Port of Richmond Terminal 3 Log Storage and Shipping Facility

CITY OF RICHMOND, CALIFORNIA

INITIAL STUDY & MITIGATED NEGATIVE DECLARATION

MAY 2017

Port of Richmond Terminal 3 Log Storage and Shipping Facility

Initial Study/Mitigated Negative Declaration

TABLE OF CONTENTS

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Summary Information ...... 1 Description of the Project...... 2 Site Description and Surrounding Uses...... 13 Environmental Factors Potentially Affected ...... 15 Determination...... 16 Evaluation of Environmental Impacts ...... 17 I. Aesthetics...... 17 II. Agricultural Resources ...... 20 III. Air Quality...... 22 IV. Biological Resources...... 45 V. Cultural Resources ...... 47 VI. Geology and Soils ...... 51 VII. Greenhouse Gases ...... 57 VIII. Hazards and Hazardous Materials ...... 59 IX. Hydrology and Water Quality...... 66 X. Land Use and Planning ...... 77 XI. Mineral Resources ...... 87 XII. Noise...... 88 XIII. Population and Housing ...... 100 XIV. Public Services...... 102 XV. Recreation ...... 105 XVI. Transportation/Traffic...... 106 XVII. Utilities and Service Systems ...... 112 Mandatory Findings of Significance...... 116 Report Preparation...... 118 Mitigation Measures ...... 119

Initial Study/Mitigated Negative Declaration TERMINAL 3 LOG STORAGE AND SHIPPING FACILITY i

Appendices Appendix A Comment Letters on Previous Initial Study Appendix AQ–1 Air Quality Setting and Regulatory Context Appendix AQ–2 Air Quality Calculation Assumptions and Methodologies Appendix AQ–3 Health Risk Assessment Assumptions and Methodologies Appendix AQ–4 Greenhouse Gas Setting and Regulatory Context

LIST OF FIGURES

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Figure 1 Project Site Location ...... 4 Figure 2 Aerial Overview of Site and Surroundings ...... 5 Figure 3 Site Plan...... 6 Figure 4 Ultra Blocks Used for Log Stack Stability ...... 8 Figure 5 Log Stack Plan...... 9 Figure 6 Log Bunk Design ...... 10 Figure 7 Log Bunk Plan...... 11 Figure N–1 Noise Measurement Locations ...... 97 Figure N–2 Estimated Future Project Noise Levels...... 98

LIST OF TABLES

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Table AQ–1 Estimated Average Daily Project Operational Emissions in the YSAQMD (pounds per day) ...... 26 Table AQ–2 Estimated Average Daily Project Operational Emissions in the YSAQMD (tons per year) ...... 26 Table AQ–3 Estimated Average Daily Project Operational Emissions in the BAAQMD (pounds per day)...... 27 Table AQ–4 Estimated Average Daily Project Operational Emissions in the BAAQMD (tons per year) ...... 28 Table AQ–5 Regulatory and Recommended Exposure Limits for Wood Dust ...... 40 Table GH–1 Estimated Annual Greenhouse Gas Emissions in the BAAQMD ...... 58 Table N–1 Typical Noise Levels ...... 89 Table T–1 Estimated Project Trip Generation...... 107

Initial Study/Mitigated Negative Declaration ii TERMINAL 3 LOG STORAGE AND SHIPPING FACILITY California Environmental Quality Act (CEQA) Environmental Checklist Form

1. Project Title: Terminal 3 Log Storage and Shipping Facility (PLN15-420)

2. Lead Agency Name and Address: City of Richmond Planning and Building Services Department 450 Civic Center Plaza, Second Floor Richmond, CA 94804-1630

3. Contact Person and Phone Number: Lina Velasco, Senior Planner (510) 620-6841 [email protected]

4. Project Location: 1411 Harbour Way South Richmond, CA 94804

Assessor’s Parcel Number: 560-270-060

The project site is located on the west side of Harbour Way South, near its southern terminus, on the southern shoreline of the City of Richmond. The site is located on the east side of Harbor Channel, adjacent to the Richmond Inner Harbor on San Francisco Bay. It is approximately 3,500 feet (0.66 miles) south of Interstate 580, at the intersection of Harbour Way South and Hall Avenue.

5. Project Sponsor’s Name and Address: RJJ Resource Management Corporation 1411 Harbour Way South Richmond, CA 94804

Contact: Richard Lyu, President (510) 816-6671 [email protected]

6. General Plan Designation: Port

7. Zoning: IW, Water-Related Industrial

Initial Study TERMINAL 3 LOG STORAGE AND SHIPPING FACILITY 1

8. Description of Project: Introduction On April 10, 2016 the City of Richmond published and circulated for public review an Initial Study (IS) for the proposed log storage and shipping facility at Terminal 3 of the Port of Richmond. During the 30-day public review period the City received comment letters from public agencies and neighboring businesses expressing concerns about the project, including concerns about safety, wood dust migration, traffic, and noise transmissions from the proposed project, among other issues. In response, some operational changes, described herein, were made to the project at the request of the City, and agreed to by the project applicant.

Additionally, the project evaluated in the April 2016 IS assumed that docked ships would be plugged into a shoreline power terminal at Terminal 3 while they are being loaded. Subsequent to publication of the IS, it was learned that the Chinese ships that will be utilized for log export are not equipped to utilize the shoreline power, and it is not economically viable to retrofit them with this capability. Since this was a key assumption in the analysis of potential air quality and greenhouse gas (GHG) impacts, the City determined that a new, revised IS reflecting the project changes, should be prepared and circulated for additional public review. Accordingly, this IS reflects changes to the project with a revised analysis of air quality, GHG, and noise impacts. In addition, this revised IS implicitly addresses the environmental issues of concern that were raised in the comment letters submitted on the prior IS. Those letters are presented in Appendix A.

This Initial Study has been prepared in compliance with the California Environmental Quality Act (CEQA) and the CEQA Guidelines, which are codified in Title 14, Chapter 3 of the California Code of Regulations. A recent legal ruling will alter the scope of environmental review pursuant to CEQA in comparison with how it has been practiced throughout the State in recent decades. In California Building Industry Association v. Bay Area Quality Management District (CBIA v. BAAQMD)((2015) 60 Cal.4th 1086), the California Supreme Court ruled that CEQA does not require an analysis of the existing environment's impact on a potential project, except in limited circumstances. The Court found the term "environmental effects" to mean only the impacts arising from the project's effect on the environment, and not the environment's effect on the project (sometimes referred to as a "CEQA-in-reverse" analysis).

Although this ruling limits the scope of CEQA review, the Court noted that a reverse analysis is still required in certain conditions, such as when a project could exacerbate or worsen existing environmental hazards. In addition, a lead agency has authority other than CEQA to require measures to protect public health and safety, as well as the environment. The CBIA v. BAAQMD decision notwithstanding, one of the primary functions of a CEQA document continues to be for informational purposes, to disclose environmental effects of a proposed project to the public. Accordingly, the City of Richmond is publishing this Initial Study, which includes an evaluation of the environment's impacts on a project, consistent with the current version of CEQA Guidelines Appendix G, including mitigation recommendations to reduce or avoid these impacts where feasible. The Initial Study assesses both the existing setting and the project's impacts, and thus addresses the extent to which a project could "exacerbate" an existing environmental condition that is otherwise excluded by the CBIA v. BAAQMD decision.

Project Overview RJJ International (RJJ), the project applicant, is proposing to develop and operate a log export facility at Terminal 3 of the Port of Richmond. The proposed project would be located at an

Initial Study 2 TERMINAL 3 LOG STORAGE AND SHIPPING FACILITY already developed site at 1411 Harbour Way South that would be leased from the Port of Richmond. As shown on Figures 1 and 2, the project site is located adjacent to Harbor Channel on the City of Richmond’s southern shoreline along San Francisco Bay. RJJ will operate the log export facility jointly with J.W. Bamford, Inc., which would be responsible for managing the work crews and the day-to-day operations at the site. The proposed project would not require new construction; however, minor repairs to the existing building and facility improvements are proposed as further described in the facility improvement section below.

The proposed facility would receive harvested timber from California forests that would be prepared for shipment, then loaded onto ocean-going ships that would berth at Terminal 3. Once loading of a ship is complete, the prepared logs would be exported to China. It is anticipated that no more than six shiploads of timber would be exported each year. The tree species to be exported by RJJ would include Douglas fir, white fir, ponderosa pine, and sugar pine. The trees would be harvested in accordance with an approved Timber Harvest Plan (THP). Additional information about THPs is provided below.

Terminal 3 Facilities The proposed project would be implemented at an existing facility at Terminal 3, shown on Figure 3. The approximately 12.4-acre site is enclosed by a 6-foot-high chain-link security fence topped with barbed wired. (Another 1.1 acres at the southern end of the Terminal 3 property will be used as a parking lot serving the planned future ferry terminal at the southern end of Harbour Way South. Gated entrances to the site are located near the northern and southern ends of the site. A small guard house is located at the southern entrance, with a small three- story administration building located about 180 feet north of the guard house. A truck scale is located along the east side of the administration building.

A large one-story corrugated metal warehouse building is located along the eastern edge of the Terminal 3 site. This flat-roofed building is 800 feet long and has a floor area of approximately 88,000 square feet. A recently-installed shoreline 480-volt, three-phase power terminal is located at the edge of the ship berth. This terminal provides power to ships while they are docked at Terminal 3 so they don’t need to idle the ship engines for power. However, it will not be utilized by the proposed project since the ships that will be used for exporting logs are not equipped to utilize shore power. The remainder of the site consists of asphalt pavements.

Proposed Operations The proposed facility would receive logs both with and without bark. Logs without bark would arrive by truck from an RJJ site in West Sacramento. Loaded trucks would enter the facility through the northern gated entrance to Terminal 3, and would first be weighed by staff at the truck scales at the southeastern corner of the site. Trucks would then proceed to the Debarked Logs Deck area shown on Figure 3, where crews would unload the logs using a front loader equipped with a grappling claw, stacking them in piles not to exceed 25 feet in height. The unloaded trucks would be weighed again prior to departing from the site (also via the northern entrance) in order to determine the weight of the unloaded logs. It would take approximately 15 minutes to unload each truck. Logs would remain stockpiled in this area until ready for shipment; they would generally be stockpiled for no longer than one month.

Logs arriving with bark still on would also be weighed upon arrival at Terminal 3. They would then be unloaded by a front loader and stacked at the Log Layout Area shown on Figure 3. When sufficient logs have been accumulated, staff would use front loaders to move the logs into the north end of the large shed where a conveyor would feed them into a 43-inch electric-power Salem debarker that would mechanically strip the bark. To reduce the generation of airborne wood dust, water would be sprayed automatically as each log feeds into the debarking ring of

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Site Plan Source: BKF the debarker. Approximately 10 gallons of water per day would be consumed for this purpose. The water would be collected in a debris container located below the debarker that would also capture the bark stripped from the logs. The spray water would be absorbed by the bark debris and would not create runoff water. The bark debris container would be regularly emptied and bark would be recycled. A street sweeper would clean the site daily to keep it free of debris and to control dust.

The removed bark would be picked up by Agra Marketing Group (Agra), a recycler based in Chico, California, and conveyed in 25-ton semi-trailer trucks to end markets in the Bay Area or central California. Agra would haul away one to two truck loads per day, Monday through Friday, from the log export facility. The recycled bark would be ground up, screened, and used for landscape mulch and potting soil.

Once a sufficient quantity of prepared logs has accumulated in the Debarked Logs Deck area, they would be loaded into a Handymax class vessel for shipment to China. Handymax vessels carry dry bulk goods and are typically between 492 and 656 feet long, with a capacity of 40,000 to 50,000 deadweight tons (DWT). The ships would be loaded by unionized longshoremen using ship-board cranes. It would take up to ten days to load a ship.

Log export shipments would occur only during the timber harvesting season in California, which starts in April and continues to the end of November. With six shipments anticipated each year, there would be less than one shipment a month.

Prepared logs would be stacked in the Debarked Logs Deck area by an excavator equipped with a grapple claw. On an interim basis, the logs on the log deck would be confined and stabilized by a proprietary Ultra Block system comprised of stacked heavy concrete blocks. Manufactured from recycled concrete, the blocks weigh approximately 4,320 pounds each, and are 5 feet long, 2.5 feet wide, and 2.5 feet tall. As shown on Figure 4, two half-blocks that are 2.5 feet square would be stacked on two full blocks arrayed in a “T” configuration. The two half-blocks would be stacked on top of each other to create a 7.5-foot-tall L-brace. Each Ultra Block is manufactured with a galvanized steel cable loop at the top center of the block, which will allow the project applicant to shift the positions of the blocks for operational purposes using a front- loader.

As portrayed on Figure 5, a series of these stacked blocks would be arrayed in a line at either end of a log stack, spaced at intervals of 1 to 4 feet apart. They would function similar to bookends to confine the log stacks. Their immense weight would hold them in place both on the log deck and in their individual stacks, and no anchoring to the log deck would be required. Lugs on the surface of the blocks also contribute to this stability through additional friction. With approximately a dozen Ultra Block L-braces positioned at each end of a log stack, there would be sufficient mass to hold the logs in place. As shown on Figure 4, logs would be stacked up to a height of 7.5 feet at the edge of the Ultra Block array, then slope up toward the center of the stack at a maximum 2:1 slope. The stacks would not exceed a total height of 20 feet.

The project applicant is currently designing an alternative long-term log bracing system that will consist of metal log bunks placed at the ends of log stacks to stabilize and confine the log stacks, as shown on Figure 6. The log bunks would be constructed of welded wide-flange steel beams and would consist of a horizontal bed supported by two vertical end beams. Constructed of 15-inch-wide flanged beams, the bunks would be 8 feet long, 6 feet tall on the outside end, and 4 feet tall on the inside end, and would be supported on 4-foot-long base beams. Each bunk would be comprised of two pairs of beam structures placed approximately 30 feet apart. As shown on Figure 7, the bunks would be loaded with logs and the weight of the loaded bunks would function as bookends to the larger log stack. The log stacks would still be limited to a

Initial Study TERMINAL 3 LOG STORAGE AND SHIPPING FACILITY 7 Figure 4

Ultra Blocks Used for Log Stack Stability Source: KPW Structural Engineers, Inc. Figure 5

Log Stack Plan Source: KPW Structural Engineers, Inc. Figure 6

Log Bunk Design Source: BKF Engineers Figure 7

Log Bunk Plan Source: BKF Engineers maximum height of 20 feet with a maximum slope of 2:1. Similar to the temporary Ultra Blocks, no anchoring or other disturbance of the surface of the log deck would be required for the log bunks.

Normal operating hours for the proposed log export facility would be Monday through Friday from 6:00 a.m. to 6:00 p.m. Receiving hours for loaded log trucks would be from 7:00 a.m. to 5:00 p.m. It is anticipated that approximately 10 truck loads of logs would be delivered to the proposed facility each weekday, with some of the loads arriving on log trucks and others arriving on flatbed trucks.

During standard operational periods, there would be five employees working at the facility. During the periodic ship-loading operations, 16 longshoremen would be temporarily employed, for a total of 21 workers on site.

As discussed above, the operational equipment on the site would consist of an excavator, front loader with claws, and street sweeper. All equipment would be from 2011 model years or more recent and would meet the current requirements of the California Air Resources Board for Marine Cargo Handling Equipment, which requires Tier 4 Alt PM engines and annual opacity testing of particulate matter (PM) in the diesel exhaust.

Facility Improvements As previously noted, Terminal 3 is already a fully developed Port of Richmond facility. To accommodate the proposed facility, RJJ would construct tenant improvements in the first floor of the terminal building, which would include reinstallation of the electrical system. In addition, exterior lighting would be installed along the west side of the terminal shed, along with a surveillance system. The existing scales adjacent to the administration building would also be repaired. A debarker is also proposed to be installed within the warehouse building to support the operations at the site.

A new gated entrance would be created approximately 170 feet north of the existing northern gate. There is currently a curb cut and driveway entrance at this location, but the entry is fenced off and it not currently being used. While the existing northern entrance would be retained as a back-up, the primary truck entrance would be shifted to the north to avoid conflicts with debarking operations in the northern end of the terminal building. Due to the existing curb cut, restoration of this entrance is not expected to require an encroachment permit. The existing southern entrance would continue to be used only for passenger vehicle access by employees, longshoremen, and visitors, a continuation of current practice.

No other construction or improvements are proposed as part of the proposed project.

Timber Harvest Plans The timber to be exported from the facility would originate from privately-owned forest lands in northern California, both coastal areas and the Sierra Nevada. Each forest that would supply the proposed project has a Timber Harvest Plan (THP) prepared by a Registered Professional Forester (RPF) and approved by the California Department of Forestry and Fire Protection (CALFIRE).

THPs have been certified by the State as being the “functional equivalent” of an Environmental Impact Report (EIR). Their purpose is to disclose to the public all of the potential direct and cumulative environmental impacts that could result from implementation of the logging plan. The THP includes provisions to protect water, wildlife, archaeology sites, plants, and the health and safety of workers and the public. THPs are prepared in coordination with community

Initial Study 12 TERMINAL 3 LOG STORAGE AND SHIPPING FACILITY groups and regulatory agencies such as the California Department of Fish and Wildlife, Regional Water Quality Control Board, and CALFIRE. THPs are also intended to provide sufficient information for the Director of CALFIRE to make a determination that the proposed logging conforms to the Forest Practice Act and the harvesting rules promulgated by the State Board of Forestry and Fire Protection. The THP goes through a two-tier review process that can take up to two years to achieve approval. Once a THP has been approved, CALFIRE Unit Forest Practice Inspectors periodically inspect the logging operation to ensure compliance with the THP and all applicable laws and regulations. Enforcement actions are taken on any identified violations, which can range from violation notices requiring corrective actions to assessment of civil fines to criminal charges. Replanting of trees is required on all forest lands following implementation of a THP.

Upon approval of the THP, the timber owner retains a Licensed Timber Operator (LTO) to harvest the timber. The harvest is subject to the guidelines defined in the THP and, as noted above, is subject to State penalty if the LTO does not comply. The facility at Terminal 3 would only accept logs from sites with an approved THP harvested by a LTO. During initial operations at the proposed facility, RJJ would prepare and export logs that originate from forests burned in fires that occurred in 2014.

Planning Approvals Conditional Use Permit: The project would require approval of a Conditional Use Permit (CUP) by the Richmond Planning Commission for a log storage and shipping facility use in the M-4 zoning district.

Other Approvals Richmond Fire Department: The project will require approval of a Permit to Operate from the Richmond Fire Department for storage of wood products, including hogged material.

San Francisco Bay Conservation and Development Commission (BCDC): Although the project is not expected to require authorization from the San Francisco Bay Conservation and Development Commission, it is possible that compliance with one of the mitigation measures identified in this Initial Study may require approval from BCDC. See Section IX, Hydrology and Water Quality, for additional information.

State Water Resources Control Board (SWRCB): The project will require filing of a Notice of Intent (NOI) with the State Water Resources Control Board for coverage under the National Pollutant Discharge Elimination System (NPDES) Industrial General Permit (IGP) administered by the SWRCB. This requires preparation and implementation of a Stormwater Pollution Prevention Plan (SWPPP) that addresses control of stormwater pollution through implementation of Best Management Practices (BMPs). See Section IX, Hydrology and Water Quality, for additional information.

U.S. Environmental Protection Agency (EPA): The project will require filing of a Notice of Intent (NOI) with the U.S. Environmental Protection Agency (EPA) to obtain coverage under the NPDES Vessel General Permit (VGP) issued by the EPA. This permit authorizes incidental operational discharges from ocean-going vessels.

9. Site Description and Surrounding Land Uses: The project site is an industrial port property developed with a large warehouse and a small administrative office building. Aside from these buildings and a small guard house, the majority of the approximately 20-acre Terminal 3 site consists of asphalt pavements. The

Initial Study TERMINAL 3 LOG STORAGE AND SHIPPING FACILITY 13 concrete wharf at the waterfront measures 1,009 feet long by 105 feet wide. Additional details about the property are provided above in the discussion of the existing Terminal 3 facilities.

Immediately north of Terminal 3 is Terminal 2, another Port of Richmond property occupying approximately 8 acres that is developed with storage tanks, warehouses, and two cranes, and is used for the storage and distribution of bulk liquids. Immediately to the south of the project site is a portion of Terminal 3 that is leased separately from the Port and is used for temporary storage of imported Toyota automobiles. South of this southern end of Terminal 3 is a public parking lot and a short shoreline segment of the San Francisco Bay Trail, with access to a fishing pier. This site is also planned to include the Richmond Ferry terminal and associated parking lot.

The eastern side of Terminal 3 is bounded Harbour Way South, which has its southern terminus just to the south of Terminal 3. On the west side of Harbour Way South is the historic Ford Assembly Building (FAB) that was used for the assembly of jeeps and tanks during World War II. It now houses the Rosie the Riveter WWII Home Front National Historical Park and offices for businesses including Sunpower Corporation and Mountain Hardware, Inc. It also includes the Craneway Pavilion, a 45,000-square-foot space available for a wide range of events including conferences, banquets, fairs, exhibitions, performances, sporting events, workshops, dance classes, etc. A large parking lot is located on the north end of the FAB that has parking for 1,200 autos.

Terminal 3 is located on the west side of a small peninsula on the southern Richmond shoreline that is defined by Harbor Channel and Santa Fe Channel on the west and by Marina Bay, which harbors the Richmond Yacht Club, on the east. West of the FAB are a large vacant parcel adjacent to the shoreline and a large office building that previously housed municipal offices for the City of Richmond and is now partially used by Comcast. To the east of this building, on the east side of Marina Way South, are offices leased by Chevron and West Contra Costa Unified School District. Other uses occupying the buildings include Amethod Charter School and Babbaloo Cafe. Lucretia Edwards Shoreline Park is located on the southeast corner of the peninsula.

East of the northern end of Terminal 3 is a large warehouse/light industrial building that appears to house several companies and has space available for lease. To the east of this building is a large two-story building housing offices of Contra Costa County public agencies.

Just to the north of Terminal 2 is the California Oils Corporation (CalOils), which imports, processes, and distributes vegetable oils in bulk. Adjacent to CalOils is the Levin Richmond Terminal Corporation, which operates a dry bulk cargo marine terminal on the Santa Fe Channel. There are a variety of other industrial uses, many of them port-related, located to the north of Terminal 2.

West of the project site, on the other side of the Harbor Channel that feeds into the Santa Fe Channel, is Point Potrero, another peninsula defining the southern Richmond shoreline. The east side of the peninsula is developed entirely with industrial uses, most of which utilize the port facilities on the Harbor Channel/Santa Fe Channel for transport of products and materials. Companies in this area include Arco (petroleum), Conoco/Phillips (petroleum), Kinder Morgan (natural gas), National Gypsum (drywall, cement board), BP Castrol (petroleum), and Burlington Northern Santa Fe Railroad (BNSF). The southern end of Point Potrero is developed with the Point Potrero Marine Terminal, which is used to import and distribute automobiles from Asia, including Honda, Hyundai, and Kia brands.

Initial Study 14 TERMINAL 3 LOG STORAGE AND SHIPPING FACILITY

ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:

The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages.

Aesthetics Agricultural Resources X Air Quality

Biological Resources Cultural Resources X Geology/Soils

Greenhouse Gas Emissions Hazards & Haz. Materials X Hydrology/Water Quality

Land Use/Planning Mineral Resources Noise

Population/Housing Public Services Recreation

Transportation/Traffic Utilities/Service Systems

X Mandatory Findings of Significance

Initial Study TERMINAL 3 LOG STORAGE AND SHIPPING FACILITY 15

EVALUATION OF ENVIRONMENTAL IMPACTS:

I. AESTHETICS — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Have a substantial adverse effect on a scenic vista? ⌧

Explanation: The project site is situated near the shoreline of San Francisco Bay, which provides many scenic vistas. However, in the immediate vicinity of the project site the availability of scenic views is quite limited. The existing shed warehouse on the eastern edge of the site serves to block views across most of the project site from public vantage points on Harbour Way South.

South of the warehouse, one can view west across the site to the hillsides on the opposite side of Harbor Channel and can see the more distant mountains in Marin County, more than 10 miles to the west. The scenic quality of the more proximate hillsides of Point Potrero is substantially reduced by the presence of large petroleum tank fields both on top of the hills and in the foreground along the western shoreline of Harbor Channel. Other industrial development along the western shoreline of the channel further mars the views in this area.

North of the warehouse, the views across the project site would not be considered scenic by most viewers. The view is dominated by two large cranes and several warehouse buildings on the Terminal 2 property and by the existing Terminal 3 warehouse. The Point Potrero hillsides are substantially obscured by shoreline industrial development and moored ships, and are dominated by the tank farm at the top of the hills.

While public views from Harbour Way South to the north, east, and south are dominated by industrial and light industrial development and would by no means be considered scenic, the proposed project would in any event have no effect whatsoever on these views.

The proposed project would not develop new structures with the potential to block or adversely affect scenic vistas. The site has been used for various port-related uses for many years; the proposed project would introduce new uses and activities that would be consistent with the historical use of the site. As noted above, the availability of scenic views across the project site is limited at best, but the proposed stockpiles of logs awaiting shipment would have very little effect on existing views because the stockpile area would be located to the west of the existing warehouse, which already blocks views to the west entirely. Although the front loaders and other equipment would be parked to the southwest of the warehouse, and thus visible from Harbour Way South, views from the roadway across this portion of the project site are already constrained by the two-story administrative office building, and the addition of construction equipment on the far side of the paved terminal area would not substantially alter existing views.

As described above, the availability of scenic views in the immediate vicinity of the project is very limited at best, and it could be argued that there are no scenic vistas in the vicinity. The project would have a minor effect on the public views that are available across the project site. For these reasons, the project would have a less-than-significant impact on a scenic vista.

Initial Study TERMINAL 3 LOG STORAGE AND SHIPPING FACILITY 17

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic ⌧ buildings within a state scenic highway?

Explanation: There are no State-designated scenic highways in the vicinity of the project site.1 Furthermore, there are no scenic resources on the project site. Therefore, the project would have no effect on scenic resources.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Substantially degrade the existing visual character or quality of the site and its surroundings? ⌧

Explanation: The existing visual quality of the project site is generally low, dominated by the large warehouse present on the east side of the site. The harshness of the view of the site from Harbour Way South is substantially softened by street trees planted every 10 to 15 feet along the site frontage, interspersed with shrubs. Other than the warehouse, the site primarily consists of a small office building, a guard house, and an extensive expanse of asphalt pavement. The only trees on or adjacent to the site are those along the west side of Harbour Way South, within the public right-of-way.

The proposed project would not substantially alter the existing visual character of the site. The large warehouse and two smaller structures would be retained and no new structures would be constructed. While the applicant would make some tenant improvements to the first floor of the administrative office building, these improvements would be to the interior of the building and would not be visible on the exterior of the building or from offsite locations.

The only substantial change to the site would result from the stockpiling of logs. The majority of the logs would be stockpiled on the Debarked Logs Deck that would be located west of the warehouse building. As discussed in Section I-a, above, this building would block most views of the log stockpile from offsite locations. Oblique views of the southern end of the stockpile would be visible from Harbour Way South at select vantage points south of the warehouse, though the office building would obscure the view from most locations.

There would also be some short-term stockpiling of logs that still have bark on in the Log Layout Yard at the north end of the site, though the piles of logs would be shorter in height than those stored on the Debarked Logs Deck. As previously noted, the view from Harbour Way South across this northern portion of Terminal 3 is dominated by ship cranes and warehouse buildings. The visual quality of the site is therefore low, and the intermittent presence of stockpiled logs would not substantially deteriorate the visual character of the site.

1 California Department of Transportation, Officially Designated State Scenic Highways, accessed September 7, 2015 at: http://www.dot.ca.gov/hq/LandArch/16_livability/scenic_highways/schwy.htm.

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The project site is located in an industrialized neighborhood characterized by large buildings and expansive parking areas, with no appealing natural features or aesthetic amenities in the immediate vicinity (though appealing Bay views are available elsewhere on the peninsula). The only people who would typically see the project site would be passing motorists—dominated by truck drivers—on Harbour Way South. These drivers would have only a passing glance at the portions of the site not already obscured from view, and would be unlikely to notice the visual changes that would be caused by the project.

There are no residences in the area and, based on numerous visits to the site and vicinity, there appear to rarely be any pedestrians on the sidewalks adjacent to the site. While occupants of the northwest corner of the Ford Assembly Building on the east side of Harbour Way South would be able to see the southern end of logs stockpiled on the Debarked Logs Deck, the minor visual changes would be noticeable only to a small number of workers in the business(es) located in this corner of the FAB.

For all of the considerations enumerated above, the project would have a less-than-significant impact on the visual character of the site.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the ⌧ area?

Explanation: The proposed project would not result in the introduction of new glare or a substantial source of new nighttime lighting. New exterior lighting would be installed on the west side of the existing warehouse building to illuminate the Debarked Logs Deck. The visibility of this new lighting would be limited by the same factors discussed in Section I-a, above. Since there are no residences in the vicinity of the project and no residences on Point Potrero west of Harbor Channel with visual sight lines to the project site, there are no sensitive visual receptors in the vicinity of the site who would be affected by new nighttime lighting. The lighting would not be extensive or out of character with outdoor security lighting present at many of the industrial sites in the project area. Furthermore, the lighting would be required to conform with the lighting and glare standards established in Richmond Municipal Code Section 15.04.840.040, which prohibit the production of glare on public streets and adjacent parcels. The regulations also require lighting to be shielded at lot lines so as not to be directly visible from an adjoining residential district. Therefore, the project’s light and glare impacts would therefore be less than significant.

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II. AGRICULTURAL RESOURCES — In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the State’s inventory of forest land, including the Forest and Range Assessment Project and the Forestry Legacy Assessment Project, and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the ⌧ California Resources Agency, to non-agricultural use?

Explanation: The project site and all surrounding lands are designated “Urban and Built–Up Land” on the maps prepared pursuant to the Farmland Mapping and Monitoring Program (FMMP) by the Department of Conservation (DOC), a department of the California Resources Agency.2 The DOC updates the maps every two years; the most recent map was prepared in 2012 and published in 2014. Since the project site does not contain any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, there is no potential for conversion of these types of farmlands.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? ⌧

Explanation: The project property is not zoned for agricultural use or under a Williamson Act contract.

2 California Department of Conservation, Division of Land Resource Protection, Farmland Mapping and Monitoring Program, “Contra Costa County Important Farmland 2012” (map), April 2014.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)), timberland (as defined in Public Resources Code Section 4526), or timberland zoned ⌧ Timberland Production (as defined by Government Code Section 51104(g))?

Explanation: The project site is not zoned as forest land and there is no forest land on the site. The proposed project would therefore have no impact on forest or timber land.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Result in the loss of forest land or conversion of forest land to a non-forest use? ⌧

Explanation: Public Resources Code Section 12220(g) defines forest land as land that can support 10-percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits. There is no forest land on the project site as defined in Public Resources Code Section 12220(g).

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or ⌧ conversion of forest land to non-forest use?

Explanation: The project site does not contain farmland or forest land, and implementation of the proposed project would therefore have no potential to convert such lands to other uses.

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III. AIR QUALITY — Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Conflict with or obstruct implementation of the applicable air quality plan? ⌧

Explanation: The Bay Area Air Quality Management District (BAAQMD) adopted its 2010 Bay Area Clean Air Plan (CAP) in accordance with the requirements of the California Clean Air Act (CCAA) to implement all feasible measures to reduce ozone; provide a control strategy to reduce ozone, particulate matter, air toxics, and greenhouse gas (GHG) emissions in a single, integrated plan; and establish emission control measures to be adopted or implemented in the 2010 through 2012 timeframe.3 The primary goals of the 2010 Bay Area CAP are to: • Attain air quality standards; • Reduce population exposure and protect public health in the Bay Area; and • Reduce GHG emissions and protect the climate. On January 10 of 2017, the BAAQMD released the Draft 2017 Clean Air Plan.4 The 2017 Clean Air Plan/Regional Climate Protection Strategy (CAP/RCPS) provides a roadmap for BAAQMD’s efforts over the next few years to reduce air pollution and protect public health and the global climate. The CAP/RCPS includes the Bay Area’s first-ever comprehensive RCPS, which identifies potential rules, control measures, and strategies that the BAAQMD can pursue to reduce GHG in the Bay Area. Measures of the 2017 CAP addressing the transportation sector are in direct support of Plan Bay Area, which was prepared by the Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC) and includes the region’s Sustainable Communities Strategy and the 2040 Regional Transportation Plan. Highlights of the Draft 2017 Clean Air Plan control strategy include: • Limit Combustion: Develop a region-wide strategy to improve fossil fuel combustion efficiency at industrial facilities, beginning with the three largest sources of industrial emissions: oil refineries, power plants, and cement plants. • Stop Methane Leaks: Reduce methane emissions from landfills and oil and natural gas production and distribution. • Reduce Exposure to Toxics: Reduce emissions of toxic air contaminants by adopting more stringent limits and methods for evaluating toxic risks at existing and new facilities. • Put a Price on Driving: Implement pricing measures to reduce travel demand.

3 In 2015, the BAAQMD initiated an update to the 2010 CAP. On February 28, 2014, the District held a public meeting to report progress on implementing the control measures in the 2010 CAP, to solicit ideas and strategies to further reduce ozone precursors, particulate matter, toxic air contaminants, and greenhouse gases, and to seek input on innovative strategies to reduce greenhouse gases, mechanisms for tracking progress in reducing GHGs, and how the District may further support actions to reduce GHGs. The culmination of this effort will be an updated CAP. 4 Bay Area Air Quality Management District, Draft 2017 Clean Air Plan, January 10, 2017, http://www.baaqmd.gov/ ~/media/files/planning-and-research/plans/2017-clean-air-plan/baaqmd_2017_cap_draft_122816-pdf.pdf?la=en

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• Advance Electric Vehicles: Accelerate the widespread adoption of electric vehicles. • Promote Clean Fuels: Promote the use of clean fuels and low or zero carbon technologies in trucks and heavy-duty vehicles. • Accelerate Low Carbon Buildings: Expand the production of low-carbon, renewable energy by promoting on-site technologies such as rooftop solar and ground-source heat pumps. • Support More Energy Choices: Support community choice energy programs throughout the Bay Area. • Make Buildings More Efficient: Promote energy efficiency in both new and existing buildings. • Make Space and Water Heating Cleaner: Promote the switch from natural gas to electricity for space and water heating in Bay Area buildings.

When a public agency contemplates approving a project where an air quality plan consistency determination is required, BAAQMD recommends that the agency analyze the project with respect to the following questions: (1) Does the project support the primary goals of the air quality plan; (2) Does the project include applicable control measures from the air quality plan; and (3) Does the project disrupt or hinder implementation of any 2010/2017 CAP control measures? If the first two questions are concluded in the affirmative and the third question concluded in the negative, the BAAQMD considers the project consistent with air quality plans prepared for the Bay Area.

Any project that would not support the 2010/2017 CAP goals would not be considered consistent with the 2010/2017 CAP. The recommended measure for determining project support of these goals is consistency with BAAQMD CEQA thresholds of significance. As presented in the subsequent impact discussions, the proposed project would not exceed the BAAQMD significance thresholds; therefore, the proposed project would support the primary goals of the 2010/2017 CAP.

The proposed project would support the primary goals of the 2010 CAP and would be consistent with all applicable 2010/2017 CAP control measures, and would not disrupt or hinder implementation of any 2010/2017 CAP control measures. Therefore, there would have a less-than-significant impact associated with, conflicting with, or obstructing implementation of the applicable air quality plan. The air quality setting and regulatory context are described in Appendix AQ–1.

A number of regulations and rules promulgated by BAAQMD, California Air Resources Board (CARB), US Environmental Protection Agency (USEPA), and other agencies with direct application of emission sources within ports, in general, and the Port of Richmond, specifically, are discussed further within Appendix AQ–1. They include the following: • Fuel Sulfur and Other Operational Requirements for Ocean-going Vessels within California Waters and 24 Nautical miles of the California Baseline (California Code of Regulations [CCR], Title 13, Section 2299.2) • Airborne Toxic Control Measure for Auxiliary Diesel Engines Operated on Ocean-Going Vessels At-Berth in a California Port (CCR, Title 17, Section 93118.3) • Airborne Toxic Control Measure for Commercial Harbor Craft (CCR, Title 17, Section 93118.5) • California’s Drayage Truck Regulation (CCR, Title 13, Section 2027)

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• Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards • Heavy-Duty Vehicle Idling Emission Reduction Program • General Requirements for In-Use Off-Road Diesel Fueled Fleets (CCR, Title 13, Section 2449) • On-Road Heavy-Duty Diesel Vehicles (In-Use) Regulation • Off-Road Large Spark-Ignition (Gasoline and Propane) Equipment Regulation • California Low Sulfur Diesel Regulations • Standards for Nonvehicular Diesel Fuel Used in Diesel-Electric Intrastate Locomotives and Harbor Craft (CCR Title 13, Section 2299)

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Violate any air quality standard or contribute substantially to an existing or projected air quality ⌧ violation?

Explanation: The following discussion describes the project parameters that were factored in to the quantified analysis of the air pollutant emissions that would be generated by the proposed project. The project includes the development and operation of a log export facility at an existing facility at the Port of Richmond, on an approximately 12.2-acre site. The proposed facility would receive logs by truck from a site in West Sacramento that would be prepared for shipment, then loaded onto ocean-going ships while berthed at Terminal 3. It is anticipated that approximately ten truckloads of logs would be delivered to the proposed facility each weekday. Log trucks would begin travel at a site in West Sacramento, which is within the Yolo-Solano Air Quality Management District (YSAQMD). Approximately halfway to the proposed facility, logging trucks would cross over into the BAAQMD. Log truck trip lengths were estimated to be 148 miles per round trip (80 miles within BAAQMD and 68 miles within YSAQMD). Within EMFAC2014, the log trucks were classified as T7 tractor trucks; which is a heavy-heavy-duty tractor truck. The emissions associated with log truck trips were based on a CARB Truck and Bus Regulation Reporting inventory for RJJ International, which includes a total of nine logging trucks of varying model year from 2008, 2010, and 2011.

Logs arriving with bark still on would be debarked and removed bark would be picked up in 25-ton semi-trailer trucks and hauled to end markets in the Bay Area. It is anticipated that one to two truckloads of bark would be hauled away each week. Bark trucks were assumed to begin in Tracy, pick up their loads at the proposed project site, and drop them off in Milpitas. Therefore, bark truck trip lengths were estimated to be 113 miles per round trip; entirely within the BAAQMD. Within EMFAC2014, the bark trucks were also classified as T7 tractor trucks.

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Normal operating hours for the proposed facility would be Monday through Friday from 6 a.m. to 6 p.m. and receiving hours for loaded log trucks would be from 7 a.m. to 5 p.m. During standard operational periods, there would be five employees working at the proposed facility and during periodic ship-loading operations, 16 longshoremen would be temporarily employed, for a total of 21 workers on site.

Truck and Mobile Equipment Emissions Operational equipment at the proposed facility would include an excavator, front loader with claws, debarker, and street sweeper. The debarker is addressed separately below in the discussion of fugitive dust emissions. All mobile equipment would be from 2011 model years or more recent and would meet the current requirements of CARB for marine cargo handling equipment, which require Tier 4 engines5 and annual opacity testing of particulate matter in the diesel exhaust.6

Analyzed air quality pollutants include: carbon monoxide (CO), reactive organic compounds (ROG), nitrogen oxides (NOx), sulfur dioxide (SO2), particulate matter equal to or less than 10 micrometers (coarse particulates or PM10), and particulate matter equal to or less than 2.5 micrometers (fine particulates or PM2.5). The emissions generated from the proposed project include combustion emissions of criteria air pollutants (ROG, NOx, CO, PM10, and PM2.5) primarily from operation of onsite equipment, marine vessels (bulk carriers),7 harbor craft, haul trucks, (primarily diesel-operated), and worker automobile trips (primarily gasoline-operated).

The construction activities associated with the proposed project would be minimal and the air emissions would be considered less than significant.8 Thus, the air quality analysis focuses on operational impacts on air quality.

CARB’s OFFROAD emissions inventory model was used to estimate emissions from off-road operational equipment such as excavators and loaders.9 CARB’s EMFAC2014 emissions inventory model was used to estimate emissions from truck trips and worker automobile trips.10 USEPA’s Current Methodologies in Preparing Mobile Source Port-Related Emissions and other guidance was used to estimate emissions from marine vessel operations.11 Air quality calculations and assumptions are described in Appendix AQ–2.

Estimated average daily and annual operational emissions associated with the proposed project that would occur within the YSAQMD are presented in Tables AQ–1 and AQ–2 and are compared to the YSAQMD thresholds of significance. Only log truck operations would occur within YSAQMD. As indicated in Tables AQ–1 and AQ–2, the estimated proposed project

5 Emission Standards Nonroad Diesel Engines, https://www.dieselnet.com/standards/us/nonroad.php 6 Tier 4 onsite equipment reduces annual NOx emissions by 1.5 tons and other pollutants by less than 0.1 tons. 7 Bulk carriers are vessels used to transport bulk items such as mineral ore, fertilizer, wood chips, or grain. 8 Terminal 3 is already a fully developed Port of Richmond facility. To accommodate the proposed facility, improvements in the first floor of the terminal building, which would include reinstallation of the electrical system, would be made. In addition, exterior lighting would be installed along the west side of the terminal shed, along with a surveillance system. The existing scales adjacent to the administration building would also be repaired. No other construction or improvements would be required for the proposed project. 9 California Air Resources Board, OFFROAD Instructions, http://www.arb.ca.gov/msprog/ordiesel/info_ 1085/oei_write_up.pdf. 10 California Air Resources Board, EMFAC User’s Guide, December 30, 2014, http://www.arb.ca.gov/ msei/emfac2014_users_guide.pdf. 11 US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emissions, April 2009, http://trid.trb.org/view.aspx?id=927750, Emissions Estimation Methodology for Ocean-Going Vessels, May 2008, http://www.arb.ca.gov/regact/2008/fuelogv08/appdfuel.pdf, and Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, http://www3.epa.gov/otaq/models/nonrdmdl/c-marine/r00002.pdf.

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operational emissions would be below the YSAQMD’s significance thresholds and would have a less-than-significant impact on air quality within the YSAQMD jurisdiction.

Table AQ–1 Estimated Average Daily Project Operational Emissions in the YSAQMD (pounds per day)

Condition ROG NOx PM10 PM2.5 CO

Log Trucks 0.36 11.5 0.06 0.05 1.14 Total Proposed Project 0.36 11.5 0.06 0.05 1.14 Significance Threshold –– –– 80 –– –– Significant (Yes or No)? No No No No No

Source: California Air Resources Board, EMFAC2014

Notes: See Appendix AQ–2 for air quality calculations and assumptions. Average daily emissions over the project duration of 160 days per year.

Table AQ–2 Estimated Average Daily Project Operational Emissions in the YSAQMD (tons per year)

Condition ROG NOx PM10 PM2.5 CO

Log Trucks 0.03 0.92 <0.01 <0.01 0.09 Total Proposed Project 0.03 0.92 <0.01 <0.01 0.09 Significance Threshold 10 10 –– –– –– Significant (Yes or No)? No No No No No

Source: California Air Resources Board,EMFAC2014

Note: See Appendix AQ–2 for air quality calculations and assumptions.

Estimated average daily and annual operational emissions associated with the proposed project that would occur within the BAAQMD are presented in Tables AQ–3 and AQ–4 and are compared to BAAQMD’s thresholds of significance. As indicated in Tables AQ–3 and AQ–4, the estimated proposed project operational emissions would be below the BAAQMD’s significance threshold and thus, would have a less-than-significant impact on air quality within the BAAQMD jurisdiction.

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Table AQ–3 Estimated Average Daily Project Operational Emissions in the BAAQMD (pounds per day)

Condition ROG NOx PM10 PM2.5 CO

Onsite Equipment 0.61 1.31 0.07 0.06 12.1 Debarker — — 2.31 1.16 — Marine Vessels – Main Engines 1.44 23.5 0.49 0.45 2.33 Marine Vessels – Auxiliary Engines 0.20 6.82 0.12 0.11 0.54 Marine Vessels – Auxiliary Boilers 0.08 2.75 0.05 0.05 0.22 Harbor Craft 0.02 1.61 0.05 0.05 0.38 Log Trucks 0.43 13.5 0.06 0.06 1.35 Bark Trucks 0.14 3.53 0.04 0.04 0.49 Worker Automobiles 0.05 0.25 0.02 0.02 0.80 Total Proposed Project 2.97 53.3 3.21 2.00 18.2 Significance Threshold 54 54 82 54 –– Significant (Yes or No)? No No No No No

Source: CARB EMFAC2014 Notes: See Appendix AQ–2 for air quality calculations and assumptions. Average daily emissions over the project duration of 160 days per year.

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Table AQ–4 Estimated Average Daily Project Operational Emissions in the BAAQMD (tons per year)

Condition ROG NOx PM10 PM2.5 CO

Onsite Equipment 0.05 0.10 0.01 <0.01 0.97 Debarker — — 0.18 0.09 Marine Vessels – Main Engines 0.12 1.88 0.04 0.04 0.19 Marine Vessels – Auxiliary Engines 0.02 0.55 0.01 0.01 0.04 Marine Vessels – Auxiliary Boilers 0.01 0.22 <0.01 <0.01 0.02 Harbor Craft <0.01 0.13 <0.01 <0.01 0.03 Log Trucks 0.04 1.16 0.01 0.01 0.11 Bark Trucks <0.01 0.06 <0.01 <0.01 0.01 Worker Automobiles <0.01 0.02 <0.01 <0.01 0.06 Total Proposed Project 0.24 4.12 0.25 0.15 1.43 Significance Threshold 10 10 15 10 –– Significant (Yes or No)? No No No No No

Source: CARB EMFAC2014 Note: See Appendix AQ–2 for air quality calculations and assumptions.

Fugitive Dust Emissions Fugitive dust emissions (i.e., emissions released through means other than through a stack or tailpipe, such as log/bark material handling and travel on unpaved surfaces) can create nuisances and localized health impacts. Operational fugitive dust emissions would vary from day to day, depending on the level and type of activity, the type of material being handled, and the weather. High winds (greater than 10 miles per hour) occur infrequently in the area, less than 10 percent of the time. In the absence of mitigation, material handling activities may result in significant quantities of dust. A fugitive dust control efficiency of over 50 percent due to daily watering and other reduction measures (e.g., limiting vehicle speed to 15 mph, management of stockpiles, screening process controls, etc.) is typical.

A conveyor would feed logs not already stripped of bark into a 43-inch electric-power Salem debarker that would mechanically strip the bark. Removed bark would be discharged into a debris container that would be regularly emptied. Some fugitive dust would be generated by these stripping and discharge activities. A street sweeper would clean the site daily to keep it free of debris and to control dust. To estimate the PM10 and PM2.5 emissions from the debarker, the emission factor from USEPA’s AP-42 and other appropriate guidance of 0.024 pounds total suspended particulate (TSP) per ton of logs was applied to the throughput quantity of wood expected to be prepared.12, 13 Approximately 50 percent of the particulate emissions are assumed

12 US Environmental Protection Agency, Particulate Matter Potential to Emit Emission Factors for Activities at Sawmills, Excluding Boilers, Located in Pacific Northwest Indian County, May 8, 2014, http://www3.epa.gov/ region10/pdf/air/technical/spmpteef_memo.pdf.

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to be PM10 and approximately 25 percent of the particulate emissions are assumed to be PM2.5. Water suppression, enclosures, or other methods would provide 50-percent abatement of particulate emissions. Water suppression, enclosures, or other methods would provide at least 50 percent abatement of particulate emissions.

Air emissions generated from truck movement, material handling, and debarker operations may include dust (including PM10 and PM2.5) from “fugitive” sources (i.e., emissions released through means other than through a stack or tailpipe) such as from truck movement, material handling, and debarker operations as well as combustion emissions from marine vessels, onsite equipment, and haul trucks.

As discussed in the introduction to this Initial Study (page 2), the City of Richmond previously issued an Initial Study for the proposed project and circulated it for a 30-day public review period during which comment letters were submitted by public agencies and by companies operating in the vicinity of Terminal 3. A comment letter submitted by Mountain Hardwear (see Appendix A for a copy of the letter), a tenant in the Ford Assembly Building located immediately east of Terminal 3, raised concerns about dust, noise, and other potential impacts of the proposed project. The issues raised in the Mountain Hardwear letter and other comment letters are addressed, as appropriate, in various technical sections of this revised Initial Study, while the concern about dust is addressed here.

As alluded to in the comment letter, log preparation operations have already been occurring at Terminal 3 in recent months, though no debarking has occurred and no loading of ships or export by ships has occurred. During these interim operations, harvested logs are received by truck from California forests and/or RJJ’s log processing facility in West Sacramento. They are then loaded into shipping containers that are trucked to the Port of Oakland for export to China. In some cases, logs arrive from more southerly origins that have not been debarked, in which case they are loaded back onto trucks and taken to the West Sacramento facility for debarking.

