IV. ENVIRONMENTAL IMPACT ANALYSIS C. AIR QUALITY
This section examines the degree to which the proposed project may result in significant adverse changes to air quality. As the proposed project is an expansion of an existing building, the emissions associated with the expansion were calculated and are described in this section. Existing building emissions are also provided in this section. Both short-term construction emissions occurring from activities such as demolition and building construction, as well as long-term effects related to the ongoing operation of the proposed project are discussed in this section. The analysis contained herein focuses on air pollution from two perspectives: daily emissions and pollutant concentrations. “Emissions” refer to the actual quantity of air pollutants emitted measured in pounds per day (ppd). “Concentrations” refer to the amount of pollutant material per volumetric unit of air and are measured in parts per million (ppm) or micrograms per cubic meter (µg/m3).
The potential for the proposed project to conflict with or obstruct implementation of the applicable air quality plan, to violate an air quality standard or contribute substantially to an existing or projected air quality violation, to result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment, to expose sensitive receptors to substantial pollutant concentrations, and to create objectionable odors affecting a substantial number of people are also discussed. Documents used in the preparation of this section include the South Coast Air Quality Management District (SCAQMD) CEQA Air Quality Handbook,1 the SCAQMD Localized Significance Threshold (LST) Methodology2 and the 2007 Air Quality Management Plan (AQMP)3, as amended, federal and State regulations and guidelines, as well as the Traffic Study for the proposed project conducted by Crain & Associates (see Appendix K to this Draft EIR).
ENVIRONMENTAL SETTING
The project site is located within the South Coast Air Basin (Basin), named so because of its geographical formation is that of a basin, with the surrounding mountains trapping the air and its pollutants in the valleys or basins below. This area includes all of Orange County and the non-desert portions of Los Angeles, San Bernardino, and Riverside Counties. The air quality within the Basin is primarily influenced by a wide range of emissions sources, such as dense population centers, heavy vehicular traffic, industry, and meteorology.
1 South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993.
2 South Coast Air Quality Management District, Localized Significance Threshold Methodology, July 2008.
3 South Coast Air Quality Management District, Air Quality Management Plan, SCAQMD, June 2007.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-1
City of Los Angeles November 2008
Climate4
Air quality is affected by both the rate and location of pollutant emissions and by meteorological conditions that influence the movement and dispersal of pollutants. Atmospheric conditions such as wind speed, wind direction, and air temperature gradients, along with local topography, provide the link between air pollutant emissions and air quality.
The distinctive climate of the Basin is determined by its terrain and geographic location. The Basin is a coastal plain with connecting broad valleys and low hills, bounded by the Pacific Ocean to the southwest and high mountains around the rest of its perimeter. The general region lies in the semi-permanent high- pressure zone of the eastern Pacific, resulting in a mild climate tempered by cool sea breezes with light average wind speeds. The usually mild climatological pattern is interrupted occasionally by periods of extremely hot weather, winter storms, or Santa Ana winds.
The vertical dispersion of air pollutants in the Basin is hampered by the presence of persistent temperature inversions. High-pressure systems, such as the semi-permanent high-pressure zone in which the Basin is located, are characterized by an upper layer of dry air that warms as it descends, restricting the mobility of cooler marine-influenced air near the ground surface, and resulting in the formation of subsidence inversions. Such inversions restrict the vertical dispersion of air pollutants released into the marine layer and, together with strong sunlight, can produce worst-case conditions for the formation of photochemical smog. The basin wide occurrence of inversions at 3,500 feet above sea level or less averages 191 days per year.
The atmospheric pollution potential of an area is largely dependent on winds, atmospheric stability, solar radiation, and terrain. The combination of low wind speeds and low inversions produces the greatest concentration of air pollutants. On days without inversions, or on days of winds averaging over 15 miles per hour (mph), smog potential is greatly reduced.
Air Pollutants
Air pollutant emissions within the Basin are generated by stationary and mobile sources. Stationary sources can be divided into two major subcategories: point and area sources. Point sources usually require permit to operate from the SCAQMD, occur at specific identified locations, and are usually associated with large buildings, manufacturing, and industry. Examples of point sources include boilers or combustion equipment that produce electricity or generate heat, such as heating, ventilation, and air conditioning (HVAC) units. In contrast, area sources are widely distributed, produce many small emissions, and do not require permits to operate from the SCAQMD. Examples of area sources include residential and commercial water heaters, painting operations, portable generators, lawn mowers,
4 South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-2
City of Los Angeles November 2008
agricultural fields, landfills, and consumer products, such as lighter fluid and hairspray, the area-wide use of which contributes to regional air pollution. Mobile source emissions are emissions from motor vehicles, including tailpipe and evaporative emissions, and are classified as either on-road or off-road. On-road sources are those that are legally operated on roadways and highways. Off-road sources include aircraft, ships, trains, racecars, and construction vehicles.
Mobile sources account for the majority of the air pollutant emissions within the Basin. However, air pollutants can also be generated by the natural environment, such as when fine dust particles are pulled off the ground surface and suspended in the air during high winds.
Seven air pollutants have been identified by the U.S. Environmental Protection Agency (USEPA) as being of concern nationwide and classified as criteria pollutants: carbon monoxide (CO); ozone (O3); nitrogen dioxide (NO2); particulate matter equal to or less than 10 microns in size (PM10), which is also called respirable particulate or suspended particulate; fine particulate matter equal to or less than 2.5 microns in size (PM2.5); sulfur dioxide (SO2); and lead (Pb). These pollutants are collectively referred to as criteria pollutants because scientific-based (i.e., human health) criteria were used to establish permissible levels. A brief description of each of these pollutants including health effects is described below.5,6
• Ozone (O3) is a highly reactive and unstable gas that is formed when reactive organic gases
(ROGs) (a subset of volatile organic compounds [VOCs]) and nitrogen oxides (NOx), both byproducts of internal combustion engine exhaust, undergo slow photochemical reactions in the presence of sunlight. Ozone concentrations are generally highest during the summer months when conditions are favorable to the formation of this pollutant due to exposure to direct sunlight that initiates the photochemical reaction, light wind (limited air dispersion), and warm temperatures.
Individuals exercising outdoors, children and people with preexisting lung disease such as asthma and chronic pulmonary lung disease are considered to be the most susceptible sub-groups for ozone effects. Short-term exposures (lasting for a few hours) to ozone at levels typically observed in Southern California can result in breathing pattern changes, reduction of breathing capacity, increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes. Elevated ozone levels are associated with increased school absences. In
5 The descriptions of the physical properties of the criteria pollutants are taken from South Coast Air Quality Management District CEQA Air Quality Handbook, 1993.
6 The descriptions of the health effects of the criteria pollutants are taken from South Coast Air Quality Management District’s “Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning” document, May 2005 (South Coast Air Quality Management District 2005).
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-3
City of Los Angeles November 2008
recent years, a correlation between elevated ambient ozone levels and increases in daily hospital admission rates, as well as mortality, has also been reported. An increased risk for asthma has been found in children who participate in multiple sports and live in high ozone communities.
Ozone exposure under exercising conditions is known to increase the severity of the above mentioned observed responses. Animal studies suggest that exposures to a combination of pollutants that include ozone may be more toxic than exposure to ozone alone. Although lung volume and resistance changes observed after a single exposure diminish with repeated exposures, biochemical and cellular changes appear to persist, which can lead to subsequent lung structural changes.
• Carbon Monoxide (CO) is a colorless, odorless gas produced by the incomplete combustion of carbon-containing fuels, such as gasoline or wood. CO concentrations tend to be the highest during the winter morning, when little to no wind and surface-based inversions trap the pollutant at ground levels. Because CO is emitted directly from internal combustion engines, unlike ozone, motor vehicles operating at slow speeds are the primary source of CO in the Basin. The highest ambient CO concentrations are generally found near congested transportation corridors and intersections.
Individuals with a deficient blood supply to the heart are the most susceptible to the adverse effects of CO exposure. The effects observed include earlier onset of chest pain with exercise, and electrocardiograph changes indicative of worsening oxygen supply to the heart.
Inhaled CO has no direct toxic effect on the lungs, but exerts its effect on tissues by interfering with oxygen transport by competing with oxygen to combine with hemoglobin present in the blood to form carboxyhemoglobin (COHb). Hence, conditions with an increased demand for oxygen supply can be adversely affected by exposure to CO. Individuals most at risk include patients with diseases involving heart and blood vessels, fetuses, and patients with chronic hypoxemia (oxygen deficiency) as seen in high altitudes.
Reduction in birth weight and impaired neurobehavioral development has been observed in animals chronically exposed to CO resulting in COHb levels similar to those observed in smokers. Recent studies have found increased risks for adverse birth outcomes with exposure to elevated CO levels. These include pre-term births and heart abnormalities. Additional research is needed to confirm these results.
• Respirable Particulate Matter (PM10) consists of extremely small, suspended particles or droplets 10 microns or smaller in diameter, respectively. Some sources of particulate matter, like pollen and windstorms, are naturally occurring. However, in populated areas, most respirable particulate matter is caused by road dust, diesel soot, combustion products, abrasion of tires and brakes, and construction activities.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-4
City of Los Angeles November 2008
A consistent correlation between elevated ambient PM10 levels and an increase in mortality rates, respiratory infections, number and severity of asthma attacks and the number of hospital admissions has been observed in different parts of the United States and various areas around the world. In recent years, some studies have reported an association between long-term exposure to air pollution dominated by fine particles and increased mortality, reduction in life-span, and an increased mortality from lung cancer.
The elderly, people with pre-existing respiratory or cardiovascular disease and children appear to
be more susceptible to the effects of PM10.
• Fine Particulate Matter (PM2.5) consisting of particles less than 2.5 micrometers is believed to pose the greatest health risks as it can lodge deeply into the lungs due to its small size. Sources of
PM2.5 include all types of combustion activities (motor vehicles, power plants, wood burning,
etc.) and certain industrial processes. Control of PM2.5 is achieved primarily through the control of emissions form point sources, such as power plants, improved engine efficiency, and improved fuel formulations.
A consistent correlation between elevated ambient PM2.5 levels and an increase in mortality rates, respiratory infections, number and severity of asthma attacks and the number of hospital admissions has been observed in different parts of the United States and various areas around the world. In recent years, some studies have reported an association between long-term exposure to air pollution dominated by fine particles and increased mortality, reduction in life-span, and an increased mortality from lung cancer.
Daily fluctuations in fine particulate matter concentration levels have also been related to hospital admissions for acute respiratory conditions in children, to school and kindergarten absences, to a decrease in respiratory lung volumes in normal children and to increased medication use in children and adults with asthma. Recent studies show lung function growth in children is reduced with long-term exposure to particulate matter.
The elderly, people with pre-existing respiratory or cardiovascular disease and children appear to
be more susceptible to the effects of PM2.5.
• Nitrogen dioxide (NO2) is a nitrogen oxide compound (NOx) that is produced by the combustion of fossil fuels, such as in internal combustion engines (both gasoline and diesel powered), as well
as point sources, especially power plants. Of the seven types of NOx, NO2 is the most abundant
in the atmosphere. As ambient concentrations of NO2 are related to traffic density, commuters in
heavy traffic may be exposed to higher concentrations of NO2 than those indicated by regional monitors.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-5
City of Los Angeles November 2008
Population-based studies suggest that an increase in acute respiratory illness, including infections
and respiratory symptoms in children (not infants), is associated with long-term exposures to NO2 at levels found in homes with gas stoves, which are higher than ambient levels found in Southern California. Increase in resistance to air flow and airway contraction is observed after short-term
exposure to NO2 in healthy subjects. Larger decreases in lung functions are observed in individuals with asthma or chronic obstructive pulmonary disease (e.g., chronic bronchitis, emphysema) than in healthy individuals, indicating a greater susceptibility of these sub-groups.
In animals, exposure to levels of NO2 considerably higher than ambient concentrations results in increased susceptibility to infections, possibly due to the observed changes in cells involved in maintaining immune functions. The severity of lung tissue damage associated with high levels of
ozone exposure increases when animals are exposed to a combination of O3 and NO2.
• Sulfur dioxide (SO2) is a colorless, extremely irritating gas or liquid. It enters the atmosphere as a pollutant mainly as a result of burning high sulfur-content fuel oils and coal and from chemical processes occurring at chemical plants and refineries. When sulfur dioxide oxidizes in the
atmosphere, it forms sulfates (SO4). Collectively, these pollutants are referred to as sulfur oxides
(SOx).
A few minutes exposure to low levels of SO2 can result in airway constriction in some asthmatics, all of whom are sensitive to its effects. In asthmatics, increase in resistance to air flow, as well as reduction in breathing capacity leading to severe breathing difficulties, are observed after acute
exposure to SO2. In contrast, healthy individuals do not exhibit similar acute responses even after
exposure to higher concentrations of SO2.
Animal studies suggest that despite SO2 being a respiratory irritant, it does not cause substantial lung injury at ambient concentrations. However, very high levels of exposure can cause lung edema (fluid accumulation), lung tissue damage, and sloughing off of cells lining the respiratory tract.
Some population-based studies indicate that the mortality and morbidity effects associated with
fine particles show a similar association with ambient SO2 levels. In these studies, efforts to
separate the effects of SO2 from those of fine particles have not been successful. It is not clear whether the two pollutants act synergistically or one pollutant alone is the predominant factor.
• Lead (Pb) occurs in the atmosphere as particulate matter. The combustion of leaded gasoline is the primary source of airborne lead in the Basin. The use of leaded gasoline is no longer permitted for on road motor vehicles, so the majority of such combustion emissions are associated with off-road vehicles such as race cars. However, because it was emitted in large amounts from vehicles when leaded gasoline was used for on-road motor vehicles, lead is present in many urban soils and can get re-suspended in the air. Other sources of lead include the
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-6
City of Los Angeles November 2008
manufacturing and recycling of batteries, paint, ink, ceramics, ammunition, metal smelters (including secondary lead smelters), and metal processors.
Fetuses, infants, and children are more sensitive than others to the adverse effects of lead exposure. Exposure to low levels of lead can adversely affect the development and function of the central nervous system, leading to learning disorders, distractibility, inability to follow simple commands, and lower intelligence quotient. In adults, increased lead levels are associated with increased blood pressure.
