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HomeMy WebLinkAbout2017-07-26 - SupplementalsDesign Review DRC2016=00726 IPT Arrow Route- Warehouse Planning Commission July 26, 2017 EI Project Time Line Project was submitted: August 24, 2016 Deemed complete: February 28, 2017 Tribal Consultation sent: March 2, 2017 Design/Technical Review Committee Meetings: April 18, 2017 Initial Study Distribution: June 19, 2017 Planning Commission. July 26, 2017 0 A m a m Aerial Photo 7 ` x l A %et W _u 7, r d ��, r ti, ► un I 0�0000 K WAW,- Design Review DRC2016=00726 • Proposes the development of a one 611,573 square foot concrete tilt up warehouse building on a parcel area of 26.63 acres. • Office areas totaling 10,000 square feet on the southwest and southeast corners of the building. • Two employee break areas • 248 parking spaces are provided throughout. • 110 Trailer parking spaces (110 dock doors) on the east and west sides of the property • Driveway access to the project site is provided off of Arrow Route and the new proposed public street. Design Review DRC2016=00726 • Proposed building will be built out of concrete tilt -up construction painted a palette of 6 different colors. • The primary building materials: concrete and sand blasted concrete, secondary materials will be glass panels (glazing), metal accents and wood accents. • Majority of the metal, glazing and wood accents are proposed at the office areas to emphasize the office area as the main entry. Each facade will also have panel reveal lines. • Elevations have a parapet that varies slightly in height to create dimension and visual interest. Additional dimension and visual interest are provided at office areas by parapet and wall planes that vary. �.0 HPA Job No. 16196A0 CONCEPTUAL COLORED ELEVATIONS 03,30.2C 17 Floor Plan o - �i�ii�'■fi � �i� o O O o o a M © M O f ° ° c c C G C o C 0 0 ■ NIYMIDII M> ■ A� PaM 28A� ■ Mh ■ Environmental Review • Psomas consulting prepared the Initial Study for the project. o Findings in the IS determined that with the imposition of mitigation measures related to biological resources, cultural resources, geology and soils, noise, and transportation/traffic, that there would be no substantial evidence that the project would have a significant effect on the environment. o Mitigated Negative Declaration was o A Mitigation Monitoring Program implementation of, and compliance project. • Comments- prepared. has also been prepared to ensure with, the mitigation measures for the o Department of Toxic Substances Contro o Native American Heritage Commission o San Bernardino County Public Works o Law Firm representing LiUna o Southern California Air Quality Management District Public Noticing • The item was advertised as a public hearing with a regular size legal advertisement in the Inland Valley Daily Bulletin newspaper, the property was posted, and notices were mailed to all property owners within a 660-foot radius of the project site. No public response was received. Recommendation • Staff recommends that the Planning Commission approve Design Review DRC2016-00726 through adoption of the Resolution of Approval with Conditions and adopt a Mitigated Negative Declaration for the project. DRC2017-00480 DR Revocation & DRC2017-00481 DR Modification Biane Family Properties Planning Commission July 26, 2017 ��e.,, EZ-�c3 Location Map DRC2007=00951 • On January 22, 2014 the Planning Commission approved DRC2007-00951: • Provided for a partial -build option for the western 6.51 acre portion of the site. • Permitted the demolition of non-contributing buildings to allow for development of a 122,304 square foot industrial warehouse building. • Non-contributing buildings include the bottling plant/warehouse, dry wine bottling room, cooperage shop, restroom, lunch shelter, and foreman's residence. • Two residential buildings, the wine maker's residence and the caretaker residence were determined to be Contributors and were conditioned to be relocated off -site with a plaque affixed to each residence identifying its original location and significance to the Winery. Impacts Assessment L S " 1 *T xva,n,nn:f. 3 mM1MDY'Mfl911,'Sc s Er fE CMEfARH RBIOLYT. 13 MMWILR(Ml uuRl2 11(III fT bMI:TWIY ROTJ�M1Arf [nYIRIRIrtgI 7. .,f.DYARI]XIEC 8 9RRRY ROOV 10 RP.GIRdDI 14 IAISLII AIf11iR ® SO�'COSTRIRUIpI . IORQIIf10CATmg1•S11! 3 OIURfRLnNYS(i RIl1.M!Y. T pRYY1Y'I BORIJ\'(i 11 AeDORARfI1S - IDRFpESR]pYFD Iq.ru -a-tea 4 asraicRY nwaloR 8 xTAT;.uRrrs RmnrTlE 12 DRC2007=00951 Modification • A request to modify the Conditions of Approval for DRC2007-00951 to permit the demolition of the two residences was proposed. The applicant is requesting demolition of the wine maker and caretaker residences because: • The applicant was unable to find appropriate lots for the relocation. • The structural condition of the houses would make moving them difficult. • Possible recipients of the structures (Northtown Housing Development Corporation and Habitat for Humanity) declined the houses. • DRC2016-00345 Design Review Modification was submitted. DRC2016-00345 DR Modification • On November 9, 2016, the Planning Commission approved Design Review Modification DRC2016- 00345 to delete two applicable conditions from PC Resolution No. 14-08. Those conditions state: • Planning Department Condition No. 7: The costs to relocate the two contributing residences shall be borne by the owner. The owner shall notify the City in writing once the relocation plan has been finalized. • Planning Department Condition No. 8: Prepare and affix identifying plaques to the relocated residences. This would consist of at a minimum an 8-inch by 10-inch durable plaque for both of the relocated residences to identify their original locations and historical association with the Biane Winery. The plaques would be affixed to the residences in a publicly viewable location. D RC2017=00480 DR Revocation • Following PC approval of DRC2016-00345, staff determined that the two conditions were related to a Mitigation Measure in the project's IS and MND and that deleting the conditions required an Addendum to the MND. • A description of the Addendum should have been included in the project description, advertising, and public hearing notifications so that the public was fully aware of what was proposed. • DRC2016-00345 was approved in error and should be revoked. DRC2017=00481 DR Modification • LSA prepared a memorandum that further reviews the Biane Winery Impacts Assessment regarding the wine maker's and caretaker residence. • The two residences derive their significance solely from their association with the winery. • The residences are not individually significant and are typical examples of small, wood -framed houses. If they are relocated off -site, they would be out of context, and their significance as contributing resources would be lost. • Without the wine maker's and the caretaker residences, the Winery would retain its National Register eligibility, and therefore, the demolition of these structures would not be a significant impact to the historic property. • Both buildings should be documented similar to the Historic Building Survey (NABS) III. DRC2017-00481 DR Modification • The applicant is requesting deletion of the applicable Conditions from Planning Commission Resolution No. 14-08, which state: • Planning Department Condition No. 7: The costs to relocate the two contributing residences shall be borne by the owner. The owner shall notify the City in writing once the relocation plan has been finalized. • Planning Department Condition No. 8: Prepare and affix identifying plaques to the relocated residences. This would consist of at a minimum an 8-inch by 10-inch durable plaque for both of the relocated residences to identify their original locations and historical association with the Biane Winery. The plaques would be affixed to the residences in a publicly viewable location. DRC2017-00481 DR Modification • The applicant has requested deleting the applicable Mitigation Measures from Planning Commission Resolution No. 14-08, which state: • Cultural Resources Mitigation Measure No. 1: Prepare and affix identifying plaques to the relocated residences. This would consist of at a minimum an 8-inch by 10-inch durable plaque for both of the relocated residences to identify their original locations and historical association with the Biane Winery. The plaques would be affixed to the residences in a publicly viewable location. This would preserve a historical tie between the residences and the winery, mitigating the loss of their on - site historical association. DRC2017=00481 Conditions of Approval • Delete in their entirety Planning Department Conditions of Approval Nos. 7 & 8 and Cultural Resources Mitigation Measure No. 1 from PC Resolution 14-08. • Following appropriate HABS Level III documentation, the wine maker's residence and the caretaker residence may be demolished with other previously determined non-contributing structures. Environmental Review DRC2017=00480 • Pursuant to the California Environmental