At the time Mountain Hardwear’s comment letter was submitted to the City, the log preparation activities at Terminal 3 were utilizing the southern site entrance, located across the road from the Mountain Hardwear offices, for truck deliveries of logs and truck departures. In response to a request from City staff, RJJ Resource Management, the site operator, has since shifted these operations to the north entrance, which is located about 950 feet north of the Mountain Hardwear offices. In addition, log handling operations were shifted away from the southern portion of the Terminal 3 property to the northern end. As a result, the generation of dust and wood debris near the Ford Assembly Building has been substantially reduced. Whereas there was previously an unobstructed noise and dust pathway from the truck and log handling operations to the Mountain Hardwear offices, the large mass of the Terminal 3 warehouse building (approximately 800 feet long) now substantially blocks the migration toward the Ford Assembly Building of both noise and dust, and the additional separation of distance provides further reduction in these effects. Dust and noise were not observed to be a problem inside or outside of the Mountain Hardwear offices when noise measurements were conducted inside the Mountain Hardwear offices on June 30, 2016 during active log preparation operations. (The results of the noise measurements are discussed in Section XII, Noise.) The Mountain Hardwear manager accompanying the CEQA team during noise measurements acknowledged that since the submittal of their May 10, 2016 comment letter—and following the operational changes described above—dust, noise, and vibration impacts were no longer creating problems at the Mountain Hardwear offices.

13 Bay Area Air Quality Management District, Permit Handbook, Section 11.13 Tub Grinders, April 15, 2008, http://hank.baaqmd.gov/pmt/handbook/rev02/PH_00_05_11_13.pdf.

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Mitigation Measure AQ–1 identifies additional measures to be implemented by the project that are expected to further reduce the generation of dust and the offsite dissemination of bark particles and other wood debris; these measures had not been implemented at the time of the observations and noise measurements taken inside the Mountain Hardwear offices. Additional requirements have been added to Mitigation Measure AQ–1 since publication of the previous Initial Study that will further minimize the generation and migration of dust during project operations. In addition, the City will require as a condition of approval that the operator increase the frequency of site watering, street sweeping, and site sweeping as necessary to control dust and debris, and in response to complaints.

Fugitive dust emissions would vary from day to day, depending on the level and type of activity, silt content of the material, and the weather. In the absence of mitigation, activities may result in significant quantities of dust, and as a result, local visibility and PM10 concentrations may be adversely affected on a temporary and intermittent basis. In addition, the fugitive dust generated by truck movement, material handling, and debarker operations would include not only PM10, but also larger particles, which would fall out of the atmosphere within several hundred feet of the site and could result in nuisance-type impacts. Absent appropriate mitigation, the fugitive dust emissions from the proposed project would be a potentially significant impact. BAAQMD’s CEQA Air Quality Guidelines require a number of best management practices to control fugitive dust emissions. Accordingly, implementation of the following measures would reduce the impact to a less-than-significant level:

Mitigation Measure AQ–1: Fugitive Dust and Combustion Exhaust Control Measures: The Applicant shall reduce air emissions by implementing the following fugitive dust control measures, including: • Compliance with Bay Area Air Quality Management District’s (BAAQMD’s) Particulate Matter and Visible Emissions Regulation shall be maintained. • All equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. • All haul trucks transporting mulch/bark materials along public streets shall secure loads consistent with the current California State Vehicle Code. • The Applicant shall use dust-proof chutes to load mulch/bark materials into trucks whenever feasible. • The Applicant shall use a front end loader to pick up large debris and a wet power vacuum street sweeper, as necessary, to clear mulch/bark materials from adjacent public roads. If visible track-out extends more than 50 feet from the exit point onto an adjacent public road, mulch/bark materials shall be removed immediately. The wet power vacuum street sweepers shall be one of the models certified by the South Coast Air Quality Management District (SCAQMD) under SCAQMD Rule

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1186.14 The use of dry power sweeping shall be prohibited. • The wet power vacuum street sweeper shall be operated on the Terminal 3 property at least twice a day or, as necessary in response to complaints, to control dust in areas where log handling and log processing operations are occurring. • All vehicle speeds within the facility property shall be limited to 15 miles per hour. • Log and bark trucks shall utilize the north gate to access the facility instead of the south gate. Log unloading and handling shall occur north of the southern end of the log deck. • The installation of dust enclosures, curtains, and dust collectors at the debarker is not practical. Any fugitive dust generated by the debarker would be contained, within the building. However, once operation commences, should the operation produce fugitive dust that migrates from the building, the Applicant shall install additional measures to prevent the release of fugitive dust. Dust control shall include, but not limited to, water spray at transfer points, such as stockpiling from conveyors, front-end loading of materials to vehicular transport, bin transfer to vehicular transport, and minimizing drop heights when transferring any mulch/bark materials. • All mulch/bark material stockpiles shall be stored in a green waste trailer that has four walls and an open top. The green waste trailer shall be covered during periods of inactivity. • Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California Airborne Toxics Control Measure Title 13, Section 2485 of California Code of Regulations). Clear signage pertaining to idling time shall be provided for haul trucks at all access points. • All equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. • A publically visible sign shall be posted with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action with 48 hours. The

14 Certified Street Sweeper, June 1, 2016, http://www.aqmd.gov/docs/default-source/rule-book/support- documents/rule-1186/certified-street-sweepers-equipment-list.pdf?sfvrsn=2

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BAAQMD’s phone number shall also be visible to ensure compliance with applicable regulations. • The Applicant shall plant tree windbreaks along the eastside of the facility in the areas not already shielded by the existing Terminal 3 building.

Mitigation Measure AQ–2: The project applicant shall require that all trucks transporting logs to or from the Port of Richmond Terminal 3 Storage and Shipping Facility utilize 2008 model year or newer tractors.

Mitigation Measure AQ–3: The project applicant shall use shore power to provide electricity to the project-related ships instead of using the auxiliary engines, where/when feasible.

Mitigation Measure AQ–4: Diesel powered equipment shall not be left inactive and idling for more than five minutes, and shall comply with applicable BAAQMD rules. All off-road equipment (e.g., loaders and forklifts) greater than 25 horsepower (hp) and operating for more than 20 total hours over the entire duration of construction activities shall meet the following requirements: • Where access to alternative sources of power are available, portable diesel engines shall be prohibited; and • All off-road equipment shall have: • Engines that meet or exceed either USEPA or CARB Tier 3 off-road emission standards, and • Engines that are retrofitted with a CARB Level 3 Verified Diesel Emissions Control Strategy. Acceptable options for reducing emissions include the use of late model engines, low-emission diesel products, alternative fuels, engine retrofit technology, after-treatment products, add-on devices such as particulate filters, and/or other options as such are available.

Carbon Monoxide Emissions The BAAQMD has identified preliminary screening criteria for determining whether CO emissions would be exceeded. The screening criteria provide a conservative indication of whether the implementation of the proposed project would result in CO emissions that are potentially significant. This methodology utilizes the following screening criteria: 1. The proposed project is consistent with an applicable congestion management program established by the county congestion management agency for designated roads or highways, regional transportation plan, and local congestion management agency plans. 2. The proposed project traffic would increase traffic volumes at affected intersections to more than 44,000 vehicles per day. 3. The proposed project traffic would increase traffic volumes at affected intersections to more than 24,000 vehicles per day where vertical and/or horizontal mixing is

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substantially limited (e.g., tunnel, parking garage, bridge underpass, natural or urban street canyon, below-grade roadway).

The proposed project traffic would not cause the daily traffic volumes to exceed the screening criteria shown in items 1 through 3 based on the circulation infrastructure and the projected traffic volumes. Therefore, the proposed project would have a less-than-significant impact on air quality due to long-term operational CO exhaust emissions.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing ⌧ emissions which exceed quantitative thresholds for ozone precursors)?

Explanation: As shown in Tables AQ–1 through AQ–4, project-related operational emissions would be below the BAAQMD significance thresholds per BAAQMD’s CEQA Air Quality Guidelines. The BAAQMD CEQA Air Quality Guidelines recommend that cumulative air quality effects from criteria air pollutants also be addressed by comparison to the project-level daily and annual emission thresholds. These significance thresholds were developed to identify a cumulatively considerable contribution to a significant regional air quality impact. For this proposed project, as discussed in the preceding subsection, operational emissions from the project would be less than significant. Therefore, the proposed project would not be cumulatively considerable and cumulative impacts would be less than significant. Secondly, the health risk assessment was compared to the project-level thresholds and cumulative thresholds (See Appendix A, Table A-1). Cumulative health risk assessment sources (see item d below) include other Port of Richmond operations (including marine vessels, cargo handling, and rail activities), nearby permitted stationary sources, and traffic on Interstate 580. Additional analysis that includes other nearby planned projects is not required. Therefore, the project would have a less- than-significant cumulative impact on air quality.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Expose sensitive receptors to substantial pollutant concentrations? ⌧

Explanation: The discussion in this section is broken into two parts. The first part deals with the potential health risk from long-term exposure of sensitive receptors to air pollutant emissions generated by operation of the proposed project. The evaluation includes a health risk assessment that quantifies potential cancer risk and non-cancer health hazard. The second part of the discussion addresses additional analysis that was performed in response to a comment raised by Orton Development during the public review period of the previous Initial Study for the project published in April 2016 (see Appendix A). The comment noted that exposure to

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wood dust is associated with a variety of adverse health effects, including respiratory ailments and cancer. To evaluate this potential impact, the City retained the services of Forensic Analytical Consulting Services (FACS), a company with over 25 years of experience in environmental health services and eight offices nationwide. The evaluation report by a Certified Industrial Hygienist forms the basis of the second part of this section.15

Health Risk from Exposure to Toxic Air Contaminants According to BAAQMD’s CEQA Air Quality Guidelines and Air Toxics New Source Review Program Health Risk Screening Analysis Guidelines, health effects from carcinogenic air toxics are usually described in terms of individual cancer risk. Individual cancer risk is the likelihood that a person exposed to concentrations of toxic air contaminants (TACs) such as diesel particulate matter (DPM) over a 70-year lifetime will contract cancer, based on the use of standard risk- assessment methodology.16 The maximally exposed individual represents the worst-case risk estimate, based on a theoretical person continuously exposed for 30 years at the point of highest compound concentration in the air. This is a highly conservative assumption, since most people do not remain at home all day and on average residents change residences every 11 to 12 years. In addition, this assumption assumes that residents are experiencing outdoor concentrations for the entire exposure period.

BAAQMD considers the relevant zone of influence for an assessment of air quality health risks to be within 1,000 feet of a project site. Sensitive receptors such as residences, schools, and outdoor recreational areas near the proposed project were chosen as the receptors to be analyzed. The project site is located on the west side of Harbour Way South at its southern terminus, on the southern shoreline of the City of Richmond. The site is located on the east side of Harbor Channel, adjacent to the Richmond Inner Harbor on San Francisco Bay. The proposed project is approximately 3,500 feet (0.7 miles) south of Interstate 580. Sensitive receptors include the Ford Assembly Building, residences near Marina Park and Vincent Park (to the east), and recreational use at Lucretia Edwards Park and Vincent Park. The Benito Juarez Elementary School (at 1450 Marina Way South) is located approximately 1,350 feet to the southeast of the project site, outside of the 1,000-foot radius recommended by BAAQMD.

The BAAQMD has established a significance threshold for individuals exposed to TAC sources as the increased incremental cancer risk of 10 in one million or greater. This health risk assessment (HRA) analyzed the potential incremental cancer risks to sensitive receptors in the vicinity of the proposed project, using emission rates from CARB’s EMFAC2014 and OFFROAD emission models and USEPA’s guidance for marine vessels. Emission rates were input into the USEPA’s AERMOD (Version 15181) atmospheric dispersion model to calculate ambient air concentrations at receptors in the project vicinity.17

This HRA is intended to provide a worst-case estimate of the increased exposure by employing a standard emission estimation program, an accepted pollutant dispersion model, approved toxicity factors, and exposure parameters. These conservative health risk methodologies were used in order to estimate maximum potential health risks. These methodologies overestimate both non-carcinogenic and carcinogenic health risk, possibly by an order of magnitude or more. Therefore, for carcinogenic risks, the actual probabilities of cancer formation in the populations

15 Forensic Analytical Consulting Services, Employee Exposure to Wood Dust: Port of Richmond Terminal 3 Log Processing and Export Facility, FACS Project #PJ32463, January 31, 2017. 16 Bay Area Air Quality Management District. Air Toxics New Source Review Program Health Risk Screening Analysis Guidelines. January 2010. http://www.baaqmd.gov/~/media/Files/Engineering/Air%20Toxics%20Programs/hrsa_guidelines.ashx 17 US Environmental Protection Agency, AERMOD Modeling System, http://www.epa.gov/scram001/ dispersion_prefrec.htm.

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of concern due to exposure to carcinogenic pollutants are likely to be lower than the risks derived using the risk assessment methodology. The extrapolation of toxicity data in animals to humans, the estimation of concentration prediction methods within dispersion models, and the variability in lifestyles, fitness and other confounding factors of the human population also contribute to the overestimation of health impacts. Therefore, the results of this HRA are highly overstated.

In accordance with California Office of Environmental Health Hazard Assessment’s (OEHHA) Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments, this HRA was accomplished by applying the highest estimated concentrations of air toxics at the receptors analyzed to the established cancer potency factors and acceptable reference concentrations for non-cancer health effects.18 Appendix AQ–3 provides additional information on the methodology and assumptions used for this HRA.

Cumulative Health Impact Methodology The BAAQMD’s CEQA Air Quality Guidelines also include standards and methods for determining the significance of cumulative health risk impacts. The method for determining cumulative health risk requires the tallying of health risk from permitted stationary sources, major roadways, and any other identified substantial TAC sources in the vicinity of a project site (i.e., within a 1,000-foot radius) and then adding the individual sources to determine whether the BAAQMD’s cumulative health risk thresholds are exceeded. Results are summarized for the maximally exposed individual receptor.

Other operations within the Port of Richmond such as marine vessels (bulk carriers), harbor craft, cargo handling equipment, and rail operations were included as cumulative sources of health impacts.19 Secondly, the BAAQMD has developed a geo-referenced database of permitted stationary emissions sources throughout the San Francisco Bay Area and the Stationary Source Risk & Hazard Analysis Tool (May, 2012) for estimating cumulative health risks from the permitted sources. One permitted source is located within approximately 1,000 feet of the project site.

Lastly, BAAQMD has also developed a geo-referenced database of major roadways in the Bay Area and the Highway Screening Analysis Tool (May 2011) for estimating cumulative health risks from such roadways. No major roadways are within 1,000 feet of the project site. BAAQMD’s CEQA Air Quality Guidelines also require the inclusion of surface streets within 1,000 feet of the proposed project with annual average daily traffic of 10,000 vehicles or more.20 No nearby roadways meet these criteria.

Incremental Cancer Risk Cancer risk is the lifetime probability of developing cancer from exposure to carcinogenic substances. Following HRA guidelines established by OEHHA in Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments and by the BAAQMD in Recommended

18 Office of Environmental Health Hazard Assessment, 2015. Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments, http://oehha.ca.gov/air/hot_spots/hotspots2015.html. 19 The Port of Richmond operates a limited number of cargo-handling equipment. According to the 2005 inventory, these comprise two propane powered forklifts (operating for 810 hours per year) and three diesel-fueled general industrial equipment such as tractors (operating for 60 hours per year). 20 BAAQMD County Surface Street Screening Tables, May 2011 and CEHTP Traffic Linkage Service Demonstration, http://www.ehib.org/traffic_tool.jsp.

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Methods for Screening and Modeling Local Risks and Hazards, incremental cancer risks were calculated by applying established toxicity factors to modeled concentrations. 21

Health Impacts on Existing Residences, Schools, and Recreational Areas The construction activities associated with the proposed project would be minimal and the health impacts would be considered less than significant. The following describes the health risk assessment associated with existing receptors in the vicinity as a result of proposed project operations. Project operations include marine vessels, harbor craft, onsite equipment such as loaders, and haul (bark and log) trucks. The maximum DPM concentrations would occur at a residential receptor (also known as the MEI (maximally exposed individual)) within the Ford Assembly Building to the southeast of the proposed project. The maximum cancer risk from DPM emissions as a result of the proposed project for a residential receptor would be 2.9 per million persons. The maximum cancer risk from DPM emissions as a result of the proposed project for a school child receptor would be 0.1 per million persons. Thus, the cancer risk due to proposed project operations would be well under the BAAQMD threshold of 10 per million, and this would be a less-than-significant impact.

The estimated cancer risk impacts at the existing residence of the maximally exposed individual due to other Port of Richmond activities and other cumulative sources is 9.0 per million. The cumulative cancer risk from the proposed project and other nearby cumulative sources is 11.9 per million and thus, below the BAAQMD significance threshold of 100 per million. The cumulative cancer risk would therefore also be less than significant. The health impacts from the proposed project are generally low due to project design elements such as the use of Tier 4 onsite equipment, which reduces DPM emissions.

Non-Cancer Health Hazard Potential non-cancer health effects due to chronic exposure to DPM were also evaluated in the HRA. Both acute (short-term) and chronic (long-term) adverse health impacts unrelated to cancer were measured against a hazard index (HI), which is defined as the ratio of a project’s incremental DPM exposure concentration to a published reference exposure level (REL), as determined by OEHHA. To compute the total HI, individual ratios or Hazard Quotients (HQs) of each individual air toxic are added to produce an overall HI. If the overall HI is greater than 1.0, then the impact is considered to be significant.

The chronic reference exposure level for DPM as determined by OEHHA is 5 µg/m3. There is no acute REL for DPM. However, diesel exhaust does contain acrolein and other compounds, which do have an acute REL. Based on BAAQMD’s DPM speciation data, acrolein emissions are approximately 1.3 percent of the total DPM emissions. The acute REL for acrolein as determined by OEHHA is 2.5 µg /m3.22 Appendix AQ–3 provides additional information on the methodology used for the HRA.

The HRA modeling determined that both the acute and the chronic HI would be 0.01, well below the BAAQMD significance threshold of 1. The cumulative acute and chronic health impacts would also be well below the BAAQMD threshold of 10. The proposed project would therefore have a less-than-significant adverse acute and chronic health impact.

21 Bay Area Air Quality Management District, Recommended Methods for Screening and Modeling Local Risks and Hazards, May 2012. http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CEQA/Risk%20Modeling%20Approac h%20May%202012.ashx?la=en. 22 California Office of Environmental Health Hazards Assessment, Toxicity Criteria Database, 2010. http://www.oehha.ca.gov/tcdb/index.asp

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PM2.5 Concentration Dispersion modeling also estimated the exposure of sensitive receptors to project-related concentrations of PM2.5. The BAAQMD CEQA Air Quality Guidelines require inclusion of only PM2.5 exhaust emissions in this analysis; fugitive dust emissions are addressed under BAAQMD dust control measures and are required by law to be implemented during project construction. The annual PM2.5 concentration from proposed project operational activities would be 0.01 3 3 µg/m , while the annual cumulative PM2.5 concentration would be 0.3 µg/m . These concentrations would be below the respective BAAQMD significance thresholds of 0.3 µg/m3 and 0.8 µg/m3. The project would therefore have a less-than-significant impact on human health as a result of PM2.5 exhaust emissions from operation of the project. Employee Health Risk from Exposure to Airborne Wood Dust The tree species to be exported include: Douglas fir, white fir, ponderosa pine, and sugar pine.23 Wood dust exposure has been associated with numerous adverse health effects in employees working in the woodworking industry and may be associated with these tree species. Exposure to wood dust may occur via inhalation and skin and/or eye contact. Target organs include eyes, skin, and the respiratory system. Symptoms associated with inhalation of wood dusts include irritation of the eyes, nosebleeds, dermatitis, respiratory hypersensitivity, granulomatous,24 pneumonitis,25 asthma, cough, wheezing, sinusitis, prolonged colds, and potentially nasal cancer.

The International Agency for Research on Cancer (IARC) has classified wood dust as a Group 1 carcinogen – carcinogenic to humans.26 In their monograph for wood dust, IARC summarizes that “there is sufficient evidence in humans for the carcinogenicity of wood dust. Wood dust causes cancer of the nasal cavity and paranasal sinuses and of the nasopharynx.” In 2016, the American Conference of Governmental Industrial Hygienists (ACGIH) established a Threshold Limit Value (TLV) for wood dust exposure.27 ACGIH has determined the following carcinogenicity: Oak and Beech woods – A1: Confirmed Human Carcinogen Birch, Mahogany, Teak and Walnut – A2: suspected human carcinogen All other wood dusts – A4: not classifiable as a human carcinogen

ACGIH has explicitly classified Western red cedar as Not Classifiable as a Human Carcinogen (A4). However, there have been many studies showing a strong association between occupational exposure to Western red cedar dust and asthma, and it has also been found to function as an allergen.

Other agencies have also addressed adverse health effects from prolonged exposure to wood dust. The federal Occupational Safety and Health Administration (OSHA) summarizes the

23 It was previously reported that cedar trees would be exported, though they were incense cedar, not Western red cedar, a species that has been linked to respiratory ailments. However, the processing and export of cedar trees is no longer part of the project. 24 Granulomatous is an inflammatory tumor or growth composed of granulation tissue. 25 Pneumonitis is an inflammation of the lung caused by a virus or exposure to irritating substances. 26 International Agency for Research on Cancer, IARC Monographs on the Evaluation of Carcinogenic Risks to Humans, 2005, accessed January 21, 2017 at: http://monographs.iarc.fr/search.php?cx=009987501641899931167%3A2_7lsevqpdm&cof=FORID%3A9&ie=ISO- 8859-1&oe=ISO-8859-1&sa=&q=wood+dust - gsc.tab=0&gsc.q=wood+dust&gsc.page=1. 27 American Conference of Governmental Industrial Hygienists, Threshold Limit Values for Chemical Substances and Physical Agents & Biological Exposure Indices, 2016.

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health effects of wood dust as: nasal cancer, respiratory sensitization-asthma, hypersensitivity pneumonitis, and irritation of the eye, nose, throat, and skin.28 The National Institute for Occupational Safety and Health (NIOSH) lists the following symptoms associated with wood dust exposure: irritation of the eyes, nosebleeds, dermatitis, respiratory sensitizer, granulomatous, pneumonitis, asthma, cough, wheezing, sinusitis prolonged colds and potential occupational carcinogen.29

The 2005 monograph issued by IARC presents a compilation of data regarding potential exposure to workers to wood dust. This compilation of data covers a variety of industries including construction, manufacture of furniture, forestry, building of ships and boats, sawmilling, and other types of manufacturing using wood. While not directly related to debarking operations, this data does provide some insight into potential exposure to wood dust in a variety of settings and industries.

The 2005 IARC Monograph presented data showing that the following industries experienced personal exposures to wood dust greater than 5 milligrams per cubic meter (mg/m3) of inhalable particulate mass over an 8-hour workday: construction, furniture manufacturing, joinery, manufacturing, forestry, ship building, sawmilling, manufacture of other wood products, wooden boards and wooden containers. The highest exposures were generally reported in wood furniture and cabinet manufacturing, especially during machining-sanding and similar operations.

According to ACGIH, the most important factor influencing the degree to which a worker will be exposed to wood dust is the type of operation being performed. Some woodworking processes shatter the wood cells, while others chip out whole cells or groups of cells. Shattering produces much finer particle sizes than chipping and generally creates more airborne dust. The dust particles produced from chipped cells are larger and heavier, and therefore do not remain suspended in air. Consequently, they are more difficult to inhale and pose much less risk to human health.30

Woodworking processes used to create a smooth surface, such as sanding or grinding, result in more shattering of cells than rougher woodworking processes, such as debarking, which operates at a gross level. Additionally, woodworking operations performed parallel to the natural grain of the wood are less likely to shatter cells than processes performed perpendicular to the grain. In the case of the proposed project, the debarking ring would operate perpendicular to the grain, increasing the potential for cell shattering. Higher-velocity operations (e.g., mechanical sanding vs. hand sanding) obviously generate a greater volume of dust. Significant volumes of large-particle dust were observed in the immediate vicinity of the debarking ring during active debarking operations at an existing log preparation facility in West Sacramento, California.31

According to the National Toxicology Program’s Report on Carcinogens, “exposure to wood dust occurs when individuals use machinery or tools to cut or shape wood. When the dust is inhaled, it is deposited in the nose, throat and other airways. The amount of dust deposited within the airways depends on the size, shape and density of the dust particles and the strength of the air

28 U.S. Department of Labor, Occupational Safety and Health Administration, Chemical Sampling Information: Wood Dust Health Factors, Accessed January 21, 2017 at: https://www.osha.gov/dts/chemicalsampling/ data/CH_276185.html. 29 Centers for Disease Control and Prevention, NIOSH Pocket Guide to Chemical Hazards, Wood Dust, April 11, 2016. 30 California Department of Industrial Relations, Wood Dusts, 2005. https://www.dir.ca.gov/oshsb/documents/ Airborne-Contaminants-Wood-Dust-and-Western-Red-Cedar-1-TLV-2005.pdf. 31 See Section XII, Noise, for additional discussion of the operations observed at the West Sacramento facility.

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flow.”32 The Report on Carcinogens compiles a variety of case studies, leading to a conclusion that an estimated 600,000 workers are exposed to wood dust, though it should be noted that the studies were not limited to U.S. workers. These exposures ranged from 0.03 to 604 mg/m3 of inhalable particulate mass over an 8-hour workday. Occupations with high exposure to wood dust included sander in the transportation equipment industry, lath operator in the furniture industry, and sander in the wood cabinet industry. High exposures occurred in a variety of industries including mill and saw operations. Debarking operations were not noted.

It is important to note that most of the studies include a variety of industrial settings and debarking is not included. However, an IARC study on wood dust and formaldehyde exposure published in 1995 states that “debarking involves little or no exposure to wood dust, because the wood is ‘green’ (fresh) and thus has a high moisture content. Further, the main goal of the operation is to leave the wood intact.” 33 While the debarking ring of the debarker does generate wood dust, it is of larger (less hazardous) particle size than that generated by wood sanding operations.

Regulations Governing Employee Exposure to Wood Dust The proposed debarking operation would take place in Richmond, California. While federal OSHA covers all states, California has a State plan that is at least as stringent as federal OSHA, and federal OSHA oversees the State plan. Therefore, California Division of Occupational Safety and Health (Cal/OSHA) regulations apply to employees who may be exposed to wood dust at the Richmond facility. The applicable permissible exposure limits (PEL) for wood dust exposure established by Cal/OSHA and promulgated in Title 8 of the California Code of Regulations (CCR) are listed in Table AQ–5. These exposure limits are provided as short-term exposure limits (STEL) and 8-hour time-weighted average (TWA) exposure limits.

CCR Title 8, Division 1, Chapter 4, Subchapter 7, Group 8, Article 59 sets forth additional regulations pertaining to woodworking machines and equipment. Notably, Section 4324 requires the use of a suitable dust collection system “whenever the chips and wood dust produced by woodworking machines accumulate so as to endanger employees.” A dust collection system includes the collection hood, the exhaust fan, the dust collector, and all ducts, flexible hoses, or other devices used for conveying the dust. Dust collectors may include conventional solid-walled cyclones and baghouses, or enclosure-less bag-type units. Large- capacity collectors (i.e., air-handling capacity greater than 500 cubic feet per minute (cfm)) must be located outdoors, in detached rooms with fire-resistant construction and explosion vents, or inside buildings if liquid spray collectors are employed. Enclosure-less bag-type dust collectors meeting certain criteria, including a maximum air-handling capacity of 5,000 cfm, may also be located indoors. Design and operation of all exhaust systems must conform to the requirements of CCR Title 8, Division 1, Chapter 4, Subchapter 7, Group 16, Article 107, Section 5143. They must be operated continuously during operation of a dust collector, must exhaust to the outside atmosphere, and must provide a supply of clean, fresh air free of contamination from adjacent industrial exhaust systems, chimneys, stacks, or vents.

32 U.S. Department of Health and Human Services, Public Health Service, National Toxicology Program, Report on Carcinogens, 14th Edition, 2016. 33 International Agency for Research on Cancer, IARC Monographs on the Evaluation of Carcinogenic Risks to Humans, Volume 62: Wood Dust and Formaldehyde, 1995.

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Table AQ–5 Regulatory and Recommended Exposure Limits for Wood Dust

Agency/ STEL1 8-Hour TWA2 Analyte Regulatory Parameter (mg/m3) (mg/m3)

Wood dust – all soft and hard woods except Western 10 5 Red Cedar California Occupational Wood Dust - Western Red Safety and Health NA 2.5 Administration Cedar (Cal/OSHA) / Particulates, not otherwise NA 10 Permissible Exposure regulated - Total Limit (PEL)3 Particulates, not otherwise regulated – Respirable NA 5 Fraction

American Conference 0.5 of Governmental Western Red Cedar NA inhalable particulate Industrial Hygienists matter (ACGIH) / 1 Threshold Exposure All other tree species NA inhalable particulate Limit (TLV)4 matter National Institute of Occupational Safety Hard wood, soft wood, and Health (NIOSH) / NA 1 western red cedar Recommended Exposure Limit (REL)4

Notes: 1STEL = Short-Term Exposure Limit 2TWA = Time-Weighted Average 3The PELs are regulatory standards enforceable by Cal/OSHA. 4Recommended exposure levels, but not enforceable.

Although they are not regulatory in nature, more stringent exposure limits than the Cal/OSHA PELs have been recommended by the American Conference of Governmental Industrial Hygienists (ACGIH) and the National Institute of Occupational Safety and Health (NIOSH), which are also presented in Table AQ–5. The ACGIH has established Threshold Limit Values (TLVs®) for safe levels of exposure to various chemical substances and physical agents found in the workplace. The TLVs® are health-based values established by committees that review existing published and peer-reviewed literature in various scientific disciplines (e.g., industrial hygiene, toxicology, occupational medicine, and epidemiology). The TLVs® represent the opinion of the scientific community that exposure at or below the level of the TLV® does not create an unreasonable risk of disease or injury. In using these guidelines, industrial hygienists are cautioned that the TLVs® are only one of multiple factors to be considered in evaluating specific workplace situations and conditions. Since TLVs® are based solely on health factors, there is no consideration given to economic or technical feasibility.

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NIOSH has also published recommended exposure limits for wood dust. NIOSH, which is part of the Centers for Disease Control and Prevention (CDC) within the U.S. Department of Health and Human Services, is the federal agency responsible for conducting research and making recommendations for the prevention of work-related injury and illness. It has the mandate to ensure “every man and woman in the Nation safe and healthful working conditions and to preserve our human resources.” NIOSH's authority under the Occupational Safety and Health Act [29 CFR § 671] is to "develop recommendations for health and safety standards," to "develop information on safe levels of exposure to toxic materials and harmful physical agents and substances," and to "conduct research on new safety and health problems." NIOSH's recommended standards are issued as Recommended Exposure Limits (REL). The RELs are not enforceable; they are recommended exposure levels only.

Potential Impacts to Project Employees Given the lack of scientific data on the exposure of workers operating or working near log debarking machines, this analysis takes a conservative approach to the assessment of potential threats to the health and safety of workers for the proposed project. The validity of this approach is underlined by data from other woodworking industries where potentially dangerous exposures of up to 604 mg/m3 of wood dust over an 8-hour workday have been measured, despite the fact that the data is from industries that undoubtedly pose a greater risk to workers than the workers on and near the proposed debarking machine. Other measured woodworker exposure rates were far below the regulatory PLV (0.03 mg/m3 vs. a PLV of 5 mg/m3), as well as the more stringent recommended exposure limits of 1 mg/m3.

It is considered unlikely that workers at the proposed log storage and shipping facility would be exposed to wood dust in excess of the regulatory thresholds or even the more stringent recommended exposure limits listed in Table AQ–5. There are several factors for this determination. Most significantly, the employee who would potentially face the greatest exposure to wood dust generated by the debarking ring would be the debarker operator, who would sit in an enclosed, insulated cab that would provide protection both from the noise from the equipment and from the wood dust thrown off from the debarking ring. This dust would be partially suppressed by the water spray that would be automatically sprayed at the debarking ring when it is in operation.

The only other employee who would be working in the vicinity of the debarker for any significant amount of time would be a front loader operator, who would load logs into the mechanical feeder located in front of the debarker, and who would remove debarked logs from the back end of the debarker, where they would automatically roll down a chute and collect in a pile. Both of these operations would occur at some distance from the debarking ring. At the West Sacramento facility where debarking operations were observed and monitored, the loading operations were occurring at a distance of approximately 70 feet from the debarking ring at the closest approach, which occurred where the front loader deposited logs onto the feeding rack. The operator was at this closest distance, where no airborne wood dust was visible, for only a few seconds at a time, with most of his time spent at considerably greater distances, collecting logs.

The front loader approached to within 45 feet from the debarking ring when collecting debarked logs from the back end of the debarker, again for brief periods. The exposure of this front loader operator to wood dust is expected to be negligible due to two factors: (1) he would be within an enclosed cab on the front loader, and (2) the wood dust would settle and not extend to distances of 45 to 70 feet from the debarking ring. Other project operations would occur outside the terminal building where the debarker would be located and at considerably further distances from the machine, so workers performing these more distant operations

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would not be exposed to wood dust other than incidental dust that would arise during the unloading, stacking, and loading of logs.

Nonetheless, despite the considerations discussed above, due to the broad range of wood dust exposure values across varying wood-working industries that have been documented in the scientific literature, it is conservatively assumed that project employees working in the vicinity of the debarker could potentially be exposed to unhealthy levels of wood dust. This would be a potentially significant impact. Implementation of the following mitigation measures would reduce this impact to a less-than-significant level:

Mitigation Measure AQ–5: The project operator shall require employees operating the debarker and front-loaders used for loading and unloading logs from the debarker to keep the doors closed on their operator cabs during all debarking operations.

Mitigation Measure AQ–6: The project operator shall apply a water mist in the debarking area during cleanup and other operations that produce visible airborne dust.

Mitigation Measure AQ–7: Personal air monitoring for total particulates, not otherwise specified: To determine whether project employees may be exposed to hazardous levels of wood dust, the project operator shall retain the services of a Certified Industrial Hygienist to collect personal (worker exposure) air samples of total particulates, not otherwise specified, during normal log debarker operations over the course of an 8-hour work period. The personal air samples shall be collected from the debarker operator and the front-loader operator who is loading and unloading logs from the debarker. The air samples shall be collected with battery-operated air sampling pumps and sampling cassettes containing tared (pre- weighed) 37-millimeter (mm) diameter, 5-micrometer (µm) porosity polyvinyl chloride (PVC) filters. Each air sampling assembly (pump and cassette) shall be operated at an air flow rate of approximately 1 liter per minute (lpm) for a duration of approximately 120 minutes, to obtain an air sample volume of approximately 120 liters. Sample cassettes shall be removed and replaced every 120 minutes for the duration of the work shift. Thus, a total of 480 minutes of sampling shall take place in order to determine the employee exposure over the entire shift. All samples and one quality assurance “field blank” shall be analyzed via National Institute of Occupational Safety and Health (NIOSH) Method 500 – Particulates Not Otherwise Regulated - Total. Sample analysis shall be conducted by a laboratory accredited by the American Industrial Hygiene Association (AIHA) Laboratory Accreditation Program. A copy of the laboratory results shall be submitted to the City of Richmond Planning and Building Services Department.

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collect personal (worker exposure) air samples of respirable particulates, not otherwise specified, during normal log debarker operations over the course of an 8-hour work period. The personal air samples shall be collected from the debarker operator and the front-loader operator who is loading and unloading logs from the debarker. The air samples shall be collected with battery-operated air sampling pumps connected to 10-mm nylon cyclone, Higgins- Dewell [HD] cyclone, or Aluminum cyclone in line with tared 5- µm PVC membrane filter. Each air sampling assembly (pump and cassette) shall be operated at an air flow rate of approximately 2.5 liter per minute (lpm) for a duration of approximately 160 minutes, to obtain an air sample volume of approximately 400 liters. Sample cassettes shall be removed and replaced every 160 minutes for the duration of the work shift. Thus, a total of 480 minutes of sampling shall take place in order to determine the employee exposure over the entire shift. All samples and one quality assurance “field blank” shall be analyzed via National Institute of Occupational Safety and Health (NIOSH) Method 600 – Particulates Not Otherwise Regulated - Respirable. Sample analysis shall be conducted by a laboratory accredited by the American Industrial Hygiene Association (AIHA) Laboratory Accreditation Program. A copy of the laboratory results shall be submitted to the City of Richmond Planning and Building Services Department.

Mitigation Measure AQ–9: Area air monitoring for total particulates, not otherwise specified: To determine whether project employees may be exposed to hazardous levels of wood dust, the project operator shall retain the services of a Certified Industrial Hygienist to collect area air samples during normal work operations at the perimeter of the debarking operation. The area air samples will be utilized to determine if a potential for exposure to the wood dust extends beyond the area of operation. The air samples shall be collected with battery-operated air sampling pumps and sampling cassettes containing tared (pre- weighed) 37-millimeter (mm) diameter, 5-micrometer (µm) porosity PVC filters. Each air sampling assembly (pump and cassette) will be operated at an air flow rate of approximately 1 liter per minute (lpm) for a duration of approximately 120 minutes, to obtain an air sample volume of approximately 120 liters. Sample cassettes will be removed and replaced every 120 minutes for the duration of the work shift. Thus, a total of 480 minutes of sampling will take place in order to determine the employee exposure over the entire shift. All samples and (1) quality assurance “field blank” per day will be analyzed via National Institute of Occupational Safety and Health (NIOSH) Method 500 – Particulates Not Otherwise Regulated - Total. Sample analysis will be conducted by a laboratory accredited by the American Industrial Hygiene Association (AIHA) Laboratory Accreditation Program.

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Mitigation Measure AQ–10: If worker exposures measured under Mitigation Measures AQ–7, AQ–8, and/or AQ–9 exceed any of the applicable Permissible Exposure Limits (PELs), Threshold Limit Values (TLVs®), or Recommended Exposure Limits (RELs) for wood dust exposure listed in Table AQ–5, debarking operations shall be halted until the project operator can install an enclosure around the debarking ring or put other engineering controls in place to adequately suppress airborne wood dust. Following installation of the controls, the worker monitoring required by Mitigation Measures AQ–7, AQ–8, and AQ–9 shall be repeated until worker exposure is reduced below the applicable PELs, TLVs, and RELs.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Create objectionable odors affecting a substantial number of people? ⌧

Explanation: Though offensive odors from stationary and mobile sources rarely cause any physical harm, they still remain unpleasant and can lead to public distress, generating citizen complaints to local governments. The occurrence and severity of odor impacts depend on the nature, frequency, and intensity of the source; wind speed and direction; and the sensitivity of receptors. Generally, odor emissions are highly dispersive, especially in areas with higher average wind speeds. However, odors disperse less quickly during inversions or during calm conditions, which hamper vertical mixing and dispersion.

The BAAQMD’s significance criteria for odors are subjective and are based on the number of odor complaints generated by a project. Generally, the BAAQMD considers any project with the potential to frequently expose members of the public to objectionable odors to cause a significant impact. With respect to the proposed project, diesel-fueled equipment exhaust would generate some odors. However, these emissions typically dissipate quickly and would be unlikely to affect a substantial number of people. Therefore, odor impacts associated with the location of the proposed project would be less than significant.

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IV. BIOLOGICAL RESOURCES — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or ⌧ regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?

Explanation: The project site is a previously disturbed industrial port property and the majority of the site is covered with impervious surfaces (i.e., buildings and pavements). Other than a small grass lawn in front of the office building near the southern end of the site, there is no vegetation or natural habitat on the project site. There is no habitat on the site to support any special-status species.

Although special-status marine mammal species such as California sea lions (Zalophus californianus) and harbor seals (Phoca vitulina) may occasionally visit the Harbor Channel waters adjacent to Terminal 3, the proposed project does not include any modifications to the Terminal 3 wharf or any activities that would affect the marine habitat next to the site. While the project would include the temporary berthing of up to six cargo ships per year during log loading operations, this would represent a reduction in the number of vessels currently berthed at Terminal 3. Currently, approximately 10 to 12 ships are lay berthed (i.e., parked) at Terminal 3 each for varying periods of days or weeks.34 These ships are not idling while berthed, but may be connected to an existing shoreline power terminal.

Due to the lack of any supportive habitat, there is no potential for special-status plant or wildlife species to be present at or frequent the project site. Therefore, the project would have no impact on special-status species.

34 Jim Matzorkis, Director, Port of Richmond, personal communication, September 8, 2015.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, ⌧ regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?

Explanation: There is no riparian habitat or other sensitive natural community present on or in proximity to the project site. There is therefore no potential for such habitats to be adversely affected by the project.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct ⌧ removal, filling, hydrological interruption, or other means?

Explanation: There are no wetlands or other waters subject to regulation by the U.S. Army Corps of Engineers or Regional Water Quality Control Board under Section 404 of the Clean Water Act present on the project site. Although regulated waters are immediately adjacent to the project site and would be utilized by ships operated as part of the proposed project, as discussed in Section IV-a, above, the project would not increase or substantially alter the existing use of the wharf at Terminal 3. Therefore, the proposed project would have no effect on wetlands or other waters regulated under the Clean Water Act.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with any established native resident or migratory ⌧ wildlife corridors, or impede the use of native wildlife nursery sites?

Explanation: There is no suitable habitat on or in the vicinity of the project site with the potential to function as a migratory wildlife corridor.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Conflict with any local policies or ordinances protecting biological resources, such as a tree ⌧ preservation policy or ordinance?

Explanation: The proposed project would not require the removal of any trees and would not have any adverse effects on biological resources. Therefore, the project would not conflict with any local policies or ordinances protecting biological resources.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, ⌧ or state habitat conservation plan?

Explanation: There is no adopted habitat conservation plan (HCP) applicable to the City of Richmond. Furthermore, as discussed in Section IV-a, above, there is virtually no natural habitat on the site, and no potential for the proposed project to adversely affect valuable habitat.

V. CULTURAL RESOURCES — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Cause a substantial adverse change in the significance of a historical resource as defined in ⌧ §15064.5?

Explanation: In order to be considered a significant historical resource as defined in Section 15064.5 of the CEQA Guidelines, a building must be at least 50 years old. In addition, Section 15064.5 defines an historical resource as, “… a resource listed in, or determined to be eligible for listing in, the California Register of Historical Resources,” properties included in a local register of historical resources, or properties deemed significant pursuant to criteria set forth in Public Resources Code Section 5024.1(g). According to CEQA Guidelines Section 15064.5(a)(3), a lead agency can determine that a resource is significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California, provided that the determination is supported by substantial evidence in light of the whole record.

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In order to be eligible for listing in the California Register of Historical Resources, a property must meet at least one of the following criteria: • Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage; • Is associated with the lives of persons important in our past; • Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; • Has yielded, or may be likely to yield, information important in prehistory or history.35

Based on a review of historical records, including historical aerial photographs of the project site, the existing administrative office building was constructed sometime between 1974 and 1982. The northern portion of the large warehouse building was constructed between 1982 and 1993, and the building was expanded to its current size between 1993 and 1998.36 Therefore, the existing structures are less than 50 years old. They are not architecturally distinct, are not associated with historic events or persons, and are not listed on the City’s Historic Resources Inventory.37 Furthermore, the proposed project would not demolish or alter the existing building.

The former Ford Motor Co. Assembly Plant is located immediately to the east of the project site, at 1414 Harbour Way South. This property is a registered City Landmark and is on the National Register of Historic Places (NRHP) and the California Register of Historic Properties (CRHP). In addition, the Filice and Perrelli Cannery, which supplied canned fruit and tomatoes to the military during World War II and is listed as a City Resource on the City of Richmond’s Historic Resources Inventory, is located across from the project site at 1200 Harbour Way South. However, the proposed project would have no effect on either of these historic resources. There is therefore no potential for the proposed project to adversely affect historic resources, either on the project site or at adjacent properties.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to ⌧ §15064.5?

Explanation: The San Francisco Bay area was occupied by Native Americans as far back as 3,000 to 4,000 years ago. Recorded archaeological sites in Richmond and the surrounding region indicate that at the time of initial Euroamerican incursion into the project area (circa 1770), the

35 California Resources Agency, CEQA Guidelines, Section 15064.5(a)(3), as amended October 23, 2009. 36 KC Engineering Company, Phase I Environmental Site Assessment of APNs 560-270-059 and -060, Terminal 3, Port of Richmond, 1411 Harbour Way South, Richmond, Contra Costa County, California, September 21, 2015. 37 City of Richmond, Historic Resources Inventory, accessed November 3, 2015 at: http://www.ci.richmond.ca.us/ DocumentCenter/View/5510

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region was occupied by Native Americans who spoke Chochenyo.38 These people were a subset of the Penutian–speaking Bay Miwok (referred to as “Costanoans” by the Spanish) residing in northern California at the time the Spanish arrived in the region.39 The Miwok territory encompassed much of the San Francisco Bay area and extended eastward to the Central Valley.

With the arrival of the Spanish at the turn of the nineteenth century, the Native Americans in the area were either forced from the area or conscripted to work on one of the large “rancherias” established in the region, where many Chochenyo died from overwork and introduced European diseases. By the beginning of the California Gold Rush in 1848, the Costanoan culture, including the Chochenyo subset, no longer survived in the region. Artifacts from the prehistoric occupation of the Bay Area by the Costanoans remain buried throughout the region, particularly in areas proximate to the historic margins of tidal marshlands around what is now San Francisco Bay, and near other water sources and at locations otherwise suitable for human subsistence habitation. Various Native American archaeological sites have been recorded within the City of Richmond, including sites that have been deemed eligible for the NRHP.40

An archival search was conducted by the Northwest Information Center (NWIC) at Sonoma State University, which is part of the California Historical Resources Information System (CHRIS), to evaluate the potential for significant archaeological resources to be present on the project site.41 Because no ground disturbance would be required for the proposed project, the NWIC determined that archival search for pre-historic cultural resources was not warranted, and limited the archival search to a review of buildings and structures. As discussed in Section V(a), above, although an historic property is located about 175 feet east of the project site, there is no potential for the proposed project to adversely affect this resource.

Pursuant to Assembly Bill (AB) 52, passed by the California Legislature in September 2014, the City sent a Tribal Consultation List Request to the Native American Heritage Commission (NAHC) on March 20, 2017 in order to identify Native American tribal groups who may be traditionally and culturally affiliated with the geographic area of the proposed project site. A March 28, 2017 response letter from the NAHC identified six tribal groups affiliated with the project area, including the following groups: • Amah Mutsun Tribal Band of Mission San Juan Bautista • Indian Canyon Mutsun Band of Costanoan • Muwekma Ohlone Indian Tribe of the San Francisco Bay Area • North Valley Yokuts Tribe • The Ohlone Indian Tribe • Wilton Rancheria

The NAHC provided names and addresses of the chairperson or other representative of each of these groups. In accordance with AB 52, the City mailed letters to each of the representatives,

38 City of Richmond, Honda Port of Entry at the Point Potrero Marine Terminal Draft Environmental Impact Report, State Clearinghouse No. 2008022063, Volume I, July 2008. 39 In anthropological literature, the Costanoans are often referred to as the Ohlone. 40 City of Richmond, Richmond General Plan Update Draft Environmental Impact Report, Section 3.5, Cultural Resources, February 2011. 41 Northwest Information Center, Sonoma State University, Record Search Results for the Proposed Port of Richmond Terminal 3 Log Export Facility, City of Richmond, Contra Costa County, California, NWIC File No. 15-0416, October 8, 2015.

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offering them the opportunity to provide input regarding any concerns their tribes may have about the potential impacts implementation of the proposed project could have on tribal cultural resources. The City received a response from the Cultural Resources Officer of the Wilton Rancheria that stated the Tribe’s only concern pertained to ground disturbance of the site, which creates a heightened possibility that Native American artifacts and/or human remains may be uncovered. The Cultural Resources Officer stated that if such artifacts or remains are encountered during subsurface disturbance of the site, the applicant should immediately stop construction and notify the Tribe and appropriate federal and State agencies in accordance with the Archaeological Resources Protection Act (ARPA) [16 USC 469], Native American Graves Protection and Repatriation Act (NAGPRA) [25 U.S.C. 3001-30013], Health and Safety Code Section 7050.5, and Public Resources Code Section 5097.9, et al.42 However, because implementation of the proposed project would not require any subsurface disturbance, there is no potential for Tribal Cultural Resources to be adversely affected. As of May 5, 2017 when this document went to print, and following more than the 30-day response period mandated by AB 52, no other responses were received from the tribal representatives contacted by the City.

While the possible presence of buried prehistoric cultural materials at the project site cannot be ruled out, any such resources, were they to exist, would not be adversely affected by the proposed project, since no subsurface disturbance would occur. Therefore, the proposed project would have no impact on archeological resources.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Directly or indirectly destroy a unique paleontological resource or site or unique geologic ⌧ feature?