Lead poisoning can cause anemia, lethargy, seizures and death. It appears that there are no direct effects of lead on the respiratory system. Lead can be stored in the bone from early-age environmental exposure, and elevated blood lead levels can occur due to breakdown of bone tissue during pregnancy, hyperthyroidism (increased secretion of hormones from the thyroid gland) and osteoporosis (breakdown of bony tissue). Fetuses and breast-fed babies can be exposed to higher levels of lead because of previous environmental lead exposure of their mothers.
California has also established standards for sulfates, visibility reducing particles, hydrogen sulfide, and vinyl chloride. However, these pollutants are not directly monitored in the Basin.7
• Sulfates are the fully oxidized ionic form of sulfur. Sulfates occur in combination with metal and/or hydrogen ions. In California, emissions of sulfur compounds occur primarily from the combustion of petroleum-derived fuels (e.g., gasoline and diesel fuel) that contain sulfur. This
sulfur is oxidized to SO2 during the combustion process and subsequently converted to sulfate
compounds in the atmosphere. The conversion of SO2 to sulfates takes place comparatively rapidly and completely in urban areas of California due to regional meteorological features.
Elevated levels of sulfate decrease ventilatory function, aggravate asthmatic symptoms, and increase risk of cardio-pulmonary disease. Sulfates are particularly effective in degrading visibility, and, due to fact that they are usually acidic, can harm ecosystems and damage materials and property.
• Visibility-reducing particles consist of suspended particulate matter, which is a complex mixture of tiny particles that consists of dry solid fragments, solid cores with liquid coatings, and small droplets of liquid. These particles vary greatly in shape, size and chemical composition, and can be made up of many different materials such as metals, soot, soil, dust, and salt. Reduction in visibility-reducing particulates limits the frequency and severity of visibility impairment due to regional haze.
7 Visibility reducing particles are indirectly monitored as PM10 and PM2.5.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-7
City of Los Angeles November 2008
• Hydrogen sulfide is a colorless gas with the odor of rotten eggs. It is formed during bacterial decomposition of sulfur-containing organic substances. Also, it can be present in sewer gas and some natural gas, and can be emitted as the result of geothermal energy exploitation. Breathing hydrogen sulfide at elevated levels will result in exposure to a very disagreeable odor.
• Vinyl chloride, a chlorinated hydrocarbon, is a colorless gas with a mild, sweet odor. Most vinyl chloride is used to make polyvinyl chloride (PVC) plastic and vinyl products. Vinyl chloride has been detected near landfills, sewage plants, and hazardous waste sites, due to microbial breakdown of chlorinated solvents.
Short-term exposure to high levels of vinyl chloride in air causes central nervous system effects, such as dizziness, drowsiness, and headaches. Long-term exposure to vinyl chloride through inhalation and oral exposure causes in liver damage. Cancer is a major concern from exposure to vinyl chloride via inhalation. Vinyl chloride exposure has been shown to increase the risk of angiosarcoma, a rare form of liver cancer in humans.
In accordance with CEQA requirements and the CEQA review process, the Lead Agency assesses the air quality impacts of new development projects. The Lead Agency relies on the expertise of the SCAQMD and utilizes the CEQA Air Quality Handbook as the guidance document for project sites within its jurisdiction. Since sulfates, visibility reducing particles, hydrogen sulfide and vinyl chloride are neither monitored by the SCAQMD nor addressed in SCAQMD’s CEQA Air Quality Handbook, they are not considered to be pollutants of concern in the Basin; therefore, they are not evaluated or discussed further in this EIR.
In addition to the criteria pollutants, toxic air contaminants8 and greenhouse gases9 are of concern.
• Toxic Air Contaminants (TACs) refer to a diverse group of air pollutants that are capable of causing chronic (i.e., of long duration) and acute (i.e., severe but of short duration) adverse effects on human health. Health effects include carcinogenic and non-carcinogenic impacts.
They include both organic and inorganic chemical substances that may be emitted from a variety of common sources including gasoline stations, motor vehicles, dry cleaners, industrial operations, painting operations, and research and teaching facilities. Toxic air contaminants are
8 Description of TACs are taken from South Coast Air Quality Management District CEQA Air Quality Handbook, South Coast Air Quality Management District 1993.
9 Description of greenhouse gases are taken from the California’s Association of Environmental Professionals White Paper on Alternative Approaches to Analyzing Greenhouse Gas Emissions and Global Climate Change in CEQA Documents. June 2007.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-8
City of Los Angeles November 2008
different than “criteria” pollutants in that ambient air quality standards have not been established for them, largely because there are hundreds of air toxics and their effects on health tend to be felt on a local scale rather than on a regional basis.
TACs are found in ambient air, especially in urban areas, and are caused by industry, agriculture, fuel combustion, and commercial operations (e.g., dry cleaners). TACs are typically found in low concentrations, even near their source (e.g., benzene near a freeway). Because chronic exposure can result in adverse health effects, TACs are regulated at the regional, state, and federal level.
Diesel exhaust is the predominant TAC in urban air and is estimated to represent about two-thirds of the cancer risk from TACs (based on the statewide average). According to the California Air Resources Board (CARB), diesel exhaust is a complex mixture of gases, vapors and fine particles. This complexity makes the evaluation of health effects of diesel exhaust a complex scientific issue. Some of the chemicals in diesel exhaust, such as benzene and formaldehyde, have been previously identified as TACs by the CARB, and are listed as carcinogens either under the State’s Proposition 65 or under the federal Hazardous Air Pollutants programs. California has adopted a comprehensive diesel risk reduction program. The United States Environmental Protection Agency (U.S. EPA) has adopted low sulfur diesel fuel standards that will reduce diesel particulate matter substantially. These went into effect in June 2006.
• Greenhouse Gas (GHG) emissions refer to a group of emissions that are believed to affect global
climate conditions. Greenhouse gases such as carbon dioxide (CO2), methane, and nitrous oxide keep the average surface temperature of the Earth close to a hospitable 60 degrees Fahrenheit. Without greenhouse gases, the Earth would be a frozen globe with an average surface temperature of about 5 degrees Fahrenheit.
GHGs include carbon dioxide (CO2), methane (CH4), ozone (O3), water vapor, nitrous oxide
(N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). Carbon dioxide is the most abundant GHG. Other GHGs are less abundant, but have higher
global warming potential than CO2. Thus, emissions of other GHGs are frequently expressed in
the equivalent mass of CO2, denoted as CO2e. GHGs emissions are both naturally occurring and the result of human activities. Forest fires, decomposition, industrial processes, landfills, and consumption of fossil fuels for power generation, transportation, heating, and cooking are the primary sources of GHG emissions. According to the California Energy Commission (CEC), emissions from fossil fuel consumption represent approximately 81 percent of all GHG emissions and transportation creates 41 percent of all GHG emissions in the United States.10 A general
10 California Energy Commission, Inventory of California Greenhouse Gas Emissions and Sinks: 1990 to 2004, Staff Final Report, December 2006.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-9
City of Los Angeles November 2008
description of the GHGs discussed is provided in Table IV.C-1, Description of Identified Greenhouse Gases.
There appears to be a close relationship between the concentration of greenhouse gases in the atmosphere and global temperatures. A number of scientists believe that the amount of greenhouse gas emissions in the atmosphere has increased at a rapid rate due to the use of machines powered by fossil fuels and that these gases are increasing global temperatures.11 If not abated, the warming increase could reduce water supply, increase erosion of coastlines, increase sea water intrusion, increase power demand, and worsen air quality.12
Sensitive Receptors
Some population groups are considered more sensitive to air pollution than others. Sensitive receptors for air quality include children, the elderly, and the acutely and chronically ill, especially those with cardio- respiratory diseases including, but not limited to, angina.
Residences, schools, playgrounds, childcare facilities, long-term health care facilities, rehabilitation centers, convalescent centers, retirement homes and outdoor athletic facilities are considered to be sensitive land uses.13 Residential areas are considered to be sensitive to air pollution because residents (including children and the elderly) tend to be at home for extended periods of time resulting in sustained exposure to any pollutants present. Recreational land uses are considered moderately sensitive to air pollution. Although exposure periods are generally short, physical exercise places a high demand on respiratory functions, which can be impaired by air pollution. In addition, noticeable air pollution can detract from the enjoyment of recreation. Schools and childcare facilities are also considered to be sensitive uses. Industrial and commercial areas are considered the least sensitive to air pollution. Exposure periods in these areas are relatively short and intermittent, as the majority of the workers tend to stay indoors most of the time.
11 Intergovernmental Panel on Climate Change, Climate Change 2007 – The Physical Science Basis, Summary for Policymakers, 2007.
12 California Environmental Protection Agency, Climate Action Team, Climate Action Team Report to Governor Schwarzenegger and the Legislature, March 2006.
13 City of Los Angeles, L.A. CEQA Thresholds Guide, page B.3-4.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-10
City of Los Angeles November 2008
Table IV.C-1 Description of Identified Greenhouse Gases
Greenhouse Gas General Description An odorless, colorless GHG, which has both natural and anthropogenic sources. Natural sources include the following: decomposition of dead organic matter; Carbon Dioxide (CO2) respiration of bacteria, plants, animals, and fungus; evaporation from oceans; and volcanic outgassing. Anthropogenic (human caused) sources of carbon dioxide are from burning coal, oil, natural gas, and wood. A flammable gas and is the main component of natural gas. When one molecule of methane is burned in the presence of oxygen, one molecule of carbon dioxide and two molecules of water are released. A natural source of methane is from the anaerobic Methane decay of organic matter. Geological deposits, known as natural gas fields, also contain methane, which is extracted for fuel. Other sources are from landfills, fermentation of manure, and cattle. A colorless GHG. High concentrations can cause dizziness, euphoria, and sometimes slight hallucinations. Nitrous oxide is produced by microbial processes in soil and water, including those reactions which occur in fertilizer containing nitrogen. In Nitrous Oxide (N2O) addition to agricultural sources, some industrial processes (fossil fuel-fired power plants, nylon production, nitric acid production, and vehicle emissions) also contribute to its atmospheric load. It is used in rocket engines, race cars, and as an aerosol spray propellant. HFCs are synthetic man-made chemicals that are used as a substitute for chlorofluorocarbons (CFCs) for automobile air conditioners and refrigerants. CFCs are gases formed synthetically by replacing all hydrogen atoms in methane or ethane with Hydrofluorocarbons chlorine and/or fluorine atoms. CFCs are nontoxic, nonflammable, insoluble, and (HFCs) chemically unreactive in the troposphere (the level of air at the earth’s surface). CFCs were first synthesized in 1928 for use as refrigerants, aerosol propellants, and cleaning solvents. Because they destroy stratospheric ozone, their production was stopped as required by the Montreal Protocol in 1987. PFCs have stable molecular structures and do not break down though the chemical processes in the lower atmosphere. High-energy ultraviolet rays about 60 kilometers Perfluorocarbons above the earth’s surface are able to destroy the compounds. PFCs have very long (PFCs) lifetimes, between 10,000 and 50,000 years. Two common PFCs are tetrafluoromethane and hexafluoroethane. The two main sources of PFCs are primary aluminum production and semiconductor manufacture. An inorganic, odorless, colorless, non-toxic, and nonflammable gas. SF is used for Sulfur Hexafluoride 6 insulation in electric power transmission and distribution equipment, in the magnesium (SF ) 6 industry, in semiconductor manufacturing, and as a tracer gas for leak detection. Source: Association of Environment Professionals, Alternative Approaches to Analyze Greenhouse Gas Emissions and Global Climate Change in CEQA Documents, Final, June 29, 2007.
Sensitive receptors in the immediate vicinity of the project site indicated in the project description include the following:
• Single-family and multi-family residences located adjacent to the project site to the south and southwest;
• Single-family residences located approximately 200 feet to the north;
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-11
City of Los Angeles November 2008
• Yeshiva University of Los Angeles (private school) located adjacent to the project site to the east; and
• UCLA Medical Clinic located less than 200 feet to the northwest.
Existing Regional Air Quality
Ambient air quality is determined primarily by the type and amount of pollutants emitted into the atmosphere, as well as the size, topography, and meteorological conditions of a geographic area. The Basin has low mixing heights and light winds, which help to accumulate air pollutants14. The average daily emissions inventory for the entire Basin and the Los Angeles County portion of the Basin are summarized in Table IV.C-2, 2006 Estimated Average Daily Regional Emissions. As shown therein, exhaust emissions from mobile sources generate the majority of ROG, CO, NOx, and SOx in the Basin and the Los Angeles County portion of the Basin. Area-wide sources generate the most airborne particulates (i.e., PM10 and PM2.5).
Table IV.C-2 2006 Estimated Average Daily Regional Emissions
Emissions in Tons Per Day
Emissions Source ROG CO NOx SOx PM10 PM2.5 South Coast Air Basin Stationary (Point) Sources 101.9 55.4 58.3 19.3 20.9 13.7 Area-Wide Sources 148.3 110.3 25.6 0.8 210.3 51.2 Mobile Sources 425.8 3580.0 866.5 28.1 48.4 39.0 Natural (non-anthropogenic) Sources 86.5 164.2 5.0 1.5 16.6 14.1 Total Emissions 762.4 3909.9 955.4 49.8 296.2 117.9 Los Angeles County – South Coast Air Basin Stationary (Point) Sources 59.0 35.8 40.0 17.9 12.6 9.2 Area-Wide Sources 85.3 43.8 15.3 0.4 103.2 26.0 Mobile Sources 252.5 2133.5 529.4 24.6 29.5 24.0 Natural (non-anthropogenic) Sources 34.3 65.0 1.9 0.6 6.6 5.6 Total Emissions 431.1 2278.0 586.7 43.5 151.9 64.8 Source: California Air Resources Board, website: http://www.arb.ca.gov/ei/emissiondata.htm, June 2008.
