sra's comment letter #2

8/8/2019 SRA's Comment Letter #2

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Comments on Air Quality and MSAT Analysis I-5 North Corridor Project

Air Quality Analysis

The Air Quality Analysis presented in the DEIR/EIS has been prepared following Caltrans

standard format. The analysis addresses regional conformity, project-level conformity, the potential for CO hot spots, a discussion of PM 2.5/PM 10, a discussion of naturally-occurringasbestos, and a discussion of Mobile Source Air Toxics (MSATs). The following are specificcomments on the DEIR/EIS section.

1. Page 3.14-1: The Air Quality section indicates that it is based on the Draft Air QualityTechnical Study that was prepared for the project. The DEIR/EIS is dated June 2010; theTechnical Study, which is included as an appendix, is dated August 2007. Much of theinformation cited in the section is outdated. The analysis should be updated to reflectcurrent guidance and information.

2. Page 3.14-2: The Air Quality Section includes outdated information regarding theattainment status of the air basin. The basic designation for attainment has beenoverturned and the SDAB is in the process of being redesignated as a serious ozonenonattainment area. This will have a direct bearing on how projects like the I-5 NorthCoast Corridor project have been evaluated within the attainment demonstrationconducted by SANDAG and the SDAPCD. Furthermore, as shown in the MSATanalysis, emissions of MSATs increase and emissions of criteria pollutants are also likelyto increase due to increased traffic with the project; this is not discussed in the analysisand nothing has been provided to indicate how these increases are accounted for within

the SDAB given the pending redesignation.3. Page 3.14-2: Table 3.14.1 shows out of date information on the ambient air quality

standards. One of the standards that is out of date is the newly adopted federal 1-hour standard for NO 2, which is lower than the current California state standard. Since on-road traffic is the single largest contributor to NOx emissions within the San Diego Air Basin (See: http://www.arb.ca.gov/app/emsinv/emseic1_query.php ), it should be part of the quantitative analysis to assess whether the project, which results in increased trafficon the I-5 North Coast Corridor, would result in an exceedance of the new NO 2 standard,resulting in a significant impact on air quality in the vicinity of the freeway. Because the

section relies on a Technical Study that was prepared three years ago, however, nodiscussion has been provided regarding whether and how the project will comply with thenew NO 2 standard. The USEPA has also adopted a new 1-hour SO 2 standard. While it isunlikely that traffic on I-5 would result in an exceedance of the SO 2 standard, the newstandard is not acknowledged in the document.

4. Recent studies show a link between childhood asthma incidence and exposure to particulates, NOx, and black carbon generated from traffic. Given the potential
http://www.arb.ca.gov/app/emsinv/emseic1_query.phphttp://www.arb.ca.gov/app/emsinv/emseic1_query.php


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association of these health effects with traffic emissions, the I-5 North Coast Corridor study should have evaluated whether widening the road, and thus moving traffic andemissions closer to sensitive receptors, would have the potential to result in increases inhealth effects among the population.

5. Page 3.14-3: Tables 3.14.2 and 3.14.3 are out of date and do not reflect the currentattainment status of the air basin for ozone. Also, Table 3.14.3, which includesExceedance in the Last 3 Years only presents data for 2004 through 2006 and does not

present information on recent exceedances of air quality standards.

6. Page 3.14-5: The Air Quality section discusses PM 10 and PM 2.5, and indicates that aqualitative hot spot analysis method that follows federal guidelines was prepared for the

project. The conclusion is reached that indicates that the project is not a Project of Air Quality Concern. The analysis does not discuss potential exposure to ultra-fine

particulates, and does not address the effect of widening the freeway and moving traffic

closer to sensitive receptors. Ultrafine particles (particles with a diameter of less than 0.1microns) were not addressed in the analysis; yet recent studies indicate that ultrafine

particles may be a source of health concern in populations located near traffic sources.

7. Page 3.14-6: The Air Quality Section indicates that PM 10 and PM 2.5 in the SDAB show ageneral downward trend. The text states that concentrations of PM 10 and PM 2.5 from 2005through 2008 are presented in Table 3.15.6 (sic); however, the table only shows datafrom 2004 through 2006. When basin-wide PM 10 and PM 2.5 concentrations are plotted,they do not show a clear downward trend. While it may be possible to argue that annualPM 2.5 concentrations may be trending downward, 24-hour concentrations of PM 10 and

PM 2.5 do not show a downward trend, and annual PM 10 concentrations may be trendinghigher.