Quality Act (CEQA) and the City's local CEQA Guidelines, the City adopted a Mitigated Negative Declaration (MND) on January 22, 2014, in connection with the City's approval of Development Review DRC2007-00951. Pursuant to CEQA Guidelines Section 15162, no subsequent or supplemental EIR or Negative Declaration is required in connection with subsequent discretionary approvals of the same project. Environmental Review DRC2017-00481 • Pursuant to CEQA Guidelines Section 15162(a), the City prepared an Addendum to a previously adopted MND because only minor technical changes or additions are necessary and none of the conditions that require the preparation of a subsequent MND have occurred. There are no new significant or severe effects; there are no substantial changes in circumstance with respect to the project; and, there is no new information of substantial importance that was not known or could have reasonably been known at the time the previous MND was adopted. An addendum to the previously approved MND is appropriate in this case because a minor technical change to the project description in the original MND would be sufficient and there is no evidence that any of the conditions that would require a subsequent EIR or negative declaration are present. Recommendation • Staff recommends the Planning Commission take the following actions: • Adopt the Resolution Modification Revocation revoking approval of DRC2016-00345. approving Design Review DRC2017-004801 thereby Design Review Modification • Adopt the Resolution with Conditions approving Design Review Modification DRC2017-00481. Schrader, Lois From: Cavazos, Nikki Sent: Thursday, July 27, 2017 11:49 AM To: Schrader, Lois Subject: FW: Responses to SCAQMD Comments - IPT Arrow Route Project Attachments: Response to SCAQMD 072617.pdf Here are the comments Lois! Thank you. From: Tina Andersen[mailto:tina.andersen@psomas.com] Sent: Wednesday, July 26, 2017 11:16 AM To: Cavazos, Nikki <Nikki.Cavazos@cityofrc.us>; Smith, Michael <Michael.Smith@cityofrc.us> Cc: Haseeb Qureshi <hqureshi@urbanxroads.com>; Russell Pierce <rpierce@rdpdev.com>; Jennifer Marks <jen n ifer.marks@ psomas.com> Subject: Responses to SCAQMD Comments - IPT Arrow Route Project Hi Nikki — attached are the responses prepared by Urban Crossroads (the air quality technical consultant). The responses correspond to the attachment to the SCAQMD letter. I understand that although not required, you'll be sending the responses to SCAQMD with the intent of hopefully getting confirmation that they concur with the responses. It is my understanding from Urban Crossroads, based on their experience on other projects, that this is not a likely outcome. In most instances, they will agree to disagree on approach issues. Per Russ' previous email, he would like the opportunity to present the project to the Planning Commission as scheduled tonight for their consideration. If the Planning Commission requires further explanation of the SCAQMD issues, Urban Crossroads will be at the hearing tonight and can certainly address the technical/methodology issues that are being raised. Thanks, Tina Andersen P S O M A S I Balancing the Natural and Built Environment Vice President Environmental Planning & Resource Management Direct 714.481 8028 1 www.Psomas.com ©South Coast Air Quality Management District 21865 Copley Drive, Diamond Bar, CA 91765-4178 • (909) 396-2000 • www.agmd.gov SENT VIA USPS AND E-MAIL: donald.granger(&cityofrc.us Donald Granger, Senior Planner City of Rancho Cucamonga — Planning Department P.O. Box 807 Rancho Cucamonga, CA 91729 Mideated Negative Declaration (MND) for the Proposed IPT Arrow Route DC Proiect (DRC2016-00726) July 25, 2017 The South Coast Air Quality Management District (SCAQMD) staff appreciates the opportunity to comment on the above -mentioned document. The following comments are meant as guidance for the Lead Agency and should be incorporated into the Final MND. Proiect Description The Lead Agency proposes to construct and operate a 611,573-square-foot, high -cube warehouse with unknown occupants on an approximately 26.63-acre site ("proposed project"). The proposed project is bounded by commercial uses to the north, east, south, and west. Air Quality and Health Risk Assessment (HRA) Analyses In the Air Quality Section, the Lead Agency quantified the proposed project's construction and operational emissions and compared them to SCAQMD's regional and localized air quality CEQA significance thresholds. The air quality analysis was based on approximately 824 total vehicle trips, including 212 daily truck trips'. The Lead Agency found that regional and localized construction and operational emissions would be less than significant. Additionally, the Lead Agency performed a HRA and found that the Maximum Exposed Individual Resident cancer risk would be 0.23 in one million, which is below SCAQMD's CEQA significance threshold of 10 in one million for cancer risk'. SCAQMD staff has concerns about the HRA analysis in the MND. The analysis utilized assumptions which have likely led to an under -estimation of the proposed project's health risk impacts. Details are included in the attachment. After revising the HRA analysis, should the Lead Agency find that the proposed project's health impacts would exceed SCAQMD's CEQA significance thresholds, mitigation measures are required pursuant to the CEQA Guideline Section 15074(b). SCAQMD staff has included a list of mitigation measures in the attachment to assist the Lead Agency in identifying feasible mitigation measures which have the potential to substantially lessen such significant effects (Public Resources Code Section 21002). Pursuant to the CEQA Guidelines Section 15074, prior to approving the proposed project, the Lead Agency shall consider the MND for adoption together with any comments received during the public review process. Please provide SCAQMD staff with written responses to all comments contained herein prior to the adoption of the Final MND. IPT Arrow Route DC Project. Initial Study and Witigated Negative Declaration —Table 14 Project Trip Generation Summary. ' Aid Page 3.20 Donald Granger July 25, 2017 SCAQMD staff is available to work with the Lead Agency to address the issues raised in the letter and any other air quality and HRA questions that may arise. Please contact Jack Cheng, Air Quality Specialist — CEQA IGR Section, at (909) 396-2448, if you have any questions regarding these comments. Sincerely, .CCU sem Lijin Sun, J.D. Program Supervisor, CEQA IGR Planning, Rule Development & Area Sources Attachment LS:JC SBC 170621-02 Control Number Donald Granger ATTACHMENT Daily Truck Trip Rate July 25, 2017 I. In the air quality analysis, the Lead Agency used the Institute of Transportation Engineers Trip Generation Manual, 9" Edition, 2012 (ITE Manual) 1.68 overall trip generation rate (for cars and trucks totaling approximately 824 daily vehicles) , and did not use the 0.64 (38.1%) daily truck trip rate from this same reference. Rather, the Trip Generation Rates used a passenger vehicle trip rate of 1.337 vehicles per day and a daily truck trip rate of 0.343 daily truck trip rate (1.68 total daily trip rate minus 1.337 passenger vehicle trip rate or 20.43% daily truck trip rate). Additionally, truck vehicle fleet mixture percentages from the City of Fontana Truck Trip Generation Study (Fontana Study) was used to estimate project air quality operational impacts in the CaIEEMod modeling. By using the 0.343 daily truck trip rate, trucks are estimated at 212 daily truck trips in the MND instead of approximately 395 daily truck trips using the ITE 0.64 daily truck trip rate. Therefore, absent from a specific traffic study of known tenants, the Final MND should be consistent using the associated ITE truck trip rate to estimate daily truck trips so that the proposed project's truck trips and associated emissions and health impacts are not underestimated. 2. The total vehicle mixture in Appendix 3.1 — CaIEEMod Emissions Model Output was not consistent with the traffic analysis'. In Appendix 3.1 — CalEEMod Emissions Model Output — Section 4.3 Trip Type Information, heavy duty trucks accounted for 12% of the total trips while the traffic study appropriated 20.43% of total trips to heavy duty trucks. SCAQMD staff recommends using the ITE truck trip rate of 0.64 trips/tsf (38.1 % of total vehicle trips) to estimate daily truck trips so that the proposed project's truck trips, emissions, and health impacts are not underestimated. 