Measurements of ambient concentrations of the criteria pollutants are used by the U.S. EPA and the CARB to assess and classify the air quality of each regional air basin, county, or, in some cases, a specific urbanized area. The classification is determined by comparing actual monitoring data with national and State standards. If a pollutant concentration in an area is lower than the standard, the area is classified as
14 South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-12
City of Los Angeles November 2008
being in “attainment” for that pollutant. If the pollutant concentration meets or exceeds the standard (depending on the specific standard for the individual pollutants), the area is classified as a “nonattainment” area. If there are not enough data available to determine whether the standard is exceeded in an area, the area is designated “unclassified.” The U.S. EPA and the CARB use different standards for determining whether the Basin is in attainment. The attainment status for the Basin with regard to the National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS) is shown in Table IV.C-3, Attainment Status for the South Coast Air Basin (Los Angeles County Portion).
Table IV.C-3 Attainment Status for the South Coast Air Basin (Los Angeles County Portion)
Attainment Status Pollutant NAAQS CAAQS Carbon Monoxide Attainment Attainment Nitrogen Dioxide Attainment Attainment Ozone Extreme Non-attainment Non-attainment PM10 Serious Non-Attainment Non-attainment PM2.5 Non-Attainment Non-attainment Sulfur Dioxide Attainment Attainment Lead Attainment Attainment Source: California Air Resources Board, State Area Designation Maps, website: http://www.arb.ca.gov/desig/adm/adm.htm May 2008.
Existing Local Air Quality
The SCAQMD monitors ambient air pollutant concentrations through a series of monitoring stations located throughout the Basin. In doing so, the SCAQMD has divided the region into 27 source receptor areas (SRAs) in which 31 monitoring stations operate. The project site is located within SRA 2, which covers the Northwest Coastal Los Angeles County area. Table IV.C-4, Summary of Ambient Air Quality in the Project Vicinity, identifies the national and state ambient air quality standards for relevant air pollutants along with the ambient pollutant concentrations that have been measured in the project vicinity through the period of 2005 to 2007. Figure IV.C-1, Locations of Air Monitoring Stations, presents the locations of the air monitoring stations in the project vicinity.
The project area is densely urbanized with such land uses as residential, commercial, hotel, medical, and community-services land uses located along the local roadways within the immediate area. Air pollutant emissions are generated in the local vicinity by stationary and area-wide sources, such as space and water heating, landscape maintenance from leaf blowers and lawn mowers, consumer products, and mobile sources, primarily automobile traffic. Motor vehicles are the primary source of pollutants in the local vicinity.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-13
City of Los Angeles November 2008
Figure IV.C-1, Locations of Air Monitoring Stations
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-14
City of Los Angeles November 2008
Table IV.C-4 Summary of Ambient Air Quality in the Project Vicinity
Year Emissions Source 2005 2006 2007 Ozone Maximum 1-hour concentration measured 0.114 ppm 0.10 ppm 0.117 ppm Days exceeding State 0.09 ppm 1-hour standard 7 3 2 Maximum 8-hour concentration 0.09 ppm 0.098 ppm 0.087 ppm Days exceeding national 0.08 ppm 8-hour standard 1 0 0 Days exceeding State 0.07 ppm 8-hour standard 5 0 0 Respirable Particulate Matter (PM10) Maximum 24-hour concentration measured 70 µg/m3 59 µg/m3 96 µg/m3 Days exceeding national 150 µg/m3 24-hour standard 0 0 0 Days exceeding State 50 µg/m3 24-hour standard 4 3 5 Fine Particulate Matter (PM2.5) Maximum 24-hour concentration measured 73.7 µg/m3 56.2 µg/m3 64.2 µg/m3 Days exceeding national 65 µg/m3 24-hour standard 2 0 0 Carbon Monoxide (CO) Maximum 1-hour concentration measured 3.0 ppm 3.0 ppm 3.0 ppm Days exceeding national 35.0 ppm 1-hour standard 0 0 0 Days exceeding State 20.0 ppm 1-hour standard 0 0 0 Maximum 8-hour concentration measured 2.1 ppm 2.0 ppm 1.9 ppm Days exceeding national & State 9.0 ppm 8-hour standard 0 0 0 Nitrogen Dioxide (NO2) Maximum 1-hour concentration measured 0.08 ppm 0.08 ppm 0.08 ppm Days exceeding State 0.18 ppm 1-hour standard 0 0 0 AAM 0.0178 ppm 0.0173 ppm 0.02 ppm Does measured AAM exceed national 0.0534 ppm AAM standard? No No No
Note: SRA2, does not measure for either PM10 and PM2.5, therefore the measurements from the two nearest monitoring stations, SRA1 and SRA3 were used. -- = Not analyzed ppm = parts per million by volume µg/m3 = micrograms per cubic meter AAM = annual arithmetic mean
Source: South Coast Air Quality Management District, website: http://www.aqmd.gov/smog/historicaldata.htm, June 2008.
Traffic-congested roadways and intersections have the potential to generate localized high levels of CO. Localized areas where ambient concentrations exceed national and/or state standards for CO are termed CO “hotspots.” The SCAQMD considers CO as a localized problem requiring additional analysis when a project is likely to subject sensitive receptors to CO hotspots.15 As stated earlier, some populations groups are considered more sensitive to air pollution than others. Land uses such as primary and
15 South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-15
City of Los Angeles November 2008
secondary schools, hospitals, and convalescent homes are considered to be sensitive receptors to poor air quality because the very young, the old, and the infirm are more susceptible to respiratory infections and other air quality-related health problems than the general public. Residential uses are considered sensitive because people in residential areas are often at home for extended periods of time, so they could be exposed to pollutants for extended periods. Recreational areas are considered moderately sensitive to poor air quality because vigorous exercise associated with recreation places a high demand on the human respiratory function. Based on the surrounding land uses that include residential, educational and medical uses as well as the fact that project attracts sensitive receptors (i.e., schoolchildren and the elderly), a CO hotspot analysis was conducted.
The SCAQMD recommends the use of CALINE4, a dispersion model for predicting CO concentrations, as the preferred method of estimating localized pollutant concentrations at sensitive receptors near congested roadways and intersections.16 For each intersection analyzed, CALINE4 adds roadway-specific CO emissions calculated from peak-hour turning volumes to ambient CO air concentrations. For this analysis, localized CO concentrations were calculated based on a simplified CALINE4 screening procedure developed by the Bay Area Air Quality Management District and accepted by the SCAQMD.17 The simplified procedure is intended as a screening analysis, which identifies a potential CO hotspot. This methodology assumes worst-case conditions and provides a screening of maximum, worst-case CO concentrations. However, the emission factors used in the analysis have been updated to EMFAC2007 by the EIR consultant.18
Maximum existing CO concentrations for the intersections included in the Traffic Study prepared by Crain & Associates included as Appendix K to this Draft EIR, and in Section IV.I (Traffic/Transportation/Parking) of this Draft EIR. For the purpose of this analysis, receptors are any of the sensitive receptor types identified previously, as well as any location where people would be required (as in a work site) to be located for one to eight hours. The results of the localized CO calculations are presented in Table IV.C-5, Existing Localized Carbon Monoxide Concentrations. For the purpose of these calculations, representative receptor locations at the roadside edge as well as 25 and 50 feet from
16 Ibid.
17 Email correspondence between Mike Wolf, CAJA and James Koizumi, South Coast Air Quality Management District, July 8, 2008.
18 The emission factors used in the BAAQMD’s localized CO screening procedure are based on EMFAC7G, which is out of date by several years and has been superseded by newer emission factor models, the current version of which is EMFAC2007.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-16
City of Los Angeles November 2008
each roadway were utilized. The National 1-hour standard is 35.0 parts per million (ppm), and the State 1-hour standard is 20.0 ppm. The 8-hour National and State standards are both 9.0 ppm.19,20
As shown in Table IV.C-5, under worst-case conditions (at the roadway edge), existing CO concentrations near all of the study-area intersections do not exceed national or State ambient air quality standards. Therefore, CO hotspots do not exist near these intersections and localized CO is unlikely to adversely impact nearby sensitive receptors.
Table IV.C-5 Existing Localized Carbon Monoxide Concentrations (Peak)
CO Concentrations in Parts Per Million Roadway Edge 25 Feet 50 Feet Intersection 1-Hour 8-Hour 1-Hour 8-Hour 1-Hour 8-Hour 1) Olympic Boulevard & Century Park East 5.7 4.0 4.8 3.4 4.5 3.1 2) Olympic Boulevard & Roxbury Drive 5.4 3.8 4.6 3.2 4.3 2.9 3) Olympic Boulevard & Beverwil Drive 5.4 3.8 4.6 3.2 4.3 2.9 4) Pico Boulevard & Century Park East 5.1 3.6 4.4 3.0 4.2 2.8 5) Pico Boulevard & Roxbury Drive 5.0 3.5 4.3 3.0 4.1 2.8 6) Pico Boulevard & Beverwil Drive 5.1 3.6 4.4 3.1 4.2 2.8 7) Pico Boulevard & Beverly Drive 4.7 3.3 4.2 2.9 4.0 2.7 8) Pico Boulevard & Robertson Boulevard 4.7 3.3 4.2 2.9 4.0 2.7 9) Cashio Street & Castello Avenue 3.5 2.3 3.3 2.1 3.2 2.1 10) Cashio Street & Beverwil Drive 4.0 2.7 3.7 2.4 3.5 2.3 11) Monte Mar Drive & Beverwil Drive 4.5 3.1 3.8 2.6 3.6 2.4 Note: National 1-hour standard is 35.0 ppm State 1-hour standard is 20.0 ppm National and State 8-hour standard is 9.0 ppm
Source: Christopher A. Joseph & Associates, 2008. Calculation sheets are provided in Appendix G. Based on year 2007 EMFAC2007 Winter emission factors.
Existing Project Site Emissions
The project site is currently developed with an approximately 69,477-square-foot museum. Air pollutant emissions are generated by stationary sources, such as space and water heating (e.g., boilers), landscape maintenance equipment, architectural coatings (painting), and mobile sources such as motor vehicle
19 California Air Resources Board, California Ambient Air Quality Standards, website: http://www.arb.ca.gov/research/aaqs/caaqs/caaqs.htm, July 2008.
20 U.S. Environmental Protection Agency, The Green Book Nonattainment Areas for Criteria Pollutants website: http://www.epa.gov/air/oaqps/greenbk/, July 2008.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-17
City of Los Angeles November 2008
traffic traveling to and from the project site. The average daily emissions generated by the existing uses at the project site have been calculated utilizing the URBEMIS 2007 computer model recommended by the SCAQMD.21 The results of these calculations are presented in Table IV.C-6, Estimated Daily Operations Emissions – Existing Project Site - 2008.
Table IV.C-6 Estimated Daily Operational Emissions – Existing Project Site – 2008
Emissions in Pounds per Day Emissions Source ROG NOx CO SOx PM10 PM2.5 Summertime (Smog Season) Emissions Water and Space Heating 0.03 0.46 0.39 0.00 0.00 0.00 Landscape Maintenance Equipment 0.13 0.02 1.6 0.00 0.00 0.01 Architectural Coatings 0.41 0.00 0.00 0.00 0.00 0.00 Motor Vehicles 2.22 1.83 22.43 0.02 4.21 0.8 Total Emissions 2.79 2.31 24.42 0.02 4.21 0.8 Wintertime (Non-Smog Season) Emissions Water and Space Heating 0.03 0.46 0.39 0.00 0.00 0.00 Landscape Maintenance Equipment 0.13 0.02 1.6 0.00 0.00 0.01 Architectural Coatings 0.41 0.00 0.00 0.00 0.00 0.00 Motor Vehicles 2.21 2.26 21.56 0.02 4.21 0.8 Total Emissions 2.78 2.74 23.55 0.02 4.21 0.8 Note: Subtotals may not appear to add correctly due to rounding in the URBEMIS 2007 model. As a conservative estimate, emissions from landscape maintenance equipment were included in both summertime and wintertime emissions.
Source: Christopher A. Joseph & Associates, 2008. Calculation sheets are provided in Appendix G.
Existing State-wide Greenhouse Gas Emissions
The California Energy Commission published the Inventory of California Greenhouse Gas Emissions and Sinks: 1990 to 2004 in December 2006.22 This report indicates that California is the second largest emitter of greenhouse gasses in the United States next to Texas. This is largely a result of the number of people living in a large state, as opposed to a small state such as Rhode Island. California generates about half as much CO2 emissions as Texas. When considering fossil fuel emissions at the individual person level, California is second lowest in the nation in per capita CO2 emissions with only the District of Columbia lower. Between 1990 and 2000, California’s population grew by 4.1 million people and during the 1990 to 2003 period, California’s gross state product grew by 83 percent (in dollars, not adjusted for
21 South Coast Air Quality Management District, website: http://www.aqmd.gov/ceqa/models.html, June 2008.
22 Inventory of California Greenhouse Gas Emissions and Sinks: 1990 to 2004, California Energy Commission (CEC), December 2006.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-18
City of Los Angeles November 2008
inflation). However, California’s greenhouse gas emissions grew by only 12 percent between 1990 and 2003. The report concludes that California’s ability to slow the rate of growth of greenhouse gas emissions is largely due to the success of its energy efficiency, renewable energy programs, and commitment to clean air and clean energy. In fact, the State’s programs and commitments lowered its greenhouse gas emissions rate of growth by more than half of what it would have been otherwise.
Regulatory Framework
Air quality within the Basin is addressed through the efforts of various federal, State, regional, and local government agencies. These agencies work jointly, as well as individually, to improve air quality through legislation, regulations, planning, policy-making, education, and a variety of programs. The agencies responsible for regulating and improving the air quality within the Basin are discussed below.
Federal
U.S. EPA
The U.S. Environmental Protection Agency (U.S. EPA) is responsible for setting and enforcing the National Ambient Air Quality Standards (NAAQS) for atmospheric pollutants. These standards identify levels of air quality for seven “criteria” pollutants: O3, CO, NO2, SO2, PM10, PM2.5, and lead. The threshold levels are considered to be the maximum concentration of ambient (background) air pollutants determined safe (within an adequate margin of safety) to protect the public health and welfare. It regulates emission sources that are under the exclusive authority of the federal government, such as aircraft, ships, and certain locomotives. The U.S. EPA also has jurisdiction over emissions sources outside state waters (outer continental shelf), and establishes various emissions standards for vehicles sold in states.
