unacceptable air quality hazard is determined to be possible using AERSCREEN, a more refined modeling
approach is required prior to approval of the Project.
We prepared a preliminary HRA of the Project’s construction and operational health-related impact to
residential sensitive receptors using the annual PM10 exhaust estimates from CalEEMod. For the
Project’s construction emissions, we used the CalEEMod output files provided in the DEIR. For the
Project’s operational emissions, we used SWAPE’s updated operational CalEEMod output files and
subtracted SWAPE’s updated existing (passenger cars) and updated existing (trucks) CalEEMod output
files. According to the DEIR, the closest sensitive receptor is located approximately 440 meters south of
the Project site (p. 5.2-11). Consistent with recommendations set forth by OEHHA, we assumed
exposure begins during the third trimester stage of life. The Project’s construction CalEEMod output files
indicate that construction activities will generate approximately 507 pounds of diesel particulate matter
(DPM) over the 795-day construction period. The AERSCREEN model relies on a continuous average
emission rate to simulate maximum downward concentrations from point, area, and volume emission
sources. To account for the variability in equipment usage and truck trips over Project construction, we
calculated an average DPM emission rate by the following equation:
15 “South Coast AQMD Air Quality Significance Thresholds.” SCAQMD, April 2019, available at:
http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance-
thresholds.pdf?sfvrsn=2
16 “AERSCREEN Released as the EPA Recommended Screening Model,” USEPA, April 11, 2011, available at:
http://www.epa.gov/ttn/scram/guidance/clarification/20110411_AERSCREEN_Release_Memo.pdf
17 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf
18 “Health Risk Assessments for Proposed Land Use Projects,” CAPCOA, July 2009, available at:
http://www.capcoa.org/wp-content/uploads/2012/03/CAPCOA_HRA_LU_Guidelines_8-6-09.pdf
11
𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 �𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸𝐸𝐸𝑅𝑅𝑠𝑠𝐸𝐸𝐸𝐸𝑠𝑠�= 506.6 𝑙𝑙𝑙𝑙𝐸𝐸 795 𝑠𝑠𝑅𝑅𝑑𝑑𝐸𝐸 × 453.6 𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸𝑙𝑙𝑙𝑙𝐸𝐸 × 1 𝑠𝑠𝑅𝑅𝑑𝑑24 ℎ𝐸𝐸𝑜𝑜𝑔𝑔𝐸𝐸 × 1 ℎ𝐸𝐸𝑜𝑜𝑔𝑔3,600 𝐸𝐸𝑅𝑅𝑠𝑠𝐸𝐸𝐸𝐸𝑠𝑠𝐸𝐸 =𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 𝒈𝒈/𝒔𝒔
Using this equation, we estimated a construction emission rate of 0.003346 grams per second (g/s).
Subtracting the 795-day construction duration from the total residential duration of 30 years, we
assumed that after Project construction, the sensitive receptor would be exposed to the Project’s
operational DPM for an additional 27.82 years, approximately. The Project’s operational CalEEMod
emissions, calculated by subtracting the existing emissions from the proposed Project, indicate that
operational activities will generate approximately 530 pounds of DPM per year throughout operation.
Applying the same equation used to estimate the construction DPM rate, we estimated the following
emission rate for Project operation:
𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 �𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸𝐸𝐸𝑅𝑅𝑠𝑠𝐸𝐸𝐸𝐸𝑠𝑠�= 530.2 𝑙𝑙𝑙𝑙𝐸𝐸 365 𝑠𝑠𝑅𝑅𝑑𝑑𝐸𝐸 × 453.6 𝑔𝑔𝑔𝑔𝑅𝑅𝐸𝐸𝐸𝐸𝑙𝑙𝑙𝑙𝐸𝐸 × 1 𝑠𝑠𝑅𝑅𝑑𝑑24 ℎ𝐸𝐸𝑜𝑜𝑔𝑔𝐸𝐸 × 1 ℎ𝐸𝐸𝑜𝑜𝑔𝑔3,600 𝐸𝐸𝑅𝑅𝑠𝑠𝐸𝐸𝐸𝐸𝑠𝑠𝐸𝐸 =𝟎𝟎.𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎𝟎 𝒈𝒈/𝒔𝒔
Using this equation, we estimated an operational emission rate of 0.007626 g/s. Construction and
operational activity was simulated as a -acre rectangular area source in AERSCREEN with dimensions of
254.4 meters by 232 meters. A release height of three meters was selected to represent the height of
exhaust stacks on operational equipment and other heavy-duty vehicles, and an initial vertical
dimension of one and a half meters was used to simulate instantaneous plume dispersion upon release.
An urban meteorological setting was selected with model-default inputs for wind speed and direction
distribution.
The AERSCREEN model generates maximum reasonable estimates of single-hour DPM concentrations
from the Project site. EPA guidance suggests that in screening procedures, the annualized average
concentration of an air pollutant be estimated by multiplying the single-hour concentration by 10%.19 AS
previously stated, there are residential sensitive receptors located approximately 440 meters from the
Project site. The single—hour concentration estimated by AERSCREEN for Project construction is
approximately 0.5355 µg/m3 DPM at approximately 450 meters downwind. Multiplying this single-hour
concentration by 10%, we get an annualized average concentration 0.05355 µg/m3 for Project
construction at the nearest sensitive receptor. For Project operation, the single-hour concentration is
estimated by AERSCREEN is approximately 1.220 µg/m3 at approximately 450 meters downwind.
Multiplying this single- hour concentration by 10%, we get an annualized average concentration of 0.122
µg/m3 for Project operation at the nearest sensitive receptor.
We calculated the excess cancer risk to the closest sensitive receptor using applicable HRA
methodologies prescribed by OEHHA and the SCAQMD. Consistent with the construction schedule
included in the DEIR, the annualized average concentration for construction was used for the entire
third trimester of pregnancy (0.25 years) and the first 1.93 years of the infantile stage of life (0 – 2
19 “Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised.” EPA, 1992, available
at: http://www.epa.gov/ttn/scram/guidance/guide/EPA-454R-92-019_OCR.pdf; see also “Risk Assessment
Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February 2015, available at:
https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, p. 4-36
12
years). The annualized average concentration for operation was used for the remainder of the 30-year
exposure period, which makes up the remainder of the infantile stage of life (0 – 2 years), child stages of
life (2 – 16 years) and adult stages of life (16 – 30 years). Consistent with OEHHA, SCAQMD, BAAQMD,
and SJVAPCD guidance, we used Age Sensitivity Factors (ASFs) to account for the heightened
susceptibility of young children to the carcinogenic toxicity of air pollution.20, 21, 22, 23 According to this
guidance, the quantified cancer risk should be multiplied by a factor of ten during the third trimester of
pregnancy and during the first two years of life (infant) as well as multiplied by a factor of three during
the child stage of life (2 to 16 years). We also included the quantified cancer risk without adjusting for
the heightened susceptibility of young children to the carcinogenic toxicity of air pollution in accordance
with older OEHHA guidance from 2003. This guidance utilizes a less health protective scenario than what
is currently recommended by SCAQMD, the air quality district responsible for the City, and several other
air districts in the state. Furthermore, in accordance with guidance set forth by OEHHA, we used the 95th
percentile breathing rates for infants.24 Finally, according to SCAQMD guidance, we used a Fraction of
Time At Home (FAH) Value of 1 for the 3rd trimester and infant receptors.25 We used a cancer potency
factor of 1.1 (mg/kg-day)-1 and an averaging time of 25,550 days. The results of our calculations are
shown below.
The Closest Exposed Individual at an Existing Residential Receptor
Activity Duration
(years)
Concentration
(ug/m3)
Breathing
Rate (L/kg-
day)
Cancer Risk
without
ASFs*
ASF
Cancer
Risk with
ASFs*
Construction 0.25 0.05355 361 7.3E-08 10 7.3E-07
20 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf.
21 “Draft Environmental Impact Report (DEIR) for the Proposed The Exchange (SCH No. 2018071058).” SCAQMD,
March 2019, available at: http://www.aqmd.gov/docs/default-source/ceqa/comment-
letters/2019/march/RVC190115-03.pdf?sfvrsn=8, p. 4.
22 “California Environmental Quality Act Air Quality Guidelines.” BAAQMD, May 2017, available at:
http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en, p.
56; see also “Recommended Methods for Screening and Modeling Local Risks and Hazards.” BAAQMD, May 2011,
available at:
http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CEQA/BAAQMD%20Modeling%20Approac
h.ashx, p. 65, 86.
23 “Update to District’s Risk Management Policy to Address OEHHA’s Revised Risk Assessment Guidance
Document.” SJVAPCD, May 2015, available at: https://www.valleyair.org/busind/pto/staff-report-5-28-15.pdf, p. 8,
20, 24.
24 “Supplemental Guidelines for Preparing Risk Assessments for the Air Toxics ‘Hot Spots’ Information and
Assessment Act,” June 5, 2015, available at: http://www.aqmd.gov/docs/default-source/planning/risk-
assessment/ab2588-risk-assessment-guidelines.pdf?sfvrsn=6, p. 19.
“Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf
25 “Risk Assessment Procedures for Rules 1401, 1401.1, and 212.” SCAQMD, August 2017, available at:
http://www.aqmd.gov/docs/default-source/rule-book/Proposed-
Rules/1401/riskassessmentprocedures_2017_080717.pdf, p. 7.
13
3rd Trimester
Duration 0.25 7.3E-08
3rd
Trimester
Exposure
7.3E-07
Construction 1.93 0.05355 1090 1.7E-06 10 1.7E-05
Operation 0.07 0.122 1090 1.4E-07 10 1.4E-06
Infant Exposure
Duration 2.00 1.8E-06 Infant
Exposure 1.8E-05
Operation 14.00 0.122 572 1.5E-05 3 4.4E-05
Child Exposure
Duration 14.00 1.5E-05 Child
Exposure 4.4E-05
Operation 14.00 0.122 261 4.9E-06 1 4.9E-06
Adult Exposure
Duration 14.00 4.9E-06 Adult
Exposure 4.9E-06
Lifetime Exposure
Duration 30.00 2.2E-05 Lifetime
Exposure 6.8E-05
* We, along with CARB and SCAQMD, recommend using the more updated and health protective 2015 OEHHA guidance, which includes ASFs.
The excess cancer risk posed to adults, children, infants, and during the third trimester of pregnancy at
the closest receptor, located approximately 450 meters away, over the course of Project construction
and operation, utilizing age sensitivity factors, are approximately 4.9, 44, 180, and 0.73 in one million,
respectively. The excess cancer risk over the course of a residential lifetime (30 years) at the closest
receptor, with age sensitivity factors, is approximately 68 in one million. The infant, child, and lifetime
cancer risks, using age sensitivity factors, all exceed the SCAQMD threshold of 10 in one million, thus
resulting in a potentially significant impact not previously addressed or identified by the DEIR. Results
without age sensitivity factors are presented in the table above, although we do not recommend
utilizing these values for health risk analysis, as they are less conservative and health-protective
according to the most recent guidance. Regardless, the excess cancer risk over the course of a
residential lifetime (30 years) at the closest receptor, without age sensitivity factors, is approximately 22
in one million. Thus, the Project may result in a significant impact regardless of the use of age sensitivity
factors.
An agency must include an analysis of health risks that connects the Project’s air emissions with the
health risk posed by those emissions. Our analysis represents a screening-level HRA, which is known to
be conservative and tends to err on the side of health protection. The purpose of the screening-level
construction HRA shown above is to demonstrate the link between the proposed Project’s emissions
and the potential health risk. Our screening-level HRA demonstrates that construction of the Project
could result in a potentially significant health risk impact, when correct exposure assumptions and up-
to-date, applicable guidance are used. Therefore, since our screening-level construction HRA indicates a
potentially significant impact, an updated CEQA analysis should include a reasonable effort to connect
the Project’s air quality emissions and the potential health risks posed to nearby receptors. Thus, an
updated CEQA analysis should include a quantified air pollution model as well as an updated, quantified
14
refined health risk assessment which adequately and accurately evaluates health risk impacts associated
with both Project construction and operation.
Greenhouse Gas Failure to Implement All Feasible Mitigation
The DEIR concludes that the proposed Project would result in 9,861.60 megatons of CO2 equivalents per
year (MT CO2e/year), which would exceed the SCAQMD Tier 3 mixed-use screening threshold of 3,000
MT CO2e/year (p. 5.6-22). As a result, the DEIR concludes that the Project’s GHG impact would be
potentially significant (p. 5.6-22).
In an attempt to mitigate this impact, the DEIR states:
“The Project would include sustainable design features and comply with Title 24/CalGreen
standards; however, approximately 60 percent of the GHG emissions would be generated by
vehicle trips. Neither the Project Applicant nor the Lead Agency (City of Santa Ana) can
substantively or materially reduce the vehicular-source GHG emissions” (p. 5.6-22).
Despite complying with Title 24 and CalGreen standards, the DEIR states that the Project’s GHG impact
would be significant and unavoidable (p. 5.6-22). However, while we agree that the Project’s GHG
impact would be significant, the DEIR’s assertion that the Project’s GHG impact would be unavoidable
and cannot be mitigated further is incorrect. According to CEQA Guidelines § 15096(g)(2),
“When an EIR has been prepared for a project, the Responsible Agency shall not approve the
project as proposed if the agency finds any feasible alternative or feasible mitigation measures
within its powers that would substantially lessen or avoid any significant effect the project
would have on the environment.”
As you can see, an impact can only be labeled as significant and unavoidable after all available, feasible
mitigation is considered.26 Review of the Project’s proposed mitigation measures, however,
demonstrates that the DEIR fails to implement all feasible mitigation. Therefore, the DEIR’s conclusion
that impacts are significant and unavoidable is unsubstantiated. As a result, additional mitigation
measures should be identified and incorporated in an updated EIR in order to reduce the Project’s air
quality impacts to the maximum extent possible. Until all feasible mitigation is reviewed and
incorporated into the Project’s design, impacts from GHG emissions should not be considered significant
and unavoidable. Feasible Mitigation Measures Available to Reduce Construction Emissions
Our analysis demonstrates that, when Project activities are modeled correctly, construction emissions
would result in potentially significant impacts. Therefore, additional mitigation measures must be
identified and incorporated in a DEIR to reduce these emissions to a less than significant level.
26 “Final Draft Guidance for Assessing and Mitigating Air Quality Impacts.” SVJUAPCD, February 2015, available at:
http://www.valleyair.org/transportation/GAMAQI-2015/FINAL-DRAFT-GAMAQI.PDF, p. 115.
15
Additional mitigation measures can be found in CAPCOA’s Quantifying Greenhouse Gas Mitigation
Measures, which attempt to reduce GHG levels, as well as reduce criteria air pollutants such as
particulate matter and NOx.27 DPM and NOx are a byproduct of diesel fuel combustion and are emitted
by on-road vehicles and by off-road construction equipment. Mitigation for criteria pollutant emissions
should include consideration of the following measures in an effort to reduce construction emissions.28
Require Implementation of Diesel Control Measures
The Northeast Diesel Collaborative (NEDC) is a regionally coordinated initiative to reduce diesel
emissions, improve public health, and promote clean diesel technology. The NEDC recommends that
contracts for all construction projects require the following diesel control measures: 29
• All diesel generators on site for more than 10 total days must be equipped with emission control
technology verified by EPA or CARB to reduce PM emissions by a minimum of 85 percent.
• All diesel vehicles, construction equipment, and generators on site shall be fueled with ultra-low
sulfur diesel fuel (ULSD) or a biodiesel blend 30 approved by the original engine manufacturer
with sulfur content of 15 parts per million (ppm) or less.
Repower or Replace Older Construction Equipment Engines
The NEDC recognizes that availability of equipment that meets the EPA’s newer standards is limited.31
Due to this limitation, the NEDC proposes actions that can be taken to reduce emissions from existing
equipment in the Best Practices for Clean Diesel Construction report.32 These actions include but are not
limited to:
• Repowering equipment (i.e. replacing older engines with newer, cleaner engines and leaving the
body of the equipment intact).
Engine repower may be a cost-effective emissions reduction strategy when a vehicle or machine has a
long useful life and the cost of the engine does not approach the cost of the entire vehicle or machine.
Examples of good potential replacement candidates include marine vessels, locomotives, and large
construction machines.33 Older diesel vehicles or machines can be repowered with newer diesel engines
or in some cases with engines that operate on alternative fuels. The original engine is taken out of
service and a new engine with reduced emission characteristics is installed. Significant emission
27http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf
28 For measures to reduce operational DPM emissions, see section titled “Additional Feasible Mitigation Measures
Available to Reduce Operational Emissions” on p. 25 of this letter. These measures would effectively reduce
operational VOC and NOx emissions, DPM emissions, as well as GHG emissions.
29 Diesel Emission Controls in Construction Projects, available
at:http://www2.epa.gov/sites/production/files/2015-09/documents/nedc-model-contract-sepcification.pdf
30 Biodiesel lends are only to be used in conjunction with the technologies which have been verified for use with
biodiesel blends and are subject to the following requirements:
http://www.arb.ca.gov/diesel/verdev/reg/biodieselcompliance.pdf
31http://northeastdiesel.org/pdf/BestPractices4CleanDieselConstructionAug2012.pdf
32http://northeastdiesel.org/pdf/BestPractices4CleanDieselConstructionAug2012.pdf
33 Repair, Rebuild, and Repower, EPA, available at:https://www.epa.gov/verified-diesel-tech/learn-about-verified-
technologies-clean-diesel#repair
16
reductions can be achieved, depending on the newer engine and the vehicle or machine’s ability to
accept a more modern engine and emission control system. It should be noted, however, that newer
engines or higher tier engines are not necessarily cleaner engines, so it is important that the Project
Applicant check the actual emission standard level of the current (existing) and new engines to ensure
the repower product is reducing emissions for DPM.34
• Replacement of older equipment with equipment meeting the latest emission standards.
Engine replacement can include substituting a cleaner highway engine for a nonroad engine. Diesel
equipment may also be replaced with other technologies or fuels. Examples include hybrid switcher
locomotives, electric cranes, LNG, CNG, LPG or propane yard tractors, forklifts or loaders.
Replacements using natural gas may require changes to fueling infrastructure.35 Replacements often
require some re-engineering work due to differences in size and configuration. Typically, there are
benefits in fuel efficiency, reliability, warranty, and maintenance costs.36
Install Retrofit Devices on Existing Construction Equipment
PM emissions from alternatively-fueled construction equipment can be further reduced by installing
retrofit devices on existing and/or new equipment. The most common retrofit technologies are retrofit
devices for engine exhaust after-treatment. These devices are installed in the exhaust system to reduce
emissions and should not impact engine or vehicle operation. 37 It should be noted that actual emissions
reductions and costs will depend on specific manufacturers, technologies and applications.
Use Electric and Hybrid Construction Equipment
CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures38 report also proposes the use of electric
and/or hybrid construction equipment as a way to mitigate DPM emissions. When construction
equipment is powered by grid electricity rather than fossil fuel, direct emissions from fuel combustion
are replaced with indirect emissions associated with the electricity used to power the equipment.
Furthermore, when construction equipment is powered by hybrid-electric drives, emissions from fuel
combustion are also greatly reduced. Electric construction equipment is available commercially from
companies such as Peterson Pacific Corporation,39 which specialize in the mechanical processing
equipment like grinders and shredders. Construction equipment powered by hybrid-electric drives is
also commercially available from companies such as Caterpillar.40 For example, Caterpillar reports that
34 Diesel Emissions Reduction Program (DERA): Technologies, Fleets and Projects Information, available
at:http://www2.epa.gov/sites/production/files/2015-09/documents/420p11001.pdf
35 Alternative Fuel Conversion, EPA, available at:
https://www3.epa.gov/otaq/consumer/fuels/altfuels/altfuels.htm#fact
36 Cleaner Fuels, EPA, available at:https://www.epa.gov/verified-diesel-tech/learn-about-verified-technologies-
clean-diesel#cleaner
37 Retrofit Technologies, EPA, available at:https://www.epa.gov/verified-diesel-tech/learn-about-verified-
technologies-clean-diesel#retrofit
38http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf
39 Peterson Electric Grinders Brochure, available at:http://www.petersoncorp.com/wp-
content/uploads/peterson_electric_grinders1.pdf
40 Electric Power Products, available at:http://www.cat.com/en_US/products/new/power-systems/electric-power-
generation.html
17
during an 8-hour shift, its D7E hybrid dozer burns 19.5 percent fewer gallons of fuel than a conventional
dozer while achieving a 10.3 percent increase in productivity. The D7E model burns 6.2 gallons per hour
compared to a conventional dozer which burns 7.7 gallons per hour.41 Fuel usage and savings are
dependent on the make and model of the construction equipment used. The Project Applicant should
calculate project-specific savings and provide manufacturer specifications indicating fuel burned per
hour.
Implement a Construction Vehicle Inventory Tracking System
CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures42 report recommends that the Project
Applicant provide a detailed plan that discusses a construction vehicle inventory tracking system to
ensure compliances with construction mitigation measures. The system should include strategies such
as requiring engine run time meters on equipment, documenting the serial number, horsepower,
manufacture age, fuel, etc. of all onsite equipment and daily logging of the operating hours of the
equipment. Specifically, for each on-road construction vehicle, nonroad construction equipment, or
generator, the contractor should submit to the developer’s representative a report prior to bringing said
equipment on site that includes:43
• Equipment type, equipment manufacturer, equipment serial number, engine manufacturer,
engine model year, engine certification (Tier rating), horsepower, and engine serial number.
• The type of emission control technology installed, serial number, make, model, manufacturer,
and EPA/CARB verification number/level.
• The Certification Statement 44 signed and printed on the contractor’s letterhead.
Furthermore, the contractor should submit to the developer’s representative a monthly report that, for
each on-road construction vehicle, nonroad construction equipment, or generator onsite, includes: 45
• Hour-meter readings on arrival on-site, the first and last day of every month, and on off-site
date.
• Any problems with the equipment or emission controls.
• Certified copies of fuel deliveries for the time period that identify:
o Source of supply
o Quantity of fuel
o Quality of fuel, including sulfur content (percent by weight)
41http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf
42http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf
43 Diesel Emission Controls in Construction Projects, available
at:http://www2.epa.gov/sites/production/files/2015-09/documents/nedc-model-contract-sepcification.pdf
44 Diesel Emission Controls in Construction Projects, available
at:http://www2.epa.gov/sites/production/files/2015-09/documents/nedc-model-contract-sepcification.pdf The
NEDC Model Certification Statement can be found in Appendix A.
45 Diesel Emission Controls in Construction Projects, available
at:http://www2.epa.gov/sites/production/files/2015-09/documents/nedc-model-contract-sepcification.pdf
18
In addition to these measures, we also recommend that the Project implement the following mitigation
measures, called “Enhanced Exhaust Control Practices,”46 that are recommended by the Sacramento
Metropolitan Air Quality Management District (SMAQMD):
1. The project representative shall submit to the lead agency a comprehensive inventory of all off-
road construction equipment, equal to or greater than 50 horsepower, that will be used an
aggregate of 40 or more hours during any portion of the construction project.
• The inventory shall include the horsepower rating, engine model year, and projected
hours of use for each piece of equipment.
• The project representative shall provide the anticipated construction timeline including
start date, and name and phone number of the project manager and on-site foreman.
• This information shall be submitted at least 4 business days prior to the use of subject
heavy-duty off-road equipment.
• The inventory shall be updated and submitted monthly throughout the duration of the
project, except that an inventory shall not be required for any 30-day period in which no
construction activity occurs.
2. The project representative shall provide a plan for approval by the lead agency demonstrating
that the heavy-duty off-road vehicles (50 horsepower or more) to be used in the construction
project, including owned, leased, and subcontractor vehicles, will achieve a project wide fleet-
average 20% NOX reduction and 45% particulate reduction compared to the most recent
California Air Resources Board (ARB) fleet average.
• This plan shall be submitted in conjunction with the equipment inventory.
• Acceptable options for reducing emissions may include use of late model engines, low-
emission diesel products, alternative fuels, engine retrofit technology, after-treatment
products, and/or other options as they become available.
• The District’s Construction Mitigation Calculator can be used to identify an equipment
fleet that achieves this reduction.
3. The project representative shall ensure that emissions from all off-road diesel-powered
equipment used on the project site do not exceed 40% opacity for more than three minutes in
any one hour.
• Any equipment found to exceed 40 percent opacity (or Ringelmann 2.0) shall be
repaired immediately. Non-compliant equipment will be documented and a summary
provided to the lead agency monthly.
• A visual survey of all in-operation equipment shall be made at least weekly.
• A monthly summary of the visual survey results shall be submitted throughout the
duration of the project, except that the monthly summary shall not be required for any
30-day period in which no construction activity occurs. The monthly summary shall
include the quantity and type of vehicles surveyed as well as the dates of each survey.
46http://www.airquality.org/ceqa/Ch3EnhancedExhaustControl_10-2013.pdf
19
4. The District and/or other officials may conduct periodic site inspections to determine
compliance. Nothing in this mitigation shall supersede other District, state or federal rules or
regulations.
Use of Spray Equipment with Greater Transfer Efficiencies
Various coatings and adhesives are required to be applied by specified methods such as electrostatic
spray, high-volume, low-pressure (HVLP) spray, roll coater, flow coater, dip coater, etc. in order to
maximize the transfer efficiency. Transfer efficiency is typically defined as the ratio of the weight of
coating solids adhering to an object to the total weight of coating solids used in the application process,
expressed as a percentage. When it comes to spray applications, the rules typically require the use of
either electrostatic spray equipment or HVLP spray equipment. The SCAQMD is now able to certify HVLP
spray applicators and other application technologies at efficiency rates of 65 percent or greater.47
These measures offer a cost-effective, feasible way to incorporate lower-emitting equipment into the
Project’s construction fleet, which subsequently reduces construction emissions. A revised EIR must be
prepared to include additional mitigation measures, as well as include an updated air quality assessment
to ensure that the necessary mitigation measures are implemented to reduce construction emissions.
Furthermore, the updated EIR needs to demonstrate commitment to the implementation of these
measures prior to Project approval to ensure that the Project’s construction-related emissions are
reduced to the maximum extent possible. Feasible Mitigation Measures Available to Reduce Operational Emissions
Our analysis demonstrates that the Project’s air quality and GHG emissions may result in a potentially
significant impact. In an effort to reduce the Project’s operational emissions, we identified several
mitigation measures that are applicable to the Project. Feasible mitigation measures can be found in
CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures, which attempt to reduce GHG levels, as
well as reduce criteria air pollutants, such as particulate matter emissions.48 Therefore, to reduce the
Project’s operational emissions, consideration of the following measures should be made.
• Integrate affordable and below market rate housing
• Energy-related mitigation:
o Install programmable thermostat timers
o Establish onsite renewable energy systems, including solar power and wind power
o Limit outdoor lighting requirements
o Reduce unnecessary outdoor lighting by utilizing design features such as limiting the
hours of operation of outdoor lighting.
o Provide education on energy efficiency to residents, customers, and/or tenants. Provide
information on energy management services for large energy users.
o Meet “reach” goals for building energy efficiency and renewable energy use.
o Limit the use of outdoor lighting to only that needed for safety and security purposes.
47 http://www.aqmd.gov/home/permits/spray-equipment-transfer-efficiency
48 http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-14-Final.pdf
20
o Require use of electric or alternatively fueled sweepers with HEPA filters.
o Include energy storage where appropriate to optimize renewable energy generation
systems and avoid peak energy use.
o Prohibit gas powered landscape equipment and implement electric yard equipment
compatibility
• Transportation-related mitigation:
o Provide EV parking
o Require residential area parking permits
o Implement ride-sharing, vanpool, shuttle, bike-sharing programs
o Provide bike parking near transit
o Provide local shuttles
o Implement area or cordon pricing
o Install a park-and-ride lot
• Water-related mitigation:
o Install an infiltration basin to provide an opportunity for 100% of the storm water to
infiltrate on-site.
o Install a system to reutilize gray water
o Use locally-sourced water supply
o Plant native and drought-resistant trees and vegetation
• Develop and follow a “green streets guide” that requires:
o Use of minimal amounts of concrete and asphalt;
o Use of groundcovers rather than pavement to reduce heat reflection.49
• Implement Project design features such as:
o Shade HVAC equipment from direct sunlight;
o Install high-albedo white thermoplastic polyolefin roof membrane;
o Install formaldehyde-free insulation; and
o Use recycled-content gypsum board.
o Require all buildings to become “LEED” and “WELL” certified.
• Plant low-VOC emitting shade trees, e.g., in parking lots to reduce evaporative emissions from
parked vehicles.
Finally, the Kimball Business Park Project Final Environmental Impact Report includes various feasible
mitigation measures that would reduce on-site area emissions that are applicable to the proposed
Project’s retail land use, and include, but are not limited to:50
• Increase in insulation such that heat transfer and thermal bridging is minimized.
• Limit air leakage through the structure and/or within the heating and cooling distribution
system.
49 Cool Houston Plan;
http://www.harcresearch.org/sites/default/files/documents/projects/CoolHoustonPlan_0.pdf
50 Mitigation Monitoring Plan for the Kimball Business Park Project Final Environmental Impact Report, July 2016.
21
• Installation of dual-paned or other energy efficient windows.
• Installation of automatic devices to turn off lights where they are not needed.
These measures offer a cost-effective, feasible way to incorporate lower-emitting design features into
the proposed Project, which subsequently, reduces emissions released during Project operation. An
updated EIR should be prepared to include additional mitigation measures, as well as include an
updated air quality analysis to ensure that the necessary mitigation measures are implemented to
reduce emissions to below thresholds. The EIR also needs to demonstrate commitment to the
implementation of these measures prior to Project approval, to ensure that the Project’s significant
emissions are reduced to the maximum extent possible.
SWAPE has received limited discovery regarding this project. Additional information may become
available in the future; thus, we retain the right to revise or amend this report when additional
information becomes available. Our professional services have been performed using that degree of
care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants
practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is
made as to the scope of work, work methodologies and protocols, site conditions, analytical testing
results, and findings presented. This report reflects efforts which were limited to information that was
reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or
otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by
third parties.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Paul E. Rosenfeld, Ph.D.
AERSCREEN 16216 / AERMOD 19191 02/07/20
18:20:58
TITLE: Bowery_Construction
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
****************************** AREA PARAMETERS ****************************
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
SOURCE EMISSION RATE: 0.335E‐02 g/s 0.266E‐01 lb/hr
AREA EMISSION RATE: 0.567E‐07 g/(s‐m2) 0.450E‐06 lb/(hr‐m2)
AREA HEIGHT: 3.00 meters 9.84 feet
AREA SOURCE LONG SIDE: 254.40 meters 834.65 feet
AREA SOURCE SHORT SIDE: 232.00 meters 761.15 feet
INITIAL VERTICAL DIMENSION: 1.50 meters 4.92 feet
RURAL OR URBAN: URBAN
POPULATION: 334136
INITIAL PROBE DISTANCE = 5000. meters 16404. feet
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
*********************** BUILDING DOWNWASH PARAMETERS **********************
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
BUILDING DOWNWASH NOT USED FOR NON‐POINT SOURCES
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
************************** FLOW SECTOR ANALYSIS ***************************
25 meter receptor spacing: 1. meters ‐ 5000. meters
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
MAXIMUM IMPACT RECEPTOR
Zo SURFACE 1‐HR CONC RADIAL DIST TEMPORAL
SECTOR ROUGHNESS (ug/m3) (deg) (m) PERIOD
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
1* 1.000 2.245 35 150.0 WIN
* = worst case diagonal
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
********************** MAKEMET METEOROLOGY PARAMETERS *********************
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
MIN/MAX TEMPERATURE: 250.0 / 310.0 (K)
MINIMUM WIND SPEED: 0.5 m/s
ANEMOMETER HEIGHT: 10.000 meters
SURFACE CHARACTERISTICS INPUT: AERMET SEASONAL TABLES
DOMINANT SURFACE PROFILE: Urban
DOMINANT CLIMATE TYPE: Average Moisture
DOMINANT SEASON: Winter
ALBEDO: 0.35
BOWEN RATIO: 1.50
ROUGHNESS LENGTH: 1.000 (meters)
SURFACE FRICTION VELOCITY (U*) NOT ADUSTED
METEOROLOGY CONDITIONS USED TO PREDICT OVERALL MAXIMUM IMPACT
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
YR MO DY JDY HR
‐‐ ‐‐ ‐‐ ‐‐‐ ‐‐
10 01 10 10 01
H0 U* W* DT/DZ ZICNV ZIMCH M‐O LEN Z0 BOWEN ALBEDO REF WS
‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50
HT REF TA HT
‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐
10.0 310.0 2.0
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
************************ AERSCREEN AUTOMATED DISTANCES **********************
OVERALL MAXIMUM CONCENTRATIONS BY DISTANCE
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
MAXIMUM MAXIMUM
DIST 1‐HR CONC DIST 1‐HR CONC
(m) (ug/m3) (m) (ug/m3)
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
1.00 1.685 2525.00 0.6112E‐01
25.00 1.795 2550.00 0.6032E‐01
50.00 1.899 2575.00 0.5954E‐01
75.00 1.989 2600.00 0.5878E‐01
100.00 2.079 2625.00 0.5803E‐01
125.00 2.164 2650.00 0.5729E‐01
150.00 2.245 2675.00 0.5657E‐01
175.00 2.058 2700.00 0.5587E‐01
200.00 1.521 2725.00 0.5518E‐01
225.00 1.305 2750.00 0.5450E‐01
250.00 1.113 2775.00 0.5385E‐01
275.00 0.9759 2800.01 0.5320E‐01
300.00 0.8716 2825.00 0.5257E‐01
325.00 0.7888 2850.00 0.5196E‐01
350.01 0.7210 2875.00 0.5136E‐01
375.01 0.6638 2900.00 0.5076E‐01
400.00 0.6150 2925.00 0.5019E‐01
425.00 0.5727 2950.00 0.4962E‐01
450.00 0.5355 2975.00 0.4906E‐01
475.00 0.5028 3000.00 0.4851E‐01
500.00 0.4735 3025.00 0.4797E‐01
525.00 0.4470 3050.00 0.4744E‐01
550.00 0.4232 3075.00 0.4692E‐01
575.00 0.4014 3100.00 0.4641E‐01
600.00 0.3818 3125.00 0.4591E‐01
625.00 0.3635 3150.00 0.4542E‐01
650.00 0.3469 3174.99 0.4494E‐01
675.00 0.3315 3199.99 0.4447E‐01
699.99 0.3173 3225.00 0.4401E‐01
725.00 0.3041 3250.00 0.4355E‐01
749.99 0.2918 3275.00 0.4310E‐01
775.00 0.2804 3300.00 0.4266E‐01
800.00 0.2698 3325.00 0.4223E‐01
825.00 0.2597 3350.00 0.4181E‐01
850.00 0.2504 3375.00 0.4139E‐01
875.00 0.2416 3400.00 0.4098E‐01
900.00 0.2332 3425.00 0.4058E‐01
925.00 0.2254 3450.00 0.4019E‐01
950.01 0.2181 3475.00 0.3980E‐01
975.00 0.2110 3500.00 0.3942E‐01
1000.00 0.2044 3525.00 0.3904E‐01
1025.00 0.1982 3550.00 0.3867E‐01
1050.00 0.1922 3575.00 0.3831E‐01
1075.00 0.1866 3600.00 0.3795E‐01
1100.00 0.1812 3625.00 0.3760E‐01
1125.00 0.1761 3650.00 0.3726E‐01
1150.00 0.1712 3675.00 0.3692E‐01
1175.00 0.1666 3700.00 0.3658E‐01
1200.00 0.1621 3725.00 0.3625E‐01
1225.00 0.1579 3750.00 0.3593E‐01
1250.00 0.1539 3775.00 0.3561E‐01
1275.00 0.1500 3800.00 0.3530E‐01
1300.00 0.1463 3825.00 0.3498E‐01
1325.00 0.1427 3850.00 0.3468E‐01
1350.00 0.1394 3875.00 0.3438E‐01
1375.00 0.1361 3900.00 0.3408E‐01
1400.00 0.1329 3925.00 0.3379E‐01
1425.00 0.1299 3950.00 0.3350E‐01
1450.00 0.1270 3975.00 0.3321E‐01
1475.00 0.1242 4000.00 0.3339E‐01
1500.00 0.1216 4025.00 0.3311E‐01
1525.00 0.1189 4050.00 0.3283E‐01
1550.00 0.1164 4075.00 0.3255E‐01
1575.00 0.1140 4100.00 0.3228E‐01
1600.00 0.1117 4125.00 0.3201E‐01
1625.00 0.1095 4150.00 0.3175E‐01
1650.00 0.1073 4175.00 0.3149E‐01
1675.00 0.1052 4200.00 0.3123E‐01
1700.00 0.1032 4225.00 0.3098E‐01
1725.00 0.1012 4250.00 0.3073E‐01
1750.00 0.9933E‐01 4275.00 0.3049E‐01
1775.00 0.9750E‐01 4300.00 0.3024E‐01
1800.00 0.9572E‐01 4325.00 0.3001E‐01
1825.00 0.9400E‐01 4350.00 0.2977E‐01
1850.00 0.9233E‐01 4375.00 0.2954E‐01
1875.00 0.9071E‐01 4400.00 0.2931E‐01
1900.00 0.8914E‐01 4425.00 0.2908E‐01
1925.00 0.8762E‐01 4450.00 0.2886E‐01
1950.00 0.8612E‐01 4475.00 0.2864E‐01
1975.00 0.8468E‐01 4500.00 0.2842E‐01
2000.01 0.8328E‐01 4525.00 0.2821E‐01
2025.00 0.8193E‐01 4550.00 0.2799E‐01
2050.00 0.8061E‐01 4575.00 0.2779E‐01
2075.00 0.7933E‐01 4600.00 0.2758E‐01
2100.00 0.7808E‐01 4625.00 0.2738E‐01
2125.00 0.7686E‐01 4650.00 0.2717E‐01
2150.00 0.7568E‐01 4675.00 0.2698E‐01
2175.00 0.7453E‐01 4700.00 0.2678E‐01
2200.00 0.7340E‐01 4725.00 0.2659E‐01
2225.00 0.7230E‐01 4750.00 0.2639E‐01
2250.00 0.7123E‐01 4775.00 0.2621E‐01
2275.00 0.7019E‐01 4800.00 0.2602E‐01
2300.00 0.6918E‐01 4825.00 0.2584E‐01
2325.00 0.6819E‐01 4850.00 0.2565E‐01
2350.00 0.6723E‐01 4875.00 0.2547E‐01
2375.00 0.6630E‐01 4900.00 0.2530E‐01
2400.00 0.6539E‐01 4925.00 0.2512E‐01
2425.00 0.6450E‐01 4950.00 0.2495E‐01
2450.00 0.6363E‐01 4975.00 0.2478E‐01
2475.00 0.6277E‐01 5000.00 0.2461E‐01
2500.00 0.6194E‐01
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
********************** AERSCREEN MAXIMUM IMPACT SUMMARY *********************
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐
3‐hour, 8‐hour, and 24‐hour scaled
concentrations are equal to the 1‐hour concentration as referenced in
SCREENING PROCEDURES FOR ESTIMATING THE AIR QUALITY
IMPACT OF STATIONARY SOURCES, REVISED (Section 4.5.4)
Report number EPA‐454/R‐92‐019
http://www.epa.gov/scram001/guidance_permit.htm
under Screening Guidance
MAXIMUM SCALED SCALED SCALED SCALED
1‐HOUR 3‐HOUR 8‐HOUR 24‐HOUR ANNUAL
CALCULATION CONC CONC CONC CONC CONC
PROCEDURE (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3)
‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐ ‐‐‐‐‐‐‐‐‐‐
FLAT TERRAIN 2.254 2.254 2.254 2.254 N/A
DISTANCE FROM SOURCE 153.00 meters
IMPACT AT THE
AMBIENT BOUNDARY 1.685 1.685 1.685 1.685 N/A
DISTANCE FROM SOURCE 1.00 meters
Concentration Distance Elevation Diag Season/Month Zo sector Date
H0 U* W* DT/DZ ZICNV ZIMCH M‐O LEN Z0 BOWEN ALBEDO REF WS HT
REF TA HT
0.16851E+01 1.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.17950E+01 25.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.18994E+01 50.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.19887E+01 75.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.20788E+01 100.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.21636E+01 125.00 0.00 35.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.22446E+01 150.00 0.00 35.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
* 0.22540E+01 153.00 0.00 35.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.20581E+01 175.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.15215E+01 200.00 0.00 35.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13053E+01 225.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11131E+01 250.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.97588E+00 275.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.87164E+00 300.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.78880E+00 325.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.72099E+00 350.01 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.66377E+00 375.01 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.61503E+00 400.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.57271E+00 425.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.53552E+00 450.00 0.00 40.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.50281E+00 475.00 0.00 35.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.47351E+00 500.00 0.00 35.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.44705E+00 525.00 0.00 35.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.42320E+00 550.00 0.00 35.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.40144E+00 575.00 0.00 35.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.38175E+00 600.00 0.00 30.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.36355E+00 625.00 0.00 30.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.34690E+00 650.00 0.00 30.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.33152E+00 675.00 0.00 30.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.31729E+00 699.99 0.00 20.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.30407E+00 725.00 0.00 25.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.29181E+00 749.99 0.00 15.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.28040E+00 775.00 0.00 15.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.26977E+00 800.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25969E+00 825.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25037E+00 850.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.24161E+00 875.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.23319E+00 900.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.22542E+00 925.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.21806E+00 950.01 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.21101E+00 975.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.20440E+00 1000.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.19817E+00 1025.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.19222E+00 1050.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.18656E+00 1075.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.18117E+00 1100.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.17608E+00 1125.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.17122E+00 1150.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.16657E+00 1175.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.16215E+00 1200.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.15793E+00 1225.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.15386E+00 1250.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.14999E+00 1275.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.14628E+00 1300.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.14275E+00 1325.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13936E+00 1350.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13607E+00 1375.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13293E+00 1400.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12991E+00 1425.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12702E+00 1450.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12424E+00 1475.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12155E+00 1500.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11894E+00 1525.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11644E+00 1550.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11404E+00 1575.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11172E+00 1600.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10946E+00 1625.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10729E+00 1650.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10519E+00 1675.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10316E+00 1700.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10121E+00 1725.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.99327E‐01 1750.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.97501E‐01 1775.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.95719E‐01 1800.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.93995E‐01 1825.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.92326E‐01 1850.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.90709E‐01 1875.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.89143E‐01 1900.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.87616E‐01 1925.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.86124E‐01 1950.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.84676E‐01 1975.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.83279E‐01 2000.01 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.81927E‐01 2025.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.80611E‐01 2050.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.79327E‐01 2075.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.78078E‐01 2100.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.76864E‐01 2125.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.75683E‐01 2150.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.74527E‐01 2175.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.73398E‐01 2200.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.72298E‐01 2225.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.71233E‐01 2250.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.70193E‐01 2275.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.69179E‐01 2300.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.68192E‐01 2325.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.67232E‐01 2350.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.66297E‐01 2375.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.65385E‐01 2400.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.64496E‐01 2425.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.63627E‐01 2450.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.62774E‐01 2475.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.61938E‐01 2500.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.61121E‐01 2525.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.60323E‐01 2550.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.59544E‐01 2575.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.58781E‐01 2600.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.58030E‐01 2625.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.57294E‐01 2650.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.56573E‐01 2675.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.55868E‐01 2700.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.55179E‐01 2725.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.54504E‐01 2750.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.53848E‐01 2775.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.53203E‐01 2800.01 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.52575E‐01 2825.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.51959E‐01 2850.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.51356E‐01 2875.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.50765E‐01 2900.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.50185E‐01 2925.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.49615E‐01 2950.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.49055E‐01 2975.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.48507E‐01 3000.00 0.00 15.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.47969E‐01 3025.00 0.00 15.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.47442E‐01 3050.00 0.00 15.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.46923E‐01 3075.00 0.00 15.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.46413E‐01 3100.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.45913E‐01 3125.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.45423E‐01 3150.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.44942E‐01 3174.99 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.44470E‐01 3199.99 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.44006E‐01 3225.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.43551E‐01 3250.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.43102E‐01 3275.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.42662E‐01 3300.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.42229E‐01 3325.00 0.00 10.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.41806E‐01 3350.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.41391E‐01 3375.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.40983E‐01 3400.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.40582E‐01 3425.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.40186E‐01 3450.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.39798E‐01 3475.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.39416E‐01 3500.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.39040E‐01 3525.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.38671E‐01 3550.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.38308E‐01 3575.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.37952E‐01 3600.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.37601E‐01 3625.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.37257E‐01 3650.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.36917E‐01 3675.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.36583E‐01 3700.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.36255E‐01 3725.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.35931E‐01 3750.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.35611E‐01 3775.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.35295E‐01 3800.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.34985E‐01 3825.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.34679E‐01 3850.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.34378E‐01 3875.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.34081E‐01 3900.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.33786E‐01 3925.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.33497E‐01 3950.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.33211E‐01 3975.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.33390E‐01 4000.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.33107E‐01 4025.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.32828E‐01 4050.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.32552E‐01 4075.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.32281E‐01 4100.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.32014E‐01 4125.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.31750E‐01 4150.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.31490E‐01 4175.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.31234E‐01 4200.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.30982E‐01 4225.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.30733E‐01 4250.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.30487E‐01 4275.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.30245E‐01 4300.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.30006E‐01 4325.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.29770E‐01 4350.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.29538E‐01 4375.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.29308E‐01 4400.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.29082E‐01 4425.00 0.00 5.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.28859E‐01 4450.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.28638E‐01 4475.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.28421E‐01 4500.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.28206E‐01 4525.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.27995E‐01 4550.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.27786E‐01 4575.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.27579E‐01 4600.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.27376E‐01 4625.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.27174E‐01 4650.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.26976E‐01 4675.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.26780E‐01 4700.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.26586E‐01 4725.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.26395E‐01 4750.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.26206E‐01 4775.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.26019E‐01 4800.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25835E‐01 4825.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25653E‐01 4850.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25473E‐01 4875.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25296E‐01 4900.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25120E‐01 4925.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.24947E‐01 4950.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.24776E‐01 4975.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.24606E‐01 5000.00 0.00 0.0 Winter 0‐360 10011001
‐1.30 0.043 ‐9.000 0.020 ‐999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
AERSCREEN 16216 / AERMOD 19191 02/07/20
15:21:36
TITLE: Bowery_Operation
-----------------------------------------------------------------------------
****************************** AREA PARAMETERS ****************************
-----------------------------------------------------------------------------
SOURCE EMISSION RATE: 0.763E-02 g/s 0.605E-01 lb/hr
AREA EMISSION RATE: 0.129E-06 g/(s-m2) 0.103E-05 lb/(hr-m2)
AREA HEIGHT: 3.00 meters 9.84 feet
AREA SOURCE LONG SIDE: 254.40 meters 834.65 feet
AREA SOURCE SHORT SIDE: 232.00 meters 761.15 feet
INITIAL VERTICAL DIMENSION: 1.50 meters 4.92 feet
RURAL OR URBAN: URBAN
POPULATION: 334136
INITIAL PROBE DISTANCE = 5000. meters 16404. feet
-----------------------------------------------------------------------------
*********************** BUILDING DOWNWASH PARAMETERS **********************
-----------------------------------------------------------------------------
BUILDING DOWNWASH NOT USED FOR NON-POINT SOURCES
-----------------------------------------------------------------------------
************************** FLOW SECTOR ANALYSIS ***************************
25 meter receptor spacing: 1. meters - 5000. meters
-----------------------------------------------------------------------------
MAXIMUM IMPACT RECEPTOR
Zo SURFACE 1-HR CONC RADIAL DIST TEMPORAL
SECTOR ROUGHNESS (ug/m3) (deg) (m) PERIOD
-----------------------------------------------------
1* 1.000 5.116 35 150.0 WIN
* = worst case diagonal
-----------------------------------------------------------------------------
********************** MAKEMET METEOROLOGY PARAMETERS *********************
-----------------------------------------------------------------------------
MIN/MAX TEMPERATURE: 250.0 / 310.0 (K)
MINIMUM WIND SPEED: 0.5 m/s
ANEMOMETER HEIGHT: 10.000 meters
SURFACE CHARACTERISTICS INPUT: AERMET SEASONAL TABLES
DOMINANT SURFACE PROFILE: Urban
DOMINANT CLIMATE TYPE: Average Moisture
DOMINANT SEASON: Winter
ALBEDO: 0.35
BOWEN RATIO: 1.50
ROUGHNESS LENGTH: 1.000 (meters)
SURFACE FRICTION VELOCITY (U*) NOT ADUSTED
METEOROLOGY CONDITIONS USED TO PREDICT OVERALL MAXIMUM IMPACT
-------------------------------------------------------------
YR MO DY JDY HR
-- -- -- --- --
10 01 10 10 01
H0 U* W* DT/DZ ZICNV ZIMCH M-O LEN Z0 BOWEN ALBEDO REF WS
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50
HT REF TA HT
- - - - - - - - - - -
10.0 310.0 2.0
-----------------------------------------------------------------------------
************************ AERSCREEN AUTOMATED DISTANCES **********************
OVERALL MAXIMUM CONCENTRATIONS BY DISTANCE
-----------------------------------------------------------------------------
MAXIMUM MAXIMUM
DIST 1-HR CONC DIST 1-HR CONC
(m) (ug/m3) (m) (ug/m3)
--------------------- ---------------------
1.00 3.840 2525.00 0.1393
25.00 4.091 2550.00 0.1375
50.00 4.329 2575.00 0.1357
75.00 4.532 2600.00 0.1340
100.00 4.738 2625.00 0.1323
125.00 4.931 2650.00 0.1306
150.00 5.116 2675.00 0.1289
175.00 4.691 2700.00 0.1273
200.00 3.468 2725.00 0.1258
225.00 2.975 2750.00 0.1242
250.00 2.537 2775.00 0.1227
275.00 2.224 2800.01 0.1213
300.00 1.987 2825.00 0.1198
325.00 1.798 2850.00 0.1184
350.01 1.643 2875.00 0.1170
375.01 1.513 2900.00 0.1157
400.00 1.402 2925.00 0.1144
425.00 1.305 2950.00 0.1131
450.00 1.220 2975.00 0.1118
475.00 1.146 3000.00 0.1106
500.00 1.079 3025.00 0.1093
525.00 1.019 3050.00 0.1081
550.00 0.9645 3075.00 0.1069
575.00 0.9149 3100.00 0.1058
600.00 0.8700 3125.00 0.1046
625.00 0.8285 3150.00 0.1035
650.00 0.7906 3174.99 0.1024
675.00 0.7556 3199.99 0.1013
699.99 0.7231 3225.00 0.1003
725.00 0.6930 3250.00 0.9925E-01
749.99 0.6651 3275.00 0.9823E-01
775.00 0.6391 3300.00 0.9723E-01
800.00 0.6148 3325.00 0.9624E-01
825.00 0.5919 3350.00 0.9528E-01
850.00 0.5706 3375.00 0.9433E-01
875.00 0.5506 3400.00 0.9340E-01
900.00 0.5315 3425.00 0.9249E-01
925.00 0.5137 3450.00 0.9159E-01
950.01 0.4970 3475.00 0.9070E-01
975.00 0.4809 3500.00 0.8983E-01
1000.00 0.4658 3525.00 0.8898E-01
1025.00 0.4517 3550.00 0.8813E-01
1050.00 0.4381 3575.00 0.8731E-01
1075.00 0.4252 3600.00 0.8649E-01
1100.00 0.4129 3625.00 0.8570E-01
1125.00 0.4013 3650.00 0.8491E-01
1150.00 0.3902 3675.00 0.8414E-01
1175.00 0.3796 3700.00 0.8338E-01
1200.00 0.3695 3725.00 0.8263E-01
1225.00 0.3599 3750.00 0.8189E-01
1250.00 0.3507 3775.00 0.8116E-01
1275.00 0.3418 3800.00 0.8044E-01
1300.00 0.3334 3825.00 0.7973E-01
1325.00 0.3253 3850.00 0.7904E-01
1350.00 0.3176 3875.00 0.7835E-01
1375.00 0.3101 3900.00 0.7767E-01
1400.00 0.3029 3925.00 0.7700E-01
1425.00 0.2961 3950.00 0.7634E-01
1450.00 0.2895 3975.00 0.7569E-01
1475.00 0.2831 4000.00 0.7610E-01
1500.00 0.2770 4025.00 0.7545E-01
1525.00 0.2711 4050.00 0.7482E-01
1550.00 0.2654 4075.00 0.7419E-01
1575.00 0.2599 4100.00 0.7357E-01
1600.00 0.2546 4125.00 0.7296E-01
1625.00 0.2495 4150.00 0.7236E-01
1650.00 0.2445 4175.00 0.7177E-01
1675.00 0.2397 4200.00 0.7118E-01
1700.00 0.2351 4225.00 0.7061E-01
1725.00 0.2307 4250.00 0.7004E-01
1750.00 0.2264 4275.00 0.6948E-01
1775.00 0.2222 4300.00 0.6893E-01
1800.00 0.2182 4325.00 0.6839E-01
1825.00 0.2142 4350.00 0.6785E-01
1850.00 0.2104 4375.00 0.6732E-01
1875.00 0.2067 4400.00 0.6680E-01
1900.00 0.2032 4425.00 0.6628E-01
1925.00 0.1997 4450.00 0.6577E-01
1950.00 0.1963 4475.00 0.6527E-01
1975.00 0.1930 4500.00 0.6477E-01
2000.01 0.1898 4525.00 0.6428E-01
2025.00 0.1867 4550.00 0.6380E-01
2050.00 0.1837 4575.00 0.6333E-01
2075.00 0.1808 4600.00 0.6285E-01
2100.00 0.1779 4625.00 0.6239E-01
2125.00 0.1752 4650.00 0.6193E-01
2150.00 0.1725 4675.00 0.6148E-01
2175.00 0.1699 4700.00 0.6103E-01
2200.00 0.1673 4725.00 0.6059E-01
2225.00 0.1648 4750.00 0.6016E-01
2250.00 0.1623 4775.00 0.5972E-01
2275.00 0.1600 4800.00 0.5930E-01
2300.00 0.1577 4825.00 0.5888E-01
2325.00 0.1554 4850.00 0.5847E-01
2350.00 0.1532 4875.00 0.5806E-01
2375.00 0.1511 4900.00 0.5765E-01
2400.00 0.1490 4925.00 0.5725E-01
2425.00 0.1470 4950.00 0.5686E-01
2450.00 0.1450 4975.00 0.5647E-01
2475.00 0.1431 5000.00 0.5608E-01
2500.00 0.1412
-----------------------------------------------------------------------------
********************** AERSCREEN MAXIMUM IMPACT SUMMARY *********************
-----------------------------------------------------------------------------
3-hour, 8-hour, and 24-hour scaled
concentrations are equal to the 1-hour concentration as referenced in
SCREENING PROCEDURES FOR ESTIMATING THE AIR QUALITY
IMPACT OF STATIONARY SOURCES, REVISED (Section 4.5.4)
Report number EPA-454/R-92-019
http://www.epa.gov/scram001/guidance_permit.htm
under Screening Guidance
MAXIMUM SCALED SCALED SCALED SCALED
1-HOUR 3-HOUR 8-HOUR 24-HOUR ANNUAL
CALCULATION CONC CONC CONC CONC CONC
PROCEDURE (ug/m3) (ug/m3) (ug/m3) (ug/m3) (ug/m3)
--------------- ---------- ---------- ---------- ---------- ----------
FLAT TERRAIN 5.137 5.137 5.137 5.137 N/A
DISTANCE FROM SOURCE 153.00 meters
IMPACT AT THE
AMBIENT BOUNDARY 3.840 3.840 3.840 3.840 N/A
DISTANCE FROM SOURCE 1.00 meters
Concentration Distance Elevation Diag Season/Month Zo sector Date
H0 U* W* DT/DZ ZICNV ZIMCH M-O LEN Z0 BOWEN ALBEDO REF WS HT
REF TA HT
0.38404E+01 1.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.40910E+01 25.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.43288E+01 50.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.45324E+01 75.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.47377E+01 100.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.49309E+01 125.00 0.00 35.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.51156E+01 150.00 0.00 35.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
* 0.51370E+01 153.00 0.00 35.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.46906E+01 175.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.34676E+01 200.00 0.00 35.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.29748E+01 225.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25368E+01 250.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.22241E+01 275.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.19865E+01 300.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.17977E+01 325.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.16432E+01 350.01 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.15128E+01 375.01 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.14017E+01 400.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13052E+01 425.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12205E+01 450.00 0.00 40.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11459E+01 475.00 0.00 35.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10792E+01 500.00 0.00 35.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10188E+01 525.00 0.00 35.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.96449E+00 550.00 0.00 35.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.91490E+00 575.00 0.00 35.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.87004E+00 600.00 0.00 30.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.82855E+00 625.00 0.00 30.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.79061E+00 650.00 0.00 30.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.75556E+00 675.00 0.00 30.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.72312E+00 699.99 0.00 20.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.69300E+00 725.00 0.00 25.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.66506E+00 749.99 0.00 15.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.63905E+00 775.00 0.00 15.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.61482E+00 800.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.59186E+00 825.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.57062E+00 850.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.55064E+00 875.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.53146E+00 900.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.51374E+00 925.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.49696E+00 950.01 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.48089E+00 975.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.46585E+00 1000.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.45165E+00 1025.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.43807E+00 1050.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.42518E+00 1075.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.41289E+00 1100.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.40130E+00 1125.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.39022E+00 1150.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.37962E+00 1175.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.36955E+00 1200.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.35992E+00 1225.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.35066E+00 1250.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.34184E+00 1275.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.33339E+00 1300.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.32533E+00 1325.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.31760E+00 1350.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.31012E+00 1375.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.30295E+00 1400.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.29607E+00 1425.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.28948E+00 1450.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.28314E+00 1475.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.27703E+00 1500.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.27107E+00 1525.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.26537E+00 1550.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25990E+00 1575.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25462E+00 1600.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.24948E+00 1625.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.24453E+00 1650.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.23974E+00 1675.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.23511E+00 1700.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.23066E+00 1725.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.22637E+00 1750.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.22221E+00 1775.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.21815E+00 1800.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.21422E+00 1825.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.21042E+00 1850.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.20673E+00 1875.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.20316E+00 1900.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.19968E+00 1925.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.19628E+00 1950.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.19298E+00 1975.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.18980E+00 2000.01 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.18672E+00 2025.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.18372E+00 2050.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.18079E+00 2075.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.17795E+00 2100.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.17518E+00 2125.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.17249E+00 2150.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.16985E+00 2175.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.16728E+00 2200.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.16477E+00 2225.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.16234E+00 2250.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.15997E+00 2275.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.15766E+00 2300.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.15541E+00 2325.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.15323E+00 2350.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.15110E+00 2375.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.14902E+00 2400.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.14699E+00 2425.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.14501E+00 2450.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.14307E+00 2475.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.14116E+00 2500.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13930E+00 2525.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13748E+00 2550.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13570E+00 2575.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13397E+00 2600.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13226E+00 2625.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.13058E+00 2650.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12893E+00 2675.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12733E+00 2700.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12576E+00 2725.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12422E+00 2750.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12272E+00 2775.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.12125E+00 2800.01 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11982E+00 2825.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11842E+00 2850.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11704E+00 2875.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11570E+00 2900.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11438E+00 2925.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11308E+00 2950.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11180E+00 2975.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11055E+00 3000.00 0.00 15.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10932E+00 3025.00 0.00 15.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10812E+00 3050.00 0.00 15.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10694E+00 3075.00 0.00 15.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10578E+00 3100.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10464E+00 3125.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10352E+00 3150.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10243E+00 3174.99 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10135E+00 3199.99 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.10029E+00 3225.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.99254E-01 3250.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.98232E-01 3275.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.97228E-01 3300.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.96243E-01 3325.00 0.00 10.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.95278E-01 3350.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.94332E-01 3375.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.93402E-01 3400.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.92488E-01 3425.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.91587E-01 3450.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.90702E-01 3475.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.89832E-01 3500.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.88976E-01 3525.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.88134E-01 3550.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.87306E-01 3575.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.86494E-01 3600.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.85696E-01 3625.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.84910E-01 3650.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.84137E-01 3675.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.83376E-01 3700.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.82627E-01 3725.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.81889E-01 3750.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.81159E-01 3775.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.80440E-01 3800.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.79732E-01 3825.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.79035E-01 3850.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.78349E-01 3875.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.77672E-01 3900.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.77001E-01 3925.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.76341E-01 3950.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.75690E-01 3975.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.76099E-01 4000.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.75453E-01 4025.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.74816E-01 4050.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.74189E-01 4075.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.73571E-01 4100.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.72962E-01 4125.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.72361E-01 4150.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.71769E-01 4175.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.71185E-01 4200.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.70609E-01 4225.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.70042E-01 4250.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.69482E-01 4275.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.68930E-01 4300.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.68385E-01 4325.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.67848E-01 4350.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.67318E-01 4375.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.66795E-01 4400.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.66280E-01 4425.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.65771E-01 4450.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.65269E-01 4475.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.64773E-01 4500.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.64284E-01 4525.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.63801E-01 4550.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.63325E-01 4575.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.62855E-01 4600.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.62390E-01 4625.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.61932E-01 4650.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.61479E-01 4675.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.61032E-01 4700.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.60591E-01 4725.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.60155E-01 4750.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.59725E-01 4775.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.59300E-01 4800.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.58880E-01 4825.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.58465E-01 4850.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.58055E-01 4875.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.57651E-01 4900.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.57251E-01 4925.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.56856E-01 4950.00 0.00 5.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.56465E-01 4975.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.56079E-01 5000.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Enclosed Parking with Elevator 2,424.00 Space 3.42 969,600.00 0
Other Asphalt Surfaces 166.98 1000sqft 3.83 166,981.00 0
Other Non-Asphalt Surfaces 174.56 1000sqft 4.01 174,555.00 0
Fast Food Restaurant w/o Drive Thru 2.00 1000sqft 0.05 2,000.00 0
Fast Food Restaurant with Drive Thru 10.00 1000sqft 0.23 10,000.00 0
High Turnover (Sit Down Restaurant)25.00 1000sqft 0.57 25,000.00 0
Quality Restaurant 25.00 1000sqft 0.57 25,000.00 0
Apartments Mid Rise 1,150.00 Dwelling Unit 1.48 1,288,000.00 2081
Regional Shopping Center 18.00 1000sqft 0.41 18,000.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
8
Wind Speed (m/s)Precipitation Freq (Days)2.2 30
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Bowery Mixed-Use Project (Operations)
Orange County, Annual
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 1 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
Project Characteristics -
Land Use - Consistent with DEIR's model.
Construction Phase - Consistent with DEIR's model.
Off-road Equipment - Consistent with DEIR's model.
Vehicle Trips - See SWAPE comment about trip rates and trip purpose percentages.
Vehicle Emission Factors - See SWAPE comment about vehicle emission factors.
Vehicle Emission Factors -
Vehicle Emission Factors -
Woodstoves - Consistent with DEIR's model.