3. Additionally, the heavy duty fleet mixture in Appendix 3.1 was not consistent with the heavy duty truck fleet mixture in the traffic study and the HRA', which may have underestimated the proposed project's operational emissions. Appendix 3.1 included a heavy duty truck fleet mixture of LHD = 54%, MHD = 14%, HHD = 32%, while the traffic study and HRA used a heavy duty truck fleet mixture of LHD= 17%, MHD = 23%, HHD = 60%. Therefore, SCAQMD staff recommends that the Lead Agency correct the inconsistencies and use the ITE 0.64 daily truck trip rate and a heavy truck fleet mixture of LHD2 = 0.0645, MHD = 0.0865, HHD = 0.2300 consistently throughout the Final MND and technical appendices. Health Risk Assessment (HRA) Analysis 4. Based on a review of the HRA analysis, SCAQMD found that the HRA analysis utilized the 2015 revised OEHHA guidelines to estimate the health risks to sensitive receptors in the proposed project's vicinity and that the AERMOD dispersion model was used to estimate diesel particulate matter (DPM) concentrations. SCAQMD staff recommends that the Lead Agency revise the HRA analysis based on the following comments. a. The 2015 revised OEHHA guidelines acknowledge that children are more susceptible to the exposure to air toxics and have revised the way cancer risks are estimated to take this into account. Since the emissions from the project -generated trucks get cleaner with time due to existing regulations, it would not be appropriate to average out the emissions over the 70-year exposure duration since this would underestimate the health risks to children ' Ibid. Table 14Project Trip Generation Summary. 4 Ibid. Modeling File —"10360-02 HRA Truck Emissions Average.xlsx." Donald Granger 4 July 25, 2017 who would be exposed to higher DPM concentrations during the early years of project operation. Therefore, SCAQMD staff recommends that the DPM emissions for each year of operation be applied to each of the corresponding age bins (i.e. emissions from Year I of project operation should be used to estimate cancer risks to the third trimester to 0 year age bin; Year 1 and 2 of project operation should be used to estimate the cancer risks to the 0 to 2 years age bins; and so on). b. The HRA analysis involved the use of a discrete receptor placed over existing residential structures. Receptor locations should be placed at the boundaries of the residential property and not the residential structures. Placing receptors on the residential structure underestimates cancer risks to the residents. SCAQMD staff recommends that the Lead Agency revise the HRA and use a receptor grid that starts at the property boundaries to ensure potential maximum concentrations are identified. Additional Mitieation Measures for Operational Air Ouality Impacts (Mobile Sources) 5. CEQA requires that all feasible mitigation measures that go beyond what is required by law be utilized to minimize or eliminate any significant impacts. In the event that the Lead Agency, after revising the HRA analysis based on the comments provided above, finds that the proposed project would result in significant health risk impacts, SCAQMD staff recommends incorporating the following on -road mobile -source truck related mitigation measures in the Final MD. For more information on potential mitigation measures as guidance to the Lead Agency, please visit SCAQMD's CEQA Air Quality Handbook websites. • Require the use of 2010 and newer haul trucks (e.g., material delivery trucks and soil import/export). In the event that that 2010 model year or newer diesel haul trucks cannot be obtained, provide documentation as information becomes available and use trucks that meet EPA 2007 model year NOx emissions requirements`, at a minimum. Additionally, consider other measures such as incentives, phase -in schedules for clean trucks, etc. • Have truck routes clearly marked with trailblazer signs, so that trucks will not enter residential areas. • Limit activities to the amounts analyzed in the Final MD. • Promote clean truck incentive programs (see the discussion above regarding Cleaner Operating Truck Incentive Programs). • Provide electric vehicle (EV) Charging Stations (see the discussion below regarding EV charging stations). • Trucks that can operate at least partially on electricity have the ability to substantially reduce the significant NOx impacts from this project. Further, trucks that run at least partially on electricity are projected to become available during the life of the project as discussed in the 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy'. It is important to make this electrical infrastructure available when the project is built so that it is ready when this technology becomes commercially available. The cost of installing electrical charging equipment onsite is significantly cheaper if completed when the project is built compared to retrofitting an existing building. Therefore, SCAQMD staff recommends that the Lead Agency require the proposed project include the appropriate infrastructure to facilitate sufficient electric charging for trucks to plug-in. Similar to the City of Los Angeles requirements for all new projects, SCAQMD staff recommends that the Lead Agency require 'South Coast Air Quality Management District. hno./lwvvtv.aumJ. eodhome'rceulaunns/� ga/air-uuahN-anah vs-handlwok. Based on a review of the California Air Resources Board's diesel truck regulations, 2010 model year diesel haul trucks should have already been available and can be obtained in a successful manner for the project construction California Air Resources Board. March 2016. Available at. ht[n://www truckload ore/tealfiles/ccLibra Files/Fitename/(X)0000003422/Califiviva-Clean-Tmck-and-fruiter-Update Dili (See slide k23). Donald Granger July 25, 2017 at least 5% of all vehicle parking spaces (including for trucks) include EV charging stations'. Further, electrical hookups should be provided at the onsite truck stop for truckers to plug in any onboard auxiliary equipment. At a minimum, electrical panels should appropriately sized to allow for future expanded use. " City of Los Angeles March 30.2017. Accessed at: ham.//IadbsOa/LADBSWeb/LADBS V rmc/Publications/LAGre•nBuildineCodd)rd i;eod(. Responses to South Coast Air Quality Management District Comment Letter (July 25, 2017) IPT Arrow Route DC Project (DRC2016-00726) The project's vehicle fleet mix that is included in the air quality modeling has been derived from the project's Traffic Impact Study, which is based on the Institute of Transportation Engineer's (ITE) Trip Generation Manual (9th edition) and the City of Fontana's Truck Trip Generation Study. In fact, a review of the ITE's Trip Generation Manual (9th Edition) Volume 1: User's Guide and Handbook includes a direct reference to the City of Fontana Truck Trip Generation Study, which was used in the project's traffic study to derive the 20.43 percent truck trips utilized in the air quality modeling. The ITE Trip Generation Manual (Table A.4) identifies a rate of 0.38 trips per 1,000 square feet (sq ft) for Light and Heavy Warehouse Use; this value is generally consistent with the City of Fontana's rate for 0.343 trips per 1,000 sq ft (LU 150) that is used in the project's traffic study and subsequently the air quality modeling. Furthermore, as discussed in the context of the traffic study, utilized trip generation rates accurately reflect anticipated operational characteristics that are likely to occur due to the size of the building and number of dock doors. Based on the current site plan, 110 dock doors are proposed. As such, if every dock door were to generate one truck per day (2 trips), this would result in approximately 220 truck trips per day which is in line with the trip generation rates used in the traffic study. Alternatively, if the SCAQMD's recommendation of 0.64 truck trips per thousand square feet were used, the truck trips would be overstated, i.e. each dock door would generate approximately two trucks per day (4 trips). As such, the Air Quality Impact Analysis (AQIA) is consistent with the Project's traffic study, which used the City of Fontana's Truck Trip Generation Study. This Study was an effort to accurately disclose project impacts by utilizing trip generation rates tailored for the project region and supported by substantial evidence. It was based upon actual data collected at warehouses similar in size and function and location to the Project. 2. It appears as though the commenter is incorrectly reviewing the construction CalEEMod run which is not where the emissions for operations were derived for the Project. As shown in the AQIA, a separate model run was conducted for (1) construction, (2) passenger vehicles, and (3) trucks. The respective CalEEMod headers are correctly labeled as such. Please see the attached CaIEEMod output file that was also included in the Initial Study/Mitigated Negative Declaration (IS/MND), specifically Page 11 of 15 of the CaIEEMod truck model output, Section 4.3 (see highlights), which clearly shows the AQIA correctly utilized a fleet mixture of LHD = 17%, MHD = 23%, and HHD = 60%, consistent with the traffic study and Health Risk Assessment (HRA). 