As part of its enforcement responsibilities, the U.S. EPA requires each state with nonattainment areas to prepare and submit a State Implementation Plan (SIP) that demonstrates the means to attain the federal standards. The SIP must integrate federal, state, and local plan components and regulations to identify specific measures to reduce pollution, using a combination of performance standards and market-based programs within the timeframe identified in the SIP.
State
CARB
The California Air Resources Board (CARB), a part of the California Environmental Protection Agency, is responsible for the coordination and administration of both federal and State air pollution control programs within California. In this capacity, the CARB conducts research, sets California Ambient Air Quality Standards (CAAQS) that are more stringent standards than the NAAQS, compiles emission
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-19
City of Los Angeles November 2008
inventories, develops suggested control measures, provides oversight of local programs, and prepares the SIP.
California Global Warming Solutions Act
In August 2006, the California Legislature adopted AB 32, the California Global Warming Solutions Act of 2006. This bill requires the CARB to adopt regulations to require the reporting and verification of statewide greenhouse gas emissions and to monitor and enforce compliance with that program. As part of this effort, the CARB will adopt a statewide greenhouse gas emissions limit equivalent to the statewide greenhouse gas emissions levels in 1990, to be achieved by 2020. The CARB will adopt rules and regulations to achieve the maximum technologically feasible and cost-effective greenhouse gas emission reductions. These are expected to include market-based compliance mechanisms. The statute would further require the CARB to monitor compliance with and enforce any rule, regulation, order, emission limitation, emissions reduction measure, or market-based compliance mechanism that it adopts. In October 2006, the Governor issued an Executive Order in which he designated the Cal/EPA Secretary with the primary responsibility for implementing AB 32 (rather than providing the CARB with unfettered discretion as the law required). In late December, the Governor announced the members of a blue-ribbon Market Advisory Committee board to devise approaches to develop a market for carbon trading. More developments are likely as the Governor and the Legislature determine who has primary responsibility for implementation and the relationship between regulations and market-based mechanisms. Because, the intent of AB 32 is to limit 2020 emissions to the equivalent of 1990, and the present year (2008) is near the midpoint of this timeframe, it is expected that the regulations would affect many existing sources of greenhouse and not just new general development projects.
In response to the Executive Order, the Secretary of Cal/EPA created the Climate Action Team (CAT), which, in March 2006, published the Climate Action Team Report to Governor Schwarzenegger and the Legislature (the “2006 CAT Report”). The 2006 CAT Report identifies a recommended list of strategies that the State could pursue to reduce climate change greenhouse gas emissions. These are strategies that could be implemented by various State agencies to ensure that the Governor’s targets are met and can be met with existing authority of the State agencies.
In June 2008, the Governor’s Office of Planning and Research (OPR) released a technical advisory entitled, CEQA and Climate Change: Addressing Climate Change Through California Environmental Quality Act (CEQA) Review (the “OPR Climate Change Report”).23 The advisory provides lead agencies an approach to comply with CEQA climate change analysis for projects that generate GHG emissions. The steps for the lead agencies include the following:
23 Technical Advisory, CEQA and Climate Change: Addressing Climate Change Through California Environmental Quality Act (CEQA) Review. Governor’s Office of Planning and Research, June 2008.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-20
City of Los Angeles November 2008
• Determine if the project generates GHG emissions;
• Estimate GHG emissions from project;
• Determine significance threshold; and
• Apply mitigation measures and evaluate impacts.
Regional
Southern California Association of Governments
The Southern California Association of Governments (SCAG) is a council of governments for Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura Counties. It is a regional planning agency and serves as a forum for regional issues relating to transportation, the economy and community development, and the environment.
Although the SCAG is not an air quality management agency, it is responsible for developing transportation, land use, and energy conservation measures that affect air quality. SCAG’s Regional Comprehensive Plan and Guide (RCPG) provides growth forecasts that are used in the development of air quality-related land use and transportation control strategies by the SCAQMD. The RCPG is a framework for decision-making for local governments, assisting them in meeting federal and State mandates for growth management, mobility, and environmental standards, while maintaining consistency with regional goals regarding growth and changes through the year 2015, and beyond. Policies within the RCPG include consideration of air quality, land use, transportation, and economic relationships by all levels of government.
SCAQMD
The South Coast Air Quality Management District (SCAQMD) is the agency principally responsible for comprehensive air pollution control in the Basin. To that end, the SCAQMD, a regional agency, works directly with the Southern California Association of Governments (SCAG), county transportation commissions, and local governments, and cooperates actively with all State and federal government agencies. The SCAQMD develops rules and regulations, establishes permitting requirements, inspects emissions sources, and provides regulatory enforcement through such measures as educational programs or fines, when necessary.
The SCAQMD is directly responsible for reducing emissions from stationary (area and point), mobile, and indirect sources to meet federal and State ambient air quality standards. It has responded to this requirement by preparing a series of Air Quality Management Plans (AQMPs) that are approved by CARB. The most recent of these was adopted by the Governing Board of the SCAQMD on June 1, 2007. This AQMP, referred to as the 2007 AQMP, was prepared to comply with the federal and State Clean Air
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-21
City of Los Angeles November 2008
Acts and amendments, to accommodate growth, to reduce the high levels of pollutants in the Basin, to meet federal and State air quality standards, and to minimize the fiscal impact that pollution control measures have on the local economy. The 2007 AQMP identifies the control measures that will be implemented over a 20-year horizon to reduce major sources of pollutants. Implementation of control measures established in the previous AQMPs has substantially decreased the population’s exposure to unhealthful levels of pollutants, even while substantial population growth has occurred within the Basin.
According to the Final Program EIR for the 2007 AQMP, the 2007 AQMP as a whole will promote a net decrease in greenhouse gases. The transportation control measures are intended to reduce vehicle miles traveled and will consequently reduce carbon dioxide production from motor vehicles. Other strategies that promote fuel efficiency and pollution prevention will also reduce greenhouse gas emissions. Measures that stimulate the development and use of new technologies such as fuel cells will also be beneficial. In general, strategies that conserve energy and promote clean technologies usually also reduce greenhouse gas emissions.
The SCAQMD has prepared the CEQA Air Quality Handbook and other supplemental guidance documents to assist Lead Agencies, as well as consultants, project proponents, and other interested parties, in evaluating potential air quality impacts of projects and plans proposed in the Basin. Through the issuance of air permits, the SCAQMD can enforce rules and regulations to reduce specific emissions by requiring specific pollution reduction measures. Applicable rules to this project include:
• Rule 403 requires fugitive dust sources to implement Best Available Control Measures for all sources and all forms of visible particulate matter are prohibited from crossing any property line.
Rule 403 is intended to reduce PM10 emission from any transportation, handling, construction, or storage activity that has the potential generate fugitive dust.
• Rule 431.2 requires the use of low sulfur diesel fuel for stationary sources and the maintenance of the record of use.
• Rule 1113 requires manufacturers, distributors, and end-users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories.
• Rule 1138 requires new chain-driven charbroilers to be equipped and operated with a catalytic oxidizer control device.
Local
City of Los Angeles
Local jurisdictions, such as the City of Los Angeles, have the authority and responsibility to reduce air pollution through its police power and decision-making authority. Specifically, the City is responsible for
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-22
City of Los Angeles November 2008
the assessment and mitigation of air emissions resulting from its land use decisions. The City of Los Angeles is also responsible for the implementation of transportation control measures as outlined in the AQMP. Examples of such measures include transit oriented development, transportation demand management programs, bus turnouts, energy-efficient streetlights, and synchronized traffic signals.
The Air Quality Element of the City of Los Angeles General Plan was adopted on November 24, 1992 and sets forth the goals, objectives and policies which will guide the City in the implementation of its air quality improvement programs and strategies. The Air Quality Element acknowledges that numerous efforts are underway at the regional, county and city levels addressing clean air concerns and that coordination of these various efforts and the involvement of the area’s residents are crucial to the achievement of state and federal air quality standards.
The Air Quality Element acknowledges the interrelationships among transportation and land use planning in meeting the City’s mobility and clean air goals. Mutually reinforcing strategies need to be developed which work to reduce the use of single occupant vehicles and which work to reduce vehicle trips and vehicle miles traveled.
The Air Quality Element establishes six goals:
• Good air quality in an environment of continued population growth and healthy economic structure;
• Less reliance on single-occupant vehicles with fewer commute and non-work trips;
• Efficient management of transportation facilities and system infrastructure using cost-effective system management and innovative demand-management techniques;
• Minimal impacts of existing land use patterns and future land use development on air quality by addressing the relationship between land use, transportation and air quality;
• Energy efficiency through land use and transportation planning, the use of renewable resources and less-polluting fuels and the implementation of conservation measures including passive measures such as site orientation and tree planting; and
• Citizen awareness of the linkages between personal behavior and air pollution and participation in efforts to reduce air pollution.
In accordance with CEQA requirements and the CEQA review process, the City assesses the air quality impacts of new development projects, requires mitigation of potentially significant air quality impacts by conditioning discretionary permits, and may monitor and enforce implementation of such mitigation. The City utilizes the CEQA Air Quality Handbook as the guidance document for the environmental review of plans and development proposals within its jurisdiction.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-23
City of Los Angeles November 2008
The City of Los Angeles has begun to address the issue of global climate change by publishing Green LA, An Action Plan to Lead the Nation in Fighting Global Warming (the “LA Green Plan”).24 This document outlines the goals and actions the City has established to reduce the generation and emission of GHGs from both public and private activities. According to the LA Green Plan, the City is committed to the goal of reducing emissions of CO2 to 35 percent below 1990 levels. To achieve this, the City will:
• Increase the generation of renewable energy; • Improve energy conservation and efficiency; and • Change transportation and land use patterns to reduce dependence on automobiles.
As part of the LA Green Plan, the Los Angeles Green Building Ordinance was passed in April 2008, which promotes green building practices by creating a series of requirements and incentives for developers to meet the U.S. Green Building Council’s Leadership in Energy and Environmental Design (LEED) standards. The requirements apply to all new projects greater than 50 units or 50,000 square feet. Since the proposed project is less than this threshold, the Los Angeles Green Building Ordinance does not apply to the proposed project. However, the proposed project would include design features that reduce greenhouse gas emissions, including:
• Bike racks to reduce vehicle travel, if space allows.
• Proximity of the Metro Bus Service and Santa Monica Big Blue Bus lines to encourage mass transit travel.
• Energy-efficient systems and material to reduce energy that result in the emission of greenhouse gas.
• Planned green space to absorb greenhouse gases from the atmosphere.
Additional information regarding project design features is presented in the section below.
ENVIRONMENTAL IMPACTS
The environmental impacts to air quality from the proposed project were calculated based on methodology recommended by the SCAQMD. As more particularly described in Section II, Project Descriptions, the proposed project would include a Cultural Resource Center, a café with kitchen space and food preparation area, storage space, Museum store space, office area, preparation area, exhibit space, a gallery/lounge area, a changing room, restrooms, and a multi-purpose area. The expansion would
24 Green LA: An Action Plan to Lead the Nation In Fighting Global Warming. City of Los Angeles, May 2007.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-24
City of Los Angeles November 2008
include the addition of an underfire broiler and the replacement of a boiler to handle the increased demand from the increase to structural area. The expansion would also include the following design features in compliance with SCAQMD and California rules (see Appendix G):
• Measures pursuant to SCAQMD Rule 403, the fugitive dust rule;
• Measures pursuant to SCAQMD Rule 431, sulfur content of fuels;
• Measures pursuant to SCAQMD Rule 1113, architectural coatings;
• Measures pursuant to SCAQMD Rule 1138 restaurant operations; and
• All onsite diesel equipment will comply with the California Idle Reduction Program
The project would also incorporate the following project design features:
• The electrical load for the proposed project would meet Title 24 energy consumption guidelines;
• Installation of bike racks, if space allows;
• Use of electric saws during construction activities;
• Recycling of more than 50 percent of construction waste when possible;
• Use of low-VOC paint with a VOC rating of 125 grams per liter or less;
• Installation of energy-efficient appliances, such as and high-efficiency dishwashers (Energy Star rated); and heating, ventilation and air conditioning systems (HVAC) that would meet MERV 12;
• Installation of energy-efficient lighting (i.e., low wattage lamps);
• Installation of energy-efficient, low-flow water fixtures, including: high-efficiency toilets (1.28 gallons per flush), urinals (0.5 gallons per flush), restroom faucets (1.5 gallons per minute or less), and public restroom self-closing faucets;
• Installation of spectrally selective low-e glass and high performance windows where feasible;
• Insulation in new walls would exceed Title 24 requirements;
• Installation of high-efficiency dishwashers (Energy Star rated) where applicable:
• Installation of a sealed duct system;
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-25
City of Los Angeles November 2008
• Installation of R-4 insulation for all 2-inch or smaller exterior hot water pipes (R-6 for larger than 2-inch pipes);
• Installation of roofing with energy-efficient, light-colored, high-reflectance or high albedo on at least 80 percent of the roof;
• Installation of photocell controls for exterior common area lighting;
• Installation of a hot water recirculation system; and
• Strict prohibition of single-pass cooling where applicable.
Methodology
The net increase in project site emissions generated by the proposed project has been quantitatively estimated and compared to thresholds of significance recommended by the SCAQMD (see Project Impacts subheading, below). Applicable project design features and required regulations (such as Rule 403) are included in the evaluations, to the extent their effects can be quantified.
Construction Emissions
Construction emissions are calculated using the URBEMIS 2007 computer model developed for the CARB by estimating the types and number of pieces of equipment that would be used to remove existing facade, excavate the project site, and construct the proposed development. Construction emissions are analyzed according to the regional thresholds established by the SCAQMD and published in the L.A. CEQA Air Quality Handbook, based on the assumptions described below. The construction activities associated with the proposed project would cause diesel emissions, and would generate emissions of dust. Construction equipment within the project site that would generate criteria air pollutants could include excavators, dump trucks, and loaders. Some of this equipment would be used during demolition activities as well as when structures are constructed on the project site. In addition, emissions during construction activities include export truck trips off-site to remove debris and delivery truck trips during the demolition activities. URBEMIS 2007 evaluates all diesel-powered equipment used during construction activities.