Trips and VMT -
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 20.00 1.00
tblFireplaces NumberGas 977.50 1,150.00
tblFireplaces NumberNoFireplace 115.00 0.00
tblFireplaces NumberWood 57.50 0.00
tblLandUse LandUseSquareFeet 166,980.00 166,981.00
tblLandUse LandUseSquareFeet 174,560.00 174,555.00
tblLandUse LandUseSquareFeet 1,150,000.00 1,288,000.00
tblLandUse LotAcreage 21.82 3.42
tblLandUse LotAcreage 30.26 1.48
tblLandUse Population 3,289.00 2,081.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblVehicleTrips DV_TP 37.00 0.00
tblVehicleTrips DV_TP 21.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 2 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
tblVehicleTrips DV_TP 20.00 0.00
tblVehicleTrips DV_TP 18.00 0.00
tblVehicleTrips DV_TP 35.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 12.00 17.00
tblVehicleTrips PB_TP 50.00 31.00
tblVehicleTrips PB_TP 43.00 21.00
tblVehicleTrips PB_TP 44.00 22.00
tblVehicleTrips PB_TP 11.00 24.00
tblVehicleTrips PR_TP 86.00 89.00
tblVehicleTrips PR_TP 51.00 83.00
tblVehicleTrips PR_TP 29.00 69.00
tblVehicleTrips PR_TP 37.00 79.00
tblVehicleTrips PR_TP 38.00 78.00
tblVehicleTrips PR_TP 54.00 76.00
tblVehicleTrips ST_TR 6.39 5.30
tblVehicleTrips ST_TR 696.00 803.38
tblVehicleTrips ST_TR 722.03 325.70
tblVehicleTrips ST_TR 158.37 109.58
tblVehicleTrips ST_TR 94.36 82.68
tblVehicleTrips ST_TR 49.97 35.31
tblVehicleTrips SU_TR 5.86 5.30
tblVehicleTrips SU_TR 500.00 803.38
tblVehicleTrips SU_TR 542.72 325.70
tblVehicleTrips SU_TR 131.84 109.58
tblVehicleTrips SU_TR 72.16 82.68
tblVehicleTrips SU_TR 25.24 35.31
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 3 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
2.0 Emissions Summary
tblVehicleTrips WD_TR 6.65 5.30
tblVehicleTrips WD_TR 716.00 803.38
tblVehicleTrips WD_TR 496.12 325.70
tblVehicleTrips WD_TR 127.15 109.58
tblVehicleTrips WD_TR 89.95 82.68
tblVehicleTrips WD_TR 42.70 35.31
tblWoodstoves NumberCatalytic 57.50 0.00
tblWoodstoves NumberNoncatalytic 57.50 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 4 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 5 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 5.8762 0.3757 12.0102 2.1500e-
003
0.0850 0.0850 0.0850 0.0850 0.0000 295.6007 295.6007 0.0242 5.0600e-
003
297.7137
Energy 0.1578 1.3954 0.9212 8.6000e-
003
0.1090 0.1090 0.1090 0.1090 0.0000 5,614.405
5
5,614.405
5
0.1973 0.0632 5,638.183
3
Mobile 3.9046 16.5785 50.2077 0.1911 17.5772 0.1421 17.7193 4.7073 0.1321 4.8394 0.0000 17,616.51
78
17,616.51
78
0.7315 0.0000 17,634.80
63
Waste 0.0000 0.0000 0.0000 0.0000 204.2982 0.0000 204.2982 12.0737 0.0000 506.1402
Water 0.0000 0.0000 0.0000 0.0000 30.1644 568.8203 598.9846 3.1217 0.0780 700.2738
Total 9.9386 18.3497 63.1391 0.2018 17.5772 0.3361 17.9133 4.7073 0.3261 5.0334 234.4626 24,095.34
43
24,329.80
69
16.1483 0.1463 24,777.11
73
Unmitigated Operational
Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter)Maximum Mitigated ROG + NOX (tons/quarter)
Highest
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 6 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 5.8762 0.3757 12.0102 2.1500e-
003
0.0850 0.0850 0.0850 0.0850 0.0000 295.6007 295.6007 0.0242 5.0600e-
003
297.7137
Energy 0.1578 1.3954 0.9212 8.6000e-
003
0.1090 0.1090 0.1090 0.1090 0.0000 5,614.405
5
5,614.405
5
0.1973 0.0632 5,638.183
3
Mobile 3.9046 16.5785 50.2077 0.1911 17.5772 0.1421 17.7193 4.7073 0.1321 4.8394 0.0000 17,616.51
78
17,616.51
78
0.7315 0.0000 17,634.80
63
Waste 0.0000 0.0000 0.0000 0.0000 204.2982 0.0000 204.2982 12.0737 0.0000 506.1402
Water 0.0000 0.0000 0.0000 0.0000 30.1644 568.8203 598.9846 3.1217 0.0780 700.2738
Total 9.9386 18.3497 63.1391 0.2018 17.5772 0.3361 17.9133 4.7073 0.3261 5.0334 234.4626 24,095.34
43
24,329.80
69
16.1483 0.1463 24,777.11
73
Mitigated Operational
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 6/1/2020 6/1/2020 5 1
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Acres of Grading (Site Preparation Phase): 0
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 7 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
3.1 Mitigation Measures Construction
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 8.00 81 0.73
Demolition Excavators 0 8.00 158 0.38
Demolition Rubber Tired Dozers 0 8.00 247 0.40
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 0 0.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Grading Phase): 0
Acres of Paving: 11.26
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 8 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
3.2 Demolition - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 9 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
4.0 Operational Detail - Mobile
3.2 Demolition - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 10 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 3.9046 16.5785 50.2077 0.1911 17.5772 0.1421 17.7193 4.7073 0.1321 4.8394 0.0000 17,616.51
78
17,616.51
78
0.7315 0.0000 17,634.80
63
Unmitigated 3.9046 16.5785 50.2077 0.1911 17.5772 0.1421 17.7193 4.7073 0.1321 4.8394 0.0000 17,616.51
78
17,616.51
78
0.7315 0.0000 17,634.80
63
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Mid Rise 6,095.00 6,095.00 6095.00 21,524,690 21,524,690
Enclosed Parking with Elevator 0.00 0.00 0.00
Fast Food Restaurant w/o Drive Thru 1,606.76 1,606.76 1606.76 4,008,951 4,008,951
Fast Food Restaurant with Drive Thru 3,257.00 3,257.00 3257.00 6,822,622 6,822,622
High Turnover (Sit Down Restaurant)2,739.50 2,739.50 2739.50 6,962,775 6,962,775
Other Asphalt Surfaces 0.00 0.00 0.00
Other Non-Asphalt Surfaces 0.00 0.00 0.00
Quality Restaurant 2,067.00 2,067.00 2067.00 5,356,416 5,356,416
Regional Shopping Center 635.58 635.58 635.58 1,667,397 1,667,397
Total 16,400.84 16,400.84 16,400.84 46,342,852 46,342,852
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 11 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Apartments Mid Rise 14.70 5.90 8.70 40.20 19.20 40.60 89 11 0
Enclosed Parking with Elevator 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
Fast Food Restaurant w/o Drive
Thru
16.60 8.40 6.90 1.50 79.50 19.00 83 0 17
Fast Food Restaurant with Drive
Thru
16.60 8.40 6.90 2.20 78.80 19.00 69 0 31
High Turnover (Sit Down
Restaurant)
16.60 8.40 6.90 8.50 72.50 19.00 79 0 21
Other Asphalt Surfaces 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
Other Non-Asphalt Surfaces 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 78 0 22
Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 76 0 24
5.0 Energy Detail
5.1 Mitigation Measures Energy
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Apartments Mid Rise 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Enclosed Parking with Elevator 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Fast Food Restaurant w/o Drive
Thru
0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Fast Food Restaurant with Drive
Thru
0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
High Turnover (Sit Down
Restaurant)
0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Other Asphalt Surfaces 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Other Non-Asphalt Surfaces 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Quality Restaurant 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Regional Shopping Center 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 12 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated
0.0000 0.0000 0.0000 0.0000 0.0000 4,053.224
9
4,053.224
9
0.1673 0.0346 4,067.725
4
Electricity
Unmitigated
0.0000 0.0000 0.0000 0.0000 0.0000 4,053.224
9
4,053.224
9
0.1673 0.0346 4,067.725
4
NaturalGas
Mitigated
0.1578 1.3954 0.9212 8.6000e-
003
0.1090 0.1090 0.1090 0.1090 0.0000 1,561.180
6
1,561.180
6
0.0299 0.0286 1,570.457
9
NaturalGas
Unmitigated
0.1578 1.3954 0.9212 8.6000e-
003
0.1090 0.1090 0.1090 0.1090 0.0000 1,561.180
6
1,561.180
6
0.0299 0.0286 1,570.457
9
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 13 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Apartments Mid
Rise
1.31416e
+007
0.0709 0.6055 0.2577 3.8700e-
003
0.0490 0.0490 0.0490 0.0490 0.0000 701.2847 701.2847 0.0134 0.0129 705.4521
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Fast Food
Restaurant w/o
Drive Thru
518640 2.8000e-
003
0.0254 0.0214 1.5000e-
004
1.9300e-
003
1.9300e-
003
1.9300e-
003
1.9300e-
003
0.0000 27.6766 27.6766 5.3000e-
004
5.1000e-
004
27.8411
Fast Food
Restaurant with
Drive Thru
2.5932e
+006
0.0140 0.1271 0.1068 7.6000e-
004
9.6600e-
003
9.6600e-
003
9.6600e-
003
9.6600e-
003
0.0000 138.3830 138.3830 2.6500e-
003
2.5400e-
003
139.2054
High Turnover (Sit
Down Restaurant)
6.483e
+006
0.0350 0.3178 0.2670 1.9100e-
003
0.0242 0.0242 0.0242 0.0242 0.0000 345.9576 345.9576 6.6300e-
003
6.3400e-
003
348.0134
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
6.483e
+006
0.0350 0.3178 0.2670 1.9100e-
003
0.0242 0.0242 0.0242 0.0242 0.0000 345.9576 345.9576 6.6300e-
003
6.3400e-
003
348.0134
Regional
Shopping Center
36000 1.9000e-
004
1.7600e-
003
1.4800e-
003
1.0000e-
005
1.3000e-
004
1.3000e-
004
1.3000e-
004
1.3000e-
004
0.0000 1.9211 1.9211 4.0000e-
005
4.0000e-
005
1.9325
Total 0.1578 1.3954 0.9212 8.6100e-
003
0.1090 0.1090 0.1090 0.1090 0.0000 1,561.180
6
1,561.180
6
0.0299 0.0286 1,570.457
9
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 14 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Apartments Mid
Rise
1.31416e
+007
0.0709 0.6055 0.2577 3.8700e-
003
0.0490 0.0490 0.0490 0.0490 0.0000 701.2847 701.2847 0.0134 0.0129 705.4521
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Fast Food
Restaurant w/o
Drive Thru
518640 2.8000e-
003
0.0254 0.0214 1.5000e-
004
1.9300e-
003
1.9300e-
003
1.9300e-
003
1.9300e-
003
0.0000 27.6766 27.6766 5.3000e-
004
5.1000e-
004
27.8411
Fast Food
Restaurant with
Drive Thru
2.5932e
+006
0.0140 0.1271 0.1068 7.6000e-
004
9.6600e-
003
9.6600e-
003
9.6600e-
003
9.6600e-
003
0.0000 138.3830 138.3830 2.6500e-
003
2.5400e-
003
139.2054
High Turnover (Sit
Down Restaurant)
6.483e
+006
0.0350 0.3178 0.2670 1.9100e-
003
0.0242 0.0242 0.0242 0.0242 0.0000 345.9576 345.9576 6.6300e-
003
6.3400e-
003
348.0134
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
6.483e
+006
0.0350 0.3178 0.2670 1.9100e-
003
0.0242 0.0242 0.0242 0.0242 0.0000 345.9576 345.9576 6.6300e-
003
6.3400e-
003
348.0134
Regional
Shopping Center
36000 1.9000e-
004
1.7600e-
003
1.4800e-
003
1.0000e-
005
1.3000e-
004
1.3000e-
004
1.3000e-
004
1.3000e-
004
0.0000 1.9211 1.9211 4.0000e-
005
4.0000e-
005
1.9325
Total 0.1578 1.3954 0.9212 8.6100e-
003
0.1090 0.1090 0.1090 0.1090 0.0000 1,561.180
6
1,561.180
6
0.0299 0.0286 1,570.457
9
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 15 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Apartments Mid
Rise
4.5716e
+006
1,456.608
1
0.0601 0.0124 1,461.819
2
Enclosed Parking
with Elevator
5.68186e
+006
1,810.3611 0.0747 0.0155 1,816.837
7
Fast Food
Restaurant w/o
Drive Thru
72960 23.2466 9.6000e-
004
2.0000e-
004
23.3298
Fast Food
Restaurant with
Drive Thru
364800 116.2331 4.8000e-
003
9.9000e-
004
116.6489
High Turnover (Sit
Down Restaurant)
912000 290.5827 0.0120 2.4800e-
003
291.6223
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
912000 290.5827 0.0120 2.4800e-
003
291.6223
Regional
Shopping Center
205920 65.6105 2.7100e-
003
5.6000e-
004
65.8453
Total 4,053.224
9
0.1674 0.0346 4,067.725
4
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 16 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
6.1 Mitigation Measures Area
6.0 Area Detail
5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Apartments Mid
Rise
4.5716e
+006
1,456.608
1
0.0601 0.0124 1,461.819
2
Enclosed Parking
with Elevator
5.68186e
+006
1,810.3611 0.0747 0.0155 1,816.837
7
Fast Food
Restaurant w/o
Drive Thru
72960 23.2466 9.6000e-
004
2.0000e-
004
23.3298
Fast Food
Restaurant with
Drive Thru
364800 116.2331 4.8000e-
003
9.9000e-
004
116.6489
High Turnover (Sit
Down Restaurant)
912000 290.5827 0.0120 2.4800e-
003
291.6223
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
912000 290.5827 0.0120 2.4800e-
003
291.6223
Regional
Shopping Center
205920 65.6105 2.7100e-
003
5.6000e-
004
65.8453
Total 4,053.224
9
0.1674 0.0346 4,067.725
4
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 17 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 5.8762 0.3757 12.0102 2.1500e-
003
0.0850 0.0850 0.0850 0.0850 0.0000 295.6007 295.6007 0.0242 5.0600e-
003
297.7137
Unmitigated 5.8762 0.3757 12.0102 2.1500e-
003
0.0850 0.0850 0.0850 0.0850 0.0000 295.6007 295.6007 0.0242 5.0600e-
003
297.7137
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating
0.4583 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
5.0280 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 0.0279 0.2385 0.1015 1.5200e-
003
0.0193 0.0193 0.0193 0.0193 0.0000 276.1577 276.1577 5.2900e-
003
5.0600e-
003
277.7988
Landscaping 0.3620 0.1373 11.9087 6.3000e-
004
0.0657 0.0657 0.0657 0.0657 0.0000 19.4430 19.4430 0.0189 0.0000 19.9149
Total 5.8762 0.3757 12.0102 2.1500e-
003
0.0850 0.0850 0.0850 0.0850 0.0000 295.6007 295.6007 0.0242 5.0600e-
003
297.7137
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 18 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
7.1 Mitigation Measures Water
7.0 Water Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating
0.4583 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
5.0280 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 0.0279 0.2385 0.1015 1.5200e-
003
0.0193 0.0193 0.0193 0.0193 0.0000 276.1577 276.1577 5.2900e-
003
5.0600e-
003
277.7988
Landscaping 0.3620 0.1373 11.9087 6.3000e-
004
0.0657 0.0657 0.0657 0.0657 0.0000 19.4430 19.4430 0.0189 0.0000 19.9149
Total 5.8762 0.3757 12.0102 2.1500e-
003
0.0850 0.0850 0.0850 0.0850 0.0000 295.6007 295.6007 0.0242 5.0600e-
003
297.7137
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 19 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 598.9846 3.1217 0.0780 700.2738
Unmitigated 598.9846 3.1217 0.0780 700.2738
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 20 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Apartments Mid
Rise
74.9271 /
47.2367
501.8386 2.4612 0.0617 581.7659
Enclosed Parking
with Elevator
0 / 0 0.0000 0.0000 0.0000 0.0000
Fast Food
Restaurant w/o
Drive Thru
0.607067 /
0.038749
2.8483 0.0199 4.9000e-
004
3.4916
Fast Food
Restaurant with
Drive Thru
3.03534 /
0.193745
14.2417 0.0995 2.4500e-
003
17.4578
High Turnover (Sit
Down Restaurant)
7.58834 /
0.484362
35.6043 0.2486 6.1200e-
003
43.6446
Other Asphalt
Surfaces
0 / 0 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 / 0 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
7.58834 /
0.484362
35.6043 0.2486 6.1200e-
003
43.6446
Regional
Shopping Center
1.33331 /
0.817187
8.8473 0.0438 1.1000e-
003
10.2693
Total 598.9846 3.1217 0.0780 700.2738
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 21 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
8.1 Mitigation Measures Waste
7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Apartments Mid
Rise
74.9271 /
47.2367
501.8386 2.4612 0.0617 581.7659
Enclosed Parking
with Elevator
0 / 0 0.0000 0.0000 0.0000 0.0000
Fast Food
Restaurant w/o
Drive Thru
0.607067 /
0.038749
2.8483 0.0199 4.9000e-
004
3.4916
Fast Food
Restaurant with
Drive Thru
3.03534 /
0.193745
14.2417 0.0995 2.4500e-
003
17.4578
High Turnover (Sit
Down Restaurant)
7.58834 /
0.484362
35.6043 0.2486 6.1200e-
003
43.6446
Other Asphalt
Surfaces
0 / 0 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 / 0 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
7.58834 /
0.484362
35.6043 0.2486 6.1200e-
003
43.6446
Regional
Shopping Center
1.33331 /
0.817187
8.8473 0.0438 1.1000e-
003
10.2693
Total 598.9846 3.1217 0.0780 700.2738
Mitigated
8.0 Waste Detail
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 22 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 204.2982 12.0737 0.0000 506.1402
Unmitigated 204.2982 12.0737 0.0000 506.1402
Category/Year
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 23 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Apartments Mid
Rise
529 107.3822 6.3461 0.0000 266.0349
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000
Fast Food
Restaurant w/o
Drive Thru
23.04 4.6769 0.2764 0.0000 11.5869
Fast Food
Restaurant with
Drive Thru
115.19 23.3825 1.3819 0.0000 57.9292
High Turnover (Sit
Down Restaurant)
297.5 60.3898 3.5689 0.0000 149.6132
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
22.81 4.6302 0.2736 0.0000 11.4712
Regional
Shopping Center
18.9 3.8365 0.2267 0.0000 9.5048
Total 204.2982 12.0737 0.0000 506.1402
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 24 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Apartments Mid
Rise
529 107.3822 6.3461 0.0000 266.0349
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000
Fast Food
Restaurant w/o
Drive Thru
23.04 4.6769 0.2764 0.0000 11.5869
Fast Food
Restaurant with
Drive Thru
115.19 23.3825 1.3819 0.0000 57.9292
High Turnover (Sit
Down Restaurant)
297.5 60.3898 3.5689 0.0000 149.6132
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
22.81 4.6302 0.2736 0.0000 11.4712
Regional
Shopping Center
18.9 3.8365 0.2267 0.0000 9.5048
Total 204.2982 12.0737 0.0000 506.1402
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 25 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
11.0 Vegetation
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:00 PMPage 26 of 26
The Bowery Mixed-Use Project (Operations) - Orange County, Annual
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Enclosed Parking with Elevator 2,424.00 Space 3.42 969,600.00 0
Other Asphalt Surfaces 166.98 1000sqft 3.83 166,981.00 0
Other Non-Asphalt Surfaces 174.56 1000sqft 4.01 174,555.00 0
Fast Food Restaurant w/o Drive Thru 2.00 1000sqft 0.05 2,000.00 0
Fast Food Restaurant with Drive Thru 10.00 1000sqft 0.23 10,000.00 0
High Turnover (Sit Down Restaurant)25.00 1000sqft 0.57 25,000.00 0
Quality Restaurant 25.00 1000sqft 0.57 25,000.00 0
Apartments Mid Rise 1,150.00 Dwelling Unit 1.48 1,288,000.00 2081
Regional Shopping Center 18.00 1000sqft 0.41 18,000.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
8
Wind Speed (m/s)Precipitation Freq (Days)2.2 30
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Bowery Mixed-Use Project (Operations)
Orange County, Summer
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 1 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
Project Characteristics -
Land Use - Consistent with DEIR's model.
Construction Phase - Consistent with DEIR's model.
Off-road Equipment - Consistent with DEIR's model.
Vehicle Trips - See SWAPE comment about trip rates and trip purpose percentages.
Vehicle Emission Factors - See SWAPE comment about vehicle emission factors.
Vehicle Emission Factors -
Vehicle Emission Factors -
Woodstoves - Consistent with DEIR's model.
Trips and VMT -
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 20.00 1.00
tblFireplaces NumberGas 977.50 1,150.00
tblFireplaces NumberNoFireplace 115.00 0.00
tblFireplaces NumberWood 57.50 0.00
tblLandUse LandUseSquareFeet 166,980.00 166,981.00
tblLandUse LandUseSquareFeet 174,560.00 174,555.00
tblLandUse LandUseSquareFeet 1,150,000.00 1,288,000.00
tblLandUse LotAcreage 21.82 3.42
tblLandUse LotAcreage 30.26 1.48
tblLandUse Population 3,289.00 2,081.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblVehicleTrips DV_TP 37.00 0.00
tblVehicleTrips DV_TP 21.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 2 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
tblVehicleTrips DV_TP 20.00 0.00
tblVehicleTrips DV_TP 18.00 0.00
tblVehicleTrips DV_TP 35.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 12.00 17.00
tblVehicleTrips PB_TP 50.00 31.00
tblVehicleTrips PB_TP 43.00 21.00
tblVehicleTrips PB_TP 44.00 22.00
tblVehicleTrips PB_TP 11.00 24.00
tblVehicleTrips PR_TP 86.00 89.00
tblVehicleTrips PR_TP 51.00 83.00
tblVehicleTrips PR_TP 29.00 69.00
tblVehicleTrips PR_TP 37.00 79.00
tblVehicleTrips PR_TP 38.00 78.00
tblVehicleTrips PR_TP 54.00 76.00
tblVehicleTrips ST_TR 6.39 5.30
tblVehicleTrips ST_TR 696.00 803.38
tblVehicleTrips ST_TR 722.03 325.70
tblVehicleTrips ST_TR 158.37 109.58
tblVehicleTrips ST_TR 94.36 82.68
tblVehicleTrips ST_TR 49.97 35.31
tblVehicleTrips SU_TR 5.86 5.30
tblVehicleTrips SU_TR 500.00 803.38
tblVehicleTrips SU_TR 542.72 325.70
tblVehicleTrips SU_TR 131.84 109.58
tblVehicleTrips SU_TR 72.16 82.68
tblVehicleTrips SU_TR 25.24 35.31
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 3 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
2.0 Emissions Summary
tblVehicleTrips WD_TR 6.65 5.30
tblVehicleTrips WD_TR 716.00 803.38
tblVehicleTrips WD_TR 496.12 325.70
tblVehicleTrips WD_TR 127.15 109.58
tblVehicleTrips WD_TR 89.95 82.68
tblVehicleTrips WD_TR 42.70 35.31
tblWoodstoves NumberCatalytic 57.50 0.00
tblWoodstoves NumberNoncatalytic 57.50 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 4 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 5 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
Energy 0.8644 7.6462 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
Mobile 22.5194 87.3821 283.7168 1.0854 98.3073 0.7800 99.0873 26.2886 0.7254 27.0140 110,276.39
45
110,276.39
45
4.4505 110,387.65
81
Total 58.5739 115.2029 392.1516 1.2594 98.3073 3.4454 101.7527 26.2886 3.3908 29.6794 0.0000 144,230.4
211
144,230.4
211
5.2645 0.6194 144,546.5
990
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
Energy 0.8644 7.6462 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
Mobile 22.5194 87.3821 283.7168 1.0854 98.3073 0.7800 99.0873 26.2886 0.7254 27.0140 110,276.39
45
110,276.39
45
4.4505 110,387.65
81
Total 58.5739 115.2029 392.1516 1.2594 98.3073 3.4454 101.7527 26.2886 3.3908 29.6794 0.0000 144,230.4
211
144,230.4
211
5.2645 0.6194 144,546.5
990
Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 6 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 6/1/2020 6/1/2020 5 1
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 8.00 81 0.73
Demolition Excavators 0 8.00 158 0.38
Demolition Rubber Tired Dozers 0 8.00 247 0.40
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 0 0.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 11.26
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3.2 Demolition - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction Off-Site
3.1 Mitigation Measures Construction
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4.0 Operational Detail - Mobile
3.2 Demolition - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction Off-Site
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 22.5194 87.3821 283.7168 1.0854 98.3073 0.7800 99.0873 26.2886 0.7254 27.0140 110,276.39
45
110,276.39
45
4.4505 110,387.65
81
Unmitigated 22.5194 87.3821 283.7168 1.0854 98.3073 0.7800 99.0873 26.2886 0.7254 27.0140 110,276.39
45
110,276.39
45
4.4505 110,387.65
81
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Mid Rise 6,095.00 6,095.00 6095.00 21,524,690 21,524,690
Enclosed Parking with Elevator 0.00 0.00 0.00
Fast Food Restaurant w/o Drive Thru 1,606.76 1,606.76 1606.76 4,008,951 4,008,951
Fast Food Restaurant with Drive Thru 3,257.00 3,257.00 3257.00 6,822,622 6,822,622
High Turnover (Sit Down Restaurant)2,739.50 2,739.50 2739.50 6,962,775 6,962,775
Other Asphalt Surfaces 0.00 0.00 0.00
Other Non-Asphalt Surfaces 0.00 0.00 0.00
Quality Restaurant 2,067.00 2,067.00 2067.00 5,356,416 5,356,416
Regional Shopping Center 635.58 635.58 635.58 1,667,397 1,667,397
Total 16,400.84 16,400.84 16,400.84 46,342,852 46,342,852
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The Bowery Mixed-Use Project (Operations) - Orange County, Summer
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Apartments Mid Rise 14.70 5.90 8.70 40.20 19.20 40.60 89 11 0
Enclosed Parking with Elevator 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
Fast Food Restaurant w/o Drive
Thru
16.60 8.40 6.90 1.50 79.50 19.00 83 0 17
Fast Food Restaurant with Drive
Thru
16.60 8.40 6.90 2.20 78.80 19.00 69 0 31
High Turnover (Sit Down
Restaurant)
16.60 8.40 6.90 8.50 72.50 19.00 79 0 21
Other Asphalt Surfaces 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
Other Non-Asphalt Surfaces 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 78 0 22
Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 76 0 24
5.0 Energy Detail
5.1 Mitigation Measures Energy
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Apartments Mid Rise 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Enclosed Parking with Elevator 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Fast Food Restaurant w/o Drive
Thru
0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Fast Food Restaurant with Drive
Thru
0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
High Turnover (Sit Down
Restaurant)
0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Other Asphalt Surfaces 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Other Non-Asphalt Surfaces 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Quality Restaurant 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Regional Shopping Center 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Historical Energy Use: N
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.8644 7.6462 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
NaturalGas
Unmitigated
0.8644 7.6462 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 12 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Apartments Mid
Rise
36004.3 0.3883 3.3181 1.4119 0.0212 0.2683 0.2683 0.2683 0.2683 4,235.803
1
4,235.803
1
0.0812 0.0777 4,260.974
3
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Fast Food
Restaurant w/o
Drive Thru
1420.93 0.0153 0.1393 0.1170 8.4000e-
004
0.0106 0.0106 0.0106 0.0106 167.1684 167.1684 3.2000e-
003
3.0600e-
003
168.1618
Fast Food
Restaurant with
Drive Thru
7104.66 0.0766 0.6965 0.5851 4.1800e-
003
0.0529 0.0529 0.0529 0.0529 835.8421 835.8421 0.0160 0.0153 840.8091
High Turnover (Sit
Down Restaurant)
17761.6 0.1916 1.7413 1.4627 0.0105 0.1323 0.1323 0.1323 0.1323 2,089.605
2
2,089.605
2
0.0401 0.0383 2,102.022
6
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
17761.6 0.1916 1.7413 1.4627 0.0105 0.1323 0.1323 0.1323 0.1323 2,089.605
2
2,089.605
2
0.0401 0.0383 2,102.022
6
Regional
Shopping Center
98.6301 1.0600e-
003
9.6700e-
003
8.1200e-
003
6.0000e-
005
7.3000e-
004
7.3000e-
004
7.3000e-
004
7.3000e-
004
11.6036 11.6036 2.2000e-
004
2.1000e-
004
11.6725
Total 0.8644 7.6463 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 13 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Apartments Mid
Rise
36.0043 0.3883 3.3181 1.4119 0.0212 0.2683 0.2683 0.2683 0.2683 4,235.803
1
4,235.803
1
0.0812 0.0777 4,260.974
3
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Fast Food
Restaurant w/o
Drive Thru
1.42093 0.0153 0.1393 0.1170 8.4000e-
004
0.0106 0.0106 0.0106 0.0106 167.1684 167.1684 3.2000e-
003
3.0600e-
003
168.1618
Fast Food
Restaurant with
Drive Thru
7.10466 0.0766 0.6965 0.5851 4.1800e-
003
0.0529 0.0529 0.0529 0.0529 835.8421 835.8421 0.0160 0.0153 840.8091
High Turnover (Sit
Down Restaurant)
17.7616 0.1916 1.7413 1.4627 0.0105 0.1323 0.1323 0.1323 0.1323 2,089.605
2
2,089.605
2
0.0401 0.0383 2,102.022
6
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
17.7616 0.1916 1.7413 1.4627 0.0105 0.1323 0.1323 0.1323 0.1323 2,089.605
2
2,089.605
2
0.0401 0.0383 2,102.022
6
Regional
Shopping Center
0.0986301 1.0600e-
003
9.6700e-
003
8.1200e-
003
6.0000e-
005
7.3000e-
004
7.3000e-
004
7.3000e-
004
7.3000e-
004
11.6036 11.6036 2.2000e-
004
2.1000e-
004
11.6725
Total 0.8644 7.6463 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 14 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
Unmitigated 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
2.5111 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
27.5508 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 2.2324 19.0765 8.1177 0.1218 1.5424 1.5424 1.5424 1.5424 0.0000 24,352.94
12
24,352.94
12
0.4668 0.4465 24,497.65
85
Landscaping 2.8958 1.0980 95.2696 5.0300e-
003
0.5258 0.5258 0.5258 0.5258 171.4580 171.4580 0.1665 175.6194
Total 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 15 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
2.5111 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
27.5508 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 2.2324 19.0765 8.1177 0.1218 1.5424 1.5424 1.5424 1.5424 0.0000 24,352.94
12
24,352.94
12
0.4668 0.4465 24,497.65
85
Landscaping 2.8958 1.0980 95.2696 5.0300e-
003
0.5258 0.5258 0.5258 0.5258 171.4580 171.4580 0.1665 175.6194
Total 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 16 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
11.0 Vegetation
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:04 PMPage 17 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Summer
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Enclosed Parking with Elevator 2,424.00 Space 3.42 969,600.00 0
Other Asphalt Surfaces 166.98 1000sqft 3.83 166,981.00 0
Other Non-Asphalt Surfaces 174.56 1000sqft 4.01 174,555.00 0
Fast Food Restaurant w/o Drive Thru 2.00 1000sqft 0.05 2,000.00 0
Fast Food Restaurant with Drive Thru 10.00 1000sqft 0.23 10,000.00 0
High Turnover (Sit Down Restaurant)25.00 1000sqft 0.57 25,000.00 0
Quality Restaurant 25.00 1000sqft 0.57 25,000.00 0
Apartments Mid Rise 1,150.00 Dwelling Unit 1.48 1,288,000.00 2081
Regional Shopping Center 18.00 1000sqft 0.41 18,000.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
8
Wind Speed (m/s)Precipitation Freq (Days)2.2 30
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Bowery Mixed-Use Project (Operations)
Orange County, Winter
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 1 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
Project Characteristics -
Land Use - Consistent with DEIR's model.
Construction Phase - Consistent with DEIR's model.
Off-road Equipment - Consistent with DEIR's model.
Vehicle Trips - See SWAPE comment about trip rates and trip purpose percentages.
Vehicle Emission Factors - See SWAPE comment about vehicle emission factors.
Vehicle Emission Factors -
Vehicle Emission Factors -
Woodstoves - Consistent with DEIR's model.
Trips and VMT -
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 20.00 1.00
tblFireplaces NumberGas 977.50 1,150.00
tblFireplaces NumberNoFireplace 115.00 0.00
tblFireplaces NumberWood 57.50 0.00
tblLandUse LandUseSquareFeet 166,980.00 166,981.00
tblLandUse LandUseSquareFeet 174,560.00 174,555.00
tblLandUse LandUseSquareFeet 1,150,000.00 1,288,000.00
tblLandUse LotAcreage 21.82 3.42
tblLandUse LotAcreage 30.26 1.48
tblLandUse Population 3,289.00 2,081.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblVehicleTrips DV_TP 37.00 0.00
tblVehicleTrips DV_TP 21.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 2 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
tblVehicleTrips DV_TP 20.00 0.00
tblVehicleTrips DV_TP 18.00 0.00
tblVehicleTrips DV_TP 35.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 12.00 17.00
tblVehicleTrips PB_TP 50.00 31.00
tblVehicleTrips PB_TP 43.00 21.00
tblVehicleTrips PB_TP 44.00 22.00
tblVehicleTrips PB_TP 11.00 24.00
tblVehicleTrips PR_TP 86.00 89.00
tblVehicleTrips PR_TP 51.00 83.00
tblVehicleTrips PR_TP 29.00 69.00
tblVehicleTrips PR_TP 37.00 79.00
tblVehicleTrips PR_TP 38.00 78.00
tblVehicleTrips PR_TP 54.00 76.00
tblVehicleTrips ST_TR 6.39 5.30
tblVehicleTrips ST_TR 696.00 803.38
tblVehicleTrips ST_TR 722.03 325.70
tblVehicleTrips ST_TR 158.37 109.58
tblVehicleTrips ST_TR 94.36 82.68
tblVehicleTrips ST_TR 49.97 35.31
tblVehicleTrips SU_TR 5.86 5.30
tblVehicleTrips SU_TR 500.00 803.38
tblVehicleTrips SU_TR 542.72 325.70
tblVehicleTrips SU_TR 131.84 109.58
tblVehicleTrips SU_TR 72.16 82.68
tblVehicleTrips SU_TR 25.24 35.31
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 3 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
2.0 Emissions Summary
tblVehicleTrips WD_TR 6.65 5.30
tblVehicleTrips WD_TR 716.00 803.38
tblVehicleTrips WD_TR 496.12 325.70
tblVehicleTrips WD_TR 127.15 109.58
tblVehicleTrips WD_TR 89.95 82.68
tblVehicleTrips WD_TR 42.70 35.31
tblWoodstoves NumberCatalytic 57.50 0.00
tblWoodstoves NumberNoncatalytic 57.50 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 4 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2020 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 5 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
Energy 0.8644 7.6462 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
Mobile 22.1358 89.5904 272.5261 1.0367 98.3073 0.7838 99.0910 26.2886 0.7290 27.0176 105,389.1
884
105,389.1
884
4.4479 105,500.3
869
Total 58.1902 117.4111 380.9609 1.2107 98.3073 3.4492 101.7564 26.2886 3.3944 29.6830 0.0000 139,343.2
149
139,343.2
149
5.2619 0.6194 139,659.3
278
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
Energy 0.8644 7.6462 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
Mobile 22.1358 89.5904 272.5261 1.0367 98.3073 0.7838 99.0910 26.2886 0.7290 27.0176 105,389.1
884
105,389.1
884
4.4479 105,500.3
869
Total 58.1902 117.4111 380.9609 1.2107 98.3073 3.4492 101.7564 26.2886 3.3944 29.6830 0.0000 139,343.2
149
139,343.2
149
5.2619 0.6194 139,659.3
278
Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 6 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 6/1/2020 6/1/2020 5 1
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 8.00 81 0.73
Demolition Excavators 0 8.00 158 0.38
Demolition Rubber Tired Dozers 0 8.00 247 0.40
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 0 0.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 11.26
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 7 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
3.2 Demolition - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction Off-Site
3.1 Mitigation Measures Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 8 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
4.0 Operational Detail - Mobile
3.2 Demolition - 2020
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 9 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 22.1358 89.5904 272.5261 1.0367 98.3073 0.7838 99.0910 26.2886 0.7290 27.0176 105,389.1
884
105,389.1
884
4.4479 105,500.3
869
Unmitigated 22.1358 89.5904 272.5261 1.0367 98.3073 0.7838 99.0910 26.2886 0.7290 27.0176 105,389.1
884
105,389.1
884
4.4479 105,500.3
869
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Mid Rise 6,095.00 6,095.00 6095.00 21,524,690 21,524,690
Enclosed Parking with Elevator 0.00 0.00 0.00
Fast Food Restaurant w/o Drive Thru 1,606.76 1,606.76 1606.76 4,008,951 4,008,951
Fast Food Restaurant with Drive Thru 3,257.00 3,257.00 3257.00 6,822,622 6,822,622
High Turnover (Sit Down Restaurant)2,739.50 2,739.50 2739.50 6,962,775 6,962,775
Other Asphalt Surfaces 0.00 0.00 0.00
Other Non-Asphalt Surfaces 0.00 0.00 0.00
Quality Restaurant 2,067.00 2,067.00 2067.00 5,356,416 5,356,416
Regional Shopping Center 635.58 635.58 635.58 1,667,397 1,667,397
Total 16,400.84 16,400.84 16,400.84 46,342,852 46,342,852
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 10 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Apartments Mid Rise 14.70 5.90 8.70 40.20 19.20 40.60 89 11 0
Enclosed Parking with Elevator 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
Fast Food Restaurant w/o Drive
Thru
16.60 8.40 6.90 1.50 79.50 19.00 83 0 17
Fast Food Restaurant with Drive
Thru
16.60 8.40 6.90 2.20 78.80 19.00 69 0 31
High Turnover (Sit Down
Restaurant)
16.60 8.40 6.90 8.50 72.50 19.00 79 0 21
Other Asphalt Surfaces 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
Other Non-Asphalt Surfaces 16.60 8.40 6.90 0.00 0.00 0.00 0 0 0
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 78 0 22
Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 76 0 24
5.0 Energy Detail
5.1 Mitigation Measures Energy
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Apartments Mid Rise 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Enclosed Parking with Elevator 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Fast Food Restaurant w/o Drive
Thru
0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Fast Food Restaurant with Drive
Thru
0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
High Turnover (Sit Down
Restaurant)
0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Other Asphalt Surfaces 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Other Non-Asphalt Surfaces 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Quality Restaurant 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Regional Shopping Center 0.561378 0.043284 0.209473 0.111826 0.015545 0.005795 0.025829 0.017125 0.001747 0.001542 0.004926 0.000594 0.000934
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 11 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.8644 7.6462 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
NaturalGas
Unmitigated
0.8644 7.6462 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 12 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Apartments Mid
Rise
36004.3 0.3883 3.3181 1.4119 0.0212 0.2683 0.2683 0.2683 0.2683 4,235.803
1
4,235.803
1
0.0812 0.0777 4,260.974
3
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Fast Food
Restaurant w/o
Drive Thru
1420.93 0.0153 0.1393 0.1170 8.4000e-
004
0.0106 0.0106 0.0106 0.0106 167.1684 167.1684 3.2000e-
003
3.0600e-
003
168.1618
Fast Food
Restaurant with
Drive Thru
7104.66 0.0766 0.6965 0.5851 4.1800e-
003
0.0529 0.0529 0.0529 0.0529 835.8421 835.8421 0.0160 0.0153 840.8091
High Turnover (Sit
Down Restaurant)
17761.6 0.1916 1.7413 1.4627 0.0105 0.1323 0.1323 0.1323 0.1323 2,089.605
2
2,089.605
2
0.0401 0.0383 2,102.022
6
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
17761.6 0.1916 1.7413 1.4627 0.0105 0.1323 0.1323 0.1323 0.1323 2,089.605
2
2,089.605
2
0.0401 0.0383 2,102.022
6
Regional
Shopping Center
98.6301 1.0600e-
003
9.6700e-
003
8.1200e-
003
6.0000e-
005
7.3000e-
004
7.3000e-
004
7.3000e-
004
7.3000e-
004
11.6036 11.6036 2.2000e-
004
2.1000e-
004
11.6725
Total 0.8644 7.6463 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 13 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Apartments Mid
Rise
36.0043 0.3883 3.3181 1.4119 0.0212 0.2683 0.2683 0.2683 0.2683 4,235.803
1
4,235.803
1
0.0812 0.0777 4,260.974
3
Enclosed Parking
with Elevator
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Fast Food
Restaurant w/o
Drive Thru
1.42093 0.0153 0.1393 0.1170 8.4000e-
004
0.0106 0.0106 0.0106 0.0106 167.1684 167.1684 3.2000e-
003
3.0600e-
003
168.1618
Fast Food
Restaurant with
Drive Thru
7.10466 0.0766 0.6965 0.5851 4.1800e-
003
0.0529 0.0529 0.0529 0.0529 835.8421 835.8421 0.0160 0.0153 840.8091
High Turnover (Sit
Down Restaurant)
17.7616 0.1916 1.7413 1.4627 0.0105 0.1323 0.1323 0.1323 0.1323 2,089.605
2
2,089.605
2
0.0401 0.0383 2,102.022
6
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Quality
Restaurant
17.7616 0.1916 1.7413 1.4627 0.0105 0.1323 0.1323 0.1323 0.1323 2,089.605
2
2,089.605
2
0.0401 0.0383 2,102.022
6
Regional
Shopping Center
0.0986301 1.0600e-
003
9.6700e-
003
8.1200e-
003
6.0000e-
005
7.3000e-
004
7.3000e-
004
7.3000e-
004
7.3000e-
004
11.6036 11.6036 2.2000e-
004
2.1000e-
004
11.6725
Total 0.8644 7.6463 5.0476 0.0472 0.5972 0.5972 0.5972 0.5972 9,429.627
4
9,429.627
4
0.1807 0.1729 9,485.663
0
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 14 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
Unmitigated 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
2.5111 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
27.5508 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 2.2324 19.0765 8.1177 0.1218 1.5424 1.5424 1.5424 1.5424 0.0000 24,352.94
12
24,352.94
12
0.4668 0.4465 24,497.65
85
Landscaping 2.8958 1.0980 95.2696 5.0300e-
003
0.5258 0.5258 0.5258 0.5258 171.4580 171.4580 0.1665 175.6194
Total 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 15 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
2.5111 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
27.5508 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Hearth 2.2324 19.0765 8.1177 0.1218 1.5424 1.5424 1.5424 1.5424 0.0000 24,352.94
12
24,352.94
12
0.4668 0.4465 24,497.65
85
Landscaping 2.8958 1.0980 95.2696 5.0300e-
003
0.5258 0.5258 0.5258 0.5258 171.4580 171.4580 0.1665 175.6194
Total 35.1901 20.1745 103.3872 0.1268 2.0682 2.0682 2.0682 2.0682 0.0000 24,524.39
92
24,524.39
92
0.6332 0.4465 24,673.27
79
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 16 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
11.0 Vegetation
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/5/2020 3:02 PMPage 17 of 17
The Bowery Mixed-Use Project (Operations) - Orange County, Winter
Project Characteristics -
Land Use -
Construction Phase - Consistent with DEIR's model.
Off-road Equipment - Consistent with DEIR's.
Fleet Mix - Consistent with DEIR's model.
Vehicle Emission Factors - See SWAPE comment about emission factors.
Vehicle Trips - Consistent with DEIR's model.
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Industrial Park 212.12 1000sqft 4.87 212,121.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
8
Wind Speed (m/s)Precipitation Freq (Days)2.2 30
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2019Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars)
Orange County, Annual
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 1 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
2.0 Emissions Summary
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 20.00 1.00
tblFleetMix HHD 0.02 0.00
tblFleetMix LDA 0.55 0.60
tblFleetMix LDT1 0.04 0.05
tblFleetMix LDT2 0.21 0.23
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 5.7970e-003 0.00
tblFleetMix MCY 4.8300e-003 0.00
tblFleetMix MDV 0.12 0.13
tblFleetMix MH 1.0410e-003 0.00
tblFleetMix MHD 0.02 0.00
tblFleetMix OBUS 1.6370e-003 0.00
tblFleetMix SBUS 5.8300e-004 0.00
tblFleetMix UBUS 1.6330e-003 0.00
tblLandUse LandUseSquareFeet 212,120.00 212,121.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips ST_TR 2.49 1.34
tblVehicleTrips SU_TR 0.73 0.66
tblVehicleTrips WD_TR 6.83 1.79
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 2 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2019 3.0000e-
005
2.0000e-
005
2.5000e-
004
0.0000 8.0000e-
005
0.0000 8.0000e-
005
2.0000e-
005
0.0000 2.0000e-
005
0.0000 0.0736 0.0736 0.0000 0.0000 0.0737
Maximum 3.0000e-
005
2.0000e-
005
2.5000e-
004
0.0000 8.0000e-
005
0.0000 8.0000e-
005
2.0000e-
005
0.0000 2.0000e-
005
0.0000 0.0736 0.0736 0.0000 0.0000 0.0737
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2019 3.0000e-
005
2.0000e-
005
2.5000e-
004
0.0000 8.0000e-
005
0.0000 8.0000e-
005
2.0000e-
005
0.0000 2.0000e-
005
0.0000 0.0736 0.0736 0.0000 0.0000 0.0737
Maximum 3.0000e-
005
2.0000e-
005
2.5000e-
004
0.0000 8.0000e-
005
0.0000 8.0000e-
005
2.0000e-
005
0.0000 2.0000e-
005
0.0000 0.0736 0.0736 0.0000 0.0000 0.0737
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 3 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Energy 0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 1,048.993
3
1,048.993
3
0.0410 9.9700e-
003
1,052.990
8
Mobile 0.0896 0.1710 1.8166 6.4800e-
003
0.6265 3.9100e-
003
0.6304 0.1663 3.6100e-
003
0.1699 0.0000 586.0116 586.0116 0.0130 0.0000 586.3367
Waste 0.0000 0.0000 0.0000 0.0000 53.3927 0.0000 53.3927 3.1554 0.0000 132.2782
Water 0.0000 0.0000 0.0000 0.0000 15.5622 203.5086 219.0707 1.6068 0.0395 271.0053
Total 0.9652 0.2661 1.8991 7.0500e-
003
0.6265 0.0111 0.6377 0.1663 0.0108 0.1771 68.9549 1,838.518
7
1,907.473
6
4.8162 0.0495 2,042.616
6
Unmitigated Operational
Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter)Maximum Mitigated ROG + NOX (tons/quarter)
Highest
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 4 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Energy 0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 1,048.993
3
1,048.993
3
0.0410 9.9700e-
003
1,052.990
8
Mobile 0.0896 0.1710 1.8166 6.4800e-
003
0.6265 3.9100e-
003
0.6304 0.1663 3.6100e-
003
0.1699 0.0000 586.0116 586.0116 0.0130 0.0000 586.3367
Waste 0.0000 0.0000 0.0000 0.0000 53.3927 0.0000 53.3927 3.1554 0.0000 132.2782
Water 0.0000 0.0000 0.0000 0.0000 15.5622 203.5086 219.0707 1.6068 0.0395 271.0053
Total 0.9652 0.2661 1.8991 7.0500e-
003
0.6265 0.0111 0.6377 0.1663 0.0108 0.1771 68.9549 1,838.518
7
1,907.473
6
4.8162 0.0495 2,042.616
6
Mitigated Operational
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 11/11/2019 11/11/2019 5 1
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Acres of Grading (Site Preparation Phase): 0
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 5 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
3.1 Mitigation Measures Construction
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 8.00 81 0.73
Demolition Excavators 0 8.00 158 0.38
Demolition Rubber Tired Dozers 0 8.00 247 0.40
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 6 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 3.0000e-
005
2.0000e-
005
2.5000e-
004
0.0000 8.0000e-
005
0.0000 8.0000e-
005
2.0000e-
005
0.0000 2.0000e-
005
0.0000 0.0736 0.0736 0.0000 0.0000 0.0737
Total 3.0000e-
005
2.0000e-
005
2.5000e-
004
0.0000 8.0000e-
005
0.0000 8.0000e-
005
2.0000e-
005
0.0000 2.0000e-
005
0.0000 0.0736 0.0736 0.0000 0.0000 0.0737
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 7 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
4.0 Operational Detail - Mobile
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 3.0000e-
005
2.0000e-
005
2.5000e-
004
0.0000 8.0000e-
005
0.0000 8.0000e-
005
2.0000e-
005
0.0000 2.0000e-
005
0.0000 0.0736 0.0736 0.0000 0.0000 0.0737
Total 3.0000e-
005
2.0000e-
005
2.5000e-
004
0.0000 8.0000e-
005
0.0000 8.0000e-
005
2.0000e-
005
0.0000 2.0000e-
005
0.0000 0.0736 0.0736 0.0000 0.0000 0.0737
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 8 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.0896 0.1710 1.8166 6.4800e-
003
0.6265 3.9100e-
003
0.6304 0.1663 3.6100e-
003
0.1699 0.0000 586.0116 586.0116 0.0130 0.0000 586.3367
Unmitigated 0.0896 0.1710 1.8166 6.4800e-
003
0.6265 3.9100e-
003
0.6304 0.1663 3.6100e-
003
0.1699 0.0000 586.0116 586.0116 0.0130 0.0000 586.3367
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Industrial Park 379.69 284.24 140.00 1,679,401 1,679,401
Total 379.69 284.24 140.00 1,679,401 1,679,401
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Industrial Park 16.60 8.40 6.90 100.00 0.00 0.00 79 19 2
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Industrial Park 0.595976 0.047720 0.227789 0.128515 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 9 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated
0.0000 0.0000 0.0000 0.0000 0.0000 945.5323 945.5323 0.0390 8.0800e-
003
948.9149
Electricity
Unmitigated
0.0000 0.0000 0.0000 0.0000 0.0000 945.5323 945.5323 0.0390 8.0800e-
003
948.9149
NaturalGas
Mitigated
0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
NaturalGas
Unmitigated
0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 10 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Industrial Park 1.93879e
+006
0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
Total 0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Industrial Park 1.93879e
+006
0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
Total 0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 11 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
6.1 Mitigation Measures Area
6.0 Area Detail
5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Industrial Park 2.96757e
+006
945.5323 0.0390 8.0800e-
003
948.9149
Total 945.5323 0.0390 8.0800e-
003
948.9149
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Industrial Park 2.96757e
+006
945.5323 0.0390 8.0800e-
003
948.9149
Total 945.5323 0.0390 8.0800e-
003
948.9149
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 12 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Unmitigated 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating
0.0983 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.7665 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.6000e-
004
3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Total 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 13 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
7.1 Mitigation Measures Water
7.0 Water Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating
0.0983 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.7665 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.6000e-
004
3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Total 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 14 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 219.0707 1.6068 0.0395 271.0053
Unmitigated 219.0707 1.6068 0.0395 271.0053
7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Industrial Park 49.0528 /
0
219.0707 1.6068 0.0395 271.0053
Total 219.0707 1.6068 0.0395 271.0053
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 15 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
8.1 Mitigation Measures Waste
7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Industrial Park 49.0528 /
0
219.0707 1.6068 0.0395 271.0053
Total 219.0707 1.6068 0.0395 271.0053
Mitigated
8.0 Waste Detail
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 53.3927 3.1554 0.0000 132.2782
Unmitigated 53.3927 3.1554 0.0000 132.2782
Category/Year
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 16 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Industrial Park 263.03 53.3927 3.1554 0.0000 132.2782
Total 53.3927 3.1554 0.0000 132.2782
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Industrial Park 263.03 53.3927 3.1554 0.0000 132.2782
Total 53.3927 3.1554 0.0000 132.2782
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 17 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
11.0 Vegetation
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:19 AMPage 18 of 18
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Annual
Project Characteristics -
Land Use -
Construction Phase - Consistent with DEIR's model.
Off-road Equipment - Consistent with DEIR's.
Fleet Mix - Consistent with DEIR's model.
Vehicle Emission Factors - See SWAPE comment about emission factors.
Vehicle Trips - Consistent with DEIR's model.
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Industrial Park 212.12 1000sqft 4.87 212,121.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
8
Wind Speed (m/s)Precipitation Freq (Days)2.2 30
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2019Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars)
Orange County, Summer
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 1 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
2.0 Emissions Summary
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 20.00 1.00
tblFleetMix HHD 0.02 0.00
tblFleetMix LDA 0.55 0.60
tblFleetMix LDT1 0.04 0.05
tblFleetMix LDT2 0.21 0.23
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 5.7970e-003 0.00
tblFleetMix MCY 4.8300e-003 0.00
tblFleetMix MDV 0.12 0.13
tblFleetMix MH 1.0410e-003 0.00
tblFleetMix MHD 0.02 0.00
tblFleetMix OBUS 1.6370e-003 0.00
tblFleetMix SBUS 5.8300e-004 0.00
tblFleetMix UBUS 1.6330e-003 0.00
tblLandUse LandUseSquareFeet 212,120.00 212,121.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips ST_TR 2.49 1.34
tblVehicleTrips SU_TR 0.73 0.66
tblVehicleTrips WD_TR 6.83 1.79
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 2 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2019 0.0618 0.0405 0.5351 1.6900e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 0.0000 168.9210 168.9210 4.1500e-
003
0.0000 169.0249
Maximum 0.0618 0.0405 0.5351 1.6900e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 0.0000 168.9210 168.9210 4.1500e-
003
0.0000 169.0249
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2019 0.0618 0.0405 0.5351 1.6900e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 0.0000 168.9210 168.9210 4.1500e-
003
0.0000 169.0249
Maximum 0.0618 0.0405 0.5351 1.6900e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 0.0000 168.9210 168.9210 4.1500e-
003
0.0000 169.0249
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 3 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Energy 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mobile 0.5984 0.9562 12.0657 0.0424 4.0109 0.0246 4.0355 1.0632 0.0227 1.0859 4,231.826
7
4,231.826
7
0.0938 4,234.172
1
Total 5.3965 1.4772 12.5250 0.0456 4.0109 0.0643 4.0752 1.0632 0.0624 1.1256 4,856.784
0
4,856.784
0
0.1059 0.0115 4,862.846
0
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Energy 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mobile 0.5984 0.9562 12.0657 0.0424 4.0109 0.0246 4.0355 1.0632 0.0227 1.0859 4,231.826
7
4,231.826
7
0.0938 4,234.172
1
Total 5.3965 1.4772 12.5250 0.0456 4.0109 0.0643 4.0752 1.0632 0.0624 1.1256 4,856.784
0
4,856.784
0
0.1059 0.0115 4,862.846
0
Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 4 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 11/11/2019 11/11/2019 5 1
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 8.00 81 0.73
Demolition Excavators 0 8.00 158 0.38
Demolition Rubber Tired Dozers 0 8.00 247 0.40
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 5 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0618 0.0405 0.5351 1.6900e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 168.9210 168.9210 4.1500e-
003
169.0249
Total 0.0618 0.0405 0.5351 1.6900e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 168.9210 168.9210 4.1500e-
003
169.0249
Unmitigated Construction Off-Site
3.1 Mitigation Measures Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 6 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
4.0 Operational Detail - Mobile
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0618 0.0405 0.5351 1.6900e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 168.9210 168.9210 4.1500e-
003
169.0249
Total 0.0618 0.0405 0.5351 1.6900e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 168.9210 168.9210 4.1500e-
003
169.0249
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 7 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 0.5984 0.9562 12.0657 0.0424 4.0109 0.0246 4.0355 1.0632 0.0227 1.0859 4,231.826
7
4,231.826
7
0.0938 4,234.172
1
Unmitigated 0.5984 0.9562 12.0657 0.0424 4.0109 0.0246 4.0355 1.0632 0.0227 1.0859 4,231.826
7
4,231.826
7
0.0938 4,234.172
1
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Industrial Park 379.69 284.24 140.00 1,679,401 1,679,401
Total 379.69 284.24 140.00 1,679,401 1,679,401
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Industrial Park 16.60 8.40 6.90 100.00 0.00 0.00 79 19 2
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Industrial Park 0.595976 0.047720 0.227789 0.128515 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 8 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
NaturalGas
Unmitigated
0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 9 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Industrial Park 5311.74 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Total 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Industrial Park 5.31174 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Total 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 10 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Unmitigated 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.5387 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
4.2000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.0700e-
003
2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Total 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 11 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.5387 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
4.2000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.0700e-
003
2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Total 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 12 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
11.0 Vegetation
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:21 AMPage 13 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Summer
Project Characteristics -
Land Use -
Construction Phase - Consistent with DEIR's model.
Off-road Equipment - Consistent with DEIR's.
Fleet Mix - Consistent with DEIR's model.
Vehicle Emission Factors - See SWAPE comment about emission factors.
Vehicle Trips - Consistent with DEIR's model.
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Industrial Park 212.12 1000sqft 4.87 212,121.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
8
Wind Speed (m/s)Precipitation Freq (Days)2.2 30
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2019Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars)
Orange County, Winter
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 1 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
2.0 Emissions Summary
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 20.00 1.00
tblFleetMix HHD 0.02 0.00
tblFleetMix LDA 0.55 0.60
tblFleetMix LDT1 0.04 0.05
tblFleetMix LDT2 0.21 0.23
tblFleetMix LHD1 0.02 0.00
tblFleetMix LHD2 5.7970e-003 0.00
tblFleetMix MCY 4.8300e-003 0.00
tblFleetMix MDV 0.12 0.13
tblFleetMix MH 1.0410e-003 0.00
tblFleetMix MHD 0.02 0.00
tblFleetMix OBUS 1.6370e-003 0.00
tblFleetMix SBUS 5.8300e-004 0.00
tblFleetMix UBUS 1.6330e-003 0.00
tblLandUse LandUseSquareFeet 212,120.00 212,121.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips ST_TR 2.49 1.34
tblVehicleTrips SU_TR 0.73 0.66
tblVehicleTrips WD_TR 6.83 1.79
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 2 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2019 0.0697 0.0446 0.4954 1.6000e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 0.0000 159.8661 159.8661 3.9400e-
003
0.0000 159.9645
Maximum 0.0697 0.0446 0.4954 1.6000e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 0.0000 159.8661 159.8661 3.9400e-
003
0.0000 159.9645
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2019 0.0697 0.0446 0.4954 1.6000e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 0.0000 159.8661 159.8661 3.9400e-
003
0.0000 159.9645
Maximum 0.0697 0.0446 0.4954 1.6000e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 0.0000 159.8661 159.8661 3.9400e-
003
0.0000 159.9645
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 3 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Energy 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mobile 0.5790 1.0494 11.1609 0.0402 4.0109 0.0246 4.0355 1.0632 0.0227 1.0859 4,005.1159 4,005.1159 0.0889 4,007.337
8
Total 5.3771 1.5704 11.6202 0.0433 4.0109 0.0643 4.0752 1.0632 0.0624 1.1256 4,630.073
2
4,630.073
2
0.1010 0.0115 4,636.011
7
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Energy 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mobile 0.5790 1.0494 11.1609 0.0402 4.0109 0.0246 4.0355 1.0632 0.0227 1.0859 4,005.1159 4,005.1159 0.0889 4,007.337
8
Total 5.3771 1.5704 11.6202 0.0433 4.0109 0.0643 4.0752 1.0632 0.0624 1.1256 4,630.073
2
4,630.073
2
0.1010 0.0115 4,636.011
7
Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 4 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 11/11/2019 11/11/2019 5 1
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 8.00 81 0.73
Demolition Excavators 0 8.00 158 0.38
Demolition Rubber Tired Dozers 0 8.00 247 0.40
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 5 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0697 0.0446 0.4954 1.6000e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 159.8661 159.8661 3.9400e-
003
159.9645
Total 0.0697 0.0446 0.4954 1.6000e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 159.8661 159.8661 3.9400e-
003
159.9645
Unmitigated Construction Off-Site
3.1 Mitigation Measures Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 6 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
4.0 Operational Detail - Mobile
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0697 0.0446 0.4954 1.6000e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 159.8661 159.8661 3.9400e-
003
159.9645
Total 0.0697 0.0446 0.4954 1.6000e-
003
0.1677 1.1200e-
003
0.1688 0.0445 1.0300e-
003
0.0455 159.8661 159.8661 3.9400e-
003
159.9645
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 7 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 0.5790 1.0494 11.1609 0.0402 4.0109 0.0246 4.0355 1.0632 0.0227 1.0859 4,005.1159 4,005.115
9
0.0889 4,007.337
8
Unmitigated 0.5790 1.0494 11.1609 0.0402 4.0109 0.0246 4.0355 1.0632 0.0227 1.0859 4,005.1159 4,005.115
9
0.0889 4,007.337
8
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Industrial Park 379.69 284.24 140.00 1,679,401 1,679,401
Total 379.69 284.24 140.00 1,679,401 1,679,401
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Industrial Park 16.60 8.40 6.90 100.00 0.00 0.00 79 19 2
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Industrial Park 0.595976 0.047720 0.227789 0.128515 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000 0.000000
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 8 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
NaturalGas
Unmitigated
0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 9 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Industrial Park 5311.74 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Total 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Industrial Park 5.31174 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Total 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 10 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Unmitigated 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.5387 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
4.2000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.0700e-
003
2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Total 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 11 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.5387 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
4.2000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.0700e-
003
2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Total 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 12 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
11.0 Vegetation
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:20 AMPage 13 of 13
The Bowery Mixed-Use Project (Existing Operations - Passenger Cars) - Orange County, Winter
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Industrial Park 212.12 1000sqft 4.87 212,121.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
8
Wind Speed (m/s)Precipitation Freq (Days)2.2 30
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2019Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Bowery Mixed-Use Project (Existing Operations - Trucks)
Orange County, Annual
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 1 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
Project Characteristics -
Land Use - Consistent with DEIR's model.
Construction Phase - Consistent with DEIR's model.
Off-road Equipment - Consistent with DEIR's.
Vehicle Trips - Consistent with DEIR's model.
Vehicle Emission Factors - See SWAPE comment about emission factors.
Fleet Mix - Consistent with DEIR's model.
Vehicle Emission Factors - Consistent with DEIR's model.
Vehicle Emission Factors -
Trips and VMT -
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 2 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
2.0 Emissions Summary
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 20.00 1.00
tblFleetMix HHD 0.02 0.84
tblFleetMix LDA 0.55 0.00
tblFleetMix LDT1 0.04 0.00
tblFleetMix LDT2 0.21 0.00
tblFleetMix LHD1 0.02 0.09
tblFleetMix LHD2 5.7970e-003 0.00
tblFleetMix MCY 4.8300e-003 0.00
tblFleetMix MDV 0.12 0.00
tblFleetMix MH 1.0410e-003 0.00
tblFleetMix MHD 0.02 0.07
tblFleetMix OBUS 1.6370e-003 0.00
tblFleetMix SBUS 5.8300e-004 0.00
tblFleetMix UBUS 1.6330e-003 0.00
tblLandUse LandUseSquareFeet 212,120.00 212,121.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips ST_TR 2.49 1.34
tblVehicleTrips SU_TR 0.73 0.66
tblVehicleTrips WD_TR 6.83 1.79
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 3 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2019 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2019 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 4 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Energy 0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 1,048.993
3
1,048.993
3
0.0410 9.9700e-
003
1,052.990
8
Mobile 0.3659 12.9137 3.1569 0.0309 0.7238 0.0526 0.7764 0.2004 0.0504 0.2508 0.0000 3,095.108
7
3,095.108
7
0.3214 0.0000 3,103.143
4
Waste 0.0000 0.0000 0.0000 0.0000 53.3927 0.0000 53.3927 3.1554 0.0000 132.2782
Water 0.0000 0.0000 0.0000 0.0000 15.5622 203.5086 219.0707 1.6068 0.0395 271.0053
Total 1.2414 13.0087 3.2394 0.0314 0.7238 0.0599 0.7836 0.2004 0.0576 0.2580 68.9549 4,347.615
8
4,416.570
7
5.1246 0.0495 4,559.423
3
Unmitigated Operational
Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter)Maximum Mitigated ROG + NOX (tons/quarter)
Highest
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 5 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Energy 0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 1,048.993
3
1,048.993
3
0.0410 9.9700e-
003
1,052.990
8
Mobile 0.3659 12.9137 3.1569 0.0309 0.7238 0.0526 0.7764 0.2004 0.0504 0.2508 0.0000 3,095.108
7
3,095.108
7
0.3214 0.0000 3,103.143
4
Waste 0.0000 0.0000 0.0000 0.0000 53.3927 0.0000 53.3927 3.1554 0.0000 132.2782
Water 0.0000 0.0000 0.0000 0.0000 15.5622 203.5086 219.0707 1.6068 0.0395 271.0053
Total 1.2414 13.0087 3.2394 0.0314 0.7238 0.0599 0.7836 0.2004 0.0576 0.2580 68.9549 4,347.615
8
4,416.570
7
5.1246 0.0495 4,559.423
3
Mitigated Operational
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 11/11/2019 11/11/2019 5 1
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Acres of Grading (Site Preparation Phase): 0
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 6 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
3.1 Mitigation Measures Construction
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 8.00 81 0.73
Demolition Excavators 0 8.00 158 0.38
Demolition Rubber Tired Dozers 0 8.00 247 0.40
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 0 0.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 7 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 8 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
4.0 Operational Detail - Mobile
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 9 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.3659 12.9137 3.1569 0.0309 0.7238 0.0526 0.7764 0.2004 0.0504 0.2508 0.0000 3,095.108
7
3,095.108
7
0.3214 0.0000 3,103.143
4
Unmitigated 0.3659 12.9137 3.1569 0.0309 0.7238 0.0526 0.7764 0.2004 0.0504 0.2508 0.0000 3,095.108
7
3,095.108
7
0.3214 0.0000 3,103.143
4
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Industrial Park 379.69 284.24 140.00 1,679,401 1,679,401
Total 379.69 284.24 140.00 1,679,401 1,679,401
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Industrial Park 16.60 8.40 6.90 100.00 0.00 0.00 79 19 2
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Industrial Park 0.000000 0.000000 0.000000 0.000000 0.085799 0.000000 0.071006 0.843195 0.000000 0.000000 0.000000 0.000000 0.000000
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 10 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated
0.0000 0.0000 0.0000 0.0000 0.0000 945.5323 945.5323 0.0390 8.0800e-
003
948.9149
Electricity
Unmitigated
0.0000 0.0000 0.0000 0.0000 0.0000 945.5323 945.5323 0.0390 8.0800e-
003
948.9149
NaturalGas
Mitigated
0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
NaturalGas
Unmitigated
0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 11 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Industrial Park 1.93879e
+006
0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
Total 0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Industrial Park 1.93879e
+006
0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
Total 0.0105 0.0950 0.0798 5.7000e-
004
7.2200e-
003
7.2200e-
003
7.2200e-
003
7.2200e-
003
0.0000 103.4610 103.4610 1.9800e-
003
1.9000e-
003
104.0758
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 12 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
6.1 Mitigation Measures Area
6.0 Area Detail
5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Industrial Park 2.96757e
+006
945.5323 0.0390 8.0800e-
003
948.9149
Total 945.5323 0.0390 8.0800e-
003
948.9149
Unmitigated
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Industrial Park 2.96757e
+006
945.5323 0.0390 8.0800e-
003
948.9149
Total 945.5323 0.0390 8.0800e-
003
948.9149
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 13 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Unmitigated 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating
0.0983 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.7665 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.6000e-
004
3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Total 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 14 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
7.1 Mitigation Measures Water
7.0 Water Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating
0.0983 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
0.7665 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.6000e-
004
3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Total 0.8651 3.0000e-
005
2.7300e-
003
0.0000 1.0000e-
005
1.0000e-
005
1.0000e-
005
1.0000e-
005
0.0000 5.2600e-
003
5.2600e-
003
1.0000e-
005
0.0000 5.6200e-
003
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 15 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 219.0707 1.6068 0.0395 271.0053
Unmitigated 219.0707 1.6068 0.0395 271.0053
7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Industrial Park 49.0528 /
0
219.0707 1.6068 0.0395 271.0053
Total 219.0707 1.6068 0.0395 271.0053
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 16 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
8.1 Mitigation Measures Waste
7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Industrial Park 49.0528 /
0
219.0707 1.6068 0.0395 271.0053
Total 219.0707 1.6068 0.0395 271.0053
Mitigated
8.0 Waste Detail
Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 53.3927 3.1554 0.0000 132.2782
Unmitigated 53.3927 3.1554 0.0000 132.2782
Category/Year
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 17 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Industrial Park 263.03 53.3927 3.1554 0.0000 132.2782
Total 53.3927 3.1554 0.0000 132.2782
Unmitigated
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Industrial Park 263.03 53.3927 3.1554 0.0000 132.2782
Total 53.3927 3.1554 0.0000 132.2782
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 18 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
11.0 Vegetation
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:28 AMPage 19 of 19
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Annual
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Industrial Park 212.12 1000sqft 4.87 212,121.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
8
Wind Speed (m/s)Precipitation Freq (Days)2.2 30
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2019Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Bowery Mixed-Use Project (Existing Operations - Trucks)
Orange County, Summer
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 1 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
Project Characteristics -
Land Use - Consistent with DEIR's model.
Construction Phase - Consistent with DEIR's model.
Off-road Equipment - Consistent with DEIR's.
Vehicle Trips - Consistent with DEIR's model.
Vehicle Emission Factors - See SWAPE comment about emission factors.
Fleet Mix - Consistent with DEIR's model.
Vehicle Emission Factors - Consistent with DEIR's model.
Vehicle Emission Factors -
Trips and VMT -
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 2 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
2.0 Emissions Summary
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 20.00 1.00
tblFleetMix HHD 0.02 0.84
tblFleetMix LDA 0.55 0.00
tblFleetMix LDT1 0.04 0.00
tblFleetMix LDT2 0.21 0.00
tblFleetMix LHD1 0.02 0.09
tblFleetMix LHD2 5.7970e-003 0.00
tblFleetMix MCY 4.8300e-003 0.00
tblFleetMix MDV 0.12 0.00
tblFleetMix MH 1.0410e-003 0.00
tblFleetMix MHD 0.02 0.07
tblFleetMix OBUS 1.6370e-003 0.00
tblFleetMix SBUS 5.8300e-004 0.00
tblFleetMix UBUS 1.6330e-003 0.00
tblLandUse LandUseSquareFeet 212,120.00 212,121.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips ST_TR 2.49 1.34
tblVehicleTrips SU_TR 0.73 0.66
tblVehicleTrips WD_TR 6.83 1.79
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 3 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2019 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2019 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 4 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Energy 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mobile 2.2666 79.0906 19.2333 0.1959 4.6223 0.3279 4.9502 1.2775 0.3137 1.5912 21,648.83
93
21,648.83
93
2.1976 21,703.77
80
Total 7.0647 79.6116 19.6927 0.1990 4.6223 0.3676 4.9899 1.2775 0.3534 1.6309 22,273.79
66
22,273.79
66
2.2097 0.0115 22,332.45
19
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Energy 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mobile 2.2666 79.0906 19.2333 0.1959 4.6223 0.3279 4.9502 1.2775 0.3137 1.5912 21,648.83
93
21,648.83
93
2.1976 21,703.77
80
Total 7.0647 79.6116 19.6927 0.1990 4.6223 0.3676 4.9899 1.2775 0.3534 1.6309 22,273.79
66
22,273.79
66
2.2097 0.0115 22,332.45
19
Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 5 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 11/11/2019 11/11/2019 5 1
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 8.00 81 0.73
Demolition Excavators 0 8.00 158 0.38
Demolition Rubber Tired Dozers 0 8.00 247 0.40
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 0 0.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 6 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction Off-Site
3.1 Mitigation Measures Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 7 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
4.0 Operational Detail - Mobile
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 8 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 2.2666 79.0906 19.2333 0.1959 4.6223 0.3279 4.9502 1.2775 0.3137 1.5912 21,648.83
93
21,648.83
93
2.1976 21,703.77
80
Unmitigated 2.2666 79.0906 19.2333 0.1959 4.6223 0.3279 4.9502 1.2775 0.3137 1.5912 21,648.83
93
21,648.83
93
2.1976 21,703.77
80
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Industrial Park 379.69 284.24 140.00 1,679,401 1,679,401
Total 379.69 284.24 140.00 1,679,401 1,679,401
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Industrial Park 16.60 8.40 6.90 100.00 0.00 0.00 79 19 2
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Industrial Park 0.000000 0.000000 0.000000 0.000000 0.085799 0.000000 0.071006 0.843195 0.000000 0.000000 0.000000 0.000000 0.000000
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 9 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
NaturalGas
Unmitigated
0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
5.1 Mitigation Measures Energy
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 10 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Industrial Park 5311.74 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Total 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Industrial Park 5.31174 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Total 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 11 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Unmitigated 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.5387 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
4.2000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.0700e-
003
2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Total 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 12 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.5387 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
4.2000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.0700e-
003
2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Total 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 13 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
11.0 Vegetation
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 14 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Summer
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Industrial Park 212.12 1000sqft 4.87 212,121.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
8
Wind Speed (m/s)Precipitation Freq (Days)2.2 30
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2019Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Bowery Mixed-Use Project (Existing Operations - Trucks)
Orange County, Winter
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 1 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Winter
Project Characteristics -
Land Use - Consistent with DEIR's model.
Construction Phase - Consistent with DEIR's model.
Off-road Equipment - Consistent with DEIR's.
Vehicle Trips - Consistent with DEIR's model.
Vehicle Emission Factors - See SWAPE comment about emission factors.
Fleet Mix - Consistent with DEIR's model.
Vehicle Emission Factors - Consistent with DEIR's model.
Vehicle Emission Factors -
Trips and VMT -
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 2 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Winter
2.0 Emissions Summary
Table Name Column Name Default Value New Value
tblConstructionPhase NumDays 20.00 1.00
tblFleetMix HHD 0.02 0.84
tblFleetMix LDA 0.55 0.00
tblFleetMix LDT1 0.04 0.00
tblFleetMix LDT2 0.21 0.00
tblFleetMix LHD1 0.02 0.09
tblFleetMix LHD2 5.7970e-003 0.00
tblFleetMix MCY 4.8300e-003 0.00
tblFleetMix MDV 0.12 0.00
tblFleetMix MH 1.0410e-003 0.00
tblFleetMix MHD 0.02 0.07
tblFleetMix OBUS 1.6370e-003 0.00
tblFleetMix SBUS 5.8300e-004 0.00
tblFleetMix UBUS 1.6330e-003 0.00
tblLandUse LandUseSquareFeet 212,120.00 212,121.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 3.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblVehicleTrips CC_TTP 28.00 0.00
tblVehicleTrips CNW_TTP 13.00 0.00
tblVehicleTrips CW_TTP 59.00 100.00
tblVehicleTrips ST_TR 2.49 1.34
tblVehicleTrips SU_TR 0.73 0.66
tblVehicleTrips WD_TR 6.83 1.79
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 3 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Winter
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2019 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2019 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Maximum 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 2/7/2020 10:30 AMPage 4 of 14
The Bowery Mixed-Use Project (Existing Operations - Trucks) - Orange County, Winter
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Energy 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mobile 2.3409 79.7184 20.6349 0.1922 4.6223 0.3361 4.9584 1.2775 0.3215 1.5990 21,238.40
91
21,238.40
91
2.2719 21,295.20
64
Total 7.1390 80.2394 21.0942 0.1953 4.6223 0.3758 4.9980 1.2775 0.3612 1.6387 21,863.36
64
21,863.36
64
2.2840 0.0115 21,923.88
04
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Energy 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mobile 2.3409 79.7184 20.6349 0.1922 4.6223 0.3361 4.9584 1.2775 0.3215 1.5990 21,238.40
91
21,238.40
91
2.2719 21,295.20
64
Total 7.1390 80.2394 21.0942 0.1953 4.6223 0.3758 4.9980 1.2775 0.3612 1.6387 21,863.36
64
21,863.36
64
2.2840 0.0115 21,923.88
04
Mitigated Operational
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3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 11/11/2019 11/11/2019 5 1
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Demolition Concrete/Industrial Saws 0 8.00 81 0.73
Demolition Excavators 0 8.00 158 0.38
Demolition Rubber Tired Dozers 0 8.00 247 0.40
Trips and VMT
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 0 0.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 0
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3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated Construction Off-Site
3.1 Mitigation Measures Construction
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4.0 Operational Detail - Mobile
3.2 Demolition - 2019
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction Off-Site
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 2.3409 79.7184 20.6349 0.1922 4.6223 0.3361 4.9584 1.2775 0.3215 1.5990 21,238.40
91
21,238.40
91
2.2719 21,295.20
64
Unmitigated 2.3409 79.7184 20.6349 0.1922 4.6223 0.3361 4.9584 1.2775 0.3215 1.5990 21,238.40
91
21,238.40
91
2.2719 21,295.20
64
4.1 Mitigation Measures Mobile
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Industrial Park 379.69 284.24 140.00 1,679,401 1,679,401
Total 379.69 284.24 140.00 1,679,401 1,679,401
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Industrial Park 16.60 8.40 6.90 100.00 0.00 0.00 79 19 2
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Industrial Park 0.000000 0.000000 0.000000 0.000000 0.085799 0.000000 0.071006 0.843195 0.000000 0.000000 0.000000 0.000000 0.000000
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5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
NaturalGas
Unmitigated
0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
5.1 Mitigation Measures Energy
Historical Energy Use: N
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6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Industrial Park 5311.74 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Total 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Unmitigated
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Industrial Park 5.31174 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Total 0.0573 0.5208 0.4374 3.1200e-
003
0.0396 0.0396 0.0396 0.0396 624.9109 624.9109 0.0120 0.0115 628.6244
Mitigated
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Unmitigated 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.5387 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
4.2000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.0700e-
003
2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Total 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Unmitigated
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8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
0.5387 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
4.2000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 2.0700e-
003
2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Total 4.7408 2.0000e-
004
0.0219 0.0000 8.0000e-
005
8.0000e-
005
8.0000e-
005
8.0000e-
005
0.0464 0.0464 1.3000e-
004
0.0496
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
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11.0 Vegetation
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
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EXHIBIT D
DATE OF NOTICE: January 13, 2020
PUBLIC NOTICE
OF AVAILABILITY OF
DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT
DEVELOPMENT SERVICES DEPARTMENT
SAP No. 24007539
The City of San Diego Development Services Department, as the Lead Agency, has prepared a draft Supplemental
Environmental Impact Report (SEIR) for the following project and is inviting your comments regarding the adequacy
of the document. The draft Environmental Impact Report has been placed on the City of San Diego City Clerk’s
website at https://www.sandiego.gov/ceqa/draft under the heading of “California Environmental Quality Act
(CEQA) Notices & Documents.” In addition, the Notice was also distributed to the Central Library as well as the
Carmel Mountain Ranch Branch Library.