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Annual SDAB Concentrations of PM 2.5 and PM 10

Maximum 24-Hour Concentrations of PM 2.5 and PM 10

Also, there is no discussion on the location of the Beardsley monitoring station relative tothe I-5 North Coast Corridor and no explanation of why the data from the monitoringstation, which is located well south of the project site, is representative of the site.

8. Given the concerns identified by the ARB regarding exposure of sensitive receptors to particulate concentrations, and given studies indicating that freeway traffic may be a keycontributor to particulate concentrations, at a minimum, a quantitative analysis iswarranted. The ARB has released draft guidance in its Diesel Particulate Matter

Exposure Assessment Study for the Ports of Los Angeles and Long Beach (ARB 2006),which recommends calculations of mortality and morbidity based on exposure to

particulate matter concentrations to provide a quantitative assessment of health effects.Given that the project proposes to move traffic closer to receptors, a quantitativeassessment of PM impacts is warranted and should be conducted for the project.

9. The Air Quality analysis does not describe the effects of moving travel lanes, andtherefore emission sources, closer to sensitive receptors. The edge of travel lanes will bemoved anywhere from 48 to 73 feet closer to existing receptors in the City of Encinitas.It should also be noted that truck traffic tends to utilize the slower lanes, which would bethe closest to receptors.

10. Page 3.14-10: The Air Quality Analysis includes a qualitative discussion of constructioneffects, but no attempt was made to quantify construction emissions and evaluate whether construction activities (which would include earthmoving activities, heavy equipment,and increases in truck traffic) would have a significant impact on air quality both locally


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and regionally. While Caltrans typically does not quantify emissions for projects that areless than five years in duration, there is no such statement in the Air Quality section as toduration of construction. Construction emissions could have a significant impact on

basin-wide air quality issues such as ozone and PM 2.5. The statement that Theseemissions would belimited to the immediate area surrounding the relocation site, andtherefore would not adversely affect air quality does not address regional pollutantimpacts or the impacts of truck trips transporting construction materials to and from thesite. As this project is a major construction project extending through approximately half of the coastal region of San Diego County and the SDAB, construction of a project of thisscale could have a significant impact on air quality in the region and should be analyzed.It should be noted that construction emission estimates were provided in the Air QualityAnalysis; these emissions should have been discussed in the Draft EIR/EIS andconclusions as to significance provided.

MSAT Analysis

The analysis follows the same methodology used for all Caltrans projects, in that it follows theFHWAs Interim Guidance on Air Toxic Analysis for National Environmental Policy Act (NEPA) Documents (FHWA, February 3, 2006). The guidance recommends evaluating MSATemissions, comparing Build and No Build alternatives. The analysis is limited to estimatingemissions only.

It should be noted that the FHWAs guidance on MSATs was updated on September 30, 2009.

The MSAT analysis followed the 2006 guidance, rather than the 2009 guidance. In the updatedguidance, the FHWA eliminated acetaldehyde from its list of pollutants with significantcontributions to risk, and added two new pollutants, naphthalene and polycyclic organic matter.

Neither of these pollutants has been addressed in the current MSAT analysis.

The focus of the MSAT analysis that was conducted for the project involves running of the CT-EMFAC Model, which provides estimates of emissions of MSAT substances. Tables B and C of the MSAT Analysis, provided in the appendix to the EIR, as summarized in Tables 3.14.8 (2015)and 3.14.9 (2030) clearly show that MSAT emissions would increase with the proposedwidening of the I-5 North Corridor. Projected increases range from 7.5% to 20% from the No

Build alternative.Furthermore, the MSAT analysis does not describe the effects of moving travel lanes, andtherefore emission sources, closer to sensitive receptors. The edge of travel lanes will be movedanywhere from 48 to 73 feet closer to existing receptors in the City of Encinitas. It should also

be noted that truck traffic tends to utilize the slower lanes, which would be the closest toreceptors. No discussion of this has been provided in the MSAT analysis.


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Specific comments on the MSAT analysis as presented in the Draft EIR/EIS follow.

1. Page 3.14-9 of the EIR that says the following: Although the No Build Alternative isexpected to accommodate less traffic as indicated in Table 3-14.6, its MSAT emissionsare expected to be greater than those of other Build Alternatives in both 2015 and 2035.

The greater MSAT emission projected for the No Build Alternative, despite less traffic,are attributable to the congested traffic conditions and breakdown of travel speeds during

peak periods.