To determine whether or not construction activities associated with the proposed project would create significant adverse localized air quality impacts on nearby sensitive receptors located off-site, the emissions contribution from the proposed project was also analyzed in accordance with SCAQMD’s LST Methodology guidance document. Under this methodology, projects that are less than five acres in size such as this project may utilize SCAQMD spreadsheets or look-up tables, to determine whether construction activities would cause or contribute to adverse localized air quality impacts. The criteria pollutants analyzed include NOx, CO, PM10, and PM2.5.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-26
City of Los Angeles November 2008
Fugitive dust control measures in accordance with SCAQMD Rule 403 were accounted for in the evaluation and include the following:
• Use watering to control dust generation during demolition of structures or break-up of pavement.
• Water active grading/excavation sites and unpaved surfaces at least three times daily.
• Cover stockpiles with tarps or apply non-toxic chemical soil binders.
• Limit vehicle speed on unpaved roads to 15 miles per hour.
• Sweep daily (with water sweepers) all paved construction parking areas and staging areas.
• Provide daily clean-up of mud and dirt carried onto paved streets from the site.
• Install wheel washers for all exiting trucks, or wash off the tires or tracks of all trucks and equipment leaving the site.
• Suspend excavation and grading activity when winds (instantaneous gusts) exceed 15 miles per hour over a 30-minute period or more.
• An information sign shall be posted at the entrance to each construction site that identifies the permitted construction hours and provides a telephone number to call and receive information about the construction project or to report complaints regarding excessive fugitive dust generation. Any reasonable complaints shall be rectified within 24 hours of their receipt.
Operational Emissions
Operational emissions associated with the proposed project are estimated using the URBEMIS 2007 computer model developed for the CARB and the information provided in the traffic study prepared for the proposed project. Operational emissions would be comprised of additional mobile source emissions and area source emissions. Mobile source emissions are generated by the increase in motor vehicle trips to and from the project site associated with operation of the proposed project as provided in the traffic study. Area source emissions are generated by the increase in natural gas consumption for space and water heating (such as boilers), and landscape maintenance equipment. URBEMIS 2007 captures the emissions from the various sources based on land use type and the size of the project. To determine if an air quality impact would occur, the increase in emissions is compared with the SCAQMD’s recommended thresholds.
To determine whether or not on-site operational activities associated with the proposed project would create significant adverse localized air quality impacts on nearby sensitive receptors located off-site, the
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-27
City of Los Angeles November 2008
emissions contribution from the proposed project was estimated using URBEMIS 2007. The average daily emissions have been calculated assuming that each additional vehicle would travel a maximum of 0.1 mile within the project site. Mass emissions were compared to operational LSTs in accordance with SCAQMD’s LST Methodology guidance document.
Localized Hotspot CO Concentrations
As discussed previously, localized areas where ambient concentrations exceed national and/or state standards for CO are termed CO “hotspots.” The SCAQMD considers CO as a localized problem requiring additional analysis when a project is likely to subject sensitive receptors to CO hotspots.25 Localized CO concentrations were calculated based on a simplified CALINE4 screening procedure developed by the Bay Area Air Quality Management District and utilized by the SCAQMD. The simplified model is intended as a screening analysis, which identifies a potential CO hotspot. This methodology assumes worst-case conditions and provides a screening of maximum, worst-case CO concentrations. The resulting emissions are compared with adopted national and State ambient air quality standards.
Thresholds of Significance
In accordance with Appendix G to the State CEQA Guidelines, a project may have a significant adverse air quality impact if it would:
(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) 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);
(d) Expose sensitive receptors to substantial pollutant concentrations; or
(e) Create objectionable odors affecting a substantial number of people.
The thresholds discussed below are currently recommended by the SCAQMD in the CEQA Air Quality Handbook to translate the State CEQA Guidelines thresholds into numerical values or performance
25 South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-28
City of Los Angeles November 2008
standards. As discussed previously in this section, the City utilizes the CEQA Air Quality Handbook as the guidance document for the environmental review of plans and development proposals within its jurisdiction.
Violation of Air Quality Standards or Substantial Contribution to Air Quality Violations
Thresholds of significance were published by the SCAQMD in October 200626 and are presented in Table IV.C-7, Air Quality Significance Thresholds and discussed in greater detail in the subsequent sections.
Table IV.C-7 Air Quality Significance Thresholds
Mass Daily Thresholds Pollutant Construction Operation
NOx 100 lbs/day 55 lbs/day VOC 75 lbs/day 55 lbs/day
PM10 150 lbs/day 150 lbs/day PM2.5 55 lbs/day 55 lbs/day SOx 150 lbs/day 150 lbs/day CO 550 lbs/day 550 lbs/day Lead 3 lbs/day 3 lbs/day Localized Concentration Thresholds 20 ppm over 1-hour average CO 9.0 ppm over 8-hour average 10.4 µg/m3 averaged over a 24-hour period construction PM 10 2.5 µg/m3 over a 24-hour period operational 10.4 µg/m3 averaged over a 24-hour period PM 2.5 2.5 µg/m3 over a 24-hour period operational
NO2 0.18 ppm averaged over a 1-hour period Other TACs Cancer Risk >10 in a million; Non-cancer hazard index >1.0 Notes: µg/m3 = microgram per cubic meter; mg/m3 = milligram per cubic meter; ppm = parts per million. lbs/day = pounds per day; ≥ = greater than or equal to.
a Corresponds to National and State Ambient Air Quality Standard for CO.
Source: SCAQMD, Air Quality Significance Thresholds, website: http://www.aqmd.gov/ceqa/handbook/signthres.pdf, July 2008.
26 South Coast Air Quality Management District, Air Quality Significance Thresholds, website: http://www.aqmd.gov/ceqa/handbook/signthres.pdf, July 2008.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-29
City of Los Angeles November 2008
Construction Period Emissions – Mass Daily Emissions
The SCAQMD27 currently recommends that projects with construction-related mass daily emissions that exceed any of the following emissions thresholds be considered significant:
• 75 pounds per day of ROG;
• 100 pounds per day of NOx; • 550 pounds per day of CO;
• 150 pounds per day of SO x;
• 150 pounds per day of PM10; and
• 55 pounds per day of PM2.5.
The SCAQMD also recommends that any construction-related emissions from individual development projects that exceed these thresholds be considered cumulatively considerable.28 With respect to cumulative air quality impacts, the SCAQMD uses a summary of projection approach based on consistency with the AQMP and in addition recommends that a project’s potential contribution to cumulative impacts should be assessed utilizing the same significance criteria as those for project-specific impacts.29
27 Ibid.
28 South Coast Air Quality Management District White Paper on Regulatory Options for Addressing Cumulative Impacts from Air Pollution Emissions, South Coast Air Quality Management District Board Meeting, September 5, 2003, Agenda No. 29, Appendix D, p. D-3.
29 The SCAQMD’s CEQA Air Quality Handbook identifies several methods to determine the cumulative significance of land use projects (i.e., whether the contribution of a project is cumulatively considerable). However, the SCAQMD no longer recommends the use of these methodologies (see Appendix G for email correspondence between Mike Wolf, CAJA and Steve Smith, South Coast Air Quality Management District, September 2006). Instead, the SCAQMD recommends that any construction-related emissions and operational emissions from individual development projects that exceed the project-specific mass daily emissions thresholds identified above also be considered cumulatively considerable. (White Paper on Regulatory Options for Addressing Cumulative Impacts from Air Pollution Emissions. South Coast Air Quality Management District Board Meeting. September 5, 2003, Agenda No. 29, Appendix D, p. D-3). The SCAQMD neither recommends quantified analyses of the emissions generated by a set of cumulative development projects nor provides thresholds of significance to be used to assess the impacts associated with these emissions.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-30
City of Los Angeles November 2008
Construction Period Emissions – Localized Pollutant Concentrations
The SCAQMD30 recommends that projects with site-specific construction-related emissions that generate the following localized pollutant concentrations at existing human receptors be considered significant:
3 • 10.4 micrograms per cubic meter (µg/m ) of PM10 averaged over a 24-hour period; or
• 10.4 micrograms per cubic meter of PM2.5 averaged over a 24-hour period.
Because the Basin is currently in attainment of the national and State ambient air quality standards for 31 NO2 and CO, the SCAQMD recommends that projects with construction-related emissions that cause the following ambient air quality standards to be exceeded or contribute substantially to an exceeded standard at existing human receptors be considered significant:
• 0.18 parts per million NO2 averaged over a 1-hour period (State standard); • 20 parts per million of CO averaged over a 1-hour period (State standard); or • 9.0 parts per million of CO averaged over an 8-hour period (national and State standard).
Operational Emissions – Mass Daily Emissions
The SCAQMD32 currently recommends that projects with operational mass daily emissions that exceed any of the following emissions thresholds be considered significant:
• 55 pounds per day of ROG;
• 55 pounds per day of NOx; • 550 pounds per day of CO;
• 150 pounds per day of SO x;
• 150 pounds per day of PM10; and
• 55 pounds per day of PM2.5.
The SCAQMD also recommends that any operational emissions from individual projects that exceed these thresholds be considered cumulatively considerable.33 With respect to cumulative air quality
30 South Coast Air Quality Management District, Localized Significance Threshold Methodology, July 2008
31 Ibid.
32 South Coast Air Quality Management District, Air Quality Significance Thresholds, website: http://www.aqmd.gov/ceqa/handbook/signthres.pdf, July 2008.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-31
City of Los Angeles November 2008
impacts, the SCAQMD uses a summary of projection approach based on consistency with the AQMP and in addition recommends that a project’s potential contribution to cumulative impacts should be assessed utilizing the same significance criteria as those for project-specific impacts.34
Operational Emissions – Localized Pollutant Concentrations
The SCAQMD35 currently recommends that projects with site-specific operational emissions that generate the following localized pollutant concentrations at existing human receptors be considered significant:
3 • 2.5 micrograms per cubic meter (µg/m ) of PM10 averaged over a 24-hour period; or
• 2.5 micrograms per cubic meter of PM2.5 averaged over a 24-hour period.
Because the Basin is currently in attainment of the national and State ambient air quality standards for
NO2 and CO, the SCAQMD currently recommends that projects with site-specific operational emissions that cause the following ambient air quality standards to be exceeded or contributes substantially to an exceeded standard at existing human receptors be considered significant:36
• 0.18 parts per million NO2 averaged over a 1-hour period (State standard); • 20 parts per million of CO averaged over a 1-hour period (State standard); or • 9.0 parts per million of CO averaged over an 8-hour period (national and State standard).
33 South Coast Air Quality Management District White Paper on Regulatory Options for Addressing Cumulative Impacts from Air Pollution Emissions, South Coast Air Quality Management District Board Meeting, September 5, 2003, Agenda No. 29, Appendix D, p. D-3.
34 The SCAQMD’s CEQA Air Quality Handbook identifies several methods to determine the cumulative significance of land use projects (i.e., whether the contribution of a project is cumulatively considerable). However, the SCAQMD no longer recommends the use of these methodologies (see Appendix G for email correspondence between Mike Wolf, CAJA and Steve Smith, South Coast Air Quality Management District, September 2006). Instead, the SCAQMD recommends that any construction-related emissions and operational emissions from individual development projects that exceed the project-specific mass daily emissions thresholds identified above also be considered cumulatively considerable. (White Paper on Regulatory Options for Addressing Cumulative Impacts from Air Pollution Emissions. South Coast Air Quality Management District Board Meeting. September 5, 2003, Agenda No. 29, Appendix D, p. D-3). The SCAQMD neither recommends quantified analyses of the emissions generated by a set of cumulative development projects nor provides thresholds of significance to be used to assess the impacts associated with these emissions.
35 South Coast Air Quality Management District, Localized Significance Threshold Methodology, July 2008.
36 Ibid.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-32
City of Los Angeles November 2008
Toxic Air Contaminants
The SCAQMD37 recommends that projects that could emit carcinogenic or toxic air contaminants that exceed the maximum individual cancer risk of 10 in one million and/or a non-cancer hazard index of 1.0 be considered significant and cumulatively considerable.
Greenhouse Gas Emissions
There are currently no thresholds or guidance adopted by the SCAQMD or other agencies in California to assess the significance of this potential impact. Global climate change is an international phenomenon; the regulatory background and scientific data are changing rapidly.
This EIR assumes that the project would be considered to contribute to a cumulatively considerable net increase in greenhouse gas emissions if it is inconsistent with strategies from the 2006 CAT Report that the Lead Agency deems to be applicable and feasible for the proposed land use, and implements design strategies consistent with AB 32 and the LA Green Plan.
Project Impacts
Consistency with the 2007 AQMP
The 2007 AQMP, discussed previously, was prepared to accommodate growth, to reduce the high levels of pollutants within the areas under the jurisdiction of SCAQMD, to return clean air to the region, and to minimize the impact of pollution control on the economy. Projects that are considered to be consistent with the AQMP would not interfere with attainment because this growth is included in the projections utilized in the formulation of the AQMP. Therefore, activities that are consistent with the applicable assumptions used in the development of the AQMP would not jeopardize attainment of the air quality levels identified in the AQMP, even if they exceed the SCAQMD’s recommended daily emissions thresholds.
As discussed in Section IV.A, Impacts found to be Less than Significant, the proposed project would not create any new homes or businesses and, therefore, would not contribute to any direct population growth. Therefore, the proposed project would be consistent with projections of employment and population identified in the Growth Management Chapter of SCAG’s Regional Comprehensive Plan and Guide (RCPG).38 In turn, the project would also be consistent with the AQMP growth projections.39
37 South Coast Air Quality Management District, Air Quality Significance Thresholds, website: http://www.aqmd.gov/ceqa/handbook/signthres.pdf, July 2008.
38 Southern California Association of Governments Regional Comprehensive Plan and Guide, Chapter 3, Growth Management, 1996.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-33
City of Los Angeles November 2008
Another measurement tool in determining consistency with the AQMP is to determine how a project accommodates the expected increase in population or employment.40 Generally, if a project is planned in a way that results in the minimization of vehicle miles traveled (VMT) both within the project and the community in which it is located, and thereby minimizes air pollutant emissions, that aspect of the project is consistent with the AQMP.