Explanation: Paleontological resources are the fossilized remains of vertebrate or invertebrate organisms from prehistoric environments found in geologic strata. They are valued for the information they yield about the history of the earth and its past ecological settings. They are most typically embedded in sedimentary rock foundations, and may be encountered in surface rock outcroppings or in the subsurface during site grading. There are no rock outcroppings at the project site and there would be no subsurface disturbance required for the proposed project. Therefore, although the potential for paleontological resources to be buried under the project site was not evaluated, there is no potential for the project to adversely affect any such resources that may be present.

42 Antionio Ruiz, Cultural Resources Officer, Department of Environmental Resources, Wilton Rancheria, email dated April 4, 2017.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Disturb any human remains, including those interred outside of formal cemeteries? ⌧

Explanation: As noted in Section V(b), above, there would be no subsurface disturbance performed as part of the proposed project and, therefore, there is no potential for the project to adversely affect any human remains that might lie buried within the project site.

VI. GEOLOGY AND SOILS — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other ⌧ substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42.

Explanation: There is no known active earthquake fault located on or near the project site. The nearest seismically active fault is the Hayward-Rodgers Creek fault, located approximately 3.3 miles northeast of the site, while the San Andreas fault lies about 14.4 miles to the southwest.43 There is therefore no potential for fault rupture at the project site.

43 Fugro West, Inc., Geotechnical Study, Port of Richmond Operations and Security Center, Richmond, California, Fugro Project No. 04.B1413007, February 2011.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact ii) Strong seismic ground shaking? ⌧

Explanation: The San Francisco Bay Area is recognized by geologists and seismologists as one of the most seismically active region in the United States. Similar to most urban locations throughout the Bay Area, the project site is potentially subject to moderate to high seismic ground shaking during an earthquake on one of the major active earthquake faults that transect the region. Major earthquakes have occurred on the Hayward, Calaveras, and San Andreas faults during the past 200 years, and numerous minor earthquakes occur along these faults every year. At least five known earthquakes of Richter magnitude (RM) 6.5, four of them greater than RM 7.0, have occurred within the San Francisco Bay Area within the last 150 years. This includes the great 1908 San Francisco earthquake (moment magnitude 7.8) and the 1989 Loma Prieta earthquake (RM 6.9).

According to a 2014 analysis by the Working Group on California Earthquake Probabilities (WGCEP), an expert panel co-chaired by U.S. Geological Society seismologists, there is a 72 percent probability that an earthquake of magnitude 6.7 or greater will occur in the San Francisco Bay Area in the next 30 years and a 20 percent probability that an RM 7.5 earthquake will occur (starting from 2014).44 The WGCEP estimates there is a 14.3-percent chance of an RM 6.7 quake occurring on the Hayward fault in the next 30 years. It is therefore likely that a major earthquake will be experienced in the region during the life of the project that could produce strong seismic ground shaking at the project site.

A major earthquake on any of the active faults in the region could result in very strong to violent ground shaking. The intensity of earthquake ground motion would depend upon the characteristics of the generating fault, distance of the site to the earthquake epicenter and rupture zone, magnitude and duration of the earthquake, and site-specific geologic conditions. The California Geological Survey’s Interactive Probabilistic Seismic Hazards Ground Motion Interpolator (2008) indicates there is a 2-percent probability that seismic ground shaking will produce a peak horizontal ground acceleration of at least 0.882 g at the site within the next 50 years.45 This represents a large amount of ground movement, but translates to an event that would be expected to occur once every 475 years; it also means there is a 90-percent chance this level of ground motion will not be exceeded in the next 50 years.

Engineers use the estimated peak horizontal ground acceleration to design buildings for larger ground motions than are expected to occur during a 50-year interval in order to maximize a building’s ability to withstand seismic ground shaking that may occur at a project site. However, no new construction is proposed as part of the log export facility project. While there is existing risk of strong seismic shaking at the site, similar to any location in the San Francisco Bay Area, the proposed project would not result in an increase in the risk of seismic shaking or

44 Edward H. Field and Members of the 2014 Working Group on California Earthquake Probabilities, U.S. Geological Survey, California Geological Survey, UCERF3: A New Earthquake Forecast for California’s Complex Fault System, USGS Open File Report 2015-3009, 2015. 45 California Department of Conservation, California Geological, Survey, Probabilistic Seismic Hazard Map Ground Motion Interpolator (2008), accessed September 9, 2015 at: http://www.quake.ca.gov/gmaps/PSHA/psha_interpolator.html.

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in the potential structural damage that could occur during a strong earthquake on one of the region’s earthquake faults. However, at times when logs were stockpiled on the site, these logs could potentially be dislodged during strong seismic shaking that could occur during an earthquake. A collapsing log pile would have the potential to crush workers that could be nearby, killing or maiming them or causing other serious injury. This would be a potentially significant impact.

This potential impact would not be limited to the effects of seismic shaking. Stacked logs are potentially unstable even in the absence of seismic shaking, particularly in the case of high log stacks. Debarked logs are more slippery than logs with the bark left on, and are therefore less stable when stacked. Instability of the stack could be increased during operations to add or remove logs, when the pile could be jostled. Workers climbing on the stacked logs could also potentially dislodge the stack. The project applicant was previously proposing to stack the logs up to a height of 25 feet, but has subsequently agreed to limit stacks to a height of 20 feet to improve safety. When logs are stacked on the wharf prior to loading on a ship, the heights would be limited to 15 feet.

Numerous log drivers and logging workers are killed every year, often during log unloading and stacking operations. The National Institute for Occupational Safety and Health (NIOSH) reported that 70 deaths occurred in the logging industry in 2010, resulting in a fatality rate of 73.7 deaths per 100,000 workers that year, more than 21 times the nationwide rate of 3.4 deaths per 100,000 population.46 Workers have been killed climbing on stacks that shifted, unloading trucks, and moving logs. Logs have spilled from trucks where the logs were stacked higher than the vertical standards (stakes) in the truck bed and the chains securing the logs snapped.

While logs stacked in the Debarked Logs Deck would be confined and stabilized initially by the proposed Ultra Block system and subsequently by metal log bunks still being designed, improper log handling operations could still result in logs shifting in a manner that could result in injury or death to unprotected workers. As noted above, this would be a potentially significant impact. Implementation of the following measures would reduce this impact to a less-than-significant level:

Mitigation Measure GS–1: Prior to commencement of project operations, the project sponsor shall prepare and implement a worker training and safety program in accordance with guidelines published by the Occupational Safety and Health Administration (OSHA). The training and safety program shall evaluate all tasks performed by workers, identify all potential hazards, and then develop, implement, and enforce a written safety and health program that meets applicable OSHA standards and addresses these hazards. A comprehensive written occupational safety and health program must be developed for all workers and include training in hazard recognition, avoidance of unsafe conditions, safe performance of assigned tasks, and safe use and maintenance of tools or equipment. Hazards to be addressed should include the potential for rolling logs, worker falls from log stacks, the potential for a front-end loader to tip over, and other hazards associated with operating front-end loaders.

46 National Institute for Occupational Safety and Health (NIOSH), Logging Safety, Accessed November 11, 2015 at: http://www.cdc.gov/niosh/topics/logging/default.html.

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The operator shall comply with all applicable Occupational Safety and Health Administration (OSHA) log unloading regulations stipulated for the logging industry in Code of Federal Regulations (CFR) Chapter 29, Part 1910.266, and the procedures promulgated therein shall be incorporated into the worker training and safety program.

The project sponsor shall train each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to their work environment to control or eliminate any hazards or other exposure to injury or illness. The safety program shall include the following provisions, among others: • Safety procedures shall be established for log handling and movement, including ensuring other employees are not within a safe clearance area around the operations. • Transport vehicles shall be positioned to provide working clearance between the vehicle and the deck. • Only essential personnel shall be allowed in the loading/unloading work area. • No transport vehicle operator shall remain in the truck cab during loading and unloading if logs are moved over the truck cab.

Mitigation Measure GS–2: All new employees shall undergo training prior to performing work; existing employees shall undergo training prior to being assigned new work tasks or use of new tools, equipment, machines, or vehicles. Any employee who exhibits unsafe job performance shall undergo retraining in the appropriate health and safety provisions and procedures. The site operator shall be responsible for ensuring that each current and new employee can properly and safely perform the work tasks and operate the tools, equipment, machines, and vehicles used in their job. New employees and employees undergoing retraining shall work under the close supervision of a designated person until the employee demonstrates to the employer the ability to safely perform their new duties independently.

The project sponsor shall ensure that the trainer who provides employee training is qualified through education and/or experience to conduct training.

The site operator shall document the names and dates of employees completing the training program and shall retain the training records on site.

Mitigation Measure GS–3: The employer shall ensure that each employee, including supervisors, receives or has received first-aid and CPR training meeting at least the requirements specified in 29 CFR 1910.266 Appendix B. The employer shall assure that each employee's first-aid and CPR training and/or certificate of training remain current. A first-aid kit shall be maintained on site at all times and

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shall contain, at a minimum, all of the contents listed in 29 CFR 1910.266 Appendix A.

Mitigation Measure GS–4: The front loader used for moving and stacking logs shall be equipped with a falling object protective structure (FOPS) that is tested, installed, and maintained in accordance with the Society of Automotive Engineers SAE J231 (January 1981) Minimum Performance Criteria for Falling Object Protective Structures (FOPS). The debarking machine shall be equipped with guarding to protect employees from flying wood chunks, chips, bark, and other materials and the guarding shall be in place at all times the machine is in operation. Workers shall wear appropriate personal protection, including steel-toed boots, hard hats, work gloves, and eye protection.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact iii) Seismic-related ground failure, including liquefaction? ⌧

Explanation: Liquefaction occurs when clean, loose, saturated, uniformly graded, fine-grained soils are exposed to strong seismic ground shaking. The soils temporarily lose strength and cohesion due to buildup of excess pore water pressure during earthquake-induced cyclic loading, resulting in a loss of ground stability that can cause building foundations to fail. Soil liquefaction may also damage roads, pavements, pipelines, and underground cables. Soils susceptible to liquefaction include saturated, loose to medium dense sand and gravel, low- plasticity silt, and some low-plasticity clay deposits.

The project site is mapped by the U.S. Geological Survey as having a high potential for liquefaction.47 However, this is a pre-existing condition at the site that the proposed project would not alter. No new construction is proposed that could be adversely affected by soil liquefaction. As currently proposed, the project would not increase the hazard related to seismic-related ground failure, including liquefaction.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact iv) Landslides? ⌧

Explanation: The project site is virtually level, and the area surrounding the site is also level, with similar to identical elevations to those on the project site. There are no slopes on or anywhere near the project site. There is therefore no potential for landslide at the site.

47 U.S. Department of Interior, U.S. Geological Survey, Preliminary Maps of Quaternary Deposits and Liquefaction Susceptibility, Nine-County San Francisco Bay Region, California, Open File Report 00-444, 2000.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Result in substantial soil erosion or the loss of topsoil? ⌧

Explanation: The proposed project would occur on a level site that is fully developed with impervious surfaces including buildings and pavements. The project would not expose surface soils, and therefore would not create any potential for erosion from wind and stormwater runoff.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site ⌧ landslide, lateral spreading, subsidence, liquefaction, or collapse?

Explanation: The proposed project would not construct new structures on the site. The project therefore has no potential to increase the hazard related to unstable subsurface conditions.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), ⌧ creating substantial risks to life or property?

Explanation: The proposed project would not construct new structures on the site. The project therefore has no potential to increase the hazard related to expansive soils.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the ⌧ disposal of wastewater?

Explanation: The project site is served by a municipal sewer system, and the proposed project would not require the use of a septic or alternative wastewater disposal system.

VII. GREENHOUSE GAS EMISSIONS — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the ⌧ environment?

Explanation: The California Air Resources Board’s (CARB) OFFROAD48 and EMFAC201449 emissions inventory models were used to quantify greenhouse gas (GHG) emissions associated with operational activities of the proposed project. The U.S Environmental Protection Agency’s (USEPA) Current Methodologies in Preparing Mobile Source Port-Related Emissions was used to estimate GHG emissions from marine vessel (bulk carriers) and harbor craft operations.50 GHG emissions would be generated primarily by operation of onsite off-road equipment (such as excavators and loaders), marine vessels, harbor craft, haul trucks, (primarily diesel-operated), and worker automobile trips (primarily gasoline-operated). Air quality calculations and assumptions are described in Appendix AQ–2. The setting and regulatory context for GHG emissions and climate change are described in Appendix AQ–4.

As previously discussed in Section III, logging trucks would begin at a site in West Sacramento, which is within the Yolo-Solano Air Quality Management District (YSAQMD). Approximately half way to the proposed facility, logging trucks would cross over into the Bay Area Air Quality Management District (BAAQMD). Log truck trip lengths were estimated to be 148 miles per round trip (80 miles within BAAQMD and 68 miles within YSAQMD). Within EMFAC2014, the log trucks were classified as T7 tractor trucks. Logs arriving with bark still on would be debarked and removed bark would be picked up in 25-ton semi-trailer trucks and dropped off

48 California Air Resources Board, OFFROAD Instructions, http://www.arb.ca.gov/msprog/ordiesel/ info_1085/oei_write_up.pdf. 49 California Air Resources Board, EMFAC User’s Guide, December 30, 2014, http://www.arb.ca.gov/msei/ emfac2014_users_guide.pdf. 50 US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emissions, April 2009, http://trid.trb.org/view.aspx?id=927750

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to end markets in the Bay Area. Within EMFAC2014, the bark trucks were also classified as T7 tractor trucks.

Log export shipments would occur during the timber harvesting season in California, which starts in April and continues through November. With six shipments anticipated each year, there would be an estimated one shipment each five weeks. While in dock, the ships would not be equipped to use shoreline electrical power and the ship’s auxiliary engines would be required during hotelling at the berth. It would take up to ten days to load a ship. Marine vessel GHG emissions were quantified within California waters (to a distance of approximately 12 miles from Golden Gate).52 Operational equipment at the proposed project would include an excavator, front loader with claws, street sweeper, and an electric powered debarker.

The YSAQMD currently does not have an adopted or recommended GHG threshold of significance. Only log truck operations occur within YSAQMD. The estimated annual GHG emissions in the YSAQMD from the proposed project would be approximately 250 metric tons of carbon dioxide equivalent (CO2e) per year.

Estimated annual GHG emissions associated with the proposed project that would occur within the BAAQMD are presented in Table GH–1 and are compared to BAAQMD’s GHG significance threshold. The BAAQMD has an adopted operational GHG significance threshold of 1,100 metric tons of CO2e per year.

Table GH–1 Estimated Annual Greenhouse Gas Emissions in the BAAQMD

Emission Source Annual CO2e Metric Tons

Onsite Equipment 162 Marine Vessels 114 Harbor Craft 12.9 Log Trucks 222 Bark Trucks 12.2 Worker Automobiles 21.6 Total Project Emissions 545 BAAQMD Significance Threshold 1,100 Potentially Significant? No

Source: CARB OFFROAD 2011,CARB EMFAC2014

Note: See Appendix AQ–2 for air quality calculations and assumptions.

52 According to BAAQMD, emissions from water travel occurring entirely within the local government’s geographic boundary should be included. Emissions from water travel occurring outside the geographic boundaries of the community (such as with sea travel) should not be included.

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As shown in Table GH–1, the estimated GHG emissions in the BAAQMD from the proposed project would be approximately 545 metric tons of CO2e per year, which is below the BAAQMD’s significance threshold of 1,100 metric tons of CO2e per year. Thus, the proposed project would have a less-than-significant impact from GHG emissions in the BAAQMD. Even with the addition of the GHG emissions that would occur within the YSAQMD (250 metric tons), the total GHG emissions of 795 metric tons would be below the significance threshold of 1,100 metric tons of CO2e per year.

According to the proposed project design and methodology assumptions, the estimated marine vessel and harbor craft fuel usage within California waters would be approximately 12,245 gallons. The estimated fuel usage for truck trips would be 40,430 gallons. The estimated fuel usage for onsite equipment would be 15,900 gallons.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of ⌧ greenhouse gases?

Explanation: The City of Richmond is developing a Climate Action Plan (CAP) intended to reduce GHG emissions in the City.53 The CAP will be a roadmap for how the City will reduce energy consumption and GHG emissions to meet State GHG emissions targets established by Assembly Bill 32 (AB 32), which is the principal planning and policy document adopted for the purpose of reducing GHG emissions Statewide. The quantitative goal of AB 32 is to reduce GHG emissions to 1990 levels by 2020. Statewide plans and regulations such as GHG emissions standards for vehicles and the low carbon fuel standard are being implemented at the Statewide level, and compliance at the specific plan or project level is not addressed. The assumption is that AB 32 will be successful in reducing GHG emissions and reducing the cumulative GHG emissions Statewide by 2020. The State has taken these measures, because no project individually could have a major impact (either positively or negatively) on the global concentration of GHGs. Therefore, the proposed project would result in a significant impact if it would be in conflict with AB 32 State goals. The proposed project was reviewed relative to the AB 32 measures and it was determined that the proposed project would not conflict with the goals of AB 32.

VIII. HAZARDS AND HAZARDOUS MATERIALS — Would the project:

The proposed project would have a potentially significant health and safety impact that is not addressed by the standard CEQA Initial Study Environmental Checklist. The handling and movement of large logs and the creation of large stacks of stored logs that could be unstable are potentially hazardous to the health and safety of workers on the site. Please see Section VI(a)(ii) for further discussion of the potential impact and appropriate mitigation requirements.

53 City of Richmond. Climate Action Plan, Adopted October 2016. http://www.ci.richmond.ca.us/ DocumentCenter/View/40636.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Create a significant hazard to the public or the environment through the routine transport, use, or ⌧ disposal of hazardous materials?

Explanation: The proposed project would not involve the routine transport, use, or disposal of hazardous materials. Fuels for trucks and equipment would be purchased at licensed off-site dispensaries. No fuel or other hazardous substances would be stored or used on the site in quantities requiring permitting; there would just be small, containerized quantities of fluids typically used for vehicle and equipment maintenance.54, 55 Therefore, there is no potential for the project to create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of ⌧ hazardous materials into the environment?

Explanation:

Phase I Environmental Site Assessment A Phase I Environmental Site Assessment (ESA) of the project site was performed by KC Engineering Company in September 2015.56 The purpose of the ESA was to identify recognized environmental conditions on the project site, including the presence or likely presence of any hazardous substances that could create a significant hazard to the public or the environment, whether through an existing release, past release, or threat of a release into structures, into the ground, or into surface or groundwater.

The Phase I ESA included a review of publicly available local, State, and federal environmental databases; historical topographic maps from 1895 through 1995; aerial photographs from 1939 through 2012; fire insurance maps dated 1930 to 1970; City directories spanning 1980 to 2013; and other City and County records. KC Engineering also conducted a reconnaissance of the property and an interview with the current occupant of the property regarding his knowledge of the site history and conditions.

54 Richard Lyu, President, RJJ Resource Management Corp., personal communication, November 10, 2015. 55 Eric Mendoza-Govan, Fire Inspector, Richmond Fire Department, personal communication, January 26, 2016. 56 Stantec Consulting Services, Inc., Op. Cit.

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Regulatory Database Records As part of the records search, 111 federal, State, local, tribal, and proprietary databases were reviewed by Environmental Data Resources, Inc. (EDR). The project site was identified on numerous databases, including: the Resource, Conservation, and Recovery Act (RCRA) Small Quantity Generator (SQG) database; Emergency Response Notification System (ERNS) database; Leaking Underground Storage Tank (LUST) database; Spills, Leaks, Investigations and Cleanup (SLIC) database; Statewide Environmental Evaluation and Planning System (SWEEPS UST) database; Hazardous Substance Storage Container (HIST UST) database; CA Facility Inventory Database (FID UST) database; CA Hazardous Material Incident Report System (CHMIRS) database; Facility Index System (FINDS) database; HAZNET database; Hazardous Waste and Substance Site List (HIST CORTESE) database; National Pollutant Discharge Elimination System (NPDES) database; Contra Costa County Site List database; and Waste Discharge System (WDS) database. The property address of 1411 Harbour Way South is listed under the names of: The Alecto/Hull #710546; Stevedoring Services of America; South Seas Steamship Co.; Richmond Multi-Terminals; Terminal 3 City of Richmond; Octopus IMO#1007213; Pacific Battleship Center – USS Iowa; Pacific IMO#996165; Metropolitan CA; and Port of Richmond.

The project site is listed by the Contra Costa County Environmental Health Department as an inactive Underground Storage Tank (UST) facility and as an inactive hazardous waste generator site. A 10,000-gallon diesel UST and a 1,650-gallon gasoline UST were installed on the property in 1978; both were removed in September 1998 under the oversight of the San Francisco Bay Regional Water Quality Control Board (RWQCB). Soil and groundwater samples collected from the area of the former USTs determined that the groundwater was contaminated with elevated levels of petroleum hydrocarbons, including total petroleum hydrocarbons as diesel (TPHd), total petroleum hydrocarbons as gasoline (TPHg), benzene, toluene, ethylbenzene, xylenes, and methyl tertiary butyl ether (MTBE). Although the Phase I ESA does not report on whether any site remediation activities were implemented, it does note that additional soil and groundwater samples were collected from the area of the former UST pit in September 2007 and, based on the laboratory results, the case eventually received regulatory closure from the San Francisco Bay RWQCB in 2010.

The RWQCB closure report notes that the pollutants had attenuated to non-detectable levels in the soil and to low or non-detectable levels in the groundwater, and states that the site does not represent a significant risk to public health, the environment, or water resources. However, the closure summary does state that “there may be residual contamination in both soil and groundwater at the site that could pose an unacceptable risk under certain development activities such as site grading, excavation, or installation of water wells.” Absent this type of changes to use of the property, the RWQCB closure report stated that no corrective action was necessary. Since the proposed project would not require any grading, excavation, or installation of water wells, no further investigation or remediation of potential contamination of soil and/or groundwater at the site is warranted.

With respect to the other regulatory database listings of the property, the Phase I ESA noted that no institutional controls or engineering controls were identified for the site, and concluded that there were no unmitigated, historical, or controlled recognized environmental conditions (RECs) present on the site, and no further environmental investigation of the property was recommended.

Off-Site Hazardous Materials Sites The regulatory database search identified 43 offsite hazardous materials use, storage, disposal, or release sites within the applicable search radius (0.25 mile to 1 mile) from the project site.

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Twenty-five (25) of the 43 sites were identified as having had a reported spill or release of hazardous materials. The Phase I ESA determined that the 18 hazardous materials use, storage, or disposal sites where no spill or release of hazardous materials has been reported are not considered a recognized environmental condition (REC) for the project site. Of the 25 identified hazardous materials release sites, 20 of them have received regulatory agency closure, and are therefore not considered a REC for the project site. The five release sites that have not received regulatory agency closure are discussed below:

1. United Heckathorn Company, located at South 8th Street and Wright Avenue, is identified on several databases including the National Priorities List (NPL) database. The United Heckathorn site was used from approximately 1947 to 1966 to formulate and package pesticides including DDT. Various solvents were used to dissolve DDT and other pesticides into liquid formulations. Contaminated soil and groundwater were identified at this site, as well as contaminated wastewater that was discharged into Lauritzen Channel. The former processing facilities have been demolished and the area has been capped. Contaminated soils have been excavated and removed from this site. At its closest point, the contamination plume from this site is located approximately 0.25-mile north of the subject property. Based on the distance of this site from the property, and the reported groundwater flow direction beneath the property (west), the Phase I ESA concluded that this site is not considered a REC for the subject property.

2. Richmond Bulk Terminal, located approximately 0.25-mile west of the property at 1306 Canal Boulevard, is identified as an open remediation site on the SLIC database. Harbor Channel is located between this site and the subject property, and therefore the Phase I ESA concluded that this site is not considered a REC for the subject property.

3. Unocal Richmond Terminal, located approximately 0.35-mile west of the property at 1300 Canal Boulevard, is identified as an open remediation site on the SLIC database. Harbor Channel is located between this site and the subject property, and the Phase I ESA concluded that therefore this site is not considered a REC for the subject property.

4. Time Oil Company/Shore Terminals Mart, located approximately 0.35-mile northwest of the property at 488 Wright Avenue, is identified as an open site on the SLIC database. Verification monitoring is ongoing at this facility. Based on the distance of this site from the subject property, and the reported groundwater flow direction beneath the property (west), the Phase I ESA concluded that it is not considered a REC for the subject property.

5. Sun Oil Company Tank, located approximately 0.45-mile north of the property at 810 Wright Avenue, is identified as an open remediation site on the SLIC database. Based on the distance of this site from the subject property, and the reported groundwater flow direction beneath the property (west), the Phase I ESA concluded that it is not considered a REC for the subject property.

Historical Use of the Site Based on a review of historical topographic maps, aerial photos, fire insurance maps, and City directories, development on the project site dates at least to 1930, when the northwest portion of the site was occupied by a large building identified as Parr-Richmond Inner Harbor Terminal, Municipal Wharf No. 3. Scott Avenue was located on the central portion of the site, which was bordered on the east by South 10th Street. By 1946, four small buildings had been added to the

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site south of Scott Avenue; a storage yard was also on the southern portion of the site. Harbour Way South adjoined the property to the east, although Sanborn fire insurance maps continued to identify it as 10th Street. Two railroad spurs were located in the north half of the site, on either side of the large warehouse. These spurs appeared to be no longer present at the time a 1958 aerial photograph of the site was taken, nor do they appear on subsequent aerial photos, though they are depicted on all historical topographic maps of the area from 1949 on. (No railroad spurs are currently present on the site.)

Two warehouses had been added to the property by 1968, one east and one southeast of the original warehouse building, while the remainder of the site was used for parking and storage. By 1982, all of the buildings previously on the site had been removed and a new office building, extant today, had been added to the southeast portion of the site. Four large cranes had been installed in the northwest portion of the site. The remainder of the site was paved and used for storage of shipping containers. The aerial photo from 1993 as well as the 1993 USGS topo map both show a warehouse building added to the northeast edge of the site. This building had been enlarged to its current size by 1998 by an addition to the southern end of the warehouse. Two of the cranes present in 1982 had been removed. By 1998, the site appeared largely as it does today.

Based on the review of historic maps and other records, the Phase I ESA determined that no obvious RECs are present on the site. It also noted that no significant data gaps or failures hindered the environmental assessment.

Environmental Conditions on the Site During the reconnaissance of the project site, KC Engineering observed no improper drainage discharge from the site and no evidence of USTs or other subsurface structures other than common utilities (sewer and storm drains). KC Engineering also found no evidence of electrical or hydraulic equipment on the site with the potential to contain polychlorinated biphenyls (PCBs). Nine metal grates identified as “deep well” were observed on the western portion of the site, but their purpose was unknown. Utility pole-mounted transformers that would be unaffected by the proposed project were observed along Harbour Way South.

The Phase I ESA found no evidence of use, storage, or disposal of regulated quantities of hazardous materials on the site, including petroleum products, and no above-ground storage tanks (ASTs). No obvious wastewater discharge was observed on the property, nor were elevators, sumps, basements, hoists, or hydraulic lifts were observed. There were no stained soils; stained pavement; discolored water; stressed vegetation; or strong, pungent, or noxious odors noticeable on the property during the site reconnaissance conducted as part of the Phase I ESA. Nor were standing surface waters—including pits, ponds, and lagoons—observed on the property. Several storm drains are located on the property that discharge onto adjacent parcels, streets, and into the adjoining channel.

Conclusions The Phase I ESA found no evidence on the project site of unmitigated RECs, historical RECs, or controlled RECs. While it noted that residual subsurface contamination may remain in the north end of the site in the vicinity of the former USTs, the proposed project would not expose workers to potential safety hazards from exposure to residual contaminants because the project would not entail any subsurface disturbance. As noted above, the soil and groundwater contamination with petroleum hydrocarbons received regulatory case closure from the San Francisco Bay RWQCB in 2010.

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If any future changes in land use or other activities were proposed for the site, the Contra Costa County Health Services Department should be notified and an appropriate work plan approved by that agency. However, for the proposed log storage and shipping facility, the Phase I ESA concluded that no further environmental investigation or remediation of the site is warranted.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed ⌧ school?

Explanation: Benito Juarez Elementary School, at 1450 Marina Way South, is located approximately one-quarter mile east of the project site. However, the proposed project would not emit hazardous emissions, handle hazardous materials, or generate hazardous waste. There would be no project impact on schools related to hazardous materials.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, ⌧ would it create a significant hazard to the public or the environment?

Explanation: As discussed in more detail in Section VIII(b), above, the Phase I ESA performed for the project included a search of multiple federal and State agency databases for hazardous materials release sites, hazardous materials use and storage sites, or hazardous waste generation, including those compiled pursuant to Government Code Section 65962.5. Although the project site is listed on numerous regulatory databases due to historical storage of hazardous materials and leaking underground storage tanks, there are no current hazards on the site related to hazardous materials. Please see Section VIII(b) for additional information.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) For a project within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would ⌧ the project result in a safety hazard for people residing or working in the project area?

Explanation: There are no airports within 2 miles of the project site; the nearest public airport is Oakland International Airport, in the City of Oakland, located approximately 15 miles southeast of the site.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) For a project within the vicinity of a private airstrip, would the project result in a safety hazard for people ⌧ residing or working in the project area?

Explanation: There are no private airstrips in the vicinity of the project site. The nearest private airstrip is San Rafael Airport, formerly Smith Ranch Airport, located about 11 miles northwest of the project site.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact g) Impair implementation of or physically interfere with an adopted emergency response plan or emergency ⌧ evacuation plan?

Explanation: In the event of a large-scale disaster, emergency response to the site would be coordinated by City responders with other response in the City. With two entrance gates, the site currently provides adequate emergency access and egress. Implementation of the project would not alter existing streets or otherwise interfere with emergency evacuation routes. There is therefore no potential for the project to impair implementation of emergency evacuation or emergency response plans

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact h) Expose people or structures to significant risk of loss, injury, or death involving wildland fires, including where wildlands are adjacent to urbanized areas or ⌧ where residences are intermixed with wildlands?

Explanation: The project is located in a fully built-out area with industrial, light industrial, and institutional development in the vicinity of the site. There are no wildlands in the project area, and therefore there is no potential for the proposed project to result in the exposure of people or structures to wildland fires.

IX. HYDROLOGY AND WATER QUALITY — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Violate any water quality standards or waste discharge requirements? ⌧

Explanation:

Pollution Potential Urban development has a high potential to adversely affect water quality in surface water bodies, due to the concentration and characteristics of water pollution sources in the urban environment. The most widespread and pervasive source of pollutants is from trucks, automobiles, off-road construction equipment, and other vehicles. These vehicles can deposit oil and grease, fuel residues, heavy metals (e.g. lead, copper, cadmium, and zinc), tire particles, and other pollutants onto roadways and parking areas. The contaminants can be washed by stormwater runoff into storm drains that ultimately discharge to surface waterways, degrading water quality in the receiving water bodies that may be used for swimming, fishing, drinking water, and other beneficial uses. Polluted urban stormwater runoff can cause changes in hydrology and water quality that result in habitat modification and loss, increased flooding, decreased aquatic biological diversity, increased sedimentation and erosion, and potential adverse effects on human health and safety.

Due to its location adjacent to the Richmond Inner Harbor, the project site has a direct pathway for releasing pollutants into San Francisco Bay, which is on the list of impaired water bodies compiled by the San Francisco Bay Regional Water Quality Control Board (RWQCB) pursuant to Section 303(d) of the federal Clean Water Act (CWA). It is listed as impaired for a wide range of pollutants, including chlordane, dichloro-diphenyl-trichloroethane (DDT), dieldrin, dioxin

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compounds, polychlorinated biphenyls (PCBs), mercury, selenium, furan compounds, and trash.57

Industrial properties can be significant sources of water quality pollutants, both from the direct discharge of effluents as well as from surface runoff and emissions of air pollutants that subsequently get washed out of the atmosphere by rainfall. Other common sources of water pollutants are vehicle fueling areas common at many industrial sites, where spills can occur during delivery and when topping off fuel tanks, leaks can occur from leaking storage tanks, and uncontrolled discharge can result from hosing down the fuel area and from rainfall running off from the fuel area. Some of the industries that have a significant potential to adversely affect water quality include cement, fertilizer, petroleum, and phosphate manufacturing; coal and mineral mining; roofing and paving with tars and asphalt; landfills; and airport de-icing. Marine port operations are typically treated as industrial land uses for purposes of regulating discharges to surface waters.

The industrial neighbor immediately to the north of the Terminal 3 property expressed concern about the potential for contaminated stormwater from Terminal 3 to encroach on its leased property. The California Oils Corporation, which leases Terminal 2 from the Port of Richmond, noted in a comment letter submitted to the City of Richmond on the prior Initial Study for the proposed project that it is subject to water quality monitoring by the State Water Resources Control Board (SWRCB). The company expressed concerned that stormwater runoff could migrate from the log layout area at Terminal 3 (depicted on Figure 3) and adversely affect the quality of water samples that the California Oils Corporation must submit on a regular basis to the SWRCB for review. To address this concern, as a condition of project approval, the City will require the applicant to construct a concrete berm or curb along the northern property line of Terminal 3 to ensure that stormwater runoff from Terminal 3 will be prevented from migrating onto the Terminal 2 property.

The California Oils Corporation comment letter also expressed concern that logs may be fumigated or otherwise chemically treated prior to shipment overseas. However, the only processing of the logs would be the removal of bark from logs that have not already been debarked prior to their arrival at Terminal 3. No chemicals would be used or applied to logs.

Regulatory Framework Protection of surface water quality is regulated by the U.S. Environmental Protection Agency (EPA) pursuant to the federal Clean Water Act (CWA), which prohibits certain discharges of stormwater containing pollutants except in compliance with a National Pollutant Discharge Elimination System (NPDES) permit. The NPDES stormwater program regulates some stormwater discharges from three potential sources: municipal separate storm sewer systems (MS4s), construction activities, and industrial activities. The NPDES permitting program establishes discharge limits and conditions for industrial and commercial sources with specific limitations based on the type of facility/activity generating the discharge.

In California, the EPA has authorized the State Water Resources Control Board (SWRCB) to administer the NPDES industrial stormwater permitting program. On April 1, 2014 the SWRCB adopted the NPDES General Permit for Stormwater Discharges Associated with Industrial Activities (NPDES Permit No. CAS000001), which became effective on July 1, 2015. The permit replaced the previous permit, issued under Water Quality Order 97-03-DWQ by the SWRCB on

57 San Francisco Bay Regional Water Quality Control Board, Final 2010 Integrated Report (CWA Section 303(d) List/305(b) Report), Category 5 2010 California 303(d) List of Water Quality Limited Segments, USEPA Final Approval October 11, 2011, accessed December 10, 2015 at: http://www.waterboards.ca.gov/water_issues/programs/tmdl/2010state_ir_reports/category5_report.shtml.

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April 17, 1997. In the San Francisco Bay Area, the permit is enforced by the RWQCB. Among other changes, the new permit requires dischargers to implement a set of minimum Best Management Practices (BMPs) intended to prevent or reduce pollutants in industrial stormwater discharges. The minimum BMPs are primarily non-structural BMPs, but they also include advanced structural BMPs, consisting of treatment controls, exposure reduction, and stormwater containment BMPs. The minimum and advanced BMPs required in the Industrial General Permit are consistent with the EPA’s 2008 Multi-Sector General Permit for Stormwater Discharges Associated with Industrial Activity (2008 MSGP), guidance developed by the California Stormwater Quality Association, and recommendations by RWQCB inspectors.

The required BMPs include: Minimization of Exposure to Storm Water; Good Housekeeping; Preventive Maintenance; Spill and Leak Prevention and Response; Erosion and Sediments Controls; Management of Runoff; Salt Storage Piles or Piles Containing Salt; Sector Specific Non-Numeric Effluent Limits; Employee Training Program; Non-Stormwater Waste Discharges (NSWDs); Material Handling and Waste Management; Waste, Garbage and Floatable Debris; Dust Generation and Vehicle Tracking of Industrial Materials; and more. All of these BMPs are described/defined in the permit.

The NPDES Industrial General Permit (IGP) also requires implementation of Best Available Technology Economically Achievable (BAT) and Best Conventional Pollutant Control Technology (BCT) to reduce or eliminate pollutants in stormwater discharges and authorized non-storm water discharges (NSWDs). Section 402(p)(3)(A) of the CWA also requires discharges covered by the IGP to include requirements necessary to meet water quality standards. The IGP does not cover discharges from construction and land disturbance activities, which require separate application for and coverage under the RWQCB’s NPDES Construction General Permit.

Obtaining Coverage Under the NPDES Industrial General Permit Certain categories of industrial activities are required to obtain coverage under the IGP; there are 11 general categories that are further defined according to the Standard Industrial Classification (SIC) code. The codes are applicable to all primary activities and auxiliary functions at any facility. A number of SIC codes appear to apply to the proposed project, all of which fall under the umbrella category of Water Transportation (SIC Code 44). These include Deep Sea Foreign Transportation of Freight (SIC Code 4412), Marine Cargo Handling (SIC Code 4491), and a variety of subcategories. The RWQCB has confirmed that SIC Code 4491 would apply to the proposed project, which would require coverage under the Industrial General Permit.58

New Dischargers applying for coverage under the IGP that will be discharging to an impaired water body with a 303(d) listed impairment are ineligible for coverage unless the Discharger submits data and/or information, prepared by a Qualified Industrial Storm Water Practitioner (QISP), demonstrating that the facility will not cause or contribute to the impairment. The QISP must demonstrate one of the following: 1. The Discharger has eliminated all exposure to storm water of the pollutant(s) for which the water body is impaired, has documented the procedures taken to prevent exposure onsite, and has retained such documentation with the SWPPP at the facility; 2. The pollutant for which the water body is impaired is not present at the Discharger’s facility, and the Discharger has retained documentation of this finding with the SWPPP at the facility; or

58 Michelle Rembaum-Fox, QSP, Engineering Geologist, California Regional Water Quality Control Board, San Francisco Bay Region, personal communication, November 19, 2015.

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3. The discharge of any listed pollutant will not cause or contribute to an exceedance of a water quality standard. This is demonstrated if: (1) the discharge complies with water quality standards at the point of discharge, or (2) if there are sufficient remaining waste load allocations in an approved Total Maximum Daily Load (TMDL) and the discharge is controlled at least as stringently as similar discharges subject to that TMDL.

The IGP requires that all Dischargers to develop, implement, and retain onsite a site-specific Stormwater Pollution Prevention Plan (SWPPP). The SWPPP requirements generally follow EPA’s five-phase approach to developing SWPPPs, with modifications to reflect the requirements of the IGP. The approach provides the flexibility necessary to establish appropriate BMPs for different industrial activities and pollutant sources. The SWPPP must include a site map, authorized NSWDs at the facility, and an identification and assessment of potential pollutants sources resulting from exposure of industrial activities to stormwater. The SWPPP must clearly describe the BMPs that are being implemented, who is responsible for the BMPs, where the BMPs will be installed, and when and how often the BMPs will be implemented.

The SWPPP must also provide for training of employees for the Pollution Prevention Team responsible for implementing and monitoring the SWPPP and BMPs, record keeping, monitoring, and an annual evaluation. The monitoring requirements are quite detailed and prescribed, and must occur during at least four annual Qualifying Storm Events (QSEs) that are defined by the permit, unless there are fewer than four QSEs during the monitoring period. A detailed Monitoring Implementation Plan must be included in the SWPPP.

In order to obtain coverage under the Industrial General Permit, a Discharger must prepare, certify, and electronically file Permit Registration Documents (PRDs) via the SWRCB’s Storm Water Multiple Application and Report Tracking System (SMARTS), which include a Notice of Intent (NOI), a risk assessment, site map, signed certification, Stormwater Pollution Prevention Plan (SWPPP), and other site-specific PRDs that may be required.

Exemption From Coverage Under the NPDES Industrial General Permit Entities that operate facilities generating stormwater associated with industrial activities that is not discharged to waters of the United States are not required to obtain Industrial General Permit coverage. In addition, some Dischargers may file a claim of “No Discharge” in order to obtain an exemption from the majority of the IGP requirements. The IGP applies EPA Phase II regulations regarding a conditional exclusion for facilities that have no exposure of industrial activities and materials to stormwater.59

Any type of industry can claim a conditional exclusion by filing a Notice of Non-Applicability (NONA). The Discharger must submit and certify in SMARTS a NONA Technical Report that contains the analysis and details of the containment design supporting the “No Discharge” eligibility determination. Because containment design will require hydraulic calculations, soil permeability analysis, soil stability calculations, appropriate safety factor consideration, and the application of other general engineering principles, State law requires the technical report to be signed with a wet signature and license number by a California licensed professional engineer. The No Exposure Certification (NEC) requires enrollment for coverage before a Discharger can be excluded from the majority of the Industrial General Permit requirements.

59 40 C.F.R. § 122.26(g).

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Additional Requirements for Port Facilities The California Ocean Plan was adopted by the SWRCB on October 16, 2012 for purposes of protecting water quality and marine communities in all near coastal ocean waters. Effective as of August 19, 2013, the Ocean Plan prohibits the discharge of waste to Areas of Special Biological Significance (ASBS). ASBSs are defined in the California Ocean Plan as “those areas designated by the SWRCB as ocean areas requiring protection of species or biological communities to the extent that alteration of natural water quality is undesirable.”

For discharges related to waterfront and marine operations, Dischargers must develop a Waterfront and Marine Operations Management Plan (Waterfront Plan) that identifies appropriate management measures and practices to reduce or eliminate non-point source pollutant discharges to the affected ASBS. These include any waste discharges associated with the operation and maintenance of vessels, moorings, piers, launch ramps, and cleaning stations. The requirements are intended to ensure that beneficial uses are protected and natural water quality is maintained in the affected ASBS.

The California Ocean Plan does not apply to enclosed bays or estuaries meeting certain criteria. It does not apply to San Francisco Bay and, therefore, the proposed project would not be required to prepare a Waterfront Plan.

Regulation of Vessel Discharges Pursuant to the federal Clean Water Act, the EPA regulates discharges incidental to the normal operation of vessels via a Vessel General Permit (VGP), which is applicable to non-recreational ships operating in Waters of the U.S., including the territorial seas that extend 3 miles outward from the U.S. coastline. The EPA also administers a streamlined Small Vessel General Permit (sVGP) that applies to commercial vessels less than 79 feet in length. The Handymax class vessels that would be used for the proposed project would be subject to the VGP. The VGP was initially issued in December 2008 and expired on December 19, 2013, when the current VGP became effective. The current permit will expire on December 19, 2018. EPA estimates that the domestic vessel population subject to the VGP is approximately 60,000 vessels, and another 12,400 foreign flagged vessels are also subject to the VGP requirements.

The VGP is an NPDES permit issued under EPA’s regulatory authority under Section 402 of the CWA. It applies to vessels operating in a capacity as a means of transportation, including commercial fishing vessels, cruise ships, ferries, barges, mobile offshore drilling units, oil and petroleum tankers, bulk carriers, cargo ships, container ships, other cargo freighters, refrigerant ships, research vessels, emergency response vessels, including firefighting and police vessels, and any other vessels operating in a capacity as a means of transportation. Vessels of the Armed Forces of the United States are not covered by the permit.

The VGP establishes effluent limitations to control a variety of materials that fall into the following categories: Aquatic Nuisance Species (ANS), nutrients, pathogens (including E. coli & fecal coliform), oil and grease, metals, most conventional pollutants (Biochemical Oxygen Demand, pH, Total Suspended Solids), and other toxic and non-conventional pollutants with toxic effects. EPA has established effluent limitations to control these materials because, depending on the particular vessel, such materials are constituents in the industrial waste, chemical waste and/or garbage “pollutant” discharge resulting from the activities of these vessels. “Industrial waste,” “chemical waste” and “garbage” are expressly included in the CWA’s definition of “pollutant,” which governs, among other things, which discharges are properly subject to the CWA. The CWA authorizes the EPA to issue permits for the “discharge of any pollutant” to navigable Waters of the U.S.

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The VGP covers a broad range of incidental vessel discharges, such as ballast water, bilge water, gray water (e.g., water from sinks, showers), and deck wash-down and runoff. The VGP also sets forth requirements applicable to 25 specific states, including California. Among other things, it requires vessel discharges in California to comply with the requirements and discharge prohibitions established in the California Clean Coast Act of 2005, and prohibits vessel discharges from Water Quality Protection Areas defined in Public Resources Code Sections 36700-36900. It prohibits discharge of bilge water and discharges containing hazardous waste as defined in California Code of Regulations Title 22, Section 66261 and in Water Code Section 13173. A variety of other regulations pertaining to vessels operating in California are included in the VGP.

To obtain authorization to discharge under the VGP, the owner or operator of any vessel of 300 gross tons or more or with a ballast water capacity of more than 8 cubic meters (2,113 gallons) must submit a Notice of Intent (NOI) to the EPA via its Electronic Notice of Intent (eNOI) system at: http://www.epa.gov/npdes/vessels/eNOI. Vessel discharges occurring prior to seven days after EPA processes the NOI will be in violation of the VGP. Submittal of paper NOIs is permitted only if the discharger meets one of the electronic reporting exemptions list in Part 1.14 of the permit, in which case, the NOI must be processed by the EPA at least 30 days prior to any discharge. If a vessel is exempt from the NOI requirement due to its size, it must maintain a signed copy of the Permit Authorization and Record of Inspection (PARI) form onboard the vessel.

The NOI includes information about the owner/operator of the vessel, a variety of details about the vessel, general voyage information (i.e., destination ports, crew capacity, etc.), specific information about the different discharges from the vessel and any onboard treatment systems, and certification under penalty of law that the information in the NOI is complete and accurate and that the discharge limits and other applicable terms of the VGP will be adhered to during vessel operations.

Potential Water Quality Impacts Operation of the proposed project would have the potential to adversely affect water quality in San Francisco Bay and in ocean waters near coastal California. Such impacts could occur from the uncontrolled discharge of stormwater from the site that could be contaminated by leaking equipment or trucks or from accidental spills. Bay and seawater could also be contaminated by uncontrolled discharges from the ships carrying prepared logs to China. These effects would be a potentially significant adverse impact on water quality. The impact would be reduced to a less-than-significant level with implementation of Mitigation Measures WQ–1 and WQ–2, below.

Mitigation Measure WQ–1: The project sponsor shall obtain National Pollutant Discharge Elimination System (NPDES) coverage under the Industrial General Permit (IGP) No. CAS000001, adopted by State Water Resources Control Board (SWRCB) Order No. 2014-0057-DWQ. Pursuant to the Order, the project applicant shall electronically file the Permit Registration Documents (PRDs) via the SWRCB’s Storm Water Multiple Application and Report Tracking System (SMARTS) at: https://smarts.waterboards.ca.gov/smarts/faces/ SwSmartsLogin.jsp. The required PRDs include a Notice of Intent (NOI), a risk assessment, site map, signed certification, Stormwater Pollution Prevention Plan (SWPPP), and other site- specific PRDs that may be required. At a minimum the SWPPP shall include a site map, authorized NSWDs at the facility, and an identification and assessment of potential pollutants sources

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resulting from exposure of industrial activities to stormwater. The SWPPP must clearly describe the Best Management Practices (BMPs) that are being implemented, who is responsible for the BMPs, where the BMPs will be installed, and when and how often the BMPs will be implemented. The PRDs shall be submitted at least seven days prior to commencing discharge.

Mitigation Measure WQ–2: For all ships used to transport prepared logs to customers in China, the project sponsor shall obtain National Pollutant Discharge Elimination System (NPDES) coverage under the 2013 Vessel General Permit (VGP) issued by the U.S. Environmental Protection Agency (EPA), which became effective on December 18, 2013. To obtain coverage, the project sponsor shall complete and submit a Notice of Intent (NOI) to the EPA via its Electronic Notice of Intent (eNOI) system at: http://www.epa.gov/ npdes/vessels/eNOI. No discharges from project vessels may occur until seven days after the EPA has processed the NOI.

During public review of the previous Initial Study for the proposed project, California Oils Corporation, which leases the Port of Richmond Terminal 2 property located immediately to the north of the project site, expressed concern about stormwater runoff from the proposed project (see Appendix A). California Oils Corporation has a stormwater collection area adjacent to Terminal 3 that is subject to water quality monitoring by the State Water Resources Control Board (SWRCB). The company expressed concern that stormwater runoff could migrate from the log layout area at Terminal 3 (depicted on Figure 3 of the Initial Study) and adversely affect the quality of water samples that the California Oils Corporation must submit on a regular basis to the SWRCB for review. This would be a potentially significant impact that would be reduced to a less-than-significant level with implementation of the following mitigation measure:

Mitigation Measure WQ–3: The project applicant shall retain the services of a qualified hydrologist or hydrological engineer to conduct a hydrology analysis of the stormwater runoff patterns on the Terminal 3 property and determine whether stormwater and/or wind- blown debris from the Terminal 3 property could migrate onto adjacent properties, including the Terminal 2 property. If the analysis determines that such migration of pollutants could occur, the engineer shall identify a design solution to prevent the migration of stormwater and/or wind-blown debris onto adjacent properties. This design solution—which could entail erection of booms, construction of concrete berms or curbs along the property line(s) of Terminal 3, or other measures—shall be implemented by the applicant prior to commencing export operations.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level (e.g., the production rate of pre-existing nearby ⌧ wells would drop to a level that would not support existing land uses or planned uses for which permits have been granted)?