Comments must be received by February 27, 2020, to be included in the final environmental document
considered by the decision-making authorities. Please send your written comments to the following address:
E. Shearer-Nguyen, Environmental Planner, City of San Diego Development Services Center, 101 Ash Street,
Suite 1200, San Diego, CA 92101 or e-mail your comments to DSDEAS@sandiego.gov with the Project Name
and Number in the subject line.
General Project Information:
Project Name: Avion
Project No. 598173 / SCH No. 97111070
Community Plan Area: Black Mountain Ranch
Council District: 5
Subject: A request for a REZONE from AR-1-1 to RS-1-14; VESTING TENTATIVE MAP (VTM); PLANNED
DEVELOPMENT PERMIT (PDP); SITE DEVELOPMENT PERMIT (SDP); MULTI-HABITAT PLANNING AREA BOUNDARY LINE
ADJUSTMENT; and a reorganization consisting of expansion of Olivenhain Municipal Water District's (OMWD’s)
sewer latent powers and annexation to OMWD and the district's sewer service area, to subdivide the project site
and construct 84 multi-family residential, the transfer of 19 affordable units to Lot X of Map No. 15919 in the Black
Mountain Ranch North Village Town Center, and the transfer of 14 market rate dwelling units to Lots 12, 13, 18 and
19 of Map No. 15919 in the Black Mountain Ranch North Village Town Center for a combined total of 117 dwelling
units. The project would also construct various site improvements which include associated public and private
streets, hardscape, retaining walls and landscaping. The project site consists of a 41.48-acre parcel of undeveloped
land located approximately 0.6 mile south of Carmel Valley Road/Bernardo Center Drive, 1.2 miles west of
Interstate 15, and 1.4 miles east of Black Mountain Road. The site is designated Low Density Residential and zoned
AR-1-1 (Agricultural) within the Black Mountain Ranch Subarea Plan. Additionally, the site is within the Airport Land
Use Compatibility Overlay Zone (Marine Corps Air Station [MCAS] Miramar), Airport Influence Area (MCAS-Miramar -
Review Area 2), Affordable Housing Parking Demand, and the Very High Hazard Severity Zone. (LEGAL DESCRIPTION
PARCEL 1: The Southeast quarter of the Southeast quarter of Section 32, Township 13 South, Range 2 West, San
Form Revised 1/2020
Bernardino Base and Meridian, in the City of San Diego, County of San Diego, State of California, except for all crude
oil, petroleum, gas, brea, asphaltium, and all kindred substances and other minerals under and said land, as
reserved in Deed recorded May 30, 1960 as Instrument No. 111628 of Official Records. LEGAL DESCRIPTION
PARCEL 2: Lots 1 and 2 and the Southeast quarter of the Northeast quarter of Section 5, Township 14 South, Range
2 West, San Bernardino Base and Meridian, in the City of San Diego, County of San Diego, State of California, except
for all crude oil, petroleum, gas, brea, asphaltium, and all kindred substances and other minerals under and said
land, as reserved in Deed recorded May 30, 1960 as Instrument No. 111628 of Official Records). The site is not
included on any Government Code listing of hazardous waste sites.
Applicant: Lennar.
Recommended Finding: The draft SEIR concludes that the project would result in significant environmental
impacts to the following areas: Biological Resources, Cultural Resources (Historical Resources/Archaeology),
Visual Quality (Landform Alteration), and Air Quality (Construction).
Availability in Alternative Format: To request this Notice, the draft SEIR, and/or supporting documents in
alternative format, call the Development Services Department at 619-446-5460 or (800) 735-2929 (TEXT
TELEPHONE).
Additional Information: For environmental review information, contact E. Shearer-Nguyen at (619) 446-5369. The
draft SEIR and supporting documents may be reviewed or purchased for the cost of reproduction at the
Development Services Department, located at 101 Ash Street, San Diego CA 92101. For information regarding
public meetings and/or hearings on this project, contact the Project Manager, Jeffrey Peterson, at (619) 446-5237.
This notice was published in the SAN DIEGO DAILY TRANSCRIPT and distributed on January 13, 2020.
Gary Geiler
Deputy Director
Development Services Department
1
SUPPLEMENTAL
ENVIRONMENTAL IMPACT REPORT
Project No. 598173
SCH No. 97111070
SUBJECT: AVION: A request for a REZONE from AR-1-1 to RS-1-14; VESTING TENTATIVE MAP (VTM);
PLANNED DEVELOPMENT PERMIT (PDP); SITE DEVELOPMENT PERMIT (SDP); MULTI-
HABITAT PLANNING AREA BOUNDARY LINE ADJUSTMENT; and a reorganization
consisting of expansion of Olivenhain Municipal Water District's (OMWD’s) sewer latent
powers and annexation to OMWD and the district's sewer service area, to subdivide the
project site and construct 84 multi-family residential, the transfer of 19 affordable units
to Lot X of Map No. 15919 in the Black Mountain Ranch North Village Town Center, and
the transfer of 14 market rate dwelling units to Lots 12, 13, 18 and 19 of Map No. 15919
in the Black Mountain Ranch North Village Town Center for a combined total of 117
dwelling units. The project would also construct various site improvements which
include associated public and private streets, hardscape, retaining walls and
landscaping. The project site consists of a 41.48-acre parcel of undeveloped land located
approximately 0.6 mile south of Carmel Valley Road/Bernardo Center Drive, 1.2 miles
west of Interstate 15, and 1.4 miles east of Black Mountain Road. The site is designated
Low Density Residential and zoned AR-1-1 (Agricultural)) within the Black Mountain
Ranch Subarea Plan. Additionally, the site is within the Airport Land Use Compatibility
Overlay Zone (Marine Corps Air Station (MCAS) Miramar), Airport Influence Area (MCAS-
Miramar - Review Area 2), Affordable Housing Parking Demand, and the Very High
Hazard Severity Zone. (LEGAL DESCRIPTION PARCEL 1: The Southeast quarter of the
Southeast quarter of Section 32, Township 13 South, Range 2 West, San Bernardino Base
and Meridian, in the City of San Diego, County of San Diego, State of California, except
for all crude oil, petroleum, gas, brea, asphaltium, and all kindred substances and other
minerals under and said land, as reserved in Deed recorded May 30, 1960 as Instrument
No. 111628 of Official Records. LEGAL DESCRIPTION PARCEL 2: Lots 1 and 2 and the
Southeast quarter of the Northeast quarter of Section 5, Township 14 South, Range 2
West, San Bernardino Base and Meridian, in the City of San Diego, County of San Diego,
State of California, except for all crude oil, petroleum, gas, brea, asphaltium, and all
kindred substances and other minerals under and said land, as reserved in Deed
recorded May 30, 1960 as Instrument No. 111628 of Official Records). Applicant: Lennar.
2
ENVIRONMENTAL DETERMINATION:
Based on the analysis conducted for the project described above, the City of San Diego has prepared
the following Supplemental Environmental Impact Report (SEIR) in accordance with the California
Environmental Quality Act (CEQA). The analysis conducted identified that the project could result in
significant impacts to the following issue area(s): Biological Resources, Cultural Resources
(Historical Resources/Archaeology), Visual Quality (Landform Alteration), and Air Quality
(Construction).
The purpose of this document is to inform decision-makers, agencies, and the public of the
significant environmental effects that could result if the project is approved and implemented,
identify possible ways to minimize the significant effects, and describe reasonable alternatives to the
project.
PUBLIC REVIEW DISTRIBUTION:
The following agencies, organizations, and individuals received a copy or notice of the draft SEIR and
were invited to comment on its accuracy and sufficiency. Copies of the Draft SEIR, the Mitigation
Monitoring and Reporting Program and any technical appendices may be reviewed in the offices of
the Development Services Department, or purchased for the cost of reproduction.
Federal Government
Commanding General MCAS Miramar Air Station (13)
U.S. Environmental Protection Agency (19)
U.S. Fish and Wildlife (23)
Commanding General MCAS Miramar Air Station (24)
U.S. Army Corps of Engineers (26)
State of California
California Department of Fish and Wildlife (32)
California Department of Toxic Substances Control (39)
California Regional Water Quality Control Board, Region 9 (44)
State Clearinghouse (46A)
California Department of Transportation (51)
California Transportation Commission (51A)
California Transportation Commission (51)
City of San Diego
Mayor’s Office (91)
Councilmember Bry, District 1 (MS 10A)
Councilmember Campbell, District 2 (MS 10A)
Councilmember Ward, District 3 (MS 10A)
Councilmember Montgomery, District 4 (MS 10A)
Councilmember Kersey, District 5 (MS 10A)
Councilmember Cate, District 6 (MS 10A)
Councilmember Sherman, District 7 (MS 10A)
3
City of San Diego - continued
Councilmember Moreno, District 8 (MS 10A)
Councilmember Gomez, District 9 (MS 10A)
Development Services Department
EAS
Transportation
Planning Review
Fire Plan Review
Engineering Review
Geology
Landscaping
PUD-Water and Sewer Development
Project Manager
Planning Department
MSCP
Plan Long Range Planning
Plan-Park and Recreation
Plan-Facilities Financing
San Diego Fire-Rescue Department (MS 603)
San Diego Police Department (MS 776)
Transportation Development (78)
Development Coordination (78A)
Fire and Life Safety Services (79)
San Diego Fire – Rescue Department Logistics (80)
Library Department (81)
Central Library (81A)
Carmel Mountain Ranch Branch Library (81E)
Historical Resources Board (87)
Environmental Services Department (93A)
Facilities Financing (MS 93B)
City Attorney’s Office (93C)
Other Groups, Organizations and Interested Individuals
Rancho Santa Ana Botanic Garden at Claremont (161)
Sierra Club (165)
San Diego Natural History Museum (166)
Mr. Jim Peugh (167A)
San Diego Audubon (167)
California Native Plant Society (170)
Citizens Coordinate for Century III (179)
Endangered Habitats League (182)
Endangered Habitats League (182A)
Carmen Lucas (206)
South Coastal Information Center (210)
San Diego Archaeological Center (212)
Save Our Heritage Organisation (214)
Ron Christman (215)
4
Other Groups, Organizations and Interested Individuals - continued
Clint Linton (215B)
Frank Brown, Inter-Tribal Cultural Resources Council (216)
Campo Band of Mission Indians (217)
San Diego County Archaeological Society, Inc. (218)
Kumeyaay Cultural Heritage Preservation (223)
Kumeyaay Cultural Repatriation Committee (225)
Native American Distribution – Public Notice Only (225A-S)
Black Mountain Ranch – Subarea I (226C)
Joan Mei
Angie Huang
Michael Beckman
Kimberly Uyeda
Alex Plishner, CalAtlantic/Lennar, Applicant
Marina Wurst, Project Design Consultants, Agent
RESULTS OF PUBLIC REVIEW:
( ) No comments were received during the public input period.
( ) Comments were received but did not address the accuracy or completeness of the draft
environmental document. No response is necessary and the letters are incorporated
herein.
( ) Comments addressing the accuracy or completeness of the draft environmental
document were received during the public input period. The letters and responses are
incorporated herein.
January 13, 2020
Gary Geiler Date of Draft Report
Deputy Director
Development Services Department
Date of Final Report
Analyst: Shearer-Nguyen
Draft
Supplemental Environmental Impact
Report for the Avion Project
San Diego, California
Project #598173
SCH #97111070
January 13, 2020
Table of Contents
Avion Project SEIR
i
TABLE OF CONTENTS
List of Abbreviated Terms ....................................................................................... iv
Executive Summary ................................................................................................ S-1
1.0 Introduction .................................................................................................. 1-1
1.1 Project Background .............................................................................................................1 -1
1.2 Project Scope ........................................................................................................................1 -1
1.3 SEIR Purpose Legal Authority .............................................................................................1-2
1.4 SEIR Scope .............................................................................................................................1 -4
1.5 SEIR Public Review Process .................................................................................................1-8
2.0 Environmental Setting ................................................................................. 2-1
2.1 Regional Setting ....................................................................................................................2 -1
2.2 Project Location ....................................................................................................................2 -1
2.3 Physical Environment ..........................................................................................................2 -1
2.4 Planning Context ..................................................................................................................2 -3
3.0 Project Description ...................................................................................... 3-1
3.1 Relationship to the Black Mountain Ranch (Subarea I) Subarea Plan ..........................3-1
3.2 Project Objectives ................................................................................................................3 -2
3.3 Description of Project Components ..................................................................................3-2
3.4 Discretionary Actions ...........................................................................................................3 -5
4.0 History of Project Changes .......................................................................... 4-1
5.0 Environmental Analysis ............................................................................... 5-1
5.1 Land Use ............................................................................................................................ 5.1-1
5.2 Biological Resources ........................................................................................................ 5.2-1
5.3 Cultural/Historical Resources ......................................................................................... 5.3-1
5.4 Landform Alteration/Visual Quality ............................................................................... 5.4-1
5.5 Air Quality .......................................................................................................................... 5.5-1
5.6 Noise .................................................................................................................................. 5.6-1
6.0 Significant Unavoidable Environmental Effects/Irreversible Changes . 6-1
6.1 Significant Environmental Effects Which Cannot Be Avoided if the Project Is
Implemented ........................................................................................................................6 -1
6.2 Irreversible Environmental Changes Which Would Result if the Project Is
Implemented ........................................................................................................................6 -1
7.0 Growth Inducement ..................................................................................... 7-1
8.0 Cumulative Impacts ..................................................................................... 8-1
8.1 Cumulative Effects Found to be Significant ......................................................................8-3
8.2 Cumulative Effects Found Not to be Significant ..............................................................8-3
Table of Contents
Avion Project SEIR
ii
9.0 Black Mountain Ranch (Subarea I) Subarea Plan EIR Subject Areas
Requiring No Change in Analysis ............................................................... 9-1
9.1 Land Use (Plan Consistency) ...............................................................................................9-1
9.2 Traffic/Circulation ................................................................................................................9 -2
9.3 Hydrology and Water Quality .............................................................................................9-2
9.4 Visual Quality ........................................................................................................................9 -4
9.5 Air Quality ..............................................................................................................................9 -5
9.6 Geology and Soils .................................................................................................................9 -5
9.7 Agricultural Resources / Mineral Resources .....................................................................9-6
9.8 Paleontological Resources .................................................................................................9-6
9.9 Noise ......................................................................................................................................9 -6
9.10 Public Facilities and Services .............................................................................................9 -7
9.11 Water Conservation/Domestic Water/Wastewater ...................................................... 9-11
9.12 Public Safety ...................................................................................................................... 9-12
9.13 Population .......................................................................................................................... 9-12
10.0 Project Alternatives ................................................................................... 10-1
10.1 No Project (No Development) Alternative ..................................................................... 10-2
10.2 Reduced Development Footprint Alternative ............................................................... 10-4
10.3 Environmentally Superior Alternative ........................................................................... 10-5
11.0 Mitigation Monitoring and Reporting Program ...................................... 11-1
12.0 References ................................................................................................... 12-1
13.0 Individuals and Agencies Consulted ........................................................ 13-1
FIGURES
2-1: Regional Location ........................................................................................................................2 -6
2-2: Project Location on Aerial Photograph ....................................................................................2-7
3-1: Black Mountain Ranch Subarea I ..............................................................................................3-7
3-2: Black Mountain Ranch Subarea Plan Designations ...............................................................3-8
3-3: Site and Grading Plan .................................................................................................................3 -9
3-4: Landscape Concept Plan ......................................................................................................... 3-10
3-5a: Existing MHPA Boundary ........................................................................................................ 3-11
3-5b: Proposed MHPA Boundary Line Adjustment ....................................................................... 3-12
3-6: Proposed Avion Project MWD Reorganization .................................................................... 3-13
5.1-1: Existing Land Use Designations .......................................................................................... 5.1-17
5.2-1: Existing Biological Resources .............................................................................................. 5.2-21
5.2-2: Location of Primary Subarea Plan Wildlife Corridors ...................................................... 5.2-22
5.2-3: Location of Project Impacts ................................................................................................. 5.2-23
5.2-4: Location of Jurisdictional Waters/Wetland and Wetland Buffer ..................................... 5.2-24
5.6-1: Possible Blasting Locations ................................................................................................. 5.6-11
5.6-2: Adjacent MHPA ...................................................................................................................... 5.6-12
8-1: Location of Cumulative Projects ...............................................................................................8 -6
Table of Contents
Avion Project SEIR
iii
TABLES
S-1: Summary of Significant Environmental Impacts and Mitigation Measures .............................. S-6
1-1: Impact Assessment Summary 1998 EIR .........................................................................................1-5
3-1: Total Project Square Footage ...........................................................................................................3-3
5.1-1: Summary of Proposed MHPA Boundary Line Adjustment ...................................................... 5.1-8
5.2-1: Survey Dates, Times, and Weather Conditions ......................................................................... 5.2-1
5.2-2: Existing Vegetation Communities and Land Cover Types ........................................................ 5.2-2
5.2-3: Jurisdictional Waters ..................................................................................................................... 5.2-6
5.2-4: Impacts to Vegetation Communities and Land Cover Types ................................................. 5.2-10
5.2-5: Mitigation Requirement for Sensitive Vegetation Communities ........................................... 5.2-13
5.5-1: Ambient Air Quality Standards .................................................................................................... 5.5-3
5.5-2: Air Quality Impact Analysis Trigger Levels................................................................................ 5.5-10
5.5-3: Summary of Worst-case Construction Emissions ................................................................... 5.5-11
5.5-4: SDAPCD CEQA Toxic Air Contaminant Emissions Thresholds ............................................... 5.5-12
5.6-1: Predicted Hydraulic Hammering Vibration Levels .................................................................... 5.6-6
5.6-2: Predicted Blasting Vibration Levels by Charge Weight ............................................................. 5.6-8
8-1: Cumulative Projects ...........................................................................................................................8-2
10-1: Comparison of Project and Alternatives Impacts Summary ..................................................... 10-2
APPENDICES
A: Notice of Preparation and Comments
B: Biological Technical Report (RECON, January 2020)
C-1: Historical Resources Survey Report (RECON, June 2019)
C-2: Results of the Cultural Resources Testing Program for CA-SDI-18,428 and CA-SDI-18,429
(RECON, August 2019)
D: Air Quality Analysis (RECON, November 2019)
E: Noise Analysis (RECON, November 2019)
F: Traffic Memo (KOA, June 2019)
G: Waste Management Plan (RECON, July 2019)
List of Abbreviated Terms
Avion Project SEIR
iv
LIST OF ABBREVIATED TERMS
1998 EIR Black Mountain Ranch (Subarea I) Subarea Plan Environmental Impact Report
ADD Assistant Deputy Director
AME Archaeological Monitoring Exhibit
ASMD area-specific management directives
BCME Biological Construction Mitigation/Monitoring Exhibit
BI Building Inspector
BLA Boundary Line Adjustment
BMP Best Management Practices
BMR Black Mountain Ranch
BMZ Brush Management Zone
CAA Clean Air Act
CAAQS California Ambient Air Quality Standards
CalEEMod California Emissions Estimator Model
CARB California Air Resources Board
CCR California Code of Regulations
CD Construction Documents
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
cfs cubic feet per second
City City of San Diego
CM Construction Manager
CNDDB California Natural Diversity Database
CNEL Community Noise Equivalent Level
CNPS California Native Plant Society
CO Carbon monoxide
CRHR California Register of Historic Resources
CSVR Consultant Site Visit Record
dB(A) A-weighted decibel
DPM diesel particulate matter
DSD Development Services Department
EAS Environmental Analysis Section
ED Environmental Designee
EIR Environmental Impact Report
ESA Endangered Species Act
ESL Environmentally Sensitive Lands
FEIR Final Environmental Impact Report
FHWA Federal Highway Administration
FMZ Fuel Modification Zone
FTA Federal Transit Authority
GHG Greenhouse gas
HCP Habitat Conservation Plan
HRA health risk assessment
HRG Historical Resources Guidelines
Hz Hertz
in/sec Inches per second
ITP Incidental Take Permit
LAFCO Local Area Formation Commission
LDC Land Development Code
Leq average equivalent sound level
List of Abbreviated Terms
Avion Project SEIR
v
Lpw sound power
MHPA Multi-Habitat Planning Area
MLD Most Likely Descendent
MMC Mitigation Monitoring Coordinator
MMRP Mitigation Monitoring and Reporting Program
MRZ Mineral Resource Zone
MSCP Multiple Species Conservation Program
NAAQS National Ambient Air Quality Standards
NAHC Native American Heritage Commission
NCCP Natural Community Conservation Planning
NCFUA North City Future Urbanizing Area
NO2 Nitrogen dioxide
NOP Notice of Preparation
NOx Oxides of nitrogen
NRHP National Register of Historic Places
NTP Notice to Proceed
O3 Ozone
OEHHA Office of Environmental Health Hazard Assessment
OMWD Olivenhain Municipal Water District
Pb Lead
PDP Planned Development Permit
PFFP Public Facilities Financing Plan
PI Principal Investigator
PM10 Particulate matter less than 10 microns in diameter
PM2.5 Particulate matter less than 2.5 microns in diameter
PPV peak particle velocity
PRC Public Resources Code
project Avion Project
RAQS Regional Air Quality Strategy
RE Resident Engineer
ROG Reactive organic gases
RPO Resource Protection Ordinance
SANDAG San Diego Association of Governments
SCIC South Coastal Information Center at San Diego State University
SDAB San Diego Air Basin
SDAPCD San Diego County Air Pollution Control District
SDP Site Development Permit
SEIR Supplemental Environmental Impact Report
SIP State Implementation Plan
SO2 Sulfur dioxide
SOI sphere of influence
SOx Oxides of sulfur
TCM Transportation Control Measures
U.S. EPA United States Environmental Protection Agency
U.S.C. United States Code
USACE United States Army Corps of Engineers
USFWS United States Fish and Wildlife Service
VOC Volatile organic compounds
VTM Vesting Tentative Map
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Page S-1
Executive Summary
This Supplemental Environmental Impact Report (SEIR) has been prepared for the Avion Project
(project). This document analyzes the potential environmental effects associated with
implementation of the project. The SEIR was prepared under the direction of the City of San Diego’s
(City’s) Environmental Analysis Section and reflects the independent judgment of the City as lead
agency pursuant to the California Environmental Quality Act (CEQA) (California Public Resources
Code (PRC), Section 21000 et seq.) and the CEQA Guidelines (14 California Code of Regulations [CCR]
15000 et seq.). This SEIR was prepared to evaluate the environmental effects of the project.
S.1 Project Synopsis
This summary provides a brief synopsis of: (1) the project, (2) the results of the environmental
analysis contained within this SEIR, (3) the alternative to the project that was considered, and (4) the
major areas of controversy and issues to be resolved by decision makers. This summary does not
contain the extensive background and analysis found in the document. Therefore, the reader should
review the entire document to fully understand the project and its environmental consequences.
S.1.1 Project Location and Setting
The project site consists of a 41.48-acre parcel of undeveloped land located approximately 0.6 mile
south of Carmel Valley Road/Bernardo Center Drive, 1.2 miles west of Interstate 15, and 1.4 miles
east of Black Mountain Road.
Topographically, the project site is located at the upper end of a broad north-south trending valley. A
ridgeline occurs in the central portion of the site that rises in elevation from north to south from
740 feet mean sea level to 915 feet mean sea level. The project site is located in a developing area
that consists primarily of residential development and open space. Land uses surrounding the
project site include a portion of the Black Mountain Open Space Park to the west, east, and south,
the Heritage Bluffs residential development to the north, and additional Black Mountain Open Space
Park open space lands to the northwest.
S.1.2 Project Description
In July of 1998, the City adopted the Black Mountain Ranch (Subarea I) Subarea Plan in the former
North City Future Urbanizing Area (NCFUA) and certified the Final Environmental Impact Report
(FEIR; Land Development Review No. 96-7902, SCH No. 97111070). The Subarea Plan identifies
several perimeter properties, which were originally held by 11 different ownerships. The Avion
project site is within the area of the Subarea Plan referred to as the “Southeast Perimeter”
properties, which are composed of four parcels (A, B, C, and D). The project site consists of Parcel C,
totaling 41.48 acres. The 1998 Subarea Plan Environmental Impact Report (EIR) provides analysis for
the project site, based on these general development parameters, but because no specific project
design was known or proposed at the time the 1998 EIR was certified, the analysis of certain impacts
for the site was only done at a “program level.” The 1998 EIR acknowledges that future site-specific
S.0 Executive Summary
Avion Project SEIR
Page S-2
CEQA analysis would be required for areas outside of the Black Mountain Ranch Vesting Tentative
Map II project area.
Discretionary actions are those actions taken by an agency that call for the exercise of judgment in
deciding whether to approve or how to carry out a project. For the project, the following
discretionary actions are required and are further described below:
• Vesting Tentative Map (VTM)
• Rezone
• Planned Development Permit (PDP)
• Site Development Permit (SDP)
• Multi-Habitat Planning Area (MHPA) Boundary Line Adjustments
• A reorganization consisting of latent powers expansion for sewer service for Olivenhain
Municipal Water District (OMWD) and annexation to OMWD's sewer service area (Local Area
Formation Commission)
A VTM is required for the project to subdivide the property into one residential lot with 84 detached
multi-family units and two open space (MHPA) lots to be dedicated in fee to the City. The VTM details
the specific grading and necessary infrastructure. The site is currently zoned as AR-1-1 (Agricultural –
Residential, minimum 10-acre lots). Under the project, the site would be rezoned to RS-1-14
(Residential Single Unit, minimum 5,000-square-foot lots).
The project includes a PDP to allow for development of detached multi-family residential units
rather than single-family residential units, and a deviation to exceed the maximum retaining wall
height outside of required setbacks. The project includes a SDP due to impacts to Environmentally
Sensitive Lands (ESL; i.e., steep slopes and sensitive biological resources). The project also proposes
a MHPA boundary line adjustment to preserve 4.99 acres of southern mixed chaparral, 0.49 acre of
non-native grassland, and 0.13 acre of coastal sage scrub.
S.1.3 Project Objectives
In accordance with CEQA Guidelines Section 15124, the following primary objectives support the
purpose of the project, assist the Lead Agency in developing a reasonable range of alternatives to be
evaluated in this report, and ultimately aid decision-makers in preparing findings and overriding
considerations, if necessary. The specific goals and objectives for the project are:
• Provide residential development that is consistent with the location and the goals and
objectives of the adopted Black Mountain Ranch Subarea Plan.
• Provide new residential development, which is consistent with existing residential
development patterns in the surrounding area.
• Implement “smart growth” principles of development through the provision of new
residences within a complete master planned community.
• Implement sustainable development principles through the provision of a community of
new residences with many energy-efficient features.
• Provide infrastructure improvements consistent with the Subarea Plan.
S.0 Executive Summary
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Page S-3
S.2 Summary of Significant Effects and Mitigation
Measures that Reduce or Avoid the
Significant Effects
Table S-1 summarizes the significant impacts identified through the environmental analysis
completed for the project. Table S-1 also identifies the mitigation measures that would reduce
and/or avoid the environmental effects as feasible, with a conclusion as to whether the impact
would be mitigated to below a level of significance or if impacts would remain significant and
unavoidable. Further discussion of potential and anticipated environmental impacts is detailed in
Chapter 5.0.
S.3 Areas of Controversy
Pursuant to CEQA Section 15123(b)(2), an EIR shall identify areas of controversy known to the lead
agency, including issues raised by the agencies, and the public, and issues to be resolved. The Notice
of Preparation (NOP) for the SEIR was distributed on May 24, 2019, for a 30-day public review and
comment period. No areas of controversy were raised in the comment letters received on the NOP
or during the scoping meeting. The NOP and comment letters received are included in this SEIR as
Appendix A.
S.4 Issues to be Resolved by the Decision-Making
Body
The issues to be resolved by the decision-making body (in this case the City Council) are whether:
(1) the significant impacts associated with land use, biological resources, cultural resources, and air
quality would be fully mitigated to below a level of significance, (2) to approve the proposed
alternative instead of the project, and how (3) to reduce significant and unavoidable environmental
impacts to the maximum extent feasible while achieving project objectives through adoption of
mitigation measures and/or the project alternative identified in this EIR. Furthermore, a Statement
of Overriding Considerations pursuant to CEQA Guidelines Section 15093 would be required for
those impacts found to be significant and unavoidable as identified in the EIR.
S.5 Project Alternatives
The CEQA Guidelines Section 15126.6 requires that an EIR compare the effects of a “reasonable
range of alternatives” to the effects of a project. The alternatives selected for comparison should be
those that would attain most of the basic project objectives and avoid or substantially lessen one or
more significant effects of the project. The “range of alternatives” is governed by the “rule of reason,”
which requires the EIR to set forth only those alternatives necessary to permit an informed and
reasoned choice by the lead agency and to foster meaningful public participation (CEQA Guidelines
Section 15126.6[f]). CEQA generally defines “feasible” to mean an alternative that is capable of being
S.0 Executive Summary
Avion Project SEIR
Page S-4
accomplished in a successful manner within a reasonable period of time while also taking into
account economic, environmental, social, technological, and legal factors.
The EIR addresses one alternative in addition to the “no project” alternative, required under CEQA.
Alternatives to the project are evaluated in full detail in Chapter 10 of this document.
S.5.1 No Project (No Development) Alternative
The No Project (No Development) Alternative would maintain the project site in its current condition.
This alternative would preserve the existing environmental setting, and would thereby eliminate all
of the project’s impacts. However, the No Project (No Development) Alternative would not provide
any of the project’s benefits, including residential development and affordable housing consistent
with the adopted Subarea Plan and expansion of the MHPA through a boundary line adjustment
that would result in a net increase of 5.06 acres. These benefits would be foregone under this
alternative. Furthermore, the No Project (No Development) Alternative would not meet any of the
project objectives listed in Section S.1.3 above.
S.5.2 Reduced Development Footprint Alternative
The Reduced Development Footprint Alternative would reduce the grading footprint compared to
the project. Under this alternative, the project would develop 117 residential units consistent with
the amount anticipated for the project site in the Black Mountain Ranch (Subarea I) Subarea Plan by
constructing attached multi-family structures with an increased density compared to the project.
The Reduced Development Footprint Alternative would incrementally reduce all of the project’s
significant impacts due to the smaller grading footprint. This alternative would avoid impacts to the
MHPA and would not require a boundary line adjustment. Similarly, the smaller project footprint
would reduce impacts to sensitive vegetation communities and reduce impacts on landform
alteration. However, the increased density associated with this alternative would not be consistent
with the character of the single-family and detached multi-family residential units surrounding the
project site. Similarly, the increased density would require a height deviation to accommodate
development of 117 units within the reduced grading footprint. Furthermore, the Reduced
Development Footprint Alternative would lessen impacts on biological resources because the
project would actually increase land within the MHPA through the proposed boundary line
adjustment and would successfully mitigate impacts to sensitive vegetation communities to a level
less than significant.
S.5.3 Environmentally Superior Alternative
CEQA Guidelines Section 15126.6(e)(2) requires the identification of an environmentally superior
alternative among the alternatives analyzed in an EIR. The guidelines also require that if the No
Project Alternative is the environmentally superior alternative, then another environmentally
superior alternative must be identified.
S.0 Executive Summary
Avion Project SEIR
Page S-5
The Reduced Development Footprint Alternative would be considered the environmentally superior
alternative. This alternative would avoid impacts to the MHPA and would not require a boundary line
adjustment. Similarly, the smaller project footprint would reduce impacts to sensitive vegetation
communities and reduce impacts on landform alteration. Although the increased density and
introduction of attached multi-family residential units that would occur under this alternative would
not be consistent with the character of the single-family and detached multi-family residential units
surrounding the project site, it would be considered environmentally superior to the project due to
the reduction in grading and biological impacts.
Avion Project SEIR
Page S-6
Table S-1
Summary of Significant Environmental Impacts and Mitigation Measures
Environmental Issue Impacts Mitigation
Impact Level
After
Mitigation
Biological Resources
Would the project result in
a substantial adverse
impact on any Tier I
habitats, Tier II habitats,
Tier IIIA habitats, or
Tier IIIB habitats as
identified in the Biology
Guidelines of the Land
Development manual or
other sensitive natural
community identified in
local or regional plans,
policies, regulations, or by
the California Department
of Fish and Wildlife (CDFW)
or U.S. Fish and Wildlife
Service (USFWS)?
Vegetation Communities
Impact BIO-1: Impacts to coastal sage scrub,
southern mixed chaparral, and non-native
grassland would be significant.
MM-BIO-1: Upland Vegetation Communities
Mitigation for impacts to coastal sage scrub (Tier II
habitat), southern mixed chaparral (Tier IIIA
habitat), and non-native grassland (Tier IIIB
habitat) communities would be achieved through
the preservation of habitat on the site located
outside of the development area. Prior to
issuance of any construction permits, including
but not limited to, the first Grading Permit,
Demolition Plans/Permits and Building
Plans/Permits, the project would demonstrate to
the satisfaction of the City that impacts to a total
of 15.2 acres of sensitive vegetation would be
mitigated by the on-site preservation of
24.03 acres of sensitive vegetation as summarized
by habitat type in Table 5.2-5. The preserved
habitat areas on the site would all be within the
boundaries of the MHPA Boundary Line
Adjustment (BLA) dedicated to the City in fee title.
Acceptance of land dedicated in fee title is subject
to approval by the City’s Park and Recreation
Open Space.
Less Than
Significant
Would the project result in
substantial adverse
impacts, either directly or
through habitat
modifications, to any
species identified as a
Sensitive Wildlife
Impact BIO-2: Impacts to Cooper’s hawk
and/or rufous-crowned sparrow would be
significant.
MM-BIO-2: Standard City Construction
Measures
Prior to issuance of any construction permits,
including but not limited to, the first Grading
Permit, Demolition Plans/Permits and Building
Plans/Permits, mitigation for general impacts to
Less Than
Significant
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Page S-7
Table S-1
Summary of Significant Environmental Impacts and Mitigation Measures
Environmental Issue Impacts Mitigation
Impact Level
After
Mitigation
candidate, sensitive or
special status species in
the Multiple Species
Conservation Program
(MSCP) or other local or
regional plans, policies, or
regulations, or by the
CDFW or USFWS?
biological resources would be incorporated via
standard measures including general mitigation
measures, biological protections during
construction, (includes monitoring,
preconstruction meetings, and development of a
Biological Condition Monitoring Exhibit, etc.) as
described below. These biological resources
protection requirements shall be depicted on the
construction documents verbatim and
implemented accordingly.
Biological Resource Protection During
Construction
I. Prior to Construction
A. Biologist Verification - The
owner/permittee shall provide a letter to
the City’s Mitigation Monitoring
Coordination (MMC) section stating that a
Project Biologist (Qualified Biologist) as
defined in the City’s Biological Guidelines
(2012), has been retained to implement
the project’s biological monitoring
program. The letter shall include the
names and contact information of all
persons involved in the biological
monitoring of the project.
Avion Project SEIR
Page S-8
Table S-1
Summary of Significant Environmental Impacts and Mitigation Measures
Environmental Issue Impacts Mitigation
Impact Level
After
Mitigation
B. Preconstruction Meeting - The Qualified
Biologist shall attend the preconstruction
meeting, discuss the project’s biological
monitoring program, and arrange to
perform any follow up mitigation
measures and reporting including site-
specific monitoring, restoration or
revegetation, and additional fauna/flora
surveys/salvage.
C. Biological Documents - The Qualified
Biologist shall submit all required
documentation to MMC verifying that any
special mitigation reports including but
not limited to, maps, plans, surveys,
survey timelines, or buffers are
completed or scheduled per the City’s
Biology Guidelines, MSCP, ESL Ordinance,
project permit conditions; CEQA;
endangered species acts (ESAs); and/or
other local, state, or federal requirements.
D. Biological Construction Mitigation/
Monitoring Exhibit (BCME) - The
Qualified Biologist shall present a BCME,
which includes the biological documents
in “C” above. In addition, include:
restoration/revegetation plans, plant
salvage/relocation requirements (e.g.,
coastal cactus wren plant salvage,
burrowing owl exclusions, etc.), avian or
Avion Project SEIR
Page S-9
Table S-1
Summary of Significant Environmental Impacts and Mitigation Measures
Environmental Issue Impacts Mitigation
Impact Level
After
Mitigation
other wildlife surveys/survey schedules
(including USFWS protocol), timing of
surveys, wetland buffers, other impact
avoidance areas, and any subsequent
requirements determined by the Qualified
Biologist and the City Assistant Deputy
Director (ADD)/MMC. The BCME shall
include a site plan, written and graphic
depiction of the project’s biological
mitigation/monitoring program, and a
schedule. The BCME shall be approved by
MMC and referenced in the construction
documents.
E. Avian Protection Requirements - To
avoid any direct impacts to Cooper’s
hawk, rufous-crowned sparrow, and
coastal California gnatcatcher or any
species identified as listed, candidate,
sensitive, or special status in the MSCP,
removal of habitat that supports active
nests in the proposed area of disturbance
should occur outside of the breeding
season for these species (February 1 to
September 15). If removal of habitat in
the proposed area of disturbance must
occur during the breeding season, the
Qualified Biologist shall conduct a
preconstruction survey to determine the
presence or absence of nesting for these
three sensitive bird species on the
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Page S-10
Table S-1
Summary of Significant Environmental Impacts and Mitigation Measures
Environmental Issue Impacts Mitigation
Impact Level
After
Mitigation
proposed area of disturbance. The
preconstruction survey shall be conducted
within 10 calendar days prior to the start
of construction activities (including
removal of vegetation). The applicant
shall submit the results of the
preconstruction survey to the City’s
Development Services Department (DSD)
for review and approval prior to initiating
any construction activities. If nesting
activities for any of the above-mentioned
sensitive bird species are detected, a
letter report or mitigation plan in
conformance with the City’s Biology
Guidelines and applicable state and
federal law (i.e., appropriate follow up
surveys, monitoring schedules,
construction and noise barriers/buffers,
etc.) shall be prepared and include
proposed measures to be implemented to
ensure that take of birds or eggs or
disturbance of breeding activities is
avoided. The report or mitigation plan
shall be submitted to the City for review
and approval and implemented to the
satisfaction of the City. The City’s MMC
Section or Resident Engineer, and
Biologist shall verify and approve that all
measures identified in the report or
mitigation plan are in place prior to
and/or during construction.
Avion Project SEIR
Page S-11
Table S-1
Summary of Significant Environmental Impacts and Mitigation Measures
Environmental Issue Impacts Mitigation
Impact Level
After
Mitigation
F. Resource Delineation - Prior to
construction activities, the Qualified
Biologist shall supervise the placement of
orange construction fencing or equivalent
along the limits of disturbance adjacent to
sensitive biological habitats and verify
compliance with any other project
conditions as shown on the BCME. This
phase shall include flagging plant
specimens and delimiting buffers to
protect sensitive biological resources (e.g.,
habitats/flora and fauna species, including
nesting Cooper’s hawk, rufous-crowned
sparrow, and coastal California
gnatcatcher) during construction.
Appropriate steps/care should be taken to
minimize attraction of nest predators to
the site.
G. Education – Prior to commencement of
construction activities, the Qualified
Biologist shall meet with the
owner/permittee or designee and the
construction crew and conduct an on-site
educational session regarding the need to
avoid impacts outside of the approved
construction area and to protect sensitive
flora and fauna (e.g., explain the avian
and wetland buffers, flag system for
removal of invasive species or retention
Avion Project SEIR
Page S-12
Table S-1
Summary of Significant Environmental Impacts and Mitigation Measures
Environmental Issue Impacts Mitigation
Impact Level
After
Mitigation
of sensitive plants, and clarify acceptable
access routes/methods and staging areas,
etc.).
II. During Construction
A. Monitoring – All construction (including
access/staging areas) shall be restricted to
areas previously identified, proposed for
development/staging, or previously
disturbed as shown on “Exhibit A” and/or
the BCME. The Qualified Biologist shall
monitor construction activities as needed
to ensure that construction activities do
not encroach into biologically sensitive
areas, or cause other similar damage, and
that the work plan has been amended to
accommodate any sensitive species
located during the preconstruction
surveys. In addition, the Qualified
Biologist shall document field activity via
the Consultant Site Visit Record (CSVR).
The CSVR shall be e-mailed to the MMC
on the first day of monitoring, the first
week of each month, the last day of
monitoring, and immediately in the case
of any undocumented condition or
discovery.
B. Subsequent Resource Identification –
The Qualified Biologist shall note/act to
prevent any new disturbances to habitat,
flora, and/or fauna on-site (e.g., flag plant
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specimens for avoidance during access,
etc.). If active nests for Cooper’s hawk,
rufous-crowned sparrow, and coastal
California gnatcatcher, or other previously
unknown sensitive resources are
detected, all project activities that directly
impact the resource shall be delayed until
species specific to local, state, or federal
regulations have been determined and
applied by the Qualified Biologist.
III. Post Construction Measures
A. In the event that impacts exceed
previously allowed amounts, additional
impacts shall be mitigated in accordance
with City Biology Guidelines, ESL and
MSCP, CEQA, and other applicable local,
state and federal law. The Qualified
Biologist shall submit a final BCME/report
to the satisfaction of the City ADD/MMC
within 30 days of construction completion.
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Cultural/Historical Resources
Would the project result in
an alteration, including the
adverse physical or
aesthetic effects and/or
the destruction of a
prehistoric or historic
building (including an
architecturally significant
building), structure, or
object or site?
Historic Resources
Impact HIST-1: Unearthing of subsurface
deposits associated with HJP-3 during project
construction would have the potential to
result in a significant impact.
MM-HIST-1: Archaeological Monitoring
I. Prior to Permit Issuance
A. Entitlements Plan Check
1. Prior to issuance of any
construction permits, including but
not limited to, the first Grading
Permit, Demolition Plans/Permits
and Building Plans/Permits or a
Notice to Proceed for Subdivisions,
but prior to the first preconstruction
meeting, whichever is applicable,
the Assistant Deputy Director (ADD)
Environmental designee shall verify
that the requirements for
Archaeological Monitoring and
Native American monitoring have
been noted on the applicable
construction documents through
the plan check process.
Less Than
Significant
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B. Letters of Qualification have been
submitted to ADD
1. The applicant shall submit a letter of
verification to Mitigation Monitoring
Coordination (MMC) identifying the
Principal Investigator (PI) for the
project and the names of all
persons involved in the
archaeological monitoring program,
as defined in the City of San Diego
Historical Resources Guidelines
(HRG). If applicable, individuals
involved in the archaeological
monitoring program must have
completed the 40-hour HAZWOPER
training with certification
documentation.
2. MMC will provide a letter to the
applicant confirming the
qualifications of the PI and all
persons involved in the
archaeological monitoring of the
project meet the qualifications
established in the HRG.
3. Prior to the start of work, the
applicant must obtain written
approval from MMC for any
personnel changes associated with
the monitoring program.
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II. Prior to Start of Construction
A. Verification of Records Search
1. The PI shall provide verification to
MMC that a site specific records
search (1/4 mile radius) has been
completed. Verification includes,
but is not limited to a copy of a
confirmation letter from South
Coastal Information Center, or, if
the search was in-house, a letter of
verification from the PI stating that
the search was completed.
2. The letter shall introduce any
pertinent information concerning
expectations and probabilities of
discovery during trenching and/or
grading activities.
3. The PI may submit a detailed letter
to MMC requesting a reduction to
the ¼ mile radius.
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B. PI Shall Attend Precon Meetings
1. Prior to beginning any work that
requires monitoring; the Applicant
shall arrange a Precon Meeting that
shall include the PI, Native American
consultant/monitor (where Native
American resources may be
impacted), Construction Manager
(CM) and/or Grading Contractor,
Resident Engineer (RE), Building
Inspector (BI), if appropriate, and
MMC. The qualified Archaeologist
and Native American Monitor shall
attend any grading/excavation
related Precon Meetings to make
comments and/or suggestions
concerning the Archaeological
Monitoring program with the
Construction Manager and/or
Grading Contractor.
a. If the PI is unable to attend the
Precon Meeting, the Applicant
shall schedule a focused Precon
Meeting with MMC, the PI, RE,
CM or BI, if appropriate, prior to
the start of any work that
requires monitoring.
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2. Identify Areas to be Monitored
a. Prior to the start of any work
that requires monitoring, the PI
shall submit an Archaeological
Monitoring Exhibit (AME) (with
verification that the AME has
been reviewed and approved by
the Native American
consultant/monitor when Native
American resources may be
impacted) based on the
appropriate construction
documents (reduced to 11x17)
to MMC identifying the areas to
be monitored including the
delineation of grading/
excavation limits.
b. The AME shall be based on the
results of a site specific records
search as well as information
regarding existing known soil
conditions (native or formation).
3. When Monitoring Will Occur
a. Prior to the start of any work,
the PI shall also submit a
construction schedule to MMC
through the RE indicating when
and where monitoring will
occur.
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b. The PI may submit a detailed
letter to MMC prior to the start
of work or during construction
requesting a modification to the
monitoring program. This
request shall be based on
relevant information such as
review of final construction
documents which indicate site
conditions such as depth of
excavation and/or site graded to
bedrock, etc., which may reduce
or increase the potential for
resources to be present.
III. During Construction
A. Monitor(s) Shall be Present During
Grading/Excavation/Trenching
1. The Archaeological Monitor shall
be present full-time during all
soil disturbing and grading/
excavation/trenching activities
which could result in impacts to
archaeological resources
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as identified on the AME. The
Construction Manager is
responsible for notifying the RE, PI,
and MMC of changes to any
construction activities such as in the
case of a potential safety concern
within the area being monitored. In
certain circumstances OSHA safety
requirements may necessitate
modification of the AME.
2. The Native American consultant/
monitor shall determine the extent
of their presence during soil
disturbing and grading/
excavation/trenching activities
based on the AME and provide that
information to the PI and MMC. If
prehistoric resources are
encountered during the Native
American consultant/monitor’s
absence, work shall stop and the
Discovery Notification Process
detailed in Section III.B-C and IV.A-D
shall commence.
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3. The PI may submit a detailed letter
to MMC during construction
requesting a modification to the
monitoring program when a field
condition such as modern
disturbance post-dating the
previous grading/trenching
activities, presence of fossil
formations, or when native soils are
encountered that may reduce or
increase the potential for resources
to be present.
4. The archaeological and Native
American consultant/monitor shall
document field activity via the
Consultant Site Visit Record (CSVR).
The CSVR’s shall be faxed by the CM
to the RE the first day of monitoring,
the last day of monitoring, monthly
(Notification of Monitoring
Completion), and in the case of ANY
discoveries. The RE shall forward
copies to MMC.
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B. Discovery Notification Process
1. In the event of a discovery, the
Archaeological Monitor shall direct
the contractor to temporarily divert
all soil disturbing activities, including
but not limited to digging, trenching,
excavating or grading activities in
the area of discovery and in the
area reasonably suspected to
overlay adjacent resources and
immediately notify the RE or BI, as
appropriate.
2. The Monitor shall immediately
notify the PI (unless Monitor is the
PI) of the discovery.
3. The PI shall immediately notify MMC
by phone of the discovery, and shall
also submit written documentation
to MMC within 24 hours by fax or
email with photos of the resource in
context, if possible.
4. No soil shall be exported off-site
until a determination can be made
regarding the significance of the
resource specifically if Native
American resources are
encountered.
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C. Determination of Significance
1. The PI and Native American
consultant/monitor, where Native
American resources are discovered
shall evaluate the significance of the
resource. If Human Remains are
involved, follow protocol in
Section IV below.
a. The PI shall immediately notify
MMC by phone to discuss
significance determination and
shall also submit a letter to
MMC indicating whether
additional mitigation is required.
b. If the resource is significant, the
PI shall submit an
Archaeological Data Recovery
Program (ADRP) which has been
reviewed by the Native
American consultant/monitor,
and obtain written approval
from MMC. Impacts to
significant resources must be
mitigated before ground
disturbing activities in the area
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of discovery will be allowed to
resume. Note: If a unique
archaeological site is also an
historical resource as defined in
CEQA, then the limits on the
amount(s) that a project
applicant may be required to
pay to cover mitigation costs as
indicated in CEQA Section
21083.2 shall not apply.
c. If the resource is not significant,
the PI shall submit a letter to
MMC indicating that artifacts will
be collected, curated, and
documented in the Final
Monitoring Report. The letter
shall also indicate that that no
further work is required.
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IV. Discovery of Human Remains
If human remains are discovered, work
shall halt in that area and no soil shall
be exported off-site until a
determination can be made regarding
the provenance of the human remains;
and the following procedures as set
forth in CEQA Section 15064.5(e), the
California Public Resources Code (Sec.
5097.98) and State Health and Safety
Code (Sec. 7050.5) shall be undertaken:
A. Notification
1. Archaeological Monitor shall notify
the RE or BI as appropriate, MMC,
and the PI, if the Monitor is not
qualified as a PI. MMC will notify the
appropriate Senior Planner in the
Environmental Analysis Section
(EAS) of the Development Services
Department to assist with the
discovery notification process.
2. The PI shall notify the Medical
Examiner after consultation with the
RE, either in person or via
telephone.
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B. Isolate discovery site
1. Work shall be directed away from
the location of the discovery and
any nearby area reasonably
suspected to overlay adjacent
human remains until a
determination can be made by the
Medical Examiner in consultation
with the PI concerning the
provenance of the remains.
2. The Medical Examiner, in
consultation with the PI, will
determine the need for a field
examination to determine the
provenance.
3. If a field examination is not
warranted, the Medical Examiner
will determine with input from the
PI, if the remains are or are most
likely to be of Native American
origin.
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C. If Human Remains ARE determined to
be Native American
1. The Medical Examiner will notify the
Native American Heritage
Commission (NAHC) within 24
hours. By law, ONLY the Medical
Examiner can make this call.
2. NAHC will immediately identify the
person or persons determined to be
the Most Likely Descendent (MLD)
and provide contact information.
3. The MLD will contact the PI within
24 hours or sooner after the
Medical Examiner has completed
coordination, to begin the
consultation process in accordance
with CEQA Section 15064.5(e), the
California Public Resources and
Health & Safety Codes.
4. The MLD will have 48 hours to make
recommendations to the property
owner or representative, for the
treatment or disposition with
proper dignity, of the human
remains and associated grave
goods.
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5. Disposition of Native American
Human Remains will be determined
between the MLD and the PI, and, if:
a. The NAHC is unable to identify
the MLD, OR the MLD failed to
make a recommendation within
48 hours after being granted
access to the site, OR;
b. The landowner or authorized
representative rejects the
recommendation of the MLD
and mediation in accordance
with PRC 5097.94 (k) by the
NAHC fails to provide measures
acceptable to the landowner,
the landowner shall reinter the
human remains and items
associated with Native American
human remains with
appropriate dignity on the
property in a location not
subject to further and future
subsurface disturbance, THEN
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c. To protect these sites, the
landowner shall do one or more
of the following:
(1) Record the site with the
NAHC;
(2) Record an open space or
conservation easement; or
(3) Record a document with the
County. The document shall
be titled “Notice of
Reinterment of Native
American Remains” and
shall include a legal
description of the property,
the name of the property
owner, and the owner’s
acknowledged signature, in
addition to any other
information required by PRC
5097.98. The document shall
be indexed as a notice
under the name of the
owner.
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d. Upon the discovery of multiple
Native American human
remains during a ground
disturbing land development
activity, the landowner may
agree that additional conferral
with descendants is necessary
to consider culturally
appropriate treatment of
multiple Native American
human remains. Culturally
appropriate treatment of such a
discovery may be ascertained
from review of the site utilizing
cultural and archaeological
standards. Where the parties
are unable to agree on the
appropriate treatment
measures the human remains
and items associated and buried
with Native American human
remains shall be reinterred with
appropriate dignity, pursuant to
Section 5.c., above.
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D. If Human Remains are NOT Native
American
1. The PI shall contact the Medical
Examiner and notify them of the
historic era context of the burial.
2. The Medical Examiner will
determine the appropriate course
of action with the PI and City staff
(PRC 5097.98).
3. If the remains are of historic origin,
they shall be appropriately removed
and conveyed to the San Diego
Museum of Man for analysis. The
decision for internment of the
human remains shall be made in
consultation with MMC, EAS, the
applicant/landowner, any known
descendant group, and the San
Diego Museum of Man.
V. Night and/or Weekend Work
A. If night and/or weekend work is included
in the contract
1. When night and/or weekend work is
included in the contract package,
the extent and timing shall be
presented and discussed at the
precon meeting.
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2. The following procedures shall be
followed.
a. No Discoveries
In the event that no discoveries
were encountered during night
and/or weekend work, the PI
shall record the information on
the CSVR and submit to MMC via
fax by 8AM of the next business
day.
b. Discoveries
All discoveries shall be
processed and documented
using the existing procedures
detailed in Sections III - During
Construction, and IV – Discovery
of Human Remains. Discovery of
human remains shall always be
treated as a significant
discovery.
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c. Potentially Significant
Discoveries
If the PI determines that a
potentially significant discovery
has been made, the procedures
detailed under Section III -
During Construction and IV-
Discovery of Human Remains
shall be followed.
d. The PI shall immediately contact
MMC, or by 8AM of the next
business day to report and
discuss the findings as indicated
in Section III-B, unless other
specific arrangements have
been made.
B. If night and/or weekend work becomes
necessary during the course of
construction
1. The Construction Manager shall
notify the RE, or BI, as appropriate, a
minimum of 24 hours before the
work is to begin.
2. The RE, or BI, as appropriate, shall
notify MMC immediately.
C. All other procedures described above
shall apply, as appropriate.
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VI. Post Construction
A. Preparation and Submittal of Draft
Monitoring Report
1. The PI shall submit two copies of the
Draft Monitoring Report (even if
negative), prepared in accordance
with the Historical Resources
Guidelines (Appendix C/D) which
describes the results, analysis, and
conclusions of all phases of the
Archaeological Monitoring Program
(with appropriate graphics) to MMC
for review and approval within 90
days following the completion of
monitoring. It should be noted that
if the PI is unable to submit the
Draft Monitoring Report within the
allotted 90-day timeframe resulting
from delays with analysis, special
study results or other complex
issues, a schedule shall be
submitted to MMC establishing
agreed due dates and the provision
for submittal of monthly status
reports until this measure can be
met.
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a. For significant archaeological
resources encountered during
monitoring, the Archaeological
Data Recovery Program shall be
included in the Draft Monitoring
Report.
b. Recording Sites with State of
California Department of Parks
and Recreation
The PI shall be responsible for
recording (on the appropriate
State of California Department
of Park and Recreation forms-
DPR 523 A/B) any significant or
potentially significant resources
encountered during the
Archaeological Monitoring
Program in accordance with the
City’s Historical Resources
Guidelines, and submittal of
such forms to the South Coastal
Information Center with the
Final Monitoring Report.
2. MMC shall return the Draft
Monitoring Report to the PI for
revision or, for preparation of the
Final Report.
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3. The PI shall submit revised Draft
Monitoring Report to MMC for
approval.
4. MMC shall provide written
verification to the PI of the
approved report.
5. MMC shall notify the RE or BI, as
appropriate, of receipt of all Draft
Monitoring Report submittals and
approvals.
B. Handling of Artifacts
1. The PI shall be responsible for
ensuring that all cultural remains
collected are cleaned and
catalogued
2. The PI shall be responsible for
ensuring that all artifacts are
analyzed to identify function and
chronology as they relate to the
history of the area; that faunal
material is identified as to species;
and that specialty studies are
completed, as appropriate.
3. The cost for curation is the
responsibility of the property
owner.
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C. Curation of artifacts: Accession
Agreement and Acceptance Verification
1. The PI shall be responsible for
ensuring that all artifacts associated
with the survey, testing and/or data
recovery for this project are
permanently curated with an
appropriate institution. This shall be
completed in consultation with
MMC and the Native American
representative, as applicable.
2. The PI shall include the Acceptance
Verification from the curation
institution in the Final Monitoring
Report submitted to the RE or BI
and MMC.
3. When applicable to the situation,
the PI shall include written
verification from the Native
American consultant/monitor
indicating that Native American
resources were treated in
accordance with state law and/or
applicable agreements. If the
resources were reinterred,
verification shall be provided to
show what protective measures
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were taken to ensure no further
disturbance occurs in accordance
with Section IV – Discovery of
Human Remains, Subsection 5.
D. Final Monitoring Report(s)
1. The PI shall submit one copy of the
approved Final Monitoring Report to
the RE or BI as appropriate, and one
copy to MMC (even if negative),
within 90 days after notification
from MMC that the draft report has
been approved.
2. The RE shall, in no case, issue the
Notice of Completion and/or release
of the Performance Bond for
grading until receiving a copy of the
approved Final Monitoring Report
from MMC which includes the
Acceptance Verification from the
curation institution.
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Landform Alteration/
Visual Quality
Would the project result in
a substantial change in the
existing landform?
Landform Alteration
Impact VIS-1: The project would result in a
substantial change in an existing landform.
Therefore, impacts would be significant. This
impact is consistent with the conclusion in
the 1998 EIR.
The project has been designed to minimize the
visual impacts of landform alteration to the extent
feasible. As a result, the project would preserve
approximately 23.75 acres of the project site
(57.3 percent) within the proposed MHPA open
space, which consists of natural vegetation, and
would also preserve the majority of steep slopes
on-site. The project would also revegetate
manufactured slopes in order to minimize the
visual impact of grading. However, no further
mitigation is available to reduce impacts
associated with landform alteration.
Significant and
Unavoidable
Air Quality
Sensitive Receptors (Construction)
Impact AIR-1: Dust generated from blasting
operations required during project
construction would have the potential to
release naturally occurring subsurface
arsenic, which could result in short-term
exposure that may result in a significant
impact.
MM-AIR-1a: Arsenic Testing Protocol in Areas
Requiring Blasting
Geocon shall obtain periodic random samples
from select air-track borehole spoils or the ground
surface over the course of the blasting program.
The number of samples shall vary and be based
on judgement depending on the size of the shot.
The samples shall be assigned for analysis of
arsenic using U.S. Environmental Protection
Agency Test Method 6010B with a reporting limit
of 1.0 milligram per kilogram. The sampling shall
be performed under the direct supervision of
Geocon’s Project Manager and Professional
Geologist.
Less Than
Significant
Avion Project SEIR Page S-40 Table S-1 Summary of Significant Environmental Impacts and Mitigation Measures Environmental Issue Impacts Mitigation Impact Level After Mitigation MM-AIR-1b: Blasting Dust Mitigation Plan The following protocols shall be performed to minimize the generation of visible dust during the hard rock blasting events: The areas shall be heavily watered prior to the planned blasting. The amount of water applied shall depend on the size of the shot and composition of the materials exposed at the top of the shot (i.e., topsoil vs. hard rock). A water truck shall be dedicated to pre-wet the ground surface. Detergent, if necessary, shall be added to the water truck to reduce the surface tension of the water and promote soaking into the surface materials. The water used shall be confined to the area of the shot and not be allowed to migrate out of the work limits. Confinement of the water shall be achieved through use of earthen berms, ditches, or other containment features that shall prevent migration of the water outside the work area. Once the boreholes are loaded with blasting agent, a final soaking shall occur just prior to the shot.
1.0 Introduction
Avion Project SEIR
Page 1-1
Chapter 1
Introduction
This chapter provides a brief description of the background and scope of the Avion Project (project),
the purpose and legal authority for this Supplemental Environmental Impact Report (SEIR), the SEIR
scope and process, and an explanation of how the SEIR is organized.
1.1 Project Background
This SEIR updates the certified Environmental Impact Report No. 96-7902 (1998 EIR) prepared for the
Black Mountain Ranch (Subarea I) Subarea Plan adopted in July 1998, and addresses the potential
environmental effects of the proposed Avion Project (project). The Subarea Plan identifies several
perimeter properties, which were originally held by 11 different ownerships. The Avion project site is
within the area of the Subarea Plan referred to as the “Southeast Perimeter” properties, which are
composed of four parcels (A, B, C, and D). The project site consists of Parcel C, totaling 41.48 acres,
which is designated for 117 dwelling units. The anticipated development envelope for Parcel C
would be approximately 17.74 acres. The remaining approximate 23.75 acres on-site would be
preserved as Multi-Habitat Planning Area (MHPA) open space. The 1998 EIR provides analysis for the
project site, based on these general development parameters, but because no specific project
design was known or proposed at the time the 1998 EIR was certified, the analysis of certain impacts
for the site was only done at a “program level”, and that future site-specific California Environmental
Quality Act (CEQA) analysis would be required for areas outside of the previously approved Black
Mountain Ranch II Vesting Tentative Map (VTM)/Planned Residential Development (DEP No. 95-0173;
SCH No. 95041041) project area.
1.2 Project Scope
The project requires approval of a VTM, a Rezone from AR-1-1 (Agricultural – Residential, minimum
10-acre lots) to RS-1-14 (Residential Single Unit, minimum 5,000-square-foot lots), a Planned
Development Permit (PDP), a Site Development Permit (SDP), and a MHPA Boundary Line
Adjustment to subdivide and construct 84 detached multi-family residential units. The Black
Mountain Ranch Subarea Plan allows 117 dwelling units on-site, including a requirement for
19 affordable units. The project proposes to construct 84 detached multi-family units on-site and
transfer 19 affordable units to Lot X of Map 15919 in the Black Mountain Ranch North Village Town
Center. In addition, the project proposes the transfer of 14 market rate dwelling units to Lots 12, 13,
18 and 19 of Map 15919 in the Black Mountain Ranch North Village Town Center. In total, the project
proposes a combined 117 dwelling units, including 19 affordable units, on-site and off-site in
conformance with the Black Mountain Ranch Subarea Plan.
The San Diego Local Agency Formation Commission (LAFCO) would act as a responsible agency in
accordance with CEQA. The applicant would be required to obtain approval from LAFCO of a
reorganization consisting of expansion of Olivenhain Municipal Water District's (OMWD’s) sewer
latent powers and annexation to OMWD and the district's sewer service area.
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Approximately 17.74 acres of the 41.48-acre site would be developed for residential uses and
various site improvements, including private drives, hardscape, retaining walls, and landscaping.
Native low-fuel volume species would be used to re-vegetate the graded slopes. The treatment for
the interior would primarily be parkway street trees and groundcover, ornamental in nature, fire-
resistant, and would complement the building architecture. The remaining approximate 23.75 acres
on-site would be preserved as MHPA open space.
Grading operations would entail approximately 296,000 cubic yards of cut (maximum depth of
52 feet) and 296,000 cubic yards of fill (maximum depth of 64 feet), resulting in a net balance of soils
on the project site. The project would construct retaining walls with a total length of 2,038 feet and a
maximum height of 55 feet, 7 inches. Blasting may be required in conjunction with grading
operations for the project in areas of shallow bedrock.
Discretionary actions required to implement the project include the following and are also described
in detail in Chapter 3.0:
• VTM
• Rezone
• PDP
• SDP
• MHPA Boundary Line Adjustment
• A reorganization consisting of latent powers expansion for sewer service for OMWD and
annexation to OMWD and the district's sewer service area (LAFCO).
1.3 SEIR Purpose Legal Authority
1.3.1 Intended Uses
This SEIR provides public agencies and the public in general with detailed information about the
effect a proposed project is likely to have on the environment; lists ways in which the significant
effects of such a project might be minimized; and identifies alternatives to such a project. This SEIR
is an informational document for use by the City, decision-makers, public agencies, and the general
public about the potential significant adverse environmental impacts of the project. This document
complies with all criteria, standards, and procedures of CEQA (California Public Resources Code
[PRC] Section 21000 et seq.) and the State CEQA Guidelines (California Code of Regulations Title 14
Section 15000 et seq.); the City’s EIR Guidelines (2005); and the City’s CEQA Determination
Thresholds (2016). This document has been prepared as a project-level SEIR, and it represents the
independent judgment of the City as Lead Agency (State CEQA Guidelines Section 15050).
1.3.2 Lead Agency
The City of San Diego is the Lead Agency for the project pursuant to Article 4 (Sections 15050 and
15051) of the CEQA Guidelines. The Lead Agency, as defined by CEQA Guidelines Section 15367, is
the public agency that has the principal responsibility and authority for carrying out or approving
the project. As Lead Agency, the City of San Diego Development Services Department,
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Environmental Analysis Section conducted a preliminary review of the proposed development and
determined that this SEIR was required. The analysis and findings in this document reflect the
independent, impartial conclusions of the City.
1.3.3 Responsible and Trustee Agencies
State law requires that all EIRs be reviewed by responsible and trustee agencies. A Responsible
Agency, defined pursuant to State CEQA Guidelines Section 15381, includes all public agencies other
than the Lead Agency that have discretionary approval power over the project. A Trustee Agency is
defined in Section 15386 of the CEQA Guidelines as a state agency having jurisdiction by law over
natural resources affected by a project that are held in trust for the people of the state of California.
Implementation of the project would require consultation with the following responsible and trustee
agencies, as described below.
U.S. Fish and Wildlife Service (USFWS): Acting under the federal Endangered Species Act (ESA), the
USFWS is responsible for ensuring that any action authorized, funded, or carried out by a federal
agency (such as the U.S. Army Corps of Engineers) is not likely to jeopardize the continued existence
of listed species or modify their critical habitat. Accordingly, the USFWS would provide input to the
U.S. Army Corps of Engineers as part of the Section 404 process.
Within areas covered by San Diego’s Multiple Species Conservation Program (MSCP) Subarea Plan,
including the project site, the role of the USFWS is limited with respect to species covered under the
Subarea Plan. For species covered by the Subarea Plan, the USFWS has granted take authorization
for listed species to the City in accordance with the requirements of the MSCP Implementing
Agreement, executed between the City, the USFWS, and the California Department of Fish and
Wildlife (CDFW) in 1997.
For projects that are consistent with San Diego’s MSCP, the City, therefore, has authority to grant
permits for take of covered species and a separate permit is not required from the wildlife agencies.
For listed species not included on the MSCP covered species list, the wildlife agencies retain permit
authority. In addition, the USFWS along with the CDFW must approve the MHPA boundary line
adjustments associated with each project.
California Department of Fish and Wildlife (CDFW): The CDFW has jurisdiction over sensitive
wildlife that is held in trust for the people of California. The CDFW would be a Trustee Agency for the
project, as sensitive wildlife is located on-site and in the project vicinity. The CDFW has the authority
to reach an agreement with an agency or private party proposing to alter the bed, banks, or floor of
any watercourse/stream, pursuant to Section 1600 et seq. of the State Fish and Game Code. The
CDFW generally evaluates information gathered during preparation of the environmental
documentation, and attempts to satisfy their permit concerns in these documents. Along with the
USFWS, the CDFW must approve of any MHPA boundary adjustments.
Local Agency Formation Commission (LAFCO): LAFCO would have discretionary approval of a
reorganization consisting of a latent powers expansion to provide sewer service and annexation to
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OMWD and the district's sewer service area. LAFCO would act as a responsible agency in accordance
with State CEQA Guidelines.
San Diego County Air Pollution Control District (SDAPCD): The County Board of Supervisors sits
as the Board of the SDAPCD, which is an agency that regulates sources of air pollution within the
county. This is accomplished through an integrated monitoring, engineering, and compliance
operation, the components of which are separate divisions within the SDAPCD and each of them
designed to protect the public from the adverse impacts of polluted air. The SDAPCD would be
responsible for issuing permits with respect to air emissions for construction and operation of the
project.
1.4 SEIR Scope
1.4.1 Type of EIR
This EIR has been prepared as a Project SEIR, as defined in Section 15163 of the CEQA Guidelines. In
accordance with CEQA, this Project SEIR examines the environmental impacts of a specific
development project and focuses on the physical changes in the environment that would result
from the project, including all phases of planning, construction, and operation.