3. It appears as though the commenter is incorrectly reviewing the construction CaIEEMod run which is not where the emissions for operations were derived for the Project. As shown in the AQIA, a separate model run was conducted for (1) construction, (2) passenger vehicles, and (3) trucks. The respective CalEEMod headers are correctly labeled as such. Please see the attached CalEEMod output file that was also included in the IS/MND, specifically Page 11 of 15 of the CaIEEMod truck model output, Section 4.3 (see highlights), which clearly shows the AQIA correctly utilized a fleet mixture of LHD = 17%, MHD = 23%, and HHD = 60%, consistent with the traffic study and HRA. 4. See below a. Urban Crossroads reviewed the 2015 Office of Environmental Health Hazard Assessment (OEHHA) guidance' to determine applicability of the use of early life exposure adjustments to identified carcinogens. For risk assessments conducted under the auspices of The Air Toxics "Hot Spots" Information and Assessment Act of 1987 (AB2588), OEHHA applies specific adjustment factors to all carcinogens regardless of purported mechanism of action. However, the 2015 OEHHA guidance relied upon U.S. EPA guidance relating to the use of early life exposure adjustment factors (Supplemental Guidance for Assessing Susceptibility from Early -Life Exposure to Carcinogens, EPA/630/R-003F) whereby adjustment factors are only considered when carcinogens act "through the mutagenic mode of action." A mutagen is a physical or chemical agent that changes genetic material, such as DNA, increasing the frequency of mutations to produce carcinogenic effects. The use of adjustment factors is recommended to account for the susceptibility of producing adverse health effects during early life stages from exposure to these mutagenic compounds. None of the carcinogens considered in the study for this Project elicit a mutagenic mode of action and, therefore, the use of age specific adjustment factors is not warranted. The study correctly used a lifetime exposure adjustment factor of 1.0. By way of background, the Air Toxics "Hot Spots" Information and Assessment Act requires stationary sources (facilities) to report the type and quantity of substances they routinely release into the air. The regulation requires that toxic air emissions from facilities be quantified and compiled into an inventory according to criteria and guidelines developed by CARB, that each facility be prioritized to determine whether a risk assessment is conducted, that risk assessments be conducted according to methods developed by OEHHA and that the public be notified of significant risks. Please note that OEHHA clarifies its risk assessment's applicability by stating that "roadways are not part of the Hot Spots program because the program only addresses stationary sources." It should be noted. that neither the South Coast Air Quality Management District (SCAQMD) nor any other air agency in the Southern California region has adopted guidance on the applicability/use of Age Sensitivity Factors (ASFs) under CEQA. At the June 5, 2015 SCAQMD Board Meeting, the SCAQMD adopted the 2015 OEHHA guidelines for use in their permitting process. Notwithstanding, the SCAQMD acknowledged in their response to comments received on the revised permitting rules2 that: "The Proposed Amended Rules are separate from the CEQA significance thresholds. The SCAQMD staff is currently evaluating how to implement the Revised OEHHA Guidelines under CEQA. The SCAQMD staff will evaluate a 'http://oehha.ca.gov/air/hot spots/hotspots2015.htm1 "See Response to Comment #13, Page A-7 and A-8 of the June 5, 2015 board meeting Agenda No. 28. http://www.aq md.g ov/dots/d efault-source/Agendas/Governing-Board/2015/2015-jun 1-028 variety of options on how to evaluate health risks under the Revised OEHHA Guidelines under CEQA. The SCAQMD staff will conduct public workshops to gather input before bringing recommendations to the Governing Board. In the interim, staff will continue to use the previous guidelines for CEQA determinations." Further at a June 18, 2015 Association of Environmental Professionals Meeting, the SCAQMD staff (Ms. Jillian Wong, Ph.D.) stated that any new guidance regarding ASFs under CEQA for projects where SCAQMD is not the lead agency, will not be adopted until there is completion of a public process. At this time, no such process has commenced and no formal guidance has been adopted. Lastly, as previously noted the SCAQMD is in the process of evaluating how the Revised OEHHA Guidelines will be applied to CEQA projects under their jurisdiction and currently recommends continued use of previous guidelines for CEQA determinations. In the rulemaking activity for the 2015 OEHHA guidelines as they apply to permitting projects, the SCAQMD also recommends use of the previous version of the OEHHA guidelines for spray booths and retail gasoline stations3. Similarly, the San Joaquin Valley Air Pollution Control District (SJVAPCD) has actually adopted a new significance threshold in conjunction with the 2015 OEHHA guidelines4. More specifically, in recognition of the impact that the 2015 OEHHA guidelines would have on CEQA, SJVAPCD has actually adopted a new maximally exposed individual risk numeric significance threshold of 20 in one million which is two times the prior SJVAPCD threshold of 10 in one million5. It should be noted that the SJVAPCD's adoption of the 2015 OEHHA guidelines for CEQA was part of a public process. Given that there is no available guidance that has been adopted by SCAQMD for CEQA purposes and the fact that the Project does not emit any pollutants that elicit a primary mutagenic mode of action, the use of the 2015 OEHHA guidelines would not be appropriate and therefore was not undertaken for this analysis. b. The Project's HRA includes individual discreet receptors placed geospatially at nearby existing residences. Receptors were placed where an individual can reasonably be expected to remain for a 24-hour duration and where long-term exposure could occur. There is no basis for placing receptors at the property line instead of the structure since the risk modeling is based on constant exposure for 24-hours per day, 350 days per year, for a period of 70 years which is already extremely conservative. As such, it is unreasonable to assume that this long-term constant exposure would occur at the property line as it would reasonably occur at the physical residential, worker, school structure as modeled in the HRA. The commenter provides no substantial evidence as to why it is appropriate to place receptors at property lines. It is clear that people spend the vast majority of their time inside the applicable structure, not at the property line. 3 See Page 3 of the June 5, 2015 board meeting Agenda No. 28. http://www.agmd.gov/docs/default-source/Agendas/Governing- Board/2015/2015-junt-028 4 http://www.va[leyair.org/busind/pto/staff-report-5-28-15.pdf 5 http://www.valleyalr.org/transportation/0714-GAMAQI-TACs-Thresholds-of-Significance.pdf 5. As identified in the ISIMND, the Project would not result in a'significant impact, as such, no mitigation is required. CaIEEMod Version: CalEEMOd.2013.2.2 Page 1 of 15 Date: 8/16/2016 10:51 AM Arrow Route Operation Trucks San Bernardino -South Coast County, Summer 1.0 Project Characteristics 1.1 Land Usage L`andUses-"_,. . '' - "' Si e , -- Metric ' - :Lot Acreage FloorSurlaoe Area " 'Population Unrefdgerated Warehouse -No Rail 616.56 1000sgft 21.35 ) 616,660.00 I 0 ______________________________• .______. ___________ _______________ ___ __ Parking Lot 610.00 Space 5.49 244.000.00 0 1.2 Other Project Characteristics Urbanization Urban Wind Speed (Ms) Climate Zone 10 Utility Company Southern California Edison CO2 Intensity 497.64 CH4Intensity (IbIMWhr) (IbIMWhr) 1.3 User Entered Comments & Non -Default Data 2.2 Precipitation Freq (Days) 32 Operational Year 2018 0.029 N20 Intensity 0.006 (IbIMWhr) CaIEEMod Version: CalEEMOd.2013.2.2 Page 2 of 15 Date: 8/16/2016 10:51 AM Project Characteristics - CPUC GHG Calculator version 3c, worksheet tab "CO2 Allocations," cells AH/AQ 35-44. Land Use - Based on site plan dated June 27, 2016 Construction Phase - Operation only Off -road Equipment - Operation only Trips and VMT - Operation only On -road Fugitive Dust - Operation only Architectural Coating - Operation only Vehicle Trips - Based on Traffic Study and ITE Trip Generation Manual, 9th Edition; Weighted Trip Length based on SCAG recommendations Vechicle Emission Factors - Trucks only Vechicle Emission Factors - Trucks only Vechicle Emission Factors - Trucks only Consumer Products - Area Coating - Based on consultation with the client Energy Use - Title-24 Electricity Energy Intensity and Title-24 Natural Gas Energy Intensity were adjusted by 21.8% and 16.8% respectively, to reflect 2013 Title 24 requirements. Source: Impact Analysis California's 2013 Building Energy Efficiency Standards (CEC 2013) Area Mitigation - Based on Rule 1113 Operational Off -Road Equipment -. 'Table -Name: - Columrf Name - Default Value - New Value ' tblArchilecturalCoating ConstArea_Nonresidential_Eterior 311.940.00 1 0.00 ______________________9_._________________________________r__________________________+__.__________________.____ tblArchitecturalCoatin Constkea_Nonresidential_interior 935,820.00 i 0.00 ___________________9_._______________________.