Explanation: The majority of the project site is already covered with impervious surfaces, consisting of pavements and buildings. A small strip of exposed soil is located adjacent to the shoreline south of the ship wharf, and a landscape strip runs along the eastern boundary of the site, adjacent to Harbour Way South. Due to its current condition, the project site does not provide for any appreciable amount of groundwater recharge. Because the proposed project would not create any new impervious surfaces at the project site, the project would have no effect on groundwater recharge or groundwater supplies.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, in a manner which ⌧ would result in substantial erosion or siltation on- or off-site?

Explanation: As noted in Section IX(b), above, the proposed project would not create any new impervious surfaces at the project site or otherwise alter the existing drainage patterns on the project site.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a ⌧ manner which would result in flooding on- or offsite?

Explanation: The project would not alter the course of a stream or river and would not alter the existing drainage pattern of the site. There is therefore no potential for the project to increase the risk of on- or off-site flooding.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional ⌧ sources of polluted runoff?

Explanation: As discussed above in Section IX(a), stormwater runoff from the site is discharged to San Francisco Bay. Normal operational deposits of oil, grease, heavy metals, and other contaminants would occur from the operation of diesel-powered trucks and equipment such as the front-end loader and excavator. These deposits along with potential accidental spills could potentially result in the pollutants being entrained in stormwater that would be discharged into the Bay. Although this would be a potentially significant impact, implementation of Mitigation Measure WQ–1 would ensure that the impact would remain less than significant, while implementation of Mitigation Measure WQ–2 would ensure that storm runoff and other discharges from ships transporting logs to China would not be a substantial source of pollutants.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) Otherwise substantially degrade water quality? ⌧

Explanation: See Section IX(a). Other than the impacts identified therein, the project would not have the potential to substantially degrade water quality.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact g) Place housing within a 100-year flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation ⌧ map?

Explanation: The project site is within a larger surrounding area mapped as Zone X by the Federal Emergency Management Agency (FEMA), which is the designation assigned to areas that have been determined to be outside of the 0.2 percent annual chance flood plain (i.e., the 500-year flood plain).60 In any event, the project would not create new housing.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact h) Place within a 100-year flood hazard area structures which would impede or redirect flood flows? ⌧

Explanation: As discussed in Section IX(g), above, the project site is not located within a 100- year or 500-year flood hazard area. In addition, the project would not create new structures.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact i) Expose people or structures to a significant risk of loss, injury, or death involving flooding, including ⌧ flooding as a result of the failure of a levee or dam?

Explanation: According to the General Plan EIR, although portions of the City of Richmond are located within the dam failure inundation zone for the San Pablo Reservoir dam, the East Bay Municipal Utilities District (EBMUD) completed a seismic upgrade of the dam foundation and buttress in September 2010, and the dam is now fully operational.61 General Plan Policy SN1.E requires the City to meet regularly with EBMUD staff to discuss dam failure hazards and EBMUD’s Emergency Action Plan. The General Plan EIR concluded that with implementation of applicable General Plan policies, new development in the City would be exposed to a less- than-significant impact from dam failure inundation. Furthermore, the project site is outside the dam failure inundation zone for San Pablo Reservoir, as determined by the California Office of

60 Federal Emergency Management Agency, Flood Insurance Rate Map, Contra Costa County, California and Incorporated Areas, Community Panel Number 06013C0236G, revised September 30, 2015. 61 City of Richmond, Richmond General Plan Update Draft Environmental Impact Report, Section 3.9, Hydrology and Water Quality, February 2011.

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Emergency Services.62 Therefore, the proposed project would not expose people or structures to risks associate with inundation from a dam failure.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact j) Inundation by seiche, tsunami, or mudflow? ⌧

Explanation: Tsunamis (seismic sea waves) are long-period waves that are typically caused by underwater disturbances (landslides), volcanic eruptions, or seismic events. Areas that are highly susceptible to tsunami inundation tend to be located in low-lying coastal areas such as tidal flats, marshlands, and former bay margins that have been artificially filled but are still at or near sea level. The project site is not located within a tsunami inundation area, as mapped by the California Emergency Management Agency.63 The site is also outside tsunami evacuation areas mapped by the Association of Bay Area Governments.64 Therefore, the project would not be subjection to inundation by tsunami.

A seiche is a free or standing wave oscillation(s) of the surface of water in an enclosed or semi- enclosed basin that may be initiated by an earthquake. Given its location adjacent to San Francisco Bay, the potential for a seiche run-up at the project site would not be greater than the potential for inundation by tsunami. The General Plan EIR also reported that there are no designated seiche risk areas within the City. Therefore, there is no potential for inundation by seiche at the project site.

Debris flows, mudslides, and mudflows begin during intense rainfall as shallow landslides on steep slopes. The rapid movement and sudden arrival of debris flows can pose a hazard to life and property during and immediately following a triggering rainfall. The project site is essentially flat, as is the surrounding area. There is therefore no potential for mudslides or debris flows.

62 California Office of Emergency Services, Dam Inundation Register Images and Boundary Files in ESRI Shapefile Format, September 2015. 63 California Emergency Management Agency, Tsunami Inundation Map for Emergency Planning, State of California, San Francisco Bay Area, December 9, 2009. 64 Association of Bay Area Governments, Resilience Program, Tsunami Evacuation Area (Interactive Map), accessed December 28, 2015 at: http://gis.abag.ca.gov/website/Hazards/?hlyr=tsunami.

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X. LAND USE AND PLANNING — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Physically divide an established community? ⌧

Explanation: The project site is currently developed with a large one-story warehouse, small three-story administration building, small guard house, and large areas of pavements. The project would not include any new construction such as new off-site roadways that could physically divide an existing neighborhood, nor would it otherwise create any barriers to existing circulation within the community. Therefore, implementation of the proposed project would not physically divide an established community.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project (including, but not limited to, the general plan, specific plan, local coastal program, or zoning ⌧ ordinance) adopted for the purposed of avoiding or mitigating an environmental effect?

Explanation:

General Plan: Land Use The General Plan land use designation of the site is Port, which is one of six Business and Industry land use classifications defined in the Richmond General Plan 2030. The Port category is applied to working waterfront uses, such as private and publicly-owned port terminals, warehousing, commercial fishing, ship repair, and related office uses. It has a height limit of 100 feet and an allowable floor area ratio (FAR) of 0.25 to 1.0. The proposed project is a principal permitted use within the Port land use designation. The project site is already developed with structures that conform to the height and FAR restrictions, and no new construction is proposed. The proposed project would conform to the Port General Plan land use designation.

The project site is located within the City’s Port Priority Use Area, one of six districts established in the City that provide a unique mix of uses that serve the entire community and/or where there is a concentration of related or complementary activities and uses. Some of these districts are considered “change areas” that provide significant economic development opportunities. Others, such as the San Pablo Peninsula Area, offer opportunities for open space preservation, recreation, and natural habitat protection. The Port Priority Use Area, which centers on the Santa Fe Channel adjacent to San Francisco Bay, is intended as an area providing

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opportunities for economic development. The General Plan notes that new improvements within this change area should focus on strengthening the overall economic vitality of the Port of Richmond. It states that the Port Priority Use Area is designated as Port to recognize and reflect the Port’s continuing role as a major hub of port and related industrial uses. The proposed log export facility is consistent with this objective.

The project site is adjacent to, but outside of, the Ford Peninsula in Marina Bay Change Area Major Activity Center (CA-3), one of three change areas identified in the General Plan as concentrated, high-intensity community hubs that generate revenue and jobs, and serve as the focal point of cultural, commercial, and social activities.

General Plan Policies All of the Richmond General Plan 2030 policies were reviewed to identify those applicable to the proposed project and evaluate the project’s consistency with those policies.

In particular, the project would further the City’s goal expressed in Land Use and Urban Design Policy LU3.5, An Economically Viable and Modern Port, which calls for developing the Ford Peninsula area as a working waterfront that supports the Port’s operations and provides opportunities for job-generating uses and other uses. It would also support Economic Development Policy ED8.6, An Economically Viable and Modern Port, which encourages growth and modernization of private port businesses and the Port of Richmond.

No conflicts with adopted General Plan policies were identified for the proposed project.

Other Planning Documents Due to its shoreline location adjacent to San Francisco Bay, land use at the project site is subject to the provisions of several additional local and regional plans, including the San Francisco Bay Plan, the South Richmond Shoreline Special Area Plan, the Knox Freeway/Cutting Boulevard Corridor Specific Plan, the San Francisco Bay Area Seaport Plan, and the San Francisco Bay Trail Plan. Each of these plans is discussed below.

San Francisco Bay Plan Established temporarily by the State by the 1965 McAteer-Petris Act, and permanently by the 1969 McAteer-Petris Act, the San Francisco Bay Conservation and Development Commission (BCDC) was established to halt the unregulated filling of San Francisco Bay, which had occurred at the average rate of 4 square miles per year between 1850 and 1960, resulting in a loss of over 235 square miles of Bay area since the California Gold Rush. The enabling legislation charged BCDC with the responsibility of preparing a plan for the long-term protection and use of the Bay. The result was the San Francisco Bay Plan (Bay Plan), completed in 1969 and periodically amended over the past four decades.

The Bay Plan also references a number of special area plans formally adopted by BCDC that provide more detailed guidance for fill and development in the areas governed by the plans. Among others, these special area plans included the South Richmond Shoreline Special Area Plan, which encompasses the Terminal 3 site and is discussed separately below.

The Bay Plan is the mechanism by which BCDC controls both Bay filling and dredging and shoreline development along the Bay. The Commission has jurisdiction over these activities within the Bay and within a shoreline band extending 100 feet landward from the mean high tide line of the Bay. The Commission’s jurisdiction also includes marshlands lying between

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mean high tide and 5 feet above mean sea level, diked salt ponds, managed wetlands, and the portions of certain creeks or rivers that discharge to the Bay that are subject to tidal action.

Bay Plan Map 4, which encompasses the north central portion of San Francisco Bay, including the south Richmond shoreline, designates Terminal 3 for Port Priority Use. The proposed log storage and shipping facility is consistent with this designation and with Bay Plan policies prioritizing water-related industry and port uses at sites designated for such use.

As part of this environmental review, the Bay Plan was reviewed to identify policies and other plan provisions that may apply to the proposed project and evaluate potential conflicts. Although no policy conflicts were identified, based on Safety of Fills Policy 1, the BCDC may want to review and comment on the project proposal. Policy 1 states, in part, “The Commission has appointed the Engineering Criteria Review Board . . . empowered to . . . review all except minor projects for the adequacy of their specific safety provisions, and make recommendations concerning these provisions . . .” The Plan does not define what constitutes a “minor project,” but given the proposed project’s lack of new construction, it may qualify for this exception.

While Bay Plan policies, as well as the McAteer-Petris Act, require any project built on the shoreline or on Bay fill to provide public access “to the maximum extent feasible,” the proposed project would be implemented on an existing port property that has been used for port uses for decades. No new construction or expansion of the existing facilities is proposed and the nature of port operations in general and the proposed project operations in particular are not conducive to public access to the shoreline. It is therefore assumed that it would be neither feasible nor appropriate to provide public access to the shoreline at Terminal 3, and no Bay Plan policy conflict is identified. However, there is existing public access to the shoreline about 300 feet south of the project site, at Sheridan Observation Point, located at the southern end of the Ford Peninsula. This small parklet provides a lawn and fishing pier.

In addition to restricting Bay filling, the policies promulgated in the Bay Plan are particularly focused on protecting aquatic habitats and water quality in and around the Bay, among other policy directives. Although project operations, including the operation of ships used for conveying prepared logs to end markets in China, have the potential to adversely affect water quality in the Bay and the offshore coastal waters, implementation of Mitigation Measures WQ– 1 and WQ–3 (see Section IX, Hydrology and Water Quality) would ensure that project-related impacts to water quality in the Bay and ocean would be less than significant and no policy conflicts would occur.

The BCDC requires a permit for dredging or filling of the Bay, the latter of which can include placement of piers or pilings or the extended mooring of floating structures. A permit is also required for any new development within the 100-foot shoreline band under the Commission’s jurisdiction. Permitting requirements for new development are essentially the same as the permit system for dredging or filling of the Bay. Because the proposed project would not require modifications to the pier at Terminal 3, and it does not propose any new construction or improvements other than outdoor lighting and electrical upgrades, the project is not expected to require permitting by BCDC. However, to confirm that no permit is required, once project plans are finalized for the bracing of log stacks, City Planning staff should consult with BCDC. If it turns out that a permit from the Commission is required, the project applicant will be required to obtain the permit prior to initiating log preparation and export operations.

South Richmond Shoreline Special Area Plan Terminal 3 is located within the area governed by the South Richmond Shoreline Special Area Plan (SRSSAP), a joint planning document adopted in 1977 by both BCDC and the City of

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Richmond.65 The aim of the plan was to achieve consistency between BCDC’s San Francisco Bay Plan and the Richmond General Plan and, accordingly, amended both of those plans by resolution of BCDC and the Richmond City Council, respectively. Previous incompatibility between the two planning documents pertained to future plans for Richmond’s Inner Harbor Basin, which designated the basin area for future port use, while the City desired to develop the water– oriented complex that exists today and includes a major marina, park and public access uses, commercial areas, and residential development at varying densities. The adoption of the SRSSAP permitted this development to move forward with BCDC approval, including the removal of the Inner Harbor Basin as a Port Priority Use Area.

The SRSSAP divides the South Richmond shoreline into four subareas: Brooks Island, Point Isabel, Inner Harbor, and Santa Fe, with Terminal 3 being located within the latter subarea. Policies promulgated in the SRSSAP are specific to one of these subareas. The SRSSAP reasserts the applicability of policies established in the San Francisco Bay Plan, Richmond General Plan, and the Urban Renewal Plan for Redevelopment Project Area 11–A (Redevelopment Plan 11–A). However, with the dissolution of all California redevelopment agencies by the State in 2012, Redevelopment Plan 11–A is no longer in effect.

The major policy direction for the Santa Fe Sub-Area as established in the SRSSAP is: (1) to retain the Harbor and Santa Fe Channels as a port priority area, and (2) to encourage public access where feasible. Although Bay fill is permitted for expansion of port facilities in the shoreline port priority areas, the proposed project would not require any placement of fill. Similar to the discussion of the Bay Plan, above, it would not be appropriate to provide public shoreline access at Terminal 3, so the project would not conflict with Public Recreation, Other Open Space and Public Access Policy 1 for the Santa Fe Sub-Area, which reads: Require waterfront developments, as part of any project approval process, to provide the maximum feasible public access to the shoreline consistent with the project, with adequate links to inland areas. (Continuing Policy)

The proposed project would not conflict with the SRSSAP or any of the policies promulgated therein.

Bicycle Master Plan The City of Richmond Bicycle Master Plan (BMP) was adopted by the City in 2011, with the basic purpose of setting in motion the policies and action items identified in the current General Plan.66 The BMP provides a blueprint for completing a 145-mile system of bikeways and support facilities within the City of Richmond. For purposes of planning the bicycle network, the City is divided into four geographic sub-areas. The project site is located within the Central Richmond sub-area. Harbour Way South is identified as one of the City’s key bicycle corridors, where a variety of bicycle-friendly roadway treatments are recommended.

The BMP identifies an existing northbound Class II bike lane on Harbour Way South between Hall Avenue and Wright Avenue, and an existing southbound Class III bike route on the same roadway segment. A Class I bike path extends on Harbour Way South from Wright Avenue to its southern terminus, continuing along the southern and eastern shores of the Ford Peninsula. These routes are identified as ongoing bikeway projects (since 2009), as are these additional

65 South Richmond Shoreline Special Area Plan Citizens’ Advisory Committee, South Richmond Shoreline Special Area Plan, An Amendment to the City of Richmond General Plan and the San Francisco Bay Conservation and Development Commission Bay Plan, adopted by the Richmond City Council on April 25, 1977 and by the San Francisco Bay Conservation and Development Commission (BCDC) on May 5, 1977, amended by BCDC on August 20, 1987. 66 City of Richmond, City of Richmond Bicycle Master Plan, October 2011.

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projects in the vicinity of the Terminal 3 site: Ferry Point Loop Trail Guide, Ford Point Bay Trail Loop, and Hall Avenue Bike Lane Racks.

While the BMP identifies several alternative configurations for improved bicycle facilities along Harbour Way South between Wright Avenue and Pennsylvania Avenue (north of the project site), these plans have subsequently been superseded by the more recent South Richmond Transportation Connectivity Plan, which is discussed below. The proposed project would not conflict with any of the goals and policies set forth in the BMP.

South Richmond Transportation Connectivity Plan The South Richmond Transportation Connectivity Plan (SRTCP) was developed to address deficiencies in the existing transportation systems in South Richmond, shortcomings that are expected to become more critical when the planned ferry terminal on the Ford Peninsula becomes operational in 2018 and when the planned Berkeley Global Campus at Richmond Bay is developed.67 The SRTCP planning area extends from Richmond’s Inner Harbor on San Francisco Bay north to Maine Street, and from Harbor Channel and South 6th Street on the west to San Pablo Avenue on the east. The planned ferry terminal is identified in the SRTCP as one of the key opportunities for increasing transportation connectivity within South Richmond and improving regional access.

In the project area, the SRTCP identifies Harbour Way South as a key multi-modal transportation corridor, with the planned ferry terminal at the southern end of Harbour Way South providing regional transit access. Challenges for this corridor and a parallel corridor on Marina Way include balancing the movement of goods with auto access to the ferry terminal while maintaining bicycle and pedestrian access and safety and addressing conflicts at rail crossings and I-580 ramps.

Harbour Way South, Hall Avenue, and Wright Avenue are all identified as proposed truck routes in the SRTCP. Hall Avenue and Harbour Way South south of Hall Avenue are identified as primary transit corridors. The Plan identifies the Ford Peninsula east of Harbour Way South as a Pedestrian Improvement District and Harbour Way South as a Key Pedestrian Route. A variety of both pedestrian enhancements and improved bicycle facilities are recommended for the planning area. The SRTCP provides updated recommendations for the types of bicycle facilities previously identified for Harbour Way South in the Bicycle Master Plan discussed above, consistent with changes in best practices in bicycle and pedestrian facility design and implementation since 2011.

Within the project vicinity, the SRTCP calls for the following improvements to Harbour Way South:

Near-Term (2015-2024) ! Maintain as a Primary Truck Route ! Ford Point to Hoffman Boulevard: Add two-way separated bikeway on east side Formalize parking on west side, with parking restrictions near driveways and intersections to improve sight lines, and enhance safety of truck turning movements. ! Hoffman/Harbour: Stripe triple-four trail crossings on east and north side of intersection

67 City of Richmond, South Richmond Transportation Connectivity Plan (SRTCP), July 2015.

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Stripe large corner bulb/queue on both SE and SW corners of the intersection to allow cyclists to make two-stage left turn crossings. Stripe curb extension on SE corner, to slow and improve safety of auto turning movements.

Long-Term (2030+) ! Maintain as a Primary Truck Route ! Ford Point to Hoffman Boulevard: Raised two-way cycletrack on the east side of the roadway ! Hoffman Boulevard to Cutting Boulevard: Raised one-way cycletracks through I-580 Square up On- and Off Ramps per Pedestrian Plan with hardscape curb extensions Stripe large sidewalk extension with soft-hit posts in the northbound direction, north of off-ramp ! Hoffman Boulevard/Harbour Way Intersection Modify signal to allow bike phase concurrent with NB protected left-turn Formalize curb extensions with curb and gutter

The SRTCP identifies signalization of the Harbour Way/Wright Avenue intersection as a planned improvement, noting that there is a need for improvements such as coordinated traffic signals, warning lights, and rail crossing gates at this intersection, where the BNSF rail line crosses at grade through the currently unsignalized intersection. As discussed in Section XVI, Transportation/Traffic, the City will require the proposed project to make a fair-share contribution to the signalization of this intersection as a condition of project approval.

The Urban Design Framework presented in the SRTCP designates Harbour Way South as a Shoreline Connector passing through an industrial neighborhood. For Shoreline Connectors, the following streetscape elements are recommended to help achieve this goal: convey a positive first impression and establish a distinctive sense of place.

! A consistent, evenly spaced street tree palette that includes tall, narrow-canopy sidewalk and median trees interspersed with palm trees; ! A planting palette that features coastal-tolerant species commonly found along the Richmond waterfront and around San Pablo Bay; ! Prominently featured lighting fixtures with a design that draws strongly from industrial and maritime influences and reinforces the formal sense of entry; ! Prominent, consistently-designed wayfinding signage that directs visitors to key South Shoreline destinations; and ! Overpass and underpass crossing enhancements that create a more welcoming entry experience to the South Shoreline area and reflect the local community and heritage.

The Plan provides a recommended street tree palette for inclusion in the streetscape elements. For Shoreline Connectors, the recommended species include Raywood ash (Fraxinus augustifolio ‘Raywood’), water gum tree (Trisaniopsis laurina), sour gum tree (Nyssa sylvatica), and Brisbane box tree (Lophostemon), with Robinson flowering crabapple (Malus ‘Robinson’) and Natchez crape myrtle (Lagerstromia ‘Natchez’) as small accent trees. For medians and parkways within Shoreline Connectors, the recommended species include water gum tree and Monterey cypress (Cupressus macrocarpa). Canary date palm (Phoenix canariensis) and Guadalupe palm (Brahae edulis) are recommended accent palms.

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Detailed corridor profiles are presented in the SRTCP for all of the key transportation routes within the planning area. For the segment of Harbour Way South from its southern terminus to Hoffman Boulevard, the Plan depicts a recommended 75-foot-wide right-of-way with 10-foot sidewalks on both sides, a single 11-foot travel lane in each direction separated by an 11-foot turning lane, and an 8-foot parking lane on the southbound side. On the northbound side, a 2- foot buffer with a physical barrier separates vehicle traffic from a two-way raised cycletrack, with 6-foot bicycle lanes in both the northbound and southbound directions.

The proposed project would not conflict with or impair implementation of the planned improvements on the Ford Peninsula identified in the SRTCP. As discussed above for the Knox Freeway/Cutting Boulevard Corridor Specific Plan, the City will require the project applicant to install additional landscape screening along Harbour Way South as a condition of approval of the Conditional Use Permit for the project. The improvements will be required to conform to the Urban Design Framework presented in the SRTCP. As previously noted, the applicant will also be required to make a fair-share contribution to the future signalization of the Harbour Way/Wright Avenue intersection.

BCDC Seaport Plan The San Francisco Bay Area Seaport Plan was developed cooperatively between BCDC and the Metropolitan Transportation Commission (MTC) and serves as the primary port policy document for BCDC and as the maritime element of MTC’s Regional Transportation Plan.68

The Seaport Plan calls for BCDC’s Seaport Planning Advisory Committee to monitor the region’s maritime cargo volumes, marine terminal use, and ship calls on an ongoing basis. The monitoring is intended to determine whether there has been a shift in the method of transporting bulk cargoes and ensure that the Seaport Plan’s marine terminal designations continue to adequately accommodate needed port and marine terminal development. Seaport Plan states that no changes in use or deletions of port priority use areas should be considered until the cargo monitoring process has been implemented.

The Seaport Plan is intended to promote the following goals: 1. Ensure the continuation of the San Francisco Bay port system as a major world port and contributor to the economic vitality of the San Francisco Bay region; 2. Maintain or improve the environmental quality of San Francisco Bay and its environs; 3. Provide for the efficient use of finite physical and fiscal resources consumed in developing and operating marine terminals through the year 2020; 4. Provide for integrated and improved surface transportation facilities between San Francisco Bay ports and terminals and other regional transportation systems; and 5. Reserve sufficient shoreline areas to accommodate future growth in maritime cargo, thereby minimizing the need for new Bay fill for port development.

To achieve these goals, the Seaport Plan assigns land use designations to appropriate shoreline areas under BCDC jurisdiction and promulgates enforceable policies. Consistent with the San Francisco Bay Plan, Figure 6 of the Seaport Plan designates Terminal 3 and other Port properties surround the Santa Fe and Harbor channels as a Port Priority Use Area. Port Priority Use Area policies call for the protection and preservation of these areas for marine terminals and other directly related port activities. Public access and commercial recreation development may be

68 San Francisco Bay Conservation and Development Commission and Metropolitan Transportation Commission, San Francisco Bay Area Seaport Plan, April 18, 1996, as amended through January 2012.

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allowed provided that the use would not impair existing or future use of the area for port purposes.

Of Seaport Plan policies pertaining specifically to the Port of Richmond, only one has any bearing on the proposed project. Port of Richmond Policy 1 states that the Port of Richmond should have the annual cargo throughput listed in an accompanying table (Table 15). For the combined Terminal 2 and Terminal 3, with two ship berths, the expected 2020 throughput capability is 209,000 metric tons of container capacity and 286,000 metric tons of neo-bulk capacity. The proposed project would contribute to the Port’s ability to achieve the target neo- bulk capacity. Therefore, the project would be consistent with the Seaport Plan.

A comment submitted to the City by BCDC (see Appendix A) on the prior April 2016 Initial Study for the proposed project stated that Terminals 2 and 3 were designated in the Seaport Plan as providing 418,000 metric tons of container throughput and 572,000 metric tons of neo- bulk throughput to meet the 2020 regional cargo forecast. The numbers reported in the Initial Study and those referenced in the comment both come from Table 15 of the Seaport Plan. The volumes of 209,000 metric tons of container cargo and 286,000 metric tons of neo-bulk cargo reported above and in the prior Initial Study represent the expected throughput capability whereas the 418,000 tons and 572,000 tons, respectively, identified in the comment represent total throughput, which is identified in the Plan as the optimal annual throughput capability. The Seaport Plan does not explain the distinction between these two categories. Nonetheless, as noted above and acknowledged in the BCDC comment, the proposed project would contribute to the regional cargo volume and assist BCDC and the Metropolitan Transportation Commission in meeting the cargo objectives for the Port of Richmond set forth in Table 15 of the Seaport Plan.

San Francisco Bay Trail Plan The Bay Trail Plan was prepared in 1989 in response to California Assembly Bill 100 (1987), which mandated the creation of regional hiking and bicycling trail around San Francisco Bay.69 The Plan proposes the alignment for an approximately 500-mile network of recreational trails encircling San Francisco and San Pablo Bays. The trail is planned to pass through all nine Bay Area counties and 47 cities, and cross seven toll bridges. To date, 343 miles of the trail have been completed, including over 32 miles within the City of Richmond. When completed, the Bay Trail system will provide connections between more than 90 parks and public open space areas, as well as to a burgeoning network of “water trails” on the Bay itself.

Maps developed by the San Francisco Bay Trail Project to implement the Bay Trail Plan designate an existing on-street segment of the Bay Trail that extends along Harbour Way South from Hoffman Boulevard (just south of I-580) south to the southern end of the Ford Peninsula, where it becomes a paved trail that extends along the southern and eastern edges of the peninsula, then connects with other trail segments, including another on-street segment on Hall Avenue.70

The Bay Trail Plan contains policies to guide implementation of the planned trail system that fall into one of the following five categories: trail alignment, trail design, environmental protection, transportation access, and implementation. Because the Terminal 3 site is located adjacent to two existing segments of the Bay Trail and no other segments are planned for the project vicinity, there is no potential for the project to conflict with the trail alignment or trail design policies. The environmental protection, transportation access, and implementation policies were

69 Association of Bay Area Governments (ABAG) and the San Francisco Bay Trail Project, The Bay Trail: Planning for a Recreational Ring Around San Francisco Bay, July 1989. 70 http://baytrail.org/get-on-the-trail/map-by-number/albany-to-richmond/

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reviewed to identify any that would be relevant to the proposed project. None of the policies would apply to the project and the project would not conflict with any of the provisions of the Bay Trail Plan.

Land Use Compatibility One of the comment letters submitted to the City on the previous April 2016 Initial Study asserted that the proposed project does not constitute a maritime use, does not require waterfront property, and should not be implemented at the Terminal 3 site. The letter also asserted that the project is incompatible with the future ferry terminal planned for the wharf at the southern end of the Ford Assembly Building. However, the primary objective of the proposed project is to export harvested logs to China, for which a deep-water ship berth is essential. As discussed above, the project is entirely consistent with the uses intended for and expressly permitted in the Port General Plan land use designation and the M-4 Marine Industrial zoning district in which the site is located. As discussed in considerable detail above, the project is consistent with the General Plan, San Francisco Bay Plan, San Francisco Bay Area Seaport Plan, South Richmond Shoreline Special Area Plan, Knox Freeway/Cutting Boulevard Corridor Specific Plan, City of Richmond Bicycle Master Plan, and the South Richmond Transportation Connectivity Plan. As discussed below, it is also in conformance with the Richmond Zoning Ordinance. The project site has been intended for marine industrial land uses for numerous decades, as demonstrated by these planning documents, one of which dates to 1977 and identified the project site as a Port Priority Area, which it remains today. The dirt and noise from the project are being controlled through changes to operations and by mitigation requirements that have yet to be implemented. See Section III, Air Quality, and Section XII, Noise, for additional information. As discussed in those sections, with these changes and mitigation requirements, the project is expected to have less-than-significant impacts related to dust, debris, and noise that could adversely affect neighboring land uses, including the planned ferry terminal. There is no evidence to suggest that the proposed log storage and shipping facility would interfere with the operation of the ferry terminal.

Zoning Ordinance The project site is zoned IW, Water-Related Industrial. The IW zoning district is intended for waterfront-related industrial development that includes manufacturing, warehousing and distribution, marine services, supporting office uses and other large-scale uses that support the Port of Richmond. Permitted uses include incubator-research facilities for marine-related activities, prototype manufacturing, testing, repairing, packaging, and storage as well as offices and support facilities.

The IW zone encompasses land area around the Santa Fe and Harbour Channels. The M-4 regulations are intended to strengthen the unique physical and environmental quality of these areas, which are extensions of adjacent San Francisco Bay. They are also intended to ensure the aesthetic quality of development and ensure compatibility of development with nearby residential areas. Adjacent zoning districts should provide buffering between residential districts and the IW district. There are no overlay districts assigned to the project site that would impose additional regulations.

The zoning ordinance provides a lengthy list of industrial, manufacturing, transportation, communications, public utilities, wholesale durable goods, civic, public, and semi-public uses that are permitted in the IW zoning district, along with an equally lengthy list of uses that may be permitted by a Conditional Use Permit. The lists of permitted and conditionally permitted uses in the IW district do not include log processing facilities, log export facilities, lumber storage terminals, or similar uses, nor are such uses defined as allowed uses in the Knox Cutting Specific Plan (KCSP). However, pursuant to Section 15.04.204.020 of the Richmond Municipal

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Code, in cases where a specific land use or activity is not defined, the Zoning Administrator shall assign the land use or activity to a classification that is substantially similar in character. Because the proposed project is similar to a Freight/Truck Terminal and Warehouse use, the City has determined that the proposed use is subject to a Conditional Use Permit to ensure compatibility with surrounding uses.

The IW district has a height limit of 100 feet. Marine terminal equipment such as cranes are exempt from the height limits. The maximum allowable floor area ratio (FAR) is 0.5. No side yard setback is required unless abutting an RL, PCI, or PR district, in which case a side setback of 10 feet is required, reduced to 5 feet where there is a solid fence; when abutting a minor street, a side setback of 10 feet is required, and a setback of 25 feet is required when abutting a collector street. There is no rear setback required except for parcels abutting an RL, PCI, or PR zone, in which case a 15-foot setback is required. Minimum setbacks from minor streets and collector streets are 10 feet and 25 feet, respectively. Although these development standards would not apply to the proposed project, which would not include any new development, the existing development on the Terminal 3 site appears to conform to all of these standards.

Outdoor storage of raw or finished goods is permitted in the IW district if screened from view from any abutting residential or mixed-use district. The site abuts the MC-5 district and appropriate screening measures will be taken to screen from view as required by the Zoning. A variety of other development regulations apply to the M-4 zone, such as landscaping, street trees and other trees, fencing, front yards, open space, etc. Since the proposed project does not entail any new development or site modifications, these regulations would not apply to the project. Regulations on the use or storage of hazardous materials would not apply to the project because it would not entail use or storage of hazardous materials. However, some performance standards established in Chapter 15.04.840 of the Zoning Ordinance, specifically those pertaining to noise (Section 15.04.840.020), would apply to the project. Those standards are addressed in Section XII of this Initial Study.

Based on the review of the General Plan, Zoning Ordinance, and other local and regional planning documents summarized above, the proposed project would not conflict with any applicable land use plan, policy, or regulation of an agency with jurisdiction over the project adopted for the purposed of avoiding or mitigating an environmental effect.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Conflict with any applicable habitat conservation plan or natural community conservation plan? ⌧

Explanation: There is no adopted habitat conservation plan (HCP) applicable to the City of Richmond.

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XI. MINERAL RESOURCES — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Result in the loss of availability of a known mineral resource that would be of value to the region and the ⌧ residents of the state?

Explanation: No regionally significant mineral deposits have been mapped on or in the vicinity of the project site. The site is within a large area classified as Mineral Resource Zone MRZ-1 by the California Department of Conservation’s Division of Mines and Geology (DMG).71 The MRZ-1 designation is assigned to areas where sufficient data exists for a determination that no significant mineral deposits exist, or where it is judged that there is little likelihood for their presence. Furthermore, the site is in a fully developed, urbanized area where mineral extraction would not be practical. Therefore, the project would not have an effect on the availability of mineral resources.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Result in the loss of availability of a locally- important mineral resource recovery site delineated on a local general plan, specific plan, or other land ⌧ use plan?

Explanation: The Richmond General Plan does not identify any local mineral resources in the project vicinity, and the Richmond General Plan EIR reports that the City’s significant sectors of sandstone and shale aggregates are located in the San Pablo-Potrero Hills Ridge Area, well away from the project site. The map of geology and mineral resource sectors presented in the General Plan EIR indicates that the project site is underlain by Bay Mud. In any event, the project site has been developed with marine-related uses for many decades. There is no potential for the project to have an adverse effect on the availability of significant mineral resources.

71 California Department of Conservation, Division of Mines and Geology, Generalized Mineral Land Classification Map of the South San Francisco Bay Production-Consumption Region (Plate 1 of 29), 1996.

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XII. NOISE — Would the project result in:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Exposure of persons to or generation of noise levels in excess of standards established in the local general plan or noise ordinance, or applicable standards of ⌧ other agencies?

Explanation:

Introduction to Noise Descriptors Noise is defined as unwanted sound. Airborne sound is a rapid fluctuation of air pressure above and below atmospheric pressure. Sound levels are usually measured and expressed in decibels (dB) with 0 dB corresponding roughly to the threshold of hearing.

Most of the sounds that we hear in the environment do not consist of a single frequency, but rather a broad band of frequencies, with each frequency differing in sound level. The intensities of each frequency add together to generate a sound. The method commonly used to quantify environmental sounds consists of evaluating all of the frequencies of a sound in accordance with a weighting that reflects the facts that human hearing is less sensitive at low frequencies and extreme high frequencies than in the mid-range frequency. This is called "A" weighting, and the decibel level so measured is called the A-weighted sound level (dBA). In practice, the level of a sound source is conveniently measured using a sound level meter that includes an electrical filter corresponding to the A-weighting curve. Typical A-weighted levels measured in the environment and in industry are shown in Table N–1 for different types of noise.

Although the A-weighted noise level may adequately indicate the level of environmental noise at any instant in time, community noise levels vary continuously. Most environmental noise includes a conglomeration of noise from distant sources that create a relatively steady background noise in which no particular source is identifiable. To describe the time-varying character of environmental noise, the statistical noise descriptors, L01, L10, L50, and L90, are commonly used. They are the A-weighted noise levels equaled or exceeded during 1 percent, 10 percent, 50 percent, and 90 percent of a stated time period. A single number descriptor called the Leq is also widely used. The Leq is the average A-weighted noise level during a stated period of time.

In determining the daily level of environmental noise, it is important to account for the difference in response of people to daytime and nighttime noises. During the nighttime, exterior background noises are generally lower than the daytime levels. However, most household noise also decreases at night and exterior noise becomes very noticeable. Further, most people sleep at night and are very sensitive to noise intrusion. To account for human sensitivity to nighttime noise levels, a descriptor, DNL (day/night average sound level), was developed. The DNL divides the 24-hour day into the daytime of 7:00 AM to 10:00 PM and the nighttime of 10:00 PM to 7:00 AM. The nighttime noise level is weighted 10 dB higher than the daytime noise level.

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The Community Noise Equivalent Level (CNEL) is another 24-hour average which includes both an evening and nighttime weighting, adding 5 decibels to the average noise levels during the evening and 10 decibels to the average noise levels during the nighttime period. CNEL and DNL descriptors are similar and are often used interchangeably. Noise standards established in the Richmond General Plan are expressed using the CNEL descriptor. For obvious reasons, the DNL and CNEL descriptors are only relevant in cases where residential or other noise-sensitive land uses are nearby.

Table N–1 Typical Noise Levels

Noise Level (dBA) Outdoor Activity Indoor Activity

90+ Gas lawn mower at 3 feet, Rock Band jet flyover at 1,000 feet 80-90 Diesel truck at 50 feet Loud television at 3 feet Garbage disposal at 3 feet, 70-80 Gas lawn mower at 100 feet, noisy urban area vacuum cleaner at 10 feet 60-70 Commercial area Normal speech at 3 feet

40-60 Quiet urban daytime traffic Large business office, at 300 feet dishwasher next room Concert hall (background), library, 20-40 Quiet rural, suburban nighttime bedroom at night 10-20 Broadcast/recording studio 0 Lowest threshold of human hearing Lowest threshold of human hearing

Source: (modified from Caltrans Technical Noise Supplement, 2011)

Noise levels that are generally considered acceptable or unacceptable can characterize various environments. Lower levels are expected in rural or suburban areas than would be expected in commercial or industrial zones. Nighttime ambient levels in urban environments are about 7 decibels lower than the corresponding average daytime levels. The day-to-night noise level difference in rural areas away from roads and other human activity can be considerably less. Noise levels above 45 dBA at night can result in the onset of sleep interference.72 At 70 dBA, sleep interference becomes considerable.

State and Federal Regulation of Industrial Noise Exposure The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) regulates exposure of general industry employees, such as those working in the manufacturing, utilities, and service sectors. Exposure standards are promulgated in Code of Federal Regulations (CFR) Title 29, Section 1910.95. OSHA sets legal limits on noise exposure in the workplace, based on a worker's time-weighted average exposure over an 8-hour day. OSHA's

72 U.S. Environmental Protection Agency, Community Noise, 1971.

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permissible exposure limit (PEL) for noise is 90 dBA for all workers.73 The OSHA standard uses a 5-dBA exchange rate, which means that when the noise level is increased by 5 dBA, the amount of time a person can be exposed to the higher noise level is cut in half. Thus, workers can be exposed to a time-weighted average noise level of 95 dBA for a maximum of 4 hours; exposure to 100 dBA would be limited to 2 hours per day.

OSHA implemented additional noise protections for industrial workers in 1981. In facilities where workers are exposed to a time-weighted average noise level of 85 dBA or higher over an 8-hour work shift, the employer is required to implement a Hearing Conservation Program. The Hearing Conservation Program requires the employer to measure noise levels, provide free annual hearing exams and free hearing protection, provide training, and conduct evaluations of the adequacy of the hearing protectors in use. Alternatively, the employer can implement changes to tools, equipment, and schedules to reduce worker noise exposure of less than 85 dBA.

Worker noise exposure is also regulated by the State of California’s Department of Industrial Relations. Noise exposure limits are promulgated in Title 8, Subchapter 7, Group 15, Article 105 of the California Code of Regulations (CCR). The State regulations effectively mirror the federal regulations. Both sets of regulations require an employer to administer a continuing hearing conservation program whenever employee noise exposures equal or exceed an 8-hour time- weighted average sound level of 85 dBA. The program must include noise exposure monitoring, audiometric testing of employees, provision of personal hearing protection, and other provisions.

City of Richmond Noise Standards Section 15.04.840.010 of the Richmond Municipal Code (and Chapter 9.52, the Community Noise Ordinance) establishes exterior noise limits that are not to be exceeded more than 30 minutes in any hour, as measured at the property line. In the case of M-3 and M-4 zoning districts (the project is in an M-4 district), the noise limits apply at the district boundary rather than the property line. For these heavy and marine industrial districts, the standards establish a maximum noise level of 75 dBA; at any boundary of a residential zone, the limit is 65 dBA.

The Public Safety and Noise Element of the Richmond General Plan incorporates the community noise exposure guidelines recommended by the Governor’s Office of Planning and Research. For industrial land uses, CNEL noise levels up to 80 dB are considered Normally Acceptable, while noise exposure up to 85 dB is Conditionally Acceptable, subject to an assessment of appropriate noise-insulation features.

Existing Conditions Existing ambient noise levels in the project vicinity are generally fairly low, with intermittent noise generated from Port operations, including operations of ships and cranes. Traffic volumes on Harbour Way South are low and traffic is not a significant source of noise in the area. Although noise measurements were not taken during the initial environmental review of the proposed log storage and shipping facility,74 24-hour measurements were previously taken by Miller Environmental Consultants that are considered representative of the ambient noise levels in the vicinity of the project. The measurements, which were taken 50 feet from the centerline of Harbour Way South adjacent to the project site, determined that the 24-hour CNEL was 67 dBA

73 29 CFR 1910.95. 74 As discussed further below, in response to concerns expressed by neighboring businesses, targeted noise measurements were subsequently taken, with the results summarized herein.

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75 and hourly Leq values were between 46 and 66 dBA. These noise levels are well within the noise limits for the M-4 zoning district.

The only noise-sensitive receptor in the project vicinity is Sheridan Observation Point, located at the southern end of the Ford Peninsula, about 300 feet south of the project site, which has a lawn and fishing pier. Although there is an elementary school on the east side of the Ford Peninsula—Benito Juarez Elementary School, at 1450 Marina Way South—it is located approximately 1,350 feet from the front property line of the project site and more than 1,500 feet from the nearest anticipated log handling operations. Furthermore, the two-story historic Ford Assembly Building, which is approximately 1,050 feet long, lies between the school and the southern project entrance. (This southern portion of the project site, south of the terminal building, provides the greatest opportunity for sound generated by project operations to migrate off-site. North of this relatively open area, the terminal building provides a very effective noise shield.) Due to the considerable distance and the intervening Ford Assembly Building, there is no potential for project noise to adversely affect students at Benito Juarez Elementary School.

In addition to these two sensitive receptors, there could be future residents in the Ford Assembly Building, which is located about 250 feet east of the Terminal 3 truck scales, about 380 feet east of the proposed equipment storage area, and about 400 feet from the nearest log storage deck. Although there are currently no residents occupying the building, live/work is an approved use in the building, and it is likely that residential receptors will be present in the building in the future.

Project-Generated Noise Operation of the proposed project would generate noise from multiple sources, including the following: • arrival and departure of log-hauling trucks; • operation of a front loader to unload trucks and move logs from the log layout deck to the debarking shed; • operation of the debarker; • operation of an excavator to moved debarked logs to the Debarked Log Deck; • periodic emptying of the bark debris container; • daily operation of the street sweeper to clean the site; and • loading of ships.

The loudest noise would be generated by operation of the debarker. Noise comes from the handling chain, the debarking rotor, and the associated drive and transmission systems. There are two types of potential impacts from noise generated by the debarker: (1) noise impacts on the operator and other workers, with the potential to cause hearing loss and other adverse health effects; and (2) excessive noise exposure to offsite receptors, particularly sensitive receptors, such as schools and residential receptors. Each of these potential impacts is discussed below.

75 City of Richmond, Ford Assembly Building Reuse Project Mitigated Negative Declaration, Table N-2: Summary of Existing Noise Measurements, June 2004.

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Operator Exposure to Debarker Noise In a noise study of debarking machines at nine different sawmills, operators were equipped with personal noise dosimeters in order to measure actual noise exposure levels over the course of 8-hour work days.76 The microphones for the noise dosimeters were placed approximately 10 centimeters from the operators’ ears. Noise data was collected during two separate work days, one in summer and one in winter. Data was collected from a total of 213 sawmill workers in 13 different job categories, including debarker operator.

Debarker operators had the lowest noise exposure of the 13 job categories. During the summer monitoring, their average noise exposure was 73.6 dB Leq. The collected data reflected both time spent inside the operator cab, where noise exposure was substantially lower, and outside the cab, where noise exposure was more direct. The study noted that the results were skewed upward by variables such as operation of a chainsaw nearby, operation of loud radios inside the operator cabs, leaving the cab door open, and performance of other, noisier jobs during the 8- hour work shift.

The debarker that would be used for the proposed project at Terminal 3 would be equipped with an operator cab that a facility employee would occupy during debarking operations. Based on the noise study cited above, the noise exposure levels for project employees would be expected to be well below the 90-dBA 8-hour PEL and the 85-dBA 8-hour threshold for conducting noise monitoring or implementing a Hearing Conservation Program. This was confirmed by noise measurements taken from inside the operator cab of an operational debarker at an existing log processing facility in West Sacramento by an acoustical consultant.77

The ring debarking machine that was monitored at the West Sacramento facility is the same make and design as the machine that would be used for the proposed Terminal 3 project, but it is larger than the proposed machine. Thus, the noise generated by this machine is louder than the machine that would be used at Terminal 3. Noise levels were not measured immediately outside the operator’s cab, but they were quite loud, and were estimated to be 95 dBA Leq at a distance of approximately 15 feet from the debarking ring. The estimated Leq of 95 dBA at a distance of 15 feet is consistent with another study of a ring debarker in Fair Haven, Vermont, 78 which had an estimated Leq of 107 dBA at 1 meter (3.28 feet).

The operator’s cab had thick tempered glass and insulated steel walls. Although the front window of the cab was approximately 6 feet from the debarking rings, the inside of the cab was reasonably quiet. Noises discernible inside the cab included pneumatic controls on the conveyor outside the cab, rumble from structure vibration, and other general debarker noise. The sound level caused no interference with normal conversation. Because the sound is fairly continuous with minor fluctuations (increases) when the log feeder is moving another log into the debarking rings, the noise level was monitored for only 5 minutes. The results revealed an Leq of 68 dBA, which is comparable to an outdoor noise level in a commercial area and an indoor noise level from normal speech at a distance of 3 feet. Based on the research discussed above and the evidence of these measured noise levels, project workers would not be exposed to hazardous noise levels. Therefore, the proposed project would have a less-than-significant impact from exposure of project employees to operational noise at the proposed log preparation and storage facility.

76 Niels Kevin Koehncke, University of Alberta, An Investigation of Noise Levels in Alberta Sawmills, Fall 1999. 77 Environmental Service, Noise Measurement & Impact Assessment for the Proposed Port of Richmond Terminal 3 Log Processing and Export Facility, ES Project No. 2016-026, July 21, 2016. 78 Resource Systems Group, Inc., Noise Impact Study for Beaver Wood Energy’s Biomass Plant and Wood Pellet Facility in Fair Haven Vermont, November 2010.

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Off-Site Noise Exposure With respect to offsite noise, the debarker would be located inside the existing warehouse building at Terminal 3; its operation would not be audible at the site property line, except near the northern entrance to Terminal 3. While the operation of trucks, the front loader, and the excavator would generate noise that would be audible at the property line, it would generally not be expected to exceed the 30-minute 75-dBA threshold for industrial properties. Shipboard cranes used to load logs onto ships would likely operate on shoreline electric power and would not be audible at the property line. However, in the event they were operated on diesel power, they would generate approximately the same noise level as the excavator, discussed below, but would be located further from the property line on Harbour Way South, and thus would generate lower off-site noise levels than the excavator.

The most significant source of operational noise migrating off-site would be from operation of the excavator and front loader in the vicinity of the outdoor log storage decks. Much of this noise would be effectively blocked from reaching offsite receptors to the east by the intervening Terminal 3 warehouse building, which is approximately 800 feet long and 20 feet tall.

Based on noise data from the Federal Highway Administration’s Roadway Construction Noise Model (RCNM), a typical front loader generates a maximum sound level (Lmax) of 79 dBA at 50 79 feet, while an excavator has an Lmax of 81 dBA at 50 feet. The Lmax is the highest instantaneous peak noise measurement during any measurement period, and is higher than the average DNL or CNEL noise levels. With attenuation for distance, the noisier excavator could generate an Lmax of 63 dBA at the façade of the Ford Assembly Building located on the east side of Harbour Way South, while the average noise level can be assumed to be lower.80

Preliminary analysis—factoring in attenuation factors for exterior walls, windows, and distance—indicated that the noise exposure of occupants in the Ford Assembly Building would be within interior noise limits for residential uses; Title 24, Part 2, California Code of Regulations establishes an interior noise standard of 45 dBA for residential space (CNEL or DNL). However, in response to concerns about noise expressed by occupants of the Ford Building, the City retained the services of an acoustical consultant to conduct noise measurements of current log preparation and handling operations at Terminal 3, which do not yet include loading of ships or export of logs by ship, and do not include debarking operations.81 However, current operations include arrival and departure of log trucks, truck weighing, log unloading operations, log stockpiling, loading of logs into shipping containers, and regular mechanical site cleanup with a street sweeper.

