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Air Quality CEQA Review

[FRAQMD's Indirect Source Review Guideline]
[See Area Designations Here]  [CEQA Thresholds of Significance]  
[Landscaping and Air Quality]
[Health advisory to school District done by South Coast AQMD]

Overview
Please read through this entire page once to get the whole picture. Then go back thru for the details. Direct any questions you may have to air district planning staff.

Introduction
The California Environmental Quality Act (CEQA; CEQA FAQs) requires public agencies to take responsibility for protecting the environment.  The general public and responsible/commenting agencies such as the air district are provided an opportunity to review and submit comments pertaining to the project to the Lead Agency (typically the city or county planning agency; community development; community services department) prior to project approval by their governing board.  In regulating public or private projects, agencies are expected to avoid or minimize environmental damage especially impacts to the health of its citizens. The purpose of an environmental review is to identify the significant effects of a project on the environment, identify alternatives to the project, and indicate the manner in which significant impacts can be mitigated or avoided. To this end, below is a list of air district-approved resources to estimate project air pollutant emissions, identify a project's air quality significant effects, and select the best available mitigation measures designed to avoid or reduce the air quality environmental impacts of transportation and land-use activities.

All project proponents and Lead Agencies are encouraged to utilize these resources when evaluating a project to ensure an adequate evaluation is performed for significant air quality effects.

Air District Review of CEQA Documents
What if the air district doesn't comment on a project?  All air district recommended tools, procedures, and feasible mitigation measures are presented here at this web site. It is the duty of the project proponent to evaluate the air quality impacts of the project, to determine how those impacts will be mitigated or substantially reduced, and to submit a Mitigation Monitoring Plan detailing the selected measures and the means by which they will be implement and deemed complete.

The materials presented here constitute the same methodologies implemented by air district planning staff to formulate CEQA Review comments to the lead agency. Following these procedures and implementing the measures provided here to the maximum extent feasible, to achieve either a mitigated negative declaration or to achieve a minimum 35 % emission reduction with performance of an EIR, meets air district criteria, provided the emissions evaluation, selected mitigation measures, and proposed Mitigation Monitoring Plan are approved by the Lead Agency.

The Urban Emissions Model
The URBan EMISsions (URBEMIS) model is widely used throughout California by project applicants, environmental consultants, local governments, and air districts, to evaluate the air quality impacts of a project. URBEMIS is the only FRAQMD-approved model at this time. The model is used to calculate air emissions associated with land development projects. The data generated by URBEMIS is used to determine whether or not a project would generate significant quantities of air pollutants from indirect sources to cause a "significant effect" and the extent of mitigation that will be necessary. Not all projects can be evaluated using the URBEMIS model; contact the District for further assistance.  

All other methodologies used to derive emissions estimates for submittal in the CEQA review process, not provided on this web site, must be pre-approved by the FRAQMD Air Pollution Control Officer (APCO).

Air District Policy
Projects submitted for CEQA review unaccompanied by the latest version of an URBEMIS evaluation or without the detailed project-specific parameters necessary for the lead agency, or if preferred, air district staff, to evaluate air quality impacts, significantly impairs the lead agency's/air district's capacity to perform an adequate CEQA environmental review and should be considered to pose a significant environmental effect and required to perform an EIR and implement all feasible and recommended mitigation measures. 

Nevertheless,  project-specific air pollutant emissions estimates and supporting documentation must be submitted with the project during the CEQA review process to ensure public disclosure and to achieve consensus for a proposed negative declaration, mitigated negative declaration, or Environmental Impact Report (EIR).  Project proponents and lead agencies are encouraged to work with the air district prior to project submittal for CEQA review (early consultation) in order to allow an adequate timeframe to assess air quality impacts and prepare a thorough mitigation monitoring plan for the project.

Mitigation Monitoring Plan
An approved (Lead Agency/FRAQMD) written Mitigation Monitoring Plan should be developed, attached, and submitted with the project proposal for approval by the governing Board. At a minimum, the Plan should document each mitigation measure to be implemented, the impact being addressed, the phase of the project in which the measure is to be implemented, implementation goals and timeframes to be met (dates should be provided), actions to be taken by the lead agency, air district, or other agencies if implementation is not successful, and the responsible agency to contact at the time of implementation and/or completion, whichever is applicable, for monitoring and signoff.

