Northeast Interstate Logistics Center FEIS – Air Quality Response to Comments III.16 Air Quality Comment No. 16-1 The FEIS should include definition of PM2.5 and PM10. (B-1, AKRF) Response No. 16-1 PM2.5 are particulates with a diameter of 2.5 micrometers or less. PM10 are particulates with a diameter of 10 micrometers or less. Comment No. 16-2 The FEIS should include time averaging periods for each pollutant. (B-1, AKRF) Response No. 16-2 The revised Table III.C.16-1 is presented below (was Table III.N-1 in the DEIS). III.16-1 Northeast Interstate Logistics Center FEIS – Air Quality Response to Comments Table III.C.16-1 (revised) Representative Monitored Ambient Air Quality Data (2016) Averaging Pollutant Location Units Period Concentration NAAQS Botanical Garden (Pfizer Lab), 8-hour 1.1 9 CO ppm Bronx 1-hour 1.86 35 3-hour 500 (6) SO2 Mt. Ninham, Putnam ppb 1-hour 4.7 (1) 75 PM10 IS 52, Bronx µg/m3 24-hour 37 150 Annual 6.9 (2) 12 PM2.5 Newburgh, Orange µg/m3 24-hour 17.5 (2) 35 Botanical Garden (Pfizer Lab), Annual 30 100 NO2 µg/m3 Bronx 1-hour 109 (3) 188 Lead Wallkill, Orange µg/m3 3-month 0.022 (4) 0.15 Ozone Mt. Ninham, Putnam ppm 8-hour 0.069 (5) 0.070 Notes: + Indicated values exceeding the National Ambient Air Quality Standards (NAAQS). (1) The 1-hour value is based on a three-year average (2014-2016) of the 99th percentile of daily maximum 1- hour average concentrations. EPA replaced the 24-hr and the annual standards with the 1-hour standard. (2) Annual value is based on a three-year average (2014-2016) of annual concentrations. The 24-hour value is based on the 3-year average of the 98th percentile of 24-hour average concentrations. (3) The 1-hour value is based on a three-year average (2014-2016) of the 98th percentile of daily maximum 1- hour average concentrations. (4) Based on the highest quarterly average concentration measured in 2016. (5) Based on the 3-year average (2014-2016) of the 4th highest daily maximum 8-hour average concentrations. (6) Not to be exceeded more than once per year. Sources: New York State Air Quality Report Ambient Air Monitoring System, DEC, 2016 Comment No. 16-3 The FEIS should remove rescinded S02 annual NAAQS threshold and monitored concentration from Table III.N-1 and update table footnotes. (B-1, AKRF) Response No. 16-3 See Response No. 16-2. III.16-2 Northeast Interstate Logistics Center FEIS – Air Quality Response to Comments Comment No. 16-4 The FEIS should include S02 3-hour NAAQS threshold and monitored concentration into Table III.N-1 and update table footnotes. (B-1, AKRF) Response No. 16-4 See Response No. 16-2. Comment No. 16-5 The FEIS should include discussion of stationary air quality sources, if any, that would be introduced/changed in the Future without the Proposed Project from the Existing Conditions. (B-1, AKRF) Response No. 16-5 The Applicant has no information on any stationary air quality sources that would be introduced/changed in the future without the proposed project. Comment No. 16-6 NYSDOT's mobile source screening guidance does not assess the potential air quality conditions in the Future without the Proposed Project, nor was the guidance used to assess the air quality conditions. The FEIS should provide this information. (B-1, AKRF) III.16-3 Northeast Interstate Logistics Center FEIS – Air Quality Response to Comments Response No. 16-6 The guidance references ETC (estimated time of completion) and comparing build to no-build. See Response No. 16-15. Comment No. 16-7 Page IIl.N-4 indicates that "The volume of cars and trucks (including heavy equipment) will be less than that during the operation of the facility." The air quality analysis should reference where this has been determined. (B-1, AKRF) Response No. 16-7 The construction traffic in the Construction section of this FEIS, will be far less than the operational traffic during the peak travel time periods and therefore will not create any air quality, noise or roadway capacity issues. See Response No. 15-1. Comment No. 16-8 The FEIS should include definition of "de minimis" as it relates to the threshold for air quality impacts. (B-1, AKRF) Response No. 16-8 The sentence in the DEIS is revised as follows: Thus, any pollutant emissions from motor vehicles during construction, as explained in the DEIS Construction Section III.M.4, will be less than during operation, and not cause any violation of the NAAQS. III.16-4 Northeast Interstate Logistics Center FEIS – Air Quality Response to Comments Comment No. 16-9 Per EPM Chapter 1.1 Section 15, include discussion of the duration of construction work, its schedule and the type of work being done. (B-1, AKRF) Response No. 16-9 Additional discussion of the construction work and schedule are provided in Response 