____._______r_______________________--____. tblAreaCoatin Area —Nonresidential —interior _ 935820 1 -------------------------- 182384 ________________9............y----------------------------- .;------------------------------ -------------------------- tblAreaMiti ation • UseLowVOCPaintNonresidentialEuteriorV• 250 100 alue _____________________________i_______.___________-------_-- tblAreaMitigation -___________________-..-__-___ • UseLowVOCPaintNonresidentiallntedorV • 250 -------------------------- 50 alue ------- _______________; ------------- ________________4_________________ tblConstrudionPhase NurnDays 35.00 f 100 _____________________________ �___-.-..------._----_-_______r__________________—__________+__________-_-___.-_.-_---- tblEnergyUse T24E 0.45 0.35 ----------------------------- ;----------------------------- ;,.------------------------------ thiEnergyUse T24NG 2.11 i 1.76 tblLandUse LotAcreage 14.15 21.35 CalEEMod Version: CalEEMOd.2013.2.2 Page 3 of 15 Date: 8/16/2016 10:51 AM tblOffRoadEquipment m OffRoadEquipmentUnitAmount 1.00 0.00 _______________________________________________4__....__.______...._..________-------------------------- tblOnRoadDust HaulingPercenlPave 100.00 i ' 0.00 _________ ______________ tblOnRoa____dDusl ----------------------------- VendorPercenWave 4.----------------------------- �........................... 100.00 i 0.00 tblOnRoadDust WorkerPercentPave 100.00 i 0.00 tblProjectCharacteristics CO21ntensityFactor 630.89 497.64 ------ iIProjectCharacteristics ----- ------------------- - --------V_-_-_----_-- Operaflonarfea ------------------------------- 014 ---_--___2018_---------- -------------------'--- tblTri--'---psAndVMT +...__----------P------------- WorkerTd Number -----------------------------f 72.00 1 -------------------------- 0.00 _____________________________ tblVehicleEF ----------------------------- HHD ----------------------------- +______..___________.__..._ 0.04 i 0.60 ............................. tblVehicleEF 4...___..________.___.________4._________________ HHD 0.04 - 1 0.60 .............. _--------------- tblVehicleEF _______________.__...________4._____________________________+...__....._.._._.._.....__ HHD 0.04 i 0.60 ----------------------------- tblVehicleEF __----------------------------- LDA ------------------------------ 0.47 + 0.00 _____________________________ tblVehicleEF 4----------------------------- LDA 4------------------------------- 0.47 i ..___....__..__.......__-- 0.00 _____________________________ tblVehicleEF _______________________------ LDA 0.47 + 0.00 ----------------------------- tblVehicleEF ----------------------------- LDT7 r------------------------------ 0.07 i 0.00 _____________________________ tblVehicleEF ------------------------------ LDT1 ._________________ 0.07 i 0.00 _____________________________ tblVehicleEF ------------------------------ LDT1 ._____________________________t._._._.__.._.___._..__..._ 0.07 0.00 _____________________________ tblVehicleEF ----------------------------------------------- LDT2 i 0.17--_---------i----_---___ 0.00 -------------- _____________________________ tblVehicleEF 4___________..___.___._...___. LDT2 ._____________________________ 0.17 i .......................... 0.00 ............................. tblVehicleEF ;------------------------------ LDT2 ._____________________________.f._.___.___________________ 0.17 1 0.00 tblVehicleEF LHD1 0.06 i 0.17 ............................. tblVehicleEF ------------------------------ LHD1 0.06 i 0.17 _____________________________ tblVehicleEF _____________________________4 LHD1 ----------------------------- 0.06 + 0.17 ---------- ----_-----tblVehicleEF ---------------_---_--__------------9.0500e-003 LHD2 0.00 ............................. tblVehicleEF ............................. LHD2 ------------------------------ 9.0500e-003 ____________________...__. 0.00 tblVehicleEF LHD2 9.0500e-003 i 0.00 ............................. tblVehicleEF ------------------------------ MY ------------------------------ +__.__...__...._ 4.9650e-003 1 0.00 _____________________________ tblVehicleEF 4...___________________._.._.. MY -------------------------- 4.9650e-003 1 0.00 tblVehicleEF MY 4.9650e-003 0.00 CaIEEMod Version: CaIEEMod.2O13.2.2 Page 4 of 15 Date: 8/16/2016 10:51 AM tblVehiGeEF MDV 0.16 0.00 _____________________________ tblVehicleEF ----------------------------- MDV �---------------------------- --i__.........----------- 0.00 _____________________________ tblVehicleEF _____________________________ ; MDV r_____________________________ ; 0.16 + 0.00 _____________________________;___________-...._____________ tblVehicleEF ; MH r___________________ ; 2.9440e-003 - 1 0.00 ............................. lbVehicleEF .............................. MH 2.9440e-003 1 0.00 ---------- tblVehicleEF---------- ------------------------ ---- ----------2.9440e-003 0.00 ____________________________ tblVehicleEF ;______.._______.._....____-__ ; MHD r_________________ i ; 0.02 -1 0.23 _____________________________ tblVehiGeEF ---------------------- _------- MHD _ ----------__0.02 ____________i_____----. 0.23---------- ____________________________-______---..-._____________---Y_____________________________f________________.__-.--.-. tblVehicleEF MHD 0.02 i 0.23 ----------------------------- tblVehiGeEF ;------------------------------ ; OBUS ___________________ 1.1190e-003 _t 0.00 -------------------- tblVehicleEF ------------------------------_-___- OBUS 1.1190e-003 i 0,00 _____________________________ tblVehicieEF ----------------------------- OBUS ------------------------------ 1.1190e-003 i -------------------------- 0.00 _____________________________ tblVehicleEF ________________._---------- ; SBUS 4-___________________ - 7.00OOe-004 + 0.00 _____________________________ tblVehiGeEF ----------------------------- ; SBUS 7.00OOe-004 -i 0.00 ----------tblVehicleEF---------- ------------ SBUS------------T----_----_7.00OOe-004 0.00 ----------------------------- tblVehicleEF ;----------------------------- UBUS i r___________________ __________.f-------------------------- 1.3370e-003 i 0.00 tblVehiGeEF ; UBUS __________f T 1.3370e-003 1 __________________________ 0.00 _____________________________ tblVehicleEF ............._-...__._.____.__- UBUS ._____________________________f 1.3370e-003 -------------------------- 0.00 tblVehicleTri s ; CC_TL ; 8.40 -i 0.00 ____________P_-_____-_. tblVehicleTri s ._.......__.___________---.;._____________________________+______________----_-___-__ CNW TL 6.90 0.00 ------------------P---------- tbNehicleTris ----------------------------- CNW TTP --------"� --------------------------------------------- 41.00 i 0.00 ----------------------------- tblVehicleTri s __------------------------------ ; CW TL ____________________ ; 16.60 _t 22.40 --------------------------- tb[VehicleTdps ---------------------- CW TTP --------------r 59.00 --- 10 ............................. tblVehicleTri s ^••------------------------------ DV_TP -------------------------------i-------------------------- 5.00 i 0.00 ------------------P----------- tblVehicleTri s ------------------------------------------------------------F-----------------------.-- PB_TP 3.00 i 0.00 .............................. tblVehicleTrips ...................----------- PR_TP .;,------------------------------ 92.00 i 100.00 tblVehicleTri s ST TR 2.59 0.34 __________ __________________ tblVehicleTrips ;____..______--. Su-TR ________ 2.59 � __._______ _________ 0.34 CaIEEMod Version: CalEEMOd.2013.2.2 Page 5 of 15 Date: 8/16/2016 10:51 AM tblVehicleTrips WD_TR 2.59 0.34 2.0 Emissions Summary 2.1 Overall Construction (Maximum Daily Emission) Unmitigated Construction ROG - -NOx CO, S02. Fdgiiive Exhaust": -PM10- Fugitive Exhaust PM2.5 Bio-0O2 NBid-0O2 Total CO2 C74 N20 CO2e _ -PM10 PM10 _Total PM2.5 PM2.5 `Total - Year -' .. lb/day ^- - lb/day 2019 0.0000 0.0000 0.0000 0.0000 0.0000 r 0.0000 0.0000 0.0000 0.0000 0.0000 i 0.0000 0.0000 • 0.0000 • 0.0000 0.0000 0.0000 i • i 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 - ROG' NOx- CO 'fugitive Exhaust PM10 fugdive Exhaust PM2.5 Bio- CO2-NBio- CO2 Total CO2' CNA+ N20 CO2e [SO2 " _ PM10 PM10' 10 _ 'Total PM2.5 - PM; Total Year --- , - . Iblday .: - - lb/day 2019 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0009 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 ± i • i 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 CaIEEMod Version: CaIEEMOd.2013.2.2 Page 6 of 15 Date: 8/16/2016 10:51 AM `- ROG +,'-,NOx CO, '.S02- +'Fugitive' Exhaust.., `,PM10. :.Fugitive :.'Exhaust; �. PM2.5 � SId-0O241 NSID-CO2' Total CO2 CNQ-` N20 CO2e J PMSO, ; PM10=" Total : --PM2.6. PMZS Total - y.� j , - j Percent 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 Reduction I CaIEEMod Version: CaIEEMOd.2013.2.2 Page 7 of 15 Date: 8/16/2016 10:51 AM 2.2 Overall Operational Unmitigated Operational ROGI^G;-NOR.- CO. ;-,;S02" ;Fugtive' Exhaust":. ,"PM70; Fugitive.. Exhaust.:PM2:5 Bio- CO2; NBio=CO2Tota1.0O2 ..CH4,-` N20 ''CO2e r.',. - PM70.=PM70 = 'Total . PM2.5 PM25 Total ;Category �' N�. „%1�.