The project site is located in an urbanized area that is accessible by public transportation. Local public transportation in the area is provided by the Metropolitan Transportation Authority (Metro) and the Santa Monica Big Blue Bus. Metro lines servicing the area include line 28/328 which provides service between Century City and Downtown Los Angeles via Olympic Boulevard, and line 14 which provides service between Downtown Los Angeles and Beverly Hills via Beverly Boulevard. Big Blue Bus line 5 provides service between Santa Monica, Century City and the Rimpau Transit Center via Pico Boulevard, Olympic Boulevard, and Colorado Avenue. Furthermore, Big Blue Bus line 7 provides service between Santa Monica and the Rimpau Transit Center. The accessibility of public transit helps reduce project-related VMT.41 Therefore the proposed project is consistent with the goals of the AQMP for reducing VMT- related emissions.
Since the proposed project would be consistent with the goals of the AQMP for reducing VMT-related emissions and would not induce substantial population growth beyond City projections, impacts would be less than significant.
Construction Period Emissions – Mass Daily Emissions
During construction, two basic types of activities are expected to occur and generate emissions: (1) removal of the building façade (demolition); (2) construction of the proposed project structures and ancillary facilities which includes excavation to allow for enlarged footings on the ground level to support the Museum’s addition. Construction of the proposed project may result in regional or local impacts and include airborne dust from demolition, excavation and soil exporting as well as gaseous emissions from the use of heavy equipment, delivery and dirt hauling trucks, and employee vehicles. Regional pollutants, such as ozone, are those where emissions from many sources combine in the atmosphere and impact areas far removed from the emission sources. Local pollutants are those where the impacts occur very close to the source.
39 South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993.
40 Ibid.
41 Although public transit reduces project-related VMT, as a conservative measure, these reductions were not accounted for in this evaluation. In addition, the majority of visitors to the museum during the weekdays arrive via buses.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-34
City of Los Angeles November 2008
The analysis of daily construction emissions has been prepared utilizing the URBEMIS 2007 computer model recommended by the SCAQMD. Due to the construction time frame and the normal day-to-day variability in construction activities, it is difficult, if not impossible, to precisely quantify the daily emissions associated with the proposed construction activities. Nonetheless, the daily construction- related emissions have been estimated for peak construction days based on the assumptions described below.42
Equipment
Construction of the proposed project would be divided into two activities,43 each with its own type and amount of equipment. The first activity, excavation and demolition, would extend for approximately 3 months. The following equipment would be used for the first activity:
• two concrete/industrial saw (electric powered);44 • one crane; • two dumpers/tenders; • two forklifts; • one generator set; • one haul truck; • one tractor/loader/backhoe; and • one welder.
The second activity, building construction, would extend for approximately 21 months. The following equipment listed below would be used for the second activity:
• one crane; • one excavator; • two forklifts; • two generator sets; • two haul trucks;
42 The assumptions used to estimate the construction-related emissions of the proposed project were obtained from the construction contractor for the proposed project (Appendix G). In instances where the contractor could not provide the information, the default assumptions in the URBEMIS model were used.
43 The two activities analyzed herein include all six construction phases addressed in Section IV.I, Traffic/Transportation/Parking.
44 Since the concrete/industrial saws will be electric-powered, they will not be included in the evaluation of diesel- powered construction equipment.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-35
City of Los Angeles November 2008
• one tractor, loader or backhoe; and • one welder.
It is assumed that these pieces of equipment would run for a maximum of eight hours per day five days per week.
Trucks
As discussed above, approximately 20,000 square feet of the existing building façade would be removed as a part of the proposed project. In addition, approximately 260 cubic yards of soil would be excavated and removed from the proposed project. Removal of the existing building facade and soil would require approximately 1.5 truck trips (round trips) per day with each truck hauling 10 cubic yards of waste for a total of 60 days. Trips were assumed to average 30 miles each way based on URBEMIS 2007 defaults.
Construction Worker Vehicle Trips
Different workers would be on the project site at different phases of construction. This analysis uses the URBEMIS computer model defaults for construction worker vehicle trips. For the demolition phase of construction, the model assumes that the number of worker commute trips equals 125 percent of the total number of off-road vehicles. For the worker trips associated with the building construction phase, the URBEMIS computer model assumes 0.32 worker vehicle trips per unit of commercial/retail development per day during the peak construction period.
Table IV.C-8, Estimated Daily Construction Emissions, below, identifies daily emissions that are estimated to occur on peak construction days. Construction is anticipated to begin in the first half of 2009 and be completed within 24 months.
As shown in Table IV.C-8, construction-related mass daily emissions would not exceed any of the SCAQMD significance thresholds and would, therefore, be considered less than significant.
Construction Period Emissions – Localized Emissions of CO, NOx, PM10, and PM2.5
The SCAQMD has developed localized significance threshold (LST) look-up tables for project sites that are one, two, and five acres in size to simplify the evaluation of localized emissions at small sites. LSTs are provided for each SRA and various distances from the source of emissions. As described above, a number of properties with sensitive receptors are located nearby the project site including residences, the YULA school, and the UCLA medical center. In addition, the construction site is located at the Museum, which attracts a wide array of populations, including sensitive receptors such as school children and the elderly. Therefore, LSTs for a 0.8-acre site with receptors located within 25 meters were calculated and used to address the potential localized NOx, CO, PM10, and PM2.5 emissions.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-36
City of Los Angeles November 2008
Table IV.C-8 Estimated Mass Daily Construction Emissions
Emissions in Pounds per Day a Emissions Source ROG NOx CO SOx PM10 PM2.5 Excavation and Demolition (2009) Fugitive Dust 0.00 0.00 0.00 0.00 0.69 0.14 Off-Road Diesel Equipment 4.59 44.49 16.60 0.00 1.81 1.67 On-Road Diesel Equipment 0.13 1.59 0.64 0.00 0.08 0.07 Worker Trips 0.09 0.18 2.90 0.00 0.02 0.01 Total Excavation and Demolition 4.81 46.26 20.15 0.01 2.60 1.89 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Building Construction (2009) Building Construction Off-Road Diesel Equip. 4.56 22.07 14.48 0.00 1.59 1.46 Building Construction Worker Trips 0.02 0.25 0.21 0.00 0.01 0.01 Building Construction Vendor Trips 0.05 0.10 1.57 0.00 0.01 0.01 Total Building Construction Emissions 4.64 22.42 16.26 0.00 1.61 1.48 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Building Construction (2010) Building Construction Off-Road Diesel Equip. 4.29 20.93 14.22 0.00 1.49 1.37 Building Construction Worker Trips 0.02 0.23 0.19 0.00 0.01 0.01 Building Construction Vendor Trips 0.05 0.09 1.47 0.00 0.01 0.01 Total Building Construction Emissions 4.35 21.25 15.88 0.00 1.52 1.39 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Note: Subtotals may not appear to add correctly due to rounding in the URBEMIS2007 model.
a Construction activities include all six construction phases addressed in Section IV.I, Traffic/Transportation/Parking.
Source: Christopher A. Joseph & Associates, 2008. Calculation sheets are provided in Appendix G.
The average daily construction emissions that would be generated at the project site during the construction activities are shown in Table IV.C-9, Localized Construction-Related Air Quality Impacts – Proposed Project, along with the applicable LSTs for SRA 2.
As shown in Table IV.C-9, construction-related daily emissions would not exceed the SCAQMD’s applicable LSTs for the construction activities. Therefore, this would be a less-than-significant impact.
A separate TAC evaluation was not conducted for construction activities. Although the toxic air contaminant diesel particulate matter (DPM) may be generated from diesel-powered equipment used during construction activities, DPM’s health effects are only identified for chronic exposure (e.g., over a 70 year exposure). Given the short construction period (within 24 months), DPM does not require a separate analysis. No other TACs were identified for the construction activities.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-37
City of Los Angeles November 2008
Table IV.C-9 Localized Construction-Related Air Quality Impacts – Proposed Project
Emissions in Pounds per Day a Emissions Source NOx CO PM10 PM2.5 Demolition and Excavation Total Site-Specific Emissions 35.8 16.6 2.1 1.9 SCAQMD LSTs for SRA 2 88.58 471.94 3.43 2.97 Significant Impact? No No No No Building Construction Total Site-Specific Emissions 52.4 25.2 3.1 0.7 SCAQMD LSTs for SRA 2 88.58 471.94 3.43 2.97 Significant Impact? No No No No Note: NT = No threshold.
a Construction activities include all six construction phases addressed in Section IV.I, Traffic/Transportation/Parking.
Source: Christopher A. Joseph & Associates, 2008. Calculation sheets are provided in Appendix G.
Operational Emissions – Mass Daily Emissions
Additional operational emissions generated by both stationary and mobile sources would result from normal day-to-day activities on the project site after the expansion. Stationary area source emissions would be generated by the additional consumption of natural gas for space and water heating devices and cooking appliances, the operation of landscape maintenance equipment, the additional use of consumer products, and the application of architectural coatings (paints). Mobile emissions would be generated by the motor vehicles traveling to and from the project site.
The analysis of daily operational emissions has been prepared utilizing the URBEMIS 2007 computer model recommended by the SCAQMD. The results of these calculations are presented in Table IV.C-10, Estimated Mass Daily Operational Emissions – Proposed Project. As shown therein, the proposed project would generate an increase in average daily emissions that does not exceed the thresholds of significance recommended by the SCAQMD. This would be a less-than-significant impact.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-38
City of Los Angeles November 2008
Table IV.C-10 Estimated Mass Daily Operational Emissions – Proposed Project
Emissions in Pounds per Day
Emissions Source ROG NOx CO SOx PM10 PM2.5 Summertime (Smog Season) Emissions Proposed Land Uses Water and Space Heating 0.01 0.20 0.17 0.00 0.00 0.00 Landscape Maintenance Equipment 0.26 0.04 3.21 0.00 0.01 0.01 Consumer Products 0.00 0 0 0 0 0 Architectural Coatings 0.18 0 0 0 0 0 Motor Vehicles 10.11 10.56 129.79 0.14 24.37 4.61 TOTAL 10.56 10.80 133.17 0.14 24.38 4.62 SCAQMD Thresholds 55.00 55.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Wintertime (Non-Smog Season) Emissions Proposed Land Uses Water and Space Heating 0.01 0.20 0.17 0.00 0.00 0.00 Landscape Maintenance Equipment 0.26 0.04 3.21 0.00 0.01 0.01 Consumer Products 0.00 0 0 0 0 0 Architectural Coatings 0.18 0 0 0 0 0 Motor Vehicles 11.56 13.06 124.76 0.11 24.37 4.61 TOTAL 12.01 13.30 128.14 0.11 24.38 4.62 SCAQMD Thresholds 55.00 55.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Note: Subtotals may not appear to add correctly due to rounding in the URBEMIS 2007 model. As a conservative estimate, emissions from landscape maintenance equipment were included in both summertime and wintertime emissions.
Source: Christopher A. Joseph & Associates, 2008. Calculation sheets are provided in Appendix G.
Operational Emissions – Localized Emissions of CO, NOx, PM10, and PM2.5
The average daily emissions associated with stationary and motor vehicles operating within the project site have the potential to generate localized emissions of NOx, CO PM10, and PM2.5. The average daily emissions have been calculated assuming that each additional vehicle would travel a maximum of 0.1 mile within the project site based on a round-trip through the proposed project site. SCAQMD recommends that off-site mobile emissions from the project should not be included.45 The results of these calculations for area sources and the internal vehicle trips are shown in Table IV.C-11, Localized Operational Air Quality Impacts – Proposed Project. As shown, the average daily emissions generated within the project site would not exceed the applicable operational LSTs for SRA 2. This would be a less-than-significant impact.
45 South Coast Air Quality Management District, Localized Significance Threshold Methodology, July 2008.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-39
City of Los Angeles November 2008
Table IV.C-11 Localized Operational Air Quality Impacts – Proposed Project
Emissions in Pounds per Day
Emissions Source NOx CO PM10 PM2.5 Summertime (Smog Season) Emissions Water and Space Heating 0.20 0.17 0.00 0.00 Landscape Maintenance Equipment 0.04 3.21 0.01 0.01 Consumer Products 0 0 0 0 Architectural Coatings 0 0 0 0 Motor Vehicles 1.59 15.89 0.32 0.08 Total Localized Emissions 1.83 19.27 0.33 0.09 SCAQMD LSTs for SRA 2 74.93 372.91 1.14 0.83 Significant Impact? No No No No Wintertime (Non-Smog Season) Emissions Water and Space Heating 0.20 0.17 0.00 0.00 Landscape Maintenance Equipment 0.04 3.21 0.01 0.01 Consumer Products 0 0 0 0 Architectural Coatings 0 0 0 0 Motor Vehicles 1.85 21.41 0.32 0.08 Total Localized Emissions 2.09 24.79 0.33 0.09 SCAQMD LSTs for SRA 2 74.93 372.91 1.14 0.83 Significant Impact? No No No No Notes: NT = No threshold Subtotals may not appear to add correctly due to rounding in the URBEMIS 2007 model. As a conservative estimate, emissions from landscape maintenance equipment were included in both summertime and wintertime emissions.
Source: Christopher A. Joseph & Associates, 2008. Calculation sheets are provided in Appendix G.
Operational Emissions – Localized Hotspot CO Concentrations
The localized hotspot CO concentration impacts associated with the proposed project have been evaluated with the addition of traffic growth associated with cumulative development.
Similar to existing hotspot CO concentrations, the simplified CALINE4 screening procedure was used to predict future peak CO concentrations at the study-area intersections in the vicinity of the project site in the year 2011 with cumulative development in order to provide a worst-case analysis of future conditions. The results of these calculations are provided in Table IV.C-12, Future with Project Localized Carbon Monoxide Concentrations (Peak).
As shown in Table IV.C-12, future CO concentrations near these intersections would not exceed the national and State ambient air quality standards for CO. Therefore, implementation of the proposed project and cumulative development would not expose any possible sensitive receptors (such as residential uses, schools, hospitals) located in close proximity to these intersections to substantial
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-40
City of Los Angeles November 2008
localized pollutant concentrations. This would be a less-than-significant impact regarding the exposure of sensitive receptors to substantial pollutant concentrations.