Noise measurements were taken during log preparations both on the Terminal 3 property and inside the Ford Building, within the offices of Mountain Hardwear, which was determined to be the closest and the maximally exposed receptor in the Ford Building. Therefore, this analysis represents a worst-case evaluation of noise impacts to offsite receptors. Potential future live/work occupants would be located further away (and most likely not at the Harbour Way

79 U.S. Department of Transportation, Federal Highway Administration, Construction Noise Handbook, Table 9.1 RCNM: Default Noise Emission Reference Levels and Usage Factors, August 2006. 80 For point noise sources, the sound level is reduced by approximately 6 to 7.5 dBA for every doubling of distance from the source, assuming level ground, hard surfaces, and no intervening buildings, structures, or vegetation; the attenuation factor is increased by the presence of any of those features. The discussion above conservatively assumes an attenuation factor of 6 dBA. 81 Environmental Service, op. cit.

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South façade of the building), and therefore would experience lower noise levels than those measured in the Mountain Hardwear offices.

The noise measurements were taken on June 30, 2016 on the second floor in a large customer meeting room. This location is depicted as Mic#4, shown on Figure N–1. Measurements were made with windows both open and closed. The noise analysis demonstrated that noise levels that would be experienced at the Mountain Hardwear offices would be well within noise levels common in an office environment. During the noise measurements taken from inside the second-floor Mountain Hardwear conference room during active log handling operations at Terminal 3, the loudest noises observed occurred when U.S. mail and FedEx delivery trucks passed by on Harbour Way South. Additional noticeable noise came from vehicle traffic in the driveway to the Ford Assembly Plant building, which was discernible with windows partially open or closed. Loading and unloading of logs at Terminal 3 was not specifically discernible with windows closed or open.

With two windows partially open, measured noise levels at Mic#4 inside the conference room were 47 dBA (L50), 57 dBA (L1), and 58 dBA (Lmax,3). With the windows closed, these noise levels were 37 dBA, 51 dBA, and 49 dBA, respectively. The corresponding outdoor sound levels near the entrance to the Mountain Hardwear offices were estimated to be 59 dBA (L50), 71 dBA (L1), and 70 dBA (Lmax,3). Factoring in the additional noise from the proposed debarker (using noise data collected at the Sacramento debarking facility), the future noise levels inside the Mountain Hardwear conference room during log handling and preparation operations are projected to be 47 dBA (L50), 57 dBA (L1), and 58 dBA (Lmax,3). Thus, the addition of the debarker noise would not increase noise experienced at this location.

Sound levels in most office environments are in the 45-60 dBA range, with occupant-generated sounds (e.g., office machines, conversations, ventilation, etc.) typically comprising a major source of noise in the office. Thus, the noise levels experienced inside the Mountain Hardwear offices during log handling and preparation operations are well within normal office noise levels, and are not expected to increase with the addition of the debarker noise.

It should also be noted that the Ford Assembly Building site has a land use designation of Business/Light Industrial, which allows DNL noise levels up to 80 dBA as Normally Acceptable. The land use compatibility standards established in the General Plan establish a Normally Acceptable DNL of 70 dBA for multi-family residential land use and a Normally Acceptable DNL of 65 dBA for single-family residential land use. Thus, even the higher Lmax values that would be generated by project operations would be well within allowable noise levels for single-family residential land uses.

Exterior Noise Levels As previously noted, noise measurements were also taken on the project site while log handling operations were underway. These operations consisted of unloading logs from trucks, stacking logs, and loading logs into shipping containers. In addition to these activities, noise was generated by tractor engine idling. Loading containers and unloading incoming tractor-trailers bringing logs was performed by CAT 325 and Link-Belt 240 excavators with log grapples.

Measurements were taken near the north end of the Terminal 3 warehouse building at the location depicted on Figure N–1 as Mic#5. At this location the predominant noise source was log loading and unloading by a pair of excavators, with intermittent inbound passbys of tractor- trailer trucks loaded with logs, which were exclusively using the northern facility entrance. The estimated distance of Mic#5 from the predominant noise sources was 550 feet from loading operations and 850 feet from unloading operations. Log trucks entering from Harbour Way

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South occasionally passed within 80 feet of Mic#5; however, these passbys were infrequent. Mic#5 was in an open paved lot without shielding by intervening buildings or walls, with a clear line-of-sight to the two excavators. The measured noise levels at Mic#5 were an L50 of 59 dBA, an L1 of 70 dBA, and an Lmax,3 of 69 dBA. The L1 is the noise level not exceeded more than 1 percent of an hour, equivalent to 0.6 minutes. Lmax,3 here means the maximum level equaled or exceeded during 3 minutes of 60 minutes.

To estimate future noise levels with the additional operational noise from the proposed debarker, the noise levels were adjusted using noise measurements of an operational debarker taken at an existing log processing facility in West Sacramento, as discussed above. In addition to the measurements made inside the operator cab, measurements were also conducted at two outdoor areas: one located approximately 125 feet northeast of the debarker ring (Mic#1), and one located approximately 66 feet northwest of the debarker ring (Mic#2). At both locations the calibrated noise meter was mounted on a tripod approximately 5.5 feet above the ground surface, with direct line-of-sight to the debarker ring. The measurements also captured log loading to the loader conveyor and log off-loading from the outfeed conveyor, activities that will also take place at the proposed facility.

The Mic#1 and Mic#2 noise measurements of an operational debarker were added to the Mic#5 noise measurements of current log preparation operations at Terminal 3 to derive the expected future noise levels that could occur with simultaneous log handling and debarking activity. The aggregate future L50 noise levels were calculated for four locations (A, B, C, and D) along the Terminal 3 property line adjacent to Harbour Way South, as shown on Figure N–2. The future L50 noise levels are projected to be in the range 60-74 dBA, except near the north driveway along the north side of the Terminal 3 building. Approximately 40 feet north or south of the driveway, near locations C and D, projected L50 noise may approach 79-80 dBA.

The elevated noise levels at these limited locations is due to the intermittent noise of log trucks entering and exiting the facility in combination with the noise generated by the debarker. This is because the north end of the Terminal 3 warehouse, where the debarker would be located, is currently (and will remain) completely open. Thus, as shown on Figure N–2, the maximum noise levels generated by the proposed project would emanate from the north end of the terminal building. However, the Port/Maritime district boundary is approximately 35 feet east of the Terminal 3 property line. Adjusting for the additional 35 feet of separation from the debarker (i.e., roughly 75 feet from the opening at the north end of the terminal building) and additional acoustic shielding provided by the eastern wall of the terminal building (because the debarker would be set back approximately 60 to 70 feet from the open northern wall of the building), the projected L50 noise level near locations C and D would be reduced by 2 or 3 decibels, resulting in 76-78 dBA.

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Figure N-1

Noise Measurement Locations Source: Environmental Service, 2016 Page 7 of 9

Figure N-2

Page 9 of 9 Estimated Future Project Noise Levels Source: Environmental Service, 2016

According to Section 15.04.840.010 of the City of Richmond’s Municipal Code, the maximum allowable noise level in the Port/Maritime district in which Terminal 3 is located is an L50 of 75 dBA, as measured at the district boundary. Thus, while the projected noise levels along the Terminal 3 property boundary would be below the noise limit established in the Noise Ordinance at most locations, the 75-dBA limit could be exceeded near the north driveway entrance. However, it is expected that noise levels would be acceptable at nearby offsite receptors. Despite the potential conflict with Municipal Code Section 15.04.840.010, project- generated noise would not adversely affect offsite receptors. Therefore, the proposed project would have a less-than-significant impact due to generation of noise levels in excess of applicable local, State, or federal standards.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Exposure of persons to or generation of excessive groundborne vibration or groundborne noise levels? ⌧

Explanation: Occupants of the Ford Assembly Building (FAB), located as close as 400 feet from where logs were previously being loaded into shipping containers, reported in comments on the previous Initial Study that vibrations from logs being dropped on the ground or into shipping containers created perceptible and disturbing vibrations inside the FAB. Concern was expressed that such vibration could result in damage to the building, which is an historical building, or to state-of-the-art audio/visual equipment and other high-tech installations used in the building that are sensitive to disturbance from vibrations. In response to these comments, the City worked with RJJ, the project sponsor, to implement some operational changes to reduce vibration effects at the FAB. Log handling operations were shifted away from the southern portion of the Terminal 3 property to the northern end, creating a substantial additional distance buffer for FAB occupants. Additionally, RJJ has worked with its log handling operators to reduce the heights from which logs are released both into shipping containers and onto log stacks. Since travel by heavy log trucks can generate both noise and vibration, the log truck traffic was shifted from the south entrance near the Mountain Hardwear offices to the north entrance. Consequently, loaded and empty trucks are no longer traveling on Harbour Way South adjacent to the Mountain Hardwear offices. During the noise measurements conducted in the Mountain Hardwear offices while log handling operations were active (discussed in Section XII(a), above), no vibrations were perceived by the noise consultant or the CEQA project manager. Additionally, the Mountain Hardwear representative who accompanied the CEQA team acknowledged that vibration impacts had not been a problem since the operations had been shifted further to the north.

Following the operational changes described above, the site inspection and noise measurements conducted inside the FAB demonstrated that the proposed project would not generate substantial amounts of groundborne vibration at offsite receptors. While it’s still possible that workers at offsite properties could experience periodic groundborne vibration from the movement of heavy logs, such vibration would be momentary, intermittent, and not of sufficient intensity to cause damage, unduly annoy workers, or result in perceptible vibration at offsite locations. The relocation of log loading operations further north appears to have successfully minimized vibration experienced inside the FAB. No railroads operate in proximity to the site and there are no other existing sources of substantial groundborne vibration. The project would have a less-than-significant impact related to groundborne vibration .

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) A substantial permanent increase in ambient noise levels in the project vicinity above levels existing ⌧ without the project?

Explanation: The noise that would be generated by onsite operations is discussed in Section XII(a), above. Trucks hauling logs to the proposed facility would also generate noise along I-580 and Harbour Way South en route to the site. With respect to traffic noise sources, a doubling of traffic volumes is generally required before an increase in ambient noise will be perceived by the average person, corresponding to a noise level increase of 3 dB. As discussed in more detail in Section XVI, Traffic/Transportation, during normal operations, the proposed project is expected to generate a total of 14 truck and auto vehicle trips during both the AM and PM peak hours, with a passenger car equivalent (PCE) of 26 trips. During the limited periods when ship- loading operations would occur, there would be 31 total trips and 43 PCE trips during both peak hours. Existing peak-hour traffic volumes on Harbour Way South are about 408 vehicles and 415 vehicles during the AM and PM peak hours, respectively, at the intersection of Wright Avenue. At Hall Avenue, opposite the project site, the existing volumes on Harbour Way South are about 190 vehicles and 91 vehicles during the AM and PM peak hours, respectively.82 As these figures demonstrate, the proposed project would not come close to doubling existing traffic volumes on Harbour Way South, and the additional traffic on I-580 would represent a minute fraction of existing traffic on this regional freeway. Therefore, the noise that would be generated by the project would have no discernable effect on the ambient noise levels at the site.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) A substantial temporary or periodic increase in ambient noise levels in the project vicinity above ⌧ levels existing without the project?

Explanation: The project’s potential noise impacts are addressed in Sections XII(a) and (c), above. The project would not require new construction or other potential sources of substantial temporary noise.

82 Fehr & Peers, Amethod Charter School Transportation Impact Analysis, Figure 2: Peak Hour Traffic Volumes, Intersection Controls, and Lane Configurations–Existing Conditions, June 17, 2015.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, ⌧ would the project expose people residing or working in the project area to excessive noise levels?

Explanation: The project site is not located within the area governed by an airport and use plan or within 2 miles of an airport.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) For a project within the vicinity of a private airstrip, would the project expose people residing or working ⌧ in the project area to excessive noise levels?

Explanation: There are no private airstrips in the vicinity of the project.

XIII. POPULATION AND HOUSING — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Induce substantial population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through ⌧ extension of roads or other infrastructure)?

Explanation: The proposed project would not induce population growth. It would not create new housing and would not construct new infrastructure. While it would create employment for five workers, they would likely be already living in the area. Even in the unlikely event that all five employees relocated from outside the area to take the jobs, this would represent minuscule growth relative to the existing population of Richmond and the surrounding region. The longshoremen who would be hired on an intermittent and temporary basis to load ships would be expected to already reside in the area.

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One of the comment letters submitted to the City on the previous April 2016 Initial Study (see Appendix A) stated that the proposed project would have “the lowest job density possible,” in contravention of the residential and job density needed to support the planned ferry terminal on the wharf at the southern end of the Ford Assembly Building. While the City encourages new developments that would bring increased employment opportunities to the City, it cannot dictate what kinds of development proposals it receives. It is true that the job density of the proposed project would be low, boosted intermittently by the employment of longshoremen to load outgoing ships. However, the project would bring needed revenue to the Port and the City at a Port property that is currently underutilized. As discussed in Section X, Land Use and Planning, the proposed project is consistent with the types of land uses for which the Terminal 3 property has been reserved for decades. The relatively small number of jobs that would be created by the project is not an environmental issue under the purview of CEQA, but the commenter’s concerns will be considered by decision makers prior to making a decision on whether or not to approve the proposed project. It should be noted that the planned ferry terminal is expected to draw ridership from the entire City of Richmond as well as neighboring cities. The success of the ferry would not be undermined because the proposed activity at Terminal 3 does not generate a high job density.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Displace substantial numbers of existing housing, necessitating the construction of replacement ⌧ housing elsewhere?

Explanation: There is no existing housing on the project site; the project would have no effect on housing.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Displace substantial numbers of people, necessitating the construction of replacement housing elsewhere? ⌧

Explanation: See Section XIII(b), above.

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XIV. PUBLIC SERVICES - Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the following public services:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Fire protection? ⌧

Explanation: Fire response to the project site would be provided by the Richmond Fire Department (RFD), which operates seven stations located throughout the City of Richmond’s geographical area of 56 square miles. The Department currently has a staff of 93 sworn personnel and 4 non-sworn administrative staff.83 The General Plan EIR reported that in 2009 the Department had an acceptable staffing ratio of 1 fire personnel per 4,200 residents.

The RFD responds to approximately 11,000 alarms each year, about 77 percent of them for emergency medical service.84 The Department has a response time goal of responding to 85 percent of emergency calls within 6 minutes or less.

Fire Station No. 67, located at 1131 Cutting Boulevard, about 4,000 feet (0.76 mile) north of the project, would provide first response to the project in the event of a fire or medical emergency. Fire response time to the site would be well within the Department’s response time goal established in the General Plan.

The RFD has conducted a preliminary review of the proposed project, and identified the following conditions that must be satisfied.85 These will become conditions of approval for the required Conditional Use Permit. Additional fire safety requirements may be identified by the RFD prior to project approval.

1) The applicant shall provide adequate and approved dust collection for any dust producing equipment and/or appliances if the wood process will be occurring within any building on site. All dust producing equipment shall be reviewed by the Richmond Fire Department for compliance prior to installation.

2) In and around all areas which produce possible explosive/combustible dust particles, electrical wiring shall be installed to meet the requirements of Class Division I/II. Plans and specifications for this wiring requirement shall be submitted to the Richmond Fire Department for review and approval prior to installation.

83 Richmond Fire Department, Department Facts, accessed November 25, 2015 at: http://ca- richmond2.civicplus.com/1483/Department-Facts. 84 City of Richmond, Richmond General Plan Update Draft Environmental Impact Report, Section 3.12; Public Services, February 2011. 85 John Fitch, Fire Service Specialist, Richmond Fire Department, personal communication, February 8, 2016.

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3) All automatic fire sprinkler systems shall require a California State Fire Marshal certification as required by State law. A copy of this certification shall be submitted to the Richmond Fire Department for review prior to allowing occupancy within the fire sprinklered buildings on the premises.

4) Fire extinguishers shall be provided and mounted throughout the site and shall have a service tag affixed to them verifying they have received their annual servicing.

The proposed project would not cause a substantial increase in demand for fire protection services. It would be developed on an existing marine industrial site that has been used for marine cargo operations for many decades. The project would not develop any new structures, and temporary log piles would not create a fire hazard. While the movement and handling of logs would create some potential for worker injury, with just five workers and a health and safety plan required to be prepared and implemented (see Section VI, Geology and Soils), this would not be expected to significantly increase the calls for emergency medical response, and any calls for service that might be generated by the project could readily be accommodated with the RFD’s existing facilities, equipment, and personnel. Therefore, the project’s potential impact on fire protection services would be less than significant.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Police protection? ⌧

Explanation: Police protection would be provided to the project by the Richmond Police Department (RPD), which operates out of a central station at 1701 Regatta Boulevard and has a force of 195 sworn officers.86 The General Plan EIR reported that the RPD had a staffing ratio of 1.6 sworn officers per 1,000 residents in 2008.87 The RPD had an average response time in 2009 of 6 minutes and 43 seconds for Priority 1 calls—such as shootings, robberies, burglaries, and assaults—and 14 minutes and 50 seconds for Priority 2 calls.

The proposed project would not cause a substantial increase in demand for police protection services. Although it would generate employment for five workers, there are currently workers at the Terminal 3 site. The project would not create new security concerns and does not entail any uses of the site that might attract criminal activity. It would be expected to have a negligible effect on demand for police protection. Therefore, the project’s potential impact on police protection services would be less than significant.

86 Chris Magnus, Chief of Police, Richmond Police Department, RPD Update, Spring 2014. 87 City of Richmond, Ibid.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Schools? ⌧

Explanation: The project would not create new housing and, as discussed in Section VIII(a), is not expected to result in an increase in the population of the City of Richmond. There is therefore no potential for the project to adversely affect schools.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Parks? ⌧

Explanation: As noted in Section IX(c), above, the project would not increase the population of Richmond, and therefore the project would have no effect on the demand for park services.

There is an existing park, Sheridan Observation Point, located about 300 feet south of the project site, at the end of Harbour Way South. Aside from a parking lot and a small observation/fishing pier, this site consists of a strip of sparse grass about 30 feet wide, with some shrubs and a few trees. The site appears to get very little use; in numerous visits by the environmental consultant, no visitors were ever observed at Sheridan Observation Point. Visitors to the small park would likely be able to hear operations at the project site during periods of ship loading or during movement of logs into the Debarked Logs Deck. As discussed in more detail in Section XII, Noise, at this distance the noise levels would not be significant, and would be intermittent. The project would therefore have a negligible effect on park users.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Other public facilities? ⌧

Explanation: As noted in Section IX(c), above, the project would not increase the population of Richmond, and therefore the project would have no effect on the demand for other public facilities such as libraries.

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XV. RECREATION —

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration ⌧ of the facility would occur or be accelerated?

Explanation: As discussed in Section IX(c), above, the project would not increase the population of Richmond, and therefore it would have no effect on existing parks or other recreational facilities.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect ⌧ on the environment?

Explanation: The proposed project does not include construction of any recreational facilities.

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XVI. TRANSPORTATION/TRAFFIC — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Conflict with an applicable plan, ordinance, or policy establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation, including mass transit and non-motorized travel and relevant ⌧ components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit?

Explanation: All truck traffic and most other traffic (i.e., employee trips) would travel to and from the project site via Interstate 580 (I-580) and Harbour Way South. The transportation consulting firm of Fehr & Peers conducted a transportation assessment for the proposed project to identify potential traffic impacts on these roadways, the results of which are summarized in this section.88 The evaluation represents a worst-case analysis because at the time of preparation of the transportation assessment, it was assumed that there would be up to 40 log truck deliveries per day. The project was subsequently revised to entail a maximum of 10 truck deliveries per day. Thus, the analysis presented in this section exaggerates the potential traffic effects of the proposed project.

Earlier in 2015 Fehr & Peers had conducted a traffic impact analysis for the Amethod Charter School project that included an evaluation of existing operating conditions at the intersections of Harbour Way South at Hall Avenue and Harbour Way South at Wright Avenue, the two primary intersections that would be affected by project-related traffic. In that analysis, Fehr & Peers determined that both intersections were currently operating at Level of Service (LOS) A, representing free-flowing conditions, and both would continue to operate at LOS A with the additional traffic that would be generated by the proposed school.

Fehr & Peers estimated the vehicle trip generation for the proposed project based on the project information provided by the project applicant. Because the trucks hauling logs are larger and slower than passenger cars, Fehr & Peers converted the haul truck trips to a passenger car equivalent (PCE), using a PCE of 2.5 vehicle trips per truck, the rate recommended in the 2010 Highway Capacity Manual (HCM). Employees were assumed to travel individually to and from the site in private autos. It was conservatively assumed that each employee (and longshoreman, during ship-loading operations) would leave the site for lunch each day in separate cars, resulting in four daily vehicle trips per employee. It is likely that some employees would remain on site during the lunch break and others would travel offsite in shared vehicles, resulting in fewer actual daily trips generated by the project.

88 Fehr & Peers, Terminal 3 Transportation Assessment, October 2, 2015.

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The project is expected to generate 284 daily vehicle trips (PCE), with a maximum of 31 peak- hour trips (43 PCE trips) during both the AM and PM peak hours. This would only potentially occur during ship-loading operations, when an additional 16 longshoremen would work at the facility for about 10 days to load each vessel, which would occur seven to eight times per year. During other times of regular operations, there would be a total of 14 peak-hour vehicle trips (26 PCE trips) during both peak hours and a daily total of about 220 trips. A breakdown of the trips is presented in Table T–1.

Table T–1 Estimated Project Trip Generation

Weekday AM Peak Hour PM Peak Hour Trip Type Daily Trips In Out Total In Out Total

Normal Daily Operations

Workers 20 5 1 6 1 5 6 Trucks 80 4 4 8 4 4 8 PCE1 200 10 10 20 10 10 20 Total Vehicles 100 9 5 14 5 9 14

PCE1 220 15 11 26 11 15 26

Ship-Loading Operations

Workers 84 21 2 23 2 21 23 Trucks 80 4 4 8 4 4 8 PCE1 200 10 10 20 10 10 20 Total Vehicles 164 25 6 31 6 25 31

PCE1 284 31 12 43 12 31 43

Source: Fehr & Peers, 2015 Notes: 1 Truck trips converted to a passenger car equivalent (PCE) of 2.5 trips per truck trip.

Fehr & Peers determined that the 26 to 43 PCE peak-hour trips added to I-580 and the intersections on Harbour Way South would not noticeably affect these facilities or cause a degradation in LOS. Therefore, the proposed project would have a less-than-significant impact on traffic.

Although the project would not have a significant adverse effect on operation of the Harbour Way South/Wright Avenue intersection, the May 2014 Richmond Ferry Terminal Project Initial Study/Mitigated Negative Declaration determined that this intersection would operate unacceptably at LOS F following implementation of the planned Ferry Terminal at the southern end of Harbour Way South. That document found that signalization of this intersection would improve operating conditions to acceptable levels (LOS A). Accordingly, the mitigation for the ferry project consisted of requiring the project to contribute the fair-share amount of funding

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towards the signalization of the intersection. Because the proposed log export facility would add traffic to this intersection projected to be overburdened once the ferry terminal is established, the City intends to require the project applicant to also make a fair-share contribution to the signalization of the intersection. Fehr & Peers calculated the proposed log export facility’s contribution to traffic at the intersection to be 5 percent of total traffic volumes.89

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Conflict with an applicable congestion management program, including but not limited to level of service standards and travel demand measures, or other standards established by the county congestion ⌧ management agency for designated roads or highways?

Explanation: A study of Congestion Management Program (CMP) roadways and freeway segments overseen by the Contra Costa County Transportation Authority (CCTA), the applicable congestion management agency, was not required for the project because it would generate fewer than 100 peak-hour trips, the CCTA threshold for CMP analysis. Thus, although the project would cause an incremental increase in traffic on I-580, which is a CMP roadway, the project would not conflict with the Contra Costa County CMP.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Result in a change in air traffic patterns, including either an increase in traffic levels or a change in ⌧ location that results in substantial safety risks?

Explanation: The proposed project would have no effect on air traffic patterns.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) ⌧ or incompatible uses (e.g., farm equipment)?

Explanation: Fehr & Peers evaluated the proposed site plan as part of the transportation analysis in order to identify any potential safety hazards or access/circulation problems. The

89 Fehr & Peers, Terminal 3 – Fair Share Contribution Assessment [draft technical memorandum], March 24, 2016.

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project would not create new offsite roads or intersections or alter existing offsite roadways. It would utilize two existing driveways to the Terminal 3 site.

Primary access to the project would be provided by a full-access driveway on Harbour Way South, 250 feet north of the Harbour Way South/Hall Avenue intersection (i.e., the northern entry gate). The driveway is 33 feet wide and trucks are expected to turn right into the facility and turn left onto Harbour Way South to exit the facility. Fehr & Peers determined that this driveway provides adequate sight distance for entering and exiting vehicles. A second driveway, located about 1,200 feet south of the primary driveway would only be used by site workers and visitors. The southern entrance would not be used by trucks.

Trucks carrying debarked logs would use the primary driveway to enter the facility and drive towards the truck scales on the south side of the site, as illustrated on the site plan (Figure 3). Facility employees would weigh the fully loaded trucks, unload the logs, and weigh the empty trucks before departure. Trucks carrying logs with bark would enter the scale yard north of the truck entrance to be weighed and logs would be unloaded and left in this area until a sufficient amount have been collected to be debarked.

Based on the project site plan, Fehr & Peers determined that the proposed facility would provide for safe vehicle circulation during typical operations. Trucks would enter and exit the facility staggered at 15-minute intervals. It is estimated that a typical truck would spend about 15 minutes on the site. The project site would provide adequate space for trucks to maneuver through the entrance toward the truck scales and exit the log facility. Fehr & Peers noted that the proposed truck route within the project site should be maintained clear of obstructions in order to continue to provide adequate vehicle circulation into, out of, and within the project site. Based on the expected frequency of trucks during peak delivery periods, trucks are not expected to queue within the facility or along Harbour Way South.

Among the issues raised in comment letters submitted to the City on the April 2016 Initial Study for the proposed project were concerns, both implied and stated explicitly, about traffic and pedestrian safety on Harbour Way South. (Issues of worker safety are discussed in Section III, Air Quality, and Section XII, Noise.) The concern is that the log-hauling trucks travelling on Harbour Way South would endanger future commuter traffic traveling to and from the planned ferry terminal at the south end of Harbour Way South, and would also endanger the new bicycle and pedestrian improvements along Harbour Way South. However, the Fehr & Peers analysis referenced above also evaluated the potential roadway traffic safety hazards that could be created by the proposed project and concluded that the project would not cause any safety hazards, either on the site or on existing roadways.

The use of Harbour Way South by trucks serving the Port terminals has been supported in Richmond planning documents for decades and continues to be supported in recently adopted documents. For example, the South Richmond Shoreline Special Area Plan (SRSSAP), a joint planning document adopted in 1977 by the City of Richmond and the San Francisco Bay Conservation and Development Commission (BCDC), designates the Santa Fe Sub-Area in which the project is located as a port priority area, and lists the primary land uses as industrial and marine. The Knox Freeway/Cutting Boulevard Corridor Specific Plan adopted in 1991 assigns a land use designation of Port/Maritime to the project site. The City’s General Plan also assigns a Port land use designation to the project site, which is located in a Port Priority Use Area intended to recognize and reflect the Port’s continuing role as a major hub of port and related industrial uses. The General Plan notes that new improvements within this change area should focus on strengthening the overall economic vitality of the Port of Richmond.

More recently, the City adopted the South Richmond Transportation Connectivity Plan (SRTCP) in July 2015 to address deficiencies in the existing transportation systems in South Richmond,

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shortcomings that are expected to become more critical when the planned ferry terminal on the Ford Peninsula becomes operational in 2018 and when the planned Berkeley Global Campus at Richmond Bay is developed. Safety is the first of nine key principles guiding the transportation planning effort documented in the SRTCP. The SRTCP designates Harbour Way South as a key multi-modal transportation corridor, intended to serve not only the planned ferry terminal at the southern end of Harbour Way South, but also the truck traffic needed to support the existing industrial and marine activities on the Ford Peninsula, where industrial use is identified as a primary land use.

Maintaining freight access is listed as a key objective of the SRTCP. Accordingly, the Plan designates Harbour Way South as a Truck Route. Both near-term and long-term planned improvements for Harbour Way South are intended to provide greater separation between truck traffic and bicyclists and pedestrians. The planned improvements will include a two-way separated bikeway on the east side that will eventually be a raised two-way cycletrack. Parking restrictions near driveways and intersections will improve sight lines and enhance the safety of truck turning movements. Implementation of the SRTCP is intended to reduce and minimize the types of traffic safety hazards alluded to in the comments received on the previous Initial Study for the proposed project.

As with any activity involving use of motorized vehicles, there is some inherent safety risk involved with the operation of haul trucks to serve the proposed project. However, the proposed project would not create a significant new safety hazard through the operation of legally licensed commercial trucks on public roadways. Furthermore, planned improvements to Harbour Way South, once implemented, will increase pedestrian, cyclist, and motorist safety along this corridor.

Based on the above considerations, the project would not create or increase traffic hazards.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Result in inadequate emergency access? ⌧

Explanation: As discussed in Section XVI(d), above, Fehr & Peers concluded that the plan exhibits adequate site access and on-site circulation for motor vehicles, including fire trucks and other emergency vehicles, and would not alter offsite access routes. Furthermore, prior to project approval, the Richmond Fire Department will be required to sign off on the adequacy of the project plans as they pertain to site access and fire safety issues.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) Conflict with adopted policies, plans, or programs regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or ⌧ safety to such facilities?

Explanation: According to Map 4.1 of the Richmond General Plan 2030, Harbour Way South is designated as an existing Class I bicycle route south of Hall Avenue (opposite the project site) and as a Class III bicycle route between Hall Avenue and Wright Avenue. A short segment of Harbour Way South north of Wright Avenue is designated as a Class II bicycle route. Map 4.1 also designates much of the Ford Peninsula east of Harbour Way South as a Pedestrian Improvement District. Map 10.1 of the General Plan designates Harbour Way South south of Hoffman Boulevard as an existing bicycle and pedestrian trail.

The General Plan does not contain any policies or guidance pertaining to Pedestrian Improvement Districts. In any event, Harbour Way South, the access route for the proposed project, is located outside of the designated Pedestrian Improvement District. Class I Bikeways (Bike Paths) provide a completely separate right-of-way and are designated for the exclusive use of bicycles and pedestrians, with cross-flow of vehicles minimized. Class II Bikeways (Bike Lanes) provide a restricted right-of-way and are designated for the use of bicycles with a striped lane on a street or highway. They are generally 5 feet wide, and vehicle parking and vehicle/pedestrian cross-flow are permitted. The Class III Bikeway (Bike Route) provides a right-of-way designated by signs or pavement markings for shared use of the roadway with pedestrians or motor vehicles.

Implementation of the proposed project would not conflict with the use of Harbour Way South by pedestrians and bicyclists. It is a wide, lightly traveled thoroughfare with a curb-to-curb width of 55 feet, with continuous sidewalks on both sides of the street. North of Hall Avenue there is a striped bike lane on the east side of the roadway. There is ample space along Harbour Way South for bicyclists and pedestrians, with good distance separation from vehicle traffic. While the project would add up to four trucks per hour to the roadway during weekdays, based on multiple visits to the project vicinity during weekdays by the environmental consultant, there is negligible pedestrian and bicycle traffic Harbour Way South at these times. The minor incremental increase in truck traffic along the roadway would not interfere with pedestrian and bicycle travel along this roadway. Although the General Plan notes that there is a need for warning lights, gates, and other improvements at BNSF rail crossing at Harbour Way South and Wright Avenue, the proposed project would not exacerbate safety hazards at this intersection and would not result in any increase in pedestrian or bicycle traffic at this crossing.

Map 4.2 of the General Plan designates Harbour Way South as a Transit Priority Street. Hall Avenue and Harbour Way South north of Hall Avenue are part of a Bay Area Rapid Transit (BART) shuttle route providing connections to the Richmond and El Cerrito Del Norte BART stations.

As previously discussed in Section X(b), all of the Richmond General Plan 2030 policies, including those pertaining to public transit, bicycle, and pedestrian facilities, were reviewed to identify those applicable to the proposed project and evaluate the project’s consistency with those

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policies. In particular, the project would further the City’s goal expressed in Land Use and Urban Design Policy LU3.5, An Economically Viable and Modern Port, which calls for developing the Ford Peninsula area as a working waterfront that supports the Port’s operations and provides opportunities for job-generating uses and other uses. It would also support Economic Development Policy ED8.6, An Economically Viable and Modern Port, which encourages growth and modernization of private port businesses and the Port of Richmond. No conflicts with adopted General Plan policies were identified for the proposed project.

XVII. UTILITIES AND SERVICE SYSTEMS — Would the project:

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Exceed wastewater treatment requirements of the applicable Regional Water Quality Control Board? ⌧

Explanation: Wastewater from the project would be treated at the Richmond Municipal Sewer District’s (RMSD) Wastewater Treatment Plant (WWTP) located at 601 Canal Boulevard, approximately 1 mile northwest of the project site. The RMSD provides wastewater collection service to approximately 68,000 Richmond residents. Veolia Water West Operating Services, Inc., an independent company, operates, maintains, and manages the WWTP as well as the wastewater and stormwater collections systems for a significant portion of the City of Richmond, including the project site. The wastewater treatment plant is permitted by the Regional Water Quality Control Board (RWQCB) and effluent from the plant is regularly monitored to ensure that water quality standards are not violated.

In August 2013 the RMSD adopted a Sewer System Management Plan (SSMP) to comply with RWQCB sanitary sewer overflow (SSO) reporting requirements and also to ensure the WWTP meets the General Waste Discharge Requirements (Statewide WDRs) established by the State Water Resources Control Board (SWRCB). The SSMP lays out a detailed operation, maintenance, and training program for complying with the Statewide WDRs. It also includes an Overflow Emergency Response Plan and plans for ensuring adequate collection and treatment capacity and for monitoring needs for system upgrades. Other goals of the SSMP are to minimize the frequency and severity of SSOs and to mitigate the impacts of SSOs.

Based on a search of violation reports over the past five years, the San Francisco Bay Regional Water Quality Control Board (RWQCB) shows one National Pollutant Discharge Elimination System (NPDES) violation for the WPCP in the past five years.90 In April 2012 a Category 3 violation was logged for deficient monitoring due to failure to report biochemical oxygen demand (BOD) removal. This represented an oversight in monitoring but did not involve a violation of effluent limitations for regulated pollutants. No other violations were reported over the past five years.

90 California Environmental Protection Agency, State Water Resources Control Board, California Integrated Water Quality System Project (CIWQS), Violation Reports, accessed December 7, 2015 at: https://ciwqs.waterboards.ca.gov/ciwqs/readOnly/CiwqsReportServlet?inCommand=reset&reportName=Publi cVioSummaryReport.

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The plant operator is responsible for complying with the applicable wastewater treatment requirements. As indicated by the search results, the Richmond WWTP is generally in compliance with these requirements, as confirmed by the San Francisco Bay RWQCB. Wastewater generated by the proposed project would be typical of wastewater generated throughout the WPCP service area. There is no potential for the project to cause the WPCP to exceed wastewater treatment requirements.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Require or result in the construction of new water or wastewater treatment facilities or expansion of existing facilities, the construction of which could ⌧ cause significant environmental effects?

Explanation: Water service is currently provided to the project site by the East Bay Municipal Utility District (EBMUD); the existing service is expected to be adequate to meet the needs of the project. EBMUD submitted a comment letter (see Appendix A) in response to the previous Initial Study circulated for public review in April 2016. In its comment letter, EBMUD expressed concern about a distribution pipeline that it owns and operates under Chandler Avenue, which is a private road crossing the north end of Terminal 3; it coincides with the northern entrance to Terminal 3. The City acknowledges that the integrity of the pipeline needs to be maintained at all times. Implementation of the proposed project would not require disturbance or relocation of this below-ground pipeline, and there are no aspects to the proposed project that would interfere with EBMUD’s operation of this water distribution pipeline.

EBMUD’s comment letter also expressed concern about the potential for contaminated soils or groundwater to be present within the project site boundaries, noting that it will not install or design piping or services in contaminated soil or groundwater. Based on the results of the Phase I Environmental Site Assessment, discussed in Section VIII, it is assumed that there is minimal contamination remaining at the north end of the site in the vicinity of former underground storage tanks (USTs). While soil and groundwater contamination with total petroleum hydrocarbons as diesel (TPHd), total petroleum hydrocarbons as gasoline (TPHg); benzene, toluene, ethylbenzene, and xylenes (BTEX); and methyl tertiary butyl ether (MTBE) was present when the USTs were removed in 1998, subsequent sampling conducted in September 2007 determined that the pollutants had attenuated to non-detectable levels in the soil and to low or non-detectable levels in the groundwater. As a precautionary measure, the San Francisco Bay Regional Water Quality Control Board (RWQCB) stated in the case closure report that “there may be residual contamination in both soil and groundwater at the site that could pose an unacceptable risk under certain development activities such as site grading, excavation, or installation of water wells.” However, the proposed project would not require any grading, excavation, or installation of water wells or new water piping. Consequently, the proposed project would not expose any residual contamination that could be present and would not cause an increase in health risk to onsite workers or offsite workers or residents.

The comment letter from EBMUD noted that the project presents an opportunity to incorporate water conservation measures, stating that new or expanded service will not be furnished without such measures. As requested in the comment, the City will require the applicant, as a condition of project approval, to incorporate water conservation measures to achieve compliance with the irrigation efficiency requirement established in the Model Water Efficient

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Landscape Ordinance promulgated in Division 2, Title 23, Chapter 2.7 of the California Code of Regulations. However, the proposed project would not require new or expanded service from EBMUD.

The proposed project would have a negligible effect on demand for water and wastewater treatment capacity. Water consumption would primarily consist of domestic use in bathrooms by employees. In addition, approximately 10 gallons of water per day would be consumed at the debarking ring of the debarker, where water would be sprayed each time a log is fed through the debarker in order to suppress wood dust. Water consumption would be comparable to existing water use at Terminal 3, and would not require new or expanded water treatment facilities. Similarly, a negligible amount of wastewater would be generated by project employees, comparable to existing use, and would not require expanded wastewater treatment capacity. The proposed project would be consistent with development envisioned in the Richmond General Plan EIR, which concluded that implementation of the General Plan would not require or result in construction or expansion of water or wastewater treatment facilities. Therefore, the project would have a less-than-significant impact on water treatment and distribution facilities.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Require or result in the construction of new stormwater drainage facilities or expansion of existing facilities, the construction of which could ⌧ cause significant environmental effects?

Explanation: The proposed project would not affect existing stormwater drainage facilities. It would not create new impervious surfaces or otherwise affect long-established drainage patterns on the site. The project would not cause any increase in the generation of stormwater. It would therefore have no effect on stormwater drainage facilities.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact d) Have sufficient water supplies available to serve the project from existing entitlements and resources, or ⌧ are new or expanded entitlements needed?

Explanation: The proposed project would be consistent with development envisioned in the Richmond General Plan EIR, which concluded that implementation of the General Plan would not require water supplies in excess of existing entitlements. As noted in Section XVII(b), above, the project would have a negligible effect on water demand for minor domestic use; no process water would be required for the project. Therefore, the project would have a less-than- significant impact on water supplies.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact e) Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the ⌧ project’s projected demand in addition to the provider’s existing commitments?

Explanation: See Section XVII(b), above.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact f) Be served by a landfill with sufficient permitted capacity to accommodate the project’s solid waste ⌧ disposal needs?

Explanation: The majority of waste that would be generated by the proposed project would consist of bark and wood debris stripped from logs. This byproduct would be collected once or twice a week by a recycler based (Agra Marketing Group) and conveyed in 25-ton semi-trailer trucks to end markets in the Bay Area or central California, where the waste bark would be ground up, screened, and used for landscape mulch and potting soil. Other waste generated at the facility would consist of incidental office waste, most of which would also be recycled. The project would generate a negligible amount of solid waste requiring disposal in a landfill.

Solid waste generated in the City of Richmond is currently disposed of at the Potrero Hills Landfill in Solano County. As of early 2011, the landfill had an approved capacity that would add 35 years to the remaining capacity of 10 years that was estimated at that time.91 In addition, the City has access to numerous other regional waste disposal facilities used by the West Contra Costa Integrated Waste Management Authority (WCCIWMA), of which the City of Richmond is a member. Given the collective capacities of these facilities, there is more than sufficient landfill capacity to accommodate the City’s landfill disposal needs through buildout of the General Plan in 2030. The proposed project would be consistent with development envisioned in the Richmond General Plan EIR, which concluded that implementation of the General Plan would not require or result in construction or expansion of landfill disposal capacity. Therefore, the project would have a less-than-significant impact on landfill disposal capacity.

91 City of Richmond, Richmond General Plan Update Draft Environmental Impact Report, Section 3.13, Public Utilities, February 2011.

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XVIII. MANDATORY FINDINGS OF SIGNIFICANCE —

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Does the project have the potential to degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal ⌧ community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory?

Explanation: The project site is an industrial port site that contains no valuable or sensitive habitats, and there is no potential for impacts to biological resources. Although there is a possibility for historic/prehistoric cultural resources to be buried under the site, the project would not require any subsurface disturbance.

Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact b) Does the project have impacts that are individually limited but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when ⌧ viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.)

Explanation: No significant cumulative impacts were identified for the proposed project. The less-than-significant cumulative impacts are discussed individually in the dedicated resource sections, including air quality, greenhouse gases, traffic, and others.

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Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact c) Does the project have environmental effects that will cause substantial adverse effects on human beings, ⌧ either directly or indirectly?

Explanation: Stacked logs on the project site could potentially collapse, primarily due to improper handling or stacking, which could potentially injure or kill nearby workers. Measures have been identified in this Initial Study to address this potentially significant impact. Mitigation measures have also been identified to address potentially significant impacts on water quality, which could result in indirect health effects in swimmers in the San Francisco Bay (waterborne diseases) and to those consuming fish or shellfish. Mitigation measures have been identified to reduce these potential impacts to less-than-significant levels. With implementation of all mitigation measures identified in this Initial Study, the project would not have environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly.

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REPORT PREPARATION

This Initial Study/Mitigated Negative Declaration was prepared under the direction of Douglas Herring & Associates, with assistance from the City of Richmond and the Port of Richmond. In addition, the technical consultants listed below contributed to preparation of the Initial Study or produced separate technical reports.

Project Manager: Douglas Herring & Associates 1331 Linda Vista Drive El Cerrito, CA 94530

Doug Herring, AICP, Principal

City of Richmond: Lina Velasco, Senior Planner

Air Quality & Greenhouse Gases: The RCH Group, Inc. 11060 White Rock Road, #150-A Rancho Cordova, CA 95670

Mike Ratte, Senior Air Quality Scientist

Wood Dust Exposure: Forensic Analytical Consulting Services 7625 Sunrise Boulevard, Suite 104 Citrus Heights, CA 95610

Sylvia Fontes, MS, CIH

Hazardous Materials: KC Engineering 865 Cotting Lane, Suite A Vacaville, CA 95688

Amy Lee, REPA, Environmental Assessor

Noise: Environmental Service 5789 Gold Creek Drive Castro Valley, CA 94552

Marc Papineau, R.E.A.

Traffic/Transportation: Fehr & Peers 1330 Broadway, Suite 833 Oakland, CA 94612

Jackson Lo, Transportation Engineer

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MITIGATION MEASURES

Air Quality Mitigation Measure AQ–1: Fugitive Dust and Combustion Exhaust Control Measures: The Applicant shall reduce air emissions by implementing the following fugitive dust control measures, including: • Compliance with Bay Area Air Quality Management District’s (BAAQMD’s) Particulate Matter and Visible Emissions Regulation shall be maintained. • All equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. • All haul trucks transporting mulch/bark materials along public streets shall secure loads consistent with the current California State Vehicle Code. • The Applicant shall use dust-proof chutes to load mulch/bark materials into trucks whenever feasible. • The Applicant shall use a front end loader to pick up large debris and a wet power vacuum street sweeper, as necessary, to clear mulch/bark materials from adjacent public roads. If visible track-out extends more than 50 feet from the exit point onto an adjacent public road, mulch/bark materials shall be removed immediately. The wet power vacuum street sweepers shall be one of the models certified by the South Coast Air Quality Management District (SCAQMD) under SCAQMD Rule 1186.92 The use of dry power sweeping shall be prohibited. • The wet power vacuum street sweeper shall be operated on the Terminal 3 property at least twice a day or, as necessary in response to complaints, to control dust in areas where log handling and log processing operations are occurring. • All vehicle speeds within the facility property shall be limited to 15 miles per hour. • Log and bark trucks shall utilize the north gate to access the facility instead of the south gate. Log unloading and handling shall occur north of the southern end of the log deck.

92 Certified Street Sweeper, June 1, 2016, http://www.aqmd.gov/docs/default-source/rule-book/support- documents/rule-1186/certified-street-sweepers-equipment-list.pdf?sfvrsn=2

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• The installation of dust enclosures, curtains, and dust collectors at the debarker is not practical. Any fugitive dust generated by the debarker would be contained, within the building. However, once operation commences, should the operation produce fugitive dust that migrates from the building, the Applicant shall install additional measures to prevent the release of fugitive dust. Dust control shall include, but not limited to, water spray at transfer points, such as stockpiling from conveyors, front-end loading of materials to vehicular transport, bin transfer to vehicular transport, and minimizing drop heights when transferring any mulch/bark materials. • All mulch/bark material stockpiles shall be stored in a green waste trailer that has four walls and an open top. The green waste trailer shall be covered during periods of inactivity. • Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California Airborne Toxics Control Measure Title 13, Section 2485 of California Code of Regulations). Clear signage pertaining to idling time shall be provided for haul trucks at all access points. • All equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. • A publically visible sign shall be posted with the telephone number and person to contact at the Lead Agency regarding dust complaints. This person shall respond and take corrective action with 48 hours. The BAAQMD’s phone number shall also be visible to ensure compliance with applicable regulations. • The Applicant shall plant tree windbreaks along the eastside of the facility in the areas not already shielded by the existing Terminal 3 building.

Mitigation Measure AQ–3: The project applicant shall use shore power to provide electricity to the project-related ships instead of using the auxiliary engines, where/when feasible.

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than 20 total hours over the entire duration of construction activities shall meet the following requirements: • Where access to alternative sources of power are available, portable diesel engines shall be prohibited; and • All off-road equipment shall have: • Engines that meet or exceed either USEPA or CARB Tier 3 off-road emission standards, and • Engines that are retrofitted with a CARB Level 3 Verified Diesel Emissions Control Strategy. Acceptable options for reducing emissions include the use of late model engines, low-emission diesel products, alternative fuels, engine retrofit technology, after-treatment products, add-on devices such as particulate filters, and/or other options as such are available.

Mitigation Measure AQ–6: The project operator shall apply a water mist in the debarking area during cleanup and other operations that produce visible airborne dust.

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of the laboratory results shall be submitted to the City of Richmond Planning and Building Services Department.

Mitigation Measure AQ–8: Personal air monitoring for respirable particulates, not otherwise specified: To determine whether project employees may be exposed to hazardous levels of wood dust, the project operator shall retain the services of a Certified Industrial Hygienist to collect personal (worker exposure) air samples of respirable particulates, not otherwise specified, during normal log debarker operations over the course of an 8-hour work period. The personal air samples shall be collected from the debarker operator and the front-loader operator who is loading and unloading logs from the debarker. The air samples shall be collected with battery-operated air sampling pumps connected to 10-mm nylon cyclone, Higgins- Dewell [HD] cyclone, or Aluminum cyclone in line with tared 5- µm PVC membrane filter. Each air sampling assembly (pump and cassette) shall be operated at an air flow rate of approximately 2.5 liter per minute (lpm) for a duration of approximately 160 minutes, to obtain an air sample volume of approximately 400 liters. Sample cassettes shall be removed and replaced every 160 minutes for the duration of the work shift. Thus, a total of 480 minutes of sampling shall take place in order to determine the employee exposure over the entire shift. All samples and one quality assurance “field blank” shall be analyzed via National Institute of Occupational Safety and Health (NIOSH) Method 600 – Particulates Not Otherwise Regulated - Respirable. Sample analysis shall be conducted by a laboratory accredited by the American Industrial Hygiene Association (AIHA) Laboratory Accreditation Program. A copy of the laboratory results shall be submitted to the City of Richmond Planning and Building Services Department.

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All samples and (1) quality assurance “field blank” per day will be analyzed via National Institute of Occupational Safety and Health (NIOSH) Method 500 – Particulates Not Otherwise Regulated - Total. Sample analysis will be conducted by a laboratory accredited by the American Industrial Hygiene Association (AIHA) Laboratory Accreditation Program.