Statement of Overriding Considerations: Avoidance of Significant but Unavoidable Recommendations for Projects
It is the recommendation of the FRAQMD staff that until implementation of "all feasible mitigation measures" from the Best Available Mitigation Measures (BAMM) list, the BAMM "Point-Value List", voluntary offsite mitigation projects, and/or written project-specific recommendations from air district staff are exhausted, a project considered for approval as "Significant But Unavoidable" should be avoided entirely by the Lead Agency and governing Board and sent back to the drawing table for further deliberation.  At a minimum, a project proponent that cannot mitigate to below the thresholds after exhausting all measures described above should strive to achieve a minimum 35% mitigation and perform an environmental impact report.

In the unlikely event, and, in order to minimize the potential for proponents to summarily dismiss standard and recommended mitigation measures as impractical or infeasible, a written report should be submitted by the project proponent or lead agency adequately documenting the reasons for refusal to implement sufficient mitigation offsets using BAMM, Point-Value, voluntary offsite mitigation projects, and air district staff project-specific recommended mitigation measures.

The report should include an infeasibility determination for each measure, alternative proposed measures and their associated emission reduction factors for air district review/approval, and a description of and the reasoning behind any modifications made to air district recommended mitigation measures. This documentation should be provided to the air district, the public, and lead agency with adequate time for air district and public review and comment and prior to submittal to the governing board for consideration at a public hearing.

Unresolved issues should be delivered to the governing board for deliberation at the public hearing. District staff will be available to meet with the project proponent, the public, the lead agency, and the governing board to resolve air pollution mitigation issues.

South Sutter County Specific Plan Projects
Land-use projects proposed for the South Sutter County Specific Plan area should work closely with Sutter County, Community Services Department, personnel to discuss adopted air quality mitigation requirements. The Point Value List for SSCSP projects may be reviewed or downloaded here (MS Excel spreadsheet) or obtained from FRAQMD or the County.

Resources: Software and Tools

bulletURBEMIS 2002 Model: Use the most current computer model to estimate short-term and long-term air pollutant impacts from transportation and land-use projects such as residential, commercial, and industrial developments and determine if the project exceeds established, FRAQMD Board of Directors approved, CEQA "Thresholds of Significance" and may pose a significant effect to local and regional air quality. 

Download the current URBEMIS model Software and User's Manual The latest release of URBEMIS Software and User's Manual may be downloaded from the Air Resources Board web site.

[Note: To download the manual, go to the URBEMIS 2002 website, Right click on the link URBEMIS2002 User's Manual (or whatever version is available at the time).  A menu will appear.  Click on “Save Target As…” from the menu.  The “Save As” window will open.  Save the manual to your hard drive or other storage media.  Make sure you remember where you saved the manual.  Once the manual has been downloaded, go to the directory where you saved it and open it.]
 
bullet A Roadway Construction Emissions Model (in MS Excel - 1.8 Mb) is available at the SMAQMD web site to assist roadway (or Levee) project proponents with determining the emission impacts of their projects.
 
bulletIn addition, AP-42 Compilation of Air Pollutant Emission Factors, Fifth Edition, Volume I: Stationary Point and Area Sources, may be used in the absence of specific emission factors provided by the manufacturer, to estimate stationary source and portable equipment emissions at the project site.

NOTE: An URBEMIS Screening Analysis should be performed first for all projects to determine if a refined URBEMIS analysis will be required (Use Lower Sacramento Valley Air Basin).

bulletURBEMIS Screening Analysis Mode Procedure:  Screening Analysis
Minimal information regarding the project is entered into the URBEMIS model by the project proponent or lead agency. The model uses default settings to estimate and summarize the air pollution impacts associated only with the long-term Operational/Area Source Phases of the project (no construction phase emission estimates are performed) and presents the data in report format for evaluation and submittal for review. Use the screening method to derive a quick estimate of project emissions. A Screening Analysis may be used to evaluate the project for air quality impacts during an Initial Study.
 