Table IV.C-12 Future With Project Localized Carbon Monoxide Concentrations (Peak)
CO Concentrations in Parts Per Million Roadway Edge 25 Feet 50 Feet Intersection 1-Hour 8-Hour 1-Hour 8-Hour 1-Hour 8-Hour 1) Olympic Boulevard & Century Park East 6.4 4.4 5.8 3.9 5.5 3.7 2) Olympic Boulevard & Roxbury Drive 6.1 4.2 5.6 3.7 5.4 3.6 3) Olympic Boulevard & Beverwil Drive 6.3 4.4 5.7 3.8 5.4 3.6 4) Pico Boulevard & Century Park East 5.9 4.0 5.4 3.6 5.2 3.5 5) Pico Boulevard & Roxbury Drive 5.8 4.0 5.4 3.6 5.2 3.4 6) Pico Boulevard & Beverwil Drive 6.0 4.1 5.5 3.7 5.3 3.5 7) Pico Boulevard & Beverly Drive 5.7 3.8 5.3 3.5 5.1 3.4 8) Pico Boulevard & Robertson Boulevard 5.8 3.9 5.4 3.6 5.2 3.5 9) Cashio Street & Castello Avenue 4.8 3.1 4.6 3.0 4.6 2.9 10) Cashio Street & Beverwil Drive 5.2 3.4 4.9 3.2 4.8 3.1 11) Monte Mar Drive & Beverwil Drive 5.6 3.7 5.0 3.3 4.9 3.2 Notes: National 1-hour standard is 35.0 ppm State 1-hour standard is 20.0 ppm National and State 8-hour standard is 9.0 ppm
Source: Christopher A. Joseph & Associates, 2008. Calculation sheets are provided in Appendix G. Based on year 2007 EMFAC2007 Winter emission factors.
Operational Emissions – Toxic Air Contaminants
The impacts from the project’s emissions of toxic air contaminants (TACs) were evaluated for the project site. The museum currently attracts, among its visitors, school children delivered to the project site by diesel-powered school buses. In response to comments raised in the Notice of Preparation (NOP), an analysis of the potential impacts from two additional diesel-powered school buses was done even though the proposed project is not expected to increase bus trips. Diesel-powered vehicles are recognized by CARB as a potential source of diesel particulate matter (DPM), identified as a known toxic air contaminant and would be emitted from buses traveling to and from the project site. School buses are prohibited to travel through the nearby residential areas to access the Museum pursuant to Condition 15 of the 1986 CUP. However, to evaluate a hypothetical worst-case scenario, a health risk assessment (HRA) was conducted to evaluate the impacts of annual average diesel exhaust emissions from two school buses traveling through the residential areas. The evaluation includes two buses per day even though no additional buses are expected to occur from the proposed project. The HRA is discussed in detail below.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-41
City of Los Angeles November 2008
Health Risk Assessment (HRA)
The HRA prepared for the proposed project was designed to evaluate the chronic cancer risk as well as non-cancer health effects of DPM associated with school bus travel through residential neighborhoods. As stated earlier, DPM from construction activities are not evaluated because the short duration that DPM would be generated from these activities. DPM emissions from construction activities are not expected to significantly increase exposure to DPM relative to the DPM associated with the school bus travel. DPM has been identified by the State of California as a toxic air contaminant which, exposure to, poses potential cancer and non-cancer health risks. The methodologies and assumptions utilized in the HRA are consistent with guidance provided by various federal and State agencies including the EPA, Cal/EPA, CARB, and SCAQMD.
With respect to methodology, an air quality dispersion model was used to estimate maximum potential diesel concentrations at receptors surrounding the proposed site. The dispersion model used an emission factor of approximately 0.695 grams per mile (g/mi) for diesel powered school buses obtained from the EMFAC2007 computer model. In addition, the model utilizing a conservative approach, assumed that two buses per day (10 buses per week) would travel through a 0.25-mile road segment at a speed of 10 miles per hour between the hours of 10 AM and 5 PM (which are the operating hours of MOT). The estimated air concentration calculated by the air quality dispersion model was then used to calculate the cancer risk and non-cancer hazard effects for the evaluated receptors exposed to DPM based on methodologies consistent with the Cal/EPA’s Office of Environmental Health Hazard Assessment Air Toxics Hot Spots Program Risk Assessment Guidelines.46
Based on the dispersion model, the maximum concentration of DPM in air near a receptor would be approximately 0.002 parts per billion. Only the single highest concentration at receptor height was evaluated, since it can be reasonably assumed that other receptors in the area would have a concentration less then the maximum. The maximum DPM concentration determined for the area would result in an incremental lifetime cancer risk of 0.43 in one million which is below the significance criteria of 10 per one million.47 In addition, the DPM concentration for the area would result in a non-cancer health risk of approximately 0.0003. Any non-cancer health risk less than one (1) is considered to be less than significant. These thresholds would only be exceeded if 47 daily bus trips occurred within the 0.25-mile segment of road assumed for the dispersion model. The estimated maximum cancer and non-cancer health impacts are summarized in Table IV.C-13, Proposed Project Estimated Health Risks. The complete HRA is presented in Appendix G to this Draft EIR.
46 Cal/EPA OEHHA, Air Toxics Hot Spots Program Risk Assessment Guidelines, 2003.
47 South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-42
City of Los Angeles November 2008
The inhalation cancer risk and the non-cancer hazard index at the maximum receptor location are below the significance thresholds. Therefore, impacts would be less than significant.
Table IV.C-13 Proposed Project Estimated Health Risks
Impact Value Cancer Risk 0.4 in one million Significance Threshold 10 in one million Significant Impact? No Non-Cancer HIa 0.0003 Significance Threshold 1.0 Significant Impact? No Notes: Non-Cancer HI = Non-Cancer Health Index
a The Non-Cancer HI, a unitless value, is the ratio of the DPM concentration and the Reference Exposure Limit (REL). The REL is a concentration level at or below which no adverse health effects are expected following long-term exposure.
Source: Christopher A Joseph & Associates, June 2008.
Operational Emissions – Airborne Odors
As part of the proposed project, food preparation facilities would be constructed. To evaluate potential odors from these operations, an odor modeling study was conducted by ERM-West, Inc (ERM) for the proposed project (see Appendix H to this Draft EIR). Only minor food preparation operations currently exist at the project site, so effective existing setting odor measurements could not be conducted. Air dispersion modeling analysis was used in order to assess the potential maximum short-term odor levels. The dispersion modeling was performed using the US EPA’s Industrial Source Complex—Short Term, Release 3 (ISCST3) model to estimate the short-term odor concentrations. Odor emission data from a restaurant exhaust with similar exhaust characteristics to the proposed project was used to simulate odors for the proposed project. Odors were quantified in terms of detectability using the dilution-to-threshold ratio (D/T). The maximum odor concentration projected at the property boundary was predicted with a value of 1.4 D/T. Typically, odor concentrations below 2 D/T cannot be discerned by the general public. Based on the analysis, no significant odor concentrations are expected off-site from the proposed food preparation operations. Therefore, potential odors from the proposed project food preparation operations would be less than significant.
Operational Emissions – Greenhouse Gas Emissions
As discussed below, under “Cumulative Impacts, the proposed project would be consistent with all feasible and applicable strategies to reduce greenhouse gas emissions in California. Therefore, the impact of the proposed project would be less than significant.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-43
City of Los Angeles November 2008
CUMULATIVE IMPACTS
AQMP Consistency
The 2007 AQMP was prepared to accommodate growth anticipated in the Basin, to reduce the high levels of pollutants within the areas under the jurisdiction of SCAQMD, to return clean air to the region, and to minimize the impact on the economy. Growth considered to be consistent with the 2007 AQMP would not interfere with attainment because this growth is included in the projections utilized in the formulation of the AQMP. Consequently, as long as growth in the Basin is within the projections for growth identified in the Growth Management Chapter of the RCPG, implementation of the 2007 AQMP will not be obstructed by such growth. As discussed above with respect to project-level impacts, the proposed project would not jeopardize attainment of air quality standards in the 2007 AQMP for the Basin and the Los Angeles County portion of the Basin; therefore the project would not contribute to a cumulatively considerable impact, as it would neither conflict with nor obstruct the implementation of the applicable air quality plan.
Construction and Operational Impacts
Because the Basin is currently in nonattainment for ozone, CO, and PM10, cumulative development could exceed an air quality standard or contribute a substantial increase to an existing or projected air quality exceedance. With respect to cumulative air quality impacts, the SCAQMD uses a summary of projection approach based on consistency with the AQMP and in addition recommends that a project’s potential contribution to cumulative impacts should be assessed utilizing the same significance criteria as those for project specific impacts. As discussed previously, construction and operational emissions associated with the proposed project would not exceed the recommended thresholds and would neither be cumulatively considerable nor significant.
As construction at the adjacent BHS may be conducted concurrently with the construction of the proposed project, responses to the NOP raised questions regarding the impacts that would result. To evaluate the cumulative impact of the two construction sites, the localized construction–related emissions from the two sites were summed and compared to localized significance thresholds based on the combined size of the sites. At the time of this evaluation, the dates for construction for the BHS have not been established; therefore, the worst-case alignment was used (i.e., the highest emissions from each site were summed). Construction equipment anticipated to be used at BHS were provided by the BHS applicant (Appendix G). The average daily construction emissions that would be generated at the two sites during the construction activities are shown in Table IV.C-14, Localized Construction-Related Air Quality Impacts – Cumulative, along with the applicable LSTs for SRA 2. As shown therein, the average daily emissions generated within the two sites would not exceed the applicable LSTs for SRA 2. Therefore, this would be a less-than-significant impact.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-44
City of Los Angeles November 2008
Table IV.C-14 Localized Construction-Related Air Quality Impacts - Cumulative
Emissions in Pounds per Day Emissions Source NOx CO PM10 PM2.5 BHS Maximum Site-Specific Emissions 40.8 19.8 2.1 1.9 Proposed Project Maximum Site-Specific Emissions 35.8 16.6 2.1 1.9 Total 76.6 36.4 4.2 3.8 SCAQMD LSTs for SRA 2 121.47 766.33 6.52 3.96 Significant Impact? No No No No Note: NT = No threshold.
Source: Christopher A. Joseph & Associates, 2008. Calculation sheets are provided in Appendix G.
Localized CO Impacts
Cumulative development is not expected to expose sensitive receptors to substantial pollutant concentrations. As discussed previously, the future CO concentrations at the study intersections in 2011 are based on the projected future traffic volumes from the study intersections contained in the traffic study for the proposed project, which takes into account emissions from the proposed project, future ambient growth, and related projects in the project area. As shown in Table IV.C-12, CO concentrations near the study intersections would not exceed national or State ambient air quality standards. Therefore, CO hotspots would not occur near these intersections in the future, and this cumulative impact would be less than significant; no significant project cumulative impact would occur for CO. It is also unlikely that future projects would result in long-term future exposure of sensitive receptors to substantial pollutant concentrations because CO levels are projected to be lower in the future due to improvements in vehicle emission rates predicted by the CARB. Therefore, the proposed project with respect to CO hot spots would not contribute to a cumulatively considerable impact.
Greenhouse Gas Emissions
Consistent with the OPR Climate Change Report, an inventory of the proposed project’s GHG emissions in carbon dioxide equivalencies (CO2e) was calculated using methodologies described in the California Climate Action Registry (CCAR) General Reporting Protocol (version 3.0) published in April 2008.48 While this Protocol was not developed expressly for CEQA purposes, it does provide methods that are appropriate to use to quantify the GHG emissions.
48 California Climate Action Registry General Reporting Protocol: Reporting Entity-Wide Greenhouse Gas Emissions, April 2008.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-45
City of Los Angeles November 2008
The predicted greenhouse gas emissions are shown in Table IV.C-15, Predicted Project Operational Greenhouse Gas Emissions.
Table IV.C-15 Predicted Proposed Project Operational Greenhouse Gas Emissions
Emissions Source CO2e Emissions in Metric Tons per Year Proposed Project Natural Gas Use 57.62 Electrical Use 164.96 Motor Vehicles 1,892.56 Total 2,115.14 Source: Christopher A. Joseph & Associates, 2008. Calculation data and results are provided in Appendix G.
The GHG emissions presented in Table IV.C-15 do not account for project design features that may further reduce GHG emissions. As discussed earlier, these include:
• The electrical load for the proposed project would meet Title 24 energy consumption guidelines;
• Installation of bike racks, if space allows;
• Use of electric saws during construction activities during construction activities;
• Recycling of more than 50 percent of construction waste when possible;
• Use of low-VOC paint with a VOC rating of 125 grams per liter or less;
• Installation of energy-efficient appliances, such as and high-efficiency dishwashers (Energy Star rated); and heating, ventilation and air conditioning systems (HVAC) that would meet MERV 12;
• Installation of energy-efficient lighting (i.e., low wattage lamps);
• Installation of energy-efficient, low-flow water fixtures, including: high-efficiency toilets (1.28 gallons per flush), urinals (0.5 gallons per flush), and restroom faucets (1.5 gallons per minute or less), and public restroom self-closing faucets;
• Installation of spectrally selective low-e glass and high performance windows where feasible;
• Insulation in new walls would exceed Title 24 requirements;
• Installation of high-efficiency dishwashers (Energy Star rated) where applicable;
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-46
City of Los Angeles November 2008
• Installation of a sealed duct system;
• Installation of R-4 insulation for all 2-inch or smaller exterior hot water pipes (R-6 for larger than 2-inch pipes);
• Installation of roofing with energy-efficient, light-colored, high-reflectance or high albedo on at least 80 percent of the roof;
• Installation of photocell controls for exterior common area lighting;
• Installation of a hot water recirculation system; and
• Strict prohibition of single-pass cooling where applicable.
The proposed project would comply with all requirements set forth in AB 32, the 2006 CAT Report, and the LA Green Plan (see also Mitigation Measure C-4).
Emitting GHGs into the atmosphere is not itself an adverse environmental effect. Rather, it is the increased accumulation of GHGs in the atmosphere that may result in global climate change. The resultant consequences of that climate change can cause adverse environmental effects. Due to the complex physical, chemical, and atmospheric mechanisms involved in global climate change, it is not possible to predict the specific impact, if any, to global climate change from one project’s relatively small incremental increase in emissions. Therefore, impacts associated with GHG emissions should not be evaluated on a project-level basis, but instead on a cumulative basis.