Geology and Soils Mitigation Measure GS–1: Prior to commencement of project operations, the project sponsor shall prepare and implement a worker training and safety program in accordance with guidelines published by the Occupational Safety and Health Administration (OSHA). The training and safety program shall evaluate all tasks performed by workers, identify all potential hazards, and then develop, implement, and enforce a written safety and health program that meets applicable OSHA standards and addresses these hazards. A comprehensive written occupational safety and health program must be developed for all workers and include training in hazard recognition, avoidance of unsafe conditions, safe performance of assigned tasks, and safe use and maintenance of tools or equipment. Hazards to be addressed should include the potential for rolling logs, worker falls from log stacks, the potential for a front-end loader to tip over, and other hazards associated with operating front-end loaders.

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• Safety procedures shall be established for log handling and movement, including ensuring other employees are not within a safe clearance area around the operations. • Transport vehicles shall be positioned to provide working clearance between the vehicle and the deck. • Only essential personnel shall be allowed in the loading/unloading work area. • No transport vehicle operator shall remain in the truck cab during loading and unloading if logs are moved over the truck cab.

The project sponsor shall ensure that the trainer who provides employee training is qualified through education and/or experience to conduct training.

The site operator shall document the names and dates of employees completing the training program and shall retain the training records on site.

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protection, including steel-toed boots, hard hats, work gloves, and eye protection.

Hydrology and Water Quality Mitigation Measure WQ–1: The project sponsor shall obtain National Pollutant Discharge Elimination System (NPDES) coverage under the Industrial General Permit (IGP) No. CAS000001, adopted by State Water Resources Control Board (SWRCB) Order No. 2014-0057-DWQ. Pursuant to the Order, the project applicant shall electronically file the Permit Registration Documents (PRDs) via the SWRCB’s Storm Water Multiple Application and Report Tracking System (SMARTS) at: https://smarts.waterboards.ca.gov/smarts/faces/ SwSmartsLogin.jsp. The required PRDs include a Notice of Intent (NOI), a risk assessment, site map, signed certification, Stormwater Pollution Prevention Plan (SWPPP), and other site- specific PRDs that may be required. At a minimum the SWPPP shall include a site map, authorized NSWDs at the facility, and an identification and assessment of potential pollutants sources resulting from exposure of industrial activities to stormwater. The SWPPP must clearly describe the Best Management Practices (BMPs) that are being implemented, who is responsible for the BMPs, where the BMPs will be installed, and when and how often the BMPs will be implemented. The PRDs shall be submitted at least seven days prior to commencing discharge.

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CITY OF RICHMOND, CALIFORNIA

Port of Richmond Terminal 3 Log Storage and Shipping Facility

TECHNICAL APPENDICES TO THE INITIAL STUDY

AIR QUALITY AND GREENHOUSE GASES

MARCH 2017

Appendix A-1

Air Quality Setting and Regulatory Context

The project site is located within the San Francisco Bay Area Air Basin (Air Basin), which encompasses Alameda, Contra Costa, Santa Clara, San Francisco, San Mateo, Marin, and Napa Counties, and the southern portions of Solano and Sonoma Counties. The Air Basin is characterized by complex terrain which distorts normal wind flow patterns, consisting of coastal mountain ranges, inland valleys, and bays. Regional Meteorology Air quality is affected by the rate, amount, and location of pollutant emissions and the associated meteorological and geographical conditions that influence pollutant movement and dispersal. Atmospheric conditions, including wind speed, wind direction, stability, and air temperature, in combination with local surface topography (i.e., geographic features such as mountains, valleys, and San Francisco Bay), determine the effect of air pollutant emissions on local air quality. The climate of the greater San Francisco Bay Area, including Richmond, is a Mediterranean- type climate characterized by warm, dry summers and mild, wet winters. The climate is determined largely by a high-pressure system that is often present over the eastern Pacific Ocean off the West Coast of North America. In winter, the Pacific high-pressure system shifts southward, allowing storms to pass through the region. During summer and fall, air emissions generated within the Bay Area can combine with abundant sunshine under the restraining influences of topography and subsidence inversions to create conditions that are favorable to the formation of photochemical pollutants, such as ozone and secondary particulates, such as sulfates and nitrates. The proposed project lies in the Northern Alameda–Western Contra Costa Counties climatological sub-region of the Bay Area. This area stretches 20 miles from the Richmond area through Oakland to San Leandro. Its western boundary is defined by the San Francisco Bay and its eastern boundary by the Oakland-Berkeley Hills. The Oakland-Berkeley Hills are a significant barrier to air flow having an approximate ridge line height of 1500 feet. The most densely populated area of the region is that strip of land between the bay and the 500 foot elevation, where most people live, drive and work. It is a narrow strip of land averaging about four miles in width, with a two mile minimum in the Berkeley and southern Richmond areas and an eight mile maximum at points in the San Leandro and Oakland areas. This area is home to an international airport, major chemical, petroleum, shipping and other industrial operations, a large university, a major military facility (in the process of being decommissioned) and over three quarters of a million people. In this area, marine air intrusion through the Golden Gate, across San Francisco, and through the San Bruno Gap is a dominant weather factor throughout the year. The Oakland-Berkeley Hills causes a bifurcation of westerly flow in the vicinity of Oakland, with southerly winds observed over the San Francisco Bay north of the Golden Gate and north westerlies over the bay to the south of the Golden Gate. The divergent wind field results in diminished speed on the east side of the bay, with a higher frequency of near calm conditions than areas west of this split flow. Richmond, the northern most city of this zone, is ten miles northeast of the Golden Gate. At the Bay Area Air Quality Management District’s (BAAQMD) Point San Pablo meteorological station, 4.5 miles west northwest of downtown Richmond, the prevailing direction is south southwesterly with over 50 percent of the winds coming from the south through southwest sector. The average wind speed at this station is 11 miles per hour (mph). Richmond's maximum summer temperatures average in the low 70's and minimums average in the mid- 50's. In the winter, maximums are in the high 50's to low 60's and minimum are in the low to mid-40's. Precipitation totals near 22 inches annually, on the average.1 Local Air Quality BAAQMD maintains a network of monitoring stations within the Air Basin that monitor air quality and compliance with applicable ambient standards. The monitoring station closest to the project site is in San Pablo, approximately three miles north of the project site; where levels of ozone, particulate matter less than 10 micrometers (PM10), particulate matter less than 2.5 micrometers (PM2.5), carbon monoxide (CO), nitrogen dioxide (NO2), and sulfur dioxide (SO2) are recorded. Table A-1 summarizes the most recent three years of data (2013 through 2015) from the San Pablo air monitoring station. The federal 24-hour PM2.5 standard was exceeded twice in 2013 and once in 2014; and no exceedances occurred in 2015. No other State or federal air quality standards were exceeded during the three-year period. The Bay Area is currently designated “nonattainment” for state and national (1-hour and 8-hour) ozone standards, for the state PM10 standards, and for state and national (annual average and 24-hour) PM2.5 standards. The Bay Area is designated “attainment” or “unclassifiable” with respect to the other ambient air quality standards.

1 Bay Area Air Quality Management District, Climate, Physiography, and Air Pollution Potential – Bay Area and Its Subregions, http://hank.baaqmd.gov/dst/papers/bay_area_climate.pdf Table A–1: Air Quality Data Summary (2013 through 2015) Monitoring Data by Year Pollutant Standarda 2013 2014 2015 Ozone Highest 1 Hour Average (ppm) 0.09 0.074 0.075 0.084 Days over State Standard 0 0 0 Highest 8 Hour Average (ppm) 0.075 0.065 0.060 0.062 Days over National Standard 0 0 0 Nitrogen Dioxide (NO2) Highest 1 Hour Average (ppm) 0.180 0.047 0.052 0.046 Days over State Standard 0 0 0 Annual Average (g/m3) b 0.030/0.053 0.010 0.009 0.009 Carbon Monoxide (CO) Highest 1 Hour Average (ppm) 9.0 2.2 1.8 2.0 Days over State Standard 0 0 0 Highest 8 Hour Average (ppm) 20 1.0 1.0 1.1 Days over State Standard 0 0 0 Coarse Particulate Matter (PM10) Highest 24 Hour Average (g/m3) 50 48 46 43 Days over State Standard 0 0 0 State Annual Average (g/m3) 20 18.4 16.4 18.6 Fine Particulate Matter (PM2.5) Highest 24 Hour Average (g/m3) 35 41.2 38.2 33.2 Days over National Standard 2 1 0 State Annual Average (g/m3) 12 12.0 10.5 8.9 NOTES: Values in bold are in excess of at least one applicable standard. Generally, state standards and national standards are not to be exceeded more than once per year. ppm = parts per million; g/m3 = micrograms per cubic meter. PM10 is not measured every day of the year. Number of estimated days over the standard is based on 365 days per year. PM2.5 monitoring using federally accepted methods did not begin at San Pablo until December 2012. Source: United States Environmental Protection Agency (http://www.epa.gov/air/data) and California Air Resources Board Air Quality Data Statistics (http://www.arb.ca.gov/adam/welcome.html), 2013–2015. The BAAQMD’s Community Air Risk Evaluation (CARE) program was initiated in 2004 to evaluate and reduce health risks associated with exposure to outdoor air toxics in the Bay Area. Based on findings of the latest report, diesel particulate matter (DPM) was found to account for approximately 85 percent of the cancer risk from airborne toxics. Carcinogenic compounds from gasoline-powered cars and light duty trucks were also identified as significant contributors: 1,3- butadiene contributed four percent of the cancer risk-weighted emissions, and benzene contributed three percent. Collectively, five compounds—DPM, 1,3-butadiene, benzene, formaldehyde, and acetaldehyde—were found to be responsible for more than 90 percent of the cancer risk attributed to emissions. All of these compounds are associated with emissions from internal combustion engines. The most important sources of cancer risk-weighted emissions were combustion-related sources of DPM, including on-road mobile sources (31 percent), construction equipment (29 percent), and ships and harbor craft (13 percent). A 75 percent reduction in DPM was predicted between 2005 and 2015 when the inventory accounted for California Air Resources Board (CARB)’s diesel regulations. Overall, cancer risk from toxic air contaminants (TAC) dropped by more than 50 percent between 2005 and 2015, when emissions inputs accounted for state diesel regulations and other reductions.2 Modeled cancer risks from TAC in 2005 were highest near sources of DPM: near core urban areas, along major roadways and freeways, and near maritime shipping terminals. Peak modeled risks were found to be located east of San Francisco, near West Oakland, and the maritime Port of Oakland. BAAQMD has identified seven impacted communities in the Bay Area:  Western Contra Costa County and the cities of Richmond and San Pablo.  Western Alameda County along the Interstate 880 corridor and the cities of Berkeley, Alameda, Oakland, and Hayward.  San Jose.  Eastern side of San Francisco.  Concord.  Vallejo.  Pittsburgh and Antioch. The proposed project is within the city of Richmond, which is part of the seven CARE program impacted communities in the Bay Area. The health impacts in the Bay Area, as determined both by pollution levels and by existing health vulnerabilities in a community, are approximately 160 cancer risk per million persons, while in Richmond, the health impacts is approximately 224 cancer risk per million persons.3 In May of 2016, the Bay Area Air Quality Management District (BAAQMD) published Planning Health Places: A Guidebook for Addressing Local Sources of Air Pollutants in Community Planning.4 The BAAQMD’s primary goal in providing the Guidebook is to support and promote infill development; which is important to reducing vehicle miles traveled and the associated air emissions, while minimizing air pollution exposure for existing and future residents. The Guidebook provides developers and planners with the information and tools needed to create health-protective communities.

2 Bay Area Air Quality Management District, Improving Air Quality & Health in Bay Area Communities, Community Air Risk Program (CARE) Retrospective & Path Forward (2004 – 2013), April 2014. http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CARE%20Program/Documents/CARE_Retro spective_April2014.ashx?la=en 3 Bay Area Air Quality Management District, Identifying Areas with Cumulative Impacts from Air Pollution in the San Francisco Bay Area, March 2014. http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CARE%20Program/Documents/ImpactCom munities_2_Methodology.ashx?la=en 4 Bay Area Air Quality Management District, Planning Health Places: A Guidebook for Addressing Local Sources of Air Pollutants in Community Planning, May 2016. http://www.baaqmd.gov/~/media/files/planning-and- research/planning-healthy-places/draft_planninghealthyplaces_marchworkshop-pdf.pdf?la=en The Planning Health Places Guidebook recommends Best Practices to Reduce Emissions and Reduce Exposure to Local Air Pollution. Implementing as many Best Practices to Reduce Emissions as is feasible will reduce potential health risks to the greatest extent. The Planning Health Places Guidebook also lists examples of a variety of strategies to reduce exposure to, and emissions of, air pollution, including the adoption of air quality-specific ordinances, standard conditions of approval, and incorporation of policies into general plans and other planning documents. The BAAQMD recommends implementing all best practices to reduce exposure that are feasible and applicable to a project in areas that are likely to experience elevated levels of air pollution. To reduce exposure to pollutants, the Guidebook recommends practices like installing indoor air filtration systems, planting dense vegetation, implementing project design which provides a buffer between sensitive receptors and emission source, and developing alternative truck routes. The Planning Health Places Guidebook provides an interactive map of the Bay Area showing areas with estimated elevated levels of fine particulates and/or toxic air contaminants. The interactive map shows locations where further study is needed, such as a detailed health risk assessment; specifically locations next to major roads and freeways and large industrial sites, as well as the downtown districts of cities. The BAAQMD also has existing health risk screening tools that can determine the health impacts for nearby sensitive receptors, such as the Stationary Source Risk & Hazard Analysis Tool for estimating cumulative health risks from permitted stationary sources and the Highway Screening Analysis Tool for estimating cumulative health risks from roadways. Nearby Sensitive Receptors Land uses such as schools, children’s daycare centers, hospitals, and convalescent homes are considered to be more sensitive than the general public to poor air quality because the population groups associated with these uses have increased susceptibility to respiratory distress. Persons engaged in strenuous work or exercise also have increased sensitivity to poor air quality. The CARB has identified the following people as most likely to be affected by air pollution: children less than 14 years of age, the elderly over 65 years of age, athletes, and those with cardiovascular and chronic respiratory diseases. These groups are classified as sensitive population groups. Residential areas are considered more sensitive to air quality conditions than commercial and industrial areas, because people generally spend longer periods of time at their residences, resulting in greater exposure to ambient air quality conditions. Recreational uses are also considered sensitive, due to the greater exposure to ambient air quality conditions and because the presence of pollution detracts from the recreational experience. According to the BAAQMD, workers are not considered sensitive receptors because all employers must follow regulations set forth by the Occupation Safety and Health Administration to ensure the health and well- being of their employees. Terminal 3 is located on the west side of a small peninsula on the southern Richmond shoreline that is defined by Harbor Channel and Santa Fe Channel on the west and by Marina Bay, which harbors the Richmond Yacht Club, on the east. West of the Ford Assembly Building are a large vacant parcel adjacent to the shoreline and a large office building that previously housed municipal offices for the City of Richmond and is now partially used by Comcast. To the east of this building, on the east side of Marina Way South, are offices leased by Chevron and West Contra Costa Unified School District. Other uses occupying the buildings include Amethod Charter School and Babbaloo Cafe. Lucretia Edwards Shoreline Park is located on the southeast corner of the peninsula. BAAQMD considers the relevant zone of influence for an assessment of air quality health risks to be within 1,000 feet of a project site. The project site is bounded by Harbour Way South to the east. East of Harbour Way South is the historic Ford Assembly Building, housing a National Historic Park, offices, Craneway Pavilion, and a 45,000-square-foot space available for a wide range of public events. To the north is Terminal 2, another Port of Richmond property occupying approximately eight acres and to the south is a portion of Terminal 3, which is leased separately and used for temporary storage of automobiles. The site is located on the east side of Harbor Channel, adjacent to the Richmond Inner Harbor on San Francisco Bay. The proposed project is approximately 3,500 feet (0.7 miles) south of Interstate 580. Sensitive receptors include the Ford Assembly Building, residences near Marina Park and Vincent Park (to the east), and recreational use at Lucretia Edwards Park and Vincent Park. The Benito Juarez Elementary School (at 1450 Marina Way South) is located approximately 1,350 feet to the southeast of the project site, outside of the 1,000-foot radius recommended by BAAQMD.

Air Quality Significance Thresholds

The significance of potential impacts was determined based on State CEQA Guidelines, Appendix G, and the BAAQMD CEQA Air Quality Guidelines. Using Appendix G evaluation thresholds, the proposed project would be considered to have significant air quality impacts if it were to: A. Conflict with or obstruct implementation of the applicable air quality plan; B. Violate any air quality standard or contribute substantially to an existing or projected air quality violation; C. Expose sensitive receptors to substantial pollutant concentrations; D. Create objectionable odors affecting a substantial number of people; or E. Result in a cumulatively considerable net increase of any nonattainment pollutant, and/or health impacts (including releasing emissions that exceed quantitative thresholds for ozone precursors). The air quality analysis follows the methodology presented in the recent CEQA Guidelines released by the BAAQMD in May 2012. However, since the May 2012 CEQA Air Quality Guidelines do not provide specific significance thresholds, the thresholds and methodologies from the BAAQMD’s 2011 CEQA Air Quality Guidelines were used to evaluate the potential impacts of remediation activities. The thresholds of significance applied to assess project-level air quality impacts are:  Average daily construction exhaust emissions of 54 pounds per day of ROG, NOx, or PM2.5 or 82 pounds per day of PM10;

 Average daily operation emissions of 54 pounds per day of ROG, NOx, or PM2.5 or 82 pounds per day of PM10; or result in maximum annual emissions of 10 tons per year of ROG, NOx, or PM2.5 or 15 tons per year of PM10;  Exposure of persons by siting a new source or a new sensitive receptor to substantial levels of TAC resulting in (a) a cancer risk level greater than 10 in one million, (b) a noncancerous risk (chronic or acute) hazard index greater than 1.0, or (c) an increase of annual average PM2.5 of greater than 0.3 micrograms per cubic meter (µg/m3). For this threshold, sensitive receptors include residential uses, schools, parks, daycare centers, nursing homes, and medical centers; or  Frequently and for a substantial duration, create or expose sensitive receptors to substantial objectionable odors affecting a substantial number of people. Assessment of a significant cumulative impact if it would result in:  Exposure of persons, by siting a new source or a new sensitive receptor, to substantial levels of TAC during either construction or operation resulting in (a) a cancer risk level greater than 100 in a million, (b) a noncancer risk (chronic or acute) hazard index greater than 10.0, or (c) annual average PM2.5 of greater than 0.8 µg/m3. The BAAQMD air quality significance thresholds are found in Table A-2.

For projects that are considered new sources of TAC or PM2.5 (such as construction activity, stationary sources, industrial sources, or roadway projects), it is generally appropriate to use both the project-level and cumulative-level thresholds because the project-level threshold identifies project’s incremental contribution to health impacts, while the cumulative threshold assesses project’s cumulative contribution to health impacts. However, for projects that consist of new receptors (such as proposed residences or schools), it is generally appropriate to use only the cumulative-level threshold because the project itself is not a source of TAC or PM2.5 and, thus, the individual project-level threshold is not relevant. Therefore, the proposed project, which does not include new receptors, was compared to both the project-level and cumulative- level thresholds. The BAAQMD CEQA Air Quality Guidelines identify a project-specific threshold of either 1,100 metric tons of CO2e per year or 4.6 metric tons of CO2e per year per service population (i.e., the number of residents plus the number of employees associated with a new development), which is also considered a cumulatively considerable contribution to the global GHG burden and, therefore, a significant cumulative impact. This analysis applies the 1,100 metric tons of CO2e per year significance criterion to the proposed project GHG emissions. Table A–2: BAAQMD Air Quality Significance Thresholds Daily Daily Annual Pollutant Construction Operational Operational Thresholds Thresholds Thresholds Criteria Air Pollutants Reactive Organic Compounds (ROG) 54 54 10 Nitrogen Oxides (NOx) 54 54 10 Coarse Particulate matter (PM10) 82 82 15 Fine Particulate Matter (PM2.5) 54 54 10 Carbon Monoxide (CO) NA 9.0 ppm (8-hour) and 20.0 ppm (1-hour) Fugitive Dust Best Management NA Practices Project Health Risk and Hazards Excess Cancer Risk 10 per million 10 per million Chronic Hazard Index 1.0 1.0 Acute Hazard Index 1.0 1.0

Incremental Annual Average PM2.5 0.3 µg/m3 0.3 µg/m3 Cumulative Health Risk and Hazards Excess Cancer Risk 100 per million 100 per million Chronic Hazard Index 10.0 10.0 Acute Hazard Index 10.0 10.0

Incremental Annual Average PM2.5 0.8 µg/m3 0.8 µg/m3 Greenhouse Gas Emissions Annual Emissions 1,100 metric tons or 4.6 metric tons per capita SOURCE: Bay Area Air Quality Management District, Adopted Air Quality CEQA Thresholds of Significance - June 2, 2010, http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CEQA/Summary_Table_Proposed_BAAQMD _CEQA_Thresholds_May_3_2010.ashx?la=en Regulatory Contest The USEPA is responsible for implementing a myriad of regulations and programs established under the federal Clean Air Act (CAA), such as establishing and reviewing the National Ambient Air Quality Standards (NAAQS) and judging the adequacy of State Implementation Plans (SIP). However, USEPA has delegated the authority to implement many of the federal programs to individual states, while retaining an oversight role to ensure that the programs continue to be implemented. The CARB is responsible for establishing and reviewing California’s air quality standards, compiling the California SIP, securing approval of this plan from USEPA, and identifying toxic air contaminants. CARB also regulates mobile emissions sources in California, such as construction equipment, ships, trains, trucks, and automobiles, and oversees the activities of air quality management districts, which are organized at the county and/or regional level. Local councils of governments, county transportation agencies, cities and counties, and various non–governmental organizations also join in the efforts to improve air quality through a variety of programs. These programs include the adoption of regulations and policies, as well as implementation of extensive education and public outreach programs. The BAAQMD is the CARB-appointed regional agency with jurisdiction over the Port of Richmond. The BAAQMD is responsible for bringing the area into compliance and/or maintaining air quality within federal and State air quality standards. This includes the responsibility to monitor ambient (i.e. “outdoor”) air pollutant levels and to develop and implement attainment strategies to ensure that future emissions are within federal and State standards. A number of regulations and rules promulgated by CARB and other agencies with direct application of emission sources within ports, in general, and the Port of Richmond, specifically, are discussed within the following:

Fuel Sulfur and Other Operational Requirements for Ocean-going Vessels within California Waters and 24 Nautical miles of the California Baseline (CCR, Title 13, Section 2299.2) Adopted by CARB in 2008, this regulation requires the use of low sulfur marine distillate fuels in order to reduce emissions of PM, DPM, nitrogen dioxides (NOX) and sulfur oxides (SOX) from the use of auxiliary diesel and diesel-electric engines, main propulsion diesel engines, and auxiliary boilers on ocean-going vessels within any regulated California waters. This rule, which became effective on July 1, 2009, limits fuel sulfur content for auxiliary and main diesel engines to 1.5 percent by weight for marine gas oil and 0.5 percent by weight for marine diesel oil. In addition, by January 1, 2012, fuel sulfur content for auxiliary and main diesel engines shall be limited to 0.1 percent by weight for both marine gas oil and marine diesel oil. On December 22, 2009, USEPA announced final emission standards under the Clean Air Act for new marine diesel engines with per-cylinder displacement at or above 30 liters (called Category 3 marine diesel engines) installed on U.S.-flagged vessels. The final engine standards are equivalent to those adopted in the amendments to Annex VI to the International Convention for the Prevention of Pollution from Ships. The emission standards apply in two stages: near-term standards for newly-built engines will apply beginning in 2011, and long-term standards requiring an 80 percent reduction in NOX began in 2016. On March 26, 2010, the International Maritime Organization officially designated waters off North American coasts as an area in which stringent international emission standards will apply to ships. These standards will dramatically reduce air pollution from ships and deliver substantial air quality and public health benefits that extend hundreds of miles inland.

Airborne Toxic Control Measure for Auxiliary Diesel Engines Operated on Ocean-Going Vessels At-Berth in a California Port (CCR, Title 17, Section 93118.3)

This regulation is aimed at reducing NOX and DPM emissions from auxiliary engines on container vessels, passenger vessels, and refrigerated cargo vessels by limiting their operation while they are docked at berth at a California port. It will reduce emissions by limiting the time that auxiliary diesel engines are operated on the regulated vessels while such vessels are docked at-berth in a California port, as well as by applying other requirements. This section implements provisions of the Goods Movement Emission Reduction Plan, adopted by CARB in April 2006, to reduce emissions and health risk from ports and the movement of goods in California, and also helps achieve the goals specified in the California Global Warming Solutions Act of 2006, established under California law by Assembly Bill 32. The regulation provides vessel fleet operators visiting these ports two options to reduce at-berth emissions from auxiliary engines: 1) turn off auxiliary engines while in port and connect the vessel to some other source of power (i.e., grid-based shore power); or 2) use alternative control technique(s) that achieve equivalent emission reductions.

Airborne Toxic Control Measure for Commercial Harbor Craft

The purpose of this regulation is to reduce DPM, SOX, and NOX from diesel propulsion and auxiliary engines on harbor craft operating in any regulated California waters. This section implements provisions of the Goods Movement Emission Reduction Plan, adopted by CARB in April 2006, to reduce emissions and health risk from ports and the movement of goods in California. On February 16, 2010, CARB staff drafted amendments to the California’s Commercial Harbor craft Regulation which add in-use engine requirements for diesel engines on dredges, barges, and crew and supply boats that operate in regulated California waters. At its June 24, 2010 public hearing, CARB approved the adoption of amendments to Title 17, CCR section 93118.5 (the Commercial Harbor Craft Regulation), and to title 13, CCR section 2299.5. These amendments are intended to further reduce emissions of DPM and NOx from diesel engines on commercial harbor craft operating within any of the regulated California waters.

California’s Drayage Truck Regulation (CCR, Title 13, Section 2027)

CARB adopted this measure in 2008 to reduce public exposure to DPM emissions, NOX, and other air contaminants by setting emission standards for in-use, heavy-duty diesel-fueled vehicles that transport cargo to and from California’s ports and intermodal rail facilities. Section 2027’s definition of port specifically includes Port of Richmond. This regulation requires all drayage trucks that operate at California’s ports and intermodal rail yards to meet the following requirements: 1. By December 31, 2009, all drayage trucks must be equipped with: o 1994–2003 model year engines certified to California or federal emissions standards and a level 3 Verified Diesel Emission Control Strategy for PM emissions; o a 2004 or newer model year engine certified to California or federal emission standards; or o a 1994 or newer model year engine that meets or exceeds 2007 year California or federal emission standards. 2. After December 31, 2011, all drayage trucks with 2004 model year engines must be equipped with the highest level of Verified Diesel Emission Control Strategy for PM emissions. 3. After December 31, 2012, all drayage trucks with 2005 and 2006 model year engines must be equipped with the highest level Verified Diesel Emission Control Strategy for PM emissions. 4. After December 31, 2013, all drayage trucks must be equipped with a 1994 or newer model year engine that meets or exceeds 2007 model year California or federal emission standards.

Mobile Cargo Handling Equipment at Ports and Intermodal Rail Yards The purpose of this regulation is to reduce DPM and criteria pollutant emissions from compression ignition (CI) mobile cargo handling equipment in operation at California ports and intermodal rail yards. With certain exemptions, the regulation applies to any person who conducts business in California who sells, offers for sale, leases, rents, purchases, owns or operates any CI mobile cargo handling equipment that operates at any California port or intermodal rail yard. The Office of Administrative Law approved amendments to the Cargo Handling Equipment Regulation, effective December 3, 2009. The amendments exempt sweepers and mobile cranes (other than rubber-tired gantry cranes) from the Cargo Handling Equipment Regulation, placing them under either the In-Use Off-Road Diesel Vehicle Regulation or the In-Use Heavy-Duty Diesel Vehicle Regulation (On-Road Truck and Bus Regulation), depending on the engine configuration.

Heavy-Duty Vehicle Idling Emission Reduction Program Under this rule, 2008 and newer model year heavy-duty diesel engines must either be equipped with a non-programmable engine shutdown system that automatically shuts down the engine after five minutes of idling, or optionally meet a stringent NOX idling emission standard. The in- use truck requirements require operators of both in-state and out-of-state registered sleeper berth equipped trucks to manually shut down their engine when idling more than five minutes at any location within California.

General Requirements for In-Use Off-Road Diesel Fueled Fleets (CCR, Title 13, Section 2449)

Adopted in July 26, 2007, this regulation is intended to reduce emissions of DPM and NOX from in-use off-road diesel vehicles operating in California. CARB estimates the regulation will significantly reduce DPM and NOX emissions from the nearly 180,000 off-road diesel vehicles that operate in California, which is necessary to meet state and federal air quality standards. The regulation requires fleet owners to accelerate turnover to cleaner engines and install exhaust retrofits.5 The regulation also supports the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles, which was adopted by the Board on September 30, 2000. It should be noted that on April 22, 2010, CARB met to consider relaxing certain deadline requirements of CCR, Title 13, Section 2449 for diesel trucks and construction equipment to account for the slumping economy and inaccurate emissions projections.

5 The regulation establishes fleet average emission rates for PM and NOX that decline over time. Each year, the regulation requires each fleet to meet the fleet average emission rate targets for PM or apply the highest level verified diesel emission control system to 20 percent of its horsepower. In addition, large and medium fleets are required each year to meet the fleet average emission rate targets for NOX or to turn over a certain percent of their horsepower (8 percent in early years, and 10 percent in later years). “Turn over” means repowering with a cleaner engine, rebuilding the engine to a more stringent emissions configuration, retiring a vehicle, replacing a vehicle with a new or used piece, or designating a dirty vehicle as a low-use vehicle. If retrofits that reduce NOX emissions become available, they may be used in lieu of turnover as long as they achieve the same emission benefits. At its December 2010 hearing, CARB adopted amendments that staff estimated would reduce compliance costs by more than 95 percent during the first five years and more than 70 percent during the entire span of the regulation, compared to the regulation before the amendments. The December 2010 amendments included: 1. A four year delay from the original timeline for all fleets, making the first compliance deadline January 1, 2014, for large fleets (over 5,000 hp), January 1, 2017, for medium fleets (2,501-5,000 hp), and January 1, 2019, for small fleets (2,500 hp or less). 2. A dramatic reduction and simplification in the annual requirements for fleets, and fleet average structure. Fleets now have only one fleet average target to meet based on their NOx emissions; if they cannot meet the fleet average target, they are required to clean up 5 to 10 percent of their horsepower annually, as opposed to the previous requirement of 28 to 30 percent. 3. Making exhaust retrofits no longer mandatory. 4. Raising the low use threshold to 200 hours per year instead of 100 hours.

On-Road Heavy-Duty Diesel Vehicles (In-Use) In addition, on December 12, 2008, CARB approved a new regulation, the On-Road Heavy-Duty Diesel Vehicles (In-Use) Regulation, to substantially reduce emissions from existing on-road diesel vehicles operating in California. The regulation requires affected trucks to meet performance requirements between 2011 and 2023. By January 1, 2023 all vehicles must have a 2010 model year engine or equivalent; this includes on-road heavy-duty diesel fueled vehicles with a gross vehicle weight rating greater than 14,000 pounds.6

Off-Road Large Spark-Ignition (Gasoline and Propane) Equipment On May 25, 2006, CARB amended the existing emission standards and test procedures for offroad large spark-ignition (LSI) engine powered equipment, Off-Road Large Spark-Ignition (Gasoline and Propane) Equipment Regulation, to make them more stringent. The CARB also adopted new regulations requiring emission reductions from existing LSI fleets and prescribing verification procedures for LSI retrofit emission control systems. The new engine emission standards apply to manufacturers of any 25 horsepower or greater off-road LSI engine placed in, but not limited to, ground support equipment (GSE), forklifts, generator sets,

6 In general, the regulation requires owners to reduce emissions in their fleet by upgrading existing vehicles one of three ways. The first option is to install PM retrofits and replace vehicles (or engines) according to a prescribed schedule based on the existing engine model year. The second option is to retrofit a minimum number of engines each year with a high level PM exhaust retrofit and to replace a minimum number of older engines with newer engines meeting the 2010 new engine standards. The third option is to meet a fleet average. With this option, a fleet operator can use PM and NOX emission factors established by the regulation to calculate the average emissions of the fleet. Then, by the applicable compliance date each year, the owner can demonstrate that the fleet average emissions for PM and NOX do not exceed the PM and NOX fleet average emission rate targets set by the regulation. sweeper/scrubbers, industrial tugs (tow tractors), and turf care equipment. The fleet requirements only apply to forklifts, sweepers/scrubbers, industrial tow tractors, and GSE.7

California Low Sulfur Diesel Regulations In July 2003, CARB promulgated amendments to existing fuel regulations (section 2281 – sulfur content, section 2282 – aromatic hydrocarbon content, and section 2284 – lubricity) stating that diesel fueled equipment and vehicles would reduce fuel sulfur content from 500 to 15 ppmw beginning in 2006. To ensure compliance with the federal regulations, CARB will allow use of emissions control technologies on model year 2007 and later heavy duty engines and vehicles. To prevent excessive engine wear that would occur due to the reduction in fuel sulfur, CARB has also modified existing fuel lubricity standards, requiring that high frequency reciprocating engine rigs are not to possess wear scars greater than 520 microns in diameter due to low sulfur diesel fuel use.

Standards for Nonvehicular Diesel Fuel Used in Diesel-Electric Intrastate Locomotives and Harbor Craft (CCR Title 13, Section 2299) CARB defines “intrastate locomotives” as those “operat[ing] within California for which at least 90 percent of [the] annual fuel consumption, annual hours of operation, or annual rail miles traveled occur within California. This definition would typically include, but not be limited to, diesel-electric locomotives used in the following operations: passenger intercity and commuter, short haul, short line, switch, industrial, port and terminal operations.” The regulation requires that all nonvehicular diesel fuel sold and supplied for use in intrastate locomotives satisfy the requirements established for sulfur content (section 2281), aromatic hydrocarbon content (section 2282) and lubricity (section 2284), treated as if it were vehicular diesel fuel. Notably, these requirements also apply to fuel supplied to harbor craft typically operating in the Port of Richmond.

7 The regulation establishes more stringent combined HC and NOX emission certification standards for engine manufacturers. The regulation also establishes verification procedures for manufacturers of retrofit emission control systems. Engine and retrofit emission control system manufacturers will likely employ advanced automotive-style emission control technologies including electronic fuel/air controllers, three-way catalysts, and oxygen sensors to meet the certification and verification standards, respectively. Appendix A-2 Air Quality Calculation Assumptions and Methodologies Air quality calculations were made for combustion sources such as on-road vehicles from employees and haul (bark and log) trucks as well as onsite combustion equipment such as loaders and excavators. Air quality calculations were also made for marine vessels and harbor craft. Marine vessel emissions include operation of the main engines, the auxiliary engines, and the auxiliary boilers. This air quality analysis focuses on daily and annual emissions from the proposed project operations (onsite equipment, marine vessels, haul trucks, and worker automobiles). This air quality analysis is consistent with the methods described in the Bay Area Air Quality Management District (BAAQMD) CEQA Air Quality Guidelines (dated June 2010, updated in May 2011, and revised in May 2012).1

The air quality analysis includes a review of criteria pollutant2 emissions such as carbon 3 monoxide (CO) , nitrogen oxides (NOx), sulfur dioxide (SO2), volatile organic compounds 4 (VOC) as reactive organic gases (ROG) , particulate matter less than 10 micrometers (PM10), 5 particulate matter less than 2.5 micrometers (PM2.5). Regulatory models used to estimate air quality impacts include:

 California Air Resources Board’s (CARB) EMFAC20146emissions inventory model. EMFAC is the latest emission inventory model that calculates emission inventories and emission rates for motor vehicles operating on roads in California. This model reflects CARB’s current understanding of how vehicles travel and how much they emit. EMFAC

1 The Air District’s June 2010 adopted thresholds of significance were challenged in a lawsuit. Although the BAAQMD’s adoption of significance thresholds for air quality analysis has been subject to judicial actions, the lead agency has determined that BAAQMD’s Revised Draft Options and Justification Report (October 2009) provide substantial evidence to support the BAAQMD recommended thresholds. Therefore, the lead agency has determined the BAAQMD recommended thresholds are appropriate for use in this analysis. 2 Criteria air pollutants refer to those air pollutants for which the United States Environmental Protection Agency (USEPA) and California Air Resources Board (CARB) has established National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS) under the Federal Clean Air Act (CAA). 3 CO is a non–reactive pollutant that is a product of incomplete combustion of organic material, and is mostly associated with motor vehicle traffic, and in wintertime, with wood–burning stoves and fireplaces. 4 VOC means any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, which participates in atmospheric photochemical reactions and thus, a precursor of ozone formation. ROG are any reactive compounds of carbon, excluding methane, CO, CO2, carbonic acid, metallic carbides or carbonates, ammonium carbonate, and other exempt compounds. The terms VOC and ROG are often used interchangeably. 5 PM10 and PM2.5 consists of airborne particles that measure 10 micrometers or less in diameter and 2.5 micrometers or less in diameter, respectively. PM10 and PM2.5 represent fractions of particulate matter that can be inhaled into the air passages and the lungs, causing adverse health effects. 6 California Air Resources Board, EMFAC User’s Guide, December 30, 2014, http://www.arb.ca.gov/msei/emfac2014_users_guide.pdf can be used to show how California motor vehicle emissions have changed over time and are projected to change in the future.

 CARB OFFROAD7 emissions inventory model. OFFROAD is the latest emission inventory model that calculates emission inventories and emission rates for off-road equipment such as loaders, excavators, and off-road haul trucks operating in California. This model reflects CARB’s current understanding of how equipment operates and how much they emit. OFFROAD can be used to show how California off-road equipment emissions have changed over time and are projected to change in the future.  AERMOD (American Meteorological Society/USEPA Regulatory Model, Version 15181) is an atmospheric dispersion model which can simulate point, area, volume, and line emissions sources and has the capability to include simple, intermediate, and complex terrain along with meteorological conditions and multiple receptor locations.8,9 AERMOD is commonly executed to yield 1-hour maximum and annual average concentrations (in µg/m3) at each receptor. On-Road Vehicles

Vehicular emissions were computed using the CARB’s emission factor model, EMFAC2014, to estimate on-road emissions. Employee trips were modeled using the light-duty auto classification with aggregate speeds. The proposed project would include a maximum of 21 employees during periodic ship-loading operations. Trip distance was calculated using EMFAC’s vehicle miles traveled (VMT) and trip frequency data from for light-duty auto classifications in the BAAQMD. Trip distance was calculated to be approximately six miles per trip and each employee was assumed to make four trips per workday. Employee trips were assumed to be a composite of gasoline and diesel vehicles. Log trucks were modeled using the T7 classification, which is a heavy-heavy duty truck emission factor for haul trucks. The T7 classification has a number of different subcategories for different haul truck applications. T7 tractor truck) was the best subcategory that fit the description of log trucks. Brake wear and tire wear particulate emissions were also accounted for and included in the analysis using EMFAC2014 factors. The air quality analysis assumed ten logging truck round trips per day and 1,600 round trips per year for the proposed project. Log truck trips were assumed to begin in West Sacramento, which is within the Yolo-Solano Air Quality Management District (YSAQMD). Approximately half way to the proposed facility, logging trucks would cross over into the BAAQMD. Log truck trip lengths were estimated to be 148 miles per round trip (80 miles within BAAQMD and 68

7 California Air Resources Board, OFFROAD Instructions, http://www.arb.ca.gov/msprog/ordiesel/info_1085/oei_write_up.pdf 8 USEPA Preferred/Recommended Models, AERMOD Modeling System, http://www.epa.gov/ttn/scram/dispersion_prefrec.htm#aermod. 9 Title 40 CFR Part 51, Revision to the Guideline on Air Quality Models: Adoption of a Preferred General Purpose (Flat and Complex Terrain) Dispersion Model and Other Revisions; Final Rule, http://www.epa.gov/ttn/scram/guidance/guide/appw_05.pdf. miles within YSAQMD). Idling emissions were calculated using idling emissions factors from EMFAC2014 and log trucks were assumed to idle for a maximum of five minutes per CARB regulations.10 Log (or tractor) trucks are limited to a total permit weight (truck and load) of 80,000 pounds. An empty tractor truck is approximately 25,000 pounds. Thus, the log load is limited to 55,000 pounds. The number of logs per truck would vary from five to 30, depending on diameter of the logs. An average load of 20 logs per truck trip equates to 2,750 pounds per log.11 At 14 truck trips per day, the total daily truck transport would be 550,000 pounds (or 200 logs). Based on 160 days of operation, the total annual truck transport would be 88,000,000 pounds (or 32,000 logs). Bark trucks were also modeled using the T7 tractor truck classification. Brake wear and tire wear particulate emissions were also accounted for and included in the analysis using EMFAC2014 emission factors. The air quality analysis assumed a maximum of two round trips per weekday and 64 round trips per year for the proposed project. Bark trucks were assumed to begin in Tracy, pick up from the proposed project, and drop off in Milpitas. Bark truck trip lengths were estimated to be 113 miles per round trip. Idling emissions were calculated using idling emissions factors from EMFAC2014 and log trucks were assumed to idle for a maximum of five minutes per CARB regulations. Emissions calculations were based on Equation 1. The EMFAC2014 emissions factors are summarized on Table A-3 for employee vehicles, haul trucks, and truck idling. Equation 1

Emission Rate (tons/year) = EMFAC Emission Factor (gram/mile) * trips per day * miles per trip * days/year * (453.59/2000 tons/gram)

Emission Rate (tons/year) = EMFAC Emission Factor (gram/hour) * total idle hours * (453.59/2000 tons/gram)

10 California Air Resources Board, Heavy-Duty Vehicle Idling Emission Reduction Program, http://www.arb.ca.gov/msprog/truck-idling/truck-idling.htm 11 A 50-foot pine tree with a 12 inch diameter, http://temporaryrepair.com/blog/2013/9/19/how-much-does-a-tree- weight Table A-3: On-Road Vehicle Emission Factors (gram/mile and gram/hour)

Condition ROG CO NOx CO2 PM10 PM2.5 Employee Vehicles 0.05 0.76 0.24 285 0.02 0.02 Bark Trucks 0.28 0.98 7.07 1,678 0.08 0.08 Bark Trucks (idle) 0.05 0.21 1.44 195 <0.01 <0.01 Log Trucks 0.24 0.76 7.68 1,736 0.04 0.04 Log Trucks (idle) 0.06 0.24 1.71 239 0.00 0.00 Source: CARB EMFAC. CO = carbon monoxide; NOX = oxides of nitrogen; PM10 = particulate matter with diameter equal to or less than 10 micrometers; PM2.5 = particulate matter with diameter equal to or less than 2.5 micrometers; ROG = reactive organic gas; CO2 = carbon dioxide

Table A-4 provides the expected log truck fleet mix. The emissions associated with log truck trips were based on a CARB Truck and Bus Regulation Reporting inventory for RJJ International, which includes a total of nine logging trucks of varying model years from 2008, 2010, and 2011.