This SEIR tiers to the certified (No. 96-7902) 1998 EIR. This SEIR considers the issues discussed in the
first-tier document and evaluates whether a significant effect has been adequately addressed or if
there is an effect that was not addressed in the previous report.
1.4.2 Scope of SEIR
The scope of analysis for this SEIR was determined by the City of San Diego as a result of initial
project review and consideration of comments received in response to the Notice of Preparation
(NOP) distributed on July 2, 2019. The City’s NOP and associated responses are included in
Appendix A of this SEIR.
This SEIR serves as a supplement to the previously certified 1998 EIR, as referenced above. All
environmental issues analyzed in the 1998 EIR were considered during initial review of the project.
The following issues were determined to either: (1) lack a site-specific impact analysis and adequate
mitigation for project impacts; or (2) result in new impacts that may be potentially significant and
require subsequent analysis and/or mitigation as part of this SEIR:
• Land Use (Land Development Code Deviations, MSCP Consistency);
• Biological Resources;
• Cultural Resources;
• Landform Alteration/Visual Quality (landform alteration);
• Noise (construction); and
• Air Quality (construction)
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These issues are discussed in detail in Chapter 5.0 of this SEIR. This SEIR provides project-specific
environmental review pursuant to CEQA. The analysis identifies environmental effects specific to the
project and appropriate mitigation, when warranted.
Chapter 9.0 of this SEIR, “No Changes in Analysis,” contains a summary of the impacts of the project
compared with the impacts analyzed in the 1998 EIR. The analysis in this document evaluates the
adequacy of the 1998 EIR relative to approval of the project. The 1998 EIR indicates that significant
impacts for the project site would be substantially lessened or avoided if the mitigation measures
recommended in the EIR are implemented by future development for various environmental issues,
as identified below in Table 1-1. Greenhouse gas (GHG) emissions were not addressed in the 1998
EIR. The issue of GHG is not addressed in this SEIR as the courts have established that climate
change and GHG do not constitute “new information” because the effects of GHG on climate change
were known when the EIR was certified in 1998 and therefore do not have to be addressed as “new
information” in a SEIR (Citizens Against Airport Pollution v. City of San Jose (2014) 227 Cal.App.4th
788, 806-808). A comparison of the project to the 1998 EIR is provided below in Table 1-1. The
project would implement applicable mitigation measures included in the 1998 EIR and/or this SEIR,
as indicated in the table.
Table 1-1
Impact Assessment Summary 1998 EIR
Issue Area
FEIR/Subarea Plan Analysis
Conclusion1
New or
Substantially
Increased
Impact?
New and/or
Previous
Mitigation)?
Resultant Project Impact
after Mitigation?
A. Land Use
Plan Consistency Less than significant No No Less than significant
LDC Deviations Potentially2 significant No No Less than significant
MSCP consistency (MHPA
Adjacency) Potentially significant Yes New Less than significant
B. Traffic Significant unmitigated No Previous Significant unmitigated
C. Biological Resources Significant unmitigated No New Less than significant
D. Hydrology/Water Quality Significant mitigated No No Less than significant
E. Landform Alteration/Visual Quality
Landform Alteration Potentially significant Yes New Significant unmitigated
Visual Character Significant mitigated No No Less than significant
Unique geologic feature Less than significant No No Less than significant
Landmark Trees Less than significant No No Less than significant
F. Cultural Resources Less than significant No No Less than significant
G. Air Quality
Direct Impacts (Traffic) Significant unmitigated No No Significant unmitigated
Cumulative Impacts
(Construction) Significant unmitigated Yes Previous Less than significant
H. Geology and Soils Potentially significant No No Less than significant
I. Natural Resources/
Agriculture Significant and unmitigated No No Significant and
unmitigated
J. Paleontological Resources Less than significant No No Less than Significant
K. Noise
Traffic Less than significant No No Less than significant
Construction Potentially significant Yes New Less than significant
L. Public Facilities and Services
Schools Significant and mitigated No No Less than significant
Parks and Recreation Less than significant No No Less than significant
Libraries Less than significant No No Less than significant
Police and Fire Services Police: Less than significant
Fire: Potentially significant No No Less than significant
Water Supply and Service Significant and mitigated No No Less than significant
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Table 1-1
Impact Assessment Summary 1998 EIR
Issue Area
FEIR/Subarea Plan Analysis
Conclusion1
New or
Substantially
Increased
Impact?
New and/or
Previous
Mitigation)?
Resultant Project Impact
after Mitigation?
Wastewater Generations Potentially significant No No Less than significant
Waste Management Service Significant and mitigated No No Less than significant
Electrical Utilities Less than significant No No Less than significant
M. Water Conservation Significant and mitigated No No Less than significant
N. Public Safety Less than significant No No Less than significant
O. Population Less than significant No No Less than significant
1The analysis applies to the southeast perimeter properties, if applicable; otherwise the conclusion is based on buildout of the overall Subarea
Plan.
2“Potentially Significant” refers to impacts for which the 1998 EIR was unable to make a definitive conclusion about the significance of an
impact for the perimeter properties due to a lack of site-specific information at the time the Subarea Plan was adopted.
1.4.3 SEIR Content and Format
1.4.3.1 SEIR Analysis Content
This SEIR determines whether implementation of the project would have a significant effect on the
environment through analysis of the issues identified during the scoping process (see Section 1.3.2).
Pursuant to CEQA Guidelines Section 15126, all phases of the project are considered in this SEIR
when evaluating its potential impacts on the environment, including the planning, acquisition,
development, and operation phases. Impacts are identified as direct or indirect, short-term or long-
term, and assessed on a “plan-to-ground” basis. The “plan-to-ground” analysis addresses the
changes or impacts that would result from implementation of the project compared to existing
ground conditions.
1.4.4.2 SEIR Format
Organization
The format and order of contents of this SEIR follow the direction of the City’s EIR Guidelines. A brief
overview of the various chapters of this SEIR is provided below:
Executive Summary. Provides a summary of the SEIR and a brief description of the project,
identifies areas of controversy, and includes a summary table identifying significant impacts,
mitigation measures (new and from the 1998 EIR), and impact conclusion after mitigation. A
summary of the analyzed project alternatives and comparison of the potential impacts of the
alternatives with those of the project is also provided.
Chapter 1.0 Introduction. Contains an overview of the purpose and intended uses of the SEIR;
identifies the Lead, Responsible, and Trustee Agencies; summarizes the SEIR scope and content; and
details the CEQA environmental review process.
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Chapter 2.0 Environmental Setting. Provides a description of the project’s regional context,
location, and existing physical characteristics and land use. Available public infrastructure and
services, as well as relationship to relevant plans, are also provided in this chapter.
Chapter 3.0 Project Description. Provides a detailed discussion of the project, including
background, objectives, key features, off-site components, and environmental design
considerations. A description of the discretionary actions required to implement the project is also
included.
Chapter 4.0 History of Project Changes. Provides an outline of the project’s history and any
changes in project design that have been made in response to environmental concerns raised
during the City’s review of the project.
Chapter 5.0 Environmental Analysis. Provides a detailed evaluation of potential environmental
impacts of the project. In accordance with the City’s EIR Guidelines, Chapter 5.0 begins with the issue
of land use, followed by the remaining issues included in order of significance. Under each issue
area, this chapter includes a description of the existing conditions relevant to each environmental
topic including the regulatory framework; presentation of threshold(s) of significance based on the
City of San Diego’s CEQA Significance Determination Thresholds for the particular issue area under
evaluation; identification of an issue statement; an assessment of any impacts associated with
implementation of the project; a conclusion as to the significance of any project impacts; and
recommendations for mitigation measures and mitigation monitoring and reporting, as appropriate,
for each significant issue area. Where mitigation measures are required, a statement regarding the
significance of the impact after mitigation is additionally provided.
Chapter 6.0 Significant Unavoidable Environmental Effects/Significant Irreversible
Environmental Changes. Discusses the significant unavoidable impacts of the project, including
those that can be mitigated but not reduced to below a level of significance. This chapter also
describes the potentially significant irreversible changes that may be expected with development of
the project and addresses the use of nonrenewable resources during its construction and
operational life.
Chapter 7.0 Growth Inducement. Evaluates the potential influence the project may have on
economic or population growth within the project area as well as the region, either directly or
indirectly.
Chapter 8.0 Cumulative Impacts. Identifies the impacts of the project in combination with other
planned and future development in the region.
Chapter 9.0 Subject Areas Requiring No Change in Analysis. The analysis and conclusions
reached in a number of the environmental subject areas contained within the 1998 EIR do not
require supplemental analysis and are not addressed in detail in Chapter 5 of this SEIR. These issues
are briefly summarized in this chapter.
Chapter 10.0 Project Alternatives. Provides a description of two alternatives to the project,
including a No Project/No Development Alternative and a Reduced Development Footprint
Alternative.
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Chapter 11.0 Mitigation Monitoring and Reporting Program. Documents all the mitigation
measures identified in the 1998 EIR and this SEIR that are required to be implemented as part of the
project.
Chapter 12.0 References Cited. Lists all of the reference materials cited in the SEIR.
Chapter 13.0 Individuals and Agencies Consulted. Identifies all of the individuals and agencies
contacted during preparation of the SEIR.
Chapter 14.0 Certification. Identifies all of the agencies, organizations, and individuals responsible
for the preparation of the SEIR.
Technical Appendices
Technical appendices, used as a basis for much of the environmental analysis in the SEIR, have been
summarized in the SEIR and are printed under separate cover as part of the SEIR. The technical
appendices are available for review at the City of San Diego Development Services Center, 1222 First
Avenue, Fifth Floor, San Diego, California 92101.
Incorporation by Reference
As permitted by CEQA Guidelines Section 15150, this SEIR incorporates by reference previously
certified 1998 EIR (No. 96-7902) subsequent addenda and approved plans, which provide supporting
documentation used in the analysis for the project. This SEIR also references several technical
studies and reports, including the City of San Diego General Plan and EIR (2008) and the Black
Mountain Ranch Subarea Plan (2009, as amended). Information from these documents has been
briefly summarized in this SEIR, and their relationship to this SEIR described. These documents are
included in Chapter 12.0, References Cited, and are hereby incorporated by reference. They are
available for review at the City of San Diego Development Services Center, 1222 First Avenue, Fifth
Floor, San Diego, California 92101.
1.5 SEIR Public Review Process
1.5.1 Draft SEIR
In accordance with Sections 15085 and 15087 (a) (1) of the CEQA Guidelines, upon completion of the
Draft SEIR a Notice of Completion is filed with the State Office of Planning and Research, and a
notice of availability of the Draft SEIR is issued in a newspaper of general circulation in the area.
The Draft SEIR is distributed for a 45-calender day review to the public, and interested and affected
agencies for the purpose of providing comments “on the sufficiency of the document in identifying
and analyzing the possible impacts on the environment and ways in which the significant effects of
the project might be avoided or mitigated” (Section 15204, CEQA Guidelines). The public review
period will be from November 15 through December 30, 2019.
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This Draft SEIR and all related technical studies are available for review during the public review
period at the offices of the City of San Diego, Development Services Department, located at 1222
First Avenue, Fifth Floor, San Diego, California, 92101. Copies of the Draft SEIR are also available at
the following public locations:
Central Library Carmel Valley Branch Library Carmel Mountain Ranch Library
330 Park Boulevard 3919 Townsgate Drive 12095 World Trade Drive
San Diego, CA 92101 San Diego, CA 92130 San Diego, CA 92128
An electronic copy of the SEIR and the technical analyses is posted on the Development Services
Department website at https://www.sandiego.gov/ceqa/draft.
1.5.2 Final SEIR
Following public review of the Draft SEIR, the City will provide written responses to comments per
CEQA Guidelines Section 15088 and consider the written comments in making its decision to certify
the Final SEIR. Responses to the comments received during public review, a Mitigation Monitoring
and Reporting Program, and Findings of Fact will be included with the Final SEIR. If no new
significant and unmitigated impacts are identified for the project, then the City shall re-adopt the
Statement of Overriding Considerations adopted in conjunction with the 1998 EIR.
The culmination of this process is a public hearing where the City Council will determine whether to
certify the Final SEIR as being complete and in accordance with CEQA. Pursuant to Section
128.0310(a) of the City of San Diego Land Development Code, the Final SEIR will be available for
public review for at least 14 calendar days before the first public hearing or discretionary action on
the project.
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Chapter 2
Environmental Setting
This chapter provides a description of existing site conditions for the Avion Property (project). The
existing setting addresses the project site as well as the off-site components; and provides an
overview of the local and regional environmental setting pursuant to Section 15152 of the State
CEQA Guidelines.
2.1 Regional Setting
The project site is in the city of San Diego (City), in San Diego County, east of Interstate 5, west of
Interstate 15, and north of State Route 56 (Figure 2-1). The project site lies approximately seven
miles inland from the Pacific Ocean and is approximately 20 miles north of downtown San Diego.
The undeveloped 41.48-acre project site is located within the Black Mountain Ranch Subarea, which
constitutes Subarea I of the former North City Future Urbanizing Area Framework Plan. The Black
Mountain Ranch Subarea encompasses 5,098 acres in the northern portion of the City, and is
generally bounded on the west, north, and east by unincorporated areas of San Diego County. The
4S Ranch and Santa Fe Valley Specific Plan areas form a portion of this county land. On the east,
southeast, and south, the Black Mountain Ranch Subarea is bounded by the Rancho Peñasquitos
and Rancho Bernardo community planning areas and Subarea IV Torrey Highlands.
2.2 Project Location
The project site is located approximately 0.6 mile south of Carmel Valley Road/Bernardo Center
Drive, 1.2 miles west of Interstate 15, and 1.4 miles east of Black Mountain Road. The project site
consists of a 41.48-acre parcel of undeveloped land (Assessor’s Parcel Number 312-010-16 within
Section 5 of Township 14 South, Range 2 West of the U.S. Geological Survey (USGS) 1996 7.5-minute
topographic map, Poway quadrangle). The legal description of the project parcel is the southwest
quarter of the northeast quarter of Section 5, Township 14 south, Range 2 west, San Bernardino
base and meridian, in the City of San Diego, County of San Diego, State of California, except all crude
oil, petroleum, gas, brea, asphaltum, and all kindred substances and other minerals under and in
said land, as reserved in deed recorded May 30, 1960 as Instrument No. 111628.
2.3 Physical Environment
2.3.1 Landform
Topographically, the project site is located at the upper end of a broad north-south trending valley. A
ridgeline occurs in the central portion of the site that rises in elevation from north to south from
740 feet mean sea level to 915 feet mean sea level. The ridge is bounded by two small canyons, one
to the east and one to the west, with one main drainage course and smaller tributaries in each.
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These drainages have slopes of moderate to steep grade. There is a small meadow in the northwest
corner of the property, at the mouth of the eastern drainage.
2.3.2 Land Use
The project site is located in a developing area that consists primarily of residential development
and open space (Figure 2-2). Land uses surrounding the project site include a portion of the Black
Mountain Open Space Park to the west, east, and south, the Heritage Bluffs residential development
to the north, and additional Black Mountain Open Space Park open space lands to the northwest.
The project site is undeveloped, although a dirt road occurs along the crest of the ridge. Remnant
concrete slabs from former structures occur at the north end of the site. The presence of various
abandoned objects such as metal tanks, agricultural staking, and old irrigation lines indicate that the
site was once used for minor agricultural activities. Native upland and wetland vegetation occurs on-
site.
The project site is currently zoned as Agricultural – Residential in the Black Mountain Ranch
(Subarea I) Subarea Plan (AR-1-1). Approximately 18.97 acres of the project site are included in the
City’s Multi-Habitat Planning Area (MHPA). MHPA lands are those that have been included within the
City’s Multiple Species Conservation Program (MSCP) Subarea Plan for habitat conservation. The
MHPA boundary surrounds the area to be developed.
2.3.3 Transportation/Circulation
The regional transportation network in the project area consists of State Route 56 to the south,
Interstate 15 to the east, and Interstate 5 to the west. Access to the project site would be provided
by constructing an access road that would connect to Winecreek Drive at the northeast corner of the
project site. There are no existing or proposed bus stops near the project site.
2.3.4 Historical Resources
A total of nine cultural resources have been identified on the project site:
• A record search of the South Coastal Information Center at San Diego State University
identified two prehistoric archaeological sites recorded on the project property (CA-SDI-
18428 and CA-SDI-18429) that both consist of flake scatters.
• Field surveys during July 2013 and December 2017 identified a total of seven cultural
resources:
o Three prehistoric isolates consisting of one or two flakes (7178-RDS-1, 7178-RDS-2, and
7178-HJP-1);
o Two prehistoric sites (7179-HJP-2 and 7178-RDS-3);
o A historic farmstead site (7178-HJP-3); and
o A historic structure and associated road (7178-RDS-4).
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None of the material identified during the 2013 survey was at, or immediately adjacent to, the
mapped locations of either CA-SDI-18428 or CA-SDI-18429. The 2017 survey did find seven flakes
within 15 meters of the mapped location of SDI-18428. RDS-3 and the flakes adjacent to SDI-18428
have been included in an expanded boundary for this site for recording purposes.
2.3.5 Biological Resources
Four vegetation communities and one land cover type occur on the project site. Southern mixed
chaparral comprises the majority of the site with lesser acreages of coastal sage scrub, non-native
grassland, and freshwater marsh patches. The single land cover type occurring on the project site
consists of disturbed land.
Coastal sage scrub, southern mixed chaparral, non-native grassland, and freshwater marsh are all
considered sensitive vegetation types by the City (City of San Diego 2012). Coastal sage scrub is
ranked as a Tier II habitat, southern mixed chaparral as a Tier IIIA habitat, non-native grassland as a
Tier IIIB habitat, and freshwater marsh as a wetland habitat. No sensitive plant species were
observed on the project site and none are expected to occur due to lack of appropriate habitat
and/or soil conditions. Two sensitive animal species (cooper’s hawk and San Diego desert woodrat)
were observed on-site, while four other sensitive animal species (Belding’s orange-throated whiptail,
coastal whiptail, coastal California gnatcatcher, and southern California rufous-crowned sparrow)
have a moderate potential to occur on the project site due to the habitat conditions.
2.3.6 Air Quality
The project site is within the San Diego Air Basin (SDAB), as defined by the California Air Resources
Board and San Diego Air Pollution Control District. The eastern portion of the SDAB is surrounded by
mountains to the north, east, and south. These mountains tend to restrict airflow and concentrate
pollutants in the valleys and low-lying areas below.
The SDAB is currently classified as a federal and state non-attainment area for ozone and a state
non-attainment area for particulate matter less than 10 microns (PM10), particulate matter less than
2.5 microns (PM2.5), and ozone. Air pollutants transported into the basin from the adjacent South
Coast Air Basin contribute to the nonattainment conditions in the SDAB.
2.4 Planning Context
Development projects in the City are generally guided by the City’s General Plan, and more
specifically by the applicable community plan. In addition, various other City, regional, and state
plans, programs, and ordinances regulate the development of land within San Diego. A brief
description of plans relevant to the project is provided below. A detailed evaluation of the project’s
consistency with relevant plans and ordinances was completed in conjunction with the 1998
Environmental Impact Report. This Supplemental Environmental Impact Report includes a
consistency analysis with relevant City ordinances in Chapter 5.1.
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2.4.1 City of San Diego General Plan
The City of San Diego General Plan sets forth a comprehensive long-term plan for development
within the City. The General Plan incorporates a City of Villages strategy, which aims to redirect
development away from undeveloped lands and toward already urbanized areas and/or areas with
conditions allowing the integration of housing, employment, civic, and transit uses. This
development strategy mirrors regional planning and smart growth principles intended to preserve
remaining open space and natural habitat and focus development within areas with available public
infrastructure.
2.4.2 Black Mountain Ranch (Subarea I) Subarea Plan
The Black Mountain Ranch Subarea Plan describes land use patterns and policies to guide the long-
term use and development of the Black Mountain Ranch Subarea. A Subarea Plan is comparable to
a community plan in regards to its content and relationship to the City’s General Plan.
2.4.3 Land Development Code (Municipal Code)
The City’s Municipal Code contains all the adopted ordinances for the City and is divided into 15
chapters. Chapters 11 through 14 are known collectively as the Land Development Code and include
applicable development regulations for the Base Zones of a project site as well as supplemental
development regulations contained within the applicable Overlay Zones.
2.4.3.1 Environmentally Sensitive Lands Regulations
The purpose of the Environmentally Sensitive Lands (ESL) Regulations (Land Development Code
[LDC] Sections 143.0101 – 143.0160) is to protect, preserve and, where damaged, restore
environmentally sensitive lands and the viability of the species supported by those lands. The ESL
Regulations apply to all proposed development when environmentally sensitive lands, including
sensitive biological resources, steep hillsides, floodplains, or coastal bluffs, are present. The
regulations are designed to ensure that development occurs in a manner that protects natural
resources and the natural and topographic character of the area, and retains biodiversity and
interconnected habitats.
2.4.3.2 Historical Resources Regulations
The purpose of the City’s Historical Resources Regulations, found in Section 143.0251 of the LDC, is
to protect, preserve, and, where damaged, restore the historical resources of San Diego, which
include historical buildings, historical structures or objects, important archaeological sites, historical
districts, historical landscapes, and traditional cultural properties. These regulations are intended to
assure that development occurs in a manner that protects the overall quality of historical resources.
2.0 Environmental Setting
Avion Project SEIR
Page 2-5
2.4.4 Multiple Species Conservation Program
The MSCP is a comprehensive habitat conservation planning program for San Diego County. A goal
of the MSCP is to preserve a network of habitat and open space, thereby protecting biodiversity.
Local jurisdictions, including the City of San Diego, implement their portions of the MSCP through
subarea plans, which describe specific implementing mechanisms. MHPA lands are those that have
been included within the City’s MSCP Subarea Plan for habitat conservation. These lands have been
determined to provide the necessary habitat quality, quantity, and connectivity to sustain the unique
biodiversity of the San Diego region. MHPA lands are considered by the City to be a sensitive
biological resource. Approximately 18,97 acres of the project site is within the MHPA, with the MHPA
surrounding the area to be developed.
2.4.5 Air Quality Plans
Air quality plans provide an overview of the region's air quality and identify the pollution-control
measures needed to expeditiously attain and maintain air quality standards. The region’s plans
include the San Diego Regional Air Quality Strategy, addressing state requirements, and the San
Diego portion of the California State Implementation Plan, addressing federal requirements.
2.4.6 Water Quality Plans
The Water Quality Control Plan for the San Diego Basin designates beneficial uses for water bodies
in the San Diego region, and establishes water quality objectives and implementation plans to
protect those beneficial uses. The City’s current Storm Water Standards Manual provides
information to project applicants on how to comply with the permanent and construction storm
water quality requirements in the City.
2.4.7 Olivenhain Municipal Water District Sphere of
Influence
The Olivenhain Municipal Water District (OMWD) Sphere of Influence (SOI) defines long-range
service boundaries for a city or special district. The project site is located within the OMWD adopted
SOI and sewer service SOI.
FIGURE 2-1
Regional Location
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USMC AIR
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USMC AIR
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0 5Miles [M:\JOBS5\8958\common_gis\fig2_1_EIR.mxd 6/27/2019 bma SAN DIEGO
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FIGURE 2-2
Project Location on Aerial Photograph
C A R M E L V A L LE Y
C A R M E L V A L LE Y
Image Source: NearMaps (flown February 2019)
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Project Boundary
Heritage Bluffs Boundary
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3.0 Project Description
Avion Project SEIR
Page 3-1
Chapter 3
Project Description
This section of the EIR provides a statement of the project goals and objectives, describes the
specific characteristics of the project, discusses project phasing and construction, and identifies the
discretionary actions required to implement the project. This section has been prepared pursuant to
Section 15124 of the State CEQA Guidelines.
3.1 Relationship to the Black Mountain Ranch (Subarea I) Subarea Plan
In July of 1998, the City of San Diego (City) adopted the Black Mountain Ranch (Subarea I) Subarea
Plan in the former North City Future Urbanizing Area (NCFUA) and certified the Final Environmental
Impact Report (FEIR; Land Development Review No. 96-7902, SCH No. 97111070). The 1998 Subarea
Plan and FEIR included: all of the previously approved Black Mountain Ranch II Vesting Tentative
Map (VTM)/Planned Residential Development (DEP No. 95-0173; SCH No. 95041041) project area
(3,690 acres; except for 94 acres1); 893 additional acres within the original Black Mountain Ranch
ownership; and 515 acres of other ownership adjoining the Black Mountain Ranch parcels
(perimeter properties). The Subarea Plan added 1,408 acres to the original Black Mountain Ranch
community. At that time, the additional 1,408-acre area included a northern area comprising a
mixed-use Northern Village (467 acres) with industrial, office, employment center, commercial/retail,
and high-density residential areas; the finger ridges north of La Jolla Valley; a 300-room resort/hotel;
a mixed-use southern village; seven additional residential development clusters; and four groupings
of perimeter ownerships.
The Subarea Plan identifies several perimeter properties, which were originally held by 11 different
ownerships (Figure 3-1). The Avion project site is within the area of the Subarea Plan referred to as
the “Southeast Perimeter” properties, which are composed of four parcels (A, B, C, and D). The
project site consists of Parcel C, totaling 41.48 acres. The Southeast Perimeter properties are
designated by the Subarea Plan to allow for up to a total 330 residential units within a 66-acre
development envelope (up to 5 dwelling units/gross acre). Specifically, Parcel C is designated for
117 dwelling units (Figure 3-2). The anticipated development envelope for Parcel C would be
approximately 17.74 acres. The remaining approximate 23.75 acres on-site would be preserved as
Multi-Habitat Planning Area (MHPA) open space. The 1998 Subarea Plan Environmental Impact
Report (EIR) provides analysis for the project site, based on these general development parameters,
but because no specific project design was known or proposed at the time the 1998 EIR was
certified, the analysis of certain impacts for the site was only done at a “program level.” The 1998 EIR
acknowledges that future site-specific California Environmental Quality Act (CEQA) analysis would be
required for areas outside of the Black Mountain Ranch VTM II project area.
1Ninety-four acres of dedicated Open Space at the eastern end of the panhandle was accounted for in the
Rancho Peñasquitos Community Plan.
3.0 Project Description
Avion Project SEIR
Page 3-2
3.2 Project Objectives
In accordance with CEQA Guidelines Section 15124, the following primary objectives support the
purpose of the project, assist the Lead Agency in developing a reasonable range of alternatives to be
evaluated in this report, and ultimately aid decision-makers in preparing findings and overriding
considerations, if necessary. The specific goals and objectives for the project are:
• Provide residential development that is consistent with the location and the goals and
objectives of the adopted Black Mountain Ranch Subarea Plan.
• Provide new residential development, which is consistent with existing residential
development patterns in the surrounding area.
• Implement “smart growth” principles of development through the provision of new
residences within a complete master planned community.
• Implement sustainable development principles through the provision of a community of
new residences with many energy-efficient features.
• Provide infrastructure improvements consistent with the Subarea Plan.
3.3 Description of Project Components
3.3.1 Residential Development
The project would develop 84 detached multi-family residential units and associated private drives
as shown in the Site and Grading Plan (Figure 3-3). The proposed development would include
grading, landscaping, brush management and the installation of all necessary infrastructure (utility
lines, storm drains, etc.). The Black Mountain Ranch Subarea Plan allows 117 dwelling units on the
site, including a requirement for 19 affordable units. The project proposes to construct 84 detached
multi-family units on-site and transfer 19 affordable units to Lot X of Map 15919 in the Black
Mountain Ranch North Village Town Center. In addition, the project proposes the transfer of
14 dwelling units to Lots 12, 13, 18 and 19 of Map 15919 in the Black Mountain Ranch North Village
Town Center. In total, the project proposes a combined 117 dwelling units, including 19 affordable
units, on-site and off-site in conformance with the Black Mountain Ranch Subarea Plan.
The proposed 84 detached multi-family units to be developed on-site would consist of four different
housing product types: 20 detached multi-family, 2,289-square-foot residential units; 20 detached
multi-family, 2,303-square-foot residential units; 22 detached multi-family, 2,446-sqaure-foot
residential units, and 22 detached multi-family, 2,479squarefoot residential units. As shown in
Table 3-1, the project would construct a total of 200,190 square feet of detached multi-family
residential development based on this mix of product types.
3.0 Project Description
Avion Project SEIR
Page 3-3
Table 3-1
Total Project Square Footage
Product Type
Square Footage of
Product Type Number of Units
Total Square Footage of
Product Type
Product 1 2,289 20 45,780
Product 2 2,303 20 46,060
Product 3 2,446 22 53,812
Product 4 2,479 22 54,538
TOTAL 84 200,190
3.3.2 Natural Open Space
The project would preserve approximately 23.75 acres of natural open space on-site through
dedication to the City’s MHPA. The on-site MHPA open space would include preservation of two
open space lots (Lots A and B), which would be dedicated in fee title to the City of San Diego. Within
Lots A and B to be dedicated in fee title to the City, the project applicant would retain ownership of
the 50-foot radii lots surrounding the storm drain outlets and grant them to the City through a
Covenant of Easement.
3.3.3 Grading and Retaining Walls
Implementation of the VTM would result in approximately 296,000 cubic yards of cut (maximum
depth of 52 feet) and 296,000 cubic yards of fill (maximum depth of 64 feet) over the approximately
15.69-acre graded area, resulting in a net balance of soils on the project site. Manufactured slopes in
excess of 10 feet in height at a 2:1 gradient would be created on the perimeter of the development
area boundary. Cut slopes would have a maximum height of 52 feet and 2:1 gradient. All the
manufactured slopes would be contoured.
The project would construct retaining walls with a total length of 2,038 feet and a maximum height
of 55 feet, 7 inches. Retaining walls would be constructed along both sides of the drainage that
would be crossed by Winecreek Drive, on the western project boundary adjacent to the row of
detached multi-family residential units accessed by Private Drives B and C, and on the eastern
project boundary downslope from Private Drive E (see Figure 3-3).
3.3.4 Water, Sewer, and Stormwater Systems
A summary of the proposed water, sewer, and stormwater improvements for the project is provided
below.
3.3.4.1 Water
Water service would be provided by the City of San Diego Public Utilities Department. The project
would connect to existing water service facilities within the Heritage Bluffs residential development
to north.
3.0 Project Description
Avion Project SEIR
Page 3-4
3.3.4.2 Sewer
As described in greater detail in Section 3.34.6 below, the San Diego Local Agency Formation
Commission (LAFCO) would need to approve a reorganization consisting of an expansion of latent
powers for the Olivenhain Municipal Water District (OMWD) sewer service area and the annexation
of the project site to OMWD and the sewer service area. Proposed sewer flows generated by the
project would be conveyed to the downstream sewer treatment plant owned and operated by the
OMWD. The project sewer mains would connect to existing sewer facilities within the Heritage Bluffs
residential development to north. The agreement to have OMWD provide sewer service rather than
the City San Diego is consistent with two other adjacent projects within Black Mountain Ranch (East
Clusters Unit 3 and the Heritage Bluffs residential development).
3.3.4.3 Stormwater
New storm drain facilities would be constructed per applicable San Diego standards. Storm drain
inlets would be constructed to collect runoff from within the developed areas that would drain into
an underground storm drain system. The project would comply with erosion control requirements
of the City's Grading Ordinance and the State Water Resources Control Board's National Pollutant
Discharge Elimination System General Permit. The project would include erosion control measures
such as retaining walls and replanting slopes with container material in conformance with the
grading ordinance and brush management guidelines
3.3.5 Access and Circulation
Access to the project site would be provided by constructing a private drive that would connect to
Winecreek Drive at the northeast corner of the project site. Six interior private drives (A through G)
would be constructed within the project site (refer to Figure 3-3). Private Drive A would connect to
Winecreek Drive at the northeast corner of the project site and provide the main access to the site.
Private Drives B, C, and G would be stub streets less than 150 feet in length. Internal circulation
would include stop signs at internal intersections. Emergency access would be provided via Private
Drive A’s connection to Winecreek Drive at the northeast corner of the project site.
3.3.6 Landscaping and Brush Management
The landscape concept plan design includes plantings to blend and complement the existing native
planting surrounding the project site. Native low-fuel volume species would be used to revegetate the
graded slopes, and the interior of the project site would feature parkway street trees and
groundcover—ornamental in nature and fire resistant. Plant materials utilized in the landscape
concept plan would be from the palette of plants known to perform well in this climactic zone and
amended soil type. Figure 3-4 presents the landscape concept plan.
Brush Management Zones would be implemented with Zone 1 located adjacent to structures and
must be the least flammable. Zone 2 would consist of selective thinning and pruning of native plants.
The standard BMZ widths are 35 feet for BMZ 1 and 65 feet for BMZ 2 as stated in Table 142-04h of the
City Municipal Code. The project proposes to implement Alternative Compliance measures to
3.0 Project Description
Avion Project SEIR
Page 3-5
traditional brush management zones that involve a reduction in BMZ 1 limits and introduction of a
non-combustible wall between BMZ 1 and BMZ 2. By reducing the BMZ 1 limit and providing a non-
combustible wall between BMZ 1 and BMZ 2, the overall impact to vegetation is reduced as the
graded area is less. By reducing the BMZ 1 limit and providing a non-combustible wall between
BMZ 1 and BMZ 2, the overall impact to vegetation is reduced as the graded area is less. All BMZ 1
impacts are located within the grading limits. The majority of the BMZ 2 impacts are also located
within the grading limits. Although 1.32 acres of BMZ 2 impacts extend into southern mixed
chaparral that lies outside of the grading limits primarily on the western side of the project area,
BMZ 2 impacts are considered “impact neutral” and involve only minor thinning, trimming, and
pruning of vegetation without destroying habitat value.
3.4 Discretionary Actions
Discretionary actions are those actions taken by an agency that call for the exercise of judgment in
deciding whether to approve or how to carry out a project. For the project, the following
discretionary actions are required and are further described below:
• Vesting Tentative Map (VTM)
• Rezone
• Planned Development Permit (PDP)
• Site Development Permit (SDP)
• MHPA Boundary Line Adjustments
• A reorganization consisting of latent powers expansion for sewer service for OMWD and
annexation to OMWD and the district's sewer service area (LAFCO)
3.4.1 Vesting Tentative Map
A VTM is required for the project to subdivide the property into one residential lot with 84 detached
multi-family units and two open space (MHPA) lots to be dedicated in fee to the City. The VTM details
the specific grading and necessary infrastructure.
3.4.2 Rezone
The site is currently zoned as AR-1-1 (Agricultural – Residential, minimum 10-acre lots). Under the project,
the site would be rezoned to RS-1-14 (Residential Single Unit, minimum 5,000-square-foot lots).
Application of the RS-1-14 zone would allow the project to include a variety of unit sizes, consistent
with nearby residential development.
3.4.3 Planned Development Permit
The project includes a PDP to allow for development of detached multi-family residential units
rather than single-family residential units and a deviation to exceed the maximum retaining wall
height outside of required setbacks.
3.0 Project Description
Avion Project SEIR
Page 3-6
3.4.4 Site Development Permit
The project includes a SDP due to impacts to Environmentally Sensitive Lands (ESL; i.e., steep slopes
and sensitive biological resources). Exceptions and deviations may be allowed by the City if certain
findings can be made. The project has been designed to minimize impacts to ESL, and includes
landform and contour grading; preservation of most sensitive biological resources in an MHPA open
space preserve; and the revegetation of slopes with native plant species. The proposed
encroachment into steep slopes is within the permitted allowances under ESL, and therefore, no
deviations are required.
3.4.5 MHPA Boundary Line Adjustments
Adjustments to an MHPA boundary may be in cases where the new MHPA boundary results in an
area of equivalent or higher biological value. The determination of the biological value of a proposed
boundary change is made by the City in accordance with the MSCP Plan, with the concurrence of the
Wildlife Agencies. After concurrence from the Wildlife Agencies is obtained, the MHPA boundary line
adjustment must ultimately be approved through a San Diego hearing body such as the City Council.
The existing MHPA boundary is shown on Figure 3-5a and the proposed MHPA boundary line
adjustment is shown on Figure 3-5b. The proposed boundary line adjustment would entail the
removal of 0.55 acre from the MHPA and the addition of 5.61 acres on-site (currently outside the
MHPA). Land that would be incorporated into the MHPA through the boundary line adjustment
consists of 4.99 acres of southern mixed chaparral, 0.49 acre of non-native grassland, and 0.13 acre
of coastal sage scrub. The MHPA boundary line adjustment proposed in conjunction with the project
is detailed in Section 5.1.4 of this document.
3.4.6 LAFCO Actions
The Cortese-Knox-Hertzberg Act requires that LAFCO conduct reviews of all municipal services
provided in each county. In 2005, the San Diego LAFCO conducted the North Central San Diego
County Municipal Service Review, which comprehensively studied existing and future public service
conditions and evaluated organizational options to accommodate growth, prevent urban sprawl,
and ensure that critical services are provided in an efficient and cost-effective manner. The analysis,
which studied OMWD, the Rancho Santa Fe Community Services District, and the City of San Diego
was accompanied by a Sphere of Influence Update. The project site is located within the OMWD’s
SOI and sewer service SOI.
In May 2005, the San Diego LAFCO adopted the update, which was affirmed in August 2007 and June
2013. A special district may only provide those activities described in its principal act. Those services
are further restricted by LAFCO’s responsibility to regulate latent powers (i.e., the services or
functions authorized by the principal act, but not currently exercised by the district). Consequently,
the project would require a reorganization consisting of an expansion of latent powers for sewer
service and the annexation of the project site to OMWD and the district’s sewer service area.
Approval of the proposed approximately 41.48-acre reorganization to the OMWD sewer service area
would increase the geographic area for OMWD to exercise latent powers for sewer service and
annex the same territory to OMWD (Figure 3-6).
FIGURE 3-1
Black Mountain Ranch Subarea I
M:\JOBS5\8958\env\graphics\EIR\fig3-1.ai 06/27/19
Map Source: City of San Diego
FIGURE 3-2
Black Mountain Ranch Subarea Plan Designations
M:\JOBS5\8958\env\graphics\EIR\fig3-2.ai 06/27/19
Map Source: City of San Diego
FIGURE 3-3Site and Grading PlanMap Source: Project Design Consultants (2019)M:\JOBS5\8958\env\graphics\EIR\fig3-3.ai 10/28/19SITE VISIBILITY DETAILFOR INTERNAL PRIVATE DRIVESNTS
FIGURE 3-4Landscape Concept PlanMap Source: Project Design Consultants (2019)M:\JOBS5\8958\env\graphics\EIR\fig3-4.ai 10/28/1943434R3R4R1R1211243R4R3R1R1211234R3R4R1R1211211243R4R3R4R1R12R1R12R1R121121121123R
4R 3
434R21R12R1R12R3R4343421R12R1R12R1R12R4R3434321R12R1R3R43424IMPROVEMENTS SUCH AS DRIVEWAYS, UTILITIES, DRAINS, ANDWATER/SEWER LATERALS SHALL BE DESIGNED SO AS NOT TO PROHIBITTHE PLACEMENT OF STREET TREES, ALL TO THE SATISFACTION OF THECITY.ORNAMENTAL LANDSCAPE AREAS WILL BE SERVED BY A PERMANENT,AUTOMATIC MULTIPLE- VALVE IRRIGATION SYSTEM. THIS SYSTEM WILL USELOW PRECIPITATION HEADS, SEGREGATED BASED ON PLANT MATERIAL TYPEAND ASPECT, AND BE DESIGNED TO MINIMIZE OVERSPRAY ONTO ANY NATIVEAREAS, HARDSCAPE SURFACE. RECYCLED WATER MAY BE USED, IFAVAILABLE.PERMANENT IRRIGATION WILL BE PROVIDED FOR THE REQUIRED STREETTREES AND INTERIOR SLOPES PER THE PLANT LEGEND SHEET.TEMPORARY IRRIGATION WILL BE PROVIDED FOR THE PERIMETER SLOPES TOREVEGETATE AND STABILIZE THE SLOPES FOR EROSION CONTROL.PROPOSED IRRIGATION SYSTEMS WILL USE AN APPROVED RAIN SENSORSHUTOFF DEVICE..MINIMUM 24-INCH BOX SIZE STREET TREES SHALL BE INSTALLED IN THEPUBLIC RIGHT-OF-WAY. TREE PLANTING AREAS SHALL HAVE A MINIMUM 40SQUARE FEET OF AIR-AND-WATER, PERMEABLE AREA.INSTALL ALL APPROVED LANDSCAPE AND OBTAIN ALL REQUIREDLANDSCAPE INSPECTION FORMS. COPIES OF THESE APPROVEDDOCUMENTS MUST BE SUBMITTED TO THE CITY.PERMANENT MONUMENT SIGNAGE MAYBE PROPOSED BY THEDEVELOPER.NO IMPROVEMENTS, INCLUDING ENHANCED PAVING, IRRIGATION ANDLANDSCAPING, SHALL BE INSTALLED IN OR OVER ANY EASEMENT PRIORTO THE APPLICANT OBTAINING AN ENCROACHMENT MAINTENANCE ANDREMOVAL AGREEMENT.ALL LANDSCAPE AND IRRIGATION SHALL CONFORM TO THE CITY OF SANDIEGO LANDSCAPE REGULATIONS AND CITY OF SAN DIEGO LANDDEVELOPMENT MANUAL LANDSCAPE STANDARDS AND ALL REGIONALSTANDARDS FOR LANDSCAPE INSTALLATION AND MAINTENANCE.THE PALETTE OF LANDSCAPE PLANT MATERIALS WILL PROVIDEVARIATIONS OF FOLIAGE, BARK, AND FLOWER FORM, TEXTURE, ANDCOLOR. THESE VARIATIONS WILL BE USED TO BLEND IN WITH EXISTINGSURROUNDING LANDSCAPE TREATMENTS ESPECIALLY AT PERIMETERSLOPES.TREE ROOT BARRIERS SHALL BE INSTALLED WHERE TREES ARE PLACEDWITHIN 5 FEET OF PUBLIC IMPROVEMENTS INCLUDING WALKS, CURBS, ORSTREET PAVEMENT OR WHERE NEW PUBLIC IMPROVEMENTS ARE PLACEDADJACENT TO EXISTING TREES. ROOT BARRIERS WHICH WRAP AROUNDTHE ROOT BALL ARE NOT PERMITTEDMULCH: ALL REQUIRED PLANTING AREAS SHALL BE COVERED WITH MULCHTO A MINIMUM DEPTH OF 2 INCHES, EXCLUDING SLOPES REQUIRINGREVEGETATION AND AREAS PLANTED WITH GROUND COVER. ALL EXPOSEDSOIL AREAS WITHOUT VEGETATION SHALL ALSO BE MULCHED TO THISMINIMUM DEPTH.PLANT MATERIALS SPECIFIED FOR USE ON THIS PROJECT WILL BE FROMTHE PALETTE OF PLANTS KNOWN TO PERFORM WELL IN THIS CLIMATICZONE AND AMENDED SOIL TYPE.LANDSCAPE PLANTING AREAS WILL BE GRADED TO ASSURE POSITIVESURFACE DRAINAGE.ONSITE SOILS WILL BE AMENDED TO COMPLY WITH THE RECOMMENDATIONOF A CERTIFIED SOILS TESTING LABORATORY.ALL SLOPE ASPECTS 2:1 OR STEEPER SHALL RECEIVE JUTE MATTING(OR PER THE RECOMENDATION BY THE GEO-TECHNICAL ENGINEER).LANDSCAPE DESIGN OBJECTIVES:IRRIGATION:NOTES:NO TREES OR SHRUBS EXCEEDING THREE FEET IN HEIGHT AT MATURITYMAY BE LOCATED WITHIN TEN FEET OF ANY SEWER FACILITIES.1.2.3.4.5.1.2.3.4.5.6.7.8.9.20 FEET5 FEET10 FEET10 FEET25 FEET10 FEETTRAFFIC SIGNAL, STOP SIGNUDERGROUND UTILITY LINESABOVE GROUND UTILITY STRUCTURESDRIVEWAYSINTERSECTIONSSEWERSMINIMUM TREE SEPARATION DISTANCE:DESIGN STATEMENT:MAINTENANCE NOTE:THE PRIMARY GOAL OF THE LANDSCAPE DESIGN IS TO BLEND ANDCOMPLIMENT THE EXISTING NATIVE PLANTING IN THE AREA. NATIVELOW FUEL VOLUME SPECIES WILL BE USE TO RE-VEGETATE THEGRADED SLOPES. THE TREATMENT FOR THE INTERIOR SHALLPRIMARILY BE PARKWAY STREET TREES AND GROUNDCOVER,ORNAMENTAL IN NATURE, FIRE-RESISTENT, AND COMPLIMENT THEBUILDING ARCHITECTURE. THE RECREATION AREA WILL BE MIX OFORNAMENTAL AND NATURALIZED MATERIAL AND LOW MAINTENANCE.ALL REQUIRED COMMON LANDSCAPE AREAS SHALL BE MAINTAINEDBY THE HOMEOWNERS ASSOCIATION. THE LANDSCAPE AREAS SHALLBE MAINTAINED FREE OF DEBRIS AND LITTER AND ALL PLANTMATERIAL SHALL BE MAINTAINED IN A HEALTHY GROWING CONDITION.DISEASED OR DEAD PLANT MATERIAL SHALL BE SATISFACTORILYTREATED OR REPLACED PER THE CONDITIONS OF THE PERMIT.GRADING NOTES:1. PERMANENT REVEGETATION - ALL GRADED, DISTURBED, ORERODED AREAS THAT WILL NOT BE PERMANENTLY PAVED ORCOVERED BY STRUCTURES SHALL BE PERMANENTLY REVEGETATEDAND IRRIGATED AS SHOWN IN TABLE 142-04F AND IN ACCORDANCEWITH THE STANDARDS IN THE LAND DEVELOPMENT MANUAL2. TEMPORARY REVEGETATION - GRADED, DISTURBED, OR ERODEDAREAS THAT WILL NOT BE PERMANENTLY PAVED, COVERED BYSTRUCTURE, OR PLANTED FOR A PERIOD OVER 90 CALENDAR DAYSSHALL BE TEMPORARILY REVEGETATED WITH A NON-IRRIGATEDHYDROSEED MIX, GROUND COVER, OR EQUIVALENT MATERIAL.TEMPORARY IRRIGATION SYSTEMS MAY BE USED TO ESTABLISH THEVEGETATION.3. ALL REQUIRED REVEGETATION AND EROSION CONTROL SHALL BECOMPLETED WITHIN 90 CALENDAR DAYS OF THE COMPLETION OFGRADING OR DISTURBANCE.4. INTERIM BINDER NOTE: GRADED, DISTURBED OR ERODED AREASTO BE TREATED WITH A NON-IRRIGATED HYDROSEED MIX ANDINTERIM BINDER / TACKIFIER AS NEEDED BETWEEN APRIL 2ND ANDAUGUST 31ST FOR DUST-EROSION CONTROL WITH SUBSEQUENTAPPLICATION OF HYDROSEED MIX DURING THE RAINY SEASONBETWEEN OCTOBER 1ST AND APRIL 1ST.RE-VEGETATED SLOPES 241,124 SF or (5.53 Acres)INTERIOR SLOPED AREAS 40,595 SFRECREATION AREA 5,906 SFPARKWAY AREAS 8,935 SFWATER QUALITY BASIN 31,324 SFDEVELOPER INSTALLED LANDSCAPE AREASSTREET TREES SHALL HAVE A 40 S.F. ROOT ZONE AREA(10' FROMUNDERGROUND SEWER & 5' FROM UNDERGROUND WATERUTILITIES) OR IF CONFLICTS ARISE THE TREES SHALL BELOCATED ON THE RESIDENTIAL LOT.STREET TREES:STREET TREE NOTE:IMPROVEMENT SUCH AS DRIVEWAYS UTILITIES, DRAINS ANDWATER SEWER LATERALS SHALL BE DESIGNED SO AS NOT TOPROHIBIT THE PLACEMENT OF STREET TREES, ALL TO THESATISFACTION OF THE DEVELOPMENT SERVICES DEPARTMENT.PROPOSED WALLFINISH GRADEBACKFILL MIXROOTBALL-SET AS SLOSE TO STRUCTRURE AS POSSIBLEPLACE ROOTBALL TO ACCOMODATEFTG. WHERE OCCURSSEE GRADING PLANSFOR HEIGHT OR PER EXISTING CONDITIONSFILL 12" THICKDRAINAGE AGGREGATE12" THICKAPPROXIMATE EXCAVATIONLINEVINE PLANTED AT TOP OF WALLPLANTING ALONG WALLNOTE:1. CONTRACTOR SHALL IRRIGATE FROM THE TOP OF WALL AND FROMBOTTOM OF WALL.2)ALL PLANTING PROVIDED SHALL PROVIDE 80% SCREENING OF THE WALLWITHIN TWO YEARS.REVEGETATED SLOPESINTERIOR SLOPED AREASPUBLIC STREET SIDEWALKSPARKWAY AREASWATER QUALITY BASINSTREAM BEDCONCEPTUAL LANDSCAPE PLANRECREATION AREA ENLARGEMENT3-RAIL FENCE - CONCRETEW/ WOOD GRAIN3-RAIL FENCE - CONCRETEW/ WOOD GRAINPARK SCALE SHADE TREESCOMMUNITY LOOK-OUT W/BENCHES SET INDECOMPOSED GRANITE5' DECOMPOSED GRANITEWALKWAYDOG PARK- LARGE AND SMALL DOGPENS W/ STAGING AREAS- METAL PICKET FENCE ANDGATES- ARTIFICIAL TURFSINGLE VIEWING BENCHNTSRECREATION AREA, SEEENLARGEMENT THIS SHEETEXISTING MHPA BOUNDARYLANDSCAPE CONCEPT PLANPUMP STATIONTYPICAL STREETSCAPE AND EXCLUSIVE USE AREANTSRESIDENTIAL EXCLUSIVEUSE AREABLOCK WALL ALONGSTREET SIDE UNITSMETAL PICKET VIEWFENCE AT TOP OFSLOPESNON-COMBUSTABLEWOOD OR VINYLSIDEYARD FENCEREMAINING LANDSCAPINGOUTSIDE OF RESIDENTIALEXCLUSIVE USE AREAS TOBE MAINTAINED BY HOAGLASS AND BLOCK VIEWFENCE ALONG UNITSADJACENT TO OPEN SPACEPUBLIC STREETSEE TYPICAL EXCLUSIVEUSE & FENCE LAYOUTENLARGEMENT THIS SHEETVIEWVIE
W
VIE
W
LARGE BOULDER WITHHISTORIC PLAQUE ORENGRAVING FOR THEDEBEVOISE FAMILY* TREES WITHIN ZONE 1 SHALL BE LOCATED A MINIMUM OF 10' AWAY FROM THE STRUCTURE PER THE BRUSH MANAGEMENT CODE.NO DIRECT ACCESS TO THE MHPA IS PROPOSED . WHERE NOFENCE EXISTS, SIGNAGE WILL BE PROVIDED IDENTIFYING THATENTRANCE INTO THE MHPA IS PROHIBITED.MHPA ACCESS NOTE:ADA ACCESS ROUTE TOCOMMON AREAPER SDMC 143.0143(d) DISTURBED PORTIONS OF THE SITE IN 25 PERCENT(4 HORIZONTAL FEET TO 1 VERTICAL FOOT) OR GREATER SLOPES SHALLBE REVEGETATED OR RESTORED IN ACCORDANCE WITH CHAPTER 14,ARTICLE 2, DIVISION 4 (LANDSCAPE REGULATIONS).10.ROLL UP GARAGE DOOR2 CAR GUEST PARKING2 CAR GARAGE PARKINGSTREET TREE- PER PLANT PALETTE- PER BMR SUB-AREA PLANSTORAGE AREA- TRASH, RECYCLE, AND GREEN WASTECOMMUNITY SIDEWALK- 5' WIDE CONCRETE WITH BROOM FINISHWALKWAY ACCESSTO EXCLUSIVE USEPRIVATE DRIVEWAYPROHIBITIVE ENTRANCEINTO MHPA SIGNAGE WILLBE PROVIDED, TYP.RANITEKAND SMALL DOGSTAGING AREASPICKET FENCE ANDAL TURFTYPICAL STREETSCAPE AND EXCLUSIVE USE AREANTSRESIDENTIAL EXCLUSIVEUSE AREABLOCK WALL ALONGSTREET SIDE UNITSMETAL PICKET VIEWFENCE AT TOP OFSLOPESNON-COMBUSTABLEWOOD OR VINYLSIDEYARD FENCEREMAINING LANDSCAPINGOUTSIDE OF RESIDENTIALEXCLUSIVE USE AREAS TOBE MAINTAINED BY HOAGLASS AND BLOCK VIEWFENCE ALONG UNITSADJACENT TO OPEN SPACEPUBLIC STREETVIEW* TREES WITHIN ZONE 1 SHALL BE LOCATED A MINIMUM OF 10' AWAY FROM THE STRUCTURE PER THE BRUSH MANAGEMENT CODE.ROLL UP GARAGE DOOR2 CAR GUEST PARKING2 CAR GARAGE PARKINGSTREET TREE- PER PLANT PALETTE- PER BMR SUB-AREA PLANSTORAGE AREA- TRASH, RECYCLE, AND GREEN WASTECOMMUNITY SIDEWALK- 5' WIDE CONCRETE WITH BROOM FINISHWALKWAY ACCESSTO EXCLUSIVE USEPRIVATE DRIVEWAYLENGTH OFDRIVEWAY 18’ MIN.
FIGURE 3-5a
Existing MHPA Boundary
Image Source: NearMaps (flown February 2019)
0 200Feet [
Project Boundary
Existing MHPA Boundary
Jurisdictional Waters
Wetland Waters
Non-wetland Water/Streambed
Vegetation Community/Land Cover Type
Coastal Sage Scrub
Disturbed Land
Freshwater Marsh
Non-native Grassland
Southern Mixed Chaparral
M:\JOBS5\8958\common_gis\fig3_5a_EIR.mxd 9/10/2019 bma
FIGURE 3-5b
Proposed MHPA Boundary Line Adjustment
Image Source: NearMaps (flown February 2019)
0 200Feet [
Project Boundary
Limit of Disturbance
MHPA Addition
MHPA Deletion
Existing MHPA Boundary
Jurisdictional Waters
Wetland Waters
Non-wetland Water/Streambed
Vegetation Community/Land Cover Type
Coastal Sage Scrub
Disturbed Land
Freshwater Marsh
Non-native Grassland
Southern Mixed Chaparral
M:\JOBS5\8958\common_gis\fig3_5b_EIR.mxd 9/10/2019 bma
0 0.3 0.60.15MilesL e g e n dParcelsOlivenhain MWD Sewer Service AreaOlivenhain MWD Sewer Service Area SOIOlivenhain MWD SOISANGIS.TOPO_40ftOlivenhain MWDFIGURE 3-6Proposed Avion Project MWD ReorganizationMap Source: San Diego LAFCO 2015M:\JOBS5\8958\env\graphics\EIR\fig3-6.ai 06/27/19Project Boundary
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Avion Project SEIR
Page 4-1
Chapter 4
History of Project Changes
As described in Section 3.1, the project site is located within the area referred to as the “Southeast
Perimeter” properties by the Subarea Plan. The project site consists of Parcel C of the Southeast
Perimeter properties, totaling 41.48 acres. Parcel C is designated to allow for development of 117
dwelling units, including a requirement for 19 affordable units. However, initial review of the project
site in 2017 determined that existing site constraints such as steep slopes and sensitive biological
resources made full buildout of the parcel with 117 detached multi-family residential units
infeasible. Similarly, the isolated location of the parcel southwest of existing and proposed
commercial uses made the project site unsuitable for development of affordable housing units.
Therefore, the project applicant designed the project to construct 84 detached multi-family units on-
site and transfer the remaining density (14 market-rate units and 19 affordable housing units) to the
Black Mountain Ranch North Village Town Center. The reduced density of the project would allow for
development of 84 detached multi-family units based on the existing site topography, and the
transfer of the 19 affordable housing units to the Black Mountain Ranch North Village Town Center
would ensure that these units would be located closer to existing commercial uses.
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Chapter 5
Environmental Analysis
All environmental issues analyzed in the 1998 Subarea Plan Environmental Impact Report (EIR) were
considered during initial review of the project. Through City of San Diego (City) review of the project
and comments received in response to the Notice of Preparation, the following issues were
determined to either: (1) lack a site-specific impact analysis and/or adequate mitigation for project
impacts; or (2) result in new impacts that may be potentially significant and require subsequent
analysis and/or mitigation as part of this Supplemental Environmental Impact Report (SEIR):
• Land Use (Land Development Code [LDC] Compliance, Multiple Species Conservation
Program [MSCP] Consistency);
• Biological Resources;
• Cultural Resources;
• Landform Alteration/Visual Quality (Landform Alteration);
• Noise (construction); and
• Air Quality (construction).
This chapter analyzes the potentially new environmental impacts that may occur as a result of project
implementation. Each section within this chapter includes an environmental issue that has been
identified for this project and addresses the issues from the 1998 EIR that require supplemental analysis.
The issue analyses include a summary of existing conditions; the criteria for the determination of impact
significance; evaluation of potential project impacts; a list of required mitigation measures if applicable,
and conclusion of significance after mitigation for impacts identified as requiring mitigation.
All potential direct and indirect impacts are evaluated in relation to applicable City, state, and federal
standards, as reflected in the City’s Significance Determination Thresholds, and include City goals
and standards in compliance with the City General Plan (2008).
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5.1 Land Use
This section evaluates potential land use impacts associated with the project in relation to land uses,
policies, and regulations applicable to the project.
5.1.1 Relationship to the Black Mountain Ranch
(Subarea I) Subarea Plan
The analysis in this section updates the land use analysis in the 1998 Environmental Impact Report
(EIR), with an emphasis on effects that were not addressed in the previous report. Because no site-
specific design was proposed at the time the 1998 EIR was prepared, issues regarding Land
Development Code (LDC) deviations and Multiple Species Conservation Program (MSCP) consistency
could not be analyzed in detail for the perimeter properties, and impacts were assumed to be
potentially significant. Therefore, this section provides a site-specific analysis of LDC and MSCP
consistency relative to the project. Other issues related to land use were adequately analyzed as
part of the 1998 EIR, to which this Supplemental EIR (SEIR) is tiered. Those issues are summarized in
Chapter 9.0.
5.1.2 Existing Conditions
The project site is undeveloped and located within the Black Mountain Ranch Subarea in the
northern portion of the city of San Diego. The project site is located at the upper end of a broad
north-south trending valley. A ridgeline occurs in the central portion of the site that rises in elevation
from north to south from 740 feet mean sea level to 915 feet mean sea level. The ridge is bounded
by two small canyons, one to the east and one to the west, with one main drainage course and
smaller tributaries in each. These drainages have slopes of moderate to steep grade. There is a
small meadow in the northwest corner of the property, at the mouth of the eastern drainage.
5.1.2.1 Land Use Context
The project site is currently zoned as Agricultural – Residential (AR-1-1). Approximately 22.51 acres of
the project site have been designated as Low Residential (2–5 dwelling unit/acre) in the Black
Mountain Ranch (Subarea I) Subarea Plan and the remainder of the site as Resource Based Open
Space. The project site is within the City of San Diego’s (City’s) MSCP, and approximately 18.97 acres
of the project site are included in the Multi-Habitat Planning Area (MHPA). The MHPA boundary
surrounds the area to be developed.
5.1.2.2 Surrounding Land Uses
Figure 5.1-1 shows the existing land use designations surrounding the project site. Land uses
surrounding the project site include a portion of the Black Mountain Open Space Park to the west,
east, and south, and the Heritage Bluffs residential development to the north, and additional Black
Mountain Open Space Park open space lands to the northwest.
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The Black Mountain Ranch Subarea encompasses 5,098 acres and is generally bounded on the west,
north, and east by unincorporated areas of San Diego County. The 4S Ranch and Santa Fe Valley
Specific Plan areas form a portion of this county land. On the east, southeast, and south, the Black
Mountain Ranch Subarea is bounded by the Rancho Peñasquitos and Rancho Bernardo Community
Planning Areas and Subarea IV Torrey Highlands.
5.1.3 Regulatory Framework
5.1.3.1 City of San Diego General Plan
State law requires each city to adopt a general plan to guide its future development, and mandates
that the plan be periodically updated to assure its continuing relevance and value (State Planning
and Zoning Law, California Government Code, Section 65300). State law also requires the inclusion
of seven mandatory elements into the General Plan (land use, circulation, housing, conservation,
noise, open space, and safety) but permits flexibility and the inclusion of optional elements to best
meet the needs of a particular city.
The City’s General Plan sets forth a comprehensive, long-range vision and policy framework to guide
future development within the City. A comprehensive update of the City’s General Plan was adopted
March 10, 2008 and was based on a new planning strategy for the City developed in the 2002
Strategic Framework Element. Known as the City of Villages strategy, the General Plan aims to
redirect development away from undeveloped lands and toward already urbanized areas and/or
areas with conditions allowing the integration of housing, employment, civic, and transit uses. This
development strategy mirrors regional planning and smart growth principles intended to preserve
remaining open space and natural habitat and focus development within areas with available public
infrastructure.
5.1.3.2 Black Mountain Ranch Subarea Plan
The Black Mountain Ranch (BMR) Subarea Plan constitutes Subarea I of the former North City Future
Urbanizing Area (NCFUA) Framework Plan, and consists of approximately 5,098 acres of land. The
goal of the land use element is to create a pattern of land use and conservation that is clearly
distinguishable from surrounding communities and that fosters appealing and enjoyable
neighborhoods and business districts. The land use element of the BMR Subarea Plan focuses
development in two villages surrounded by significant open space, recreational amenities, and low-
density development. Overall, the Subarea Plan allows for development of 5,400 residential units on
1,395 acres, 235 acres of non-residential development, and 3,065 acres of open space. The
remaining acreage is identified for development of streets. The majority of the Subarea Plan has
been built out, with only a small number of planned residential and non-residential units yet to be
developed. The project site is within the area of the Subarea Plan referred to as the “Southeast
Perimeter” properties, which are composed of four parcels (A, B, C, and D). The project site consists
of Parcel C, totaling 41.48 acres, and is designated for 117 dwelling units.
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5.1.3.3 Land Development Code
a. Environmentally Sensitive Land Regulations
On January 1, 2000, Environmentally Sensitive Lands (ESL) Regulations were adopted by the San
Diego City Council as a part of the LDC. The purpose of the ESL Regulations is to protect and
preserve environmentally sensitive lands and the viability of the species supported by those lands.
The regulations are intended to assure that development occurs in a manner that protects the
overall quality of the resources and the natural and topographic character of the area. It is further
intended that the development regulations for ESL, which include guidelines for biology, flood
hazard areas, steep hillsides, and coastal bluffs and beaches, serve as standards for the
determination of impacts and mitigation. Within the project site, ESL development regulations apply
to sensitive biological resources, such as coastal sage scrub, southern mixed chaparral, and
wetlands, which are discussed in detail in Section 5.2 below.
According to the ESL regulations, development that proposes encroachment into steep hillsides is
subject to Municipal Code §143.0142 Development Regulations for Steep Hillsides, and the Steep
Hillside Guidelines in the Land Development Manual. Outside of the MHPA, the allowable
development area includes all portions of the premises without steep hillsides. The regulations state
that steep hillsides shall be preserved in their natural state, except that development is permitted in
steep hillsides if necessary to achieve a maximum development area of 25 percent of the premises.
Development encroachment into steep hillsides and sensitive biological resources within the MHPA
is restricted. Development within the MHPA beyond the allowed 25 percent would require a MHPA
boundary line adjustment. A Site Development Permit (SDP) is required for projects proposing to
impact any ESL.
b. Historical Resources Regulations
The purpose of the City’s Historical Resources Regulations, found in Section 143.0251 of the LDC, is
to protect, preserve, and, where damaged, restore the historical resources of San Diego, which
include historical buildings, historical structures or objects, important archaeological sites, historical
districts, historical landscapes, and traditional cultural properties. These regulations are intended to
assure that development occurs in a manner that protects the overall quality of historical resources.
The Historic Resources Regulations require that development affecting designated historical
resources or historical districts shall provide full mitigation for the impact to the resource, in
accordance with the Historical Resources Guidelines of the Land Development Manual, as a
condition of approval. If development cannot, to the maximum extent feasible, comply with the
development regulations for historical resources, then a project would require a permit.
5.1.3.4 Multiple Species Conservation Program Subarea Plan
The MSCP is a comprehensive, long-term habitat conservation planning program that covers
approximately 900 square miles in southwestern San Diego County under the federal and state
Endangered Species Acts and state Natural Community Conservation Planning (NCCP) Act of 1991.
Local jurisdictions, including the City, implement their portions of the regional umbrella MSCP
through subarea plans, which describe specific implementing mechanisms. The City’s MSCP Subarea
5.0 Environmental Analysis 5.1 Land Use
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Plan was approved in March 1997 and covers approximately 206,000 acres within the City’s
jurisdictional boundary. The City, U.S. Fish and Wildlife Service (USFWS) and the California
Department of Fish and Wildlife have signed an MSCP Implementing Agreement that allows the City
to issue incidental take authorizations for “MSCP Covered” species. The MSCP identifies
approximately 57,000 acres as MHPA that is considered to be 90 percent conserved in order to
adequately preserve habitat for the MSCP covered species.
MHPA lands are those that have been included within the City’s MSCP Subarea Plan for habitat
conservation. These lands have been determined to provide the necessary habitat quality, quantity,
and connectivity to sustain the unique biodiversity of the San Diego region. MHPA lands are
considered by the City to be a sensitive biological resource.
MHPA lands once occurred over the majority of the project site. In 1998, the Subarea Plan EIR
evaluated whether the project site (Southeast Perimeter Parcel C) and several other perimeter
properties would impact the MHPA. As part of this subarea plan, an MHPA Boundary Line
Adjustment (BLA) was approved that reconfigured the MHPA boundary over the project site to
further exclude portions of the central ridge and lower flat land, while still including the canyons to
the east and west of the ridge. Approximately 18.97 acres of the project site are included within the
City’s MHPA as a result of the BLA approved for the Subarea Plan.
The MSCP Subarea Plan northern area has four general guidelines, none of which apply to the
project site. Land uses that are considered compatible with the objectives of the MSCP and which
are permitted uses in MHPA open space include:
• passive recreation;
• utility lines and roads (must adhere to MHPA construction and maintenance policies);
• limited water facilities and essential public facilities;
• limited low-density residential use;
• brush management zone-2; and
• limited agriculture.
For properties that are entirely within the MHPA, allowable development of up to 25 percent of the
site can occur. San Diego's MSCP Subarea Plan states that adjustments to the MHPA boundary line
are permitted without the need to amend San Diego's Subarea Plan, as discussed below.
a. Boundary Line Adjustment
An MHPA BLA may be requested by projects to move the MHPA boundary, as long as the adjustment
provides an equivalent MHPA. The MHPA BLA requires approval from the City and Wildlife Agencies.
For an MHPA BLA to be considered, it must meet six functional equivalency criteria to demonstrate
the habitat conveyed is of equal or higher value. The comparison of biological value must analyze
the following:
1. Effects on significantly and sufficiently conserved habitats (i.e., the exchange maintains or
improves the conservation, configuration, or status of significantly or sufficiently conserved
habitats);
5.0 Environmental Analysis 5.1 Land Use
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2. Effects to covered species (i.e., the exchanges maintains or increases the conservation of
covered species
3. Effects on habitat linkages and function of preserve areas (i.e., the exchange results in
similar or improved management efficiency and/or protection for biological resources);
4. Effects on preserve configuration and management (i.e., the exchange results in similar or
improved management efficiency and/or protection for biological resources);
5. Effects on ecotones or other conditions affecting species diversity (i.e., the exchange
maintains topographic or structural diversity and habitat interfaces of the preserve); and/or
6. Effects to species of concern not on the covered species list (i.e., the exchange does not
significantly increase the likelihood that an uncovered species will meet the criteria for
listing under either the federal or state Endangered Species Acts; City of San Diego 1998).
b. Land Use Adjacency Guidelines
The City’s MSCP Subarea Plan provides Land Use Adjacency Guidelines to avoid or reduce significant
indirect impacts to MHPAs from adjacent land uses. The Land Use Adjacency Guidelines include
drainage, lighting, noise, and slope grading recommendations for adjacent development, as well as
recommendations for avoiding or redirecting toxic chemicals (e.g., from landscape or agricultural
fertilization) and prohibition of the planting of invasive species.
Section 1.4.3 of San Diego MSCP Subarea Plan presents Land Use Adjacency Guidelines, as
summarized below. Section 1.5.2 of the MSCP provides general management recommendations to
implement these guidelines, as summarized below.
Drainage. All new and proposed parking lots and developed areas in and adjacent to the MHPA
must not drain directly into the MHPA. All developed and paved areas must prevent the release of
toxins, chemicals, petroleum products, exotic plant materials, and other elements that might
degrade or harm the natural environment or ecosystem processes within the MHPA.
Toxics. Land uses such as recreation and agriculture that use chemicals or generate by-products
that are potentially toxic or impactive to wildlife, sensitive species, habitat, or water quality, need to
incorporate measures to reduce impacts caused by the application and/or drainage of such
materials into the MHPA.
Lighting. Lighting of all developed areas adjacent to the MHPA should be directed away from the
MHPA. Where necessary, development should provide adequate shielding with non-invasive plant
materials (preferably native), berming, and/or other methods to protect the MHPA and sensitive
species from night lighting.
Noise. Uses in or adjacent to the MHPA should be designed to minimize noise impacts. Excessively
noisy uses or activities adjacent to breeding areas must incorporate noise reduction measures and
be curtailed during the breeding season of sensitive species.
5.0 Environmental Analysis 5.1 Land Use
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Barriers. New development adjacent to the MHPA may be required to provide barriers (e.g., non-
invasive vegetation, rocks/boulders, fences, walls and/or signage) along the MHPA boundary to
direct public access to appropriate locations and reduce domestic animal predation.