15-3. Specifically, with respect to air quality, there are two pertinent items from the NYSDOT Environmental Procedures Manual (EPM) Chapter 1.1, Section 15. The first one is: Typical measures include wetting of exposed soil and covering of trucks and other dust sources. These are standard mitigation practices that will be employed on all phases of construction, including: the off-site road improvements; site clearing; and site grading. The second one is: Consequently, if construction diversions or detours lasting 2 years or more (at a minimum, two consecutive CO seasons) at any one location, or permanent improvements to other facilities as a result of project detours/diversions are anticipated, an air quality analysis should be performed. III.16-5 Northeast Interstate Logistics Center FEIS – Air Quality Response to Comments The off-site road improvements to support the Preferred Alternative are anticipated to include the following items: • Widening NY 312 from Pugsley Road to I-84 from 2 lanes to 4 lanes; • Improvements to Pugsley Road (from Route 312 to Barrett Road) will include both widening and reconstruction to heavy-duty pavement standards that are designed to accommodate truck traffic; • A traffic signal will be provided as a traffic control device at the intersection of Pugsley Road and Route 312; • North of Barrett Road, Fields Corner Road will not be improved and will use a height barrier device to restrict truck access to the local road to/from Patterson. Fields Corner Road will remain closed and not maintained to the north of the project during winter months. Since there will be no traffic diversions and each building can be constructed in less than 2 years, no air quality analysis is required for the off-site improvements. Comment No. 16-10 Include discussion of emissions from on-site construction equipment. Comparison to the operational air quality assessment is not sufficient as there will be no such sources in the Future with the Proposed Project. (B-1, AKRF) Response No. 16-10 See Response 15-2. Comment No. 16-11 Page III.N-5 states, "Because all traffic passing the site (i.e. not just that associated with the construction) can re-suspend the deposited material, this "secondary" source of emissions III.16-6 Northeast Interstate Logistics Center FEIS – Air Quality Response to Comments may be more important than all the dust sources actually within the construction site." It is unclear from the discussion that this is the case. The FEIS should provide more rationale. (B-1, AKRF) Response No. 16-11 This sentence was simply stressing the importance of not tracking soil off-site where it can become airborne due to all traffic (both construction traffic and the traffic on the road in question). Comment No. 16-12 Particulate matter is both a primary and principal pollutant of concern with vehicular exhaust emissions. Per NYSDOT guidance (EPM Chapter 1.1 Section 8), include discussion of PM and whether quantitative hot-spot analysis is warranted. (B-1, AKRF) Response No. 16-12 The discussion in EPM Chapter 1.1 Section 8 as it pertains to PM2.5 and PM10 is for nonattainment and maintenance. Since Putnam County is in attainment for both PM2.5 and PM10 a quantitative hot-spot analysis is not warranted. Comment No. 16-13 Page IIl.N-6 states, "Since ozone and smog formation is a low process with occurs outside the primary impact area of the project, these pollutants are reviewed only on a regional (mesoscale) basis, not a local (microscale) basis." The DEIS did not include a review of regional impacts. The FEIS should include a discussion why a regional analysis is not warranted. (B-1, AKRF) III.16-7 Northeast Interstate Logistics Center FEIS – Air Quality Response to Comments Building 4 is contemplated to have a cooling system, which, again, provides emission and more noise. How does that affect your calculations? (B-3, PH #2, Ms. Armstrong) Response No. 16-13 The criteria for the requirement of a mesoscale analysis as stated in EPM Chapter 1.1 Section 9.A.ii are as follows: Projects with build alternatives that could have a significant impact on emissions on a regional basis should have a mesoscale analysis performed. Examples of these types of projects include: • HOV lanes vs general use lanes, • new or significant modifications to interchanges on access-controlled facilities, • large-scale signal coordination projects, • in attainment area, projects having alternatives (including the no- build) with significantly different (10%) vehicle miles traveled (VMT), • in nonattainment and maintenance areas and included in the regional emissions analysis supporting the conformity determination for the TIP and Plan, projects having build alternatives with significant different (10%) VMT.