Table A-4: Log Truck Fleet Mix

Model Make Year License # Volvo 2011 9F32617 Volvo 2011 9E94759 Volvo 2011 9F34600 Volvo 2010 9E36634 International 2010 9D46796 Volvo 2010 WP39116 Volvo 2008 9E91037 Volvo 2008 9D46791 Volvo 2008 9E37404 Source: Email titled Terminal 3 log facility questions from Dennis Shen RJJ Resource to Lina Velasco City of Richmond, dated January 6, 2017. Onsite Off-Road Equipment

Logs arriving with bark still on would also be weighed upon arrival at Terminal 3. They would then be unloaded by a front loader equipped with claws and stacked at the Log Layout Area. When sufficient logs have been accumulated, staff would use front loaders to move the logs into the north end of the large shed where a conveyor would feed them into a 43-inch electric-power Salem debarker that would mechanically strip the bark. Removed bark would be discharged into a debris container that would be regularly emptied. A street sweeper would clean the site daily to keep it free of debris and to control dust. Operational equipment at the proposed facility would include two excavators (one 204 horsepower [hp] and one 162 hp), a 267 hp front loader with claws, and a street sweeper. All equipment would meet the current requirements of CARB for marine cargo handling equipment, which require Tier 4 engines and annual opacity testing of particulate matter in the diesel exhaust. Emission factors from the OFFROAD model and Tier 4 emission standards were used. Equipment load factors (percent of full throttle) were adjusted using the latest information in the OFFROAD emissions model. Emission parameters for off-road equipment, including equipment and fuel type, estimated horsepower and estimated annual hours of operation, were developed. Hours of off-road equipment operation were based on normal business hours of 12 hours per day (6 a.m. to 6 p.m.), five days per week, and 160 days per year. This information was applied to criteria pollutant emissions factors, in grams per horsepower- hour, primarily derived using the CARB OFFROAD emissions model (i.e., the Offroad Emissions Inventory [OEI] Database).12 Equation 2 outlines how off-road offroad equipment emissions were computed, and the emissions factors used in this assessment are summarized, by equipment type, on Table A-5. Equation 2

Emission Rate (tons/year) = OFFROAD Emission Factor (gram/hp-hour) * size (hp) * hours of operation * Load Factor * (453.59/2000 tons/gram) Table A-5: Offroad Equipment Emission Factors (gram/hp-hour)

Equipment ROG CO NOx CO2 PM10 PM2.5 Excavator 0.14 2.60 0.30 512 0.02 0.01 Loader 0.14 2.60 0.30 512 0.02 0.01 Sweeper/Washer 0.14 3.70 0.30 514 0.02 0.01 Source: California Air Resources Board, OFFROAD. CO = carbon monoxide; NOX = oxides of nitrogen; PM10 = particulate matter with diameter equal to or less than 10 micrometers; PM2.5 = particulate matter with diameter equal to or less than 2.5 micrometers; ROG = reactive organic gas; CO2 = carbon dioxide

Marine Vessels

Log export shipments would occur during the timber harvesting season in California, which starts in April and continues through November. With six shipments anticipated each year, there would be one shipment every five weeks. While in dock, the ships would not be equipped to use shoreline electrical power and the ship’s auxiliary engines would be required during hoteling at the berth. It would take up to ten days to load a ship. Processed logs would be stacked in the Debarked Logs Deck area by an excavator. Once a sufficient quantity of processed logs has accumulated in the Debarked Logs Deck area, they would be loaded into a Handymax class vessel for shipment to China. Handymax vessels carry dry bulk goods and are typically between 492 and 656 feet long, with a capacity of 40,000 to 50,000 deadweight tons (DWT). The ships would be loaded by unionized longshoremen using ship-board cranes.13 It would take up to ten days to load a ship. Given the annual number of

12 California Air Resources Board, OFFROAD Emissions Model, http://www.arb.ca.gov/msei/categories.htm#offroad_motor_vehicles 13 The crane is driven by an operator who sits in a cabin suspended from the trolley. The trolley runs along rails located on the top or sides of the boom and girder. The operator runs the trolley over the ship to lift the cargo, ships would be six, each bulk carrier would be expected to transport 14,700,000 pounds of logs (or 7,300 logs). The total annual transport would be 88,000,000 pounds (or 32,000 logs). USEPA’s Current Methodologies in Preparing Mobile Source Port-Related Emissions and other guidance was used to estimate emissions from marine vessel operations.14 For bulk carrier marine vessels, emission factors were developed by review of the literature and information specific to the proposed project. Emissions were calculated by multiplying the emission factors by vessel-specific activity parameters such as in-use horsepower and hours of operation. Calculations were made to adequately characterize the complicated activities of marine vessels (e.g., separate calculations were made for vessel transit and maneuvering activities for propulsion engines, auxiliary engines, and auxiliary boilers). Hotelling activities were assumed because the vessels would not be equipped to connect to shoreline power and the ship’s auxiliary engines would be required during hoteling at the berth. The results of all the calculations were summed to produce the overall emission estimates. In developing an activity-based emissions inventory for bulk carriers, emissions were estimated as a function of vessel power demand (expressed in kW-hours) multiplied by an emission factor, where the emission factor is expressed in terms of grams per kilowatt-hour (g/kW-hr). PM2.5 was estimated to be 80 percent of PM10. 15 The emission factor is dependent on the fuel used; an average sulfur content of 0.3 percent (residual oil) was assumed.16 Main engine emission factors (Table A-6) were then applied to the various activity data (Table A-7). A main engine of 8,000 kilowatts was assumed. 17 All our vessels are single screw and main engine rating is from 5005 kilowatts (Imabari 28) to 8058 kilowatts (Supramax).

usually containers. Once the spreader locks onto the container, the container is lifted, moved over the dock, and placed on a truck chassis (trailer) to be taken to the storage yard. The crane also lifts containers from chassis on the dock to load them onto the ship. Generally, a crane can be powered by two types of power supply: a diesel engine– driven generator located on top of the crane or electric power from the dock. In this case, the crane is powered by the ship’s auxiliary engines. 14 United States Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emissions, April 2009, http://trid.trb.org/view.aspx?id=927750, Emissions Estimation Methodology for Ocean-Going Vessels, May 2008, http://www.arb.ca.gov/regact/2008/fuelogv08/appdfuel.pdf, and Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, http://www3.epa.gov/otaq/models/nonrdmdl/c- marine/r00002.pdf 15 Starcrest Consulting Group, LLC, Port of Long Beach Air Emissions Inventory – 2014, September 2015, http://www.polb.com/environment/air/emissions.asp 16 California Air Resources Board, Fuel Sulfur and Other Operation Requirements for Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline, July 24, 2008, http://www.arb.ca.gov/ports/marinevess/ogv.htm 17 Starcrest Consulting Group, LLC, Port of Long Beach Air Emissions Inventory – 2014, September 2015, http://www.polb.com/environment/air/emissions.asp Table A-6: Emission Factors for Main Engines

Cruise Emission Factor Slow Cruise Emission Factor Maneuvering Emission Factor Pollutant (g/kW-hr) (g/kW-hr) (g/kW-hr) CO 1.10 1.10 1.10 HC 0.50 0.50 0.50 NOx 13.2 13.2 13.2 PM10/PM2.5 0.25/0.23 0.25/0.23 0.25/0.23 SO2 1.2 1.2 1.2 CO2 646 646 646 SOURCES: United States Environmental Protection Agency, Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009, and Emissions Estimation Methodology for Ocean-Going Vessels, May 2008 Table A-7: Operational Parameters for Main Engines

Parameters Cruise Slow Cruise Maneuvering Load Factor 0.8 0.4 0.2 Hours per Operation 0.5 1.8 0.25 SOURCES: United States Environmental Protection Agency, Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009, Emissions Estimation Methodology for Ocean-Going Vessels, May 2008, and Email titled Richmond Terminal 3 Timber Export Facility – Air Quality Analysis Data Request from Dennis Shen RJJ Resource to Lina Velasco City of Richmond, dated August 05, 2016. Marine vessel GHG emissions were quantified within California waters (to a distance of approximately 12 miles from Golden Gate). The cruise mode occurs in the open ocean where there are fewer navigational challenges and where ships typically operate at their design speed. The cruise mode occurs for seven nautical miles from the Sea Buoy to the North Buoy for Asia destinations and takes approximately 30 minutes (one way) at a cruise speed of 14.5 knots.18 The slow cruise mode requires ships to slow down and stay within prescribed lanes. For arriving ships, slow cruise occurs after a pilot takes command of the vessel at the Sea Buoy until the vessel slows to a maneuvering speed directly in front of the Port of Richmond. According to the San Francisco Bar Pilots, car carriers travel at 15 knots inside the Sea Buoy and tankers/bulk carriers travel at 12 knots during initial slow cruise. All vessels slow to eight knots when they pick up a tug on the north end of Angel Island. Furthermore, all vessels slow to five knots to make the turn east of Richmond, and then stay at five knots as they approach the Port (in some instances picking up a second tug). Slow cruise is similar in reverse order for ships leaving the

18 San Francisco Bay Area Seaports Air Emissions Inventory, Port of Richmond 2005 Air Emissions Inventory, June 2010, http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/Emission%20Inventory/Port%20of%20Richm ond%202005%20Emissions%20Inventory%20June%202010.ashx Port of Richmond. The total transit from the Sea Buoy is about 22 nautical miles and takes approximately two hours (one way). 19 The maneuvering time is considered the time when the vessel is in front of its berth and is maneuvering with tug assistance into or out of berth. It was assumed that each call has 15 minutes total of maneuvering time; 15 minutes inbound and outbound. Lastly, the hotelling mode occurs when the vessel is stopped at berth or at anchor in the San Francisco Bay. During hotelling, the main engines are assumed to be off and only the auxiliary engines are running (unless shore power is available).20 Emission factors for main engines were derived from data at high operational loads. To estimate emissions at low operational loads (when the engine is less efficient), factors are needed to adjust the emission factors upwards. A two percent low load factor was assumed for the maneuvering mode. For the slow cruise mode, a 20 percent low load factor was used.21 Vessels typically do not use the total auxiliary engine installed power when at sea and during maneuvering. This is due to the design of the auxiliary system and the need for some level of redundancy in case of equipment failures. For each mode and vessel type, a different number of engines may be used and at varying loads depending on several factors, such as temperature. Maneuvering is generally the highest auxiliary load mode as the bow thrusters need to be available and used in spurts. The fairway or open sea is generally where the lowest auxiliary loads are found as additional auxiliary power is not required for maneuvering and many vessels have shaft generators and exhaust turbine generators that help provide power to the ship in an effort to reduce operating costs through lower fuel consumption.22 Typical number of auxiliary engines and size of auxiliary engine (assumption is three engines for maneuvering) for lights, heating/ventilation, communications, vessel’s gear, pumps, and other power demands while at berth. Typically our vessels have three auxiliary engines but many vessels have only two auxiliary engines. During maneuvering we usually run two auxiliary engines even if vessel has three auxiliary engines. Power demand at berth depends upon use of ballast pumps/ cranes/ grabs and will vary between 200 to 500 kilowatts. Alternate generator engine emission factors (Table A-8) were applied to the various activity data (Table A-9). Auxiliary engines of 612 kilowatts each were assumed.23 Actual power

19 San Francisco Bay Area Seaports Air Emissions Inventory, Port of Richmond 2005 Air Emissions Inventory, June 2010, http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/Emission%20Inventory/Port%20of%20Richm ond%202005%20Emissions%20Inventory%20June%202010.ashx 20 San Francisco Bay Area Seaports Air Emissions Inventory, Port of Richmond 2005 Air Emissions Inventory, June 2010, http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/Emission%20Inventory/Port%20of%20Richm ond%202005%20Emissions%20Inventory%20June%202010.ashx 21 San Francisco Bay Area Seaports Air Emissions Inventory, Port of Richmond 2005 Air Emissions Inventory, June 2010, http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/Emission%20Inventory/Port%20of%20Richm ond%202005%20Emissions%20Inventory%20June%202010.ashx 22 Starcrest Consulting Group, LLC, Port of Long Beach Air Emissions Inventory – 2014, September 2015, http://www.polb.com/environment/air/emissions.asp 23 Starcrest Consulting Group, LLC, Port of Long Beach Air Emissions Inventory – 2014, September 2015, http://www.polb.com/environment/air/emissions.asp demand at berth depends upon use of ballast pumps/cranes/grabs and would likely be between 200-500 kilowatts. Three engines were assumed operational within the slow cruise and maneuvering but many vessels only have two auxiliary engines.24 During maneuvering the vessels would likely operate two auxiliary engines even if the vessels have three auxiliary engines. During hoteling, one auxiliary engine would operate continuously, two auxiliary engines would operate when ballast pump and two deck cranes are in use, and three auxiliary engine would operate when all four deck cranes and ballast pumps are operating.25 The emission factor is dependent on the fuel used; an average sulfur content of 0.3 percent was assumed.26 Table A-8: Emission Factors for Auxiliary Engines

Slow Cruise Emission Factor Maneuvering Emission Factor Pollutant (g/kW-hr) (g/kW-hr) CO 1.10 1.10 HC 0.40 0.40 NOx 13.9 13.9 PM10/PM2.5 0.25/0.23 0.25/0.23 SO2 1.3 1.3 CO2 691 691 SOURCES: United States Environmental Protection Agency, Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009, and Emissions Estimation Methodology for Ocean-Going Vessels, May 2008 Table A-9: Operational Parameters for Auxiliary Engines

Parameters Slow Cruise Maneuvering Load Factor 0.17 0.45 Hours per Operation 1.8 0.25 SOURCES: United States Environmental Protection Agency, Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009, Emissions Estimation Methodology for Ocean-Going Vessels, May 2008, and Email titled Richmond Terminal 3 Timber Export Facility – Air Quality Analysis Data Request from Dennis Shen RJJ Resource to Lina Velasco City of Richmond, dated August 05, 2016. In addition to the auxiliary engines that are used to generate electricity for on-board uses, most marine vessels have one or more boilers used for fuel heating and for producing hot water.

24 Starcrest Consulting Group, LLC, Port of Long Beach Air Emissions Inventory – 2014, September 2015, http://www.polb.com/environment/air/emissions.asp 25 Email titled Richmond Terminal 3 Timber Export Facility – Air Quality Analysis Data Request from Dennis Shen RJJ Resource to Lina Velasco City of Richmond, dated August 05, 2016. 26 California Air Resources Board, Fuel Sulfur and Other Operation Requirements for Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline, July 24, 2008,, http://www.arb.ca.gov/ports/marinevess/ogv.htm Boilers are typically not used during transit at sea since vessels are equipped with an exhaust gas recovery system that uses exhaust for heating purposes and therefore the boilers are not needed when the main engines are used. Boilers are used at reduced speeds during maneuvering. Auxiliary boiler emission factors (Table A-10) were applied to the various activity data (Table A-11). An auxiliary boiler of 371 kilowatts27 was assumed. One auxiliary boiler would operate and provide heating while hoteling at the berth. Table A-10: Emission Factors for Auxiliary Boilers

Emission Factor Pollutant (g/kW-hr) CO 1.10 HC 0.40 NOx 13.9 PM10/PM2.5 0.25/0.23 SO2 1.3 CO2 691 SOURCES: United States Environmental Protection Agency, Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009, and Emissions Estimation Methodology for Ocean-Going Vessels, May 2008 Table A-11: Operational Parameters for Auxiliary Boilers

Parameters Maneuvering Load Factor 0.45 Hours per Operation 0.25 SOURCES: United States Environmental Protection Agency, Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009, Emissions Estimation Methodology for Ocean-Going Vessels, May 2008, and Email titled Richmond Terminal 3 Timber Export Facility – Air Quality Analysis Data Request from Dennis Shen RJJ Resource to Lina Velasco City of Richmond, dated August 05, 2016. Harbor Craft

Tugboats (or harbor craft) are used to propel bulk carrier marine vessels to and from the berth. Emissions were based on an average tugboat engine size of 2,000 horsepower (1,493 kilowatts) and a load factor of 31 percent.28 Two tugs were assumed to operate for each bulk carrier at one hour each. PM2.5 emissions were estimated to be 80 percent of PM10 emissions. The emission

27 Starcrest Consulting Group, LLC, Port of Long Beach Air Emissions Inventory – 2014, September 2015, http://www.polb.com/environment/air/emissions.asp 28 Detroit Diesel specification 4000 Series factor is dependent on the fuel used; an average sulfur content of 1.5 percent (marine diesel oil) was assumed.29 Tugboat emission factors (Table A-12) were applied to the various activity data. Table A-12: Emission Factors for Harbor Craft

Emission Factor Pollutant (g/kW-hr) CO 2.39 HC 0.322 NOx 11.1 PM10/PM2.5 0.284 SO2 8.76 CO2 775 SOURCE: United States Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009

29 California Air Resources Board, Fuel Sulfur and Other Operation Requirements for Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline, July 24, 2008, http://www.arb.ca.gov/ports/marinevess/ogv.htm

Attachment A-2 Air Emission Calculations o Offroad Equipment o Debarker o Motor Vehicle and Trucks in BAAQMD o Motor Vehicle and Trucks in YSAQMD o Bulk Carrier o Harbor Craft o Ocean Going Vessels Summary Offroad Equipment Emissions

Usage Load Emission Factor (gram/hp-hour) Emissions (pounds/day) Emissions (tons/year) Year Equipment Factor # HP Factor ROG CO NOX CO2 SO2 PM10 PM2.5 CH4 ROG CO NOX PM10 PM2.5 ROG CO NOX CO2 PM10 PM2.5 CH4 2015 Excavators 0.67 2 183 0.38 0.14 2.60 0.30 512 0.00 0.02 0.01 0.15 0.35 6.42 0.74 0.04 0.03 0.03 0.51 0.06 101.2 0.00 0.00 0.03 2015 Tractors/Loaders/Backhoes 0.45 1 267 0.37 0.14 2.60 0.30 512 0.00 0.02 0.01 0.15 0.17 3.08 0.36 0.02 0.02 0.01 0.25 0.03 48.5 0.00 0.00 0.01 2015 Sweepers/Scrubbers 0.59 1 100 0.46 0.14 3.70 0.30 514 0.00 0.02 0.01 0.15 0.10 2.64 0.21 0.01 0.01 0.01 0.21 0.02 29.3 0.00 0.00 0.01 0.61 12.1 1.31 0.07 0.06 0.05 0.97 0.10 179 0.01 0.00 0.05 162 metric tons

10.21 kg CO2/gallon 162,348 kg CO2 15,901 gallon PM10 (lb/yr) = (THROUGHPUT tons/yr)(0.024 lb TSP/ton)(0.50 lb PM10/lb TSP)(0.50) PM2.5 (lb/yr) = (THROUGHPUT tons/yr)(0.024 lb TSP/ton)(0.25 lb PM2.5/lb TSP)(0.50)

0.18 PM10 tons per year 0.09 PM2.5 tons per year 2.31 PM10 pounds per day 1.16 PM2.5 pounds per day

To approximate the particulate emissions for wood grinding, the emission factor for “Log Debarking” from a previous edition of AP-42, Table 10.3-1 of (0.024 lb TSP/ton) will be used with the throughput quantity of wood processed, as provided by the applicant. Approximately 60% of the particulate emissions are assumed to be PM10. Water suppression will also provide 50% abatement of particulate emissions. Motor Vehicle and Truck Emissions in BAAQMD

Emission Factors (gram/mile or gram/hr for idle) Emissions (pounds per day) Emsisions (tons per year) ROG CO NOX CO2 PM10 PM2_5 ROG CO NOX CO2 PM10 PM2_5 ROG CO NOX CO2 PM10 PM2_5 Worker 0.045 0.763 0.242 285 0.022 0.021 0.05 0.80 0.25 298 0.02 0.02 0.00 0.06 0.02 23.8 0.00 0.00

Bark Trucks Moving 0.28 0.98 7.07 1,678 0.08 0.08 0.14 0.49 3.53 838 0.04 0.04 0.00 0.01 0.06 13.40 0.00 0.00

Bark Trucks Idle 0.05 0.21 1.44 195 0.00 0.00 0.00 0.00 0.00 0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Bark Trucks Total 0.14 0.49 3.53 838 0.04 0.04 0.00 0.01 0.06 13.40 0.00 0.00

Log Trucks Moving 0.24 0.76 7.68 1,736 0.04 0.04 0.43 1.35 13.5 3,061 0.06 0.06 0.03 0.11 1.08 245 0.01 0.00

Log Trucks Idle 0.06 0.24 1.71 239 0.00 0.00 0.00 0.00 0.00 0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Log Trucks Total 0.43 1.35 13.5 3,061 0.06 0.06 0.03 0.11 1.08 245 0.01 0.00

Grand Total 0.61 2.64 17.3 4,197 0.13 0.12 0.04 0.18 1.16 282 0.01 0.01

Worker Trips 22.6 miles per day (2 round trips) 5.66 miles per one way trip 21 employees 5 days per week 160 days per year

Bark Trucks 113 miles round trip per day 64.2 miles from Tracy to Project 49 miles from Project to Milpitas 2 round trips per day 32 days per year 5 minutes idle

Log Trucks 80 miles round trip per day 40 miles from BAAQMD Border to Project 40 miles from Project to BAAQMD Border 10 round trips per day 160 days/year 5 minutes idle Motor Vehicle and Truck Emissions in YSAQMD

Emission Factors (gram/mile or gram/hr for idle) Emissions (pounds per day) Emsisions (tons per year) ROG CO NOX CO2 PM10 PM2_5 ROG CO NOX CO2 PM10 PM2_5 ROG CO NOX CO2 PM10 PM2_5 Log Trucks Moving 0.24 0.76 7.68 1,736 0.04 0.04 0.36 1.14 11.5 2,602 0.06 0.05 0.03 0.09 0.92 208 0.00 0.00

Log Trucks Idle 0.06 0.24 1.71 239 0.00 0.00 0.00 0.00 0.00 0.04 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Log Trucks Total 0.36 1.14 11.5 2,602 0.06 0.05 0.03 0.09 0.92 208 0.00 0.00

Grand Total 0.36 1.14 11.5 2,602 0.06 0.05 0.03 0.09 0.92 208 0.00 0.00

Log Trucks 68 miles round trip per day 34 miles from West Sac to BAAQMD Border 34 miles from BAAQMD Border to West Sac 10 round trips per day 160 days/year 5 minutes idle Main Engine Emission Factors (g/kW-hr) Low Load Main Engine Operation Assumptions Pollutant Cruise Slow Cruise Manuevering Factor 8,000 Main Engine size (kW) CO 1.10 1.10 1.10 9.68 0.8 Cruise Load HC 0.50 0.50 0.50 21.2 0.4 Slow Cruise Load NOx 13.2 13.2 13.2 4.63 0.2 Manuevering Load PM10 0.25 0.25 0.25 7.29 223 Fuel Consumption Cruise Load (g/kW-hr) PM2.5 0.23 0.23 0.23 7.29 241 Fuel Consumption Slow Cruise Load (g/kW-hr) SO2 1.2 1.2 1.2 3.36 276 Fuel Consumption Manuevering Load (g/kW-hr) CO2 646 646 646 3.28 0.79 Fuel Consumption Cruise Load (tons per day) Current Methodologies in Preparing Mobile Source 1.53 Fuel Consumption Slow Cruise Load (tons per day) Port-Related Emission Inventories, April 2009 0.12 Fuel Consumption Manuevering Load (tons per day) Table 2-9 1 Bulk Carriers per day 6 Bulk Carriers per year 0.5 hours per day per Bulk Carrier - Cruise 1.8 hours per day per Bulk Carrier - Slow Cruise 0.25 hours per day per Bulk Carrier - Manuevering 0.3 % sulfur Main Engine Emission Rates - Cruise Pollutant gm/hr lb/hr lb/day tons/yr Current Methodologies in Preparing Mobile Source CO 7,040 15.5 7.74 0.05 Port-Related Emission Inventories, April 2009 HC 3,200 7.0 3.52 0.02 Table 2-4 NOx 84,480 186 92.9 0.56 PM10 1,600 3.5 1.76 0.01 PM2.5 1,472 3.2 1.62 0.01 SO2 7,616 16.8 8.38 0.05 CO2 4,134,912 9,097 4,548 27.3 Fuel 1,429,549 3,145 1,573 9.4

Main Engine Emission Rates - Slow Cruise Pollutant gm/hr lb/hr lb/day tons/yr CO 3,520 7.7 13.9 0.1 HC 1,600 3.5 6.3 0.0 NOx 42,240 92.9 167 1.0 PM10 800 1.8 3.2 0.0 PM2.5 736 1.6 2.9 0.0 SO2 3,808 8.4 15.1 0.1 CO2 2,067,456 4,548 8,187 49.1 Fuel 771,254 1,697 3,054 18.3

Main Engine Emission Rates - Manuevering Pollutant gm/hr lb/hr lb/day tons/yr CO 17,037 37.5 9.4 0.1 HC 16,944 37.3 9.3 0.1 NOx 97,786 215 54 0.3 PM10 2,916 6.4 1.6 0.0 PM2.5 2,683 5.9 1.5 0.0 SO2 6,397 14.1 3.5 0.0 CO2 3,390,628 7,459 1,865 11.2 Fuel 442,107 973 243 1.5

Main Engine Emission Rates - Total Pollutant lb/day tons/yr CO 31.1 0.2 HC 19.2 0.1 NOx 314 1.9 PM10 6.5 0.0 PM2.5 6.0 0.0 SO2 27.0 0.2 CO2 14,600 88 Fuel 4,870 29.2 Alternate Generator Engines Emission Factors (g/kW-hr) Alternate Generator Engines Operation Assumptions Pollutant Sea Load Manuevering Hotelling 612 Auxilary Engine size (kW) CO 1.10 1.10 1.10 3 Auxilary Engines during Sea and Manuevering HC 0.40 0.40 0.40 3 Auxilary Engines during Hotelling NOx 13.9 13.9 13.9 0.17 Sea Load PM10 0.25 0.25 0.25 0.45 Manuevering Load PM2.5 0.23 0.23 0.23 0.10 Hotelling Load SO2 1.3 1.3 1.3 289 Fuel Consumption Sea Load (g/kW-hr) CO2 691 691 691 237 Fuel Consumption Manuevering Load (g/kW-hr) Current Methodologies in Preparing Mobile Source 347 Fuel Consumption Hotelling Load (g/kW-hr) Port-Related Emission Inventories, April 2009 0.10 Fuel Consumption Sea Load (tons per day) Table 2-16 0.22 Fuel Consumption Manuevering Load (tons per day) 0.07 Fuel Consumption Hotelling Load (tons per day) 1 Bulk Carriers per day 6 Bulk Carriers per year 1.8 hours per day per Bulk Carrier - Sea Load 0.25 hours per day per Bulk Carrier - Manuevering Load Alternate Generator Engines Emission Rates - Sea Load 12 hours per day per Bulk Carrier - Hotelling Pollutant gm/hr lb/hr lb/day tons/yr 0.3 % sulfur CO 343 0.76 1.4 0.0 HC 125 0.275 0.49 0.0 Current Methodologies in Preparing Mobile Source NOx 4,338 9.5 17.2 0.1 Port-Related Emission Inventories, April 2009 PM10 78 0.17 0.3 0.0 Table 2-4 PM2.5 72 0.16 0.3 0.0 Analysis of Commercial Marine Vessels Emissions and Fuel SO2 396 0.87 1.6 0.0 Consumption Data, February 2000 CO2 215,584 474 854 5.1 Table 5-2 Fuel 90,133 198 357 2.1 Emissions Estimation Methodology for Ocean-Going Vessels, May 2008 Alternate Generator Engines Emission Rates - Manuevering Load Table II-2 Pollutant gm/hr lb/hr lb/day tons/yr CO 909 2.0 0.5 0.0 HC 330 0.7 0.2 0.0 NOx 11,484 25.3 6.3 0.0 PM10 207 0.5 0.1 0.0 PM2.5 190 0.4 0.1 0.0 SO2 1,049 2.3 0.6 0.0 CO2 570,665 1,255 314 1.9 Fuel 195,888 431 108 0.6

Alternate Generator Engines Emission Rates - Hotelling Pollutant gm/hr lb/hr lb/day tons/yr CO 201.96 0.44 5.33 0.03 HC 73.44 0.16 1.94 0.01 NOx 2,552.04 5.61 67.37 0.40 PM10 45.90 0.10 1.21 0.01 PM2.5 42.23 0.09 1.11 0.01 SO2 233.17 0.51 6.16 0.04 CO2 126,814.36 278.99 3,347.90 20.09 Fuel 63,693.96 140.13 1,681.52 10.09

Alternate Generator Engines Emission Rates - Total Pollutant lb/day tons/yr CO 7.2 0.0 HC 2.6 0.0 NOx 90.9 0.5 PM10 1.6 0.0 PM2.5 1.5 0.0 SO2 8.3 0.0 CO2 4,515 27.1 Fuel 2,146 12.9 Auxillary Boiler Emission Factors (g/kw-hr) Pollutant 371 Engine size (kW) CO 1.10 0 hours per day per Auto Carrier - Slow Cruise HC 0.40 0.25 hours per day per Auto Carrier - Manuevering NOx 13.9 12 hours per day per Auto Carrier - Hotelling PM10 0.25 1 Bulk Carriers per day PM2.5 0.23 6 Bulk Carriers per year SO2 1.3 0.45 Manuevering Load CO2 691 0.26 Hotelling Load

Auxillary Boiler Emission Rates - Manuvering Pollutant gm/hr lb/hr lb/day tons/yr CO 184 0.40 0.1 0.0 HC 67 0.15 0.0 0.0 NOx 2,321 5.11 1.3 0.0 PM10 42 0.09 0.0 0.0

PM2.5 38 0.08 0.0 0.0 SO2 212 0.47 0.1 0.0 CO2 115,314 254 63 0.4

Auxillary Boiler Emission Rates - Hotelling Pollutant gm/hr lb/hr lb/day tons/yr CO 106 0.23 2.80 0.02 HC 39 0.08 1.02 0.01 NOx 1,341 2.95 35.40 0.21 PM10 24 0.05 0.64 0.00

PM2.5 22 0.05 0.59 0.00 SO2 123 0.27 3.23 0.02 CO2 66,626 147 1,758.92 10.55

Auxillary Boiler Emission Rates - Total Pollutant lb/day tons/yr CO 2.9 0.0 HC 1.1 0.0 NOx 36.7 0.2 PM10 0.7 0.0 PM2.5 0.6 0.0

SO2 3.4 0.0 CO2 1,822 11 Tug Operations Emission Factors Operation Assumptions Pollutant gm/kW-hr 2 tugs per day CO 2.48 1 hours per day per tug HC 0.134 6 events per year NOx 10.6 2,000 Avg tug engine size (hp) PM10/2.5 0.32 0.31 Average load 251 Fuel Consumption (g/kW-hr) 0.41 Fuel Consumption (tons per tug per day) Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009 Table 3-4

Tug Emission Rates Pollutant gm/hr lb/hr lb/day tons/yr CO 1,147 2.52 5.05 0.03 HC 62 0.14 0.27 0.00 NOx 4,881 10.7 21.5 0.13 PM10/2.5 148 0.33 0.65 0.00 Fuel 116,257 255.77 511.53 3.07 Main Alternative Auxillary Main Alternative Auxillary Main Alternative Auxillary Engine Generator Boiler Tugs Engine Generator Boiler Tugs Engine Generator Boiler Tugs Total Total Pollutant lb/day lb/day lb/day lb/day tons/yr tons/yr tons/yr tons/yr lb/day lb/day lb/day lb/day lb/day tons/yr CO 31.1 7.19 2.90 5.05 0.19 0.04 0.02 0.03 2.33 0.54 0.22 0.38 3.09 0.25 HC 19.2 2.61 1.06 0.27 0.12 0.02 0.01 0.00 1.44 0.20 0.08 0.02 1.71 0.14 NOx 314 90.9 36.7 21.5 1.88 0.55 0.22 0.13 23.5 6.82 2.75 1.61 33.1 2.65 PM10 6.5 1.63 0.66 0.65 0.04 0.01 0.00 0.00 0.49 0.12 0.05 0.05 0.66 0.05 PM2.5 6.0 1.50 0.61 0.65 0.04 0.01 0.00 0.00 0.45 0.11 0.05 0.05 0.61 0.05 SO2 27.0 8.30 3.35 2.92 0.16 0.05 0.02 0.02 2.02 0.62 0.25 0.22 2.90 0.23 CO2 14,600 4,515 1,822 2,374 87.6 27.1 10.9 14.2 1,095 339 137 178 Fuel 4,870 2,146 - 69.3 29.2 12.88 - 0.42 365 161 - 5.20

114 metric tons 6.943 lb/gallon 12.9 metric tons 12,246 gallons Appendix A-3

Health Risk Assessment Assumptions and Methodologies

A health risk assessment (HRA) is accomplished in four steps: 1) hazards identification, 2) exposure assessment, 3) toxicity assessment, and 4) risk characterization. These steps cover the estimation of air emissions, the estimation of the air concentrations resulting from a dispersion analysis, the incorporation of the toxicity of the pollutants emitted, and the characterization of the risk based on exposure parameters such as breathing rate, age adjustment factors, and exposure duration; each depending on receptor type (i.e., residence, school, adult, child, recreational areas). This HRA was conducted in accordance with technical guidelines developed by federal, state, and regional agencies, including U.S. Environmental Protection Agency (USEPA), California Environmental Protection Agency (CalEPA), California Office of Environmental Health Hazard Assessment (OEHHA) Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments,1 and the Bay Area Air Quality Management District (BAAQMD) Health Risk Screening Analysis Guidelines.2 This HRA addresses the emissions from the operations of on-site equipment such as loaders, marine vessels, and log/bark trucks. Specific focus is on diesel particulate matter (DPM) emissions. In accordance with the BAAQMD guidelines, the HRA also evaluated concentrations of particulate matter equal to or less than 2.5 micrometers (fine particulate or PM2.5). According to CalEPA, a HRA should not be interpreted as the expected rates of cancer or other potential human health effects, but rather as estimates of potential risk or likelihood of adverse effects based on current knowledge, under a number of highly conservative assumptions and the best assessment tools currently available. Terms and Definitions

As the practice of conducting a HRA is particularly complex and involves concepts that are not altogether familiar to most people, several terms and definitions are provided that are considered essential to the understanding of the approach, methodology and results: Acute effect – a health effect (non-cancer) produced within a short period of time (few minutes to several days) following an exposure to toxic air contaminants (TAC). Cancer risk – the probability of an individual contracting cancer from a lifetime (i.e., 70 year) exposure to TAC such as DPM in the ambient air.

1 Office of Environmental Health Hazard Assessment, Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments, March 6, 2015, http://oehha.ca.gov/air/hot_spots/hotspots2015.html. 2 Bay Area Air Quality Management District, Air Toxics NSR Program Health Risk Screening Analysis Guidelines, January 2010, http://www.baaqmd.gov/~/media/Files/Engineering/Air%20Toxics%20Programs/hrsa_guidelines.ashx Chronic effect – a health effect (non-cancer) produced from a continuous exposure occurring over an extended period of time (weeks, months, years). Hazard Index (HI) – the unitless ratio of an exposure level over the acceptable reference dose (RfC). The HI can be applied to multiple compounds in an additive manner. Hazard Quotient (HQ) – the unitless ratio of an exposure level over the acceptable reference dose. The HQ is applied to individual compounds. Toxic air contaminants – any air pollutant that is capable of causing short-term (acute) and/or long-term (chronic or carcinogenic, i.e., cancer causing) adverse human health effects (i.e., injury or illness). The California list of TAC lists approximately 200 compounds, including particulate emissions from diesel-fueled engines. Human Health Effects - comprise disorders such as eye watering, respiratory or heart ailments, and other (i.e., non-cancer) related diseases. Health Risk Assessment – an analysis designed to predict the generation and dispersion of TAC in the outdoor environment, evaluate the potential for exposure of human populations, and to assess and quantify both the individual and population-wide health risks associated with those levels of exposure. Incremental – under CEQA, the net difference (or change) in conditions or impacts when comparing the baseline to future year project conditions. Maximum exposed individual (MEI) – an individual assumed to be located at the point where the highest concentrations of TAC, and therefore, health risks are predicted to occur. Non-cancer risks – health risks such as eye watering, respiratory or heart ailments, and other non-cancer related diseases. Receptors – the locations where potential health impacts or risks are predicted (i.e., schools, residences, and recreational sites). Limitations and Uncertainties

There are a number of important limitations and uncertainties commonly associated with a HRA due to the wide variability of human exposures to TAC, the extended timeframes over which the exposures are evaluated and the inability to verify the results. Among these challenges are the following:  The HRA exposure estimates do not take into account that people do not usually reside at the same location for 70 years and that other exposures (i.e., school children) are also of much shorter durations than was assumed in this analysis. Therefore, the results of the HRA are highly overstated for those cases.  Other limitations and uncertainties associated with HRA and identified by the CalEPA include: (a.) lack of reliable monitoring data; (b.) extrapolation of toxicity data in animals to humans; (c.) estimation errors in calculating TAC emissions; (d.) concentration prediction errors with dispersion models; and (e.) the variability in lifestyles, fitness and other confounding factors of the human population. Hazard Identification

CARB has developed a list of TAC, where a TAC3 is “an air pollutant which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health (California Health and Safety Code Section 39655). All USEPA hazardous air pollutants are TAC. The CARB administers the Air Toxics “Hot Spots” program under Assembly Bill 2588 (AB2588) “Hot Spots” Information and Assessment Act, which requires periodic local review of facilities which emit TAC. Local air agencies periodically must prioritize stationary sources of TAC and prepare health risk assessments for high-priority sources. CARB also regulates TAC via Air Toxics Control Measures (ATCM) for stationary and mobile sources, of which the diesel engine ATCM are most relevant to this proposed project. Diesel exhaust is a complex mixture of numerous individual gaseous and particulate compounds emitted from diesel-fueled combustion engines. DPM is formed primarily through the incomplete combustion of diesel fuel. DPM is removed from the atmosphere through physical processes including atmospheric fall-out and washout by rain. Humans can be exposed to airborne DPM by deposition on water, soil, and vegetation; although the main pathway of exposure is inhalation. In August 1998, the CARB identified DPM as an air toxic. The CARB developed the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel- Fueled Engines and Vehicles and Risk Management Guidance for the Permitting of New Stationary Diesel-Fueled Engines and approved these documents on September 28, 2000.4,5 The documents represent proposals to reduce DPM emissions, with the goal of reducing emissions and the associated health risk by 75 percent in 2010 and by 85 percent in 2020. The program aimed to require the use of state-of-the-art catalyzed DPM filters and ultra-low-sulfur diesel fuel. In 2001, CARB assessed the state-wide health risks from exposure to diesel exhaust and to other toxic air contaminants. It is difficult to distinguish the health risks of diesel emissions from those of other air toxics, since diesel exhaust contains approximately 40 different TAC. The CARB study detected diesel exhaust by using ambient air carbon soot measurements as a surrogate for diesel emissions. The study reported that the state-wide cancer risk from exposure to diesel exhaust was about 540 per million population as compared to a total risk for exposure to all ambient air toxics of 760 per million. This estimate, which accounts for about 70 percent of

3 Toxic air contaminants are a broad class of compounds known to cause morbidity or mortality. TAC are found in ambient air, especially in urban areas, and are caused by industry, agriculture, fuel combustion, and commercial operations (e.g., gasoline service stations, dry cleaners). TAC are typically found in low concentrations, even near their source (e.g., diesel particulate matter near a freeway). Because chronic exposure can result in adverse health effects, TAC are regulated at the regional, state, and Federal level. 4 California Air Resources Board, Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled Engines and Vehicles, October 2000, http://www.arb.ca.gov/diesel/documents/rrpfinal.pdf 5 California Air Resources Board, Risk Management Guidance for the Permitting of New Stationary Diesel-Fueled Engines, October 2000, http://www.arb.ca.gov/diesel/documents/rmgfinal.pdf the total risk from TAC, included both urban and rural areas in the state. The estimate can also be considered an average worst-case for the state, since it assumes constant exposure to outdoor concentrations of diesel exhaust and does not account for expected lower concentrations indoors, where most of time is spent. Exposure Assessment

Dispersion is the process by which atmospheric pollutants disseminate due to wind and vertical stability. The results of a dispersion analysis are used to assess pollutant concentrations at or near an emission source. The results of an analysis allow predicted concentrations of pollutants to be compared directly to air quality standards and other criteria such as health risks based on modeled concentrations. A rising pollutant plume reacts with the environment in several ways before it levels off. First, the plume’s own turbulence interacts with atmospheric turbulence to entrain ambient air. This mixing process reduces and eventually eliminates the density and momentum differences that cause the plume to rise. Second, the wind transports the plume during its rise and entrainment process. Higher winds mix the plume more rapidly, resulting in a lower final rise. Third, the plume interacts with the vertical temperature stratification of the atmosphere, rising as a result of buoyancy in the unstable-to-neutrally stratified mixed layer. However, after the plume encounters the mixing lid and the stably stratified air above, its vertical motion is dampened. Molecules of gas or small particles injected into the atmosphere will separate from each other as they are acted on by turbulent eddies. The Gaussian mathematical model such as AERMOD simulates the dispersion of the gas or particles within the atmosphere. The formulation of the Gaussian model is based on the following assumptions:  The predictions are not time-dependent (all conditions remain unchanged with time)  The wind speed and direction are uniform, both horizontally and vertically, throughout the region of concern  The rate of diffusion is not a function of position  Diffusion in the direction of the transporting wind is negligible when compared to the transport flow Dispersion Modeling Approach Air dispersion modeling was performed to estimate the downwind dispersion of DPM exhaust emissions resulting from construction activities. The following sections present the fundamental components of an air dispersion modeling analysis including air dispersion model selection and options, receptor locations, meteorological data, and source exhaust parameters. Model Selection and Options AERMOD (Version 15181)6 was used for the dispersion analysis. AERMOD is the USEPA preferred atmospheric dispersion modeling system for general industrial sources. The model can simulate point, area, volume, and line sources. AERMOD is the appropriate model for this

6 US Environmental Protection Agency, AERMOD Modeling System, http://www.epa.gov/scram001/dispersion_prefrec.htm analysis based on the coverage of simple, intermediate, and complex terrain. It also predicts both short-term and long-term (annual) average concentrations. The model was executed using the regulatory default options (stack-tip downwash, buoyancy-induced dispersion, and final plume rise), default wind speed profile categories, default potential temperature gradients, and assuming no pollutant decay. The selection of the appropriate dispersion coefficients depends on the land use within three kilometers (km) of the project site. The types of land use were based on the classification method defined by Auer (1978); using pertinent United States Geological Survey (USGS) 1:24,000 scale (7.5 minute) topographic maps of the area. If the Auer land use types of heavy industrial, light-to-moderate industrial, commercial, and compact residential account for 50 percent or more of the total area, the USEPA Guideline on Air Quality Models recommends using urban dispersion coefficients; otherwise, the appropriate rural coefficients can be used. Based on observation of the area surrounding the project site, rural (urban is only designated within dense city centers such as downtown San Francisco) dispersion coefficients were applied. Receptor Locations BAAQMD considers the relevant zone of influence for an assessment of air quality health risks to be within 1,000 feet of a project site. Sensitive receptors such as residences, schools, and outdoor recreational areas near the proposed project were chosen as the receptors to be analyzed. The project site is located on the west side of Harbour Way South at its southern terminus, on the southern shoreline of the City of Richmond. The site is located on the east side of Harbor Channel, adjacent to the Richmond Inner Harbor on San Francisco Bay. The proposed project is approximately 3,500 feet (0.7 miles) south of Interstate 580. Sensitive receptors include the Ford Assembly Building, residences near Marina Park and Vincent Park (to the east), and recreational use at Lucretia Edwards Park and Vincent Park. The Benito Juarez Elementary School (at 1450 Marina Way South) is located approximately 1,350 feet to the southeast of the project site. Receptors were placed at a height of 1.8 meters (typical breathing height). Terrain elevations for receptor locations were used (i.e., complex terrain) based on available USGS information for the area. Figure A-1 displays the location of the sensitive receptors used in the HRA. Meteorological Data Air quality is a function of both the rate and location of pollutant emissions under the influence of meteorological conditions and topographic features affecting pollutant movement and dispersal. Atmospheric conditions such as wind speed, wind direction, atmospheric stability, and air temperature gradients interact with the physical features of the landscape to determine the movement and dispersal of air pollutants, and consequently affect air quality. Hourly meteorological data from BAAQMD’s University of California at Richmond monitoring station (surface data), located approximately two miles to the east of the proposed project, and Oakland International Airport (upper air) were used in the dispersion modeling analysis. Meteorological data from 2004 through 2009 were used (the most recent available data from the BAAQMD’s monitoring station). Figure A-2 displays the annual wind rose. Wind directions are predominately from the south-southwest and a low frequency of calm with moderate wind speed conditions, as shown in Figure A-3. The average annual wind speed is 6.9 miles per hour. Figure A-1: Health Risk Assessment Receptors

Figure A-2: Windrose for University of California at Richmond

Figure A-3: Wind Speed Distribution for University of California at Richmond

Source Release Characteristics The bark/log truck volume was assigned a release height of 3.05 meters and an initial vertical dimension of 4.15 meters, which accounts for dispersion from the movement of vehicles. The release height reflects the height of the truck exhaust plus an additional distance to account for plume rise of the exhaust gases. The roadway width was set at 40 meters to represent both the north and south bound directions. The truck emissions were represented as line volume source centers separated by two times the volume source width, as required by USEPA. The line source extends from the proposed project site to I-580 along Harbour Way South. Terrain elevations for emission source locations were used based on available USGS DEM for the project area. AERMAP (Version 11103)7 was used to develop the terrain elevations, although the project site is generally flat. An area source at the project site was included in the modeling analysis to represent the onsite equipment and truck idling emissions. Model parameters for area sources include emission rate, release height, lengths of x and y sides of a polygonal area, and initial vertical dimensions of the plume. The area source was modeled with a height of 3.05 meters. Marine vessels and harbor craft (tugboats) in open waters are simulated as line sources with a release height of 50 and 6 meters, respectively, and an initial vertical dimension of 23.3 and 2.79 meters, respectively. The line sources were simulated with a width of 60 meters within the maneuvering and slow cruise conditions. Exhaust release parameters for marine vessel include stack height, stack diameter, stack exhaust temperature, and stack exhaust exit velocity which are included in Table A-12.

Table A-12: Marine Vessel Exhaust Release Parameters

Stack Stack Exhaust Exit Velocity Height (m) Diameter (m) Temperature (K) (m/s) 43 0.5 618 16 SOURCE: CARB’s Diesel Particulate Matter Exposure Assessment Study for the Ports of Los Angeles and Long Beach, April 2006. Normal operating hours for the proposed log export facility would be Monday through Friday from 6:00 a.m. to 6:00 p.m. Receiving hours for loaded log trucks would be from 7:00 a.m. to 5:00 p.m. Log export shipments would occur only during the timber harvesting season in California, which starts in April and continues through November. With four shipments anticipated each year, there would be roughly one shipment every two months. This facility operating scheduled was incorporated into the dispersion modeling analysis. Temporal factors (Table A-13) are used to describe the relationship of activity levels in one period of time to another period of time (i.e., the relationship of the activity during one-hour to the activity during a 24-hour period). The use of temporal factors gives the model the ability to more accurately reflect real world conditions.

7 US Environmental Protection Agency, AERMAP, http://www.epa.gov/ttn/scram/dispersion_related.htm#aermap Table A-13: Marine Vessel Emission Source Temporal Distributions

Source Period Activity Distribution (%) Hours per Day Marine Vessel 4 am – 8 pm 80 16 Maneuvering 8 pm – 4 am 20 8 Hotelling midnight-midnight 100 24 Tugboats 6 am – 6 pm 80 12 6 pm – 6 am 20 12 Rail 6 am – 6 pm 80 12 6 pm – 6 am 20 12 SOURCE: CARB’s Diesel Particulate Matter Exposure Assessment Study for the Ports of Los Angeles and Long Beach, April 2006. Exposure Parameters

The HRA was conducted following methodologies in OEHHA’s Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments (dated February 2015). This was accomplished by applying the estimated concentrations at the receptors analyzed to the established cancer risk estimates and acceptable reference concentrations (RfC) for non-cancer health effects. OEHHA's revisions to its Guidance Manual were primarily designed to ensure that the greater sensitivity of children to cancer and other health risks is reflected in HRAs. For example, OEHHA now recommends that risks be analyzed separately for multiple age groups, focusing especially on young children and teenagers, rather than the past practice of analyzing risks to the general population, without distinction by age. OEHHA also now recommends that statistical "age sensitivity factors" be incorporated into a HRA, and that children's relatively high breathing rates be accounted for. On the other hand, the Guidance Manual revisions also include some changes that would reduce calculated health risks. For example, under the former guidance, OEHHA recommended that residential cancer risks be assessed by assuming 70 years of exposure at a residential receptor; under the Guidance Manual, this assumption is lessened to 30 years. OEHHA developed exposure factors (e.g., daily breathing rates) for six age groups including the last trimester to birth, birth to 2 years, 2 to 9 years, 2 to 16 years, 16 to 30 years, and 16 to 70 years. These age bins allow for more refined exposure information to be used when estimating exposure and the potential for developing cancer over a lifetime. This means that exposure variates are needed for the third trimester, ages zero to less than two, ages two to less than nine, ages two to less than 16, ages 16 to less than 30, and ages 16 to 70. Residential receptors utilize the 95th percentile breathing rate values. OEHHA developed age sensitivity factors (ASF) to take into account the increased sensitivity to carcinogens during early-in-life exposures. OEHHA recommends that cancer risks be weighted by a factor of 10 for exposures that occur from the third trimester of pregnancy to 2 years of age, and by a factor of 3 for exposures from 2 years through 15 years of age. For estimating cancer risks for residential receptors over a 30 year and 70 year lifetime, the incorporation of the ASF results in a cancer risk adjustment factor (CRAF) of 1.7. OEHHA evaluated information from activity pattern databases to estimate the fraction of time at home (FAH) during the day. This information was used to adjust exposure duration and cancer risk based on the assumption that a person is not present at home continuously for 24 hours and therefore exposure to emissions is not occurring when a person is away from their home. In general, the FAH factors are age-specific and are 0.85 for ages less than 2 years, 0.72 for ages 2 to 16 years, and 0.73 for ages 16 to 70 years. OEHHA has decreased the exposure duration currently being used for estimating cancer risk at the maximum exposed individual resident (MEIR) from 70 years to 30 years. This is based on studies showing that 30 years is a reasonable estimate of the 90th to 95th percentile of residency duration in the population. Additionally, OEHHA recommends using the 9 and 70-year exposure duration to represent the potential impacts over the range of residency periods. Detailed results of the health risk assessment outputs are included as part of this appendix. Risk Characterization

Cancer risk is defined as the lifetime probability of developing cancer from exposure to carcinogenic substances. Cancer risks are expressed as the chance in one million of getting cancer (i.e., number of cancer cases among one million people exposed). The cancer risks are assumed to occur exclusively through the inhalation pathway. The cancer risk can be estimated by using the cancer potency factor (milligrams per kilogram of body weight per day [mg/kg- day]), the 30-year annual average concentration (microgram per cubic meter [µg/m3]), and the lifetime exposure adjustment. Following guidelines established by OEHHA, the incremental cancer risks attributable to the proposed project were calculated by applying exposure parameters to modeled DPM concentrations in order to determine the inhalation dose (mg/kg-day) or the amount of pollutants inhaled per body weight mass per day. The cancer risks occur exclusively through the inhalation pathway; therefore, the cancer risks can be estimated from the following equation:

Dose-inh = Cair * {DBR} * A * ASF * FAH * EF * ED * 10-6 AT Where: Dose-inh = Dose of the toxic substance through inhalation in mg/kg-day 10-6 = Micrograms to milligrams conversion, Liters to cubic meters conversion

Cair = Concentration in air in microgram (μg)/cubic meter (m3) {DBR} = Daily breathing rate in liter (L)/kg body weight – day A = Inhalation absorption factor ASF = Age Sensitivity Factor EF = Exposure frequency (days/year) ED = Exposure duration (years) FAH = Fraction of Time at Home AT = Averaging time period over which exposure is averaged in days (25,550 days for a 70 year cancer risk)

To determine incremental cancer risk, the estimated inhalation dose attributed to the proposed project was multiplied by the cancer potency slope factor (cancer risk per mg/kg-day). The cancer potency slope factor is the upper bound on the increased cancer risk from a lifetime exposure to a pollutant. These slope factors are based on epidemiological studies and are different values for different pollutants. This allows the estimated inhalation dose to be equated to a cancer risk. Non-cancer adverse health impacts, acute (short-term) and chronic (long-term), are measured against a hazard index (HI), which is defined as the ratio of the predicted incremental exposure concentration from the project to a published reference exposure level (REL) that could cause adverse health effects as established by OEHHA. The ratio (referred to as the Hazard Quotient [HQ]) of each non-carcinogenic substance that affects a certain organ system is added to produce an overall HI for that organ system. The overall HI is calculated for each organ system. If the overall HI for the highest-impacted organ system is greater than one, then the impact is considered to be significant. The HI is an expression used for the potential for non-cancer health effects. The relationship for the non-cancer health effects is given by the annual concentration (in µg/m3) and the REL (in µg/m3). The acute hazard index was determined using the “simple” concurrent maximum approach, which tends to be conservative (i.e., overpredicts). The relationship for the non-cancer health effects is given by the following equation:

HI = C/REL Where:

HI = Hazard index; an expression of the potential for non-cancer health effects. C = Annual average concentration (g/m3) during the 30 year exposure period. REL = Concentration at which no adverse health effects are anticipated.