Invasives. No invasive non-native plant species shall be introduced into areas adjacent to the
MHPA.
Brush management. New residential development located adjacent to and topographically above
the MHPA (e.g., along canyon edges) must be set back from slope edges to incorporate Zone 1 brush
management areas on the development pad and outside of the MHPA. Zone 2 should be placed in
an open space easement that identifies a homeowners association or other private party that would
be responsible for the ongoing Zone 2 brush management activities. The amount of woody
vegetation thinning shall not exceed 50 percent of the vegetation existing when the initial thinning is
done. Additional thinning and pruning shall be done consistent with San Diego standards to obtain
minimum vertical and horizontal clearances and shall avoid/minimize impacts to covered species to
the maximum extent possible. For all new development, regardless of the ownership, the brush
management in the Zone 2 area would be the responsibility of a homeowners association or other
private party.
Grading/land development. Manufactured slopes associated with site development shall be
included within the development footprint for projects within or adjacent to the MHPA.
5.1.4 Issue 1: LDC Deviations
Would the project require a deviation or variance, and the deviation or variance would in turn result
in a physical impact on the environment?
5.1.4.1 Threshold
According to the City’s California Environmental Quality Act (CEQA) Significance Determination
Thresholds, land use compatibility impacts may be significant if the project would result in:
• Conflict with an adopted land use designation or intensity and indirect or secondary
environmental impacts could occur.
5.1.4.2 Impacts
The project is consistent with the underlying zone of RS-1-14 (Residential Single Unit, minimum
5,000-square-foot lots); however, a deviation from the applicable development regulations, for over-
height retaining walls outside of the required setback is being requested. The project is requesting
retaining walls with a maximum height of 55 feet, 7 inches that would be located along both sides of
the existing drainage channel, where Section §142.0340 of the Land Development Code requires
that the heights of retaining walls do not exceed 12 feet outside of required setbacks.
The retaining walls that would exceed the maximum height allowance would be located along both
sides of the existing drainage that would be crossed by the arch culvert allowing for the extension of
5.0 Environmental Analysis 5.1 Land Use
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Winecreek Drive. Implementation of these retaining walls would avoid encroachments into the
existing drainage that would otherwise occur if the project conformed to the maximum height
allowed by the RS-1-14 zone, thereby preventing impacts to sensitive wetlands.
The retaining walls would be downslope from the project and would not exceed the elevation of the
arch culvert or the development pad. As a result, the proposed retaining walls that would deviate
from the maximum height allowance would not be visible from the project site. Furthermore, the
proposed retaining walls would be developed with earth tones that would blend in with the
surrounding natural environment and would be landscaped with cascading vines at the top of the
walls that would extend downslope to provide an aesthetically pleasing appearance from views off-
site. Section 5.4, Landform Alteration/Visual Quality, addresses the over-height retaining walls; the
analysis concludes that a negative visual appearance would not be created by the over-height walls
proposed. The allowable deviation from the development regulations would not result in secondary
environmental impacts as they would not be substantial, and would occur internal to the project,
and not affect off-site areas.
5.1.4.3 Significance of Impacts
Proposed deviation from the base zone development regulations would not result in secondary
physical impacts as they would be internal to the project and not affect off-site areas. The retaining
walls would avoid impacts to wetlands and not result in any significant impacts related to visual
resources. Therefore, impacts would be less than significant.
5.1.4.4 Mitigation, Monitoring, and Reporting
Mitigation would not be required.
5.1.5 Issue 2: MSCP Consistency
• Would the proposal conflict with the provisions of the City’s MSCP Subarea Plan or other
approved local, regional, or state habitat conservation plan?
5.1.5.1 Threshold
According to the City’s Significance Determination Thresholds, land use impacts may be significant if
the project would be:
• Inconsistent or conflict with adopted environmental plans for an area.
5.1.5.2 Impacts
The project site lies within the Northern Area of the City MSCP Subarea Plan, and areas of the
project site are designated as MHPA (which is the City’s planned habitat preserve system). The MSCP
Subarea Plan provides guidelines for compatible uses within the MHPA, general planning policies,
design guidelines, and general management directives regarding issues such as mitigation,
5.0 Environmental Analysis 5.1 Land Use
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restoration, public access, trails and recreation, litter/trash storage, adjacency management issues,
exotics control, and flood control. Consistency with MSCP land use policies is summarized below,
with additional detail regarding biological impacts and mitigation provided in Section 5.2 below.
a. MHPA Boundary Line Adjustment
The current MHPA boundary in the vicinity of the project site is shown on Figure 3-5a. Minor
encroachments into the current MHPA boundary on the eastern portion of the site would occur
under the project (see Figure 3-5b). These encroachments would impact a total of 0.55 acre
comprised of 0.14 acre of coastal sage scrub, 0.27 acre of southern mixed chaparral, and 0.14 acre
of non-native grassland. Under the proposed MHPA BLA, these impact areas would be removed
from the current MHPA and on-site land not currently within the MHPA would be added into the
preserve. Land added into the MHPA with the BLA would include 5.61 acres comprised of 4.99 acres
of southern mixed chaparral, 0.49 acre of non-native grassland, and 0.13 acre of coastal sage scrub
(Table 5.1-1), resulting in a net gain of 5.06 acres.
Table 5.1-1
Summary of Proposed MHPA Boundary Line Adjustment
Vegetation Communities/
Land Cover Types
Existing MHPA
Acres
Deletions (Impact)
Acres
Added
Acres
Proposed MHPA
with BLA
(Net Change)
Coastal Sage Scrub 3.58 0.14 0.13 3.57 (-0.01)
Southern Mixed Chaparral 15.03 0.27 4.99 19.75 (+4.72)
Non-native Grassland 0.23 0.14 0.49 0.58 (+0.35)
Freshwater Marsh 0.13 -- -- 0.13 (0)
Disturbed Land -- -- -- --
TOTAL 18.97 0.55 5.61 24.03 (+5.06)
The overall MSCP policy for BLAs requires that they must transfer equal or higher biological values
of impacted species and habitats into the preserve. A comparison of the biological values of the
impacted areas and land to be transferred into the preserve is presented below. This comparison is
based on the six biological factors required by the MSCP for a MHPA BLA.
Effects on Significantly and Sufficiently Conserved Habitats
• The amount and distribution of habitats considered significantly and sufficiently conserved
within the preserve areas would be functionally equivalent to the impacted areas. The BLA
would also result in an increase in total area due to an increase in acreage of southern
mixed chaparral and non-native grassland. The areas of coastal sage scrub, southern mixed
chaparral, and non-native grassland conserved together on-site within the adjusted MHPA
would add approximately 5.06 acres of native habitat in excess of the amount of native
habitat deleted, resulting in increases in the area of significantly conserved Tier IIIA and IIIB
habitats within the MSCP subarea. The habitat value would be functionally higher relative to
the current MHPA, despite the minor loss (0.01 acre) of coastal sage scrub as there would be
a net gain of undisturbed native habitat to the MHPA. Thus, the proposed habitat exchange
5.0 Environmental Analysis 5.1 Land Use
Avion Project SEIR
Page 5.1-9
would maintain and slightly improve the conservation, configuration, and area of
significantly or sufficiently conserved habitats within this portion of the MHPA.
Effects to Covered Species
• The approved land exchange in this portion of the MHPA would maintain the overall
conservation of covered species, as no covered species occur within the area to be deleted
from the MHPA. The addition of southern mixed chaparral and non-native grassland
habitats within the lands to be added to the MHPA may increase habitat for covered species
that may occur in the vicinity of the project (e.g., coastal California gnatcatcher [Polioptila
californica californica], Cooper’s hawk [Accipiter cooperii]).
Effects on Habitat Linkages and the Function of Preserve Areas
• The project site is part of, and adjacent to, an existing open space area. Although it is
reasonable to assume that wildlife may currently move locally through the project area, the
site is somewhat restricted by residential development and paved roads in the Heritage
Bluffs II project to the northeast. Currently, local wildlife movement may occur on the Avion
site to the west, east, and south as the site is adjacent to MHPA lands within the
undeveloped Black Mountain Park Open Space. In addition, some local north-south wildlife
movement is possible along the ephemeral drainages that occur in the bottoms of the
canyons. The proposed private drive crossing of the eastern drainage would be constructed
as an arch culvert with a span of approximately 42 feet wide and 21 feet high, a span and
height that would continue to allow local wildlife movement through this area.
Although the Avion project would have minor affects to the existing habitat linkages to the
southwest of the Heritage Bluffs II project through the loss of habitat, the MHPA boundary
adjustment would offset this affect through the preservation of habitat linkages along the
west, east, and south sides of the project where newly added MHPA area would occur. The
addition of these conserved lands would preserve the local habitat linkages in these
directions.
Therefore, effects of the approved changes to the MHPA boundary would be negligible with
respect to the function of the preserve area and habitat linkages. All of the changes
approved are adjacent to a major wildlife corridor and associated linkages that would
remain intact with linkages present.
Effects on Preserve Configuration and Management
• The proposed modifications to the MHPA boundary do not change the proportions or
decrease the total area of the MHPA. The minor changes in shape or length of edges of the
MHPA boundary are due to relatively small encroachments by the project. These minor
encroachments into the MHPA would be offset by gains in native habitat acreage primarily
on the southern portion of the site. The resulting MHPA preserve area configuration would
be similar to the pre-construction condition and include the addition of land to the MHPA.
The approved changes to the MHPA boundary would not conflict with any of the previously
5.0 Environmental Analysis 5.1 Land Use
Avion Project SEIR
Page 5.1-10
identified conservation or management needs for the subarea or cause the need for
additional measures.
Effects on Ecotones or Other Conditions Affecting Species Diversity
• The proposed changes to the MHPA boundary at this location would improve the extent of
open space and local habitat linkages to the surrounding MHPA preserve lands. These
modifications to the MHPA would maintain the local topographic and structural diversity of
the preserve while slightly improving the habitat interfaces along the southern, western, and
eastern project site borders over the current preserve design at this portion of the MHPA.
Effects to Species of Concern Not Covered under the MSCP
• The proposed MHPA BLA at this location would not significantly increase the likelihood that
any uncovered species would be listed under either the federal or state Endangered Species
Act. The observed nest of the San Diego woodrat would be avoided and the surrounding
habitat would be preserved in open space.
The proposed MHPA boundary line adjustment was approved by the Wildlife Agencies and City
MSCP on June 21, 2019. Once the boundary line adjustment is completed, no direct impacts or loss
of MHPA lands would result from the project. The proposed MHPA BLA would be beneficial to the
overall MHPA preserve at this location due to an increase in Tier IIIA and IIIB habitats and acreage of
preserved land. The minor losses of coastal sage scrub, southern mixed chaparral, and non-native
grassland habitats from encroachments into the current MHPA total 0.55 acre and would be offset
by additions of coastal sage scrub, southern mixed chaparral, and non-native grassland habitats into
the MHPA currently located within the southern portion of the project site totaling 5.06 acres. This
proposed land exchange complies with the overall MSCP policy for BLAs, as the approved BLA would
transfer equal or higher biological values of impacted species and habitats into the preserve.
b. Area Specific Management Directives
Measures to protect the MHPA are outlined in the MSCP and include general and specific guidelines
for development within and adjacent to the MHPA, and management and monitoring goals for
specific areas, habitat, and species. These guidelines are intended to preclude impacts, particularly
those related to urban edge effects which include (but are not limited to) trampling, dumping,
vehicular traffic, competition with invasive species (i.e., parasitism or predation from invasive animal
species and habitat degradation from introduction of non-native plant species), predation by
domestic animals, noise, collecting, recreational activities, and other human intrusion (City of San
Diego 1997). Appendix A of the MSCP (City of San Diego 1997) also outlines species specific
conditions of coverage for all covered species. These conditions of coverage are outlined in below.
5.0 Environmental Analysis 5.1 Land Use
Avion Project SEIR
Page 5.1-11
Belding’s Orange-throated Whiptail
The area-specific management directives (ASMDs) for Belding’s orange-throated whiptail must
address edge effects.
• To address edge effects, the entire development footprint shall be located outside of the
MHPA. Manufactured slopes adjacent to the MHPA would be steep and relatively high to
minimize potential edge effects and prevent encroachment into the MHPA. These slopes
would be revegetated with native species.
Cooper’s Hawk
The ASMDs for Cooper’s hawk include a 300-foot impact avoidance area around active nests, and
minimization of disturbance in oak woodlands and oak riparian forests.
• Should an active Cooper’s hawk, or raptor nest, be detected within the MHPA during the pre-
grading survey, discussed in Section 7.2.1, appropriate construction setback of 300 feet will
be implemented until the fledglings are independent of the nest.
Coastal California Gnatcatcher
For coastal California gnatcatchers, the ASMDs must include additional measures to reduce edge
effects and minimize disturbance during the nesting period, fire protection measures to reduce the
potential for habitat degradation due to unplanned fire, and management measures to maintain or
improve habitat quality including vegetation structure. No clearing of occupied habitat within the
City of San Diego’s MHPAs may occur during this species’ breeding season between March 1 and
August 15.
• The entire development footprint is outside of the MHPA. The manufactured slopes adjacent
to the MHPA would be steep, relatively high, and revegetated with native species; therefore,
the proposed project should not increase edge effects in the MHPA. A buffer occurs between
the development footprint and the MHPA which should help protect from accidental fires
spreading into the MHPA from the proposed project. As stated in the MHPA Adjacency
Guidelines under Brush Management, vegetation clearing will be done consistent with City of
San Diego standards and will avoid/minimize impacts to species such as the coastal
California gnatcatcher.
Southern California Rufous-crowned Sparrow
For this species, the management directive includes maintenance of dynamic processes, such a fire,
to perpetuate some open phases of coastal sage scrub with herbaceous components.
• The project would not alter the current dynamic processes, such as fire, as a buffer is
provided between the development footprint and the MHPA which should help protect from
accidental fires spreading into the MHPA from the proposed project.
5.0 Environmental Analysis 5.1 Land Use
Avion Project SEIR
Page 5.1-12
c. MHPA Adjacency
MHPA surrounds the project’s development footprint. As described in the MSCP, when land is
developed adjacent to the MHPA, there is a potential for indirect impacts, or edge effects, that may
degrade the habitat value or disrupt animals within the preserve area. These impacts could be
short-term, resulting from construction activities, or long-term. Short-term construction impacts
could result in disruption of nesting and breeding, and could thus affect the population of sensitive
species. Long-term impacts would be associated with drainage, toxins, lighting, noise, invasives,
brush management, access to MHPA, and grading/land development. Potential impacts to the
adjacent MHPA would include an increase in urban pollutants entering sensitive water bodies, an
increase in night lighting, habitat disturbance, removal of plant cover due to hiking, biking, and other
human activities, increased presence of toxins, increased presence of non-native and invasive plant
species, and pollutants (fugitive dust). Thus, projects adjacent to MHPA areas are subject to the
MHPA Land Use Adjacency Guidelines.
The project has the potential for indirect impacts to the adjacent MHPA along the western, eastern,
and southern boundaries. As stated in the MSCP Section 1.4.3 (City of San Diego 1997), land uses
adjacent to the MHPA are to be managed to ensure minimal impacts to the MHPA. The MSCP
establishes adjacency guidelines to be addressed on a project-by-project basis to minimize direct
and indirect impacts and maintain the function of the MHPA. The guidelines listed in Section 1.4.3 of
the MSCP (City of San Diego 1997) are outlined below with corresponding project action.
Implementation of the MHPA Land Use Adjacency Guidelines would become conditions of project
approval. Note that the discussion below first reiterates the MSCP MHPA Land Use Adjacency
Guideline (italicized text) and then analyzes the project’s compliance with the guideline.
Drainage
All new and proposed parking lots and developed areas in and adjacent to the preserve must not drain
directly into the MHPA. All developed and paved areas must prevent the release of toxins, chemicals,
petroleum products, exotic plant materials and other elements that might degrade or harm the natural
environment or ecosystem processes within the MHPA. This can be accomplished using a variety of
methods including natural detention basins, grass swales or mechanical trapping devices. These systems
should be maintained approximately once a year, or as often as needed, to ensure proper functioning.
Maintenance should include dredging out sediments if needed, removing exotic plant materials, and
adding chemical-neutralizing compounds (e.g., clay compounds) when necessary and appropriate (City of
San Diego 2013).
• The project has been designed so as to not drain directly into the MHPA. All drainage will be
treated on-site within the development footprint using detention/water quality basins to
dissipate/detain and filter/treat runoff. The runoff from the development (storm water,
irrigation, etc.), with the exception of the eastern fill slope, would be captured in storm
drains that flow to the bioretention basin located in the northern portion of the site. The
eastern fill slope would drain directly into the existing drainage course. Temporary irrigation
of this slope would occur during the establishment of native vegetation to stabilize the slope
and this supplemental irrigation would be discontinued within a couple of years. Irrigation
rates during this period could be adjusted to minimize any excess runoff.
5.0 Environmental Analysis 5.1 Land Use
Avion Project SEIR
Page 5.1-13
Toxics
Land uses, such as recreation and agriculture, that use chemicals or generate by-products such as
manure, that are potentially toxic or impactive to wildlife, sensitive species, habitat, or water quality need
to incorporate measures to reduce impacts caused by the application and/or drainage of such materials
into the MHPA. Such measures should include drainage/detention basins, swales, or holding areas with
non-invasive grasses or wetland-type native vegetation to filter out the toxic materials. Regular
maintenance should be provided. Where applicable, this requirement should be incorporated into leases
on publicly owned property as leases come up for renewal (City of San Diego 2013).
• The project would incorporate measures to reduce impacts caused by the application and/or
drainage of chemicals or project generated by-products such as pesticides, herbicides,
animal waste, and other substances that are potentially toxic or impactive to native
habitats/flora/fauna (including water) into the MHPA. All construction-related activity that
may have potential for leakage or intrusion shall be monitored by the Qualified
Biologist/Owner’s Representative or Resident Engineer to ensure there is no impact to the
MHPA. The project has been designed to limit post-development storm water runoff
discharge rates and velocities to maintain or reduce pre-development erosion and to reduce
nutrients, organic compounds, oxygen demanding substances, oil and grease, bacteria and
viruses, and pesticides by applying best management practices (BMPs).
Construction BMPs, such as monitoring, flagging, staking or silt/bio fencing around sensitive
areas would be used to ensure toxins from construction and project implementation would
not impact the MHPA.
Lighting
Lighting of all developed areas adjacent to the MHPA should be directed away from the MHPA. Where
necessary, development should provide adequate shielding with non-invasive plant materials (preferably
native), berming, and/or other methods to protect the MHPA and sensitive species from night lighting (City
of San Diego 2013).
• Lighting for the project would be shielded and/or directed away from the MHPA. Lighting for
the project would be responsive to the species in the area as well as the overall rural
surroundings. Understanding that some species rely on darkness for shelter, feeding
patterns, migrating, etc., the areas adjacent to any MHPA would be especially sensitive to
light exposure in order to retain native characteristics. Placement and use of lighting
associated with the project would be designed to be shielded and directed downward to
minimize light pollution of adjacent MHPA lands and accommodate the habits of nocturnal
species that prefer to move and forage in darkness.
Additionally, the MHPA is located at the bottom of a manufactured slope and there would be
a 20- to 30-foot elevation difference from the project. Any lighting for the project at the top
of the slope would be shielded and directed away from the MHPA such that no direct
illumination would occur towards the MHPA.
5.0 Environmental Analysis 5.1 Land Use
Avion Project SEIR
Page 5.1-14
Noise
Uses in or adjacent to the MHPA should be designed to minimize noise impacts. Berms or walls should be
constructed adjacent to commercial areas, recreational areas, and any other use that may introduce
noises that could impact or interfere with wildlife utilization of the MHPA. Excessively noisy uses or
activities adjacent to breeding areas must incorporate noise reduction measures and be curtailed during
the breeding season of sensitive species. Adequate noise reduction measures should also be incorporated
for the remainder of the year (City of San Diego 2013).
There is suitable Diegan coastal sage scrub habitat within the MHPA in the northwestern and
northeastern portions of the site to support coastal California gnatcatcher. Protocol surveys
shall be conducted to determine the presence or absence of this sensitive bird species if
construction occurs within its breeding season noted above. If coastal California gnatcatcher
is present within the MHPA, construction noise levels at the MHPA boundary shall not
exceed 60 A-weighted decibels. Additionally, development adjacent to the MHPA has been
designed to minimize noise impacts to coastal California gnatcatcher. A benefit of the project
design is the MHPA is at a lower elevation than the entire project site; therefore, it is not
anticipated that the MHPA will be impacted by excessive noise.
Brush Management
New residential development located adjacent to and topographically above the MHPA (e.g., along canyon
edges) must be set back from slope edges to incorporate Zone 1 brush management areas on the
development pad and outside of the MHPA. Zones 2 and 3 will be combined into one zone (Zone 2) and
may be located in the MHPA upon granting of an easement to the City (or other acceptable agency) except
where narrow wildlife corridors require it to be located outside of the MHPA (City of San Diego 2013).
Brush management is required on all premises that are within 100 feet of a structure and
contain highly flammable, native, or naturalized vegetation. The standard brush
management zone (Zone) widths are 35 feet for Zone 1 and 65 feet for Zone 2 as stated in
Table 142-04h of the City Municipal Code. The project proposes to implement Alternative
Compliance measures to traditional brush management zones that involve a reduction in
Zone 1 limits consistent with the current requirements of Municipal Code Section 142.0412.
By reducing the Zone 1 limit and providing a non-combustible wall between Zone 1 and
Zone 2, the overall impact to vegetation is reduced as the graded area is less. All Zone 1
impacts are located within the grading limits. The majority of the Zone 2 impacts are also
located within the grading limits. Although 1.32 acres of Zone 2 impacts to southern mixed
chaparral lie outside of the grading limits primarily on the western side of the project area,
Zone 2 impacts are considered “impact neutral” and involve only minor thinning, trimming,
and pruning of vegetation without destroying habitat value. This 1.32-acre of Zone 2 located
in southern mixed chaparral habitat is not included in the project’s mitigation area and is not
counted toward satisfying mitigation acreage. The Zone 2 zones located adjacent to the
MHPA would be managed by the homeowners association. Therefore, the proposed brush
management zones would comply with the City requirements.
5.0 Environmental Analysis 5.1 Land Use
Avion Project SEIR
Page 5.1-15
Invasives
No invasive non-native plant species shall be introduced into areas adjacent to the MHPA (City of San
Diego 2013).
The project planting palette does not include any invasive or non-native plant species
adjacent to the MHPA area. Additionally, according to City standards for brush
management, Zone 2 will include only native, locally indigenous species.
Native shrub species and hydroseed would be installed on the manufactured slope adjacent
to the MHPA on the western and eastern slopes of the project and only temporarily irrigated
until the plants have become established. It is recommended that they be irrigated using a
temporary aboveground irrigation system. The plants should be installed in late winter to
early spring, as this is the optimal time for native plant growth and seed germination. A
120-day plant establishment period and a 24-month maintenance and monitoring period are
necessary to ensure that the native plants establish successfully. Maintenance activities
would involve control of non-native plant species, maintenance and removal of the
temporary irrigation system, and replacement planting (if necessary). The site should be
monitored by a biologist quarterly to evaluate site conditions and to recommend remedial
actions, if needed.
Barriers/Access
New development adjacent to the MHPA may be required to provide barriers (e.g., non-invasive vegetation,
rocks/boulders, fences, walls, and/or signage) along the MHPA boundaries to direct public access to
appropriate locations and reduce domestic animal predation (City of San Diego 2013).
The project would include boundary fencing along lots at the top of slopes and at the edge
of most private drives to delineate residential use areas from adjacent MHPA open space
areas. Lots adjacent to MHPA open space would have a glass-block view fence and lots at the
top of slopes would have a metal picket view fence. The entry private drive would have a
3-rail concrete fence to deter access to the adjacent MHPA open space area. The private
drive segment that terminates in the southwest portion of the site dead ends into a steep
cut slope which with signage would deter pedestrian access to the MHPA. The private drive
segment in the southeast portion of the site adjacent to open space would be at the top of a
steep slope that, along with signage, would restrict access to the adjacent MHPA located at
the toe of the slope.
Signs should be posted at the edge of unfenced private drives and along perimeter
segments fenced with the 3-rail concrete fence to inform residents of the restricted adjacent
MHPA open space preserve areas.
The project would include native vegetated slopes adjacent to the MHPA boundary. These
vegetated steep slopes (2.2:1-1.5:1) would also function as a deterrent to pedestrian access
into the MHPA.
5.0 Environmental Analysis 5.1 Land Use
Avion Project SEIR
Page 5.1-16
Grading/Land Development
Manufactured slopes associated with site development shall be included within the development footprint
for projects within or adjacent to the MHPA (City of San Diego 2013).
The proposed manufactured slopes for the project do not encroach into the MHPA.
5.1.5.3 Significance of Impacts
The project would not conflict or be inconsistent with adopted environmental plans for the area.
Therefore, impacts would be less than significant.
5.1.5.4 Mitigation, Monitoring, and Reporting
Mitigation would not be required.
FIGURE 5.1-1
Existing Land Use DesignationsCA
M
D
E
L
N
O
R
T
E
CA R M E L M TNPEN
A
S
Q
UIT
O
S
BERNARDO CENT E R
C A R M E L V A L L E Y BLACKMOUNTAI
N§¨¦15CA
M
D
E
L
N
O
R
T
E
CA R M E L M TNPEN
A
S
Q
UIT
O
S
BERNARDO CENT E R
C A R M E L V A L L E Y BLACKMOUNTAI
N§¨¦15
Image Source: NearMaps (flown February 2019)
0 1,000Feet [
Project Boundary
Heritage Bluffs Boundary
CURRENT LAND USE
RESIDENTIAL
Single Family Residential
Multi-Family Residential
COMMERCIAL AND OFFICE
Commercial and Office
PUBLIC FACILITIES AND UTILITIES
Transportation, Communications, Utilities
Education
Institutions
PARKS AND RECREATION
Recreation
Open Space Parks
UNDEVELOPED
Undeveloped
M:\JOBS5\8958\common_gis\fig5.1_1_EIR.mxd 6/27/2019 bma
5.0 Environmental Analysis 5.2 Biological Resources
Avion Project SEIR
Page 5.2-1
5.2 Biological Resources
This section evaluates potential biological resources impacts associated with the project. The
following discussion is based on the Biological Technical Report and appendices (including the
Jurisdictional Waters Delineation) (RECON 2019a) prepared by RECON and included as Appendix B.
5.2.1 Relationship to the Black Mountain Ranch
(Subarea I) Subarea Plan
The analysis in this section updates the biological resources analysis in the 1998 Environmental
Impact Report (EIR), with an emphasis on effects that were not addressed in the previous report.
5.2.2 Existing Conditions
RECON biologists conducted a general biological survey of the project site on November 13 and
December 8, 2017, to document the existing conditions of the biological resources occurring on the
site. The project site was walked on foot and notes were taken on the flora and fauna observed
during the survey (Table 5.2-1). A jurisdictional waters delineation was conducted on November 29,
2017 on the site to locate the extent of any wetland and non-wetland waters. A spring survey for
sensitive plant species was conducted on the site on March 21, 2018. This survey also included a
focused spring survey for thread-leaved brodiaea. Additional focused surveys for thread-leaved
brodiaea were conducted on March 14 and April 12, 2019.
Table 5.2-1
Survey Dates, Times, and Weather Conditions
Date Surveyors Type of Survey Beginning Conditions
Ending
Conditions
11/13/17 Gerry Scheid
Beth Procsal General Biology Survey
8:00 a.m.; 60° F; wind
0-1 mph;
60% cloud cover
12:00 p.m.; 72° F;
wind 0-1 mph; 40%
cloud cover
11/29/17 Gerry Scheid Wetland Delineation
12:00 p.m.; 75° F; wind
0-1 mph;
30% cloud cover
5:00 p.m.; 65° F; wind
0-1 mph; 30% cloud
cover
12/8/17 Gerry Scheid
Beth Procsal General Biology Survey
8:00 a.m.; 65° F; wind
0-1 mph;
50% cloud cover
12:00 p.m.; 74° F;
wind 0-1 mph; 20%
cloud cover
3/21/18 Gerry Scheid
Spring Rare Plant Survey;
Focused Thread-leaved Brodiaea
Survey
10:00 a.m.; 70° F; wind
0-5 mph;
20% cloud cover
2:00 p.m.; 75° F; wind
0-5 mph; 20% cloud
cover
3/14/19 Gerry Scheid
Spring Rare Plant Survey;
Focused Thread-leaved Brodiaea
Survey
NA NA
4/12/19 Gerry Scheid
Spring Rare Plant Survey;
Focused Thread-leaved Brodiaea
Survey
NA NA
NA = not applicable.
° F = degrees Fahrenheit; mph = miles per hour
5.0 Environmental Analysis 5.2 Biological Resources
Avion Project SEIR
Page 5.2-2
5.2.2.1 Botany
Four vegetation communities and one land cover type occur on the project site (Table 5.2-2).
Southern mixed chaparral comprises the majority of the site with lesser acreages of coastal sage
scrub, non-native grassland, and freshwater marsh patches (Figure 5.2-1). A total of 62 plant species
(36 native and 26 non-native species) were observed during the survey (Appendix B - Attachment 1).
A description of each of these vegetation communities and land cover types is provided below.
Table 5.2-2
Existing Vegetation Communities and Land Cover Types
(acres)
Vegetation Communities/
Land Cover Types
Existing Acres
Inside MHPA
Existing Acres
Outside MHPA Total
Coastal Sage Scrub 3.58 0.74 4.32
Southern Mixed Chaparral 15.03 19.36 34.39
Non-native Grassland 0.23 2.06 2.29
Freshwater Marsh 0.13 -- 0.13
Disturbed Land -- 0.35 0.35
TOTAL 18.97 22.51 41.48
MHPA = Multi-Habitat Planning Area
a. Coastal Sage Scrub
Patches of coastal sage scrub vegetation occur in the northeast corner and northwest portion of the
site. Black sage (Salvia mellifera), California buckwheat (Eriogonum fasciculatum), laurel sumac, and
California sagebrush (Artemisia californica) make up this shrub community. Coastal sage scrub is
ranked as a Tier II habitat.
b. Southern Mixed Chaparral
The southern mixed chaparral on the site is dominated by a mixture of chaparral shrub species that
includes chamise (Adenostoma fasciculatum), laurel sumac (Malosma laurina), mission manzanita
(Xylococcus bicolor), toyon (Heteromeles arbutifolia), and lilac (Ceanothus tomentosus). Dense chaparral
covers the slopes to the east and west while a more open chaparral occurs along the ridge and
eastern flank. Southern mixed chaparral is ranked as a Tier IIIA habitat.
c. Non-native Grassland
Non-native grassland occurs in the northeast portion of the site in the flatter land where past land
use was most intense. The grassland area supports a mixture of non-native annual grasses such as
purple falsebrome (Brachypodium distachyon), smooth brome (Bromus hordaceous), red brome
(Bromus madritensis), ripgut grass (Bromus diandrus), and slender wild oat (Avena barbata). Scattered
non-native trees were planted in this area and include species of eucalyptus (Eucalyptus spp.), Italian
cypress (Cupressus sempervirens), Canary Island pine (Pinus canariensis), and Peruvian peppertree
(Schinus molles). Non-native grassland as a Tier IIIB habitat.
5.0 Environmental Analysis 5.2 Biological Resources
Avion Project SEIR
Page 5.2-3
d. Freshwater Marsh
Two impoundments occur along the drainage course within the eastern canyon. These
impoundments have been breached and do not hold water for long durations anymore, but do
support herbaceous freshwater marsh vegetation. Plant species observed in the impoundments
include annual beardgrass (Polypogon monspeliensis), curly dock (Rumex crispus), pale spike rush
(Eleocharis macrostachya), alkali heliotrope (Heliotropium curassavicum), and hedge nettle (Stachys
rigida). Freshwater marsh is considered a type of wetland habitat.
e. Disturbed Land
A small area of disturbed land occurs in the north-central portion of the site where past land use
had altered the soils. Non-native plants such as black mustard (Brassica nigra), star-thistle (Centauria
meletensis), stinkwort (Dittrichia graveolens), and Italian thistle (Carduus pycnocephalus) dominate this
area in a dense stand.
5.2.2.2 Zoology
A list of the wildlife species detected in the survey areas is provided in Appendix B - Attachment 2. A
general discussion of wildlife usage in the survey areas is presented below.
a. Amphibians
No amphibians were observed during the survey. The site lacks a permanent water source;
therefore, it is unlikely that amphibians occur on the site.
b. Reptiles
No reptile species were observed during the survey. The site likely supports a small population of
common lizard species such as the western fence lizard (Sceloporus occidentalis) and side-blotched
lizard (Uta stansburiana).
c. Birds
Fifteen bird species were observed on the site during the survey. Common bird species observed
include wrentit (Chamaea fasciata henshawi), black phoebe (Sayornis nigricans semiatra), and Anna’s
hummingbird (Calypte anna).
d. Mammals
Four mammal species were detected on the site. Coyote (Canis latrans), desert cottontail (Sylvilagus
audubonii), and southern mule deer (Odocoileus hemionus fuliginata) were all detected by the
presence of their scat. San Diego desert woodrat (Neotoma lepida intermedia; CDFW Species of
Special Concern) was detected by the presence of a nest.
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5.2.2.3 Sensitive Biological Resources
a. Sensitive Vegetation Communities
Coastal sage scrub, southern mixed chaparral, non-native grassland, and freshwater marsh are all
considered sensitive vegetation types under the City (City of San Diego 2012). Coastal sage scrub is
ranked as a Tier II habitat, southern mixed chaparral as a Tier IIIA habitat, non-native grassland as a
Tier IIIB habitat, and freshwater marsh as a wetland habitat. All these habitat designations require
mitigation for impacts to these habitat types.
b. Sensitive Plant Species
A spring survey to look for sensitive plant species was conducted on the site on March 21, 2018. No
sensitive plant species were observed during the spring survey and none are expected to occur on
the site. A list of sensitive plant species, including species endemic to San Diego County, with the
potential for occurrence on the site is provided in Appendix B - Attachment 3.
One sensitive plant species, thread-leaved brodiaea (Brodiaea filifolia), was initially considered to
have a potential to occur on the project site solely due to close proximity to a known population to
the north that occurs within the Heritage Brodiaea Preserve. The Heritage Brodiaea Preserve
population of thread-leaved brodiaea occurs within open space set aside as part of the Heritage
Bluffs II development project. Over ten thousand individual thread-leaved brodiaea plants have
been documented in this preserve. The thread-leaved brodiaea in the Heritage Brodiaea Preserve
occur on heavy clay soils.
A focused spring survey for thread-leaved brodiaea was also conducted on the Avion project site on
March 21, 2018. Additional focused surveys for thread-leaved brodiaea were conducted on March 14
and April 12, 2019. These surveys were timed to coincide with the emergence and observability of
the existing population of this species within the Heritage Brodiaea Preserve. No thread-leaved
brodiaea plants were observed on the Avion project site and none are expected to occur. Therefore,
there is a low potential for this species to occur on the site due to the following several factors.
• Historically Chaparral/Sage Scrub Habitat – A review of historical aerial photographs back to
1953 show that the Avion project area was vegetated with shrublands (i.e., chaparral, coastal
sage scrub) while the location of the Heritage Preserve to the north has been grassland to
the present. By the mid-1960s the Avion site had an established homestead that cleared the
surrounding shrublands for access, buildings, and local agricultural activities. The non-native
grassland areas that currently occur on the site colonized some of these disturbed areas
once they were abandoned.
• Poor Quality Grassland Habitat – The non-native grassland vegetation on the project site has
been subject to historical disturbances (e.g., dirt roads, clearing, agricultural activities,
homestead, etc.). The non-native grassland that developed after the homestead was
abandoned grew a tall, thick thatch that makes it difficult for herbaceous species other than
grasses to persist. This grass thatch is much taller and denser than that where the known
thread-leaved brodiaea population to the north occurs. The non-native grassland on the site
5.0 Environmental Analysis 5.2 Biological Resources
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currently supports an active gopher population that is present throughout the habitat. This
level of gopher activity confined to a relatively small area creates conditions that are not
suitable for plants that grow from bulbs or corms.
• Low Plant Species Composition – The existing non-native grassland areas on the site are
comprised of dense stands of non-native grasses almost to the complete exclusion of other
plant species. No plant species from bulbs or corms occur in the grassland on the site. This
condition is in sharp contrast to the Heritage Brodiaea Preserve where the less dense
grassland (i.e., lower thatch development) habitat on heavy clay soil supports bulb and corm
species such as thread-leaved brodiaea, blue-eyed grass, blue dicks, death camas, and
goldenstar in relatively large numbers.
• Lack of Clay Soil – Thread-leaved brodiaea in San Diego County occurs primarily on clay soils
that are moist during the spring, typically derived from granitic rock, and that support native
grassland, annual grasslands, alkali grasslands, or open sage/chaparral scrub habitats (U.S.
Fish and Wildlife Service [USFWS] 1998, 2005). The species may also occur on soils with a clay
subsurface, or clay lenses within loamy, silty loam, loamy sand, silty deposits with cobbles, or
alkaline soils. The Avion site occurs on shallow San Miguel-Exchequer rocky silt loam soils
derived from meta-volcanic rock. The brodiaea population within the Heritage Preserve to
the north occurs solely on Auld clay soils. This Auld clay soil lens does not extend onto the
Avion site.
• Past Surveys – Thread-leaved brodiaea was not observed on the project site during a past
biological survey conducted on the site in 2013 (RECON 2013). Numerous other surveys
conducted over the last five years of the adjacent land to the north where the Heritage Bluffs
II and East Clusters development projects are located did not find thread-leaved brodiaea in
close proximity to the southern boundary of the Avion project site.
c. Sensitive Wildlife Species
Two sensitive wildlife species were observed during the survey. A Cooper’s hawk (Accipiter cooperii)
was observed flying over the project site. A nest of the San Diego desert woodrat was observed in
the chaparral vegetation. The woodrat nest is located in dense chaparral in the northeastern portion
of the project site to the east of the drainage course (see Figure 5.2-1).
Four other sensitive species have a moderate potential to occur on the project site due to the
habitat conditions. Two sensitive reptile species, Belding’s orange-throated whiptail (Aspidoscelis
hyperythra beldingi) and coastal whiptail (Aspidoscelis tigris stejnegeri), may occur in small numbers in
the shrub land habitats on the project site. Two sensitive bird species, coastal California gnatcatcher
(Polioptila californica californica) and southern California rufous-crowned sparrow (Aimophila ruficeps
canescens), have the potential to occur in small numbers in the coastal sage scrub and southern
mixed chaparral areas on the project site. A list of sensitive wildlife species with the potential to
occur on the site is provided in Appendix B - Attachment 4.
A habitat assessment for the potential for the site to support western burrowing owl (Athene
cunicularia hypugaea) was conducted during the general survey of the site. It was determined that
there is a low potential for this species to occur on-site, as the non-native grassland present is likely
5.0 Environmental Analysis 5.2 Biological Resources
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Page 5.2-6
too small an acreage to support burrowing owl, the structure of the grassland (i.e., tall, dense) is not
optimal for burrowing owl, and the lack of observations of suitable burrows, burrow complexes, or
any sign of burrowing owl presence on-site.
d. Jurisdictional Waters and Wetlands
The drainage courses, their tributaries, and the two impoundment areas located on the project site
are considered federal and state jurisdictional waters (Table 5.2-3). The major drainage courses are
federal (USACE) non-wetland waters and state (CDFW, Regional Water Quality Control Board)
streambed features that are ephemeral. These drainage courses do not support wetland vegetation,
but occur within the upland chaparral habitat in the canyon bottoms. The two impoundments
support herbaceous wetland plant species, hydric soils, and secondary wetland hydrology
indicators, and therefore, are federal and state wetlands. The two impoundment areas support
herbaceous wetland plants and, therefore, are considered a wetland under the City’s Biology
Guidelines (City of San Diego 2012).
Table 5.2-3
Jurisdictional Waters
Jurisdictional Waters Type
Existing
Acres Agency
Wetland 0.13
U.S. Army Corps of Engineers
Regional Water Quality Control Board
California Department of Fish and Wildlife
City of San Diego
Non-wetland water/Streambed 0.63
U.S. Army Corps of Engineers
Regional Water Quality Control Board
California Department of Fish and Wildlife
TOTAL 0.76
5.2.2.4 Wildlife Movement Corridors
Wildlife movement corridors are defined as areas that connect suitable wildlife habitat areas in a
region otherwise fragmented by rugged terrain, changes in vegetation, or human disturbance.
Natural features such as canyon drainages, ridgelines, or areas with vegetation cover provide
corridors for wildlife travel. Wildlife movement corridors are important because they provide access
to mates, food, and water; allow the dispersal of individuals away from high-density population
areas; and facilitate the exchange of genetic traits between populations (Beier and Loe 1992).
Wildlife movement corridors are considered sensitive by the City and Wildlife Agencies.
Regional wildlife corridors were established as part of the MSCP planning that is documented in the
Subarea Plan EIR. These established wildlife corridors connected the La Jolla Valley and associated
Lusardi Creek lowlands to the Black Mountain Open Space Preserve to the east and south
(Figure 5.2-2). The anticipated development boundary of the Avion property adjacent to the Black
Mountain Open Space Preserve were accounted for in the development of these regional wildlife
corridors. The Avion project site is surrounded by portions of the Black Mountain Open Space
5.0 Environmental Analysis 5.2 Biological Resources
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Preserve and currently wildlife movement can occur across the property in all directions except from
the northeast where movement is impeded by the existing Heritage Bluffs II residential area.
5.2.3 Regulatory Framework
5.2.3.1 Natural Habitat Conservation and Planning
The Natural Community Conservation Planning (NCCP) program was enacted by the State of
California in 1991 to provide long-term regional protection of natural vegetation and wildlife
diversity while allowing compatible development. The NCCP process was initiated to provide an
alternative to single-species conservation efforts (habitat conservation plans). The NCCP is intended
to provide a regional approach to the protection of species within a designated natural community.
In the City, the MSCP is an outgrowth of this planning.
5.2.3.2 Multiple Species Conservation Program
The MSCP is a comprehensive, long-term habitat conservation planning program that covers
approximately 900 square miles in southwestern San Diego County under the federal and state
Endangered Species Acts and state NCCP Act of 1991. The planned MSCP regional preserve is
targeted at 172,000 acres. Local jurisdictions, including the City, implement their portions of the
regional umbrella MSCP through Subarea Plans, which describe specific implementing mechanisms.
The City’s MSCP Subarea Plan was approved in March 1997. The City’s MSCP study area includes
206,124 acres within its municipal boundaries. The City’s planned MSCP preserve totals 56,831 acres,
with 52,012 acres (90 percent) targeted for preservation. In 2004, the City committed to increasing
the conservation target by 715 acres in association with revisions to the City’s brush management
regulations in response to local fires.
The MSCP Subarea Plan is a plan, which established the process for the issuance of incidental take
permits (ITP) for listed species under Section 10(a)(1)(B) of the federal Endangered Species Act (ESA)
and Section 2835 under the state ESA. The primary goal of the MSCP Subarea Plan is to conserve
viable populations of sensitive species and to conserve regional biodiversity while allowing for
reasonable economic growth. In July 1997, the City signed an Implementing Agreement with the
USFWS and the CDFW. The Implementing Agreement serves as a binding contract between the City,
the USFWS, and the CDFW that identifies the roles and responsibilities of the parties to implement
the MSCP and Subarea Plan. The agreement allows the City to issue incidental take authorizations
for “MSCP Covered” species. Applicable state and federal permits are still required for wetlands and
listed species that are not covered by the MSCP.
“MSCP Covered” refers to species covered by the City’s federal ITP issued pursuant to Section 10(a)
of the federal ESA (16 United States Code § 1539(a)(2)(A)). Under the federal ESA, an ITP is required
when non-federal activities would result in “take” of a threatened or endangered species. A habitat
conservation plan (HCP) must accompany an application for a federal ITP. Take authorization for
federally listed wildlife species covered in the HCP shall generally be effective upon approval of the
HCP.
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5.2.3.3 Multi-Habitat Planning Area
One of the primary objectives of the MSCP is to identify and maintain a preserve system which
allows for animals and plants to exist at both the local and regional levels. The MSCP has identified
large blocks of native habitat having the ability to support a diversity of plant and animal life known
as “core biological resource areas.” “Linkages” between these core areas provide for wildlife
movement. These lands have been determined to provide the necessary habitat quality, quantity,
and connectivity to sustain the unique biodiversity of the San Diego region. Input from responsible
agencies and other interested participants resulted in creation of the City’s Multi-Habitat Planning
Area (MHPA). The MHPA is the area within which the permanent MSCP preserve would be
assembled and managed for its biological resources.
In accordance with the MSCP, for parcels located outside the MHPA:
there is no limit on encroachments into sensitive biological resources, with the
exception of wetlands and listed non-covered species’ habitat [which are regulated
by federal and state agencies and narrow endemic species as described below] …
impacts to sensitive biological resources must be assessed, and mitigation, where
necessary, must be provided in conformance with Section III of [the City’s Biological
Guidelines]. (City of San Diego 2012)
To address the integrity of the MHPA, guidelines were developed to manage land uses adjacent to
the MHPA. The adjacency guidelines are intended to be addressed on a project-by-project basis
either in the planning or management stage. These guidelines address the issues of drainage, toxics,
lighting, noise, invasives, brush management, access to MHPA, and grading/land development. As
shown in Table 5.2-2, 18.97 acres of the project is site is currently located within the MHPA.
5.2.3.4 Land Development Code/Environmentally Sensitive Lands
On December 9, 1997, the Environmentally Sensitive Lands (ESL) Regulations were adopted by
ordinance as a part of the Land Development Code (LDC). The purpose of the ESL Regulations is to
protect and preserve environmentally sensitive lands (e.g., sensitive biological resources, steep
hillsides, coastal beaches, sensitive coastal bluffs, and special flood hazard areas), along with the
viability of the species supported by those lands. The regulations are intended to assure that
development occurs in a manner that protects the overall quality of the resources and the natural
and topographic character of the area. The ESL defines “sensitive biological resources” as those
lands included within the MHPA as identified in the MSCP Subarea Plan, and other lands outside of
the MHPA that contain: wetlands; vegetation communities classifiable as Tier I, II, IIIA or IIIB; habitat
for rare, endangered or threatened species; or narrow endemic species. Per this definition, the
entire project site, with the exception of 0.35 acres of disturbed land located outside the MHPA,
qualifies as sensitive biological resources subject to ESL.
5.2.3.5 Land Development Manual/Biology Guidelines
The Biology Guidelines aid in the implementation and interpretation of ESL Regulations. Also,
Section III of these Guidelines (Biological Impact Analysis and Mitigation Procedures) also serves as
5.0 Environmental Analysis 5.2 Biological Resources
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Page 5.2-9
standards for the determination of impact and mitigation under the California Environmental
Quality Act (CEQA). The guidelines are the baseline biological standards for processing
Neighborhood Development Permits, Site Development Permits and Coastal Development Permits
issued pursuant to the ESL.
5.2.3.6 California Fish and Game Code and Migratory Bird Treaty
Act
Raptors (birds of prey) and active raptor nests, as well as most other bird nests, are protected by the
California Fish and Game Code 3503.5, which states that it is “unlawful to take, possess, or destroy
any birds of prey or to take, possess, or destroy the nest or eggs of any such bird” unless authorized.
In addition, active nests of most bird species are protected during the breeding season under the
federal Migratory Bird Treaty Act (MBTA).
5.2.4 Issues 1, 2, and 3: Sensitive Biological Resources
• Would the proposal result in substantial adverse impacts, either directly or through habitat
modifications, to any species identified as a candidate, sensitive or special status species in
the MSCP or other local or regional plans, policies or regulations, or by the CDFW or USFWS?
• Would the proposal result in a substantial adverse impact on any Tier I, Tier II, Tier IIIA or
Tier IIIB habitats as identified in the Biology Guidelines of the Land Development Code or
other sensitive natural community identified in local or regional plans, policies, regulations
or by the CDFW or USFWS?
• Would the proposal result in a substantial adverse impact on wetlands (including, but not
limited to, marsh, vernal pools, riparian areas, etc.) through direct removal, filling,
hydrological interruption, or other means?
5.2.4.1 Threshold(s)
In accordance with the City’s Significance Determination Thresholds and LDC Biology Guidelines, the
project would have a significant impact if it would:
• Result in a substantial adverse impact, either directly or through habitat modifications, on
any species identified as a candidate, sensitive, or special status species in the MSCP or
other local or regional plans, policies or regulations, or by CDFW or USFWS;
• Result in a substantial adverse impact on any Tier I habitats, Tier II habitats, Tier IIIA habitats,
or Tier IIIB habitats as identified in the Biology Guidelines of the Land Development Manual
or other sensitive natural community identified in local or regional plans, policies or
regulations, or by CDFW or USFWS; and/or
• Result in a substantial adverse impact on wetland (including, but not limited to, marsh,
vernal pools, riparian areas, etc.) through direct removal, filling, hydrological interruption, or
other means.
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5.2.4.2 Impacts
a. Vegetation Communities
Project grading would impact coastal sage scrub, southern mixed chaparral, non-native grassland,
and disturbed land both inside and outside of the MHPA (Table 5.2-4). The project proposes to
implement Alternative Compliance measures to traditional brush management zones that involve a
reduction in brush management zone (BMZ) 1 limits. By reducing the BMZ 1 limit and providing a
non-combustible wall between BMZ 1 and BMZ 2, the overall impact to vegetation is reduced as all
BMZ 1 impacts would be located within the grading limits. The majority of the BMZ 2 impacts are
also located within the grading limits; however, 1.32 acres of BMZ 2 impacts to southern mixed
chaparral lie outside of the grading limits primarily on the western side of the project area
(Figure 5.2-3). The BMZ 2 impacts are considered “impact neutral” and involve only minor thinning,
trimming, and pruning of vegetation.
Table 5.2-4
Impacts to Vegetation Communities and Land Cover Types
(acres)
Vegetation Communities/
Land Cover Types
Permanent Impact1 Construction Zone Impact2
Total
Inside
MHPA3
Outside
MHPA Inside MHPA
Outside
MHPA
Coastal Sage Scrub 0 0.53 0 0.03 0.56
Southern Mixed Chaparral 0 13.04 0 0.10 13.14
Non-native Grassland 0 1.33 0 0.17 1.50
Freshwater Marsh 0 0 0 0 0
Disturbed Land 0 0.35 0 0 0.35
TOTAL 0 15.25 0 0.30 15.55
1Includes all Brush Management Zone 1 impacts.
2Construction Zone impact area refers to area needed for remedial work to construct the
manufactured slopes (see Figure 5.2-3).
3Assumes MHPA Boundary Line Adjustment approved
b. Sensitive Plants
No sensitive plant species were observed on the project site and none are expected to occur due to
lack of appropriate habitat and/or soil conditions.
c. Sensitive Wildlife
General Wildlife: Direct impacts are anticipated to occur to small mammals and reptiles with low
mobility during the grading of the project site. A biological monitor would be required to be present
on-site during grading to preclude any avoidable/known impacts. Birds which are not nesting are
expected to be able to avoid being impacted.
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Sensitive Wildlife: The San Diego desert woodrat nest observed on-site occurs approximately
50 feet east of the grading limit and 45 feet east of where the limit fence would be placed. Therefore,
impacts to the San Diego desert woodrat would not occur.
Potential impacts to species with a moderate potential for occurrence (e.g., Belding’s orange-
throated whiptail, coastal whiptail, southern California rufous-crowned sparrow) are not expected to
affect a large number of individuals; therefore, any impacts to these species are not considered
significant. Potential impacts to the Cooper’s hawk would be considered significant.
Direct impacts could occur to Cooper’s hawk and/or rufous-crowned sparrow that have a moderate
to high potential to occur within the project area due to mass grading and vegetation removal.
Impacts to these species identified as listed, candidate, sensitive, or special status in the MSCP are
considered significant and require biological monitoring and avoidance of typical nesting periods.
d. Jurisdictional Waters and Wetlands
The project would not impact any federal, state, or city jurisdictional waters, including wetlands. The
major access private drive into the project site would cross the eastern drainage course with an
arch-culvert type bridge crossing resulting in no permanent impacts to the bed or bank of the
drainage. The drainage course would remain in its natural soft-bottom configuration. Grading limits
along the western and eastern boundaries would not encroach into the ephemeral streambeds or
wetlands.
In accordance with San Diego Municipal Code Section 143.0141, a wetland buffer that ranges
between 171 feet and 186 feet is being maintained on the eastern side of the project to protect and
maintain the functions and values of the remaining on-site wetland areas (Figure 5.2-4). The buffer is
located between the jurisdictional wetlands and the edge of the development to avoid and minimize
any indirect edge effects to the wetlands. The buffer would include the manufactured 2.2:1 to 1.5:1
slopes to the east of the project, approximately 30 to 96 feet tall. These steep slopes would be
revegetated with native species and also function as a barrier to pedestrians as the slopes would be
too steep to walk. The wetland buffer distances would protect and maintain the biological, chemical,
and physical functions of the wetlands.
5.2.4.3 Significance of Impacts
a. Vegetation Communities
Impacts to coastal sage scrub, southern mixed chaparral, and non-native grassland would be
significant.
b. Sensitive Plants
No impacts to sensitive plant species would occur.
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c. Sensitive Wildlife
Impacts to Cooper’s hawk and/or rufous-crowned sparrow would be significant.
d. Jurisdictional Waters and Wetlands
No impacts to federal, state, or city jurisdictional waters, including wetlands, would occur.
5.2.4.4 Mitigation, Monitoring, and Reporting
a. Vegetation Communities
MM-BIO-1: Upland Vegetation Communities
Mitigation for impacts to coastal sage scrub (Tier II habitat), southern mixed chaparral (Tier IIIA
habitat), and non-native grassland (Tier IIIB habitat) communities would be achieved through the
preservation of habitat on the site located outside of the development area. Prior to issuance of any
construction permits, including but not limited to, the first Grading Permit, Demolition Plans/Permits
and Building Plans/Permits, the project would demonstrate to the satisfaction of the City that
impacts to a total of 15.2 acres of sensitive vegetation would be mitigated by the on-site
preservation of 24.03 acres of sensitive vegetation as summarized by habitat type in Table 5.2-5. The
preserved habitat areas on the site would all be within the boundaries of the MHPA Boundary Line
Adjustment (BLA) dedicated to the City in fee title. Acceptance of land dedicated in fee title is subject
to approval by the City’s Park and Recreation Open Space Division.
MM-BIO-2: Standard City Construction Measures
Prior to issuance of any construction permits, including but not limited to, the first Grading Permit,
Demolition Plans/Permits and Building Plans/Permits, mitigation for general impacts to biological
resources would be incorporated via standard measures including general mitigation measures,
biological protections during construction, (includes monitoring, preconstruction meetings, and
development of a Biological Condition Monitoring Exhibit, etc.) as described below. These Biological
Resources Protection requirements shall be depicted on the construction documents verbatim and
implemented accordingly.
Table 5.2-5
Mitigation Requirement for Sensitive Vegetation Communities
Vegetation Community
(Tier)
Impact
Inside
MHPA
Mitigation
Ratio with
Preservation
Inside MHPA
Sub-
Total
Impact
Outside
MHPA
Mitigation
Ratio with
Preservation
Inside MHPA
Sub-
Total
Total
Mitigation
Requirement
On-site
Preservation
Inside
MHPA1
Remaining
Mitigation
Requirement
Coastal Sage Scrub
(Tier II) 0.14 1:1 0.14 0.60 1:1 0.60 0.74 3.53 0
Southern Mixed
Chaparral (Tier IIIA) 0.32 1:1 0.32 12.99 0.5:1 6.49 6.81 19.47 0
Non-native Grassland
(Tier IIIB) 0.14 1:1 0.14 1.58 0.5:1 0.79 0.93 0.53 02
Freshwater Marsh
(Wetland) 0 N/A 0 0 N/A 0 0 0.13 0
Total 0.60 0.60 15.17 7.88 8.48 23.66 0
1With Multi-Habitat PMHPA BLA.
2Assumes up-tier mitigation for non-native grassland.
5.0 Environmental Analysis 5.2 Biological Resources
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Biological Resource Protection During Construction
I. Prior to Construction
A. Biologist Verification - The owner/permittee shall provide a letter to the City’s Mitigation
Monitoring Coordination (MMC) section stating that a Project Biologist (Qualified Biologist) as
defined in the City’s Biological Guidelines (2012), has been retained to implement the
project’s biological monitoring program. The letter shall include the names and contact
information of all persons involved in the biological monitoring of the project.
B. Preconstruction Meeting - The Qualified Biologist shall attend the preconstruction
meeting, discuss the project’s biological monitoring program, and arrange to perform any
follow up mitigation measures and reporting including site-specific monitoring, restoration
or revegetation, and additional fauna/flora surveys/salvage.
C. Biological Documents - The Qualified Biologist shall submit all required documentation to
MMC verifying that any special mitigation reports including but not limited to, maps, plans,
surveys, survey timelines, or buffers are completed or scheduled per the City’s Biology
Guidelines, MSCP, ESL Ordinance, project permit conditions; CEQA; endangered species acts
(ESAs); and/or other local, state or federal requirements.
D. Biological Construction Mitigation/Monitoring Exhibit (BCME) - The Qualified Biologist
shall present a BCME, which includes the biological documents in “C” above. In addition,
include: restoration/revegetation plans, plant salvage/relocation requirements (e.g., coastal
cactus wren plant salvage, burrowing owl exclusions, etc.), avian or other wildlife
surveys/survey schedules (including U.S. Fish and Wildlife Service protocol), timing of
surveys, wetland buffers, other impact avoidance areas, and any subsequent requirements
determined by the Qualified Biologist and the City Assistant Deputy Director (ADD)/MMC.
The BCME shall include a site plan, written and graphic depiction of the project’s biological
mitigation/monitoring program, and a schedule. The BCME shall be approved by MMC and
referenced in the construction documents.
E. Avian Protection Requirements - To avoid any direct impacts to Cooper’s hawk, rufous-
crowned sparrow, and coastal California gnatcatcher or any species identified as listed,
candidate, sensitive, or special status in the MSCP, removal of habitat that supports active
nests in the proposed area of disturbance should occur outside of the breeding season for
these species (February 1 to September 15). If removal of habitat in the proposed area of
disturbance must occur during the breeding season, the Qualified Biologist shall conduct a
preconstruction survey to determine the presence or absence of nesting for these three
sensitive bird species on the proposed area of disturbance. The preconstruction survey shall
be conducted within 10 calendar days prior to the start of construction activities (including
removal of vegetation). The applicant shall submit the results of the preconstruction survey
to the City’s Development Services Department (DSD) for review and approval prior to
initiating any construction activities. If nesting activities for any of the above-mentioned
sensitive bird species are detected, a letter report or mitigation plan in conformance with the
City’s Biology Guidelines and applicable state and federal law (i.e., appropriate follow up
surveys, monitoring schedules, construction and noise barriers/buffers, etc.) shall be
5.0 Environmental Analysis 5.2 Biological Resources
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prepared and include proposed measures to be implemented to ensure that take of birds or
eggs or disturbance of breeding activities is avoided. The report or mitigation plan shall be
submitted to the City for review and approval and implemented to the satisfaction of the
City. The City’s MMC Section or Resident Engineer, and Biologist shall verify and approve
that all measures identified in the report or mitigation plan are in place prior to and/or
during construction.
F. Resource Delineation - Prior to construction activities, the Qualified Biologist shall
supervise the placement of orange construction fencing or equivalent along the limits of
disturbance adjacent to sensitive biological habitats and verify compliance with any other
project conditions as shown on the BCME. This phase shall include flagging plant specimens
and delimiting buffers to protect sensitive biological resources (e.g., habitats/flora and fauna
species, including nesting Cooper’s hawk, rufous-crowned sparrow, and coastal California
gnatcatcher) during construction. Appropriate steps/care should be taken to minimize
attraction of nest predators to the site.
G. Education – Prior to commencement of construction activities, the Qualified Biologist shall
meet with the owner/permittee or designee and the construction crew and conduct an on-
site educational session regarding the need to avoid impacts outside of the approved
construction area and to protect sensitive flora and fauna (e.g., explain the avian and
wetland buffers, flag system for removal of invasive species or retention of sensitive plants,
and clarify acceptable access routes/methods and staging areas, etc.).
II. During Construction
A. Monitoring – All construction (including access/staging areas) shall be restricted to areas
previously identified, proposed for development/staging, or previously disturbed as shown
on “Exhibit A” and/or the BCME. The Qualified Biologist shall monitor construction activities
as needed to ensure that construction activities do not encroach into biologically sensitive
areas, or cause other similar damage, and that the work plan has been amended to
accommodate any sensitive species located during the preconstruction surveys. In addition,
the Qualified Biologist shall document field activity via the Consultant Site Visit Record
(CSVR). The CSVR shall be e-mailed to the MMC on the first day of monitoring, the first week
of each month, the last day of monitoring, and immediately in the case of any
undocumented condition or discovery.
B. Subsequent Resource Identification – The Qualified Biologist shall note/act to prevent any
new disturbances to habitat, flora, and/or fauna on-site (e.g., flag plant specimens for
avoidance during access, etc.). If active nests for Cooper’s hawk, rufous-crowned sparrow,
and coastal California gnatcatcher, or other previously unknown sensitive resources are
detected, all project activities that directly impact the resource shall be delayed until species
specific local, state or federal regulations have been determined and applied by the
Qualified Biologist.
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III. Post Construction Measures
A. In the event that impacts exceed previously allowed amounts, additional impacts shall be
mitigated in accordance with City Biology Guidelines, ESL and MSCP, CEQA, and other
applicable local, state and federal law. The Qualified Biologist shall submit a final
BCME/report to the satisfaction of the City ADD/MMC within 30 days of construction
completion.
b. Sensitive Plants
No mitigation is required.
c. Sensitive Wildlife
Impacts to Cooper’s hawk and/or rufous-crowned sparrow would be mitigated through
implementation of MM-BIO-2.
d. Jurisdictional Waters
No mitigation is required.
5.2.4.5 Significance after Mitigation
a. Vegetation Communities
Implementation of mitigation measures MM-BIO-1 and MM-BIO-2 would reduce impacts to a level
less than significant.
b. Sensitive Wildlife
Implementation of mitigation measure MM-BIO-2 would reduce impacts to a level less than
significant.
5.2.5 Issue 4: Wildlife Movement Corridors
• Would the project interfere substantially with the movement of any native resident or
migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, including linkages identified in the MSCP, or impede the use of native wildlife
nursery sites?
5.0 Environmental Analysis 5.2 Biological Resources
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5.2.5.1 Threshold(s)
In accordance with the City’s Significance Determination Thresholds and LDC Biology Guidelines, the
project would have a significant impact if it would:
• Interfere substantially with the movement of any native resident or migratory fish or wildlife
species or with established native resident or migratory wildlife corridors, including linkages
identified in the MSCP Plan, or impede the use of native wildlife nursery sites.
5.2.5.2 Impacts
Minor local restrictions to wildlife would occur with the project. However, wildlife movement from a
regional perspective would not be adversely disrupted by the project, as connections to large areas
of native habitat would remain functional and in conformance with the Subarea Plan objectives for
regional wildlife movement (see Figure 5.2-2).
5.2.5.3 Significance of Impacts
Impacts to wildlife movement would be less than significant.
5.2.5.4 Mitigation, Monitoring, and Reporting
No mitigation is required.
5.2.6 Issues 5 and 6: MSCP/MHPA Conflicts
• Would the proposal conflict with the provisions of an adopted HCP, NCCP or other approved
local, regional, or state habitat conservation plan, either within the MSCP plan area or in the
surrounding region?
• Would the proposal introduce a land use within an area adjacent to the MHPA that would
result in adverse edge effects?
5.2.6.1 Threshold(s)
In accordance with the City’s Significance Determination Thresholds, a project would have a
significant impact if it would:
• Result in a conflict with the provisions of an adopted HCP, NCCP, or other approved local,
regional, or state habitat conservation plan, either within the MSCP plan area or in the
surrounding region; and/or
• Introduce land use within an area adjacent to the MHPA that would result in adverse edge
effects.
5.0 Environmental Analysis 5.2 Biological Resources
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5.2.6.2 Impacts
As described in Section 5.1.5.2a above, the project is consistent with Section 1.6.4 of the City’s MSCP
Subarea Plan, as it preserves lands dedicated to the MHPA. The MHPA BLA that was approved by the
Wildlife Agencies and City MSCP on June 21, 2019 would ensure that the project meets the
equivalency standards as they pertain to a no net loss of MHPA habitat area, functions, or values. As
described in Section 5.1.5.2a above, the project would be consistent with the six biological factors
required by the MSCP for a MHPA BLA, and the approved BLA would transfer equal or higher
biological values of impacted species and habitats into the preserve. As described in Section 5.1.5.2c
above, the project would be consistent with all of the MSCP MHPA Land Use Adjacency Guidelines.
5.2.6.3 Significance of Impacts
The project would not conflict with the City’s MSCP or MHPA. Therefore, impacts would be less than
significant.
5.2.6.4 Mitigation, Monitoring, and Reporting
Mitigation would not be required.
5.2.7 Issue 7: Local Policies and Ordinances
• Would the project result in a conflict with any local policies or ordinances protecting
biological resources?
5.2.7.1 Threshold(s)
In accordance with the City’s Significance Determination Thresholds, a project would have a
significant impact if it would:
• Result in a conflict with any local policies or ordinances protecting biological resources.
5.2.7.2 Impacts
The project would comply with the ESL development regulations outlined in LDC Section §143.0141
for sensitive biological resources, as detailed below. All development occurring in sensitive biological
resources is subject to a site-specific impact analysis conducted by a Qualified Biologist, in
accordance with the Biology Guidelines in the Land Development Manual. Mitigation may include
any of the following, as appropriate to the nature and extent of the impact: (a) dedication in fee title
to the City of San Diego; or (b) dedication of a covenant of easement in favor of the City of San
Diego; or (c) monetary payment.
An evaluation of the project’s consistency with the City’s ESL regulation for sensitive biological
resources is presented below in a discussion that first presents the ESL regulation (italicized text),
followed by an analysis of the project’s compliance with the ESL regulation.
5.0 Environmental Analysis 5.2 Biological Resources
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1) Grading during wildlife breeding seasons shall be consistent with the requirements of the MSCP
Subarea Plan.
As detailed in Section 5.2.4 above, grading would be permitted during the breeding season
as subject to certain conditions.
2) Sensitive biological resources that are outside of the allowable development area on a premises,
or are acquired as off-site mitigation as a condition of permit issuance, are to be left in a natural
state and used only for those passive activities allowed as a condition of permit approval.
Mitigation for sensitive biological resources would be accomplished through dedication of
approximately 5.61 acres of land on-site to the City’s MHPA to compensate for the deletion
of 0.55 acre from the MHPA (net increase of 5.06 acres). Land within the MHPA could only be
used as prescribed by the City’s MSCP Subarea Plan.
3) Inside and adjacent to the MHPA, all development proposals shall be consistent with the MSCP
Subarea Plan.
As described in Section 5.1.5.2 above, the project would be consistent with MSCP Subarea
Plan.
4) Projects Located Outside the MHPA
The project is located within the MHPA. The MHPA boundary surrounds the area to be
developed.
5) Narrow Endemic Species: Outside the MHPA, measures for protection of narrow endemic species
shall be required such as management enhancement, restoration and/or transplantation.
There are no narrow endemic species are present on the project site.
5.2.7.3 Significance of Impacts
Impacts related to local policies or ordinances would be less than significant.
5.2.7.4 Mitigation, Monitoring, and Reporting
Mitigation would not be required.
5.2.8 Issue 8: Invasive Species
• Would the project result in the introduction of invasive species of plants into a natural open
space area?
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5.2.8.1 Threshold(s)
In accordance with the City’s Significance Determination Thresholds, a project would have a
significant impact if it would:
• Introduce invasive species of plants into a natural open space area.
5.2.8.2 Impacts
Invasive species are aggressive non-native plant species that threaten natural habitats by
outcompeting native species and reducing biodiversity. These plants thrive in areas disturbed by
activities such as grading, construction, and off-road-vehicle use or fire.
As described in Section 5.1.5.2c above, the project planting pallet would be consistent with the
MHPA Land Use Adjacency Guidelines regarding invasive and non-native plant species adjacent to
the MHPA. Native shrub species and hydroseed would be installed on the manufactured slope
adjacent to the MHPA on the western and eastern slopes of the project and only temporarily
irrigated until the plants have become established. A 120-day plant establishment period and a 24-
month maintenance and monitoring period are necessary to ensure that the native plants establish
successfully. Maintenance activities would involve control of non-native plant species, maintenance
and removal of the temporary irrigation system, and replacement planting (if necessary). The site
should be monitored by a biologist quarterly to evaluate site conditions and to recommend
remedial actions, if needed.
5.2.8.3 Significance of Impacts
Impacts related to invasive species would be less than significant.
5.2.8.4 Mitigation, Monitoring, and Reporting
Mitigation would not be required.