The consistency of the proposed project with the strategies from the 2006 CAT Report is evaluated in Table IV.C-16, Project Consistency with 2006 CAT Report Greenhouse Gas Emissions Reduction Strategies. As shown, the proposed project would be consistent with all feasible and applicable strategies to reduce greenhouse gas emissions in California. As stated earlier, the Los Angeles Green Building Ordinance does not apply to the proposed project due to the size of proposed project. Therefore, the impact of the proposed project would be less than significant.
Table IV.C-16 Project Consistency with 2006 CAT Report Greenhouse Gas Emission Reduction Strategies
Strategy Project Consistency California Air Resources Board Vehicle Climate Change Standards. AB 1493 Consistent. The vehicles that travel to and from the (Pavley) required the state to develop and adopt project site on public roadways would be in compliance regulations that achieve the maximum feasible and with CARB vehicle standards that are in effect at the time cost-effective reduction of climate change emissions of vehicle purchase. emitted by passenger vehicles and light duty trucks. Regulations were adopted by the CARB September 2004.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-47
City of Los Angeles November 2008
Table IV.C-16 (Continued) Project Consistency with 2006 CAT Report Greenhouse Gas Emission Reduction Strategies
Strategy Project Consistency Diesel Anti-Idling. In July 2004, the CARB adopted Consistent. Current State law restricts diesel vehicles a measure to limit diesel-fueled commercial motor idling to five minutes or less. Diesel vehicles traveling to vehicle idling. the project site are subject to this State-wide law. Signs indicating the limited idling requirements will be placed in appropriate areas. Alternative Fuels: Biodiesel Blends. CARB would Consistent. The project would not impede this standard, develop regulations to require the use of 1 to 4 which is applicable to State agencies. The diesel vehicles percent biodiesel displacement of California diesel that travel to and from the project site on public roadways fuel. could utilize this fuel once it is commercially available. Alternative Fuels: Ethanol. Increased use of E-85 Consistent. The project would not impede this standard, fuel. which is applicable to State agencies. Visitors and employees of the proposed project could purchase flex- fuel vehicles and utilize this fuel once it is commercially available in the region and local vicinity. Heavy-Duty Vehicle Emission Reduction Consistent. The project would not impede this standard, Measures. Increased efficiency in the design of which is applicable to State agencies. The heavy-duty heavy duty vehicles and an education program for the vehicles that travel to and from the project site on public heavy duty vehicle sector. roadways would be subject to all applicable CARB efficiency standards that are in effect at the time of vehicle manufacture. Achieve 50% Statewide Recycling Goal. Consistent. The project would not impede this standard, Achieving the State’s 50 percent waste diversion which is applicable to State agencies. As discussed in mandate as established by the Integrated Waste Section IV.A, Impacts Found to be Less than Significant, Management Act of 1989, (AB 939, Sher, Chapter each city and county in the State must divert 50 percent of 1095, Statutes of 1989), will reduce climate change its solid waste from landfill disposal through source emissions associated with energy intensive material reduction, recycling, and composting. All solid waste extraction and production as well as methane generated by the proposed project would be disposed of emission from landfills. A diversion rate of 48% has in accordance with all applicable regulations. As such, been achieved on a statewide basis. Therefore, a 2% the proposed project would not impede the achievement additional reduction is needed. of this goal. Zero Waste – High Recycling. Efforts to exceed Consistent. The project would not impede this standard, the 50 percent goal would allow for additional which is applicable to State agencies. As discussed reductions in climate change emissions. previously, all solid waste generated by the proposed project would be disposed of in accordance with all applicable regulations. Therefore, the proposed project would not impede the achievement of this goal. Department of Forestry Urban Forestry. A new statewide goal of planting 5 Consistent. The proposed project would not impede the million trees in urban areas by 2020 would be expansion of local urban forestry programs. achieved through the expansion of local urban forestry programs. Department of Water Resources Water Use Efficiency. Approximately 19 percent of Consistent. As discussed in Section IV.A, the proposed all electricity, 30 percent of all natural gas, and 88 project would not have a significant impact in regards to million gallons of diesel are used to convey, treat, waste water generation or water consumption. distribute and use water and wastewater. Increasing the efficiency of water transport and reducing water use would reduce greenhouse gas emissions.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-48
City of Los Angeles November 2008
Table IV.C-16 (Continued) Project Consistency with 2006 CAT Report Greenhouse Gas Emission Reduction Strategies
Strategy Project Consistency Energy Commission (CEC) Building Energy Efficiency Standards in Place Consistent. The project would be required to be and in Progress. Public Resources Code 25402 constructed in compliance with the standards of Title 24 authorizes the CEC to adopt and periodically update that are in effect at the time of development. its building energy efficiency standards (that apply to newly constructed buildings and additions to and alterations to existing buildings). Appliance Energy Efficiency Standards in Place Consistent. Under State law, appliances that are and in Progress. Public Resources Code 25402 purchased for the project – both pre- and post- authorizes the Energy Commission to adopt and development – would be consistent with energy periodically update its appliance energy efficiency efficiency standards that are in effect at the time of standards (that apply to devices and equipment using manufacture. energy that are sold or offered for sale in California). Fuel-Efficient Replacement Tires & Inflation Consistent. The project would not impede this standard, Programs. State legislation established a statewide which is applicable to State agencies. Visitors and program to encourage the production and use of more employees of the proposed project could purchase tires efficient tires. for their vehicles that comply with State programs for increased fuel efficiency. Alternative Fuels: Non-Petroleum Fuels. Consistent. The project would not impede this standard, Increasing the use of non-petroleum fuels in which is applicable to State agencies. Visitors and California’s transportation sector, as recommended employees of the proposed project could purchase as recommended in the CEC’s 2003 and 2005 alternative fuel vehicles and utilize these fuels once they Integrated Energy Policy Reports. are commercially available in the regional and local vicinity. Business, Transportation and Housing Measures to Improve Transportation Energy Consistent. The location of the proposed project Efficiency. Builds on current efforts to provide a promotes fuel conservation as it is located close to public framework for expanded and new initiatives transportation, providing visitors and employees of the including incentives, tools and information that project an alternative to the single occupancy vehicle. advance cleaner transportation and reduce climate change emissions. Smart Land Use and Intelligent Transportation Consistent. The proposed project is located near a Systems (ITS). Smart land use strategies encourage number of public transportation services, thereby jobs/housing proximity, promote transit-oriented reducing the number of vehicles miles traveled. Local development, and encourage high-density public transportation in the study area is provided by the residential/commercial development along transit Los Angeles County Metropolitan Transportation corridors. ITS is the application of advanced Authority (Metro) and the Santa Monica Big Blue Bus. technology systems and management strategies to Metro lines serving the area include line 28/328 and line improve operational efficiency of transportation 14. Santa Monica Big Blue Bus lines serving the area systems and movement of people, goods and include lines 5 and 7. services. The Governor is finalizing a comprehensive 10-year strategic growth plan with the intent of developing ways to promote, through state investments, incentives and technical assistance, land use, and technology strategies that provide for a prosperous economy, social equity and a quality environment. Smart land use, demand management, ITS, and value pricing are critical elements in this
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-49
City of Los Angeles November 2008
Table IV.C-16 (Continued) Project Consistency with 2006 CAT Report Greenhouse Gas Emission Reduction Strategies
Strategy Project Consistency plan for improving mobility and transportation efficiency. Specific strategies include: promoting jobs/housing proximity and transit-oriented development; encouraging high density residential/commercial development along transit/rail corridor; valuing and congestion pricing; implementing intelligent transportation systems, traveler information/traffic control, incident management; accelerating the development of broadband infrastructure; and comprehensive, integrated, multimodal/intermodal transportation planning. State and Consumer Services Agency Green Buildings Initiative. Green Building Consistent. As discussed previously, the proposed Executive Order, S-20-04 (CA 2004), sets a goal of project would be required to be constructed in compliance reducing energy use in public and private buildings with the standards of Title 24 that are in effect at the time by 20 percent by the year 2015, as compared with of development. The current 2005 Title 24 standards are 2003 levels. The Executive Order and related action approximately 8.5 percent more efficient than those of the plan spell out specific actions state agencies are to 2001 Title 24 standards. take with state-owned and –leased buildings. The order and plan also discuss various strategies and incentives to encourage private building owners and operators to achieve the 20 percent target. Public Utilities Commission (PUC) California Solar Initiative. The solar initiative Consistent. The project would not impede this standard, includes installation of 1 million solar roofs or an which is applicable to State agencies. Although solar equivalent 3,000 MW by 2017 on homes and roofs are not proposed as part of the project, they could be businesses, increased use of solar thermal systems to purchased and installed in the future if they become cost offset the increasing demand for natural gas, use of effective from a purchase and maintenance standpoint. advanced metering in solar applications, and creation of a funding source that can provide rebates over 10 years through a declining incentive schedule. a The following strategies are not applicable to the proposed project and, thus, are not included above: Hydrofluorocarbon Reduction; Transportation Refrigeration Units, Off-Road Electrification, Port Electrification (ship to shore); Manure Management; Semi Conductor Industry Targets; Reduced Venting and Leaks on Oil and Gas Systems; Hydrogen Highway; Landfill Methane Capture; Forest Management; Forest Conservation; Fuels Management/Biomass; Afforestation/Reforestation; Cement Manufacturing; Municipal Utility Energy Efficiency Programs/Demand Response; Municipal Utility Renewable Portfolio Standard; Municipal Utility Combined Heat and Power; Municipal Utility Electricity Sector Carbon Policy; Conservation Tillage/Cover Crops; Enteric Fermentation; Acceleration Renewable Portfolio Standard; and Investor Owned Utility Programs.
Sources: Climate Action Team, 2006 and Christopher A. Joseph & Associates, 2008.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-50
City of Los Angeles November 2008
MITIGATION MEASURES
As no significance thresholds for construction or operational impacts were exceeded, mitigation measures are not required. Although not considered mitigation measures, the project developer will implement measures in accordance with SCAQMD Rule 403 (fugitive dust), Rule 431.2 (sulfur content of liquid fuels), Rule 1113 (architectural coatings), Rule 1138 (restaurant operations) and comply with the California Idle Reduction Program as part of the project design.
(C-1) The project developer shall include in construction contracts the control measures required and recommended by the SCAQMD at the time of development. Examples of the types of measures currently required and recommended include the following:
Rule 403 - Fugitive Dust Rule
• Use watering to control dust generation during demolition of structures or break-up of pavement.
• Water active grading/excavation sites and unpaved surfaces at least three times daily.
• Cover stockpiles with tarps or apply non-toxic chemical soil binders.
• Limit vehicle speed on unpaved roads to 15 miles per hour.
• Sweep daily (with water sweepers) all paved construction parking areas and staging areas.
• Provide daily clean-up of mud and dirt carried onto paved streets from the site.
• Install wheel washers for all exiting trucks, or wash off the tires or tracks of all trucks and equipment leaving the site.
• Suspend excavation and grading activity when winds (instantaneous gusts) exceed 15 miles per hour over a 30-minute period or more.
• An information sign shall be posted at the entrance to each construction site that identifies the permitted construction hours and provides a telephone number to call and receive information about the construction project or to report complaints regarding excessive fugitive dust generation. Any reasonable complaints shall be rectified within 24 hours of their receipt.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-51
City of Los Angeles November 2008
Rule 431 - Sulfur Content of Fuels
• Use liquid fuel for stationary sources with sulfur content equal to or less than 500 ppm by weight or gaseous fuel equal to or less than concentrations provided in Table 1 in Rule 431.1.
• Use low sulfur diesel fuel for which the sulfur content does not exceed 15 ppm by weight.
• Maintain a record of sulfur content specifications and related information.
• Upon request from District staff, provide documents generated in the normal course of business reflecting the transfer, purchase, or sale of diesel fuel, including product certification, product transfer documentation, and purchase orders.
Rule 1113 - Architectural Coatings
• Apply rust-preventative coating below the VOC limit based on coating categories as specified in the Table of Standards VOC Limits table in Rule 1113.
• Ensure that all architectural coating containers (including drums, buckets, cans, pails, and trays) be closed when not in use.
• Add up to 10% by volume of VOC to a lacquer to avoid blushing of the finish if on the day of application:
• Relative humidity is greater than 70% and temperature is below 65°F,
• The coating is not applied from April 1 to October 31, and,
• The coating contains acetone and no more than 550 g of VOC per liter of coating (less water and exempt compounds) prior to addition of the VOC.
Rule 1138 - Control of the Emissions from Restaurant Operations
• Require the chain-driven charbroiler be equipped and operated with a catalytic oxidizer control device
• Test the charbroiler in accordance with the test method under the District's Protocol and certified by the Executive Officer.
• Maintain catalytic oxidizers or other control devices in good working order in accordance with the manufacture's manual to minimize visible emissions to the atmosphere.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-52
City of Los Angeles November 2008
• Maintain, for a minimum of five years, the records of the date of installation or changing of any catalyst, and the date and time of cleaning and maintenance.
California Idling Reduction Program
• Limit idling time to five minutes for diesel-fueled commercial motor vehicle, with gross vehicular weight ratings of greater than 10,000 pounds. Signs indicating the limited idling requirements will be placed in appropriate areas.
(C-2) The project developer shall include in construction contracts that all concrete saws be electrical-powered.
(C-3) The project developer shall post signs on the project site stating that idling time is restricted to five minutes; such that the signage is visible to construction vehicle drivers.
Although it is anticipated that the proposed project would have a less-than-significant impact with respect to GHG emissions, the following mitigation measure is recommended to further reduce this less-than- significant impact.
(C-4) The proposed project shall follow the guidelines and regulations outlined by AB 32, the 2006 CAT Report Strategies, and the LA Green Plan if applicable.
LEVEL OF SIGNIFICANCE AFTER MITIGATION
Impacts to air quality would be less than significant.
Museum of Tolerance Project IV.C. Air Quality Draft Environmental Impact Report Page IV.C-53