� :.,�Ib/daylday,-r . Ib - ,�'c ., Area •• 18.6205 1.1900e- • 0.1270 • 1.0000e- 4.6000e- 4.6000e- 4.6000e- 4.6000s- + 0.2684 0.2684 • 7A000e- 0.2839 003 005 004 004 004 004 j 004 .., , Energy .• • 0.0326 0.2964 r______.r______ 0.2490 1.7800e- 0.0225 0.0225 0.0225 0.0225 ! 355.7268 • 355.7268 • 6.8200e- • 6.5200e- • 357.8917 003 j 003 003 Mobile -- -T Y 2.8437 . 41.3037 r 29.9363 • 0.1368 4.1010 0.7253 4.6263 1.1427 0.6672 1.8099 A,• r - 4- t 73,334.11 • 13,334.11 • 0.1067 T • 13,336.35 ! 15 15 21 ! • ' , Total 21.4969 41.6013 30.3123 0.1386 4.1010 0.7483 4.8493 1.1427 0.6902 1.8329 13,690.10 13,690.10 0.1143 6.5200e- 13,694.52 67 67 003 77 Mitigated Operational •'�.., ROG'f x " CO `., ,:'-S02 ` : Fugitive ` 'ExhausV .� PM10 iFugitive .Exhaust' ! PM2.5 BIb-.0O2-. N&e=.0O2 Total CO2'. "'CH4 V,''= -'N20 CO2e d;rNox--, .,•_ 'PM10 ._. PM10." .Total PM2:5', "PM2.5 -Total .,..Category - _-."';; .. .:. . - .-ib/daylb/clay Area 17.5631 1.1900e- 0.1270 . 1.0000e- . 4.6000e- • 4.6000, • • 4.6000e- 4.6000, + 02684 . 0.2684 7.4000e- • 0.2839 003 005 004 004 004 004 004 Energy 0.0326 0.2964 . 0.2490 . 1.7800e- 0.0225 • 0.0225 - - 0.0225 • 0.0225 ! 355.7268 . 355.7268 6.8200e- • 6.5200e- 357.8917 003 j 003 003 • , 4 Mobile •• 2.8437 . 41.3037 29.9363 • 0:1368 - 4.1010 . � 0.7253 4.8263 - 1.1427 r . 0.6672 r Y . 1.8099 a •- - r - • 13,334.11 . 13,334.11 0.1067 t 13,336.35 ! 15 15 21 + ' ' • ' Total 20.4395 41.6013 30.3123 0.1386 4.1010 0.7483 4.8493 1.1427 0.6902 1.8329 13,690.10 13,69D.10 0.1143 6.5200e- 13,694.52 67 67 003 77 CalEEMod Version: CalEEMOd.2013.2.2 Page 8 of 15 Date: 8/16/2016 10:51 AM ' ROG • '.. NOx . "CO' S02 ' 'fugitive : Exhaust PM10`-, Fugitive-' `Exhaust '.PM2.5 ",EiE ,Total CO2 CH4. ' " N20 CO2e- ` - • PM10 n = -.PM10 -` _ ' Total PM2.5 :' �. PM2.5 Total j Percent 4.92 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 Reduction 3.0 Construction Detail Construction Phase Phase 4' -Phase Name `-�T, A _f _. . P,hase',Type-` ," Start Date,- "' End Date Nurn Days Num Days ., aPhase Description - -Number, •' ^ Week 1 •Architectural Coating :Architectural Coating -319/2019 -3/1112019 5. 1 Acres of Grading (Site Preparation Phase); 0 Acres of Grading (Grading Phase): 0 Acres of Paving: 0 Residential Indoor: 0; Residential Outdoor: 0; Non -Residential Indoor: 0; Non -Residential Outdoor: 0 (Architectural Coating —sgft) OffRoad Equipment ' "`.Phase Nariie'•, '."Dffroad Equipmenl=Type . , Amount lUsage Hours, - Horse PovJer� Load Factor', Architectural Coating :Air Compressors ; 0. 6.00. 78- 0.48 Trios and VMT Phase Name : ; 'Offroatl Equipmenty . WorkerTrip . Vendor Tnp. Hauling Trip, 'Worker Trip'" 'Vendor Trip": ,Haulirig Trip' Worker Vehicle �. Vendor Hauling ;. - --Conf �P, =Number ; . Number" ` Numbe;" "" "Length- -"' Length i e, Length g _` Cl Vehide Class Vehicle Class _ .. ,. _ Architectural Coating : 0; 0.001 0.00. 0.00: 14.70; 6.90: 20.00;LD_Mix ;HDT_Mix -HHDT 3.1 Mitigation Measures Construction CaIEEMod Version: CaIEEMOd.2013.2.2 Page 9 of 15 Date: 8/16/2016 10:51 AM 3.2 Architectural Coating - 2019 Unmitigated Construction On -Site CO' , ,-502 Fugitive Exhaus( PM70 ,FugNve Exhaust P,M2:5t Bio- CO2 NBio-,CO2 'Total CO2 tCH4 -N20. 2 ; CO2e PM10TotalPM2 5 = ` PMP 5Tofaf; ' .... , . , Categop': �° `` r."'^ lb/day •.- _ - _ "_ ` lb/day Archit. Coating 0.0000 0.0000 0.0000 0.0000 0.0000 i 0.0000 0.0000 3 1 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 3 3 1 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 Off -Site 'ROO;„NOzl.,CO ,502FugitiveExhaust,'i PM70 ". Fugitive Exhaust PM2;5 .Bio-0O2r NBio- CO2TotaI COT `, ... N20, ""CO2e= :PM2.5 PM2.5,. .Total'- ,CH4 Categop'.„ ., _. _. ; . ,, „IbPoey �; . .. �, lb/day . Hauling •' 0.0000 0.0000 ' 0.0000 ' 0.0000 ' 0.0000 ' 0.0000 0.0000 0.0000 r 0.0000 ' 0.0000 i 0.0000 0.0000 0.0000 0.0000 1 . . , _____ _______ _______ ------------------------------- r_ _______ 3 _______�_______-_______T,-- 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 0.0000OODO 3 3 3 worker •' o.0000 o.0000 0.0000 0.0000 0.0000 ' 0.0000 0.0000 0.0000 0.0000 0.0000 { o.odoo ' 0.0000 0.0000 ' o.oliao 3 3 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 b do Mitigated Construction Off -Site 4.0 Operational Detail - Mobile CalEEMod Version: CalEEMOd.2013.2.2 Page 11 of 15 Date: 8/16/2016 10:51 AM 4A Mitigation Measures Mobile ROG NO. I CO S02 Fugitive PM10 Exhaust PM10 PM10 Total Fugitive PM2.5 Exhaust PM2.5 PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N20 CO2e Category Iblday Iblday, Mitigated 2.8437 41.3037 • 29.9363 0.1368 4.1010 0.7253 • 4.8263 1.1427 • 0.6672 1.8099 13,334.11 • 13.334.11 0.1067 13.336.35 .. 15 15 21 ______RtT____________T______r______T______r______._______-__.____ _-in t ______T______T______T ______t ___ Unmitigated 2.8437 41.3037 29.9363 0.1368 4.1010 0.7253 4.6263 1.1427 0.6672 1.8099 • 13,334.11 • 13,334.17 0.1067 • 13,33fi.35 15 15 21 4.2 Trip Summary Information Average Daily Trip Rate Unmitigated Mitigated Land Use Weekday Saturday jSunday Annual VMT Annual VMT Parkin Lot • 0.00 0.00 i 0.00 ........................... .;___________________.___.__.... 4____..._.._____....._.._; _.____.___.._____..__. _... Unrefrigeratetl Warehouse -No Rail 209.63 209.63 I 209.63 1,709,242 1,709.242 Total 209.63 209.63 20-3 1,709,242 1,709.242 4.3 Trip Type Information Miles Trip% Trip Purpose % Land Use H-W or C-W H-S or C-C H-0 or C-NW H-W or C-W H-S or C-C I H-O or C-NW Primary Diverted Pass -by Parking Lot 16.60 8.40 6.90 0.00 i 0.00 i 0.00 0 0 0 Unretrtgerated Warehouse -No • 22.40 0.00 0.00 100.00 0.00 0.00 100 0 0 LDA I LOT1 I LDT2 I MDV I Li I LHD2 I MHD I HHD I OBUS I UBUS I MCY I SBUS I MH 0.000000• 0.000000: 0.000000- 0.000000- 0.169100- 0.000000- 0.227400- 0.603500• 0.000000• 0.000000• 0.000000• 0.000000- 0.000000 CalEEMod Version: CalEEMod.2013.2.2 Page 12 of 15 Date: 8/16/2016 10:51 AM 6.41 l8w*OpOetail Historical Energy Use: N 5.1 Mitigation Measures Energy Ug 4P 10 m0,FOgW Tt61 e,, 'PM25 Fdha4Su PM25Tota,- I4PM21d5 Bip� COV NBio�302rot Total COZ c CO2a,' ....... r lbtday • NaturalGas 0.0326 0.2964 r 0.2490 • 1.7800e- 0.0225 0.0225 0.0225 0.0225 355.7268 355.7268 6.8200e- 6.5200e- 357.8917 Mitigated 003 003 003 -------------- ------- ------------------- A -------- - - - Gas-0-.-03-2-6- 0.2964 0.2490 1.7800e- 0.0225 0.0225 ---------- I - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 0.0225 0.0225 355.7268 • 355.7268 6.8200e- 6.5200, 357.8917 Unmitigated 003 003 003 5.2 Energy by Land Use - NaturalGas Unmitigated NatanilRa�03 ,Nox� $02',.'j-F6giWeT1 Fxhaustz gior !Exhaust €"PM2.5'-, Bk=c024 kB!6-,;92 T6tiICO2'j-�CH4- ".,FU PM? -land Use7., -'�-Ibld ay, b1day Unrefrigeraded 3023.68 6, 0.0326 r 0.2964 0.2490 1.7800e- 0.0225 0.0225 r 0.0225 0.0225 355.7268 355.7268 6.8200e- 6.5200e- 357.8917 Warehouse -No at 003• 003 003 A. I ------ - --------------------- 4 ------- 4- ---- 4 -------- ------- 4 ------- 4 ---------------- ....... -------- ----------------- 4 --------------- Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 r 0.0000 r r 0.0000 0.0000 A 0.0000 r 0.0000 0.0000 - 0.0000 0.0000 r r r r r Total 0.0326 0.2964 0.2490 1.7800e- 0.0226 0.0225 0.0225 0.0226 355.7268 355.7268 6.8200e. 6.52000- 357.8917 003 003 003 CalEEMod Version: CaIEEMOd.2013.2.2 Page 13 of 15 Date: 8/16/2016 10:51 AM 5.2 Energy by Land Use - NaturalGas Mitigated _- -" NaturalGa - ROG" ?NOx' -'CO' '• SOT. Fugitive. ExhausC 'PM10.- Fugitive: '.Exhaust. PM2.5 Bio- CO2, NBioo- CO2 Toted CO2 CH4 N20-' --0O2a - PM10:=- PM70' --. :Total PM2S PM2.5 Total" ` - - r .�� Iand.Use kBTU/Yr ' „. :,...,, . ` '. ;- dti/daY - ,:: .. _ ' Ib/day', . F Unrefdgerated 3.02368 0.0326 0.2964 • 0.2490 1.7800e- r • 0.0225 • 0.0225 • • 0.0225 • 0.0225 i 355.7268 • 355.7268 r 6.8200e- • 6.5200e- • 357.8917 is Warehouse -No A. 003 003 003 c-n r i _�-_____ _._____________r______r Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 ------ 0.0000. 0.0000 0.0000 r______t_______ 0.0000 0.0000 1 1 � t • • Total 0.0326- 0.2964 0.2490 1.7800e. 0.0225 0.0225 0.0225 0.0225 355.7268 355.7268 6.8200e- 6.5200e- 357.8917 11 003 003 003 6.0 Area Detail 6.1 Mitigation Measures Area Use Low VOC Paint - Non -Residential Interior Use Low VOC Paint - Non -Residential Exterior ' : -" "' ROG:. •- _ =+ NOx ' 7 =` --'CO- 502 - FugitiveExhaust. PM10 P.M1a ` PM10 Total- FugitiveExhausT �- PM2.5 ] PM2.5= PM2.5 Totals - Bic--0O2" • NBio- CO2 f°' Total CO2 - " :CH4', I ' N20 CO2e Cale9orL ,- ,- Ib/daY ... -, INdaY j Mitigated 17.5631 11900e- 01270 1.0000e- 4.6000e- 4.6000e- 4.6000e- & 0.2684 0.2684 7.4000e- • 0.2839 .. i 003 i 005 004 004 • • r 004 ,4.6000e- 004 r 004 a UnmNgated 18.6205 1.1900e- 0.1270 1.0000e- 4.6000e- 4.6000e- 4.6000e- 4.6000e- 0.2684 0.2684 7.4000e- 0.2839 003 005 004 004 004 004 004 CaIEEMod Version: CalEEMod.2013.2.2 Page 14 of 15 Date: 8/1612016 10:51 AM 6.2 Area by SubCategory Unmitigated -,SO2 ':];ExhauSt?];kPMI0,--a,' jF tExh �Bjp,,-,CO2-- N!Bic,�C()2 Total'Cq2 2 PM70 2 otal 0SubCidegorjq� 4,- A-�, � b 5; Architectural 1.5693 0.0000 0.0000 0.0000 0.0000 1 0.0000 0.0000 Coating -------e-r ------------------- -------------- -- -- ---- - I I I I -Consum17.0391 Products 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 - ------- - - ------------------- -------------- Landsin 0.0121 1.1900e, 0.1270 1.0000e- 4.60OOe- 4.6000e- 4.6000e- 4.6000e, 0.2684 0.2684 7.4000e, 0.2839 003 005 004 004 004 004 j 004 1 Total 18.6206 1.1900e. 0.1270 1.0000e- 4.6000e. 4.6000e. 4.6000e- 4:600Oe- 0.2684 0.2684 7.4000e. 1 11 003 005 004 004 004 004 Mitigated "'ROG �j` s02',� ,,F6ghver,' Exhaust'! �Pm Ichw, 'P 23��-, �Blb,CM N!3164CO21 Total COZ -H47' N20,'��J-, CO2e-j av 19 H ;PM10 Tot`a'I'-,'�,! PM2.5 _.1,ahaust A -,subpotegory. b gay & 2 Architectural 0.5119 0.0000 0.0000 0.0000 0.0000 r 0.0000 0.0000 Coating -4; --------------- ------- 4 ------- 4 ------- 4 ------- 9 --------- --- -41 ----------------------- ---------- ---- - - -6o-naumer 17.0391 0.0000 0.0000 0.0000 7-070-00-0-1 0 ----- 0.0000 Products ------------_______ - -------- I --------------- ------- _______ ------------------------------ ............ Landscaping 0.0121 1.1900e- 0.1270 J 1.0000e- 1 4.61300� 1 4.6000e, 1 4.6000e- A ----- --- - ------- 4.6000e- . 0.2684 0.2684 7A000e, 0.2839, 003 005 004 004 004 004 004 Total 17.5631 1.1900e- 0.1270 1.0000e- 4.6000e- 4.6000e- 4.6000e- 4,6000e. 01684 0.2684 7A000e- 0.2839 003 005. 004 004 004 11 1 004 004 7.0 Water Detail CaIEEMod Version: CaIEEMod.2013.2.2 Page 15 of 15 Date: 8/16/2016 10:51 AM 7.1 Mitigation Measures Water 8.0 Waste Detail 8.1 Mitigation Measures Waste 9.0 Operational Offroad 10.0 Vegetation /ire- %,t� Cvp� Schrader, Lois From: Sent: To: Cc: Subject: Hello All, See SCAQMD's comments below. "Warm Regards, Nikki Cavazos Cavazos, Nikki Wednesday, July 26, 2017 3:14 PM Tina Andersen; Russell Pierce Smith, Michael; Schrader, Lois FW: Responses to SCAQMD Comments - IPT Arrow Route Project .Assistant Aanner, City of Rancho Cucamonga 10500 Civic Center Drive, Rancho Cucamonga CA 9173o (909) 477-2750 Ext. 4311, .T4on-frhurs. 7 am - 6pm From: Lijin Sun [mailto:LSun@agmd.gov] Sent: Wednesday, July 26, 2017 2:26 PM To: Cavazos, Nikki <Nikki.Cavazos@cityofrc.us> Cc: Jillian Wong <jwongl@agmd.gov>; Jack Cheng <jcheng@aqmd.gov> Subject: RE: Responses to SCAQMD Comments - IPT Arrow Route Project Dear Ms. Cavazos, SCAQMD staff reviewed the proposed responses to our comments on the Mitigated Negative Declaration for the proposed IPT Arrow Route DC Project (DRC2016-00726) (SCAQMD Control Number: SBC170621-02). Although SCAQMD staff disagrees with some responses, we have no further comments at this time. Thank you, Lijin Sun, J.D. Program Supervisor, CEQA IGR South Coast Air Quality Management District 21865 Copley Drive, Diamond Bar, CA 91765 Direct: (909) 396-3308 Fax: (909) 396-3324 825 East Third Street. San Bernardino, CA 92415-08351 Phone. 909-387.8109 Fax. 909.387.7876 Department of Public Works SAN BERNARDINO • fiootiControl Kevin Blakeslee, P.E. COUNTY • OperationsDirector • Solid N%n,te 111nnn};cnu•'OR • Sur\Y\or • 'francpnrtation GP�NCHOCUC AMoNGA July 25, 2017 RUC 26 ?OlI RECEIVED . p/ City of Rancho Cucamonga ZANNING Planning Department vV PO Box 807 Rancho Cucamonga, CA. 91729 File: 10(ENV)-4.01 RE: CEQA — NOTICE OF AVAILABILITY OF A MITIGATED NEGATIVE DECLARATION FOR THE IPT ARROW ROUTE FOR THE CITY OF RANCHO CUCAMONGA To whom it may concern: Thank you for allowing the San Bernardino County Department of Public Works the opportunity to comment on the above -referenced project. We received this request on June 20, 2017 and pursuant to our review, the following comments are provided: GENERAL COMMENTS We are aware there may be storm drains in and around the project site that may be affected by the proposed project. When planning for or altering existing or future storm drains, be advised that the Project is subject to the Comprehensive Storm Drain Plan Project #2 dated March 1969. Please refer to this plan as a guideline for drainage in the area and is available in the San Bernardino County Flood Control District's (District) office. If you have any questions, please contact Michael Fam in the Flood Control Planning Division at 909-387- 8120. We respectfully request to be included on the circulation list for all project notices, public reviews, or public hearings. In closing, I would like to thank you again for allowing the San Bernardino County Department of Public Works the opportunity to comment on the above -referenced project. Should you have any questions or need additional clarification, please contact the individuals who provided the specific comment, as listed above. Sincerely, yervising MR. Perry S Planner Environmental Management MRP:PE:sr South Coast Air Quality Management District MP 21865 Copley Drive, Diamond Bar, CA 21765-4178 (969) 396-2D00 • www.agmci.gov SENT VIA USPS AND E-MAIL: CITY RAAICHO CUCgMONGAuly 25, 2017 donald. rangerQcityofrc.us JUL2 Donald Granger, Senior Planner 5 2017 City of Rancho Cucamonga — Planning Department RECEIVE® - P.O. Box 807 1. Rancho Cucamonga, CA 91729 PLANNINr Mitigated Negative Declaration (MND) for the Proposed IPT Arrow Route DC Project (DRC2016-00726) The South Coast Air Quality Management District (SCAQMD) staff appreciates the opportunity to comment on the above -mentioned document. The following comments are meant as guidance for the Lead Agency and should be incorporated into the Final MND. Project Description The Lead Agency proposes to construct and operate a 611,573-square-foot, high -cube warehouse with unknown occupants on an approximately 26.63-acre site ("proposed project"). The proposed project is bounded by commercial uses to the north, east, south, and west. Air Quality and Health Risk Assessment (HRA) Analyses In the Air Quality Section, the Lead Agency quantified the proposed project's construction and operational emissions and compared them to SCAQMD's regional and localized air quality CEQA significance thresholds. The air quality analysis was based on approximately 824 total vehicle trips, including 212 daily truck trips'. The Lead Agency found that regional and localized construction and operational emissions would be less than significant. Additionally, the Lead Agency performed a HRA and found that the Maximum Exposed Individual Resident cancer risk would be 0.23 in one million, which is below SCAQMD's CEQA significance threshold of10 in one million for cancer risk'. SCAQMD staff has concerns about the HRA analysis in the MND. The analysis utilized assumptions which have likely led to an under -estimation of the proposed project's health risk impacts. Details are included in the attachment. After revising the HRA analysis, should the Lead Agency find that the proposed project's health impacts would exceed SCAQMD's CEQA significance thresholds, mitigation measures are required pursuant to the CEQA Guideline Section 15074(b). SCAQMD staff has included a list of mitigation measures in the attachment to assist the Lead Agency in identifying feasible mitigation measures which have the potential to substantially lessen such significant effects (Public Resources Code Section 21002). Pursuant to the CEQA Guidelines Section 15074, prior to approving the proposed project, the Lead Agency shall consider the MND for adoption together with any comments received during the public review process. Please provide SCAQMD staff with written responses to all comments contained herein prior to the adoption of the Final MND. IPT Arrow Route DC Project. Initial Study and Mitigated Negative Declaration —Table 14Project Trip Generation Summary. Ibid. Page 3-20. Donald Granger July 25, 2017 SCAQMD staff is available to work with the Lead Agency to address the issues raised in the letter and any other air quality and HRA questions that may arise. Please contact Jack Cheng, Air Quality Specialist — CEQA IGR Section, at (909) 396-2448, if you have any questions regarding these comments. Sincerely, Lijin Sun, J.D. Program Supervisor, CEQA IGR Planning, Rule Development & Area Sources Attachment LS:JC SBC170621-02 Control Number Donald Granger ATTACHMENT Daily Truck Trip Rate July 25, 2017 In the air quality analysis, the Lead Agency used the Institute of Transportation Engineers Trip Generation Manual, 9`t' Edition, 2012 (ITE Manual) 1.68 overall trip generation rate (for cars and trucks totaling approximately 824 daily vehicles) , and did not use the 0.64 (38.1%) daily truck trip rate from this same reference. Rather, the Trip Generation Rates used a passenger vehicle trip rate of'1.337 vehicles per day and a daily truck trip rate of 0.343 daily truck trip rate (1.68 total daily trip rate minus 1.337 passenger vehicle trip rate or 20.43% daily truck trip rate). Additionally, truck vehicle fleet mixture percentages from the City of Fontana Truck Trip Generation Study (Fontana Study) was used to estimate project air quality operational impacts in the CalEEMod modeling. By using the 0.343 daily truck trip rate, trucks are estimated at 212 daily truck trips in the MND insteadof approximately 395 daily truck trips using the ITE 0.64 daily truck trip rate. Therefore, absent from a specific traffic study of known tenants, the Final MND should be consistent using the associated ITE truck trip rate to estimate daily truck trips so that the proposed project's truck trips and associated emissions and Health impacts are not underestimated. 