FIGURE 5.2-1
Existing Biological Resources
!(!(
Image Source: NearMaps (flown February 2019)
0 200Feet [
Project Boundary
!(San Diego Desert Woodrat Nest
Jurisdictional Waters
Wetland Waters
Non-wetland Water/Streambed
Vegetation Community/Land Cover Type
Coastal Sage Scrub
Disturbed Land
Freshwater Marsh
Non-native Grassland
Southern Mixed Chaparral
M:\JOBS5\8958\common_gis\fig5.2_1_EIR.mxd 6/27/2019 bma
FIGURE 5.2-2
Location of Primary Subarea Plan Wildlife CorridorsCARMELMTNPENASQUITOSBERNARDOCENTERWESTBERNARDO
C A RM E L VA LL E Y BLACKMOUNTAI
NC
A
M
D
E
L
N
O
R
TE
CAMINO SUR CAMINO
RUIZ BLACKMOUNTAI
NS A N DIE GUITO
UV56
§¨¦15CARM E L MTNPENASQUITOSBERNARDOCENTERWESTBERNARDO
C A RM E L VA LL E Y BLACKMOUNTAI
NC
A
M
D
E
L
N
O
R
TE
CAMINO SUR CAMINO
RUIZ BLACKMOUNTAI
NS A N DIE GUITO
UV56
§¨¦15
Image Source: NearMaps (flown February 2019)
0 3,000Feet [
Anticipated Wildlife Movement
Avion Project Boundary
M:\JOBS5\8958\common_gis\fig5.2_2_EIR.mxd 6/27/2019 bma
FIGURE 5.2-3
Location of Project Impacts
!(!(
Image Source: NearMaps (flown February 2019)
0 200Feet [Project Boundary
Plan Lines
Limit of Grading
Construction Zone
Brush Managment Zone 1
Brush Managment Zone 2
Adjusted MHPA
!(San Diego Desert Woodrat Nest
Jurisdictional Waters
Wetland Waters
Non-wetland Water/Streambed
Vegetation Community/Land Cover Type
Coastal Sage Scrub
Disturbed Land
Freshwater Marsh
Non-native Grassland
Southern Mixed Chaparral
M:\JOBS5\8958\common_gis\fig5.2_3_EIR.mxd 6/27/2019 bma
FIGURE 5.2-4
Location of Jurisdictional Waters/Wetland
and Wetland Buffer
171 ft
186 ft
171 ft
186 ft
Image Source: NearMaps (flown February 2019)
0 200Feet [Project Boundary
Plan Lines
Jurisdictional Waters
Wetland Waters
Non-wetland Water/Streambed
Wetland Buffer Distance
M:\JOBS5\8958\common_gis\fig5.2_4_EIR.mxd 6/27/2019 bma
5.0 Environmental Setting 5.3 Cultural/Historical Resources
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5.3 Cultural/Historical Resources
This section evaluates potential impacts to historical resources associated with the project. The
following discussion is based on the Historical Resources Survey Report (RECON 2019b) and Results
of the Cultural Resources Testing Program for CA-SDI-18,428 and CA-SDI-18,429 (RECON 2019c)
prepared by RECON and included as Appendices C-1 and C-2, respectively.
5.3.1 Relationship to the Black Mountain Ranch
(Subarea I) Subarea Plan
The analysis in this section updates the cultural resources analysis in the 1998 Environmental Impact
Report (EIR), with an emphasis on effects that were not addressed in the previous report. Since the
preparation of the 1998 EIR, nine previously unidentified archaeological sites were detected in the
project area.
5.3.2 Existing Conditions
The project is located on the northern slope of Black Mountain, approximately 0.6 mile south of
Carmel Valley Road/Bernardo Center Drive. Topographically, the project site is located at the upper
end of a broad north-south trending valley. A ridgeline occurs in the central portion of the site that
rises in elevation from north to south from 740 feet mean sea level to 915 feet mean sea level. The
ridge is bounded by two small canyons, one to the east and one to the west, with one main drainage
course and smaller tributaries in each. These drainages have slopes of moderate to steep grade.
There is a small meadow in the northwest corner of the property, at the mouth of the eastern
drainage. Topography slopes away to the north from the north edge of the property, eventually
meeting the La Jolla Valley, about one mile to the north. One soil type occurs on the site, San Miguel-
Exchequer rocky silt loam (U.S. Department of Agriculture 1973). This relatively shallow rocky soil is
derived from metavolcanic parent materials. As described in Section 5.2.2.1, four vegetation
communities occur on the project site. Southern mixed chaparral comprises the majority of the site,
with lesser acreages of coastal sage scrub, non-native grassland, and freshwater marsh patches.
5.3.2.1 Cultural Setting
a. Prehistoric Period
The prehistoric cultural sequence in San Diego County is generally conceived as comprising three
basic periods: the Paleoindian, dated between about 11,500 and 8,500 years ago and manifested by
the artifacts of the San Dieguito Complex; the Archaic, lasting from about 8,500 to 1,500 years ago
(A.D. 500) and manifested by the cobble and core technology of the La Jollan Complex; and the Late
Prehistoric, lasting from about 1,500 years ago to historic contact (i.e., A.D. 500 to 1769) and
represented by the Cuyamaca Complex. This latest complex is marked by the appearance of
ceramics, small arrow points, and cremation burial practices.
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The Paleoindian Period in San Diego County is most closely associated with the San Dieguito
Complex, as identified by Rogers (1938, 1939, 1945). The San Dieguito assemblage consists of well-
made scraper planes, choppers, scraping tools, crescentics, elongated bifacial knives, and leaf-
shaped points. The San Dieguito Complex is thought to represent an early emphasis on hunting
(Warren et al. 1993:III-33).
The Archaic Period brings an apparent shift toward a more generalized economy and an increased
emphasis on seed resources, small game, and shellfish. The local cultural manifestations of the
Archaic Period are called the La Jollan Complex along the coast and the Pauma Complex inland.
Pauma Complex sites lack the shell that dominates many La Jollan sites. Along with an economic
focus on gathering plant resources, the settlement system appears to have been more sedentary.
The La Jollan assemblage is dominated by rough cobble-based choppers and scrapers, and slab and
basin metates. Large side-notched and Elko series projectile points appeared. Large deposits of
marine shell at coastal sites argue for the importance of shellfish gathering to the coastal Archaic
economy.
Near the coast and in the Peninsular Mountains beginning approximately 1,500 years ago, patterns
began to emerge which suggest the ethnohistoric Kumeyaay. This period is characterized by higher
population densities and elaborations in social, political, and technological systems. Economic
systems diversify and intensify during this period, with the continued elaboration of trade networks,
the use of shell-bead currency, and the appearance of more labor-intensive, but effective
technological innovations. The late prehistoric archaeology of the San Diego coast and foothills is
characterized by the Cuyamaca Complex. It is primarily known from the work of D. L. True at
Cuyamaca Rancho State Park (True 1970). The Cuyamaca Complex is characterized by the presence
of steatite arrowshaft straighteners, steatite pendants, steatite comales (heating stones), Tizon
Brownware pottery, ceramic figurines reminiscent of Hohokam styles, ceramic “Yuman bow pipes,”
ceramic rattles, miniature pottery various cobble-based tools (e.g., scrapers, choppers,
hammerstones), bone awls, manos and metates, mortars and pestles, and Desert side-notched
(more common) and Cottonwood Series projectile points.
b. Ethnohistory
The Kumeyaay (also known as Kamia, Ipai, Tipai, and Diegueño) occupied the southern two-thirds of
San Diego County. The Kumeyaay lived in semi-sedentary, politically autonomous villages or
rancherias. Settlement system typically consisted of two or more seasonal villages with temporary
camps radiating away from these central places (Cline 1984a and 1984b). Their economic system
consisted of hunting and gathering with a focus on small game, acorns, grass seeds, and other plant
resources. The most basic social and economic unit was the patrilocal extended family. A wide range
of tools were made of locally available and imported materials. A simple shoulder-height bow was
used for hunting. Numerous other flaked stone tools were made including scrapers, choppers, flake-
based cutting tools, and biface knives. Preferred stone types were locally available metavolcanics,
cherts, and quartz. Obsidian was imported from the deserts to the north and east. Ground stone
objects include mortars and pestles typically made of locally available, fine-grained granite. Both
portable and bedrock types are known. The Kumeyaay made fine baskets. These employed either
coiled or twined construction. The Kumeyaay also made pottery, using the paddle-and-anvil
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technique. Most were a plain brown utility ware called Tizon Brownware, but some were decorated
(Meighan 1954; May 1976, 1978).
c. Spanish/Mexican/American Periods
The Spanish Period (1769–1821) represents a time of European exploration and settlement. Military
and naval forces along with a religious contingent founded the San Diego Presidio, the pueblo of San
Diego, and the San Diego Mission in 1769 (Rolle 1998). Native American culture in the coastal strip of
California rapidly deteriorated despite repeated attempts to revolt against the Spanish invaders
(Cook 1976). One of the hallmarks of the Spanish colonial scheme was the rancho system. In an
attempt to encourage settlement and development of the colonies, large land grants were made to
meritorious or well-connected individuals.
In 1821, Mexico declared its independence from Spain. During the Mexican Period (1822–1848), the
mission system was secularized by the Mexican government and these lands allowed for the
dramatic expansion of the rancho system. The southern California economy became increasingly
based on cattle ranching. San Bernardo Rancho, approximately 0.64 mile to the north, is the closest
rancho to the project. San Bernardo Rancho, 17,763 acres in size, was comprised of two land grants
given to Joseph F. Snook in 1842 and 1845 (Pourade 1969). Snook, a British sea captain, married
Maria Antonia Alvarado, daughter of Don Juan Bautista Alvarado. Don Juan owned Rancho Rincon
del Diablo, the rancho just east of San Bernardo (Pourade 1969).
A second rancho, Los Peñasquitos Rancho, is approximately 0.7 mile to the south. Los Peñasquitos
Rancho was awarded to Captain Francisco María Ruiz for meritorious service in 1823 (Pourade
1969). Los Peñasquitos Rancho comprised 8,486 acres, stretching from Soledad Canyon, near the
Pacific Ocean, to within feet of the west end of the project, at the current intersection of
Interstate 15 and Poway Road. Captain Ruiz built an adobe near Soledad Canyon and raised cattle
on the rancho, but lived in Old Town. He transferred ownership of the rancho to Don Francisco
María Alvarado, a prominent member of the San Diego community, in 1837 (Pourade 1969). Don
Alvarado lived on the rancho, continuing to raise cattle. Ownership then passed to Captain George
Johnson through his marriage to Don Francisco’s daughter, Tomasa (Pourade 1969).
The Mexican Period ended when Mexico signed the Treaty of Guadalupe Hidalgo on
February 2, 1848, concluding the Mexican–American War (1846–1848; Rolle 1998). The Battle of San
Pasqual, fought during the Mexican–American War, was fought in the San Pasqual Valley,
approximately nine miles northeast of the project. The battle was fought on December 6 and
December 7, 1846, between American forces led by General Stephen W. Kearny and a smaller
contingent of local Californios and Mexican Lancers, led by Captain Leonardo Cota and Major Andrés
Pico. The American forces lost the battle and spent the next night at the Rancho San Bernardo ranch
house. The great influx of Americans and Europeans resulting from the California Gold Rush in
1848–49 eliminated many remaining vestiges of Native American culture. California became a state
in 1850.
The American homestead system encouraged settlement beyond the coastal plain into areas where
Indians had retreated to avoid the worst of Spanish and Mexican influences (Carrico 1987; Cook
1976). A rural community cultural pattern existed in San Diego County from approximately 1870 to
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1930. These communities were composed of an aggregate of people who lived within well-defined
geographic boundaries, on farmsteads tied together through a common school district, church, post
office, and country store (Hector and Van Wormer 1986). A small community developed in the San
Dieguito River Valley to the north of the project in the late 1800s, but it was destroyed when Lake
Hodges was filled in 1917 (Pourade 1969). In the post-World War II period, the economy shifted from
ranching and agriculture to light manufacturing, military, and tourism.
5.3.2.2 Cultural Resource Investigations
a. Records Search
A record search was conducted at the South Coastal Information Center at San Diego State University
(SCIC) in December 2017 for previously recorded historical resources on the project site. A total of
56 historic resources are listed within a one-mile radius of the project. The SCIC lists two prehistoric
resources on the parcel, CA-SDI-18428 and CA-SDI-18429, both of which are flake scatters.
CA-SDI-18,428
CA-SDI-18428 is a flake scatter consisting of at least 15 quartz flakes. The core site measures 20
meters north-south by 5 meters east-west. Two additional flakes discussed in the site form
potentially increased the site dimensions to 120 meters by 40 meters. However, the site boundary
shape file did not include these two flakes. The site form noted limited ground visibility. The site was
recorded by Affinis in 2007.
CA-SDI-18,429
CA-SDI-18429 is a scatter of five quartz fakes which were in a 5-by-5-meter area. Limited ground
visibility was noted on the site form, recorded by Affinis in 2007.
b. Field Investigation
The project site was surveyed twice by RECON archaeologists; once on July 19, 2013, and a second
time on December 21, 2017. A total of seven cultural resources were identified during the July 2013
and December 2017 surveys:
• Three prehistoric isolates consisting of one or two flakes (7178-RDS-1, 7178-RDS-2, and 7178-
HJP-1)
• Two prehistoric sites (7179-HJP-2 and 7178-RDS-3)
• An historic farmstead site (7178-HJP-3)
• A historic structure and associated road (7178-RDS-4)
None of the material identified during the 2013 survey was at, or immediately adjacent to, the
mapped locations of either CA-SDI-18428 or CA-SDI-18429. The 2017 survey did find seven flakes
(7178-RDS-3) within 15 meters of the mapped location of SDI-18428. No cultural material was found
at or adjacent to the mapped location of CA-SDI-18429 during the 2017 survey. A brief description of
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all seven resources is provided below. Complete descriptions of each resource are presented in
Appendix C.
Isolates
7178-RDS-1 is a prehistoric isolate consisting of two secondary flakes. One flake was of fine-grained
porphyritic metavolcanic material and the other was of medium-grained metavolcanic material.
7178-RDS-2 is a prehistoric isolate consisting of a single white quartz secondary flake near the
mapped location of CA-SDI-18428.
7178-HJP-1 is a prehistoric isolate consisting of a single white quartz secondary flake located during
the 2013 survey near the mapped location of CA-SDI-18428.
Other Sites
7178-RDS-3 is a prehistoric site found during the 2013 survey consisting of three secondary flakes in
an area of approximately 6 square meters. No material was relocated in the mapped location of
RDS-3 during the 2017 survey. However, seven flakes were found close enough to CA-SDI-18428
during the 2017 survey to be included in an expanded boundary for that site. The area of RDS-3 has
also been included in the expanded boundary of CA-SDI-18428.
7178-HJP-2 is a prehistoric site located during the 2013 survey. It consists of two secondary flakes
and a single piece of shatter. All are fine-grained porphyritic metavolcanic material. Only one flake
was relocated during the 2017 survey.
7178-HJP-3 is a homestead site located during the 2013 survey in the northeastern corner of the
project. The existing components consist of two concrete slabs, a wall, an asphalt pad with
associated fieldstone wall, a steel tank, and a fenced-in area. There is no foundation at the house
site, as determined from aerial photographs. There is an asphalt pad immediately to the north and a
low fieldstone wall and concrete walkway on the east side. It is possible the house sat on preformed
concrete masonry piers that have been moved during or after the house was demolished in the
early 2000s.
7178-RDS-4 is a historic site consisting of two buildings and an associated dirt road found during the
2013 survey. The main building and a small storage shed are built on a graded pad that cuts into the
slope. The second building is a 10-foot-by-7-foot wood-framed storage shed with a shallow pitch
gable roof. The associated dirt road runs along the west-facing slope on the eastern side of the
project. The road is 10 to 15 feet wide and is cut into the slope.
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5.3.3 Regulatory Framework
5.3.3.1 Federal
a. National Historic Preservation Act of 1966 and National Register of
Historic Places
The National Historic Preservation Act of 1966 established the National Register of Historic Places
(NRHP) as the official federal list of cultural resources that have been nominated by state offices for
their significance at the local, state, or federal level. Listing on the NRHP provides recognition that a
property is historically significant to the nation, the state, or the community. Properties listed (or
potentially eligible for listing) on the NRHP must meet certain significance criteria and possess
integrity of form, location, or setting. Barring exceptional circumstances, resources generally must
be at least 50 years old to be considered for listing on the NRHP.
Criteria for listing on the NRHP are stated in Title 36, Part 60 of the Code of Federal Regulations
(36 Code of Federal Regulations 60). A resource may qualify for listing if there is quality of
significance in American history, architecture, archaeology, engineering, and culture present in
districts, sites, buildings, structures, and objects that possess integrity of location, design, setting,
materials, workmanship, feeling, and association; and where such resources:
• Are associated with events that have made a significant contribution to the broad patterns
of history.
• Are associated with the lives of persons significant in the past.
• Embody the distinctive characteristics of a type, period, or method of construction;
represent the work of a master; possess high artistic values; or represent a significant and
distinguishable entity whose components may lack individual distinction.
• Have yielded, or may be likely to yield, information important in prehistory or history.
Eligible properties must meet at least one of the NRHP criteria and exhibit integrity, measured by
the degree to which the resource retains its historical properties and conveys its historical character,
the degree to which the original historic fabric has been retained, and the reversibility of changes to
the property. The fourth criterion is typically reserved for archaeological and paleontological
resources. These criteria have largely been incorporated into the California Environmental Quality
Act (CEQA) Guidelines (Section 15065.5).
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5.3.3.2 State
a. California Register of Historic Resources (Public Resources Code
Section 5020 et seq.)
Properties listed, or formally designated eligible for listing, on the NRHP are automatically listed on
the California Register of Historic Resources (CRHR) as are State Historical Landmarks and Points of
Interest. The CRHR also includes properties designated under local ordinances or identified through
local historical resource surveys.
b. California Environmental Quality Act
For the purposes of CEQA, a significant historical resource is one that qualifies for the CRHR or is
listed in a local historic register or deemed significant in an historical resources survey, as provided
under Section 5025.1(g) of the Public Resources Code. A resource that is not listed in or is not
determined to be eligible for listing in the CRHR, is not included in a local register or historic
resources, or is not deemed significant in an historical resources survey may nonetheless be
deemed significant by a CEQA lead agency.
As indicated above, the California criteria (State CEQA Guidelines Section 15065.5) for the
registration of significant architectural, archaeological, and historical resources on the CRHR are
nearly identical to those for the NRHP. Furthermore, CEQA Section 21083.2(g) defines the criteria for
determining the significance of archaeological resources. These criteria include definitions for a
“unique” resource, based on its:
• Containing information needed to answer important scientific research questions and that
there is a demonstrable public interest in that information.
• Having a special and particular quality such as being the oldest or best available example of
its type.
• Being directly associated with a scientifically recognized important prehistoric or historic
event or person.
c. Native American Burials (Public Resources Code Section 5097 et seq.)
State law addresses the disposition of Native American burials in archaeological sites and protects
such remains from disturbance, vandalism, or inadvertent destruction; establishes procedures to be
implemented if Native American skeletal remains are discovered during construction of a project;
and designates the Native American Heritage Commission (NAHC) to resolve disputes regarding the
disposition of such remains. In addition, the Native American Historic Resource Protection Act
makes it a misdemeanor punishable by up to a year in jail to deface or destroy an Indian historic or
cultural site that is listed or may be eligible for listing in the CRHR.
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5.3.3.3 Local
a. City of San Diego Municipal Code: Historical Resources Regulations
In January 2000, the City’s Historical Resources Regulations (Regulations), part of the San Diego
Municipal Code (Chapter 14, Article 3, Division 2: Purpose of Historical Resources Regulations or
Sections 143.0201-143.0280), were adopted, providing a balance between sound historic
preservation principles and the rights of private property owners. The Regulations have been
developed to implement applicable local, state, and federal policies and mandates. Included in these
are the City’s General Plan, CEQA, and Section 106 of the National Historic Preservation Act of 1966.
Historical resources, in the context of the City’s Regulations, include site improvements, buildings,
structures, historic districts, signs, features (including significant trees or other landscaping), places,
place names, interior elements and fixtures designated in conjunction with a property, or other
objects historical, archaeological, scientific, educational, cultural, architectural, aesthetic, or
traditional significance to the citizens of the city. These include structures, buildings, archaeological
sites, objects, districts, or landscapes having physical evidence of human activities. These are usually
over 45 years old, and they may have been altered or still be in use.
Historic Resources Guidelines are incorporated in the City’s Land Development Code by reference.
These Guidelines set up a Development Review Process to review projects in the City. This process is
composed of two aspects: the implementation of the Historical Resources Regulations and the
determination of impacts and mitigation under CEQA.
Compliance with the Historical Resources Regulations begins with the determination of the need for
a site-specific survey for a project. Section 143.0212(b) of the Regulations requires that historical
resource sensitivity maps be used to identify properties in the City that have a probability of
containing archaeological sites. These maps are based on records maintained by the South Coastal
Information Center of the California Historic Resources Information System, as well as site-specific
information in the City’s files. If records show an archaeological site exists on or immediately
adjacent to a subject property, the City shall require a survey. In general, archaeological surveys are
required when the proposed development is on a previously undeveloped parcel, if a known
resource is recorded on the parcel or within a one-mile radius, or if a qualified consultant or
knowledgeable City staff member recommends it. A historic property (built environment) survey can
be required on a project if the properties are over 45 years old and appear to have integrity of
setting, design, materials, workmanship, feeling, and association.
Section 143.0212(d) of the Regulations states that if a property-specific survey is required, it shall be
conducted according to the Guidelines criteria. Using the survey results and other available
applicable information, the City shall determine whether a historical resource exists, whether it is
eligible for designation as a designated historical resource, and precisely where it is located.
b. Historical Resources Register
The City provides a broader set of criteria for eligibility for the City’s Historical Resources Register. As
stated in the City’s Historical Resources Guidelines, “Any improvement, building, structure, sign,
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interior element and fixture, feature, site, place, district, area, or object may be designated as
historic by the City of San Diego Historical Resources Board if it meets any of the following criteria:”
• Exemplifies or reflects special elements of the City’s, a community’s, or a neighborhood’s
historical, archaeological, cultural, social, economic, political, aesthetic, engineering,
landscaping, or architectural development;
• Is identified with persons or events significant in local, state, or national history;
• Embodies distinctive characteristics of a style, type, period, or method of construction or is a
valuable example of the use of indigenous materials or craftsmanship;
• Is representative of the notable work of a master builder, designer, architect, engineer,
landscape architect, interior designer, artist, or craftsman;
• Is listed or has been determined eligible by National Park Service for listing on the National
Register of Historic Places or is listed or has been determined eligible by the State Historic
Preservation Office for listing on the State Register of Historical Resources; or
• Is a finite group of resources related to one another in a clearly distinguishable way or is a
geographically definable area or neighborhood containing improvements which have a
special character, historical interest, or aesthetic value or which represent one or more
architectural periods or styles in the history and development of the city.
If a resource is not listed in, or determined eligible for listing in, the California Register, not included
in a local register, or not deemed significant in a historical resource survey, City criteria states that it
may nonetheless be historically significant.
c. General Plan Historic Preservation Element
The Historic Preservation Element of the General Plan provides guidance on archaeological and
historic site preservation in San Diego, including the roles and responsibilities of the Historical
Resources Board, the status of cultural resource surveys, the Mills Act, conservation easements, and
other public preservation incentives and strategies. A discussion of criteria used by the Historical
Resources Board to designate landmarks is included, as is a list of recommended steps to
strengthen historic preservation in San Diego. The Element sets a series of goals for the City for the
preservation of historic resources, and the first of these goals is to preserve significant historical
resources. These goals are realized through implementation of policies that encourage the
identification and preservation of historical resources.
City General Plan Policies HP-A.1 through HP-A.5 are associated with the overall identification and
preservation of historical resources. This includes policies to provide for comprehensive historic
resource planning and integration of such plans within City land use plans. These policies also focus
on coordinated planning and preservation of tribal resources, promoting the relationship with
Kumeyaay/Diegueño tribes. Historic Preservation policies HP-B.1 through HP-B.4 address the
benefits of historical preservation planning and the need for incentivizing maintenance, restoration,
and rehabilitation of designated historical resources.
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5.3.4 Issue 1: Prehistoric/Historic Resources
• Would the project result in an alteration, including the adverse physical or aesthetic effects
and/or the destruction of a prehistoric or historic building (including an architecturally
significant building), structure, or object or site?
5.3.4.1 Threshold
The City has developed Significance Determination Thresholds to assist staff, project proponents,
and the public in determining whether, based on substantial evidence, a project may have a
significant effect on the environment, per CEQA Guidelines Section 21082.2 and, therefore, the
environmental impact requires mitigation. The City’s Significance Determination Thresholds for
analyzing impacts to historical resources describe three kinds of impacts to historical resources:
direct, indirect, and cumulative.
Direct impacts generally result from activities that would cause damage to or have an adverse effect
on the resource. Indirect impacts (primarily for built environment resources but also applicable to
archaeological resources) include the introduction of visual, audible, or atmospheric effects that are
out of character with the historic property or alter its setting, when the setting contributes to the
property’s significance. For archaeological resources and traditional cultural properties, indirect
impacts are often the result of increased public accessibility to resources not otherwise subject to
impacts that may result in an increased potential for vandalism and site destruction. Cumulative
impacts can result from individually minor but collectively significant projects taking place over a
period of time. According to the City’s Historical Resources Guidelines, the loss of a historical
resource database due to mitigation by data recovery may be considered a cumulative impact. In
the built environment, cumulative impacts most often occur to districts, where several minor
changes to contributing properties, their landscaping, or to their setting over time could result in a
significant loss of integrity to the district as a whole.
Based on the current City of San Diego’s Significance Determination Thresholds, historical resource
impacts may be significant if the project would affect any of the following:
• A resource listed in, eligible or potentially eligible for listing in the NRHP.
• A resource listed in, or determined to be eligible by, the State Historical Resources
commission, for listing in the CRHR (Public Resources Code [PRC] Section 5024.1).
• A resource included in a local register of historical resources, as defined in Section 5020.1(k)
of the PRC, or identified as significant in an historical resource survey meeting the
requirements of Section 5024.1(g) of the PRC.
• Any object, building, structure, site, area, place, record, or manuscript which a lead agency
determines to be historically significant or significant in the architectural, engineering,
scientific, economic, agricultural, educational, social, political, military, or cultural annals of
California, provided the lead agency’s determination is supported by substantial evidence in
light of the whole record. Generally, a resource shall be considered by the lead agency to be
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“historically significant” if the resource meets the criteria for listing in the CRHR (PRC
Section 5024.1).
• An archaeological site consisting of at least three associated artifacts/ecofacts (within a
40-square-meter area) or a single feature.
• A “traditional cultural property.” A site would be considered to possess ethnic significance if
it is associated with a burial or cemetery; religious, social or transitional activities of a
discrete ethnic population; an important person or event as defined by a discrete ethnic
population; or the belief system of a discrete ethnic population.
The determination of significance of impacts on historical and unique archaeological resources is
based on the criteria found in Section 15064.5 of the State CEQA Guidelines. Section 15064.5
clarifies the definition of a substantial adverse change in the significance of a historical resource as
“physical demolition, destruction, relocation, or alteration of the resource or its immediate
surroundings such that the significance of an historical resource would be materially impaired.”
5.3.4.2 Impacts
a. CA-SDI-18,428
With the inclusion of the seven flakes found during the 2017 survey and RDS-3, the expanded
boundary of CA-SDI-18,428 increased the site area to just over 2,300 square meters. It was
determined that the site had the potential to be eligible under criterion 4 for inclusion on the CRHR,
as well as inclusion under the City Historic Resources Register (HRR), criterion a. Therefore, a testing
program was conducted that consisted of 17 shovel scrapes and 2 one-meter-square test units.
Cultural material recovered during the test were washed, cataloged, and analyzed. Based on the
results of the testing program, it was determined that CA-SDI-18,428 does not qualify as a significant
historical resource under CEQA and does not qualify under any of the four criteria for inclusion on
the California Register of Historical Resources. It was also determined that CA-SDI-18,428 does not
qualify as a significant historical resource under any of the six criteria in the current City guidelines.
Furthermore, it was also determined that CA-SDI-18,428 does not qualify as an important
archaeological site under Division 2, Article 3, of the San Diego Municipal Code, because of its
relatively limited variety and density of artifacts and the disturbed nature of the deposit. Recovered
material was subsequently curated at the San Diego Archaeological Center (SDAC).
b. CA-SDI-18,429
No cultural material was found at or adjacent to the mapped location of CA-SDI-18,429 during the
2013 or the 2017 surveys. Since limited ground visibility may have obscured cultural material, a
testing program was conducted for CA-SDI-18,429 that consisted of excavating three 2meter-square
surface scrapes. Cultural material recovered during the test was washed, cataloged, and analyzed.
Thirteen artifacts were recovered from CA-SDI-18,429, all of which were debitage. No cultural
material was found during either previous surveys of the site area. Based on the results of the
testing program, it was determined that CA-SDI-18,429 does not qualify as a significant historical
resource under CEQA and does not qualify under any of the four criteria for inclusion on the
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California Register of Historical Resources. It was also determined that CA-SDI-18,429 does not
qualify as a significant historical resource under any of the six criteria in the current City guidelines.
Furthermore, it was also determined that CA-SDI-18,429 does not qualify as an important
archaeological site under Division 2, Article 3, of the San Diego Municipal Code, because of its
relatively limited variety and density of artifacts and the disturbed nature of the deposit. Recovered
material was subsequently curated at the SDAC.
c. Isolates
All three isolates (RDS-1, RDS-2, and HJP-1) are located within the proposed development footprint
and would be disturbed by proposed grading. However, cultural isolates generally lack
characteristics that would qualify them for listing on the CRHR, and therefore, are not considered
significant historical resources. Similarly, isolates are not considered significant under the City’s
historic resource guidelines.
d. Other Sites
RDS-3
As described in Section 5.3.2.2.a above, the seven flakes were found in the vicinity of CA-SDI-18,428
during the 2017 survey and RDS-3 have been included in the expanded boundary of that site.
Therefore, potential impacts to these resources are included in the impact analysis for CA-SDI-
18,428.
HJP-2
This lithic scatter site is not within the proposed development area and would not be impacted by
the project.
RDS-4
The historic structure and associated road are not within the proposed development area and
would not be impacted by the project. Therefore, no further work on this historical resource was
required.
HJP-3
The known components of HJP-3 lack sufficient integrity to be eligible for inclusion on the CRHR or
for inclusion on the City HRR. None of the original buildings still stand, and the remaining slabs, few
walls, and tank do not convey sufficient information of setting, feeling or association of the original
farmstead on their own. The remaining elements also do not exhibit sufficient design or
construction characteristics to be eligible themselves. However, project construction may unearth
subsurface deposits associated with the farmstead, which could potentially be significant historical
resources under criterion 4 for inclusion on the CRHR and under criterion a for inclusion on the City
HRR.
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5.3.4.3 Significance of Impacts
a. CA-SDI-18,428
Implementation of the testing program for CA-SDI-18,428 determined that impacts would be less
than significant.
b. CA-SDI-18,429
Implementation of the testing program for CA-SDI-18,429 determined that impacts would be less
than significant.
c. Isolates
Impacts on all three isolates (RDS-1, RDS-2, and HJP-1) would be less than significant.
d. Other Sites
HJP-2 and RDS-4 are not located within the proposed development area and would not be impacted
by the project.
Unearthing of subsurface deposits associated with HJP-3 during project construction would have the
potential to result in a significant impact.
5.3.4.4 Mitigation, Monitoring, Reporting
MM-HIST-1: Archaeological Monitoring
I. Prior to Permit Issuance
A. Entitlements Plan Check
1. Prior to issuance of any construction permits, including but not limited to, the first
Grading Permit, Demolition Plans/Permits and Building Plans/Permits or a Notice to
Proceed for Subdivisions, but prior to the first preconstruction meeting, whichever is
applicable, the Assistant Deputy Director (ADD) Environmental designee shall verify
that the requirements for Archaeological Monitoring and Native American
monitoring have been noted on the applicable construction documents through the
plan check process.
B. Letters of Qualification have been submitted to ADD
1. The applicant shall submit a letter of verification to Mitigation Monitoring
Coordination (MMC) identifying the Principal Investigator (PI) for the project and the
names of all persons involved in the archaeological monitoring program, as defined
in the City of San Diego Historical Resources Guidelines (HRG). If applicable,
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individuals involved in the archaeological monitoring program must have completed
the 40-hour HAZWOPER training with certification documentation.
2. MMC will provide a letter to the applicant confirming the qualifications of the PI and
all persons involved in the archaeological monitoring of the project meet the
qualifications established in the HRG.
3. Prior to the start of work, the applicant must obtain written approval from MMC for
any personnel changes associated with the monitoring program.
II. Prior to Start of Construction
A. Verification of Records Search
1. The PI shall provide verification to MMC that a site specific records search (1/4 mile
radius) has been completed. Verification includes, but is not limited to a copy of a
confirmation letter from South Coastal Information Center, or, if the search was in-
house, a letter of verification from the PI stating that the search was completed.
2. The letter shall introduce any pertinent information concerning expectations and
probabilities of discovery during trenching and/or grading activities.
3. The PI may submit a detailed letter to MMC requesting a reduction to the ¼ mile
radius.
B. PI Shall Attend Precon Meetings
1. Prior to beginning any work that requires monitoring; the Applicant shall arrange a
Precon Meeting that shall include the PI, Native American consultant/monitor (where
Native American resources may be impacted), Construction Manager (CM) and/or
Grading Contractor, Resident Engineer (RE), Building Inspector (BI), if appropriate,
and MMC. The qualified Archaeologist and Native American Monitor shall attend any
grading/excavation related Precon Meetings to make comments and/or suggestions
concerning the Archaeological Monitoring program with the Construction Manager
and/or Grading Contractor.
a. If the PI is unable to attend the Precon Meeting, the Applicant shall schedule a
focused Precon Meeting with MMC, the PI, RE, CM or BI, if appropriate, prior to
the start of any work that requires monitoring.
2. Identify Areas to be Monitored
a. Prior to the start of any work that requires monitoring, the PI shall submit an
Archaeological Monitoring Exhibit (AME) (with verification that the AME has been
reviewed and approved by the Native American consultant/monitor when Native
American resources may be impacted) based on the appropriate construction
documents (reduced to 11x17) to MMC identifying the areas to be monitored
including the delineation of grading/excavation limits.
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b. The AME shall be based on the results of a site specific records search as well as
information regarding existing known soil conditions (native or formation).
3. When Monitoring Will Occur
a. Prior to the start of any work, the PI shall also submit a construction schedule to
MMC through the RE indicating when and where monitoring will occur.
b. The PI may submit a detailed letter to MMC prior to the start of work or during
construction requesting a modification to the monitoring program. This request
shall be based on relevant information such as review of final construction
documents which indicate site conditions such as depth of excavation and/or site
graded to bedrock, etc., which may reduce or increase the potential for
resources to be present.
III. During Construction
A. Monitor(s) Shall be Present During Grading/Excavation/Trenching
1. The Archaeological Monitor shall be present full-time during all soil disturbing and
grading/excavation/trenching activities which could result in impacts to
archaeological resources as identified on the AME. The Construction Manager is
responsible for notifying the RE, PI, and MMC of changes to any construction
activities such as in the case of a potential safety concern within the area being
monitored. In certain circumstances OSHA safety requirements may necessitate
modification of the AME.
2. The Native American consultant/monitor shall determine the extent of their
presence during soil disturbing and grading/excavation/trenching activities based on
the AME and provide that information to the PI and MMC. If prehistoric resources are
encountered during the Native American consultant/monitor’s absence, work shall
stop and the Discovery Notification Process detailed in Section III.B-C and IV.A-D shall
commence.
3. The PI may submit a detailed letter to MMC during construction requesting a
modification to the monitoring program when a field condition such as modern
disturbance post-dating the previous grading/trenching activities, presence of fossil
formations, or when native soils are encountered that may reduce or increase the
potential for resources to be present.
4. The archaeological and Native American consultant/monitor shall document field
activity via the Consultant Site Visit Record (CSVR). The CSVR’s shall be faxed by the
CM to the RE the first day of monitoring, the last day of monitoring, monthly
(Notification of Monitoring Completion), and in the case of ANY discoveries. The RE
shall forward copies to MMC.
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B. Discovery Notification Process
1. In the event of a discovery, the Archaeological Monitor shall direct the contractor to
temporarily divert all soil disturbing activities, including but not limited to digging,
trenching, excavating or grading activities in the area of discovery and in the area
reasonably suspected to overlay adjacent resources and immediately notify the RE or
BI, as appropriate.
2. The Monitor shall immediately notify the PI (unless Monitor is the PI) of the
discovery.
3. The PI shall immediately notify MMC by phone of the discovery, and shall also submit
written documentation to MMC within 24 hours by fax or email with photos of the
resource in context, if possible.
4. No soil shall be exported off-site until a determination can be made regarding the
significance of the resource specifically if Native American resources are
encountered.
C. Determination of Significance
1. The PI and Native American consultant/monitor, where Native American resources
are discovered shall evaluate the significance of the resource. If Human Remains are
involved, follow protocol in Section IV below.
a. The PI shall immediately notify MMC by phone to discuss significance
determination and shall also submit a letter to MMC indicating whether
additional mitigation is required.
b. If the resource is significant, the PI shall submit an Archaeological Data Recovery
Program (ADRP) which has been reviewed by the Native American
consultant/monitor, and obtain written approval from MMC. Impacts to
significant resources must be mitigated before ground disturbing activities in the
area of discovery will be allowed to resume. Note: If a unique archaeological site
is also an historical resource as defined in CEQA, then the limits on the amount(s)
that a project applicant may be required to pay to cover mitigation costs as
indicated in CEQA Section 21083.2 shall not apply.
c. If the resource is not significant, the PI shall submit a letter to MMC indicating
that artifacts will be collected, curated, and documented in the Final Monitoring
Report. The letter shall also indicate that that no further work is required.
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IV. Discovery of Human Remains
If human remains are discovered, work shall halt in that area and no soil shall be exported
off-site until a determination can be made regarding the provenance of the human remains;
and the following procedures as set forth in CEQA Section 15064.5(e), the California Public
Resources Code (Sec. 5097.98) and State Health and Safety Code (Sec. 7050.5) shall be
undertaken:
A. Notification
1. Archaeological Monitor shall notify the RE or BI as appropriate, MMC, and the PI, if
the Monitor is not qualified as a PI. MMC will notify the appropriate Senior Planner in
the Environmental Analysis Section (EAS) of the Development Services Department
to assist with the discovery notification process.
2. The PI shall notify the Medical Examiner after consultation with the RE, eithe r in
person or via telephone.
B. Isolate discovery site
1. Work shall be directed away from the location of the discovery and any nearby area
reasonably suspected to overlay adjacent human remains until a determination can
be made by the Medical Examiner in consultation with the PI concerning the
provenance of the remains.
2. The Medical Examiner, in consultation with the PI, will determine the need for a field
examination to determine the provenance.
3. If a field examination is not warranted, the Medical Examiner will determine with
input from the PI, if the remains are or are most likely to be of Native American
origin.
C. If Human Remains ARE determined to be Native American
1. The Medical Examiner will notify the Native American Heritage Commission (NAHC)
within 24 hours. By law, ONLY the Medical Examiner can make this call.
2. NAHC will immediately identify the person or persons determined to be the Most
Likely Descendent (MLD) and provide contact information.
3. The MLD will contact the PI within 24 hours or sooner after the Medical Examiner has
completed coordination, to begin the consultation process in accordance with CEQA
Section 15064.5(e), the California Public Resources and Health & Safety Codes.
4. The MLD will have 48 hours to make recommendations to the property owner or
representative, for the treatment or disposition with proper dignity, of the human
remains and associated grave goods.
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5. Disposition of Native American Human Remains will be determined between the
MLD and the PI, and, if:
a. The NAHC is unable to identify the MLD, OR the MLD failed to make a
recommendation within 48 hours after being granted access to the site, OR;
b. The landowner or authorized representative rejects the recommendation of the
MLD and mediation in accordance with PRC 5097.94 (k) by the NAHC fails to
provide measures acceptable to the landowner, the landowner shall reinter the
human remains and items associated with Native American human remains with
appropriate dignity on the property in a location not subject to further and
future subsurface disturbance, THEN
c. To protect these sites, the landowner shall do one or more of the following:
(1) Record the site with the NAHC;
(2) Record an open space or conservation easement; or
(3) Record a document with the County. The document shall be titled “Notice of
Reinterment of Native American Remains” and shall include a legal
description of the property, the name of the property owner, and the owner’s
acknowledged signature, in addition to any other information required by
PRC 5097.98. The document shall be indexed as a notice under the name of
the owner.
d. Upon the discovery of multiple Native American human remains during a ground
disturbing land development activity, the landowner may agree that additional
conferral with descendants is necessary to consider culturally appropriate
treatment of multiple Native American human remains. Culturally appropriate
treatment of such a discovery may be ascertained from review of the site
utilizing cultural and archaeological standards. Where the parties are unable to
agree on the appropriate treatment measures the human remains and items
associated and buried with Native American human remains shall be reinterred
with appropriate dignity, pursuant to Section 5.c., above.
D. If Human Remains are NOT Native American
1. The PI shall contact the Medical Examiner and notify them of the historic era context
of the burial.
2. The Medical Examiner will determine the appropriate course of action with the PI
and City staff (PRC 5097.98).
3. If the remains are of historic origin, they shall be appropriately removed and
conveyed to the San Diego Museum of Man for analysis. The decision for internment
of the human remains shall be made in consultation with MMC, EAS, the
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applicant/landowner, any known descendant group, and the San Diego Museum of
Man.
V. Night and/or Weekend Work
A. If night and/or weekend work is included in the contract
1. When night and/or weekend work is included in the contract package, the extent and
timing shall be presented and discussed at the precon meeting.
2. The following procedures shall be followed.
a. No Discoveries
In the event that no discoveries were encountered during night and/or weekend
work, the PI shall record the information on the CSVR and submit to MMC via fax
by 8AM of the next business day.
b. Discoveries
All discoveries shall be processed and documented using the existing procedures
detailed in Sections III - During Construction, and IV – Discovery of Human
Remains. Discovery of human remains shall always be treated as a significant
discovery.
c. Potentially Significant Discoveries
If the PI determines that a potentially significant discovery has been made, the
procedures detailed under Section III - During Construction and IV-Discovery of
Human Remains shall be followed.
d. The PI shall immediately contact MMC, or by 8AM of the next business day to
report and discuss the findings as indicated in Section III-B, unless other specific
arrangements have been made.
B. If night and/or weekend work becomes necessary during the course of construction
1. The Construction Manager shall notify the RE, or BI, as appropriate, a minimum of 24
hours before the work is to begin.
2. The RE, or BI, as appropriate, shall notify MMC immediately.
C. All other procedures described above shall apply, as appropriate.
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VI. Post Construction
A. Preparation and Submittal of Draft Monitoring Report
1. The PI shall submit two copies of the Draft Monitoring Report (even if negative),
prepared in accordance with the Historical Resources Guidelines (Appendix C/D)
which describes the results, analysis, and conclusions of all phases of the
Archaeological Monitoring Program (with appropriate graphics) to MMC for review
and approval within 90 days following the completion of monitoring. It should be
noted that if the PI is unable to submit the Draft Monitoring Report within the
allotted 90-day timeframe resulting from delays with analysis, special study results or
other complex issues, a schedule shall be submitted to MMC establishing agreed due
dates and the provision for submittal of monthly status reports until this measure
can be met.
a. For significant archaeological resources encountered during monitoring, the
Archaeological Data Recovery Program shall be included in the Draft Monitoring
Report.
b. Recording Sites with State of California Department of Parks and Recreation
The PI shall be responsible for recording (on the appropriate State of California
Department of Park and Recreation forms-DPR 523 A/B) any significant or
potentially significant resources encountered during the Archaeological
Monitoring Program in accordance with the City’s Historical Resources
Guidelines, and submittal of such forms to the South Coastal Information Center
with the Final Monitoring Report.
2. MMC shall return the Draft Monitoring Report to the PI for revision or, for
preparation of the Final Report.
3. The PI shall submit revised Draft Monitoring Report to MMC for approval.
4. MMC shall provide written verification to the PI of the approved report.
5. MMC shall notify the RE or BI, as appropriate, of receipt of all Draft Monitoring
Report submittals and approvals.
B. Handling of Artifacts
1. The PI shall be responsible for ensuring that all cultural remains collected are
cleaned and catalogued
2. The PI shall be responsible for ensuring that all artifacts are analyzed to identify
function and chronology as they relate to the history of the area; that faunal material
is identified as to species; and that specialty studies are completed, as appropriate.
3. The cost for curation is the responsibility of the property owner.
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C. Curation of artifacts: Accession Agreement and Acceptance Verification
1. The PI shall be responsible for ensuring that all artifacts associated with the survey,
testing and/or data recovery for this project are permanently curated with an
appropriate institution. This shall be completed in consultation with MMC and the
Native American representative, as applicable.
2. The PI shall include the Acceptance Verification from the curation institution in the
Final Monitoring Report submitted to the RE or BI and MMC.
3. When applicable to the situation, the PI shall include written verification from the
Native American consultant/monitor indicating that Native American resources were
treated in accordance with state law and/or applicable agreements. If the resources
were reinterred, verification shall be provided to show what protective measures
were taken to ensure no further disturbance occurs in accordance with Section IV –
Discovery of Human Remains, Subsection 5.
D. Final Monitoring Report(s)
1. The PI shall submit one copy of the approved Final Monitoring Report to the RE or BI
as appropriate, and one copy to MMC (even if negative), within 90 days after
notification from MMC that the draft report has been approved.
2. The RE shall, in no case, issue the Notice of Completion and/or release of the
Performance Bond for grading until receiving a copy of the approved Final
Monitoring Report from MMC which includes the Acceptance Verification from the
curation institution.
5.3.4.5 Significance after Mitigation
Implementation of mitigation measure MM-HIST-1a would reduce impacts to below a level of
significance.
5.3.5 Issue 2: Religious/Sacred Uses
• Would the project result in any impact to existing religious or sacred uses within the
potential impact area?
5.3.5.1 Threshold
In accordance with the City’s Significance Determination Thresholds (2016), prehistoric and historic
resource impacts may be significant if the project would result in:
• An impact to existing religious or sacred uses within the potential impact area.
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5.3.5.2 Impacts
No known religious or sacred uses were identified within the project site. A Native American monitor
was consulted and visited the project area. No existing religious or sacred uses, including religious
or sacred lands, were identified by the Native American monitor. A letter was sent to the NAHC in
Sacramento on January 4, 2018 requesting a search of their Sacred Lands File. A response was
received on January 9, 2018 stating that search had been completed for the project area with
negative results.
5.3.5.3 Significance of Impacts
Implementation of the project would not adversely affect any known religious or sacred uses on-
site. No impact would occur.
5.3.5.4 Mitigation, Monitoring, Reporting
Mitigation would not be required.
5.3.6 Issue 3: Human Remains
• Would the project result in the disturbance of any human remains, including those interred
outside of formal cemeteries?
5.3.6.1 Threshold
In accordance with the City’s Significance Determination Thresholds, prehistoric and historic
resource impacts may be significant if the project would result in:
• The disturbance of any human remains, including those interred outside of formal
cemeteries.
5.3.6.2 Impacts
No known burial sites or cemeteries exist within the project site, and it is not anticipated that human
remains would be discovered during construction. In the unlikely event of the discovery of human
remains during project grading, work would halt in that area and the procedures set forth in the
California Public Resources Code (Section 5097.98) and state Health and Safety Code
(Section 7050.5) would be undertaken.
5.3.6.3 Significance of Impacts
No known burial sites or cemeteries exist within the project site, and it is not anticipated that human
remains would be discovered during construction. Therefore, impacts would be less than significant.
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5.3.6.4 Mitigation, Monitoring, Reporting
Mitigation would not be required.
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5.4 Landform Alteration/Visual Quality
This section evaluates potential landform alteration/visual quality impacts associated with the
project. The following discussion focuses on the change in visual character.
5.4.1 Relationship to the Black Mountain Ranch
(Subarea I) Subarea Plan
The analysis in this section updates the landform alteration/visual quality analysis in the 1998
Environmental Impact Report (EIR), with an emphasis on effects that were not addressed in the
previous report. Because no site-specific design was proposed at the time the 1998 EIR was
prepared, impacts relative to landform alteration could not be analyzed in detail for the perimeter
properties, and impacts were considered to be potentially significant. Therefore, this section
provides a site-specific analysis of landform alteration impacts relative to the project. Other issues
related to visual quality were adequately analyzed as part of the 1998 EIR, to which this
Supplemental Environmental Impact Report is tiered. Those issues are summarized in Chapter 9.0.
5.4.2 Existing Topography and Landform
Topographically, the 5,098-acre Black Mountain Ranch Subarea, of which the project site is part, is
characterized by a variety of landforms ranging from nearly flat-lying mesas in the north to Lusardi
Creek/La Jolla Valley in the center flanked by rugged, steeply sloping hillside terrain dissected by
smaller drainages and rolling hills. The more rugged terrain is found in the northwestern portion of
the Subarea near Lusardi Creek and in the southeastern portion of the site near Black Mountain.
The broad La Jolla Valley area, which crosses the central portion of Black Mountain Ranch North
presents a gentler topography.
Topographically, the project site is located at the upper end of a broad north-south trending valley. A
ridgeline occurs in the central portion of the site that rises in elevation from north to south from
740 feet mean sea level to 915 feet mean sea level. The ridge is bounded by two small canyons, one
to the east and one to the west, with one main drainage course and smaller tributaries in each.
These drainages have slopes of moderate to steep grade. There is a small meadow in the northwest
corner of the property, at the mouth of the eastern drainage. While the project site is undeveloped,
existing residential development associated with the Heritage Bluffs project is located to the north.
5.4.3 Issue 1: Development Features
1. Project bulk, scale, materials, or style which would be incompatible with surrounding
development?
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5.4.3.1 Threshold
According to the City of San Diego’s (City’s) California Environmental Quality Act (CEQA) Significance
Determination Thresholds, impacts associated with development features may be significant if the
project would:
a. Include crib, retaining, or noise walls greater than six feet in height and 50 feet in length with
minimal landscape screening or berming where the walls would be visible to the public.
5.4.3.2 Impacts
As described in Section 3.3, Project Description, the proposed retaining walls would reach a
maximum height of 55 feet, 7 inches and be located along both sides of the existing drainage
channel that would be crossed by the arch culvert allowing for the extension of Winecreek Drive
(refer to Figure 3-3). However, the proposed retaining walls would be downslope from the project
and not exceed the elevation of the arch culvert or the development pad and therefore, not be
visible from the project site once constructed. Furthermore, the retaining walls would be developed
with earth tones that would blend in with the surrounding natural environment and would be
landscaped with cascading vines at the top of the walls that would extend downslope to provide an
aesthetically pleasing appearance from views off-site. The retaining walls along both the eastern and
western project boundaries would be 135 feet in length and vary in height from one to ten feet. The
maximum height of ten feet for these retaining walls would not exceed the height regulations of the
underlying zone limiting the height of retaining walls outside of required setbacks to 12 feet.
Although the length and height of these retaining walls to be constructed on the western and
eastern project boundaries would exceed the dimensions listed in the threshold listed above, they
would be downslope from the building pad and not visible from the project site. These retaining
walls would also be developed with earth tones that would blend in with the surrounding natural
environment and would be landscaped to provide an aesthetically pleasing appearance from views
off-site.
5.4.3.3 Significance of Impacts
Although the project proposes retaining walls that would exceed the height regulations of the
underlying zone, the retaining walls would be visible in a low visibility area nor would they result in a
negative appearance, as they are located in a low visibility area and landscaped. For these reasons,
impacts would be less than significant.
5.4.3.4 Mitigation, Monitoring, and Reporting
Mitigation would not be required.
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5.4.4 Issue 2: Landform Alteration
• Would the project result in a substantial change in the existing landform?
5.4.4.1 Threshold
According to the City’s CEQA Significance Determination Thresholds, landform alteration/visual
quality impacts may be significant if the project would:
a. Alter more than 2,000 cubic yards of earth per graded acre by either excavation or fill, and
one or more of the following conditions apply:
1) Project would disturb steep hillsides in excess of the encroachment allowance of the
Environmentally Sensitive Lands (ESL) regulations;
2) The project would create manufactured slopes higher than 10 feet or steeper than 2:1
(50 percent) slope gradient;
3) The project would result in a change in elevation of steep hillsides as determined by the
San Diego Municipal Code Section 113.0103 from existing grade to proposed grade of
more than 5 feet by either excavation or fill, unless the area over which excavation or fill
would exceed 5 feet is only at isolated points on the site; or
4) The project design includes mass terracing of natural slopes with cut or fill slopes to
construct flat-pad structures.
b. However, the above conditions may not be considered significant if one or more of the
following apply:
1) The grading plans clearly demonstrate, with both spot elevations and contours, that the
proposed landforms will very closely imitate the existing on-site landform and/or the
undisturbed, pre-existing surrounding neighborhood landforms. This may be achieved
through naturalized variable slopes.
2) The grading plans clearly demonstrate, with both spot elevations and contours, that the
proposed slopes follow the natural existing landform and at no point vary substantially
from the natural landform elevations.
3) The proposed excavation or fill is necessary to permit installation of alternative design
features such as step-down or detached buildings, non-typical roadway or parking lot
designs, and alternative retaining wall designs that reduce the project‘s overall grading
requirements.
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5.4.4.2 Impacts
Each of the individual thresholds is addressed below.
a. Would the project alter more than 2,000 cubic yards of earth per graded acre by either excavation or
fill?
Project construction would grade 15.69 acres of the 41.48-acre project site (37.8 percent). Overall,
the project proposes approximately 296,000 cubic yards of cut (maximum depth of 52 feet) and
296,000 cubic yards of fill (maximum depth of 64 feet) over the approximately 15.69-acre graded
area, resulting in a net balance of grading on the project site. The project would therefore result in
approximately 18,866 cubic yards of earthwork per graded acre. This amount of earthwork would
exceed the 2,000 cubic yards of earth graded per acre threshold. Since grading would alter more
than 2,000 cubic yards of earth per graded acre by either excavation or fill, the following is an
analysis of the additional criteria pursuant to the City’s thresholds.
1) Would project grading disturb steep (25 percent gradient or steeper) slopes in excess of the
encroachment allowance of the ESL regulations and steep hillside guidelines (LDC, Section 143.0110)?
As described in Land Use Section 5.1.3.1, the project is subject to the ESL regulations of the San
Diego Land Development Code, because the project site includes naturally steep hillsides. Project
grading would encroach into 7.86 acres of steep slopes, which constitutes 18.95 percent of the
project site. Although the project would impact an additional 5.50 acres of steep slopes to establish
manufactured slopes that would be revegetated for erosion control purposes, Section 143.0142(g) of
the Steep Hillsides Guidelines states that erosion control measures outside of the Coastal Overlay
Zone are not subject to the 25 percent development area regulations for steep slopes. Therefore,
the project’s encroachment of 7.86 acres is within the 25 percent encroachment allowance as
permitted by the City’s ESL ordinance.
2) Would the project create manufactured slopes higher than 10 feet or steeper than 2:1 (50 percent)
slope gradient?
The project would create manufactured slopes over 10 feet in height by creating cut slopes of up to
52 feet in height on the perimeter of the development area. These manufactured cut slopes would
have a gradient of 2:1 (50 percent). All manufactured slopes on the project perimeter would be
revegetated with native plant material in order to blend with the adjacent natural hillside, consistent
with the City’s grading and brush management regulations. Landscaping would help reduce the
appearance of manufactured slopes relative to the natural landform.
3) Would the project result in a change in elevation of steep natural slopes from existing grade to
proposed grade of more than 5 feet by either excavation or fill, unless the area over which excavation
or fill would exceed 5 feet is only at isolated points on the site?
Overall, the project proposes approximately 296,000 cubic yards of cut (maximum depth of 52 feet)
and 296,000 cubic yards of fill (maximum depth of 64 feet) over the approximately 15.69-acre
graded area, resulting in a net balance of grading on the project site. The maximum depths of cut
and fill for proposed grade would exceed 5 feet.
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4) Would the project design include mass terracing of natural slopes with cut or fill slopes to construct
flat-pad structures?
The project would include mass grading to terrace the underlying landform in order to create flat
pads for development. While the project site would result in terracing within the development
footprint, the project would result in grading of approximately 37.8 percent of the overall site area,
and the majority of steep natural slopes surrounding the development would be retained within the
23.75 acres of the project site (57.3 percent) proposed to be preserved as Multi-Habitat Planning
Area (MHPA) open space.
Conclusion
Construction earthwork would exceed the City’s threshold of 2,000 cubic yards per graded acre.
Although the project site contains naturally steep slopes throughout the project site, the project
would not exceed the encroachment allowance into steep slopes permitted by the ESL regulations,
and the majority of steep slopes would be preserved on-site within MHPA open space.
Manufactured slopes would exceed 10 feet in height, and excavation or fill in excess of 5 feet from
existing grade would occur around the perimeter of the development footprint. Manufactured
slopes on the project perimeter would be revegetated with native plant material in order to blend
with the adjacent natural hillside, consistent with the City’s grading and brush management
regulations. However, the project would not be consistent with threshold conditions two and three
and, therefore, would result in a substantial change in an existing landform. None of the exceptions
stated in the City’s thresholds would apply.
5.4.4.3 Significance of Impacts
The project would result in a substantial change in an existing landform. Therefore, impacts would
be significant. This impact is consistent with the conclusion in the 1998 EIR.
5.4.4.4 Mitigation, Monitoring, and Reporting
The project has been designed to minimize the visual impacts of landform alteration to the extent
feasible. As a result, the project would preserve approximately 23.75 acres of the project site (57.3
percent) within the proposed MHPA open space, which consists of natural vegetation, and would
also preserve the majority of steep slopes on-site. The project would also revegetate manufactured
slopes in order to minimize the visual impact of grading. However, no further mitigation is available
to reduce impacts associated with landform alteration.
5.4.4.5 Significance after Mitigation
Preservation of approximately 23.75 acres of natural vegetation on-site within the proposed MHPA
open space and revegetation of manufactured slopes would not fully mitigate impacts associated
with landform alteration. Therefore, impacts would remain significant and unavoidable. This
significance determination is consistent with the conclusion in the 1998 EIR.
5.0 Environmental Analysis 5.5 Air Quality
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5.5 Air Quality
This section evaluates potential short-term (construction) and long-term (operational) air quality and
odor impacts associated with the project. The following discussion is based on the Air Quality
Analysis (RECON 2019d) prepared by RECON and included as Appendix D.
5.5.1 Relationship to the Black Mountain Ranch
(Subarea I) Subarea Plan
The analysis in this section updates the air quality analysis in the 1998 Environmental Impact Report
(EIR), with an emphasis on effects that were not addressed in the previous report. Because no site-
specific design was proposed at the time the 1998 EIR was prepared, impacts relative to
construction emissions, including blasting impacts, could not be analyzed in detail for the perimeter
properties. Cumulative construction-related air quality impacts were considered to be potentially
significant. Operational air quality impacts were adequately analyzed as part of the 1998 EIR, to
which this Supplemental Environmental Impact Report (SEIR) is tiered. Those impacts are
summarized in Chapter 9.0.
5.5.2 Existing Conditions
5.5.2.1 Project Site
The existing site is undeveloped and primarily covered with vegetation. The site is comprised of a
central ridge that rises in elevation towards the south bounded by small canyons with drainage
courses to the east and west, with a dirt road located along the crest of the ridge. As the project site
is undeveloped, it is currently not a source of criteria pollutant emissions.
5.5.2.2 Regional
The project site is in the San Diego Air Basin (SDAB), which lies in the southwest corner of California
and comprises the entire San Diego region. Population and emissions are concentrated mainly in
the western portion of the county. The SDAB covers 4,260 square miles, includes about 8 percent of
the state’s population, and produces about seven percent of the state’s criteria pollutant emissions.
The City of San Diego covers approximately 330 square miles, or 8 percent, of the SDAB.
Air quality at a given location is a function of the types and quantities of pollutants being emitted
into the air locally and throughout the basin, and the dispersal rates of pollutants within the region.
The major factors affecting pollutant dispersion are wind speed and direction, the vertical dispersion
of pollutants (which is affected by inversions), and the local topography. Air quality in the SDAB is
impacted not only by local emissions but also by pollutants transported from other areas, in
particular, ozone and ozone precursor emissions transported from the South Coast Air Basin and
Mexico. Although the impact of transport is particularly important on days with high ozone
concentrations, transported pollutants and emissions cannot be blamed entirely for the ozone
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problem in the San Diego area. Studies show that emissions from the SDAB are sufficient, on their
own, to cause ozone violations.
5.5.2.3 Existing Air Quality
Existing air quality is measured based upon ambient air quality standards. These standards are the
levels of air quality that are considered safe, with an adequate margin of safety, to protect the public
health and welfare. The National Ambient Air Quality Standards (NAAQS) and California Ambient Air
Quality Standards (CAAQS) are currently in effect, as well health effects of each pollutant regulated
under these standards are shown in Table 5.5-1.
The determination of whether a region’s air quality is healthful or unhealthful is determined by
comparing contaminant levels in ambient air samples to the state and federal standards presented
in Table 5.5-1. Air quality is commonly expressed as the number of days per year in which air
pollution levels exceed the NAAQS and CAAQS. The air quality in a region is considered to be in
attainment by the state if the measured ambient air pollutant levels for ozone (O3), carbon
monoxide (CO), sulfur dioxide (SO2), nitrogen dioxide (NO2), respirable particulate matter (PM10), and
fine particulate matter (PM2.5) are not equaled or exceeded at any time in any consecutive three-year
period; and the federal standards (other than O3, PM10, PM2.5, and those based on annual averages
or arithmetic mean) are not exceeded more than once per year. The O3 standard is attained when
the fourth highest 8-hour concentration in a year, averaged over three years, is equal to or less than
the standard. For PM10, the 24-hour standard is attained when 99 percent of the daily
concentrations, averaged over three years, are equal to or less than the standard.
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Table 5.5-1
Ambient Air Quality Standards
Pollutant Averaging
Time
California Standards1 National Standards2
Concentration3 Method4 Primary3,5 Secondary3,6 Method7
Ozone8
1 Hour 0.09 ppm
(180 µg/m3) Ultraviolet
Photometry
– Same as
Primary
Standard
Ultraviolet
Photometry 8 Hour 0.07 ppm
(137 µg/m3)
0.070 ppm
(137 µg/m3)
Respirable
Particulate
Matter
(PM10)9
24 Hour 50 µg/m3 Gravimetric or
Beta
Attenuation
150 µg/m3 Same as
Primary
Standard
Inertial Separation
and Gravimetric
Analysis
Annual
Arithmetic
Mean
20 µg/m3 –
Fine
Particulate
Matter
(PM2.5)9
24 Hour No Separate State Standard 35 µg/m3
Same as
Primary
Standard Inertial Separation
and Gravimetric
Analysis Annual
Arithmetic
Mean
12 µg/m3
Gravimetric or
Beta
Attenuation
12 µg/m3 15 µg/m3
Carbon
Monoxide
(CO)
1 Hour 20 ppm
(23 mg/m3)
Non-dispersive
Infrared
Photometry
35 ppm
(40 mg/m3) –
Non-dispersive
Infrared
Photometry
8 Hour 9.0 ppm
(10 mg/m3)
9 ppm
(10 mg/m3) –
8 Hour
(Lake
Tahoe)
6 ppm
(7 mg/m3) – –
Nitrogen
Dioxide
(NO2)10
1 Hour 0.18 ppm
(339 µg/m3) Gas Phase
Chemi-
luminescence
100 ppb
(188 µg/m3) –
Gas Phase Chemi-
luminescence Annual
Arithmetic
Mean
0.030 ppm
(57 µg/m3)
0.053 ppm
(100 µg/m3)
Same as
Primary
Standard
Sulfur
Dioxide
(SO2)11
1 Hour 0.25 ppm
(655 µg/m3)
Ultraviolet
Fluorescence
75 ppb
(196 µg/m3) –
Ultraviolet
Fluorescence;
Spectro-
photometry
(Pararosaniline
Method)
3 Hour – – 0.5 ppm
(1,300 µg/m3)
24 Hour 0.04 ppm
(105 µg/m3)
0.14 ppm
(for certain
areas)11
–
Annual
Arithmetic
Mean
–
0.030 ppm
(for certain
areas)11
–
Lead12,13
30 Day
Average 1.5 µg/m3
Atomic
Absorption
– –
High Volume
Sampler and
Atomic Absorption
Calendar
Quarter –
1.5 µg/m3 (for
certain
areas)12 Same as
Primary
Standard Rolling
3-Month
Average
– 0.15 µg/m3
Visibility
Reducing
Particles14
8 Hour See footnote 14
Beta
Attenuation and
Transmittance
through Filter
Tape
No National Standards Sulfates 24 Hour 25 µg/m3 Ion Chroma-
tography
Hydrogen
Sulfide 1 Hour 0.03 ppm
(42 µg/m3)
Ultraviolet
Fluorescence
Vinyl
Chloride12 24 Hour 0.01 ppm
(26 µg/m3)
Gas Chroma-
tography
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Table 5.5-1
Ambient Air Quality Standards
NOTES:
ppm = parts per million; ppb = parts per billion; µg/m3 = micrograms per cubic meter; – = not applicable.
1 California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1 and 24 hour),
nitrogen dioxide, particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be
exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in
the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
2 National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not
to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour
concentration measured at each site in a year, averaged over three years, is equal to or less than the standard.
For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour
average concentration above 150 µg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained
when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard.
Contact the U.S. EPA for further clarification and current national policies.
3 Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are
based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air
quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this
table refers to ppm by volume, or micromoles of pollutant per mole of gas.
4 Any equivalent measurement method which can be shown to the satisfaction of the Air Resources Board to give
equivalent results at or near the level of the air quality standard may be used.
5 National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect
the public health.
6 National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known
or anticipated adverse effects of a pollutant.
7 Reference method as described by the U.S. EPA. An “equivalent method” of measurement may be used but
must have a “consistent relationship to the reference method” and must be approved by the U.S. EPA.
8 On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to
0.070 ppm.
9 On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 µg/m3 to 12.0 µg/m3.
The existing national 24-hour PM2.5 standards (primary and secondary) were retained at 35 µg/m3, as was the
annual secondary standards of 15 µg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150
µg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean,
averaged over 3 years.
10 To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily
maximum concentrations at each site must not exceed 100 ppb. Note that the national standards are in units
of parts per billion (ppb). California standards are in units of parts per million (ppm). To directly compare the
national standards to the California standards the units can be converted from ppb to ppm. In this case, the
national standard of 100 ppb is identical to 0.100 ppm.
11 On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary
standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th
percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2
national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010
standard, except that in areas designated nonattainment for the 1971 standards, the 1971 standards remain in
effect until implementation plans to attain or maintain the 2010 standards are approved.
Note that the 1-hour national standard is in units of parts per billion (ppb). California standards are in units of
parts per million (ppm). To directly compare the 1-hour national standard to the California standard the units
can be converted to ppm. In this case, the national standard of 75 ppb is identical to 0.075 ppm.
12 The ARB has identified lead and vinyl chloride as ‘toxic air contaminants’ with no threshold level of exposure for
adverse health effects determined. These actions allow for the implementation of control measures at levels
below the ambient concentrations specified for these pollutants.
13 The national standard for lead was revised on October 15, 2008 to a rolling 3-month average. The 1978 lead
standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the
2008 standard, except that in areas designated nonattainment for the 1978 standard, the 1978 standard
remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
14 In 1989, the ARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile
visibility standard to instrumental equivalents, which are “extinction of 0.23 per kilometer” and “extinction of
0.07 per kilometer” for the statewide and Lake Tahoe Air Basin standards, respectively.
SOURCE: CARB 2016.
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a. Local Air Quality
Air quality is commonly expressed as the number of days per year in which air pollution levels
exceed federal standards set by the U.S. Environmental Protection Agency (U.S. EPA) or state
standards set by the California Air Resources Board (CARB). The San Diego Air Pollution Control
District (SDAPCD) maintains 10 air quality monitoring stations located throughout the greater San
Diego metropolitan region. Air pollutant concentrations and meteorological information are
continuously recorded at these stations. Measurements are then used by scientists to help forecast
daily air pollution levels.
The San Diego–Rancho Carmel Drive monitoring station, located at 11403 Rancho Carmel Drive,
approximately 1.5 miles east of the project site, is the closest monitoring station to the project site.
This monitoring station began operation in 2015 and currently measures CO and NO2. The closest
monitoring station that measures a wider range of pollutants is the Escondido–East Valley Parkway
monitoring station, located at 600 East Valley Parkway approximately 9 miles northeast of the
project site. This monitoring station measures ozone, CO, NO2, PM10, and PM2.5. This station was
temporarily closed in August 2015, and the new Escondido monitoring station is anticipated to begin
operation in 2018. Table 2 in Appendix D provides a summary of measurements collected at the San
Diego–Rancho Carmel Drive and Escondido–East Valley Parkway monitoring stations for the years
2012 through 2016.
The most recent five years of data available is shown in Table 2 in Appendix D, which identifies the
number of days ambient air quality standards were exceeded for the study area, which is
considered to be representative of the local air quality at the project site. Additionally, data for SO2
have been omitted as attainment is regularly met in the SDAB, and few monitoring stations measure
SO2 concentrations.
5.5.2.4 Pollutants of Concern
Criteria pollutants are pollutants that are regulated through the development of human health
based and/or environmentally based criteria for setting permissible levels. The U.S. EPA has
designated six criteria pollutants of primary concern: ozone (O3), carbon monoxide (CO), sulfur
dioxide (SO2), nitrogen dioxide (NO2), lead (Pb), and particulate matter, which included to sub-
categories, particulate matter less than 10 microns (PM10) and particulate matter less than
2.5 microns (PM2.5). The U.S. EPA developed primary and secondary NAAQS. Additionally, the state of
California has developed the CAAQS, which generally set more stringent limits on the criteria
pollutants. The NAAQS and CAAQS are summarized in Table 5.5-1 above.
If an air basin is not in either federal or state attainment for a particular pollutant, the basin is
classified as non-attainment area for that pollutant. The SDAB is currently classified as a federal non-
attainment area for ozone. At the state level, the SDAB is classified a non-attainment area for ozone,
PM10, and PM2.5. Criteria pollutants, their typical sources, and effects are identified below.