First, the tables are not referenced correctly in the text; the reference in the abovestatement should be to Table 3.14.7, which shows the traffic activity for the I-5 NorthCorridor project. Second, Tables 3.14.8 and 3.14.9, which present emissions associatedwith the Build alternatives versus the No Build alternative, clearly show that emissionsfor both Build alternatives increase over the No Build Alternative, in contradiction to thestatement made on Page 3.14-9 of the text. According to the data presented in the

analysis, the No Build Alternatives MSAT emissions are projected to be lower than theBuild alternatives.

2. Page 3.14-10 of the Draft EIR/EIS concludes that the amount of MSAT emissions fromeach of the project alternatives and MSAT concentrations or exposures created by each of the project alternatives cannot be predicted with enough accuracy to be useful inestimating health impacts. Caltrans concludes that the health effects from theseemissions cannot be estimated.

The State of California Office of Environmental Health Hazard Assessment (OEHHA)

has released a health risk assessment model that allows for the prediction of health effectsfrom toxic air contaminants, in its HotSpots Analysis and Reporting Program (HARP).The HARP model has been used to assess potential impacts from traffic on roadways in anumber of studies. Furthermore, the South Coast Air Quality Management District(SCAQMD) has issued guidance on addressing risks from diesel particulate matter in its

Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis (SCAQMD 2003), in which they provide recommendations for addressing diesel emissions from trucks on roadways andstreets. Contrary to the statements in the Draft EIR/EIS, these tools are available andcould have been used to estimate the health effects from MSAT emissions.

3. The MSAT analysis does not describe the effects of moving travel lanes, and thereforeemission sources, closer to sensitive receptors. The edge of travel lanes will be movedanywhere from 48 to 73 feet closer to existing receptors in the City of Encinitas. Itshould also be noted that truck traffic, which is the major source of diesel particulatematter, tends to utilize the slower lanes, which would be the closest to receptors.


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Specific comments on the Draft Air Quality Analysis and the Mobile Source Air ToxicsAnalysis, which were provided as appendices to the Draft EIR/EIS, are provided below.

Draft Air Quality Analysis

1. Pages 1 and 24: The Air Quality Analysis, which was written in August 2007, containsoutdated information regarding the attainment status of the SDAB. The SDAB is nolonger classified as a basic nonattainment area; the basic designation has beenrescinded by EPA. The SDAPCD is in the process of redesignating the SDAB as aserious ozone nonattainment area, which will require further analysis of projects such asthe I-5 North Coast Corridor Project to ascertain its impacts on ozone attainment.

2. Page 16: While ultra-fine particulates are not currently regulated by the U.S. EPA as acriteria pollutant, recent studies indicate that adverse health effects are associated withexposure to ultra-fine particulates, and specifically ultra-fine particulates from roadways.

Some discussion of ultra-fine particulates is warranted in the Air Quality Analysis.3. Page 16: The Air Quality Analysis states No standards exist for quantitative impact

analysis for diesel particulates. Some air districts have issued preliminary projectguidance for projects with large or concentrated numbers of trucks, such as warehousesand distribution facilities. Most air quality regulatory agencies are requiring quantitativeimpact analyses for diesel particulates for projects under CEQA. In 1994, the State of California identified diesel particulate matter as a toxic air contaminant, and identified acancer slope factor and reference exposure level that allows a quantitative evaluation of impacts from diesel particulates. Standards therefore do exist under the California AB

2588 Air Toxics Hot Spots Information and Assessment Act which set forth toxicityfactors and methodologies to assess potential risks of exposure to diesel particulatematter.

4. Page 20: Table 2 should be updated to present the current ambient air quality standards.The table is outdated.

5. Page 24: The Air Quality Analysis states that ambient air quality measurements from theSan Diego Beardsley Street monitoring station were used to represent background air quality. Data are presented for the period from 2004 to 2006. No analysis was presentedshowing data from the Del Mar-Mira Costa monitoring station or the Camp Pendletonmonitoring station, which are located closer to the project area. Furthermore, nodiscussion was provided as to why the Beardsley data are considered representative of conditions along the I-5 North Coast Corridor. Some discussion is warranted to give a

perspective on whether these data best and most accurately represent current conditionsin the project area. Furthermore, the data should be updated to include recentmeasurements, especially in light of adoption of new ambient air quality standards.