2. The total vehicle mixture in Appendix 3.1 — CalEEMod Emissions Model Output was not consistent with the traffic analysis3. In Appendix 3.1 — CalEEMod Emissions Model' Output — Section 4.3 Trip Type Information, heavy duty trucks accounted for 12% of the total trips while the traffic study appropriated 20.43% of total trips to heavy duty trucks. SCAQMD staff recommends using the ITE trick trip rate of 0.64 trips/tsf (38.1% of total vehicle trips) to estimate daily truck trips so that the proposed project's truck trips, emissions, and health impacts are not underestimated. Additionally, the heavy duty fleet mixture in Appendix 3.1 was not consistent with the heavy duty truck fleet mixture in the traffic study and the HRA4, which may have underestimated the proposed project's operational emissions. Appendix 3.1 included a heavy duty truck fleet mixture of LHD = 54%, MHD = 14%, HHD = 32%, while the traffic study and HRA used a heavy duty truck fleet mixture of LHD = 17%, MHD = 23%, HHD = 60%. Therefore, SCAQMD staff recommends that the Lead Agency correct the inconsistencies and use the ITE 0.64 daily truck trip rate and a heavy truck fleet mixture of LHD2 = 0.0645, MHD= 0.0865, HHD = 0.2300 consistently throughout the Final MND and technical appendices. Health Risk Assessment (HRA) Analysis 4. Based on a review of the HRA analysis, SCAQMD found that the HRA analysis utilized the 2015 revised OEHHA guidelines to estimate the health risks to sensitive receptors in the proposed project's vicinity and that the AERMOD dispersion model was used to estimate diesel particulate matter (DPM) concentrations. SCAQMD staff recommends that the Lead Agency revise the HRA analysis based on the following comments. a. The 2015 revised OEHHA guidelines acknowledge that children are more susceptible to the exposure to air toxics and have revised the way cancer risks are estimated to take this into account. Since the emissions from the project -generated trucks get cleaner with time due to existing regulations, it would not be appropriate to average out the emissions over the 70-year exposure duration since this would underestimate the health risks to children ' Ibid. Table, 14 Project Trip Generation Summary. 41bid. Modeling File— "10360-02 HRA Truck Emissions Average,xlsx," Donald Granger 4 July 25, 2017 who would be exposed to higher DPM concentrations during the early years of project operation. Therefore, SCAQMD staff recommends that the DPM emissions for each year of operation be applied to each of the corresponding age bins (i.e. emissions from Year 1 of project operation should be used to estimate cancer risks to the third trimester to 0 year age bin; Year 1 and 2 of project operation should be used to estimate the cancer risks to the 0 to 2 years age bins; and so on). b. The HRA analysis involved the use of a discrete receptor placed over existing residential structures. Receptor locations should be placed at the boundaries of the residential property and not the residential structures. Placing receptors on the residential structure underestimates cancer risks to the residents. SCAQMD staff recommends that the Lead Agency revise the HRA and use a receptor grid that starts at the property boundaries to ensure potential maximum concentrations are identified. Additional Mitigation Measures for Operational Air Quality Impacts (Mobile Sources) 5. CEQA requires that all feasible mitigation measures that go beyond what is required by law be utilized to minimize or eliminate any significant impacts. In the event that the Lead Agency, after revising the HRA analysis based on the comments provided above, finds that the proposed project would result in significant health risk impacts, SCAQMD staff recommends incorporating the following on -road mobile -source truck related mitigation measures in the Final MND. For more information on potential mitigation measures as guidance to the Lead Agency, please visit SCAQMD's CEQA Air Quality Handbook websites. • Require the use of 2010 and newer haul trucks (e.g., material delivery trucks and soil import/export). In the event that that 2010 model year or newer diesel haul trucks cannot be obtained, provide documentation as information becomes available and use trucks that meet EPA 2007 model year NOx emissions requirements, at a minimum. Additionally, consider other measures such as incentives, phase -in schedules for clean trucks, etc. • Have truck routes clearly marked with trailblazer signs, so that trucks will not enter residential areas. • Limit activities to the amounts analyzed in the Final MD. • Promote clean truck incentive programs (see the discussion above regarding Cleaner Operating Truck Incentive Programs). • Provide electric vehicle (EV) Charging Stations (see the discussion below regarding EV charging stations). • Trucks that can operate at least partially on electricity have the ability to substantially reduce the significant NOx impacts from this project. Further, trucks that run at least partially on electricity are projected to become available during the life of the project as discussed in the 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy'. It is important to make this electrical infrastructure available when the project is built so that it is ready when this technology becomes commercially available. The cost of installing electrical charging equipment onsite is significantly cheaper if completed when the project is built compared to retrofitting an existing building. Therefore, SCAQMD staff recommends that the Lead Agency require the proposed project include the appropriate infrastructure to facilitate sufficient electric charging for trucks to plug-in. Similar to the City of Los Angeles requirements for all new projects, SCAQMD staff recommends that the Lead Agency require South Coast Air Quality Management District. htp,/haww aamd gov/homelreeulations/cega/air-quality-analysis-handbook. 6 Based on a review of the California Air Resources Board's diesel truck regulations, 2010 model year diesel haul trucks should have already been available and can be obtained in a successful manner for the project construction California Air Resources Board. March 2016. Available at: hao'//w"vtriekloadore/tca/files/ccLibror Files/Filename/000000003422/California-Clean-Truck-and-Trailer-Undate.pdr(See slide#23). r Southern California Association of Governments. Adopted April 7, 2016. Available at: htto://scanrtoses.net/Paees/default.aspx. Donald Granger July 25, 2017 at least 5% of all vehicle parking spaces (including for trucks) include EV charging stations8. Further, electrical hookups should be provided at the onsite truck stop for truckers to plug in any onboard auxiliary equipment. At a minimum, electrical panels should appropriately sized to allow for future expanded use. City of Los Angeles. March 30, 2017. Accessed at: http-Hladbsorg/LADBSWeb/LADBS Forms/Fublications/LAGreenBuildineCodeOrdinancepdf. CITY OF RANCHO CUCAMONGA JUL 2 5 2017 RECEIVED - plANNING Ae (� 012 W co/�� T 5tp.6M400 I .92012th $trok. suits 2W athtw.i 'teaudalry.eaiH � 5tQ;ti36 *t2D3 � pSkP�nd,Ca �J�16{Yi l r(ciiartl�tousaudrury.cam Via Email and U.S. Mail July 26, 2017 Nikki Cavazos, Assistant Planner City of Rancho Cucamonga 10500 Civic Center Drive Rancho Cucamonga, CA 91730 Nikki.Cavazos@cityofre.us Lois Schrader, Planning Commission Secretary Planning Commission City of Rancho Cucamonga 10500 Civic Center Drive Rancho Cucamonga, CA 91730 Lois.Schrader(7a CitvofRC.us Candyce Burnett, Planning Director City of Rancho Cucamonga 10500 Civic Center Drive Rancho Cucamonga, CA 91730 Candy ce.BurnettgCityofRC. us Janice C. Reynolds, City Clerk City of Rancho Cucamonga 10500 Civic Center Drive Rancho Cucamonga, CA 91730 citv.clerkka cityofrc.us Re: CEQA Comments for DRC2016-00726 by Applicant IPT Arrow Route DC, LP Dear Ms. Cavazos, Ms. Burnett, Ms. Schrader and Ms. Reynolds: I am writing on behalf of the Laborers International Union of North America, Local Union 783 and its members living in the San Bernardino County and/or City of Rancho Cucamonga ("LiUNA") regarding the Initial Study and Mitigated Negative Declaration ("IS/MND") prepared for the project known as DRC2016-00726 by Applicant IPT Arrow Route DC, LP, including all actions referring or related to the construction and operation of a 611, 573 sq foot industrial building located on 26.63 acres on the north side of Arrow Route, west of Etiwanda Avenue on APN 0229-021-60 in the City of Rancho Cucamonga ("Project'). After reviewing the IS/MND, we have concluded that the IS/MND is insufficient under the California Environmental Quality Act ("CEQA"). Thank you for your attention to this matter. Sincerely, Richard Toshiyuki Drury Lozeau I Drury LLP