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a. Ozone
Ozone is the primary component of smog. Ozone is not directly emitted into the air but is formed
through complex chemical reactions between precursor emissions of nitrogen oxides (NOX) and
reactive organic gases (ROG) (a.k.a. volatile organic compounds [VOC] or reactive organic
compounds) in the presence of sunlight. The adverse health effects associated with exposure to
ozone pertain primarily to the respiratory system. Scientific evidence indicates that ambient levels of
ozone affect not only sensitive receptors, such as asthma sufferers and children, but healthy adults
as well. Exposure to ozone has been found to significantly alter lung functions by increasing
respiratory rates and pulmonary resistance, decreasing tidal volumes (the amount of air inhaled and
exhaled), and impairing respiratory mechanics. Symptomatic responses include throat dryness,
chest tightness, headache, and nausea. About half of smog-forming emissions come from
automobiles.
b. Carbon Monoxide
Carbon monoxide is a colorless, odorless gas that is formed when carbon in fuel is not burned
completely. It is a component of motor vehicle exhaust, which contributes about 56 percent of all CO
emissions nationwide. CO enters the bloodstream through the lungs by combining with hemoglobin,
which normally supplies oxygen to the cells. However, CO combines with hemoglobin much more
readily than oxygen does, resulting in a drastic reduction in the amount of oxygen available to the
cells. Adverse health effects associated with exposure to CO concentrations include such symptoms
as dizziness, headaches, and fatigue (U.S. EPA 2017a).
Small-scale, localized concentrations of CO above the NAAQS and CAAQS may occur at intersections
with stagnation points such as those that occur on major highways and heavily traveled and
congested roadways. Localized high concentrations of CO are referred to as “CO hotspots” and are a
concern at congested intersections, where automobile engines burn fuel less efficiently and their
exhaust contains more CO.
c. Nitrogen Dioxide
Nitrogen dioxide is a brownish, highly reactive gas that is present in all urban environments. The
major human-made sources of NO2 are combustion devices, such as boilers, gas turbines, and
mobile and stationary reciprocating internal combustion engines. Inhalation is the most common
route of exposure to NO2. Because NO2 has relatively low solubility in water, the principal site of
toxicity is in the lower respiratory tract. The severity of the adverse health effects depends primarily
on the concentration inhaled rather than the duration of exposure. An individual may experience a
variety of acute symptoms, including coughing, difficulty with breathing, vomiting, headache, and
eye irritation during or shortly after exposure. After a period of approximately 4 to 12 hours, an
exposed individual may experience chemical pneumonitis or pulmonary edema with breathing
abnormalities, cough, cyanosis, chest pain, and rapid heartbeat.
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d. Sulfur Dioxide
Sulfur dioxide is a combustion product, with the primary source being power plants and heavy
industries that use coal or oil as fuel. SO2 is also a product of diesel engine combustion. The health
effects of SO2 include lung disease and breathing problems for people with asthma. SO2 in the
atmosphere contributes to the formation of acid rain.
e. Particulate Matter
Health studies have shown a significant association between exposure to particulate matter and
premature death in people with heart or lung diseases. Other important effects include aggravation
of respiratory and cardiovascular disease, lung disease, decreased lung function, asthma attacks,
and certain cardiovascular problems such as heart attacks and irregular heartbeat (U.S. EPA 2017b).
Inhalable Coarse Particles (PM10)
PM10 is particulate matter with an aerodynamic diameter of 10 microns or less. Ten microns is about
one-seventh of the diameter of a human hair. Particulate matter is a complex mixture of very tiny
solid or liquid particles composed of chemicals, soot, and dust. Under typical conditions (i.e., no
wildfires) particles classified under the PM10 category are mainly emitted directly from activities that
disturb the soil including travel on roads and construction, mining, or agricultural operations. Other
sources include windblown dust, salts, brake dust, and tire wear.
Inhalable Fine Particles (PM2.5)
Airborne, inhalable particles with aerodynamic diameter of 2.5 microns or less have been
recognized as an air quality concern requiring regular monitoring. Federal regulations required that
PM2.5 monitoring begin January 1, 1999. Similar to PM10, PM2.5 is also inhaled into the lungs and
causes serious health problems.
f. Lead
Lead is a metal found naturally in the environment as well as in manufactured products. At high
levels of exposure, lead can have detrimental effects on the central nervous system. The major
sources of lead emissions have historically been mobile and industrial sources. As a result of the
phase-out of leaded gasoline, metal processing is currently the primary source of lead emissions.
5.5.3 Regulatory Framework
5.5.3.1 Federal Regulations
The federal Clean Air Act (CAA) was enacted in 1970 and amended in 1977 and 1990 [42 United
States Code (U.S.C.) 7401] for the purposes of protecting and enhancing the quality of the nation’s
air resources to benefit public health, welfare, and productivity. In 1971, in order to achieve the
purposes of Section 109 of the CAA [42 U.S.C. 7409], the U.S. EPA developed primary and secondary
NAAQS.
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Six criteria pollutants of primary concern have been designated: O3, CO, SO2, NO2, Pb, and PM10 and
PM2.5. The primary NAAQS were established, with a margin of safety, considering long-term
exposure for the most sensitive groups in the general population (i.e., children, senior citizens, and
people with breathing difficulties). The NAAQS are presented above in Table 5.5-1. The current
NAAQS are summarized in Table 5.5-1 above.
An air basin is designated as either attainment or non-attainment for a particular pollutant. Once a
non-attainment area has achieved the ambient air quality standards for a particular pollutant, it is
redesignated as an attainment area for that pollutant. To be redesignated, the area must meet air
quality standards for three consecutive years. After redesignation to attainment, the area is known
as a maintenance area and must develop a 10-year plan for continuing to meet and maintain air
quality standards, as well as satisfy other requirements of the federal CAA. As mentioned above, the
SDAB is a non-attainment area for the federal O3 standard.
5.5.3.2 State Regulations
a. California Air Resources Board
The CARB has developed the CAAQS and generally has set more stringent limits on the criteria
pollutants than the NAAQS (see Table 5.5-1). In addition to the federal criteria pollutants, the CAAQS
also specify standards for visibility-reducing particles, sulfates, hydrogen sulfide, and vinyl chloride.
Similar to the federal CAA, the state classifies as either “attainment” or “non-attainment” areas for
each pollutant based on the comparison of measured data with the CAAQS. The SDAB is a non-
attainment area for the state O3 standards, the state PM10 standard, and the state PM2.5 standard.
b. State Implementation Plan
The State Implementation Plan (SIP) is a collection of documents that set forth the state’s strategies
for achieving ambient air quality standards. The SDAPCD is responsible for preparing and
implementing the portion of the SIP applicable to the SDAB. The SDAPCD adopts rules, regulations,
and programs to attain state and federal air quality standards, and appropriates money (including
permit fees) to achieve its objectives.
5.5.3.3 San Diego Air Pollution Control District
The SDAPCD prepared the original 1991/1992 Regional Air Quality Strategy (RAQS) in response to
requirements set forth in the California CAA. The California CAA requires areas that are designated
state non-attainment areas for O3, CO, SO2, and NO2 prepare and implement plans to attain the
standards by the earliest practicable date. The California CAA does not provide guidance on timing
or requirements for attaining the state PM10 and PM2.5 standards. Attached as part of the RAQS are
the Transportation Control Measures (TCMs) adopted by the San Diego Association of Governments
(SANDAG). Updates of the RAQS and corresponding TCM are required every three years. The RAQS
and TCM set forth the steps needed to accomplish attainment of state and federal AAQS. The most
recent update of the RAQS and TCM occurred in 2016.
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The growth projections used by the SDAPCD to develop the RAQS emissions budgets are based on
the population, vehicle trends, and land use plans developed in general plans and used by SANDAG
in the development of the regional transportation plans and sustainable communities strategy. As
such, projects that propose development that is consistent with the growth anticipated by SANDAG’s
growth projections and/or the general plan would be consistent with the RAQS. In the event that a
project would propose a development that is less dense than that associated with the General Plan,
the project would likewise be consistent with the RAQS. In the event a project proposes
development that is greater than anticipated in the growth projections, further analysis would be
warranted to determine if the project would exceed the growth projections used in the RAQS for the
specific subregional area.
The project is consistent with the Black Mountain Ranch Subarea Plan. The project site was
designated for development of 117 dwelling units, including a requirement for 19 affordable units,
in the 1998 EIR (96-7902) to which this SEIR is tiered. The project would develop 84 detached multi-
family residential units and associated streets, which would be consistent with the land use
identified for the project site in the 1998 EIR (96-7902). Project density on-site would be less than
what was assumed and analyzed for the property under the 1998 EIR, and the project would
transfer the remaining density (19 affordable housing units and 14 market-rate units) to the Black
Mountain Ranch North Village Town Center, pursuant to the density transfer allowances established
by the Subarea Plan. Therefore, the project would be consistent with the Transportation Phasing
Plan for buildout of the Subarea Plan, and would be consistent with the growth assumptions
assumed in the RAQS.
5.5.4 Issue 1 Air Quality Violations (Construction)
• Would the project result in a violation of any air quality standard or contribute substantially
to an existing or projected air quality violation?
5.5.4.1 Threshold
As stated in Appendix G of the California Environmental Quality Act (CEQA) Guidelines, “significance
established by the applicable air quality management or air pollution control district may be relied
upon.” The City’s air quality significance determination thresholds are established by the SDAPCD.
The SDAPCD sets forth quantitative emission thresholds for stationary sources. Project-related air
quality impacts would be considered significant if any of the applicable significance thresholds
presented herein are exceeded.
For CEQA purposes, these screening criteria can be used as numeric methods to demonstrate that a
project’s total emissions would not result in a significant impact to air quality. Significance
thresholds are listed in Table 5.5-2.
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Table 5.5-2
Air Quality Impact Analysis Trigger Levels
Pollutant
Emission Rate
(pounds/hour)
Emission Rate
(pounds/day)
Emission Rate
(tons/year)
Carbon Monoxide 100 550 100
Nitrogen Oxide 25 250 40
Particulate Matter less than 10 Microns -- 100 15
Sulfur Oxide 25 250 40
Lead -- 3.2 0.6
Particulate Matter less than 2.5 Microns -- 67 10
Reactive Organic Gases -- 137 15
SOURCE: City of San Diego 2016; SDAPCD, Rules 20.1, 20.2, 20.3 (SDAPCD 2016).
5.5.4.2 Impacts
Air emissions were calculated using California Emissions Estimator Model (CalEEMod) 2016.3.2
(California Air Pollution Control Officers Association [CAPCOA] 2017). CalEEMod is a tool used to
estimate air emissions resulting from land development projects in the state of California. The
model generates air quality emission estimates from three basics sources: construction sources,
area sources (e.g., landscaping equipment and natural gas heating), and mobile sources (e.g., traffic).
CalEEMod provides emission estimates of NOX, CO, sulfur oxide (SOX), PM10, PM2.5, and ROG. As
discussed, this focused air quality report analyzes short-term impacts associated with construction.
Construction-related activities are temporary, short-term sources of air emissions. Sources of
constructionrelated air emissions include:
• Fugitive dust from grading activities;
• Construction equipment exhaust;
• Construction-related trips by workers, delivery trucks, and material-hauling trucks; and
• Construction-related power consumption.
Construction-related pollutants result from dust raised during demolition and grading, emissions
from construction vehicles, and chemicals used during construction. Fugitive dust emissions vary
greatly during construction and are dependent on the amount and type of activity, silt content of the
soil, and the weather. Vehicles moving over paved and unpaved surfaces, demolition, excavation,
earth movement, grading, and wind erosion from exposed surfaces are all sources of fugitive dust.
Construction operations are subject to the requirements established in SDAPCD Regulation 4,
Rules 52, 54, and 55.
Heavy-duty construction equipment is usually diesel powered. In general, emissions from diesel-
powered equipment contain more NOX, SOX, and particulate matter than gasoline-powered engines.
However, dieselpowered engines generally produce less CO and less ROG than gasoline-powered
engines. Standard construction equipment includes tractors/loaders/backhoes, rubber-tired dozers,
excavators, graders, cranes, forklifts, rollers, paving equipment, generator sets, welders, cement and
mortar mixers, and air compressors.
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Primary inputs are the numbers of each piece of equipment and the length of each construction
stage. Specific construction phasing and equipment parameters are not available at this time.
However, CalEEMod can estimate the required construction equipment when project-specific
information is unavailable. The estimates are based on surveys, performed by the South Coast Air
Quality Management District and the Sacramento Metropolitan Air Quality Management District of
typical construction projects, which provide a basis for scaling equipment needs and schedule with a
project’s size. Air emission estimates in CalEEMod are based on the duration of construction phases;
construction equipment type, quantity, and usage; grading area; season; and ambient temperature,
among other parameters. Emissions were modeled assuming that construction would last
approximately two years. Construction equipment included in the emission calculations was based
on construction equipment required for the adjacent Heritage Bluffs project, which required
construction and blasting activities that would be similar to the project.
Table 5.5-3 shows the total projected construction maximum daily emission levels for each criteria
pollutant. Standard dust control measures would be implemented as a part of project construction
in accordance with SDAPCD rules and regulations. Fugitive dust emissions were calculated using
CalEEMod default values, and did not take into account the required dust control measures.
Additionally, the area around the blast site would be watered the day before and the morning of the
blast in order to dampen the dust. Thus, the emissions shown in Table 5.5-3 are conservative.
Table 5.5-3
Summary of Worst-case Construction Emissions
(pounds per day)
Emissions
ROG NOX CO SOX PM10 PM2.5
Site Preparation 4 46 23 <1 21 12
Grading/Blasting 13 120 87 <1 15 10
Building Construction 2 20 18 <1 1 1
Paving 1 13 15 <1 1 1
Architectural Coatings 24 2 2 <1 <1 <1
Maximum Daily Emissions 24 120 87 <1 21 12
Significance Threshold 250 250 550 250 100 67
ROG = reactive organic gases; NOX = nitrogen oxide; CO = carbon monoxide;
SOX = sulfur oxide; PM10 = particulate matter less than 10 microns;
PM2.5 = particulate matter less than 2.5 microns
As shown in Table 5.5-3, project construction would not exceed the applicable regional emissions
thresholds, including those for PM10 and PM2.5. These thresholds are designed to provide limits
below which project emissions would not significantly change regional air quality. Therefore, as
construction emissions would be well below these limits, the project would not result in regional
emissions that would exceed the NAAQS or CAAQS or contribute to existing violations. Furthermore,
Table 5.5-3 shows that construction emissions of PM10 and PM2.5 would not exceed 100 pounds per
day. Therefore, the project would not violate any air quality standard or contribute substantially to
an existing or projected air quality violation.
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5.5.4.3 Significance of Impacts
The project would not exceed construction emission levels based on the significance determination
thresholds. Therefore, maximum daily construction emissions are projected to be less than the
applicable thresholds for all criteria pollutants, and impacts would be less than significant.
5.5.3.4 Mitigation, Monitoring, Reporting
Mitigation would not be required.
5.5.5 Issue 2: Sensitive Receptors (Construction)
• Would the project expose sensitive receptors to substantial pollutant concentrations?
5.5.5.1 Threshold
The SDAPCD’s Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program Health
Risk Assessments (SDAPCD 2015) provides guidance to perform health risk assessments (HRAs)
within the SDAB. Although the SDAPCD guidance is specifically targeted toward health risk from air
toxic emissions from stationary source operations, the thresholds were adapted here for
informational purposes. The SDAPCD’s current thresholds of significance for toxic air contaminant
emissions from the operations of permitted and non-permitted sources are presented in
Table 5.5-4.
Table 5.5-4
SDAPCD CEQA Toxic Air Contaminant Emissions Thresholds
Carcinogens
Non-Carcinogens
Chronic
Maximally exposed individual risk
equals or exceeds 10 in 1 million
Hazard Index equals or exceeds 1
for the maximally exposed individual
5.5.5.2 Impacts
Sensitive land uses include schools and schoolyards, parks and playgrounds, daycare centers,
nursing homes, hospitals, and residential communities. Sensitive receptors surrounding the project
site are limited to residential uses located northeast of the project site.
Construction of the project and associated infrastructure would result in short-term diesel exhaust
emissions from on-site heavy-duty equipment. Construction of the project would result in the
generation of dieselexhaust diesel particulate matter (DPM) emissions from the use of off-road
diesel equipment required for site grading and excavation, paving, and other construction activities
and on-road diesel equipment used to bring materials to and from the project site.
Generation of DPM from construction projects typically occurs in a single area for a short period.
According to the Office of Environmental Health Hazard Assessment (OEHHA), health risk
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assessments, which determine the exposure of sensitive receptors to toxic emissions, should be
based on a 30-year exposure period; however, such assessments should be limited to the
period/duration of activities associated with the project (OEHHA 2015). Thus, if the duration of
proposed construction activities near any specific sensitive receptor were two years, the exposure
would be less than 6 percent of the total exposure period used for health risk calculation.
Therefore, because of the limited size of the project and the short duration of construction, DPM
generated by construction is not expected to create conditions where the probability is greater than
10 in 1 million of contracting cancer for the Maximally Exposed Individual or to generate ground-
level concentrations of non-carcinogenic toxic air contaminants that exceed a Hazard Index greater
than 1 for the Maximally Exposed Individual. Additionally, with ongoing implementation of U.S. EPA
and CARB requirements for cleaner fuels; off-road diesel engine retrofits; and new, low-emission
diesel engine types, the DPM emissions of individual equipment would be substantially reduced
over time.
Soils within the regional area are known to possess naturally occurring subsurface arsenic.
Consequently, dust generated from blasting operations required during project construction would
have the potential to release naturally occurring subsurface arsenic, which could result in short-term
exposure.
5.5.5.3 Significance of Impacts
Construction of the project would not expose sensitive receptors to substantial pollutant
concentrations, and impacts related to DPM would be less than significant. However, dust generated
from blasting operations required during project construction would have the potential to release
naturally occurring subsurface arsenic, which could result in short-term exposure that may result in
a significant impact.
5.5.5.4 Mitigation, Monitoring, Reporting
MM-AIR-1a: Arsenic Testing Protocol in Areas Requiring Blasting
Geocon shall obtain periodic random samples from select air-track borehole spoils or the ground
surface over the course of the blasting program. The number of samples shall vary and be based on
judgement depending on the size of the shot. The samples shall be assigned for analysis of arsenic
using U.S. Environmental Protection Agency Test Method 6010B with a reporting limit of
1.0 milligram per kilogram. The sampling shall be performed under the direct supervision of
Geocon’s Project Manager and Professional Geologist.
MM-AIR-1b: Blasting Dust Mitigation Plan
The following protocols shall be performed to minimize the generation of visible dust during the
hard rock blasting events:
• The areas shall be heavily watered prior to the planned blasting. The amount of water
applied shall depend on the size of the shot and composition of the materials exposed at the
top of the shot (i.e., topsoil vs. hard rock).
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• A water truck shall be dedicated to pre-wet the ground surface.
• Detergent, if necessary, shall be added to the water truck to reduce the surface tension of
the water and promote soaking into the surface materials. The water used shall be confined
to the area of the shot and not be allowed to migrate out of the work limits. Confinement of
the water shall be achieved through use of earthen berms, ditches, or other containment
features that shall prevent migration of the water outside the work area.
• Once the boreholes are loaded with blasting agent, a final soaking shall occur just prior to
the shot.
5.5.5.5 Significance after Mitigation
Implementation of MM-AIR-1a and MM-AIR-1b would reduce potential impacts associated with dust
generated from blasting operations that would have the potential to release naturally occurring
subsurface arsenic to below a level of significance.
5.5.6 Issue 3: Odor (Construction)
• Would the project create objectionable odors affecting a substantial number of people?
5.5.6.1 Threshold
Per the City’s CEQA Significance Determination Thresholds, determining the significance of potential
odor impacts should be based on what is known about the quantity of the odor compound(s) that
would result from the project’s proposed use(s), the types of neighboring uses potentially affected,
the distance(s) between the project’s point source(s) and the neighboring uses such as sensitive
receptors, and the resultant concentration(s) at receptors.
SDAPCD Rule 51 (Public Nuisance) prohibits emission of any material that causes nuisance to a
considerable number of persons or endangers the comfort, health, or safety of any person (SDAPCD
1969). A project that proposes a use that would produce objectionable odors would be deemed to
have a significant odor impact if it would affect a considerable number of off-site receptors.
5.5.6.2 Impacts
During construction, diesel equipment may generate some nuisance odors. Sensitive receptors near
the project site include residential uses; however, exposure to odors associated with project
construction would be short term and temporary in nature.
5.5.6.3 Significance of Impacts
Exposure to odors associated with construction would be short term and temporary in nature, and
impacts would be less than significant.
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5.5.6.4 Mitigation, Monitoring, Reporting
Mitigation would not be required.
5.5.7 Issue 4: Particulate Matter (Construction)
• Would the project exceed 100 pounds per day of particulate matter (dust)?
5.5.7.1 Threshold
Per the City’s CEQA Significance Determination Thresholds, the project would have significant effects
if a project would:
• Exceed 100 pounds of PM dust per day.
5.5.7.2 Impacts
As shown in Table 5.5-3, emissions of PM10 from construction would be below the City’s significance
threshold of 100 pounds per day.
5.5.7.3 Significance of Impacts
Construction of the project would not result in PM10 emissions exceeding 100 pounds per day, and
impacts would be less than significant.
5.5.7.4 Mitigation, Monitoring, Reporting
Mitigation would not be required.
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5.6 Noise
This section evaluates potential noise impacts associated with the project. The following discussion
is based upon the Noise Analysis (RECON 2019e) prepared by RECON and included as Appendix E.
5.6.1 Relationship to the Black Mountain Ranch
(Subarea I) Subarea Plan
The analysis in this section updates the noise analysis in the 1998 Environmental Impact Report
(EIR), with an emphasis on effects that were not addressed in the previous report. Because no site-
specific design was proposed at the time the 1998 EIR was prepared, impacts relative to
construction noise, including blasting impacts, could not be analyzed in detail for the perimeter
properties, including the project site. Construction-related noise impacts, including impacts to the
adjacent Multi-Habitat Planning Area (MHPA) from development of the Southeast Perimeter
properties, were considered to be potentially significant. The Noise Analysis addresses anticipated
construction noise associated with land preparation activities, including blasting, which was not
considered in the 1998 EIR analysis. Operational noise impacts were adequately analyzed as part of
the 1998 EIR, to which this Supplemental Environmental Impact Report (SEIR) is tiered. Those
impacts are summarized in Chapter 9.0.
5.6.2 Existing Conditions
The project site is located in a developing area that consists primarily of residential development
and open space. A majority of the project site is surrounded by open space. The nearest circulation
element roadway is Carmel Valley Road, which is approximately 2,800 feet to the north. Local
residential streets are located in the newly constructed single-family residential neighborhood to the
northeast. However, these local streets only provide access to the neighborhood and do not carry a
significant amount of traffic. Existing noise levels on the project site would be similar to an open
space and single-family residential neighborhood, which are relatively quiet. Distant vehicle traffic
on Carmel Valley Road is the main transportation-related noise source. The existing traffic volume
and speed for Carmel Valley Road were obtained from the San Diego Association of Governments
Traffic Forecast Information Center (SANDAG 2019). Based on an existing traffic volume of 26,800
and a speed of 50 miles per hour on Carmel Valley Road, using Federal Highway Administration
(FHWA) algorithms, it was calculated that the existing vehicle traffic noise level on the project site is
approximately 57 CNEL (Appendix E).
5.6.2.1 Fundamentals of Noise
Sound levels are described in units called the decibel (dB). Decibels are measured on a logarithmic
scale that quantifies sound intensity in a manner similar to the Richter scale used for earthquake
magnitudes. Thus, a doubling of the energy of a noise source, such as doubling of traffic volume,
would increase the noise level by 3 dB; a halving of the energy would result in a 3 dB decrease.
However, human perception of noise has no simple correlation with acoustical energy. A change in
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noise levels is generally perceived as follows: 3 A-weighted dB [dB(A)] barely perceptible, 5 dB(A)
readily perceptible, and 10 dB(A) perceived as a doubling or halving of noise (California Department
of Transportation 2013).
In technical terms, sound levels are described as either a “sound power level” or a “sound pressure
level,” which while commonly confused are two distinct characteristics of sound. Both share the
same unit of measure, the dB. However, sound power, expressed as Lpw, is the energy converted
into sound by the source. As sound energy travels through the air, it creates a sound wave that
exerts pressure on receivers such as an ear drum or microphone, the sound pressure level. Sound
measurement instruments only measure sound pressure, and limits used in standards are generally
sound pressure levels.
The human ear is not equally sensitive to all frequencies within the sound spectrum. To
accommodate this phenomenon, the A-scale, which approximates the frequency response of the
average young ear when listening to most ordinary everyday sounds, was devised. When people
make relative judgments of the loudness or annoyance of a sound, their judgments correlate well
with the A-scale sound levels of those sounds. Therefore, the “A-weighted” noise scale is used for
measurements and standards involving the human perception of noise. Noise levels using A-
weighted measurements are designated with the notation dB(A).
The impact of noise is not a function of loudness alone. The time of day when noise occurs and the
duration of the noise are also important. In addition, most noise that lasts for more than a few
seconds is variable in its intensity. Consequently, a variety of noise descriptors has been developed.
The noise descriptors used for this study is the equivalent noise level (Leq). The Leq is the equivalent
steady-state noise level in a stated period of time that is calculated by averaging the acoustic energy
over a time period; when no period is specified, a 1-hour period is assumed.
Sound from a localized source (approximating a “point” source) radiates uniformly outward as it
travels away from the source in a spherical pattern, known as geometric spreading. The sound level
decreases or drops off at a rate of 6 dB(A) for each doubling of the distance.
Traffic noise is not a single, stationary point source of sound. The movement of vehicles makes the
source of the sound appear to emanate from a line (line source) rather than a point when viewed
over some time interval. The drop-off rate for a line source is 3 dB(A) for each doubling of distance.
The propagation of noise is also affected by the intervening ground, known as ground absorption. A
hard site (such as parking lots or smooth bodies of water) receives no additional ground
attenuation, and the changes in noise levels with distance (drop-off rate) are simply the geometric
spreading of the source. A soft site (such as soft dirt, grass, or scattered bushes and trees) provides
an additional ground attenuation value of 1.5 dB(A) per doubling of distance. Thus, a point source
over a soft site would drop off at 7.5 dB(A) per doubling of distance.
5.6.2.2 Fundamentals of Vibration
Groundborne vibration consists of oscillatory waves that propagate from the source through the
ground to adjacent structures. The frequency of a vibrating object describes how rapidly it is
oscillating. The number of cycles per second of oscillation is the vibration frequency, which is
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described in terms of hertz, abbreviated hertz (Hz). The normal frequency range of most
groundborne vibration that can be felt generally starts from a low frequency of less than 1 Hz to a
high of about 200 Hz.
While people have varying sensitivities to vibrations at different frequencies, in general they are
most sensitive to low-frequency vibration. Vibration in buildings caused by construction activities
may be perceived as motion of building surfaces or rattling of windows, items on shelves, and
pictures hanging on walls. Vibration of building components can also take the form of an audible
low-frequency rumbling noise, which is referred to as groundborne noise. Groundborne noise is
usually only a problem when the originating vibration spectrum is dominated by frequencies in the
upper end of the range (60 to 200 Hz), and when the structure and the construction activity are
connected by foundations or utilities, such as sewer and water pipes.
Although groundborne vibration is sometimes noticeable in outdoor environments, groundborne
vibration is almost never annoying to people who are outdoors (Federal Transit Administration [FTA]
2006). The primary concern from vibration is the ability to be intrusive and annoying to local
residents and other indoor vibration sensitive land uses.
Vibration energy spreads out as it travels through the ground, causing the vibration level to diminish
with distance away from the source. High frequency vibrations reduce much more rapidly than low
frequencies, so that low frequencies tend to dominate the spectrum at large distances from the
source. Discontinuities in the soil strata can also cause diffractions or channeling effects that affect
the propagation of vibration over long distances. When vibration encounters a building, a ground-to-
foundation coupling loss will usually reduce the overall vibration level. However, under certain
circumstances, the ground-to-foundation coupling may also amplify the vibration level due to
structural resonances of the floors and walls.
Vibration levels are usually expressed as single-number measure of vibration magnitude, in terms of
velocity or acceleration, which describes the severity of the vibration without the frequency variable.
The peak particle velocity (PPV) is defined as the maximum instantaneous positive or negative peak
of the vibration signal, usually measured in inches per second (in/sec). Since it is related to the
stresses that are experienced by buildings, PPV is often used in monitoring of blasting vibration.
Vibration-sensitive receivers are generally considered the same as noise-sensitive receivers, but may
also include historical structures, laboratories, research facilities, and similar facilities. All vibration-
sensitive receivers in the vicinity of the project are typical residential uses. There are no special uses
or historic structures affected by the project.
5.6.3 Regulatory Framework
5.6.3.1 Vibration
The threshold for blasting vibration impacts, as established by the U.S. Bureau of Mines, is 2.0 in/sec
PPV at the closest structure. Additionally, as required by the County of San Diego Fire Code, pre- and
post-blast inspections for building damage would be conducted by the blasting contractor prior to
the first blast.
5.0 Environmental Analysis 5.6 Noise
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Based on best available data, impacts for hydraulic breakers, or hammers, and other non-transient
sources such as those associated with project construction shall be considered significant if the PPV
exceeds 0.2 in/sec.
5.6.3.2 City of San Diego Municipal Code
The City of San Diego regulates construction noise through Section 59.5.0404 of the City’s Noise
Abatement and Control Ordinance as follows:
(a) It shall be unlawful for any person, between the hours of 7:00 p.m. of any day and 7:00 a.m.
of the following day, or on legal holidays as specified in Section 21.04 of the San Diego
Municipal Code, with exception of Columbus Day and Washington’s Birthday, or on Sundays,
to erect, construct, demolish, excavate for, alter or repair any building or structure in such a
manner as to create disturbing, excessive or offensive noise. . . .
(b) [I]t shall be unlawful for any person, including the City of San Diego, to conduct any
construction activity so as to cause, at or beyond the property lines of any property zoned
residential, an average sound level greater than 75 decibels during the 12-hour period from
7:00 a.m. to 7:00 p.m.
5.6.3.3 MSCP Subarea Plan
The City of San Diego’s Multiple Species Conservation Program (MSCP) and MHPA adjacency
requirements, as well as associated guidelines produced by the U.S. Fish and Wildlife Service,
require that noise be limited to a level not to exceed an hourly limit of 60 dB(A) Leq or the average
ambient noise level, whichever is greater, at the edge of MHPA habitat during the identified sensitive
species breeding season of February 1 to September 15.
5.6.4 Issue 1: Noise and Vibration (Construction)
• Would the project result in or create a significant increase in the existing ambient noise
levels, which exceed the City’s noise ordinance?
• Would the project expose persons to or generate excessive ground-borne noise vibration?
5.6.4.1 Threshold
According to the City’s CEQA Significance Determination Thresholds, a project would have a
significant noise impact if it would result in:
• Exposure of people to construction noise levels that exceed the City’s adopted Noise
Ordinance, San Diego Municipal Code, Section 5.9.5.0404 (i.e., 75 dB(A) Leq).
5.0 Environmental Analysis 5.6 Noise
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Additionally, the project would have a significant groundborne vibration impact if it would result in:
• Exposure of the nearest sensitive receiver to hydraulic breakers, hammers, and other non-
transient source vibration levels that exceed 0.2 in/sec PPV; or blasting vibration levels that
exceed 2.0 in/sec PPV.
5.6.4.2 Impacts
a. Residential Receivers
Construction activities produce varying degrees of ground vibration, depending on the equipment
and methods employed. However, with a few exceptions, ground vibrations from typical
construction activities very rarely reach levels high enough to cause damage to structures. Noise and
vibration generated by general construction activities associated with the project were assessed in
the Subarea Plan EIR. Consequently, excavation and other general construction activities are not
assessed in this analysis. The noise and vibration analysis focused on the recently identified options
for rock removal, including hammering, drilling, and blasting. As with noise, vibrations are
attenuated by distance. The vibrations that would be produced by hammering, drilling, a nd blasting
would travel relatively short distances as compared to noise. Therefore, the noise analysis focused
on the receivers located northeast of the project site (Figure 5.6-1). The nearest receivers are the
single-family homes associated with the Heritage Bluffs project, which is currently under
construction and will be occupied once construction on this project begins. The nearest receptor is
(would be) located approximately 175 feet northeast of the nearest hammering, drilling, and blasting
location. The methodology use in the noise analysis is presented in Appendix E.
Hammering
Noise
Mounted hydraulic impact hammers would be used to remove the top of the rock formation.
Hydraulic hammers used for rock breaking are assumed to operate at maximum power for
approximately 20 percent of a given hour ( FHWA 2008). A loader/backhoe would likely be used to
clear broken rock and would have a utilization factor of approximately 40 percent. Rock breaking
with hydraulic hammers is calculated to generate maximum noise levels on the order of 90 dB(A) at
50 feet. Assuming two hydraulic hammers and one loader/backhoe are operating for a full hour,
hydraulic-hammer rock breaking would generate hourly noise levels of 86 dB(A) Leq at 50 feet. Based
on standard point source propagation noise levels, noise levels would attenuate to 75 dB(A) Leq at
the nearest residential property line 175 feet to the northeast, which would comply with the City’s
applicable construction noise level standards.
Vibration
According to the FTA, vibration levels associated with the use of mounted impact hammers are
0.089 in/sec PPV at 25 feet. Using FTA’s recommended procedure for applying a propagation
adjustment to these reference levels, vibration levels would exceed Caltrans-recommended
threshold (0.2 in/sec PPV) at distances of 14 feet or less from a mounted hydraulic hammer.
Vibrations at various distances are shown in Table 5.6-1. Vibration levels are anticipated to attenuate
5.0 Environmental Analysis 5.6 Noise
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Page 5.6-6
to 0.005 in/sec PPV at nearest residential property line 175 feet to the northeast, which would not
exceed 0.2 in/sec PPV from hydraulic hammering at local residences.
Table 5.6-1
Predicted Hydraulic Hammering Vibration Levels
Distance to Construction
Non-rippable Rock
(feet)
Impact
Criteria
(in/sec PPV)
Predicted
Vibration Level
(in/sec PPV)
Potential
Significant
Impact
5
0.2
0.995 Yes
10 0.352 Yes
11 0.305 Yes
12 0.268 Yes
13 0.237 Yes
14 0.212 Yes
15 0.191 No
20 0.124 No
25 0.089 No
175 – nearest residence 0.005 No
in/sec = inches per second; PPV = peak particle velocity
Bold = Exceeds 0.2 in/sec PPV
Drilling
Noise
As an alternative to hammering, drilling may be used to prepare the boreholes for explosives. While
the numbers and diameters of the boreholes are dependent on the actual blasting process, the
noise levels generated by a rock drill would not vary. According to the FHWA, a rock drill typically
generates maximum noise levels of 85 dB(A) Leq at 50 feet. As discussed previously, this is reduced
by the actual time the equipment is generating the maximum noise in a given hour. Based on the
FHWA data, a rock drill generates the greatest noise levels for approximately 20 percent of an hour.
Thus, a single rock drill would generate an hourly noise level of 78 dB(A) Leq at 50 feet. Assuming the
use of a rock drill and a loader/backhoe are operating for a full hour, rock drilling operations would
generate hourly noise levels of 80 dB(A) Leq at 50 feet. Based on standard point source propagation
noise levels, noise levels would attenuate to 69 dB(A) Leq at the nearest residential property line
175 feet to the northeast, which is less than the City’s applicable construction noise level limit of
75 dB(A) Leq.
Vibration
According to the FTA, vibration levels associated with the use of rock drills are estimated to generate
0.089 in/sec PPV at 25 feet, which is the same level as the hydraulic impact hammer. Consequently,
vibration levels generated by rock drilling would be the same as those shown in Table 5.6-1, and
would attenuate to 0.005 in/sec PPV at nearest residential property line 175 feet to the northeast.
5.0 Environmental Analysis 5.6 Noise
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Page 5.6-7
Blasting
Noise
Blasting involves drilling boreholes and placing small amounts of explosives in each hole. By limiting
the amount of explosives in each hole, the blasting contractor can limit the fraction of the total
energy released at any single time, which can limit noise and vibration levels. When explosive
charges detonate in rock, almost all of the available energy from the explosion is used in breaking
and displacing the rock mass. However, some blast energy escapes into the atmosphere as a
sequence of airborne sound waves, a phenomenon known as “air blast over-pressure.” These sound
waves are very low frequency, below the audible range. Very high blast over-pressure levels can
rattle or in some cases break windows. However, air-blast over pressure rarely reaches levels that
could cause building damage with modern blasting practices.
According to the FHWA, within the audible frequency range, a blast generates maximum noise levels
on the order of 101 dB(A) Lmax. However, the total time for a blast would be seconds and only one
blasting event would occur in a given hour. Consequently, hourly noise levels from blasting are
calculated at 74 dB(A) Leq at 50 feet, and would not exceed 75 dB(A) Leq at the nearest residence
175 feet to the northeast.
Vibration
Vibration levels associated with blasting are site-specific and are dependent on the amount of
explosives used, soil conditions between the blast site and the receptor, and the elevation where
blasting would take place (specifically, how far below surface elevation where bedrock would be
encountered). At the current stage of project design, a blasting and monitoring plan has not been
completed. Therefore, specifics, such as the explosive, blasting quantities, and exact locations, have
not been identified. However, it can be assumed all blasting locations would be within the
boundaries of the non-rippable rock, and to be conservative, all the non-rippable rock is considered
a blasting location. Consequently, noise and vibration impacts from blasting are calculated from the
nearest location of the non-rippable rock to the nearest receiver, which is approximately 175 feet to
the northeast (see Figure 5.6-1).
Ranges of vibration levels have been predicted at various distances from potential blasting sites for
quantities of explosives ranging from 0.25 pound to 12 pounds per charge weight. The range of
vibration levels in this analysis is due primarily to the quantity of explosive, as all other parameters
were held constant. As shown in Table 5.6-2, blasting is predicted to generate vibration levels
ranging from 0.06 in/sec PPV (from a 0.25-pound charge) to 1.34 in/sec PPV (from a 12-pound
charge) at the nearest residence. Calculations are based on a receiver distance of 175 feet, which is
the approximate distance to the nearest receiver from a potential blasting location. Calculation
details are provided in the Noise Analysis (see Appendix E)
The resulting PPV from blasting can be decreased through best engineering practices used by
professional, licensed, blasters, including, but not limited to, orienting the progressions of the charges
away from receivers, decreasing confinement of the explosive energy, increasing spatial distribution of
the charges, and increasing time of energy release or detonation. The County of San Diego Fire Code
includes a minimum energy release time for individual charges of 8 milliseconds to limit vibrations.
5.0 Environmental Analysis 5.6 Noise
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Page 5.6-8
Additionally, empirical data has shown that delays of as little as 5 milliseconds can minimize vibration
in very close blasting situations (10 to 25 feet) (Bender 2007).
Table 5.6-2
Predicted Blasting Vibration Levels by Charge Weight
Distance to
Non-Rippable Rock
(feet)
Predicted Vibration Level by Charge Weight
(in/sec PPV)
12 lb. 10 lb. 8 lb. 4 lb. 2 lb. 1 lb. 0.5 lb. 0.25 lb.
10 130.93 113.16 94.66 54.37 31.23 17.93 10.30 5.92
50 9.97 8.62 7.21 4.14 2.38 1.37 0.78 0.45
100 3.29 2.84 2.38 1.37 0.78 0.45 0.26 0.15
150 1.72 1.49 1.24 0.71 0.41 0.24 0.14 0.08
175 – nearest
residence 1.34 1.16 0.97 0.56 0.32 0.18 0.11 0.06
200 1.08 0.94 0.78 0.45 0.26 0.15 0.09 0.05
in/sec = inches per second; PPV = peak particle velocity; lb. = pounds
NOTE: Bold numbers indicate an exceedance of 2.0 in/sec PPV, which would be considered an impact.
As shown in Table 5.6-2, the nearest receiver located 175 feet to the northeast of the proposed
blasting locations is not anticipated to be exposed to vibration levels in excess of 2.0 in/sec PPV.
Although a project-specific blasting plan and exact amount of explosive needed is not known at this
time, the project would comply with the County Fire Code and would implement all feasible
vibration reduction strategies, including conducting pre- and post-construction surveys of the
nearest residence to any blast. The project would also monitor blasting vibrations and overpressure
levels, the results of the monitoring would be used to reduce charge weights, increase timing
between charges, or other appropriate measures as required to reduce vibrations from blasting.
Furthermore, the proposed blasting activities would be subject to the following County Fire Code
(County of San Diego 2017) and City requirements:
1. Per Section 59.5.0404 of the City’s Noise Abatement and Control Ordinance, construction,
including blasting, shall be prohibited between the hours of 7:00 p.m. and 7:00 a.m., or on
Sundays, or on legal holidays as specified in Section 21.04 of the San Diego Municipal Code,
with exception of Columbus Day and Washington’s Birthday.
2. The blasting contractor shall obtain a permit from the Fire Chief of the City of San Diego per
the requirements of Section 53.01 of the Municipal Code.
3. Blasting activities would follow guidance provided in the General Blasting Management Plan
that would include an estimate of air blast overpressure and vibration levels of each shot at
the nearest structure. A preliminary General Blasting Management Plan is included as
Attachment 1. Blasting shall not commence until the City and Sherriff’s Department has
approved the General Blasting Management Plan.
4. Each blast shall be monitored and recorded with an air blast over-pressure monitor that is
located outside the nearest residence to the blast.
5. The City project engineer shall review the request for each blast to verify blasting only of
material that requires blasting.
5.0 Environmental Analysis 5.6 Noise
Avion Project SEIR
Page 5.6-9
6. To verify compliance with the blasting vibration limitations, all blasting operations shall be
monitored with a seismograph located at the nearest structure. All seismograph reports
shall be submitted to the City.
7. The City shall require a one-time notice in writing for each blast to the local fire agency and
dispatch center and to all residences, including mobile homes, and businesses within 300
feet of potential minor blast locations. The notice shall be given not less than 24 hours, but
not more than one week, before each blasting operation.
8. If any measure identified cannot be complied with, the project contractor shall obtain a City-
approved noise consultant to perform noise and vibration monitoring until all measures can
be complied with.
The noise consultant shall conduct noise and vibration measurements at the nearest
residence(s). The noise measurements shall be conducted for the duration of construction
activities that do not comply with all measures. The noise consultant shall have the authority
to stop work if noise levels exceed the City standards for construction (Section 59.5.0404 of
the City’s Noise Abatement and Control Ordinance), or exceed applicable vibration limits as
defined in this report. At the conclusion of monitoring, the noise consultant shall prepare a
letter report summarizing the measurements and findings, including any measures used to
reduce noise and vibrations levels. The report shall include all measurement and calculation
data used in determining impacts and resolutions and submitted to the Director of
Community Development.
Implementation of these strategies would further ensure that vibrations from blasting would not
exceed 2.0 in/sec PPV at the nearest residence.
b. Multi-Habitat Planning Area
The proposed MHPA BLA would remove minor encroachment areas and add un-disturbed on-site
habitat not currently in the MHPA into the preserve (Figure 5.6-2). The occupied MHPA habitat is
subject to an hourly limit of 60 dB(A) Leq or the average ambient noise level, whichever is greater, at
the edge of habitat during the identified sensitive species breeding season of February 1 to
September 15. Possible blasting locations in relation to the proposed MHPA lands are presented in
Figure 5.6-2.
As described in Section 5.1.4.2c above, the project would be consistent with all of the MSCP MHPA
Land Use Adjacency Guidelines, including guidelines for noise. Per the MSCP MHPA Land Use
Adjacency Guidelines, if coastal California gnatcatcher is present within the MHPA, construction
noise levels at the MHPA boundary shall not exceed 60 A-weighted decibels.
5.0 Environmental Analysis 5.6 Noise
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Page 5.6-10
5.6.4.3 Significance of Impacts
a. Residential Receivers
Noise and vibration impacts associated with impact hammering, rock drilling, and blasting would be
less than significant.
b. Multi-Habitat Planning Area
The project would be consistent with the City’s MSCP MHPA Land Use Adjacency Guidelines
regarding noise. Therefore, impacts would be less than significant.
5.6.4.4 Mitigation, Monitoring, Reporting
a. Residential Receivers
Mitigation would not be required.
b. Multi-Habitat Planning Area
Mitigation would not be required.
FIGURE 5.6-1
Possible Blasting Locations
C A R M E L V A L LE Y
C A R M E L V A L LE Y
Image Source: NearMaps (flown February 2019)
0 600Feet [
Project Boundary
Heritage Bluffs Boundary
Possible Blasting Locations
M:\JOBS5\8958\common_gis\fig5.6_1_EIR.mxd 6/27/2019 bma
FIGURE 5.6-2
Adjacent MHPA
Image Source: NearMaps (flown February 2019)
0 200Feet [Project Boundary
Limit of Disturbance
Possible Blasting Locations
Existing MHPA
MHPA Addition
MHPA Deletion
M:\JOBS5\8958\common_gis\fig5.6_2_EIR.mxd 6/27/2019 bma
6.0 Significant Unavoidable Environmental Effects/Irreversible Changes
Avion Project SEIR
Page 6-1
Chapter 6
Significant Unavoidable Environmental
Effects/Irreversible Changes
This section addresses significant environmental impacts that cannot be avoided and irreversible
environmental changes that would be involved should the project be implemented.
6.1 Significant Environmental Effects which
Cannot Be Avoided if the Project Is
Implemented
In accordance with CEQA Guidelines Section 15126.2 (b), any significant unavoidable impact of a
project, including those impacts that can be mitigated but not reduced to below a level of
significance despite the applicant’s willingness to implement all feasible mitigation measures, must
be identified in the SEIR. The project would not result in any new significant unavoidable impacts
that were not previously identified in the 1998 Environmental Impact Report (EIR). Previously
identified significant unavoidable impacts associated with buildout of the Subarea Plan that would
not be mitigated to less than significant for the project include:
• Traffic
• Air Quality (direct and cumulative)
• Natural (Mineral) Resources and Agriculture
• Visual Resources/Landform Alteration
Table S-1 in the Executive Summary summarizes the project’s significant environmental impacts and
mitigation measures that would reduce impacts to a level less than significant. Chapter 11,
Mitigation Monitoring and Report Program, lists the project-specific mitigation measures.
6.2 Irreversible Environmental Changes which
Would Result if the Project Is Implemented
In accordance with CEQA Guidelines Section 15126.2 (c):
Uses of nonrenewable resources during the initial and continued phases of the
project may be irreversible since a large commitment of such resources makes
removal or nonuse thereafter unlikely. Primary impacts and, particularly, secondary
impacts (such as highway improvements which provide access to a previously
inaccessible area) generally commit future generations to similar uses. Also
irreversible damage can result from environmental accidents associated with the
6.0 Significant Unavoidable Environmental Effects/Irreversible Changes
Avion Project SEIR
Page 6-2
project. Irretrievable commitments of resources should be evaluated to assure that
such current consumption is justified.
As described in the 1998 Subarea Plan EIR, the most prominent irreversible environmental change
associated with the project would be the conversion of undeveloped land to urbanized uses. The
conversion of undeveloped land to urbanized uses would be a permanent change because reversion
of the land to its original condition would be nearly impossible once construction is complete.
Besides the commitment of land to urban use, implementation of the project would also involve the
consumption of natural resources as well as energy derived from non-renewable sources, such as
fossil fuels. Non-renewable resources generally include biological habitat, agricultural land, mineral
deposits, water bodies, and some energy sources. As disclosed in the 1998 EIR, buildout of the Black
Mountain Ranch Community including implementation of the project would result in significant
irreversible impacts on agricultural and or mineral resources.
Implementation of the project would also require the irreversible consumption of natural resources
and energy. Natural resource consumption would include lumber and other forest products, sand
and gravel, asphalt, steel, copper, other metals, and water. Building materials, while perhaps
recyclable in part at some long-term future date, would for practical purposes be considered
permanently consumed. Energy derived from non-renewable sources, such as fossil fuels, would be
consumed during construction and operational lighting, heating, cooling, and transportation uses.
To minimize the use of energy, water, and other natural resources, the project would incorporate
sustainable building practices into the site, architectural and landscape designs. As described in the
1998 EIR, design considerations aimed at improving energy efficiency, reducing landfill waste, and
conserving water (e.g., utilizing recycled water; on-site collection and reuse of construction
materials, etc.) have been incorporated into the overall Black Mountain Ranch Community and may
serve to reduce irreversible water, energy, and building material consumption associated with
construction and occupation of the project.
The project would not introduce any long-term risks to human health or safety. The residential units
would be constructed according to all applicable regulations and standards to avoid unnecessary or
unusual risks and accidents.
7.0 Growth Inducement
Avion Project SEIR
Page 7-1
Chapter 7
Growth Inducement
California Environmental Quality Act (CEQA) Guidelines Section 15126.2(d) requires that an
Environmental Impact Report (EIR):
Discuss the ways in which the proposed project could foster economic or population
growth, or the construction of additional housing, either directly or indirectly, in the
surrounding environment. Included in this are projects which would remove
obstacles to population growth (for example, a major expansion of a waste water
treatment plant might, for example, allow for more construction in service areas).
Increases in the population might tax existing community services facilities, requiring
construction of new facilities that could cause significant environmental effects. Also
discuss the characteristic of some projects which may encourage and facilitate other
activities that could significantly affect the environment, either individually or
cumulatively. It must not be assumed that growth in any area is necessarily
beneficial, detrimental, or of little significance to the environment.
Based on the City’s Significance Determination Thresholds, a project would have a significant impact
to growth inducement if a project would:
1. Induce substantial population growth in an area.
2. Substantially alter the planned location, distribution, density, or growth rate of the
population of an area.
3. Include extensions of roads or other infrastructure not assumed in the community plan or
adopted Capital Improvement Program project list, when such infrastructure exceeds the
needs of the project and could accommodate future development.
According to the City’s Significance Determination Thresholds, the first step is to determine if the
project is growth inducing. More specifically, would the project foster economic or population
growth, or construct new infrastructure facilities where none previously existed.
7.1 Project Effects on Growth
Since the adoption of the Subarea Plan in 1998, substantial development has occurred within and
around the Black Mountain Ranch community. Development within the Subarea commenced in
2000, and two communities have since then emerged, the Santaluz community and the Del Sur
community. The 3,100-acre Santaluz community occupies the southern portion of the Black
Mountain Ranch Subarea and is approximately 90 percent built out. Santaluz is primarily composed
of a golf course and low-density residential development. The 1,400-acre Del Sur community
occupies the northern portion of Black Mountain Ranch and has approved final maps or
construction occurring within approximately 50 percent of the community. Additionally, substantial
development has occurred adjacent to the Subarea. The 4S Ranch community, located within the
7.0 Growth Inducement
Avion Project SEIR
Page 7-2
unincorporated area directly adjacent to the Subarea to the northeast, is almost completely built
out. The Rancho Peñasquitos Community Plan area lies to the east of the project site and is also
essentially built out.
In conjunction with the Subarea Plan, a Transportation Phasing Plan was adopted to guide
implementation of circulation improvements within and surrounding the community. Most of the
major circulation improvements called for in the Transportation Phasing Plan have been or are
currently being constructed. Also as identified within the 1998 EIR, major regional serving water and
electrical utilities are sited within the Subarea. Utility and roadway extensions constructed in
conjunction with the proposed Subarea I development plan would extend energy, roads, water, and
sewer to the Subarea, but would not facilitate their extension to other sites where they are currently
unavailable, and would not contribute to growth inducement.
As detailed in the 1998 EIR, buildout of the community would be required to ensure that other
essential services, such as libraries, fire, and police, continue to meet City standards. Future
development within the Subarea, along with other cumulative buildout in the area, would create
demand for new facilities and levels of service. Since adoption of the Subarea Plan, required new
facilities, such as schools, parks, police and fire stations, have been constructed within or adjacent to
the Subarea. No additional public services would be needed to serve the project site. In conclusion,
the project is consistent with the land use and buildout assumptions for the Subarea Plan. Planned
facilities (e.g., roads, utilities) and services (schools, police, fire protection) are in place and are
adequate to serve the project. The project would not extend any new roads, utilities, or services
beyond those already anticipated to serve the buildout of the Black Mountain Ranch community.
Therefore, the project would not be growth inducing.
8.0 Cumulative Impacts
Avion Project SEIR
Page 8-1
Chapter 8
Cumulative Impacts
California Environmental Quality Act (CEQA) Guidelines Section 15130(a) requires a discussion of
cumulative impacts of a project “when the project’s incremental effect is cumulatively considerable.”
Cumulatively considerable, as defined in Section 15065(c), “means that the incremental effects of an
individual project are significant when viewed in connection with the effects of past projects, the
effects of other current projects, and the effects of probable future projects.” A ccording to
Section 15130, the discussion of cumulative effects “need not provide as great detail as is provided
for the effects attributable to the project alone. The discussion should be guided by standards of
practicality and reasonableness.”
The following evaluation of cumulative impacts considers reasonably foreseeable projects in the
vicinity of the project. According to Section 15130(b)(1) of the CEQA Guidelines, the discussion of
cumulative effects is to be based on either (a) “a list of past, present, and probable future projects
producing related or cumulative impacts, including, if necessary, those impacts outside the control
of the agency,” or (b) “a summary of projections contained in an adopted plan or related planning
document, or in a prior environmental document which has been adopted or certified, which
described or evaluated regional or area wide conditions contributing to the cumulative impact. Any
such planning document shall be referenced and made available to the public at a location specified
by the Lead Agency.”
The basis of and geographic area for the analysis of cumulative impacts is dependent on the nature
of the issue. For this analysis, the evaluation of potential cumulative impacts is localized (e.g.,
construction noise, construction emissions, visual quality, and biological and cultural resources);
therefore, a list of projects approach was employed. A brief description of these projects is
presented in Table 8-1. The locations of these figures are shown in Figure 8-1.
For the other cumulative impacts, those which are regional in scope (e.g., traffic, air quality
[operational emissions]), the analysis was conducted in conjunction with the Subarea Plan
Environmental Impact Report (EIR). The analysis within the 1998 EIR is still relevant for regional
cumulative issues (refer to Section 9.15).
8.0 Cumulative Impacts
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Page 8-2
Table 8-1
Cumulative Projects
Project Name Location Description/Status
East Clusters Enclave at
Black Mountain Ranch
North of Carmel
Valley Road.
Access from Valle
Del Sur Court.
The East Clusters Enclave Project consists of
27 residential units. The project has been
constructed.
East Clusters Unit 3 at
Black Mountain Ranch
Southwest of
intersection of
Bernardo Center
Drive and Camino
Del Norte.
The East Clusters Unit 3 Project consists of
90 residential units located within the former
units 2 and 3 of the original 2001 East Clusters at
Black Mountain Ranch Project. The project has
been constructed.
Del Sur Court East of Camino Del
Sur. Access from
Del Sur Court.
The Del Sur Court project consists of 206 senior
(age-restricted) units (130 single-family detached
and 76 single-family attached) for an age-
restricted Continuing Care Facility. The project has
been constructed.
Del Sur Retail Center Intersection of
Camino del Sur
and Paseo del Sur.
The Del Sur Retail Center consists of a 143,000-
square-foot retail store within a single building
and other retail commercial uses totaling
approximately 28,000 square feet. The project has
been constructed.
Camelot/Northeast
Perimeter Property
South of Camino
San Bernardo.
Access from Nicole
Ridge Road.
The Camelot/Northeast Perimeter Property
Project consists of 307 multi-family units. A total
of 259 market rate units are located on-site within
the parcel identified by the Subarea Plan as the
Northeast Perimeter property. An additional
48 affordable units are located off-site within the
Black Mountain Ranch North Village Town Center.
The project has been constructed.
Heritage Bluffs II South of Carmel
Valley Road.
Access from
Winecreek Drive.
South of East
Clusters Unit 3.
The Heritage Bluffs II Project consists of
220 residential units. A total of 171 market rate
units are located on-site within the parcels
identified by the Subarea Plan as perimeter
parcels A and B. An additional 35 affordable units
and 14 market rate units are located off-site
within the Black Mountain Ranch North Village
Town Center. The project has been constructed.
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8.1 Cumulative Effects Found to be Significant
8.1.1 Landform Alteration/Visual Quality
The 1998 EIR identified cumulative impacts related to landform alteration/visual quality. The EIR
concludes that individual and cumulative landform alteration impacts would be limited by future
project’s compliance with the Environmentally Sensitive Lands (ESL; formerly Resource Protection
Ordinance [RPO]) steep hillsides regulations and that implementation of the Subarea Plan Design
Guidelines would serve to partially mitigate visual character impacts. As described in Section 5.4.2,
the project would result in alteration of existing landforms. The project would be consistent with the
City’s ESL steep slope regulations, and the majority of steep slopes would be preserved on-site
within Multi-Habitat Planning Area (MHPA) open space. However, manufactured slopes would
exceed 10 feet in height, and excavation or fill in excess of five feet from existing grade would occur
around the perimeter of the development footprint. Furthermore, preservation of
approximately 23.75 acres of natural vegetation on-site within the proposed MHPA open space and
revegetation of manufactured slopes would not fully mitigate impacts associated with landform
alteration. Therefore, implementation of the project would result in cumulatively considerable and
unavoidable impacts related to landform alteration/visual quality.
8.2 Cumulative Effects Found Not to be
Significant
8.2.1 Land Use
The 1998 EIR identified potential cumulative land use impacts related to compliance with the RPO
(now the ESL Ordinance). The 1998 EIR concluded that future projects may require deviations from
the RPO that would result in cumulative impacts related to regulatory nonconformance.
As described in Section 5.1.3, the project would be consistent with the City’s Land Development
Code (LDC) ESL regulations relative to the issues of sensitive biological resources and steep slopes,
and no deviations would be required. Therefore, the project’s incremental effect would therefore
not be cumulatively considerable related to LDC inconsistency. No direct impacts to habitat within
the MHPA would result from the project following the adoption of the proposed MHPA boundary
line adjustment. The project would be consistent with the six biological factors required by the
Multiple Species Conservation Program (MSCP) for a MHPA boundary line adjustment (BLA), and the
approved BLA would transfer equal or higher biological values of impacted species and habitats into
the preserve.
All of the other projects presented in Table 8-1 are constructed and were required to comply with
the LDC and MSCP prior to approval. Therefore, when considered with other cumulative projects,
the project would not result in a significant cumulative impact related to LDC or MSCP conflicts.
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8.2.2 Biological Resources
The 1998 EIR identifies a significant cumulative impact associated with the loss of important
habitats, including wetlands and non-native grassland. As discussed in Section 5.2, the project would
not impact any wetlands, and implementation of mitigation measure MM-BIO-1a would reduce
impacts on non-native grassland and other sensitive upland communities to a level less than
significant.
Projects that comply with the MSCP as specified by the City’s Subarea Plan and its implementing
ordinances are not expected to result in a significant cumulative impact for those biological
resources adequately covered by the MSCP, including vegetation communities. As described in
Section 5.2.6, conflicts with the MSCP MHPA Land Use Adjacency Guidelines related to noise would
be mitigated through implementation of MM-BIO-1b. Additionally, approval of the project’s MHPA
BLA would ensure that the project meets the equivalency standards as they pertain to a no net loss
of MHPA habitat area, functions, or values. As described in Section 5.1.4.2b above, the project would
be consistent with the six biological factors required by the MSCP for a MHPA BLA, and the approved
BLA would transfer equal or higher biological values of impacted species and habitats into the
preserve. All the other project’s presented in Table 8-1 are constructed and were required to comply
with the MSCP and mitigate for impacts to biological resources as necessary. Therefore, when
considered with other cumulative projects, the project would not result in a significant cumulative
impact related to biological resources.
8.2.3 Cultural/Historical Resources
Archaeological resources are important for prehistoric or historic information that may be
recovered. The 1998 EIR identifies cumulatively significant impacts to cultural resources. As
discussed in Section 5.3, the project would not impact any known religious or sacred uses or disturb
any human remains on-site, and implementation of mitigation measure MM-HIST-1 would reduce
potential impacts on prehistoric/historic resources to a level less than significant.
All the other project’s presented in Table 8-1 are constructed and were required to implement
appropriate mitigation measures to reduce impacts on historical resources to a level less than
significant as necessary. Therefore, when considered with other cumulative projects, the project
would not result in a significant cumulative impact related to cultural/historical resources.
8.2.4 Air Quality
The 1998 EIR identifies construction-related emissions associated with buildout of the Subarea Plan
as a significant cumulative impact. Construction of the project would be temporary in nature. As
described in Section 5.5, the project would not violate any air quality standards or expose sensitive
receptors to substantial pollutant concentrations. Additionally, all the projects presented in
Table 8-1 are constructed and were required to implement measures to comply with maximum daily
construction emissions as necessary. Therefore, when considered with other cumulative projects,
the project would not result in a significant cumulative impact related to air quality.
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8.2.5 Noise
The 1998 EIR did not address cumulative impacts relative to construction noise. Construction of the
project would be temporary in nature. As described in Section 5.6, noise and vibration impacts
associated with impact hammering, rock drilling, and blasting would be less than significant, and
implementation of mitigation measure MM-BIO-1b would reduce noise impacts on the MHPA to a
level less than significant. Additionally, all the projects presented in Table 8-1 are constructed and
were required to implement measures to avoid construction noise impacts as necessary. Therefore,
when considered with other cumulative projects, the project would not result in a significant
cumulative impact related to noise.
M:\JOBS5\8958\env\graphics\fig8-1.ai 06/27/19FIGURE 8-1Location of Cumulative Projects0200FeetMap Source: RECON 2015Del Sur CourtEast Cluster EnclaveEast Clusters Unit 3Camelot/NE Perimeter PropertyDel SurRetail CenterProject SiteHeritage Bluffs II
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Chapter 9
Black Mountain Ranch (Subarea I) Subarea
Plan EIR Subject Areas Requiring No Change in
Analysis
Pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15163, the analysis and
conclusions reached in a number of the environmental subject areas contained within the 1998
Black Mountain Ranch (Subarea I) Subarea Plan Environmental Impact Report (EIR) do not require
supplemental analysis and are not addressed further in this Supplemental Environmental Impact
Report (SEIR). This is because the project would not result in changes affecting the analysis in the
1998 EIR, as there were no substantial changes in circumstances or new information available with
respect to each subject area that would trigger a need for supplemental review (CEQA Guidelines
Section 15162). These subject areas include:
• Land Use (Plan Consistency; Land Use Conflicts)
• Traffic/Circulation
• Hydrology and Water Quality
• Visual Quality (Area Character, Unique Features, Landmark Trees)
• Air Quality (Direct Impacts)
• Geology and Soils
• Agricultural Resources/Mineral Resources
• Paleontological Resources
• Noise (Traffic Noise)
• Public Facilities and Services
• Water Conservation/Domestic Water/Wastewater
• Public Safety
• Population
• Cumulative Impacts related to the above issues
Any future environmental review related to these subjects shall be required to refer to the 1998 EIR.
9.1 Land Use (Plan Consistency)
The land use analysis in 1998 EIR concluded that the Subarea Plan would be consistent with other
adopted plans, and no significant impacts would occur. The project would be consistent with the
designated land use and density assumptions identified for Southeast Perimeter Parcel C. Therefore,
the project would also be consistent with adopted land use plans, and there would be no new
significant or substantially increased adverse impacts beyond those previously identified in the 1998
EIR relative to land use plan consistency.
Because no site-specific design was proposed at the time the 1998 EIR was prepared, issues
regarding Land Development Code deviations and Multiple Species Conservation Program (MSCP)
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consistency could not be analyzed in detail for the perimeter properties, and impacts were assumed
to be potentially significant. An analysis of the project’s impacts relative to these land use issues is
presented in Sections 5.1.3, and 5.1.4 of this SEIR.
9.2 Traffic/Circulation
The 1998 EIR included a traffic and circulation analysis for buildout of the entire Subarea Plan. The
1998 EIR identified numerous significant direct and cumulative impacts to the surrounding roadway
network in conjunction with buildout of the Subarea Plan. Mitigation for buildout of the Subarea
Plan resulted in the development of a Transportation Phasing Plan, which requires facilities be in
place based on the total number of Equivalent Dwelling Units (1 Equivalent Dwelling Unit = 1 single-
family dwelling or 10 Average Daily Traffic) constructed within the Subarea. The Transportation
Phasing Plan is funded through payment of Public Facilities Financing Plan (PFFP) fees at the time of
building permit issuance, with facilities constructed per the requirements of the Transportation
Phasing Plan.
The project is consistent with the designated land use and density assumptions for Southeast
Perimeter Parcel C. Additionally, a traffic impact memorandum prepared for the project
demonstrated how the proposed 84 detached multi-family units would be consistent with the
Subarea Plan and the traffic analysis presented in the 1998 EIR (KOA 2019; Appendix F). Therefore,
the project would be subject to conditions of approval consistent with the Mitigation Monitoring and
Report Program (MMRP) for the 1998 EIR. Specifically, prior to the issuance of any building permit,
the project would be required to be in conformance with the Black Mountain Ranch Transportation
Phasing Plan. The project would not result in any new significant or substantially increased adverse
impacts beyond those previously identified in the EIR.
9.3 Hydrology and Water Quality
9.3.1 Hydrology/Drainage
The 1998 EIR did not identify any significant impacts to natural drainage patterns; however, the EIR
concluded that buildout of the Subarea would result in an increase in runoff due to the creation of
new impervious surfaces. Runoff could result in adverse impacts to the drainage to the west, but
impacts could be mitigated through proper design of future development. The MMRP for the
1998 EIR specified that detailed drainage design and best management practices (BMPs) would be
conditions for any subsequent tentative maps for development within the Southeast Perimeter
properties. Consistent with the MMRP, the project prepared a site-specific Preliminary Drainage
Report (PDC 2019b) and Storm Water Quality Management Plan (SWQMP) (PDC 2019c). There are
minimal drainage facilities on the project site in the existing condition, and stormwater on-site
currently sheet flows into natural channels. Additionally, approximately two acres off-site to the east
drains northwest through the project site towards the natural channel located on the east side of
the project.
The post-project drainage pattern has been designed to be generally consistent with the existing
drainage pattern on-site and would not alter the destination of downstream flows. The project
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proposes to introduce new drainage facilities consisting of culverts, brow ditches, curb gutters,
storm drain inlets, and pipes that would convey flows to a new biofiltration basin to be constructed
in the northeast corner of the project site. The biofiltration basin would treat and detain stormwater
flows before discharging them into the existing channel on the eastern side of the project site.
The biofiltration basin would be needed to reduce post-project stormwater flows. Introduction of
new impervious surfaces associated with the project would increase the 100-year storm runoff rate
from the existing 20.6 cubic feet per second (cfs) to 25.7 cfs in the post-project condition. However,
the proposed biofiltration basin includes design features that would reduce the 100-year storm
runoff rate to less than or equal to the 20.6 cfs present in the existing condition. The biofiltration
basin would include an aboveground storage component with a series of flow orifices that would
detain stormwater and slowly release treated stormwater. Additionally, the biofiltration basin would
include riprap energy dissipaters to reduce flow velocities both entering and exiting the basin.
Therefore, no new significant or substantially increased adverse impacts relative to hydrology would
result from implementing the project.
9.3.2 Water Quality
The 1998 EIR also concluded that implementation of the Subarea Plan has the potential to
significantly impact water quality (both directly and cumulatively) in the San Dieguito River and
Lagoon. The EIR MMRP recommends measures to reduce levels of erosion, sedimentation, and
runoff and requires that the recommended measures or the equivalent thereof would be conditions
of future tentative maps for the Southeast Perimeter properties.
Since the certification of the 1998 EIR, the regulatory framework relative to water quality and
drainage has changed. The project would be required to comply with new regulatory standards. To
ensure that the project would comply with new state and local regulations, a site-specific SWQMP
was prepared for the project (PDC 2019c). The project would be consistent with the land use for the
site as designated by the Subarea Plan. Therefore, pollutants of concern would be the same as those
addressed in previous documents, and the BMPs for the project will comply with the City’s
requirements for stormwater treatment. In addition to the proposed biofiltration BMP attenuating
flows to provide detention benefits for peak flows, the proposed biofiltration basin is also designed
to treat the water quality flows (the “85th percentile runoff”) and mitigate for hydromodification
impacts. The project would construct a biofiltration basin in the northeast corner of the project site
that would meet City pollutant control and volume retention requirements and also control post-
developed flow rates to within 10 percent of the pre-developed flow durations across the range of
hydromodification mitigation flows, which include flow frequencies ranging from a fraction of the 2-
year flow (Q2) to the 10-year flow (Q10). The proposed biofiltration basin would be lined, would not
allow for infiltration, and would include an 18-inch engineered soil mix on top of a 3-inch washed
sand layer. Additionally, the lower portion of the biofiltration basin includes a 3-inch choking stone
layer above the gravel layer. Based on the design components described above, the Preliminary
Hydromodification Management Study completed for the project determined that the biofiltration
basin would satisfy the Preliminary Hydromodification Management Study requirements of the San
Diego Regional Water Quality Control Board (PDC 2019d). Furthermore, the project would include
other source control BMPs such as storm drain stenciling/signage and prohibition of illicit discharges
into the MS4. In addition to the permanent BMPs, temporary BMPs will be employed during
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construction and will include BMPs such as desilting basins, silt fences, gravel bags, fiber rolls, and
other erosion control measures. These temporary BMPs would be employed consistent with the
State Water Resources Control Board’s General Permit for Storm Water Discharges Associated with
Construction Activity. All of the water quality treatment measures described above would meet or
exceed those previously identified, and there would be no new significant or substantially increased
adverse impacts associated with water quality.
9.4 Visual Quality
Because no site-specific design was proposed for the Southeast Perimeter properties at the time the
1998 EIR was prepared, the EIR concluded that potential landform alteration impacts would be
evaluated during subsequent environmental review. Therefore, the analysis of project impacts
relative to landform alteration is discussed in Section 5.4.2 of this SEIR.