The chronic REL for DPM was established by the California OEHHA as 5 g/m3.8 There is no acute REL for DPM. However, diesel exhaust does contain acrolein and other compounds, which do have an acute REL. BAAQMD’s DPM speciation table (based on profile 4674 within the USEPA Speciate 4.2)9 was used to assess the acute impacts. Acrolein emissions are approximately 1.3 percent of the total diesel fuel emissions. The acute REL for acrolein was established by the California OEHHA as 2.5 g/m3.10

8 California Office of Environmental Health Hazards Assessment - Acute, 8-hour, and Chronic Reference Exposure Levels, June 2014, http://www.oehha.ca.gov/air/allrels.html 9 Provides for a speciation faction of 1.3 percent of acrolein per DPM emission rate, http://www.epa.gov/ttnchie1/software/speciate/ 10 California Office of Environmental Health Hazards Assessment - Acute, 8-hour, and Chronic Reference Exposure Levels, June 2014, http://www.oehha.ca.gov/air/allrels.html Cumulative Sources

As part of the health risk assessment, in addition to proposed project emissions, emissions were determined for cumulative sources located near the proposed project. These sources include the Port of Richmond (marine vessels, rail yard), roadways, and nearby permitted sources. The BAAQMD’s CEQA Air Quality Guidelines include standards and methods for determining the significance of cumulative health risk impacts.11 The method for determining cumulative health risk requires the tallying of health risk from permitted sources and major roadways in the vicinity of a project (i.e., within a 1,000-foot radius of the location of the proposed project), then adding the proposed project impacts to determine whether the cumulative health risk thresholds are exceeded. BAAQMD has developed a geo-referenced database of permitted emissions sources throughout the San Francisco Bay Area, and has developed the Stationary Source Risk & Hazard Analysis Tool for estimating cumulative health risks from permitted sources. One permitted source, Maroc Painting located at 1200 Harbour Way South) is located within 1,000 feet of the proposed project impact area. The estimated screening cancer risk, hazard impacts, and the PM2.5 concentrations for this cumulative permitted source is 0.01 per million, 0, and 0, respectively. BAAQMD has also developed a geo-referenced database of highways throughout the San Francisco Bay Area and has developed the Highway Screening Analysis Tool for estimating cumulative health risks from highways. I-580 is well beyond 1,000 feet of the proposed project and thus, not included as a cumulative source. BAAQMD CEQA Air Quality Guidelines also require the inclusion of surface streets within 1,000 feet of the proposed project with annual average daily traffic of 10,000 or greater.12 Upon review of nearby roadways, no roadways meet the criteria.

Port of Richmond Operations Cumulative sources within the Port of Richmond include marine vessels, harbor craft, cargo handling equipment,13 and rail operations. In general, emissions were estimated using the activity and operational information described within this attachment and emission factors, which are measures of emissions that express the mass of emissions in terms of a unit of activity. For example, emission factors for marine vessels are expressed in terms of grams of emissions (of a particular pollutant) per horsepower-hour. Horsepower-hours are the product of in-use horsepower times hours of operation times a load factor. Emissions are then calculated, by multiplying hours of operation per year (activity data) by in-use horsepower

11 Bay Area Air Quality Management District, CEQA Air Quality Guidelines, May 2012. http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CEQA/BAAQMD%20CEQA%20Guidelines_ Final_May%202012.ashx?la=en 12 Bay Area Air Quality Management District, County Surface Street Screening Tables, May 2011, http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/CEQA/County%20Surface%20Street%20Scre ening%20Tables%20Dec%202011.ashx?la=en and Fehr & Peers, Terminal 3 Transportation Assessment, October 2, 2015. 13 The Port of Richmond operates a limited number of cargo-handling equipment. According to the 2005 inventory, these comprise two propane powered forklifts (operating for 810 hours per year) and three diesel-fueled general industrial equipment such as tractors (operating for 60 hours per year). (operational information) by a load factor and by an emission factor (such as pounds per horsepower-hour) to provide an estimate of emissions in pounds of emissions per day or tons of emissions per year. Table A-14 provides the operational levels for the Port of Richmond marine vessel activities. Figure A-4 presents the location of the marine vessel berths within the Port of Richmond. Table A-14: Port of Richmond Operations

Berth Description Port of Calls Vessel Type 6C PPMT 75 Auto Carrier 7 PPMT 75 Auto Carrier 8 RCIP 73 Tanker 9 Arco 38 Tanker 11 Unitank 49 Tanker 12 Unitank 5 Tanker 14 Gypsum 6 Bulk Carrier 16 Castrol 11 Tanker 17 IMTT 64 Tanker 20 Levin Terminal 6 Bulk Carrier 21 Levin Terminal 46 Bulk Carrier 22 Time/Shore/Kaneb 72 Tanker 23 California Oils 12 Tanker 24 Stevedoring 19 Tanker Longwharf Chevron 548 Tanker SOURCE: Marine Exchange of the San Francisco Bay Region, Golden Gate Ports Handbook, 2014, http://www.sfmx.org/publications/portshandbook.php

Figure A-4: Port of Richmond Berth Locations Marine Vessels For marine vessels, emission factors were developed by review of the literature and information specific to the Port of Richmond.14 Emissions were calculated by multiplying the emission factors by vessel-specific activity parameters such as in-use horsepower and hours of operation. Calculations were made to adequately characterize the complex activities of marine vessels (e.g., separate calculations were made for vessel transit, maneuvering, and hotelling activities for main propulsion engines, auxiliary engines, and auxiliary boilers). In developing an activity-based emissions inventory for marine vessels, emissions are estimated as a function of vessel power demand (expressed in kilowatt-hours) multiplied by an emission factor, where the emission factor is expressed in terms of grams per kilowatt-hour (g/kW-hr). Main engine emission factors (Table A-15) were then applied to the various activity data (Table A-16). A main engine of 10,700 kilowatts (kW), 8,000 kW, and 9,400 kW (Tanker) for auto carrier, bulk carrier, and tankers, respectively, were used.15 The cruise mode occurs in the open ocean where there are fewer navigational challenges and where ships typically operate at their design speed. The cruise mode occurs for seven nautical miles from the Sea Buoy to the North Buoy for Asia destinations and takes approximately 30 minutes (one way) at a cruise speed of 14.5 knots.16 The slow cruise mode requires ships to slow down and stay within prescribed lanes. For arriving ships, the slow cruise mode occurs after a pilot takes command of the vessel at the Sea Buoy until the vessel slows to a maneuvering speed directly in front of the Port. According to the San Francisco Bar Pilots, car carriers travel at 15 knots inside the Sea Buoy and tankers travel at 12 knots. All vessels slow to eight knots when they pick up a tug on the north end of Angel Island. All vessels slow to five knots to make the turn east of Richmond, and then stay at five knots as they approach the Port (in some instances picking up a second tug). The slow cruise mode is similar in reverse order for ships leaving the Port of Richmond. The total transit from the Sea Buoy is about 22 nautical miles and takes approximately two hours (one way).17 The maneuvering time is considered the time when the vessel is in front of its berth and is maneuvering with tug assistance into or out of berth. It was assumed that each call had 30 minutes total of maneuvering time, 15 minutes inbound and 15 minutes outbound. Lastly, the hotelling mode occurs when the vessel is stopped at berth or at anchor in the Bay. During

14 US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emissions, April 2009, http://trid.trb.org/view.aspx?id=927750, Emissions Estimation Methodology for Ocean-Going Vessels, May 2008, http://www.arb.ca.gov/regact/2008/fuelogv08/appdfuel.pdf, and Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, http://www3.epa.gov/otaq/models/nonrdmdl/c-marine/r00002.pdf 15 Starcrest Consulting Group, LLC, Port of Long Beach Air Emissions Inventory – 2014, September 2015, http://www.polb.com/environment/air/emissions.asp 16 San Francisco Bay Area Seaports Air Emissions Inventory, Port of Richmond 2005 Air Emissions Inventory, June 2010, http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/Emission%20Inventory/Port%20of%20Richm ond%202005%20Emissions%20Inventory%20June%202010.ashx 17 San Francisco Bay Area Seaports Air Emissions Inventory, Port of Richmond 2005 Air Emissions Inventory, June 2010, http://www.baaqmd.gov/~/media/Files/Planning%20and%20Research/Emission%20Inventory/Port%20of%20Richm ond%202005%20Emissions%20Inventory%20June%202010.ashx hotelling, the main engines are assumed to be off and only the auxiliary engines are running (unless shore power is available).18 Emission factors for main engines were derived from data at high operational loads. To estimate emissions at low operational loads (when the engine is less efficient), factors are needed to adjust the emission factors upwards. A two percent low load adjustment factors were used for the maneuvering mode. For the reduced speed zone modes, 20 percent low load adjustment factors were used.19 Table A-15: Main Engine Emission factors

Cruise Slow Cruise Maneuvering Emission Factor Emission Factor Emission Factor Pollutant (g/kW-hr) (g/kW-hr) (g/kW-hr)

PM10 0.25 0.25 0.25 PM2.5 0.23 0.23 0.23 SOURCE: US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009.

Table A-16: Main Engine Operational Parameters

Marine Vessel Parameters Cruise Slow Cruise Maneuvering Auto Carrier Load Factor 0.8 0.3 0.15 Hours per Operation 1.2 4 0.5 Bulk Carrier Load Factor 0.8 0.4 0.2 Hours per Operation 1.2 4 0.5 Tanker Load Factor 0.8 0.4 0.2 Hours per Operation 1.2 4 0.5

SOURCE: US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009. Vessels typically do not use the total auxiliary engine installed power when at sea, during hotelling, and during maneuvering. This is due to the design of the auxiliary system and the need for some level of redundancy in case of equipment failures. For each mode and vessel type, a different number of engines may be used and at varying loads depending on several factors, such as temperature. Hotelling load is primarily what is needed to meet the power needs of the lights, heating/ventilation/air conditioning systems, communications, computers, ship cranes, pumps, reefer load, and various other power demands while the vessel is at dock. Maneuvering is generally the highest auxiliary load mode as the bow thrusters need to be available and used in spurts. The fairway or open sea is generally where the lowest auxiliary

Table A-17: Auxiliary Engines Emission Factors

Sea Load Maneuvering Hotelling Emission Factor Emission Factor Emission Factor Pollutant (g/kW-hr) (g/kW-hr) (g/kW-hr)

PM10 0.25 0.25 0.25 PM2.5 0.23 0.23 0.23 SOURCE: US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009.

Table A-18: Auxiliary Engines Operational Parameters

Marine Vessel Parameters Sea Load Maneuvering Hotelling Auto Carrier Load Factor 0.15 0.45 0.26 Hours per Operation 4 0.5 19.6 Bulk Carrier Load Factor 0.17 0.45 0.10 Hours per Operation 4 0.5 71.1 Tanker Load Factor 0.24 0.33 0.26 Hours per Operation 4 0.5 34.9

SOURCES: US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009, Analysis of Commercial Marine Vessels Emissions and Fuel Consumption Data, February 2000, and Emissions Estimation Methodology for Ocean-Going Vessels, May 2008. In addition to the auxiliary engines that are used to generate electricity for on-board uses, most marine vessels have one or more boilers used for fuel heating and for producing hot water. Boilers are typically not used during transit at sea since vessels are equipped with an exhaust gas recovery system or “economizer” that uses exhaust for heating purposes and therefore the boilers are not needed when the main engines are used. Boilers are used at reduced speeds, during maneuvering and when the vessel is at port and the main engines are shut down.

20 Starcrest Consulting Group, LLC, Port of Long Beach Air Emissions Inventory – 2014, September 2015, http://www.polb.com/environment/air/emissions.asp 21 California Air Resource Board, Fuel Sulfur and Other Operation Requirements for Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline, July 24, 2008, http://www.arb.ca.gov/ports/marinevess/ogv.htm Auxiliary boiler emission factors (Table A-19) were then applied to the various activity data (Table A-20). A usage rate of 0.113 tons of fuel per hour was assumed for the auxiliary boiler.

Table A-19: Auxiliary Boiler Emission Factors

Emission Factor Pollutant (lb/ton fuel)

PM10 0.25 PM2.5 0.23 SOURCE: US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009.

Table A-20: Auxiliary Boiler Operational Parameters

Marine Vessel Parameters Maneuvering Hotelling Auto Carrier Load Factor 0.45 0.26 Hours per Operation 0.5 19.6 Bulk Carrier Load Factor 0.45 0.26 Hours per Operation 0.5 71.1 Tanker Load Factor 0.45 0.26 Hours per Operation 0.5 34.9

SOURCE: US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009.

Tugboats Emission factors were developed for tugboat engines by review of the literature and information specific to the Port of Richmond. Emissions were calculated by multiplying the emission factors by the appropriate measure of activity (such as annual hours of operation).22 Tugboats are used to propel marine vessels to and from the berth. Emissions are based on an average tugboat engine size of 1,493 kW (2,000 hp) and a load factor of 31 percent.23 Two tugs are assumed to operate for each marine vessel at one hour each to maneuver it into the berth. The emission factor is dependent on the fuel used; an average sulfur content of 1.5 percent (marine diesel oil) was assumed.24 Tugboat emission factors (Table A-21) were applied to the various activity data.

22 U.S. Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009, http://epa.gov/cleandiesel/documents/ports-emission-inv-april09.pdf 23 Detroit Diesel specification 4000 Series, http://extranet.detroitdiesel.com/public/specs/4SA419ev0310.pdf. 24 California Air Resource Board, Fuel Sulfur and Other Operation Requirements for Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline, July 24, 2008, http://www.arb.ca.gov/ports/marinevess/ogv.htm Table A-21: Tugboat Emission Factors

Emission Factor Pollutant (g/kW-hr)

PM10 0.32 PM2.5 0.32 SOURCE: US Environmental Protection Agency, Current Methodologies in Preparing Mobile Source Port-Related Emission Inventories, April 2009.

Locomotives Railroad operations are typically described in terms of two different types of operation, line haul and switching. Line haul operations involve long-distance transportation between the Port and points across the country whereas switching is the local movement of railcars to prepare them for line haul transportation or to distribute them to destination terminals upon their arrival. The types of information available for these two types of activity differs – for the on-port switching locomotives, information on each locomotive and its activity (e.g., fuel use and throttle notch setting frequency) can be used to estimate emissions, whereas for the line haul locomotives the information is more general (e.g., in terms of fuel use per ton of cargo and total tons of cargo carried). Published emissions information for switch and line haul locomotive operations in both throttle notch and fuel consumption modes along with facility operational data was used to estimate emissions.25 Locomotives operate differently from other types of mobile sources with respect to how they transmit power from engine to wheels. While most mobile sources use a physical coupling such as a transmission to transfer power from the engine to the wheels, a locomotive’s engine turns a generator or alternator powering an electric motor that, in turn, powers the locomotive’s wheels. The physical connection of a typical mobile source means that the engine’s speed is dictated by the vehicle’s speed through a fixed set of gear ratios, resulting in the highly transient operating conditions (particularly engine speed and load) that characterize mobile source operations. In contrast, the locomotive’s engine and drive system operate more independently, such that the engine can be operated at a particular speed without respect to the speed of the locomotive itself. This allows operation under more steady-state load and speed conditions, and as a result locomotives have been designed to operate in a series of discrete throttle settings called notches, ranging from notch positions one through eight, plus an idle position. Many locomotives also have a feature known as dynamic braking, in which the electric drive engine operates as a generator to help slow the locomotive, with the resistance-generated power being dissipated as heat. While the engine is not generating motive power under dynamic braking, it is generating power to run cooling fans, so this operating condition is somewhat

25 U.S. Environmental Protection Agency, Emission Factors for Locomotives, April 2009, http://www.epa.gov/nonroad/locomotv/420f09025.pdf different from idling. Switch engines typically do not feature dynamic braking. Locomotive switching activities consist of:  Breaking up inbound trains and sorting railcars into contiguous fragments, and delivering the fragments to terminals.  Delivering empty container flat cars to terminals.  Delivering rail cars to non-container facilities, and removing previously delivered rail cars.  Rearranging full and empty railcars to facilitate loading by a terminal.  Picking up outbound containers in less than full train configuration and transporting them to a yard for assembly into full trains – to be transported out of the facility by one of the line haul railroads. Line haul locomotives are typically operated in groups of two to five units, with three or four units being most common, depending on the power requirements of the specific train being pulled and the horsepower capacities of available locomotives. Thus, two higher-horsepower locomotives may be able to pull a train that would take three units with lower power outputs. Locomotives operated in sets are connected such that every engine in the set is operated in unison by an engineer in one of the locomotives. Two line haul engines were assumed to operate simultaneously. For locomotives, emissions were estimated as a function of power demand (expressed in horsepower-hours) multiplied by an emission factor (shown in Table A-22), expressed in terms of grams per horsepower-hour (g/hp-hr), and then applied to the various activity data (Table A-23).

Table A-22: Locomotives Emission Factors

Switch Emission Haul Emission Factor Factor Pollutant (g/hp-hr) (g/hp-hr)

PM10 0.19 0.18 PM2.5 0.18 0.17 SOURCE: U.S. Environmental Protection Agency, Emission Factors for Locomotives, April 2009.

Table A-23: Locomotives Operational Parameters

Parameters Line Haul Switching Load Factor 0.20 0.25 Horsepower 3,200 2,000 Number per day 1 2 SOURCE: Honda Port of Entry at the Point Potrero Marine Terminal, Final Environmental Impact Report. September 2008. David J. Powers and Associates, 830 Marina Way South Residential Project, September 2013. Detroit Diesel Specification 4000 Series. Health Risk Assessment Assumptions 5 Chronic Reference Exposure Level (ug/m3) for DPM Project: Richmond Terminal 3 2.5 Acute Reference Exposure Level (ug/m3) for Acrolien Date: Januaryt 24, 2017 1.1 Cancer Potency Slope Factor (cancer risk per mg/kg-day) for DPM Condition: Project 350 days per year 25,550 days per lifetime 1.3 % Acrolien in Diesel

1090 95th Percentile Daily Breathing Rates (L/kg-day) 0<2 Years 861 95th Percentile Daily Breathing Rates (L/kg-day) 2<9 Years 745 95th Percentile Daily Breathing Rates (L/kg-day) 2<16 Years 335 95th Percentile Daily Breathing Rates (L/kg-day) 16<30 Years 290 95th Percentile Daily Breathing Rates (L/kg-day) 16<70 Years

0.85 fraction of time at home 0<2 Years 0.72 fraction of time at home 2<16 Years 0.73 fraction of time at home 16<70 Years

Exposure Calender Maximum 1-Hour Acrolien Annual PM2.5 Daily Breathing Rates Exposure fraction of time Year Year Concentration (ug/m3) Concentration (ug/m3) (L/kg-day) Factor at home Cancer Risk 1 2016 0.01 0.013 1,090 10.0 0.85 1.83 0.013 Maximum Annual PM2.5 Concentration (ug/m3) 2 2017 0.01 0.013 1,090 10.0 0.85 1.83 0.8 Significance Threshold (ug/m3) 3 2018 0.01 0.013 745 4.75 0.72 0.50 No Significant? 4 2019 0.01 0.013 745 3.00 0.72 0.32 5 2020 0.01 0.013 745 3.00 0.72 0.32 0.00 Chronic Hazard Impact 6 2021 0.01 0.013 745 3.00 0.72 0.32 10 Significance Threshold 7 2022 0.01 0.013 745 3.00 0.72 0.32 No Significant? 8 2023 0.01 0.013 745 3.00 0.72 0.32 9 2024 0.01 0.013 745 3.00 0.72 0.32 0.01 Acute Hazard Impact 10 2025 0.01 0.013 745 3.00 0.72 0.32 10 Significance Threshold 11 2026 0.01 0.013 745 3.00 0.72 0.32 No Significant? 12 2027 0.01 0.013 745 3.00 0.72 0.32 13 2028 0.01 0.013 745 3.00 0.72 0.32 8.3 Cancer Risk (Child) 14 2029 0.01 0.013 745 3.00 0.72 0.32 100 Significance Threshold 15 2030 0.01 0.013 745 3.00 0.72 0.32 No Significant? 16 2031 0.01 0.013 745 3.00 0.72 0.32 17 2032 0.01 0.013 335 1.70 0.73 0.08 2.5 Cancer Risk (Adult) 18 2033 0.01 0.013 335 1.00 0.73 0.05 100 Significance Threshold 19 2034 0.01 0.013 335 1.00 0.73 0.05 No Significant? 20 2035 0.01 0.013 335 1.00 0.73 0.05 21 2036 0.01 0.013 335 1.00 0.73 0.05 9.0 30-Year Exposure Cancer Risk 22 2037 0.01 0.013 335 1.00 0.73 0.05 100 Significance Threshold 23 2038 0.01 0.013 335 1.00 0.73 0.05 No Significant? 24 2039 0.01 0.013 335 1.00 0.73 0.05 25 2040 0.01 0.013 335 1.00 0.73 0.05 26 2041 0.01 0.013 335 1.00 0.73 0.05 27 2042 0.01 0.013 335 1.00 0.73 0.05 28 2043 0.01 0.013 335 1.00 0.73 0.05 29 2044 0.01 0.013 335 1.00 0.73 0.05 30 2045 0.01 0.013 335 1.00 0.73 0.05 Appendix A-4 Greenhouse Gas Setting and Regulatory Context “Global warming” and “global climate change” are the terms used to describe the increase in the average temperature of the earth’s near-surface air and oceans since the mid-20th century and its projected continuation. Warming of the climate system is now considered to be unequivocal (IPCC, 2007), with global surface temperature increasing approximately 1.33 degrees Fahrenheit (°F) over the last 100 years. Continued warming is projected to increase global average temperature between 2 and 11°F over the next 100 years. Natural processes and human actions have been identified as the causes of this warming. The International Panel on Climate Change (IPCC) concludes that variations in natural phenomena such as solar radiation and volcanoes produced most of the warming from pre-industrial times to 1950 and had a small cooling effect afterward. After 1950, however, increasing GHG concentrations resulting from human activity such as fossil fuel burning and deforestation have been responsible for most of the observed temperature increase. These basic conclusions have been endorsed by more than 45 scientific societies and academies of science, including all of the national academies of science of the major industrialized countries. Since 2007, no scientific body of national or international standing has maintained a dissenting opinion. Increases in GHG concentrations in the earth’s atmosphere are thought to be the main cause of human-induced climate change. GHG naturally trap heat by impeding the exit of solar radiation that has hit the earth and is reflected back into space. Some GHG occur naturally and are necessary for keeping the earth’s surface inhabitable. However, increases in the concentrations of these gases in the atmosphere during the last 100 years have decreased the amount of solar radiation that is reflected back into space, intensifying the natural greenhouse effect and resulting in the increase of global average temperature. Gases that trap heat in the atmosphere are referred to as GHG because they capture heat radiated from the sun as it is reflected back into the atmosphere, much like a greenhouse does. The accumulation of GHG has been implicated as the driving force for global climate change. The primary GHG are carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O), ozone, and water vapor.

While the presence of the primary GHG in the atmosphere are naturally occurring, CO2, CH4, and N2O are also emitted from human activities, accelerating the rate at which these compounds occur within earth’s atmosphere. Emissions of CO2 are largely by-products of fossil fuel combustion, whereas methane results from off-gassing associated with agricultural practices and landfills. Other GHG include hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride, and are generated in certain industrial processes.

CO2 is the reference gas for climate change because it is the predominant GHG emitted. The effect that each of the aforementioned gases can have on global warming is a combination of the mass of their emissions and their global warming potential (GWP). GWP indicates, on a pound- for-pound basis, how much a gas is predicted to contribute to global warming relative to how much warming would be predicted to be caused by the same mass of CO2, CH4, and N2O are substantially more potent GHG than CO2, with GWP of 25 and 310 times that of CO2, respectively. In emissions inventories, GHG emissions are typically reported in terms of pounds or metric tons (MT) of CO2 equivalents (CO2e). CO2e are calculated as the product of the mass emitted of a given GHG and its specific GWP. While CH4 and N2O have much higher GWP than CO2, CO2 is emitted in such vastly higher quantities that it accounts for the majority of GHG emissions in CO2e. Fossil fuel combustion, especially for the generation of electricity and powering of motor vehicles, has led to substantial increases in CO2 emissions (and thus substantial increases in atmospheric concentrations of CO2). In pre-industrial times (c. 1860), concentrations of atmospheric CO2 were approximately 280 parts per million (ppm). By August 2013, atmospheric CO2 concentrations had increased to 395 ppm, by over 40 percent above pre-industrial concentrations.1 There is international scientific consensus that human-caused increases in GHG have contributed and will continue to contribute to global warming. There is international scientific consensus that human-caused increases in GHG have and will continue to contribute to global warming. Potential global warming impacts in California may include, but are not limited to, loss in snow pack, sea level rise, more extreme heat days per year, more high ozone days, more large forest fires, and more drought years. Secondary effects are likely to include a global rise in sea level, impacts to agriculture, changes in disease vectors, and changes in habitat and biodiversity.2 City of Richmond General Plan In January 2007, the City of Richmond signed onto the U.S. Mayor’s Climate Protection Agreement, committing to reducing GHG emissions to meet or surpass the Kyoto Protocol targets of a seven percent reduction from 1990 levels by 2012. Additionally, in September 2007, Richmond’s City Council directed staff to develop a comprehensive policy to lead by example in the fight against global warming. On September 16, 2008, the City Council passed a resolution committing to the GHG emissions targets established by California’s AB 32. The City of Richmond is one of a handful of cities that had passed such resolutions. The Richmond General Plan 2030 Energy and Climate Change goals are listed within the following section. Action items are outlined in relation to each of the goals that pertain to sustainability and are relevant to this project.3 Goal EC1: Leadership in Managing Climate Change Take steps to address climate change and to manage its effects. This entails not only pursuing ground-breaking programs and innovative strategies, but educating residents

1 Earth System Research Laboratory, Recent Monthly Mean CO2 at Mauna Lora, www.esrl.noaa.gov/gmd/ccgg/trends/ 2 California Environmental Protectio Agency, 2006 Final Climate Action Team Report to the Governor and Legislature, March 2006. http://www.climatechange.ca.gov/climate_action_team/reports/2006report/2006-04- 03_FINAL_CAT_REPORT.PDF. 3 City of Richmond, General Plan 2030 Energy and Climate Change, Adopted April 25, 2012, http://www.ci.richmond.ca.us/DocumentCenter/Home/View/8813. and businesses about these actions and actively monitoring results to ensure progress in critical areas. Partner with other jurisdictions and organizations to develop effective regional solutions and regulation at regional, state and federal levels. Collaborate with residents, businesses, public agencies and neighboring jurisdictions, in order to meet or exceed state requirements for reductions in GHG emissions. Action EC1.A Climate Action Plan Develop a climate action plan for reducing GHG emissions to meet or exceed state reduction targets. Components of the plan should include: a comprehensive GHG gas emissions inventory and forecast; emissions reduction target(s); assessment of the City’s vulnerability to climate change; climate change resiliency goals; broader sustainability assessment; sustainability targets; strategies and measures to address climate change mitigation, sustainability and adaptation; financing and implementation approaches; a public education and information program; and a program for monitoring and reporting results. Goal EC2 Clean and Efficient Transportation Options Expand the City’s green transportation network by encouraging the use of climate- friendly technology, planning growth around multiple modes of travel and reducing automobile reliance. In addition to promoting improved public transit, partner with private developers to undertake citywide improvements that make active modes of travel, such as walking and bicycling, more comfortable and preferable options. Policy EC2.1 Climate-Friendly Vehicles and Equipment Encourage the use of available climate-friendlier vehicles and equipment to reduce energy use and carbon emissions and support the use of low-emission or renewable fuel vehicles by residents and businesses, public agencies and City government. Policy EC2.2 Climate-Friendly Fuel Support production and distribution of climate-friendlier fuels (when and if any are identified) and identify appropriate locations for fuel storage and distribution. Policy EC2.7 Climate-Friendly Goods Movement Promote the safe and efficient movement of goods by truck, rail and ship to support port operations and industrial uses. Develop strategies and programs to provide adequate infrastructure improvements and maintenance to support industrial operations in Richmond while minimizing impacts on neighborhoods and sensitive uses. Encourage the use of climate-friendly fuel and vehicles in the movement of goods, and encourage carriers to upgrade their fleets. Action EC2.A Climate-Friendly Fuel Using Vehicles Support the use of highly efficient climate-friendly fuel using vehicles, adequate alternative refueling stations and the use of waste for producing fuel where feasible or rational. Action EC2.J Port Emissions Reduction Plan Collaborate with the Port, local industry, regulatory agencies, residents and community organizations to develop a comprehensive emissions reduction plan for ship-operated emissions. Include strategies to reduce emissions from trucks, ships, locomotives and equipment. Enforce existing laws and strengthen regulations to protect human and environmental health and access available funds for clean air projects. Explore use of low-emission vehicles, short-sea shipping service, “cold ironing” and other strategies to reduce emissions. Consider the San Pedro Bay Ports Clean Air Action Plan, developed by the ports of Los Angeles and Long Beach as a model. The Port of Richmond completed a Clean Air Action Plan (CAAP) on June of 2010. The goal of the Port of Richmond CAAP was to develop and recommend feasible, cost-effective strategies and programs to reduce air emissions and health risks from operations at the Port of Richmond, while allowing port development to continue bringing revenue and jobs to the City of Richmond. The CAAP built and expanded upon the recent Honda Port of Entry CAAP by: 1) encompassing the Port of Richmond public facility, including the Point Potrero Marine Terminal; 2) accounting for new state, federal and international regulations of ocean-going vessels, harbor craft, trucks, rail and cargo-handling equipment operating at California Ports; and 3) identifying specific grant funding and low-cost financing available to the Port from the federal, state and regional agencies for goods movement, air quality and energy efficiency improvements.4 Action EC2.K Engine Replacement and Retrofitting Work with the Bay Area Air Quality Management District (BAAQMD) to develop a program to fund diesel engine retrofitting or replacement in existing automobiles, trucks, rail, ships and equipment. Regularly identify feasible technologies that can be applied for retrofitting polluting vehicles. Collaborate with key stakeholders to develop and implement the program. Goal EC3 Sustainable and Efficient Energy Systems Reduce the City’s consumption of energy by encouraging energy conservation, and supporting the consumption of energy produced by climate-friendly technologies. Reduce the City’s overall waste stream by reducing the City’s consumption of goods and materials, and by adopting a zero-waste philosophy.  Renewable Energy: Promote the generation, transmission and use of a range of renewable energy sources such as solar, wind power and waste energy to meet current and future demand and encourage new development and redevelopment projects to generate a portion of their energy needs through renewable sources.

4 City of Richmond, Clean Air Action Plan for the Port of Richmond, June 28, 2010, http://www.ci.richmond.ca.us/DocumentCenter/Home/View/5917  Energy Efficiency and Conservation: Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure and equipment.  Solid Waste Reduction and Recycling: Promote waste reduction and recycling to minimize materials that are processed in landfills.  Water Conservation and Reuse: Promote water conservation and recycled water use. Implement water conservation efforts for households, businesses, industries and public infrastructure. Include measures such as the following: o Require low-flow appliances and fixtures in all new development. o Work with water providers and water conservation agencies to create an incentives program that encourages retrofitting existing development with low-flow water fixtures; o Require new development and landscaped public areas to utilize state-of-the- art irrigation systems that reduce water consumption including graywater systems and rainwater catchment; o Encourage use of drought-tolerant and native vegetation; o Require new plantings be grouped by hydrozones of water needs developed by the Department of Water Resources and the University of California Cooperative Extension; and o Require development project approvals to include a finding that all feasible and cost-effective options for conservation and water reuse are incorporated into project design including graywater systems. Policy EC3.2 Energy Efficiency and Conservation Promote efficient use of energy and conservation of available resources in the design, construction, maintenance and operation of public and private facilities, infrastructure and equipment. Collaborate with partner agencies, utilities and businesses to support a range of energy efficiency, conservation and waste reduction measures including: development and retrofitting of green buildings and infrastructure; installation of energy-efficient appliances and equipment in homes and offices; and heightened awareness of energy and conservation issues. Collaborate with local workforce development programs to train and employ Richmond residents in these other green jobs sectors. Action EC3.C Energy Demand Reduction Work with energy providers to develop strategies that will reduce energy demand and promote energy conservation. Collaborate with neighboring jurisdictions to share best practices and implement regional programs to help residents and businesses meet regional demand reduction targets. Explore establishing special assessments on property tax bills which would enable building owners to finance energy efficiency retrofits and improvements over an extended period of time. Action EC3.E Construction and Demolition Ordinance Develop an ordinance covering all construction and demolition activities that meets and exceeds minimal state building code diversion for beneficial reuse standards. Encourage preservation and readaptation of existing structures over replacement and deconstruction and reuse of building materials over demolition. Goal EC4 Sustainable Development Reduce energy consumption by promoting sustainable land uses and development patterns. Pursue infill development opportunities and encourage the construction of higher-density, mixed-use projects around existing public transit infrastructure, schools, parks, neighborhood-serving retail and other critical services. Incorporate ecologically sustainable practices and materials into new development, building retrofits and streetscape improvements.  Infill Development: Promote infill development throughout the City, especially in the targeted redevelopment areas of Central Richmond and avoid the displacement of existing residents. Promote new development and redevelopment projects to provide community amenities and uses that serve priority community needs and retain the existing urban limit lines.  Compact Walkable Neighborhoods and Livable Streets: Promote safe and walkable neighborhoods and inter-connected streets through the design of streetscapes, public gathering places and all types of physical development.  Green Buildings and Landscaping: Require energy and resource efficient buildings and landscaping in all public and private development projects. Require that newly constructed or renovated City-owned and private buildings and structures comply with the City’s adopted Green Building Ordinances.5  Green Infrastructure: Develop green infrastructure standards that relies on natural processes for storm water drainage, groundwater recharge and flood management. Goal EC5 Community Revitalization and Economic Development Transform Richmond into a healthy community where green industries and businesses can flourish. Support sustainable businesses and practices that provide both community and environmental benefits while stimulating job and revenue growth. Policy EC5.3 Air Quality Support regional policies and efforts that improve air quality to protect human and environmental health and minimize disproportionate impacts on sensitive population groups. Work with businesses and industry, residents and regulatory agencies to

5 City of Richmond Municipal Code, Commercial and Residential Green Building Standards, http://www.energy.ca.gov/title24/2008standards/ordinances/richmond/2009-12- 16_Richmond_Green_Building_Ordinance.pdf reduce the impact of direct, indirect and cumulative impacts of stationary and non- stationary sources of pollution such as industry, the Port, railroads, diesel trucks and busy roadways. Fully utilize Richmond’s police power to regulate industrial and commercial emissions. Ensure that sensitive uses such as schools, childcare centers, parks and playgrounds, housing and community gathering places are protected from adverse impacts of emissions. Continue to work with stakeholders to reduce impacts associated with air quality on disadvantaged neighborhoods and continue to participate in regional planning efforts with nearby jurisdictions and the BAAQMD to meet or exceed air quality standards. Support regional, state and federal efforts to enforce existing pollution control laws and strengthen regulations. Action EC5.C Air Quality Monitoring and Reporting Program Work with the BAAQMD and other government agencies to establish and identify funding for a citywide air quality monitoring and reporting program. The air quality monitoring and reporting program would assess the cumulative impact of air pollution and toxins on human and environmental health and monitor exposure of sensitive uses such as schools, childcare centers, parks and playgrounds, housing and community gathering places. Collaborate with the County Health Services Department, the BAAQMD and state agencies to establish baseline exposures and document health effects associated with monitored baseline exposures and develop provisions to hold businesses and operations financially accountable for their impacts on the environment or community due to air pollution exceeding legal thresholds. Goal EC6 Climate-Resilient Communities While the impacts of climate change on local communities are uncertain, to the extent possible, prepare to respond to and protect residents and businesses from increased risks of natural disasters such as flooding or drought. City of Richmond Climate Action Plan A Climate Action Plan (CAP) has been developed by the City of Richmond and adopted in October of 2016.6. The Richmond CAP is a roadmap for how the City will reduce energy consumption and GHG emissions to meet state GHG reduction targets. The CAP will also help the City to prepare for the potential impacts of climate change on public health, infrastructure, ecosystems, and public spaces. The CAP will inventory the City’s emissions, establish an emissions reduction target, and identify City and community actions to reduce emissions. In conjunction with the City’s General Plan, the CAP will provide a vision for green businesses, healthy homes, sustainable schools, active transportation, and community resilience. The CAP will elevate health and equity as a priority in the selection of climate action measures, establishing a policy framework to support a healthy, vibrant, and equitable City. The City’s baseline year (2005) community inventory shows that industries, businesses, and residents in the city generated over 5.8 million metric tons (MT) of CO2e, and is made up of

6 City of Richmond, Climate Action Plan, Adopted October 2016, http://www.ci.richmond.ca.us/DocumentCenter/View/40636 various sources. Of the sources in this total, the largest contributors include the commercial/industrial sector and transportation-related emissions, which contribute 88 percent and 10 percent, respectively.7 A recent study of consumption-based GHG Inventories of San Francisco Bay Area neighborhoods, cities and counties indicates that the City of Richmond has the lowest carbon footprint per household (37 MT of CO2e) compared to the 40 other municipalities the San Francisco Bay Area cities analyzed in the study.8 In 2013 the City of Richmond joined Marin Clean Energy (MCE) to increase renewable energy choices for local businesses and residents. A “Community Choice Aggregation” program, MCE procures electricity from renewable sources – solar, wind, bioenergy, geothermal, and small hydro – and then partners with PG&E to deliver electricity to homes and businesses. As of 2015, over 80 percent of Richmond’s electrical customers have enrolled in MCE; of these, 99 percent are enrolled in the Light Green Option that sources 56 percent of its energy supply from renewable energy sources, and less that 1 percent were enrolled in the Deep Green option, which provides a 100 percent renewable energy option. California Air Pollution Control Officers Association The California Air Pollution Control Officers Association (CAPCOA), representing California's 35 local air districts, launched the CAPCOA Greenhouse Gas Reduction Exchange (GHG Rx).9 The Exchange provides a reliable, low-cost, secure platform to encourage locally generated, high quality GHG emission reduction credits that can be used to meet CEQA or other compliance requirements. The GHG Rx features locally generated and properly validated GHG emission reduction credits from voluntary projects within California and allow interaction between those who create the credits, potential buyers and funding organizations. Assembly Bill 32 (California Global Warming Solutions Act of 2006) California passed the California Global Warming Solutions Act of 2006 (AB 32; California Health and Safety Code Division 25.5, Sections 38500 - 38599). AB 32 establishes regulatory, reporting, and market mechanisms to achieve quantifiable reductions in GHG emissions and establishes a cap on statewide GHG emissions. AB 32 requires that statewide GHG emissions be reduced to 1990 levels by 2020. This reduction will be accomplished by enforcing a statewide cap on GHG emissions that will be phased in starting in 2012. To effectively implement the cap, AB 32 directs CARB to develop and implement regulations to reduce statewide GHG emissions from stationary sources. AB 32 specifies that regulations adopted in response to AB 1493 should be used to address GHG emissions from vehicles. However, AB 32 also includes language stating that if the AB 1493 regulations cannot be implemented, then CARB should develop new regulations to control vehicle GHG emissions under the authorization of AB 32.

7 City of Richmond, General Plan 2030 Energy and Climate Change, Adopted April 25, 2012, http://www.ci.richmond.ca.us/DocumentCenter/Home/View/8813. 8 Jones, Christopher and Kammen, Daniel, 2015.A Consumption-Based Greenhouse Gas Inventory of San Francisco Bay Area Neighborhoods, Cities and Counties, December 15, 2015. http://escholarship.org/uc/item/2sn7m83z 9 CAPCOA Greenhouse Gas Exchange, http://xappprod.aqmd.gov/ghgrx. AB 32 requires CARB to adopt a quantified cap on GHG emissions representing 1990 emissions levels and disclose how it arrived at the cap; institute a schedule to meet the emissions cap; and develop tracking, reporting, and enforcement mechanisms to ensure that the state reduces GHG emissions enough to meet the cap. AB 32 also includes guidance on instituting emissions reductions in an economically efficient manner, along with conditions to ensure that businesses and consumers are not unfairly affected by the reductions. Using these criteria to reduce statewide GHG emissions to 1990 levels by 2020 would represent an approximate 25 to 30 percent reduction in current emissions levels. However, CARB has discretionary authority to seek greater reductions in more significant and growing GHG sectors, such as transportation, as compared to other sectors that are not anticipated to significantly increase emissions. Under AB 32, CARB must adopt regulations to achieve reductions in GHG to meet the 1990 emissions cap by 2020. In September of 2016, the AB 32 was extended to achieve reductions in GHG of 40 percent below 1990 levels by 2030. The new plan, outlined in SB 32, involves increasing renewable energy use, putting more electric cars on the road, improving energy efficiency, and curbing emissions from key industries. Climate Change Scoping Plan In October of 2013, the CARB submitted the First Update to the Climate Change Scoping Plan for public review and comment. The First Update to the Scoping Plan was approved by the CARB on May 22, 2014, and builds upon the initial Scoping Plan with new strategies and recommendations. The First Update identifies opportunities to leverage existing and new funds to further drive GHG emission reductions through strategic planning and targeted low carbon investments. The First Update defines CARB’s climate change priorities for the next five years, and also sets the groundwork to reach long-term goals set forth in Executive Orders S-3-05 and B-16-2012. The Update highlights California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals defined in the initial Scoping Plan. It also evaluates how to align the State's "longer-term" GHG reduction strategies with other State policy priorities for water, waste, natural resources, clean energy, transportation, and land use. In the First Update to the Climate Change Scoping Plan, nine key focus areas were identified (energy, transportation, agriculture, water, waste management, and natural and working lands), along with short-lived climate pollutants, green buildings, and the cap-and-trade program. These key focus areas have overlapping and complementary interests that will require careful coordination in California’s future climate and energy policies. These focus areas were selected to address issues that underlie multiple sectors of the economy. As such, each focus area is not contained to a single economic sector, but has far-reaching impacts within many economic sectors. California Green Building Standard Code On January 12, 2010, the State Building Standards Commission unanimously adopted updates to the California Green Building Standards Code, which went into effect on January 1, 2011. CALGreen is a comprehensive and uniform regulatory code for all residential, commercial and school buildings. CALGreen does not prevent a local jurisdiction from adopting a more stringent code as state law provides methods for local enhancements. CALGreen recognizes that many jurisdictions have developed existing construction and demolition ordinances, and defers to them as the ruling guidance provided they provide a minimum 50-percent diversion requirement. CALGreen also provides exemptions for areas not served by construction and demolition recycling infrastructure. State building code provides the minimum standard, which buildings need to meet in order to be certified for occupancy. Enforcement is generally through the local building official. The development of CALGreen is intended to (1) cause a reduction in GHG emissions from buildings; (2) promote environmentally responsible, cost-effective, healthier places to live and work; (3) reduce energy and water consumption; and (4) respond to the directives by the Governor. In short, CALGreen is established to reduce construction waste; make buildings more efficient in the use of materials and energy; and reduce environmental impacts during and after construction. CALGreen contains requirements for construction site selection, storm water control during construction, construction waste reduction, indoor water use reduction, material selection, natural resource conservation, site irrigation conservation, and more. CALGreen provides for design options allowing the designer to determine how best to achieve compliance for a given site or building condition. CALGreen also requires building commissioning, which is a process for verifying that all building systems, like heating and cooling equipment and lighting systems, are functioning at their maximum efficiency. The following provides examples of CALGreen requirements:  Designated parking. Provide designated parking in commercial projects for any combination of low-emitting, fuel-efficient and carpool/van pool vehicles.  Recycling by Occupants. Provide readily accessible areas that serve the entire building and are identified for the depositing, storage and collection of nonhazardous materials for recycling.  Construction waste. A minimum 50-percent diversion of construction and demolition waste from landfills, increasing voluntarily to 65 and-75 percent for new homes and 80- percent for commercial projects. All (100 percent) of trees, stumps, rocks and associated vegetation and soils resulting from land clearing shall be reused or recycled.  Wastewater reduction. Each building shall reduce the generation of wastewater by installation of water-conserving fixtures or using nonpotable water systems.  Water use savings. 20-percent mandatory reduction in indoor water use with voluntary goal standards for 30, 35, and 40-percent reductions.  Water meters. Separate water meters for buildings in excess of 50,000 square feet or buildings projected to consume more than 1,000 gallons per day.  Irrigation efficiency. Moisture-sensing irrigation systems for larger landscaped areas.  Materials pollution control. Low-pollutant emitting interior finish materials such as paints, carpet, vinyl flooring, and particleboard.  Building commissioning. Mandatory inspections of energy systems (i.e. heat furnace, air conditioner, mechanical equipment) for nonresidential buildings over 10,000 square feet to ensure that all are working at their maximum capacity according to their design efficiencies. Greenhouse Gas Emission Estimates

Worldwide emissions of GHG in 2011 were 45 billion tons of CO2e per year.10 This value includes ongoing emissions from industrial and agricultural sources, but excludes emissions from land use changes. The International Maritime Organization (IMO) estimates that GHG emissions from shipping were equal to 2.2 percent of the global GHG emissions.11 In 2014, the United States emitted about 6.87 billion tons of CO2e per year or about 21.5 tons per person per year. Of the five major sectors nationwide — residential and commercial, industrial, agriculture, transportation, and electricity— electricity accounts for the highest fraction of GHG emissions (approximately 30 percent), closely followed by transportation (approximately 26 percent); these emissions from energy are primarily generated from the combustion of fossil fuels (approximately 82 percent), and emissions from transportation are entirely generated from direct fossil fuel combustion.12 United States emissions increased by three percent from 2013 to 2014. Recent trends can be attributed to multiple factors including increased emissions from electricity generation, an increase in miles traveled by on-road vehicles, an increase in industrial production and emissions in multiple sectors, and year-to-year changes in the prevailing weather. In 2014, California emitted approximately 441.5 million tons of CO2e. This represents about 6.4 percent of total U.S. emissions. This large number is due primarily to the sheer size of California compared to other states. California’s gross emissions of GHG decreased by 5.3 percent from 466.3 million metric tons of CO2e in 2000 to 441.5 million metric tons in 2014, with a maximum of 492.7 million metric tons in 2004. By contrast, at 11.4 tons per person per year, California has one of the lowest per capita GHG emission rates in the country.13 This is in part due to the success of the state’s energy efficiency and renewable energy programs and commitments that have lowered the GHG emissions rate of growth by more than half of what it would have been otherwise.14 Another factor that has reduced California’s fuel use and GHG emissions is its mild climate compared to that of many other states.

10 Climate Analysis Indicator Tool (CAIT), 2014, www.cait.wri.org 11 International Maritime Organization, Third IMO GHG Study 2014 Executive Summary and Final Report, 2015, http://www.imo.org/en/OurWork/Environment/PollutionPrevention/AirPollution/Documents/Third%20Greenhous e%20Gas%20Study/GHG3%20Executive%20Summary%20and%20Report.pdf 12 United States Environmental Protections Agency, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2014, www.epa.gov/ghgemissions/us-greenhouse-gas-inventory-report-1990-2014 13 California Air Resources Board, Emissions Trends Report, June 2016, www.arb.ca.gov/cc/inventory/data/data.htm 14 California Energy Commission, Inventory of California Greenhouse Gas Emissions and Sinks: 1990 to 2004, www.energy.ca.gov/2006publications/CEC-600- 2006-013/CEC-600-2006-013-SF.PDF The latest CARB inventory also reports that the composition of gross climate change pollutant emissions in California in 2016 (expressed as CO2e) were as follows:

 CO2 accounted for 84.3 percent;

 CH4 accounted for 9.0 percent;

 N2O accounted for 3.8 percent; and  Fluorinated gases (HFCs, PFC, and SF6) accounted for 3.9 percent. Of these gases, CARB found that transportation is the source of approximately 37 percent of the state’s GHG emissions, followed by industrial sources at 24 percent and electricity generation (both in-state and out-of-state) at 20 percent. Agriculture is the source of approximately 8 percent, and residential activity is the source of about 6 percent, followed by commercial activities at 5 percent.15 In the San Francisco Bay Area, the last inventory prepared by the BAAQMD; indicates that the transportation sector and industrial/commercial sector represent the largest sources of GHG emissions, accounting for 39.7 percent and 35.7 percent, respectively, of the Bay Area’s 86.6 million tons of CO2e in 2011. Electricity/co-generation sources account for approximately 14 percent of the Bay Area’s GHG emissions, followed by residential fuel usage at approximately 7.7 percent. Off-road equipment sources currently account for approximately 1.5 percent of total Bay Area GHG emissions.16 The City of Richmond published a community-wide GHG emissions inventory for the year of 2005.17 The inventory attributed the largest sources of GHG emissions to commercial/industrial sources such as natural gas and electrical (87.8 percent) and transportation (8.7 percent). The City of Richmond emitted approximately 5,853,020 metric tons of CO2e in 2005. Thresholds of Significance Separate thresholds of significance are established for operational GHG emissions from stationary sources (such as generators, furnaces, and boilers) and non-stationary sources (such as on-road vehicles). As no threshold has been established for construction-related emissions, the operational emissions thresholds apply. The threshold for stationary sources is 10,000 metric tons of CO2e per year (i.e., emissions above this level may be considered significant). For non- stationary sources, three separate thresholds have been established:  Compliance with a Qualified Greenhouse Gas Reduction Strategy (i.e., if a project is found to be out of compliance with a Qualified Greenhouse Gas Reduction Strategy, its GHG emissions may be considered significant); or

 1,100 metric tons of CO2e per year (i.e., emissions above this level may be considered significant); or

15 California Air Resources Board, Emissions Trends Report, June 2016, www.arb.ca.gov/cc/inventory/data/data.htm 16 Bay Area Air Quality Management District, Bay Area Emissions Inventory, Adopted June 2011, Updated May 2012. www.baaqmd.gov/~/media/files/planning-and-research/ceqa/baaqmd-ceqa-guidelines_final_may-2012.pdf?la=en 17 City of Richmond, 2005 Greenhouse Gas Emissions Inventory, February 2009. http://www.ci.richmond.ca.us/DocumentCenter/Home/View/4279.  4.6 metric tons of CO2e per service population per year (i.e., emissions above this level may be considered significant). Service population is the sum of residents plus employees expected for a development project.