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6. Page 25: Table 4 is out of date, both in the presentation of ambient monitoring data, andin the listing of ambient air quality standards. The 1-hour O 3 NAAQS has beenrescinded, a new 8-hour O 3 NAAQS of 0.075 ppm and a new 8-hour O 3 CAAQS of 0.070

ppm have been adopted; a new 1-hour NO 2 NAAQS of 0.100 ppm has been adopted; the24-hour PM 2.5 NAAQS is 35 g/m 3; and the annual and 24-hour NAAQS for SO 2 have

been rescinded and replace with a new 1-hour NAAQS for SO 2 of 0.075 ppm. None of these changes are reflected in the table and the data provided as background data do notgive an accurate representation of current conditions within the region.

7. Page 30: The statement is made that The proposed project would not generate traffic but would accommodate future traffic volumes by providing increased efficiency viaexpanded capacity. Therefore, it may be presumed that the project would not measurablyincrease traffic volume or the percentage of vehicles in cold start mode. However, theMSAT analysis (Table A, Page 5) clearly shows that traffic volumes would measurablyincrease with the project; peak hour VMT is more than doubled from the No Buildalternative with Alternative 2, and average daily VMT is 8% higher with Alternative 2than under the No Build Alternative. As stated on Page 29 of the Air Quality Analysis, asubstantial increase in traffic volumes is defined as an increase in volumes in excess of 5

percent. Thus it appears that the project does measurably increase traffic volumes;impacts from this increase in traffic volumes should be evaluated in the Air QualityAnalysis.

8. Page 31: The Air Quality Analysis states that the SDAB is not federally designated as aPM 2.5 or PM 10 nonattainment or maintenance area; thus, the project does not require aPM 2.5 or PM 10 conformity analysis. While the SDAB is not a federally designatednonattainment area for PM 2.5 and PM 10, it is a state nonattainment area for these

pollutants. Potential impacts from PM 2.5 and PM 10 emissions associated with the projectmust be addressed under CEQA, whether or not the project is designed as a federalnonattainment area. Further analysis of this issue is warranted, especially given theincreases in VMT identified in the MSAT analysis.

9. Page 44: The Air Quality Analysis states that there is no formal guidance for diesel particulate impacts. As discussed above in Comment 3, there is in fact formal guidancefrom the State of California on methods to address this issue. The Air Quality Analysisalso states that a measure to reduce potential diesel particulate impacts has been providedin Section 5.0; however, the measure, which recommends locating construction stagingareas away from sensitive receptors, does not address continuing diesel particulateemissions from the I-5 North Coast Corridor with operations, nor does it address theimpact of moving traffic lanes closer to sensitive receptors by widening the freeway.


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Draft Air Quality Study - MSAT Analysis

1. Page 1: The MSAT Analysis, which was written as a technical addendum to the Air Quality Analysis in June 2008, follows 2006 MSAT guidance from the FHWA which hassince been revised. In the updated guidance, the FHWA eliminated acetaldehyde from

its list of pollutants with significant contributions to risk, and added two new pollutants,naphthalene and polycyclic organic matter. Neither of these pollutants has beenaddressed in the current MSAT analysis.

2. Page 2: The MSAT Analysis acknowledges that the project warrants a quantitativeanalysis. The only analysis that has been conducted is to run the CT-EMFAC model, and

present differences in emissions between alternatives. However, no analysis of theimpact of moving traffic lanes closer to receptor has been provided.

3. Page 6: Table B reports emissions for Carolina. We presume this is acrolein, but

should be corrected in the table.4. Page 12: The report states Differences in MSAT emissions among the proposed

alternatives are noted in Tables B and C. The Build Alternatives result in higher VMTand emissions when compared to the No Build Alternatives. However the BuildAlternatives substantially relieve congestion with average peak period speed incrementsfrom the No Build Alternatives ranging from 85 to 103 percent for the operational year and 101 to 180 percent for the horizon year. Please clarify why this statementcontradicts information provided in the tables and text, which indicate the Buildalternatives would result in higher MSAT emissions, despite reducing congestion. The

report goes on to state that Project-specific health impacts cannot be predicted withavailable technical tools. This statement ignores the technical models that are availableand used regularly to predict downwind concentrations of MSATs, and technical modelsthat are available to predict health effects (such as HARP) from exposure to theseconcentrations of MSATs.

5. Page 13: The report provides a discussion on why the FHWA concluded that thetechnical tools available for dispersion modeling are limited; however, the project is alsosubject to CEQA, and state and local agencies in California regularly use dispersionmodeling techniques and approaches to predict health effects from mobile sources. In

their MATES Studies, the SCAQMD used AERMOD to analyze potential health effectsfrom on-road sources. The analysis should therefore have included an evaluation of potential impacts from MSATs in accordance with CEQA.