The 1998 EIR concluded that impacts to views from Black Mountain Park of future residential
development within the southeast perimeter properties may be significant. The MMRP indicates that
the application of Design Guidelines identified in the Subarea Plan that address residential lot
grading, siting of structures, architectural styles, setbacks, exterior use areas, walls and fences,
exterior lighting and landscaping, would allow for a consistent community character to be retained
and minimize impacts to views. The Subarea Plan states:
All Perimeter Properties and the BMR North Clusters will be required to adopt the
Design Guidelines approved for the BMR VTM/PRD or required to develop
independent design guidelines conforming to the Framework Plan, this Subarea I
plan and compatible with the BMR VTM/PRD Design Guidelines.
Design Guidelines have been developed for the project and are consistent with the Subarea Plan
Design Guidelines. Therefore, conclusions from the 1998 EIR are applicable and the project would
not result in any new significant or substantially increased adverse impacts beyond those previously
identified in the EIR relative to visual character.
The 1998 EIR did not identify any significant impacts to unique geologic or topographic features
from future development within the Subarea. The EIR analysis stated that the southeast perimeter
properties would encroach into approximately 9 percent of sensitive on-site slopes. The project
would encroach into approximately 18.95 percent of steep slopes subject to Environmentally
Sensitive Lands (ESL; with allowances for erosion control). The encroachment is within the allowable
limits of the City’s ESL ordinance, as detailed in Section 5.1.3 of this SEIR. Therefore, new or
substantially increased adverse impacts would result, and the conclusions are consistent with those
of the 1998 EIR.
The 1998 EIR did not identify the presence of any distinctive or landmark trees within the subarea.
No landmark trees are present on the project site, and no further analysis is required.
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9.5 Air Quality
The 1998 EIR identified significant direct and cumulative air quality impacts to regional air quality as
a result of vehicle traffic and construction-related activities, respectively. Relative to direct
(operational) air quality impacts, the 1998 EIR concluded that buildout of the subarea would not
conform to the Regional Air Quality Strategy, and impacts would be significant and unmitigated. The
project is consistent with the land use and buildout assumptions for the perimeter properties as
described in the 1998 EIR; therefore, the project would not result in any new significant or
substantially increased adverse impacts beyond those previously identified in the 1998 EIR.
The EIR incorporated mitigation measures that would reduce fugitive dust impacts from
construction activity. Dust control during construction and grading operations would be regulated in
accordance with the rules of the San Diego Air Pollution Control District. Incorporation of these
mitigation measures would reduce construction-related air quality impacts to below a level of
significance. The project would incorporate such mitigation as described in the 1998 EIR. However, in
addition to the land development activities described in the 1998 EIR, the project may require
blasting in areas of shallow bedrock. Construction-related air quality impacts associated with
blasting are discussed in Section 5.5.3 of the EIR.
9.6 Geology and Soils
The 1998 EIR states that there are no significant soil or geologic conditions observed or known to
exist within the subarea that would preclude implementation of future development. The southeast
perimeter parcels are generally underlain by Santiago Peak metavolcanics, which exhibit good
bearing and stable slope characteristics, although expansive soils may be encountered.
The 1998 EIR concluded that potentially significant geologic conditions exist, which would require
mitigation as part of any future tentative maps. The site-specific Geotechnical Report prepared for
the project concluded that no soil or geologic conditions exist at the project site that would preclude
the proposed development, provided the measures recommended in the report are implemented
for design and construction.
The City’s Geology Section has reviewed and determined that the site-specific Geotechnical
Investigation, which includes recommendations to be followed during project construction,
adequately addresses the geologic conditions potentially affecting the project site (Geocon 2018a).
Furthermore, implementation of proper engineering design and utilization of standard construction
practices to be verified at the building permit stage, in conjunction with implementation of the
recommendations of the Geotechnical Investigation, would ensure that the potential for impacts
associated with geologic hazards would be less than significant. Therefore, based on the results of
the Geotechnical Investigation, there would be no new significant or substantially increased adverse
impacts beyond those previously identified in the EIR.
The 1998 EIR also concluded that without erosion control measures, there is a potentially significant
increased erosion impact associated with the implementation of the Subarea Plan. These impacts
would be mitigated to a level below significance by incorporation of appropriate control measures,
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as outlined in the 1998 EIR. Additionally, the project would implement temporary construction
BMPs to control erosion consistent with the State Water Resources Control Board’s General Permit
for Storm Water Discharges Associated with Construction Activity. Therefore, there would be no new
significant or substantially increased adverse impacts beyond those previously identified in the EIR.
9.7 Agricultural Resources/Mineral Resources
According to the 1998 EIR, Farmland of Local Importance and grazing lands would be lost with
development of the perimeter properties. Specifically, 15 acres of grazing land and up to 204 acres
of Farmland of Local Importance may be lost with the development of the southeast perimeter
properties. Although portions of the subarea are in limited current agricultural use, no prime
farmlands would be removed and the loss of agricultural land is not considered a significant direct
impact. The cumulative effects of the loss of agricultural land from conversion are considered
significant and unmitigated. The project would impact a similar development footprint as identified
in the 1998 EIR for southeast perimeter Parcel C. Conclusions regarding the loss of agricultural
resources would be consistent with the previous analysis, and the project would not result in any
new significant or substantially increased adverse impacts beyond those previously identified in the
EIR.
The 1998 EIR concluded that implementation of future development as proposed in the Subarea
Plan would preclude mining of the mineral resource zone (MRZ)-2 aggregate for the foreseeable
future, and the cumulative effects of the incremental loss of potential aggregate deposits are
considered significant and unmitigated. The project is consistent with the land use and buildout
assumptions for the Subarea Plan; therefore, the conclusions regarding the loss of aggregate
resources would remain, and the project would not result in any new significant or substantially
increased adverse impacts beyond those previously identified in the 1998 EIR.
9.8 Paleontological Resources
The 1998 EIR states that the Southeast Perimeter properties are located in Santiago Peak
metavolcanics formations, which are areas with low paleontological resource sensitivity. The project
would impact a similar development footprint as identified in the 1998 EIR for southeast perimeter
Parcel C. Conclusions regarding paleontological resource impacts would be consistent with the
previous analysis, and the project would not result in any new significant or substantially increased
adverse impacts beyond those previously identified in the EIR.
9.9 Noise
For the southeastern perimeter parcels, the 1998 EIR identified that the 65 community noise
equivalent level (CNEL) contour would be located near the northern property line, around 400 feet
from Carmel Valley Road. The 60 CNEL contour would be around 1,000 feet from Carmel Valley
Road. The City’s exterior noise level standard would, therefore, not be exceeded on the
southeastern perimeter parcels, as all development would be located outside the 60 CNEL contour
area. Therefore, interior noise level standards would be met with standard construction techniques
in the areas proposed for development. Impacts relative to traffic noise would be less than
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significant for the subject site. Because the project is consistent with the land use and buildout
assumptions and conceptual development footprint identified in the Subarea Plan, noise impacts
associated project traffic and noise contours associated with surrounding roadways would be
consistent with the analysis in the 1998 EIR. The project would not result in any new significant or
substantially increased adverse impacts beyond those previously identified in the EIR relative to
operational noise.
The 1998 EIR indicated that potential future construction-related noise impacts to sensitive wildlife
within the Multi-Habitat Preservation Area (MHPA) may result from grading and construction in the
southeast perimeter properties. MHPA adjacency impacts associated with noise are addressed in
Section 5.1.5 of this SEIR. Additionally, blasting may be required during construction activities.
Construction noise and vibration impacts require subsequent analysis and are addressed in
Section 5.6.4 of this SEIR.
9.10 Public Facilities and Services
As required of all development proposals, the project would be required to pay applicable impact
fees for public facilities and services prior to the issuance of building permits.
9.10.1 Schools
The 1998 EIR concluded that the additional elementary, middle, and high school students generated
by buildout of the Subarea Plan would contribute to the already overcrowded schools and is
considered a direct and cumulatively significant impact. The 1998 EIR stated that implementation of
the following condition and offers of dedication would reduce direct and cumulative school impacts
from subarea development to below a level of significance:
a) Collection of required fees and setting aside three school sites, and provision of partial acreage
for a future high school site.
Mitigation for school impacts would include implementation of a final financing agreement and
phasing plan for future development in the subarea and the Poway Unified School District as
identified in the school district’s School Facilities Master Plan and Financing Plan for the Black
Mountain Ranch Subarea, which may or may not include participation in school facilities financing
with other surrounding development projects. The Poway Unified School District proposed
establishment of a Mello-Roos community facilities district; however, some other mutually
acceptable means could be employed. Proof of a final financing agreement and school site purchase
agreement would be required prior to City Council approval of the Subarea Plan.
School impacts would be reduced to below a level of significance by implementing the mitigation
measures identified in the 1998 EIR. Because the project is consistent with the land use and buildout
assumptions and conceptual development footprint identified in the Subarea Plan, impacts to
schools would be consistent with those previously identified, and the project would not result in any
new significant or substantially increased adverse impacts beyond those previously identified in the
EIR.
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9.10.2 Parks and Recreation
The 1998 EIR concluded that the dedication of community and neighborhood park sites totaling
59 acres (both public and private), and the proposed dedication of 2,211 acres of resource and
amenity public open space, would provide adequate park and recreation facilities for future needs
of the development and nearby communities. No significant impacts were identified. Because the
project is consistent with the land use and buildout assumptions identified in the Subarea Plan,
impacts to parks and recreational facilities would be consistent with those previously identified, and
the project would not result in any new significant or substantially increased adverse impacts
beyond those previously identified in the EIR.
9.10.3 Libraries
The 1998 EIR concluded that the Rancho Peñasquitos, Carmel Mountain Ranch, and Rancho
Bernardo libraries would adequately serve the needs of the Black Mountain Ranch Subarea, and
usage impacts to these libraries would not be significant. Because the project is consistent with the
land use and buildout assumptions identified in the 1998 EIR, impacts to libraries would be
consistent with those previously identified, and the project would not result in any new significant or
substantially increased adverse impacts beyond those previously identified in the previous EIR.
9.10.4 Police and Fire Services
The 1998 EIR concluded that reasonable police response times to the subarea for routine and
emergency calls-for-service are anticipated; therefore, impacts to police services are considered less
than significant. Because the project is consistent with the land use and buildout assumptions and
conceptual development footprint identified in the Subarea Plan, impacts associated with police
services would be consistent with the analysis in the 1998 EIR.
Relative to fire services, the 1998 EIR concluded that City Fire Department may or may not be able to
provide first response to all portions of the subarea within six minutes. The 1998 EIR incorporated
the following mitigation measure:
Service letters from the City of San Diego Fire Department shall be submitted when building
permits are applied for. If the Fire Department cannot respond within six minutes, then building
plans would include fire sprinkler systems or other measures to the satisfaction of the Fire
Department. Similar requirements would apply to all other development proposals in the
Subarea.
As a condition of approval, the project would be required to implement mitigation identified in the
1998 EIR MMRP for potential fire service response impacts. The project would not result in any new
significant or substantially increased adverse impacts beyond those previously identified in the EIR.
The project would add 84 detached multi-family residential units. The 2011 City Gate Associates’
study, which is the guidance document for San Diego Fire–Rescue Department’s future planning,
includes a new planned fire station (#48) in this area to serve Black Mountain Ranch.
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9.10.5 Water Supply and Service
The 1998 EIR concluded that although buildout of the Subarea Plan would increase water service
demand, the increase was not a significant impact with the implementation of conservation
measures and recycled water systems. The 1998 EIR included the following mitigation measures,
which would be incorporated into future development project design guidelines to address
cumulative water usage concerns.
1. Limit grading in areas where no construction is proposed; thereby reducing the need for
planting and irrigation of graded areas.
2. Provide lifts of low-clay content soil in landscaped areas to improve infiltration.
3. Reduce runoff potential from landscaped areas by using berming, raised planters, and drip
irrigation systems.
4. Install soil moisture override systems in all common irrigation areas to avoid sprinkling when
the ground is already saturated.
5. Identify in the plant materials list in the project design guidelines whether or not plants are
native or naturalize easily and incorporate a list of local California sources for native plants.
6. Incorporate low-flush toilets, low-flow faucets, and timers on sprinklers (including nighttime
watering) into project design.
7. Provide information regarding water conservation measures to new residents at the time of
lot purchase.
The Development Coordinator would review grading, landscape, and building permits to ensure that
the above measures have been noted on plans.
A Water Supply Assessment and Water Supply Verification Report were prepared for the 2009
Subarea Plan Amendment project by the City Water Department (November 2008) in compliance
with the requirements of Senate Bill 610 and Senate Bill 221. The water reports identified that the
water demand projections for the amendment project were included in the water demand forecasts
within the Urban Water Management Plan and other water resource planning documents of the
Water Department, the San Diego County Water Authority, and Metropolitan Water District. Water
supplies necessary to serve existing demands, projected demands of the Subarea Plan Amendment
project, and future water demands within the Water Department's service area, as well as the
actions necessary to develop these supplies, have been identified in the water supply planning
documents of the Water Department, the San Diego County Water Authority, and the Metropolitan
Water District.
The project is consistent with the land use and buildout assumptions and conceptual development
footprint identified in the Subarea Plan and subsequent Subarea Plan Amendment. Additionally, the
project would implement all water conservation measures identified in the MMRP for the 1998 EIR
(see Section 9.11, below).
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Water service would be provided by the City, and the project would make domestic water and fire
protection water connections to the existing 12-inch Pomerado Park 920 Pressure Zone public water
lines within Winecreek Drive at the northwestern project boundary adjacent to Heritage Bluffs. The
Water System Analysis completed for the project determined that a private water booster station
would be required to provide adequate flow and pressure (Dexter Wilson 2018a). This private water
booster station would be a private facility and would be installed in the northwest corner of the
project site within Winecreek Drive. The project would also include off-site improvements to install
three interties between the existing dual Pomerado Park 920 Pressure Zone. These three interties
would be installed within existing water supply facilities located within the Bernardo Center Drive
and Winecreek Drive roadways and would not result in any environmental impacts. Implementation
of these improvements would ensure that adequate flow and pressure is available to provide water
service to the project site. Therefore, impacts associated with water supply services would be
consistent with the analysis in the 1998 EIR. The project would not result in any new significant or
substantially increased adverse impacts beyond those previously identified in the EIR.
9.10.6 Wastewater Generation
The 1998 EIR indicated that new or expanded on-site sewer facilities may be required for
development of the perimeter properties. Mitigation required pursuant to the 1998 EIR included
that as a condition of the future maps, future applicants would submit a sewer capacity analysis to
the City’s Public Utilities Department. If additional capacity is needed, the applicant would provide
for the needed improvements to the satisfaction of the Water Department Manager.
Consistent with the 1998 EIR MMRP, a Sewer System Analysis was prepared for the project (Dexter
Wilson 2018b). As described in Chapter 3.0 Project Description, the project would require a
reorganization consisting of an expansion of latent powers for sewer service and the annexation of
the project site into the Olivenhain Municipal Water District (OMWD). The project would connect to
the existing OMWD sewer system within Winecreek Drive at the northwestern project boundary
adjacent to Heritage Bluffs. The project would install a gravity sewer system with eight-inch sewer
lines and a minimum slope of two percent. The Sewer System Analysis concluded that the off-site
gravity sewer collection system that the project would connect to has adequate flow capacity to
serve the project. Therefore, no additional off-site improvements would be required, and there
would be no change to the conclusions from the 1998 EIR. The project would not result in any new
significant or substantially increased adverse impacts beyond those previously identified in the EIR.
9.10.7 Waste Management Services
The 1998 EIR concluded that buildout of the Subarea Plan would result in the generation of a
significant amount of solid waste affecting waste management services, such as landfill disposal,
refuse collection, recycling programs, as well as the City’s ability to comply with the state waste
reduction mandate unless a waste reduction recycling plan is prepared specifying measures that
would be incorporated in project design to minimize waste generation and divert waste from
disposal. The 1998 EIR included mitigation for solid waste that requires:
1. Future residential development within the Subarea would comply with the City’s recycling
program.
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Avion Project SEIR
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2. The requirement for recycling bins or containers would be included in the Design Review
Guidelines for all projects and the Conditions, Covenants, and Restrictions.
3. Future development will be required to develop a waste reduction/recycling plan addressing
both construction phase as well as ongoing project impacts and specifying waste reduction
measures that would be incorporated in project design to minimize solid waste impacts.
The project would be required to comply with the City’s Recycling Ordinance, and waste would be
collected by City haulers. Additionally, the project would comply with Land Development Code
Chapter 14, Article 2, Division 8 (Refuse and Recyclable Materials Storage Regulations), as specified
in the Design Guidelines. Finally, the project would comply with the project-specific Waste
Management Plan (WMP; RECON 2019f, Appendix G). Compliance with City regulations and the
approved WMP would ensure that no new significant or substantially increased adverse impacts
would result relative to solid waste. The project would not result in any new significant or
substantially increased adverse impacts beyond those previously identified in the 1998 EIR.
9.10.8 Electrical Utilities
The 1998 EIR concluded that utilities and infrastructure are available to the subarea and no
significant adverse impacts to dry or wet utility systems or service would result from buildout of the
community. The project is consistent with the land use assumptions and conceptual footprint
identified in the 1998; therefore, impacts to electrical facilities would be consistent with those
previously identified, and the project would not result in any new significant or substantially
increased adverse impacts beyond those previously identified in the EIR.
9.11 Water Conservation/Domestic Water/
Wastewater
The 1998 EIR indicates that buildout of the subarea would incrementally increase the demand for
domestic water service, and the relatively small increase is not considered a significant impact,
particularly since recycled water would be used for landscaping irrigation throughout large portions
of the Subarea and conservation measures such as low-flow shower heads and toilets would be
incorporated into future developments.
Presently, reclaimed water is used everywhere within developed portions of the subarea, except the
East Clusters and other areas along Carmel Valley Road to the east of the community park. The
project would not be served by reclaimed water because it lacks large common areas necessitating
irrigation. Consistent with the conclusions of the 1998 EIR, the project’s contribution to the
cumulative impact associated with water supplies would be reduced to a nominal level by the
mitigation measures outlined in the 1998 EIR MMRP.
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9.12 Public Safety
The 1998 EIR concluded that no significant impacts associated with electromagnetic fields are
anticipated from development of the Subarea due to restrictions and approval requirements
associated with encroachment into San Diego Gas & Electric easements. The Phase I Environmental
Site Assessment prepared for the project did not identify any recognized environmental conditions
and determined that no further actions regarding the potential for hazardous materials were
required for the project (Geocon 2018b). The project is consistent with the Subarea Plan and would
not result in any new significant or substantially increased adverse impacts beyond those previously
identified in the 1998 EIR.
9.13 Population
The 1998 EIR concluded that assuming a 25-year buildout, with an annual population increase of
560 people, no significant impacts on the planned growth rate for the region are expected. The
Subarea Plan is part of a comprehensive subarea planning program designed to anticipate and
resolve indirect impacts caused by increased population. Because the project is consistent with the
land use and buildout assumptions of the Subarea Plan, there would be no new significant or
substantially increased adverse impacts beyond those previously identified.
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Chapter 10
Project Alternatives
The California Environmental Quality Act (CEQA) Guidelines Section 15126.6 requires that an
environmental impact report (EIR) compare the effects of a “reasonable range of alternatives” to the
effects of a project. The alternatives selected for comparison should be those that would attain most
of the basic project objectives and avoid or substantially lessen one or more significant effects of the
project. The “range of alternatives” is governed by the “rule of reason,” which requires the EIR to set
forth only those alternatives necessary to permit an informed and reasoned choice by the lead
agency and to foster meaningful public participation (CEQA Guidelines Section 15126.6[f]). CEQA
generally defines “feasible” to mean an alternative that is capable of being accomplished in a
successful manner within a reasonable period of time, while also taking into account economic,
environmental, social, technological, and legal factors.
The project would result in potentially new site-specific significant, direct, and/or cumulative
environmental impacts to land use, biological resources, landform alteration/visual quality, air
quality, and noise beyond those previously identified in the 1998 EIR. Mitigation measures have
been identified that would reduce all new direct and cumulative impacts to below a level of
significance, with the exception of impacts to landform alteration/visual quality. In developing the
alternatives to be addressed in this section, consideration was given to their ability to meet the basic
objectives of the project and eliminate or substantially reduce significant environmental impacts. As
identified in Chapter 3.0, project objectives include the following:
• Provide residential development that is consistent with the location and the goals and
objectives of the adopted Black Mountain Ranch Subarea Plan.
• Provide new residential development, which is consistent with existing residential
development patterns in the surrounding area.
• Implement “smart growth” principles of development through the provision of new
residences within a complete master planned community.
• Implement sustainable development principles through the provision of a community of
new residences with many energy-efficient features.
• Provide infrastructure improvements consistent with the Subarea Plan.
The alternatives identified in this chapter are intended to further reduce or avoid significant
environmental effects of the project. This chapter addresses the No Project (No Development)
Alternative and the Reduced Development Footprint Alternative. Each major issue area included in
the impact analysis of this Supplemental Environmental Impact Report (SEIR) has been given
consideration in the alternatives analyses, and impacts are summarized in Table 10-1.
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Table 10-1
Comparison of Project and Alternatives Impacts Summary
Environmental Issue Area Project
No Project
(No Development)
Alternative
Reduced Development
Footprint Alternative
Land Use Significant and mitigated Less than the Project Greater than the
Project
Biological Resources Significant and mitigated Less than the Project Less than the Project
Cultural/Historical Resources Significant and mitigated Less than the Project Similar to the Project
Landform Alteration/
Visual Quality Significant and unavoidable Less than the Project
Less than the Project,
but still significant and
unavoidable
Air Quality Significant and mitigated Less than the Project Less than the Project
Noise Less than Significant Less than the Project Less than the Project
10.1 No Project (No Development) Alternative
10.1.1 Description
The No Project (No Development) Alternative would maintain the project site in its current condition
and would preserve the existing environmental setting (see Figure 2-2).
10.1.2 Analysis of the No Project (No Development)
Alternative
10.1.2.1 Land Use
No development would occur under the No Project (No Development) Alternative. Consequently,
this alternative would not require any deviations from the City’s Land Development Code (LDC),
Environmentally Sensitive Lands (ESL) ordinance, or the Historic Resource Regulations. Similarly, this
alternative would not conflict with the Multiple Species Conservation Program (MSCP)/Multi-Habitat
Planning Area (MHPA). Therefore, impacts related to land use under the No Project (No
Development) Alternative would be less than the project.
10.1.2.2 Biological Resources
No grading or construction activities would occur under the No Project (No Development)
Alternative. Consequently, this alternative would not impact any sensitive vegetation communities or
wildlife species. Similarly, this alternative would not require an MHPA boundary line adjustment.
Therefore, impacts related to biological resources under the No Project (No Development)
Alternative would be less than the project.
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10.1.2.3 Cultural/Historical Resources
No grading or construction activities would occur under the No Project (No Development)
Alternative. Consequently, this alternative would not impact any unknown subsurface deposits
associated with HJP-3 that could be unearthed during construction. Therefore, impacts related to
cultural/historical resources under the No Project (No Development) Alternative would be less than
the project.
10.1.2.4 Landform Alteration/Visual Quality
No grading or construction activities would occur under the No Project (No Development)
Alternative. Consequently, this alternative would not alter existing landforms on the project site,
including steep hillsides. Therefore, impacts related to landform alteration/visual quality under the
No Project (No Development) Alternative would be less than the project.
10.1.2.5 Air Quality
No construction or blasting activities would occur under the No Project (No Development)
Alternative. Consequently, this alternative would not generate construction emissions. Therefore,
impacts related to air quality under the No Project (No Development) Alternative would be less than
the project.
10.1.2.6 Noise
No construction or blasting activities would occur under the No Project (No Development)
Alternative. Consequently, this alternative would not generate construction noise and vibration that
could affect sensitive receptors or the adjacent MHPA. Therefore, impacts related to noise under the
No Project (No Development) Alternative would be less than the project.
10.1.3 Conclusion Regarding the No Project (No
Development) Alternative
The No Project (No Development) Alternative would maintain the project site in its current condition.
This alternative would preserve the existing environmental setting, and would thereby eliminate all
of the project’s impacts. However, the No Project (No Development) Alternative would not provide
any of the project’s benefits, including residential development and affordable housing consistent
with the adopted Subarea Plan and expansion of the MHPA through a boundary line adjustment
that would result in a net increase of 5.06 acres. These benefits would be foregone under this
alternative. Furthermore, the No Project (No Development) Alternative would not meet any of the
project objectives listed in Section 10.1 above.
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10.2 Reduced Development Footprint Alternative
10.2.1 Description
The Reduced Development Footprint Alternative would reduce the grading footprint compared to
the project. Through this footprint reduction the project would avoid impacts to the MHPA and
would not require a boundary line adjustment. Similarly, the smaller project footprint would reduce
impacts to sensitive vegetation communities and reduce impacts on landform alteration. Under this
alternative, the project would develop 117 residential units consistent with the amount anticipated
for the project site in the Black Mountain Ranch (Subarea I) Subarea Plan by constructing attached
multi-family structures with an increased density compared to the project.
10.2.2 Environmental Analysis of the Reduced
Development Footprint Alternative
10.2.2.1 Land Use
The Reduced Development Footprint Alternative would reduce the grading footprint, and thereby
avoid encroachment into the MHPA. Consequently, this alternative would be consistent with the
MHPA and would not require a boundary line adjustment. However, the increased density
associated with the project would require a height deviation to allow for development of 117 units
within the reduced grading footprint. Therefore, impacts related to land use under the Reduced
Development Footprint Alternative would be greater than the project.
10.2.2.2 Biological Resources
The Reduced Development Footprint Alternative would reduce the grading footprint, and thereby
avoid encroachment into the MHPA. Furthermore, the reduced grading footprint would also lessen
impacts on sensitive upland vegetation communities compared to the project. Therefore, impacts
related to biological resources under the Reduced Development Footprint Alternative would be less
than the project.
10.2.2.3 Cultural/Historical Resources
Although the Reduced Development Footprint Alternative would reduce the overall grading
footprint, this reduction would not occur within the general location of HJP-3. Consequently, the
Reduced Development Footprint Alternative would still have the potential to impact unknown
subsurface deposits associated with HJP-3 that could be unearthed during construction. Therefore,
impacts related to cultural/historical resources under the Reduced Development Footprint
Alternative would be similar to the project.
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10.2.2.4 Landform Alteration and Visual Quality
The Reduced Development Footprint Alternative would reduce the grading footprint, and thereby
reduce the amount of landform alteration and encroachment into steep slopes. However, the
increased density associated with this alternative would not be consistent with the character of the
single-family and detached multi-family residential units surrounding the project site. On balance,
the reduction of landform alteration and encroachment into steep slopes would lessen impacts
compared to the project, but would remain significant and unavoidable.
10.2.2.5 Air Quality
The Reduced Development Footprint Alternative would reduce the grading footprint, and thereby
reduce the amount of construction emissions. Although potential impacts would not be fully
avoided, they would be reduced compared to the project. Therefore, impacts related to air quality
under the Reduced Development Footprint Alternative would be less than the project.
10.2.2.6 Noise
The Reduced Development Footprint Alternative would reduce the grading footprint, and thereby
reduce the amount of construction noise and vibration. Although potential impacts would not be
fully avoided, they would be reduced compared to the project. Therefore, impacts related to noise
under the Reduced Development Footprint Alternative would be less than the project.
10.2.3 Conclusion Regarding the Reduced Development
Footprint Alternative
The Reduced Development Footprint Alternative would incrementally reduce all of the project’s
significant impacts due to the smaller grading footprint. This alternative would avoid impacts to the
MHPA and would not require a boundary line adjustment. Similarly, the smaller project footprint
would reduce impacts to sensitive vegetation communities and reduce impacts on landform
alteration. However, the increased density associated with this alternative would not be consistent
with the character of the single-family and detached multi-family residential units surrounding the
project site. Similarly, the increased density would require a height deviation to accommodate
development of 117 units within the reduced grading footprint. Furthermore, the Reduced
Development Footprint Alternative would lessen impacts on biological resources because the
project would actually increase land within the MHPA through the proposed boundary line
adjustment and would successfully mitigate impacts to sensitive vegetation communities to a level
less than significant.
10.3 Environmentally Superior Alternative
CEQA Guidelines section 15126.6(e)(2) requires the identification of an environmentally superior
alternative among the alternatives analyzed in an EIR. The guidelines also require that if the No
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Avion Project SEIR
Page 10-6
Project Alternative is the environmentally superior alternative, then another environmentally
superior alternative must be identified.
The Reduced Development Footprint Alternative would be considered the environmentally superior
alternative. This alternative would avoid impacts to the MHPA and would not require a boundary line
adjustment. Similarly, the smaller project footprint would reduce impacts to sensitive vegetation
communities and reduce impacts on landform alteration. Although, the increased density and
introduction of attached multi-family residential units that would occur under this alternative would
not be consistent with the character of the single-family and detached multi-family residential units
surrounding the project site, it would be considered environmentally superior to the project due to
the reduction in grading and biological impacts.
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Avion Project SEIR
Page 11-1
Chapter 11
Mitigation Monitoring and Reporting Program
Section 21081.6 of the State of California Public Resources Code (PRC) requires a Lead or
Responsible Agency that approves or carries out a project where an EIR has identified significant
environmental effects to adopt a “reporting or monitoring program for adopted or required changes
to mitigate or avoid significant environmental effects.” The City of San Diego is the Lead Agency for
the Avion Project Supplemental Environmental Impact Report (SEIR), and therefore must ensure the
enforceability of the Mitigation Monitoring and Reporting Program (MMRP). An SEIR has been
prepared for this project that addresses potential environmental impacts and, where appropriate,
recommends measures to mitigate these impacts. As such, an MMRP is required to ensure that
adopted mitigation measures are implemented.
The SEIR, incorporated herein as referenced, focuses on issues determined to be potentially
significant by the City. This SEIR also considers the issues discussed in the first-tier document and
evaluates whether a significant effect has been adequately addressed or if there is an effect that was
not addressed in the previous report. The issues determined to require subsequent analysis in the
SEIR include land use, biological resources, cultural/historical resources, landform alteration/visual
quality, air quality, and noise. Chapter 9.0 of the SEIR, Black Mountain Ranch (Subarea I) Subarea
Plan EIR Subject Areas Requiring No Change in Analysis, contains a summary of the impacts of the
project compared with the impacts analyzed in the 1998 EIR. The 1998 EIR concluded that the
following impacts were significant: land use, transportation/circulation, biological resources,
hydrology/water quality, landform alteration/visual quality, air quality, geology and soils, natural
resources/agriculture, noise, public facilities and services, and water conservation. The 1998 EIR
indicates that significant impacts for the project site would be substantially lessened or avoided if
the mitigation measures recommended in the EIR were implemented by future development for
various environmental issues. Previous mitigation measures from the 1998 EIR are identified below,
along with a conclusion as to whether the impact would be mitigated to below a level of significance.
After analysis, new or substantially increased potentially significant impacts requiring mitigation
were identified in the SEIR for biological resources, cultural/historical resources, landform alteration,
and air quality. The environmental analysis concluded that all of these significant and potentially
significant impacts could be avoided or reduced through implementation of recommended
mitigation measures, with the exception of impacts to landform alteration. Mitigation measures
that would reduce and/or avoid the environmental effects of the project are carried forward and
have been incorporated into this MMRP.
As Lead Agency for the proposed project under the California Environmental Quality Act (CEQA), the
City of San Diego will administer the MMRP for the following environmental issue areas as identified
in the Avion Project SEIR and 1998 EIR: transportation/circulation, air quality, biological resources,
historical/cultural resources, and air quality. This MMRP shall be made a requirement of project
approval.
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A. GENERAL REQUIREMENTS – PART I
Plan Check Phase (prior to permit issuance)
1. Prior to the issuance of a Notice to Proceed (NTP) for a subdivision, or any construction
permits, such as Demolition, Grading or Building, or beginning any construction related
activity on-site, the Development Services Department (DSD) Director’s Environmental
Designee (ED) shall review and approve all Construction Documents (CD) (plans,
specification, details, etc.) to ensure the MMRP requirements are incorporated into the
design.
2. In addition, the ED shall verify that the MMRP Conditions/Notes that apply ONLY to the
construction phases of this project are included VERBATIM, under the heading,
“ENVIRONMENTAL/MITIGATION REQUIREMENTS.”
3. These notes must be shown within the first three (3) sheets of the construction documents
in the format specified for engineering construction document templates as shown on the
City website:
http://www.sandiego.gov/development-services/industry/standtemp.shtml
4. The TITLE INDEX SHEET must also show on which pages the “Environmental/Mitigation
Requirements” notes are provided.
5. SURETY AND COST RECOVERY – The Development Services Director or City Manager may
require appropriate surety instruments or bonds from private Permit Holders to ensure the
long-term performance or implementation of required mitigation measures or programs.
The City is authorized to recover its cost to offset the salary, overhead, and expenses for City
personnel and programs to monitor qualifying projects.
B. GENERAL REQUIREMENTS – PART II
Post Plan Check (After Permit Issuance/Prior to Start of Construction)
1. PRECONSTRUCTION MEETING IS REQUIRED TEN (10) WORKING DAYS PRIOR TO
BEGINNING ANY WORK ON THIS PROJECT. The PERMIT HOLDER/OWNER is responsible to
arrange and perform this meeting by contacting the CITY RESIDENT ENGINEER (RE) of the
Field Engineering Division and City staff from MITIGATION MONITORING COORDINATION
(MMC). Attendees must also include the Permit holder’s Representative(s), Job Site
Superintendent and the following consultants:
Qualified Paleontological Monitor(s), Acoustician, Archaeologist(s), Native American
Monitor(s), and Biologist(s)
NOTE: Failure of all responsible Permit Holder’s representatives and consultants to
attend shall require an additional meeting with all parties present.
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Contact Information:
a) The PRIMARY POINT OF CONTACT is the RE at the Field Engineering Division –
858-627-3200
b) For Clarification of ENVIRONMENTAL REQUIREMENTS, it is also required to call RE and
MMC at 858-627-3360
2. MMRP COMPLIANCE: This Project, Project Tracking System (PTS) No. 598173 and/or
Environmental Document No. 598173, shall conform to the mitigation requirements
contained in the associated Environmental Document and implemented to the satisfaction
of the DSD’s Environmental Designee (MMC) and the City Engineer (RE). The requirements
may not be reduced or changed but may be annotated (i.e. to explain when and how
compliance is being met and location of verifying proof, etc.). Additional clarifying
information may also be added to other relevant plan sheets and/or specifications as
appropriate (i.e., specific locations, times of monitoring, methodology, etc.).
NOTE: Permit Holder’s Representatives must alert RE and MMC if there are any
discrepancies in the plans or notes, or any changes due to field conditions. All
conflicts must be approved by RE and MMC BEFORE the work is performed.
3. OTHER AGENCY REQUIREMENTS: Evidence of compliance with all other agency
requirements or permits shall be submitted to the RE and MMC for review and acceptance
prior to the beginning of work or within one week of the Permit Holder obtaining
documentation of those permits or requirements. Evidence shall include copies of permits,
letters of resolution or other documentation issued by the responsible agency.
• California Department of Fish and Wildlife: California Fish and Game Code Section
1602 Streambed Alteration Agreement
• Federal Emergency Management Agency: Conditional Letter of Map Revision
• Regional Water Quality Control Board: National Pollutant Discharge Elimination
System General Construction Permit, Clean Water Act Section 401
waiver/certification
• U.S. Army Corps of Engineers: Clean Water Act Section 404 authorization
• San Diego County Airport Land Use Commission Consistency Determination
(Conditional Consistency November 6, 2018)
4. MONITORING EXHIBITS: All consultants are required to submit, to RE and MMC, a
monitoring exhibit on a 11x17 reduction of the appropriate construction plan, such as site
plan, grading, landscape, etc., marked to clearly show the specific areas including the LIMIT
OF WORK, scope of that discipline’s work, and notes indicating when in the construction
schedule that work will be performed. When necessary for clarification, a detailed
methodology of how the work will be performed shall be included.
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NOTE: Surety and Cost Recovery – When deemed necessary by the Development
Services Director or City Manager, additional surety instruments or bonds from
the private Permit Holder may be required to ensure the long-term
performance or implementation of required mitigation measures or programs.
The City is authorized to recover its cost to offset the salary, overhead, and
expenses for City personnel and programs to monitor qualifying projects.
5. OTHER SUBMITTALS AND INSPECTIONS: The Permit Holder/Owner’s representative shall
submit all required documentation, verification letters, and requests for all associated
inspections to the RE and MMC for approval per the following schedule:
Document Submittal/Inspection Checklist
Issue Area Document Submittal Associated Inspection/ Approvals/
Notes
General Consultant Qualification Letters Prior to Preconstruction Meeting
General Consultant Construction Monitoring
Exhibits Prior to or at Preconstruction Meeting
Land Use
Multi-Habitat Planning Area (MHPA)
Land Use Adjacency Issues Consultant
Site Visit Records (CSVR)
Land Use Adjacency Issue Site
Observations
Biology Biologist Limit of Work Verification Limit of Work Inspection
Biology Biology Reports Biology/Habitat Inspection
Archaeology Archaeology Reports Archaeology/Historic Site Observation
Noise Blasting Management Plan Prior to issuance of the first grading
permit
Waste Management Waste Management Reports Waste Management Inspections
Bond Release Request for Bond Release Letter Final MMRP Inspections Prior to Bond
Release Letter
C. SPECIFIC MMRP ISSUE AREA CONDITIONS/REQUIREMENTS
Biological Resources
Vegetation Communities
MM-BIO-1: Upland Vegetation Communities
Mitigation for impacts to coastal sage scrub (Tier II habitat), southern mixed chaparral (Tier IIIA habitat),
and non-native grassland (Tier IIIB habitat) communities would be achieved through the preservation of
habitat on the site located outside of the development area. Prior to issuance of any construction
permits, including but not limited to, the first Grading Permit, Demolition Plans/Permits and Building
Plans/Permits, the project would demonstrate to the satisfaction of the City that impacts to a total of
15.2 acres of sensitive vegetation would be mitigated by the on-site preservation of 24.03 acres of
sensitive vegetation as summarized by habitat type in Table 5.2-5. The preserved habitat areas on the site
would all be within the boundaries of the MHPA Boundary Line Adjustment (BLA) dedicated to the City in
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fee title. Acceptance of land dedicated in fee title is subject to approval by the City’s Park and Recreation
Open Space.
Sensitive Wildlife
MM-BIO-2: Standard City Construction Measures
Prior to issuance of any construction permits, including but not limited to, the first Grading Permit,
Demolition Plans/Permits and Building Plans/Permits, mitigation for general impacts to biological
resources would be incorporated via standard measures including general mitigation measures,
biological protections during construction, (includes monitoring, preconstruction meetings, and
development of a Biological Condition Monitoring Exhibit, etc.) as described below. These Biological
Resources Protection requirements shall be depicted on the construction documents verbatim and
implemented accordingly.
Biological Resource Protection During Construction
I. Prior to Construction
A. Biologist Verification - The owner/permittee shall provide a letter to the City’s Mitigation
Monitoring Coordination (MMC) section stating that a Project Biologist (Qualified Biologist) as
defined in the City’s Biological Guidelines (2012), has been retained to implement the
project’s biological monitoring program. The letter shall include the names and contact
information of all persons involved in the biological monitoring of the project.
B. Preconstruction Meeting - The Qualified Biologist shall attend the preconstruction
meeting, discuss the project’s biological monitoring program, and arrange to perform any
follow up mitigation measures and reporting including site-specific monitoring, restoration
or revegetation, and additional fauna/flora surveys/salvage.
C. Biological Documents - The Qualified Biologist shall submit all required documentation to
MMC verifying that any special mitigation reports including but not limited to, maps, plans,
surveys, survey timelines, or buffers are completed or scheduled per the City’s Biology
Guidelines, MSCP, ESL Ordinance, project permit conditions; CEQA; endangered species acts
(ESAs); and/or other local, state or federal requirements.
D. Biological Construction Mitigation/Monitoring Exhibit (BCME) - The Qualified Biologist
shall present a BCME, which includes the biological documents in “C” above. In addition,
include: restoration/revegetation plans, plant salvage/relocation requirements (e.g., coastal
cactus wren plant salvage, burrowing owl exclusions, etc.), avian or other wildlife
surveys/survey schedules (including U.S. Fish and Wildlife Service protocol), timing of
surveys, wetland buffers, other impact avoidance areas, and any subsequent requirements
determined by the Qualified Biologist and the City Assistant Deputy Director (ADD)/MMC.
The BCME shall include a site plan, written and graphic depiction of the project’s biological
mitigation/monitoring program, and a schedule. The BCME shall be approved by MMC and
referenced in the construction documents.
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E. Avian Protection Requirements - To avoid any direct impacts to Cooper’s hawk, rufous-
crowned sparrow, and coastal California gnatcatcher or any species identified as listed,
candidate, sensitive, or special status in the MSCP, removal of habitat that supports active
nests in the proposed area of disturbance should occur outside of the breeding season for
these species (February 1 to September 15). If removal of habitat in the proposed area of
disturbance must occur during the breeding season, the Qualified Biologist shall conduct a
preconstruction survey to determine the presence or absence of nesting for these three
sensitive bird species on the proposed area of disturbance. The preconstruction survey shall
be conducted within 10 calendar days prior to the start of construction activities (including
removal of vegetation). The applicant shall submit the results of the preconstruction survey
to the City’s DSD for review and approval prior to initiating any construction activities. If
nesting activities for any of the above-mentioned sensitive bird species are detected, a letter
report or mitigation plan in conformance with the City’s Biology Guidelines and applicable
state and federal law (i.e., appropriate follow up surveys, monitoring schedules, construction
and noise barriers/buffers, etc.) shall be prepared and include proposed measures to be
implemented to ensure that take of birds or eggs or disturbance of breeding activities is
avoided. The report or mitigation plan shall be submitted to the City for review and approval
and implemented to the satisfaction of the City. The City’s MMC Section or Resident
Engineer, and Biologist shall verify and approve that all measures identified in the report or
mitigation plan are in place prior to and/or during construction.
F. Resource Delineation - Prior to construction activities, the Qualified Biologist shall
supervise the placement of orange construction fencing or equivalent along the limits of
disturbance adjacent to sensitive biological habitats and verify compliance with any other
project conditions as shown on the BCME. This phase shall include flagging plant specimens
and delimiting buffers to protect sensitive biological resources (e.g., habitats/flora and fauna
species, including nesting Cooper’s hawk, rufous-crowned sparrow, and coastal California
gnatcatcher) during construction. Appropriate steps/care should be taken to minimize
attraction of nest predators to the site.
G. Education – Prior to commencement of construction activities, the Qualified Biologist shall
meet with the owner/permittee or designee and the construction crew and conduct an on-
site educational session regarding the need to avoid impacts outside of the approved
construction area and to protect sensitive flora and fauna (e.g., explain the avian and
wetland buffers, flag system for removal of invasive species or retention of sensitive plants,
and clarify acceptable access routes/methods and staging areas, etc.).
II. During Construction
A. Monitoring – All construction (including access/staging areas) shall be restricted to areas
previously identified, proposed for development/staging, or previously disturbed as shown
on “Exhibit A” and/or the BCME. The Qualified Biologist shall monitor construction activities
as needed to ensure that construction activities do not encroach into biologically sensitive
areas, or cause other similar damage, and that the work plan has been amended to
accommodate any sensitive species located during the preconstruction surveys. In addition,
the Qualified Biologist shall document field activity via the Consultant Site Visit Record
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(CSVR). The CSVR shall be e-mailed to the MMC on the first day of monitoring, the first week
of each month, the last day of monitoring, and immediately in the case of any
undocumented condition or discovery.
B. Subsequent Resource Identification – The Qualified Biologist shall note/act to prevent any
new disturbances to habitat, flora, and/or fauna on-site (e.g., flag plant specimens for
avoidance during access, etc.). If active nests for Cooper’s hawk, rufous-crowned sparrow,
and coastal California gnatcatcher, or other previously unknown sensitive resources are
detected, all project activities that directly impact the resource shall be delayed until species
specific local, state or federal regulations have been determined and applied by the
Qualified Biologist.
III. Post Construction Measures
A. In the event that impacts exceed previously allowed amounts, additional impacts shall be
mitigated in accordance with City Biology Guidelines, ESL and MSCP, CEQA, and other
applicable local, state and federal law. The Qualified Biologist shall submit a final
BCME/report to the satisfaction of the City ADD/MMC within 30 days of construction
completion.
Cultural/Historical Resources
Historic Resources
MM-HIST-1: Archaeological Monitoring
I. Prior to Permit Issuance
A. Entitlements Plan Check
1. Prior to issuance of any construction permits, including but not limited to, the first
Grading Permit, Demolition Plans/Permits and Building Plans/Permits or a Notice to
Proceed for Subdivisions, but prior to the first preconstruction meeting, whichever is
applicable, the Assistant Deputy Director (ADD) Environmental designee shall verify
that the requirements for Archaeological Monitoring and Native American
monitoring have been noted on the applicable construction documents through the
plan check process.
B. Letters of Qualification have been submitted to ADD
1. The applicant shall submit a letter of verification to Mitigation Monitoring
Coordination (MMC) identifying the Principal Investigator (PI) for the project and the
names of all persons involved in the archaeological monitoring program, as defined
in the City of San Diego Historical Resources Guidelines (HRG). If applicable,
individuals involved in the archaeological monitoring program must have completed
the 40-hour HAZWOPER training with certification documentation.
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2. MMC will provide a letter to the applicant confirming the qualifications of the PI and
all persons involved in the archaeological monitoring of the project meet the
qualifications established in the HRG.
3. Prior to the start of work, the applicant must obtain written approval from MMC for
any personnel changes associated with the monitoring program.
II. Prior to Start of Construction
A. Verification of Records Search
1. The PI shall provide verification to MMC that a site specific records search (1/4 mile
radius) has been completed. Verification includes, but is not limited to a copy of a
confirmation letter from South Coastal Information Center, or, if the search was in-
house, a letter of verification from the PI stating that the search was completed.
2. The letter shall introduce any pertinent information concerning expectations and
probabilities of discovery during trenching and/or grading activities.
3. The PI may submit a detailed letter to MMC requesting a reduction to the ¼ mile
radius.
B. PI Shall Attend Precon Meetings
1. Prior to beginning any work that requires monitoring; the Applicant shall arrange a
Precon Meeting that shall include the PI, Native American consultant/monitor (where
Native American resources may be impacted), Construction Manager (CM) and/or
Grading Contractor, Resident Engineer (RE), Building Inspector (BI), if appropriate,
and MMC. The qualified Archaeologist and Native American Monitor shall attend any
grading/excavation related Precon Meetings to make comments and/or suggestions
concerning the Archaeological Monitoring program with the Construction Manager
and/or Grading Contractor.
a. If the PI is unable to attend the Precon Meeting, the Applicant shall schedule a
focused Precon Meeting with MMC, the PI, RE, CM or BI, if appropriate, prior to
the start of any work that requires monitoring.
2. Identify Areas to be Monitored
a. Prior to the start of any work that requires monitoring, the PI shall submit an
Archaeological Monitoring Exhibit (AME) (with verification that the AME has been
reviewed and approved by the Native American consultant/monitor when Native
American resources may be impacted) based on the appropriate construction
documents (reduced to 11x17) to MMC identifying the areas to be monitored
including the delineation of grading/excavation limits.
b. The AME shall be based on the results of a site specific records search as well as
information regarding existing known soil conditions (native or formation).
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3. When Monitoring Will Occur
a. Prior to the start of any work, the PI shall also submit a construction schedule to
MMC through the RE indicating when and where monitoring will occur.
b. The PI may submit a detailed letter to MMC prior to the start of work or during
construction requesting a modification to the monitoring program. This request
shall be based on relevant information such as review of final construction
documents which indicate site conditions such as depth of excavation and/or site
graded to bedrock, etc., which may reduce or increase the potential for
resources to be present.
III. During Construction
A. Monitor(s) Shall be Present During Grading/Excavation/Trenching
1. The Archaeological Monitor shall be present full-time during all soil disturbing and
grading/excavation/trenching activities which could result in impacts to
archaeological resources as identified on the AME. The Construction Manager is
responsible for notifying the RE, PI, and MMC of changes to any construction
activities such as in the case of a potential safety concern within the area being
monitored. In certain circumstances OSHA safety requirements may necessitate
modification of the AME.
2. The Native American consultant/monitor shall determine the extent of their
presence during soil disturbing and grading/excavation/trenching activities based on
the AME and provide that information to the PI and MMC. If prehistoric resources are
encountered during the Native American consultant/monitor’s absence, work shall
stop and the Discovery Notification Process detailed in Section III.B-C and IV.A-D shall
commence.
3. The PI may submit a detailed letter to MMC during construction requesting a
modification to the monitoring program when a field condition such as modern
disturbance post-dating the previous grading/trenching activities, presence of fossil
formations, or when native soils are encountered that may reduce or increase the
potential for resources to be present.
4. The archaeological and Native American consultant/monitor shall document field
activity via the Consultant Site Visit Record (CSVR). The CSVR’s shall be faxed by the
CM to the RE the first day of monitoring, the last day of monitoring, monthly
(Notification of Monitoring Completion), and in the case of ANY discoveries. The RE
shall forward copies to MMC.
B. Discovery Notification Process
1. In the event of a discovery, the Archaeological Monitor shall direct the contractor to
temporarily divert all soil disturbing activities, including but not limited to digging,
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trenching, excavating or grading activities in the area of discovery and in the area
reasonably suspected to overlay adjacent resources and immediately notify the RE or
BI, as appropriate.
2. The Monitor shall immediately notify the PI (unless Monitor is the PI) of the
discovery.
3. The PI shall immediately notify MMC by phone of the discovery, and shall also submit
written documentation to MMC within 24 hours by fax or email with photos of the
resource in context, if possible.
4. No soil shall be exported off-site until a determination can be made regarding the
significance of the resource specifically if Native American resources are
encountered.
C. Determination of Significance
1. The PI and Native American consultant/monitor, where Native American resources
are discovered shall evaluate the significance of the resource. If Human Remains are
involved, follow protocol in Section IV below.
a. The PI shall immediately notify MMC by phone to discuss significance
determination and shall also submit a letter to MMC indicating whether
additional mitigation is required.
b. If the resource is significant, the PI shall submit an Archaeological Data Recovery
Program (ADRP) which has been reviewed by the Native American
consultant/monitor, and obtain written approval from MMC. Impacts to
significant resources must be mitigated before ground disturbing activities in the
area of discovery will be allowed to resume. Note: If a unique archaeological site
is also an historical resource as defined in CEQA, then the limits on the amount(s)
that a project applicant may be required to pay to cover mitigation costs as
indicated in CEQA Section 21083.2 shall not apply.
c. If the resource is not significant, the PI shall submit a letter to MMC indicating
that artifacts will be collected, curated, and documented in the Final Monitoring
Report. The letter shall also indicate that that no further work is required.
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IV. Discovery of Human Remains
If human remains are discovered, work shall halt in that area and no soil shall be exported
off-site until a determination can be made regarding the provenance of the human remains;
and the following procedures as set forth in CEQA Section 15064.5(e), the California Public
Resources Code (Sec. 5097.98) and State Health and Safety Code (Sec. 7050.5) shall be
undertaken:
A. Notification
1. Archaeological Monitor shall notify the RE or BI as appropriate, MMC, and the PI, if
the Monitor is not qualified as a PI. MMC will notify the appropriate Senior Planner in
the Environmental Analysis Section (EAS) of the Development Services Department
to assist with the discovery notification process.
2. The PI shall notify the Medical Examiner after consultation with the RE, either in
person or via telephone.
B. Isolate discovery site
1. Work shall be directed away from the location of the discovery and any nearby area
reasonably suspected to overlay adjacent human remains until a determination can
be made by the Medical Examiner in consultation with the PI concerning the
provenance of the remains.
2. The Medical Examiner, in consultation with the PI, will determine the need for a field
examination to determine the provenance.
3. If a field examination is not warranted, the Medical Examiner will determine with
input from the PI, if the remains are or are most likely to be of Native American
origin.
C. If Human Remains ARE determined to be Native American
1. The Medical Examiner will notify the Native American Heritage Commission (NAHC)
within 24 hours. By law, ONLY the Medical Examiner can make this call.
2. NAHC will immediately identify the person or persons determined to be the Most
Likely Descendent (MLD) and provide contact information.
3. The MLD will contact the PI within 24 hours or sooner after the Medical Examiner has
completed coordination, to begin the consultation process in accordance with CEQA
Section 15064.5(e), the California Public Resources and Health & Safety Codes.
4. The MLD will have 48 hours to make recommendations to the property owner or
representative, for the treatment or disposition with proper dignity, of the human
remains and associated grave goods.
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5. Disposition of Native American Human Remains will be determined between the
MLD and the PI, and, if:
a. The NAHC is unable to identify the MLD, OR the MLD failed to make a
recommendation within 48 hours after being granted access to the site, OR;
b. The landowner or authorized representative rejects the recommendation of the
MLD and mediation in accordance with PRC 5097.94 (k) by the NAHC fails to
provide measures acceptable to the landowner, the landowner shall reinter the
human remains and items associated with Native American human remains with
appropriate dignity on the property in a location not subject to further and
future subsurface disturbance, THEN
c. To protect these sites, the landowner shall do one or more of the following:
(1) Record the site with the NAHC;
(2) Record an open space or conservation easement; or
(3) Record a document with the County. The document shall be titled “Notice of
Reinterment of Native American Remains” and shall include a legal
description of the property, the name of the property owner, and the owner’s
acknowledged signature, in addition to any other information required by
PRC 5097.98. The document shall be indexed as a notice under the name of
the owner.
d. Upon the discovery of multiple Native American human remains during a ground
disturbing land development activity, the landowner may agree that additional
conferral with descendants is necessary to consider culturally appropriate
treatment of multiple Native American human remains. Culturally appropriate
treatment of such a discovery may be ascertained from review of the site
utilizing cultural and archaeological standards. Where the parties are unable to
agree on the appropriate treatment measures the human remains and items
associated and buried with Native American human remains shall be reinterred
with appropriate dignity, pursuant to Section 5.c., above.
D. If Human Remains are NOT Native American
1. The PI shall contact the Medical Examiner and notify them of the historic era context
of the burial.
2. The Medical Examiner will determine the appropriate course of action with the PI
and City staff (PRC 5097.98).
3. If the remains are of historic origin, they shall be appropriately removed and
conveyed to the San Diego Museum of Man for analysis. The decision for internment
of the human remains shall be made in consultation with MMC, EAS, the
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applicant/landowner, any known descendant group, and the San Diego Museum of
Man.
V. Night and/or Weekend Work
A. If night and/or weekend work is included in the contract
1. When night and/or weekend work is included in the contract package, the extent and
timing shall be presented and discussed at the precon meeting.
2. The following procedures shall be followed.
a. No Discoveries
In the event that no discoveries were encountered during night and/or weekend
work, the PI shall record the information on the CSVR and submit to MMC via fax
by 8AM of the next business day.
b. Discoveries
All discoveries shall be processed and documented using the existing procedures
detailed in Sections III - During Construction, and IV – Discovery of Human
Remains. Discovery of human remains shall always be treated as a significant
discovery.
c. Potentially Significant Discoveries
If the PI determines that a potentially significant discovery has been made, the
procedures detailed under Section III - During Construction and IV-Discovery of
Human Remains shall be followed.
d. The PI shall immediately contact MMC, or by 8AM of the next business day to
report and discuss the findings as indicated in Section III-B, unless other specific
arrangements have been made.
B. If night and/or weekend work becomes necessary during the course of construction
1. The Construction Manager shall notify the RE, or BI, as appropriate, a minimum of 24
hours before the work is to begin.
2. The RE, or BI, as appropriate, shall notify MMC immediately.
C. All other procedures described above shall apply, as appropriate.
VI. Post Construction
A. Preparation and Submittal of Draft Monitoring Report
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1. The PI shall submit two copies of the Draft Monitoring Report (even if negative),
prepared in accordance with the Historical Resources Guidelines (Appendix C/D)
which describes the results, analysis, and conclusions of all phases of the
Archaeological Monitoring Program (with appropriate graphics) to MMC for review
and approval within 90 days following the completion of monitoring. It should be
noted that if the PI is unable to submit the Draft Monitoring Report within the
allotted 90-day timeframe resulting from delays with analysis, special study results or
other complex issues, a schedule shall be submitted to MMC establishing agreed due
dates and the provision for submittal of monthly status reports until this measure
can be met.
a. For significant archaeological resources encountered during monitoring, the
Archaeological Data Recovery Program shall be included in the Draft Monitoring
Report.
b. Recording Sites with State of California Department of Parks and Recreation
The PI shall be responsible for recording (on the appropriate State of California
Department of Park and Recreation forms-DPR 523 A/B) any significant or
potentially significant resources encountered during the Archaeological
Monitoring Program in accordance with the City’s Historical Resources
Guidelines, and submittal of such forms to the South Coastal Information Cen ter
with the Final Monitoring Report.
2. MMC shall return the Draft Monitoring Report to the PI for revision or, for
preparation of the Final Report.
3. The PI shall submit revised Draft Monitoring Report to MMC for approval.
4. MMC shall provide written verification to the PI of the approved report.
5. MMC shall notify the RE or BI, as appropriate, of receipt of all Draft Monitoring
Report submittals and approvals.
B. Handling of Artifacts
1. The PI shall be responsible for ensuring that all cultural remains collected are
cleaned and catalogued
2. The PI shall be responsible for ensuring that all artifacts are analyzed to identify
function and chronology as they relate to the history of the area; that faunal material
is identified as to species; and that specialty studies are completed, as appropriate.
3. The cost for curation is the responsibility of the property owner.
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C. Curation of artifacts: Accession Agreement and Acceptance Verification
1. The PI shall be responsible for ensuring that all artifacts associated with the survey,
testing and/or data recovery for this project are permanently curated with an
appropriate institution. This shall be completed in consultation with MMC and the
Native American representative, as applicable.
2. The PI shall include the Acceptance Verification from the curation institution in the
Final Monitoring Report submitted to the RE or BI and MMC.
3. When applicable to the situation, the PI shall include written verification from the
Native American consultant/monitor indicating that Native American resources were
treated in accordance with state law and/or applicable agreements. If the resources
were reinterred, verification shall be provided to show what protective measures
were taken to ensure no further disturbance occurs in accordance with Section IV –
Discovery of Human Remains, Subsection 5.
D. Final Monitoring Report(s)
1. The PI shall submit one copy of the approved Final Monitoring Report to the RE or BI
as appropriate, and one copy to MMC (even if negative), within 90 days after
notification from MMC that the draft report has been approved.
2. The RE shall, in no case, issue the Notice of Completion and/or release of the
Performance Bond for grading until receiving a copy of the approved Final
Monitoring Report from MMC which includes the Acceptance Verification from the
curation institution.
AIR QUALITY
Sensitive Receptors (Construction)
MM-AIR-1a: Arsenic Testing Protocol in Areas Requiring Blasting
Geocon shall obtain periodic random samples from select air-track borehole spoils or the ground
surface over the course of the blasting program. The number of samples shall vary and be based on
judgement depending on the size of the shot. The samples shall be assigned for analysis of arsenic
using U.S. Environmental Protection Agency Test Method 6010B with a reporting limit of
1.0 milligram per kilogram. The sampling shall be performed under the direct supervision of
Geocon’s Project Manager and Professional Geologist.
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MM-AIR-1b: Blasting Dust Mitigation Plan
The following protocols shall be performed to minimize the generation of visible dust during the
hard rock blasting events:
• The areas shall be heavily watered prior to the planned blasting. The amount of water
applied shall depend on the size of the shot and composition of the materials exposed at the
top of the shot (i.e., topsoil vs. hard rock).
• A water truck shall be dedicated to pre-wet the ground surface.
• Detergent, if necessary, shall be added to the water truck to reduce the surface tension of
the water and promote soaking into the surface materials. The water used shall be confined
to the area of the shot and not be allowed to migrate out of the work limits. Confinement of
the water shall be achieved through use of earthen berms, ditches, or other containment
features that shall prevent migration of the water outside the work area.
• Once the boreholes are loaded with blasting agent, a final soaking shall occur just prior to
the shot.
D. PREVIOUS MITIGATION (1998 EIR)
Transportation/Circulation
The project would be subject to conditions of approval consistent with the MMRP for the 1998 EIR.
Specifically, prior to the issuance of any building permit, the project is required to be in conformance
with the Black Mountain Ranch Transportation Phasing Plan.
Air Quality
The 1998 EIR incorporated mitigation measures that would reduce fugitive dust impacts from
construction activity. Dust control during construction and grading operations would be regulated in
accordance with the rules of the San Diego Air Pollution Control District. The following measures
would reduce fugitive dust impacts:
1. All unpaved construction areas would be sprinkled with water or other acceptable San Diego
County Air Pollution Control District (SDAPCD) dust control agents during dust-generating
activities to reduce dust emissions. Additional watering or acceptable Air Pollution Control
District dust control agents would be applied during dry weather or windy days until dust
emissions are not visible.
2. Trucks hauling dirt and debris would be covered to reduce windblown dust and spills.
3. On dry days, dirt and debris spilled onto paved surfaces would be swept up immediately to
reduce resuspension of particulate matter caused by vehicle movement. Approach routes to
construction sites would be cleaned daily of construction-related dirt in dry weather.
11.0 Mitigation Monitoring and Reporting Program
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4. On-site stockpiles of excavated material would be covered or watered.
To reduce construction-related vehicle emissions, ride share opportunities would be encouraged
and construction vehicle access would be limited to roads determined in a temporary traffic
construction management plan. In addition, construction staging areas would be as far away from
existing or completed residences as possible.
12.0 References Cited
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Chapter 12
References Cited
Beier, P., and S. Loe
1992 A Checklist for Evaluating Impacts to Wildlife Movement Corridors. Wildlife Society Bulletin.
20:434-440.
Bender, Wesley L.
2007 Back to Basics, The Fundamentals of Blast Design.
California Air Pollution Control Officers Association (CAPCOA)
2017 California Emissions Estimator model (CalEEMod). User’s Guide Version 2016.3.2. October.
California Air Resources Board (CARB)
2016 Ambient Air Quality Standards. California Air Resources Board. May 4.
California Department of Transportation (Caltrans)
2013 Transportation and Construction Vibration Guidance Manual, September, available at:
http://www.dot.ca.gov/hq/env/noise/pub/TCVGM_Sep13_FINAL.pdf.
Carrico, Richard L.
1987 Strangers in a Stolen Land. American Indians in San Diego 1850-1880. Sierra Oaks
Publishing, Newcastle, California.
Cline, Lora L.
1984a Just Before Dawn. L. C. Enterprises, Tombstone, Arizona.
1984b Just Before Sunset. J and L Enterprises, Jacumba, California.
Cook, Sherburne F.
1976 The Population of California Indians, 1769-1970. Berkeley: University of California Press.
Dexter Wilson Engineering, Inc. (Dexter Wilson)
2018a Water System Analysis. August.
2018b Sewer System Analysis. February.
Federal Highway Administration (FHWA)
2008 Roadway Construction Noise Model. V1.1. Washington, DC.
Federal Transit Administration (FTA)
2006 Transit Noise and Vibration Impact Assessment. Washington, DC. May.
12.0 References Cited
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Geocon, Incorporated
2018a Geotechnical Investigation.
2018b Phase I Environmental Site Assessment.
Hector, Susan M., and Stephen R. Van Wormer
1986 Broken Fragments of Past Lifeways: Archaeological Excavations at Los Peñasquitos Ranch
House, Volumes I and II. RECON.
KOA Corporation
2019 Avion VTM in Black Mountain Ranch – SE Perimeter Properties. June 10.
May, Ronald V.
1976 An Early Ceramic Date Threshold in Southern California. Masterkey 50(3):103-107.
1978 A Southern California Indigenous Ceramic Typology: A Contribution to Malcolm J. Rogers
Research. ASA Journal 2:2.
Meighan, Clement W.
1954 A Late Complex in Southern California Prehistory. Southwestern Journal of Anthropology
10:215 227.
Office of Environmental Health Hazard Assessment (OEHHA)
2015 Air Toxics Hot Spots Program Guidance Manual for the Preparation of Risk Assessments
(Guidance Manual), February.
Pourade, Richard F.
1969 Historic Ranchos of San Diego. A Copley Book, Union-Tribune Publishing, San Diego
Project Design Consultants (PDC)
2019a Design Review Guidelines for Avion. September.
2019b Preliminary Drainage Report. April.
2019c Storm Water Quality Management Plan. April.
2019d Preliminary Hydromodification Management Study. April.
RECON
2013 Biological Constraints Report for the DeBevoise Property.
2019a Biological Technical Report. June.
2019b Historical Resources Survey Report. June.
12.0 References Cited
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2019c Results of the Cultural Resources Testing Program for CA-SDI-18,428 and CA-SDI-18,429.
August.
2019d Air Quality Analysis. September.
2019e Noise Analysis. September.
2019f Waste Management Plan. July.
Rogers, Malcolm J.
1938 Archaeological and Geological Investigations of the Culture Levels in an Old Channel of
San Dieguito Valley. Carnegie Institution of Washington Yearbook 37:344-45.
1939 Early Lithic Industries of the Lower Basin of the Colorado River and Adjacent Desert Areas.
San Diego Museum of Man Papers No. 3, San Diego.
1945 An Outline of Yuman Prehistory. Southwestern Journal of Anthropology 1(2):167-198.
Albuquerque.
Rolle, Andrew
1998 California: A History. Harlan Davidson, Inc. Wheeling, Illinois.
San Diego Air Pollution Control District (SDAPCD)
1969 Rules and Regulations. Regulation IV. Prohibitions. Rule 51. Nuisance. Effective January 1.
2015 Supplemental Guidelines for Submission of Air Toxics “Hot Spots” Program Health Risk
Assessments.
2016 Resolution Adopting Amended Rule 20.1 – New Source Review – General Provisions; Rule 20.2 –
New Source Review – Non-Major Stationary Sources; Rule 20.3 – New Source Review – Major
Stationary Sources And Prevention of Significant Deterioration (PSD) Stationary Sources; Rule
20.4 – New Source Review – Portable Emission Units; and Rule 20.6 – Standards for Permit to
Operate Air Quality Analysis, of Regulation II of the Rules and Regulations of the San Diego Air
Pollution Control District. Resolution Number 16-041. April 27.
San Diego Association of Governments (SANDAG)
2019 Traffic Forecast Information Center. Series 13 Year 2020 data.
http://tfic.sandag.org/map.html. August 26, 2019.
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1997 Multiple Species Conservation Program (MSCP). MSCP Subarea Plan. March. Available
online: http://www.sandiego.gov/planning/mscp/docsmaps/index.
1998 Black Mountain Ranch (Subarea I) Subarea Plan EIR [LDR No.96-7902; SCH#97111070]
2005 Environmental Impact Report Guidelines. Updated May.
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2008 City of San Diego General Plan and EIR. March.
2009 Black Mountain Ranch Subarea Plan. Adopted July 1998, Amended May.
2012 San Diego Municipal Code – Land Development Code: Biology Guidelines. Amended
April 23 by Resolution No. R-307376.
2013 MSCP Subarea Plan Land Use Adjacency Guidelines. August.
2014 San Diego Municipal Code – Chapter 14 General Regulations, Article 2 General
Development Regulations. July.
2016 Significance Determination Thresholds. California Environmental Quality Act. July.
San Diego, County of
2017 2011 Consolidated Fire Code, 4th Edition, April 14.
True, Delbert L.
1970 Investigation of a Late Prehistoric Complex in Cuyamaca Rancho State Park, San Diego
County, California. Department of Anthropology Publications. University of California, Los
Angeles.
U.S. Environmental Protection Agency (EPA)
2017a Criteria Air Pollutants, Carbon Monoxide Outdoor Air Pollution. Available at
https://www.epa.gov/co-pollution/basic-information-about-carbon-monoxide-co-outdoor-
air-pollution#Effects. Accessed December 4, 2017.
2017b Criteria Air Pollutants, Particulate Matter Basics. Available at https://www.epa.gov/pm-
pollution/particulate-matter-pm-basics#effects. Accessed on December 4, 2017.
U.S. Department of Agriculture
1973 Soil Survey, San Diego Area, California. Edited by Roy H. Bowman. Soil Conservation
Service and Forest Service. December.
U.S. Fish and Wildlife Service (USFWS)
1998 Endangered and Threatened Wildlife and Plants; Determination of Endangered and
Threatened Status for Four Southwestern California Plants of Vernal Wetlands and Clay
Soils. 50 CFR Part 17, Federal Register Vol. 63, No. 197; 54975 – 54994. October 13.
2005 Endangered and Threatened Wildlife and Plants; Designation of Critical Habitat for
Brodiaea filifolia (thread-leaved brodiaea); Final Rule. 50 CFR Part 17, Federal Register Vol.
70, No. 238; 73820 – 73863. December 13.
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Warren, Claude N., Gretchen Siegler, and Frank Dittmer
1993 Paleoindian and Early Archaic Periods. In Historic Properties Background Study for the City
of San Diego Clean Waste Program. On file with Mooney and Associates.
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Chapter 13
Individuals and Preparers Consulted
A list of individuals, preparers, and agencies consulted during the preparation of the EIR include the
following:
City of San Diego
Development Services Department
• Elizabeth Shearer-Nguyen, Environmental Analysis Section
• Kristen Forburger, Multiple Species Conservation Program
• Karen Vera, Engineering
• Terre Lien, Landscaping
• Kristal Feilen, Planning
• Felipe Avila Zepeda, Transportation
RECON Environmental, Inc.
Environmental Analysis and Report Preparation
• Lee Sherwood, Principal
• Nick Larkin, Project Manager
• Gerry Scheid, Senior Biologist
• Harry Price, Archaeologist
• Jessica Fleming, Air Quality and Noise Analyst
• Frank McDermott, GIS/UAV Coordinator
• Stacey Higgins, Senior Production Specialist
• Jennifer Gutierrez, Production Specialist