bulletPerforming an URBEMIS Refined Analysis (Use Lower Sacramento Valley Air Basin)
Download the URBEMIS User's Guide and dig in! Detailed information regarding each phase of the project is meticulously entered into the URBEMIS model by the project proponent or lead agency. The model then estimates and summarizes the air pollution impacts and presents the data in report format for evaluation and submittal. The refined analysis can perform a complete project emissions estimate including Construction, Operational, and Area Phase emissions and offers the selection of mitigation measures for each component of the analysis. Be sure that mitigation measures chosen for implementation within the model are documented in the evaluation and Mitigation Monitoring Plan and do not overlap with additional measures selected elsewhere.
 
bulletDetermining Air Quality "Significant Effect"
Compare the results of the URBEMIS analysis with the District's Board-approved "Thresholds of Significance" to determine if the project exceeds any of the thresholds and has the potential to pose a significant effect to air quality. Apply all feasible mitigation measures, especially the BAMM "Point-Value" List, to mitigate or reduce impacts. Determine whether the project can be routed as a negative declaration, mitigated negative declaration, or an environmental impact report with regard to any remaining air quality impacts.

Note: Any project requiring air district stationary source "Emission Offsets" under FRAQMD Regulation X - New Source Review criteria may be considered a "significant effect" project under CEQA requiring an EIR.
 
bulletMitigating Air Quality Impacts
Implement all feasible mitigation measures to reduce or eliminate air quality impacts using all the tools found here and any measures recommended by the air district. Board Approved Best Available Mitigation Measures (BAMM) and the BAMM "Point-Value" List derived from BAMM provides a constantly maturing set of feasible mitigation measures developed by California air district planning staff and community development consultants to be implemented under a project's mitigation monitoring plan to reduce or avoid environmental and community health-related impacts. Project proponents may propose additional mitigation measures for air district review and approval.

How to Apply the Thresholds of Significance and Implement Feasible Mitigation Measures to Reduce or Eliminate Significant Effect

bulletUsing the BAMM "Point-Value List" (MS Excel 2002 or Adobe PDF) to quantify emission reductions achieved through selected mitigation measures:
The Point-Value List is a set of Best Available Mitigation Measures for which a maximum emission reduction value has been derived. These values may be used to calculate project emission reductions associated with implementation of a measure. Each point is the equivalent of a 1% emissions reduction. FRAQMD staff is available to evaluate the measures selected by the project proponent or lead agency to determine if full or partial credit may be applied. Project proponents are encouraged to meet with District staff early in the process to ensure adequate time for selection and evaluation.
 
bulletEstimating Stationary Source and Portable Equipment Emissions Using Federal EPA, AP-42 Emission Factors
[AP-42, Compilation of Air Pollutant Emission Factors, Fifth Edition, Volume I: Stationary Point and Area Sources]
AP-42 is a compilation of emission factors used by state and local air district engineering staff to estimate stationary source and portable equipment emissions.  URBEMIS does not calculate emissions for stationary sources installed at the facility and portable equipment utilized at the facility outside of the construction phase of the project. Typically these emission sources fall under air district Rules and Regulations requiring an Authority to Construct and Permit to Operate, prior to installation and operation, and mandatory emission control technologies, emission offsets (the acquisition of Emission Reduction Credits for example), and operating limitations, and therefore, are not evaluated against the District's Indirect Source Thresholds of Significance (as they are not indirect sources); they are simply reported in the CEQA review process to divulge the total project impacts.  However, any project requiring Emission Offsets under FRAQMD Regulation X - New Source Review criteria may be considered a "significant effect" project under CEQA requiring extensive consultation with the air district.
 
bulletStatewide Portable Equipment Registration Program
Owners or operators of portable engines and associated equipment can register their units under the Air Resources Board's (ARB) statewide portable equipment registration program (PERP) in order to operate their equipment throughout California without having to obtain individual permits from each local air district. There are 35 air districts in California.

bullet Links to all Supporting Materials approved for use in transportation and land-use project evaluations have been consolidated and are provided below:
bullet URBEMIS Screening Analysis Mode Procedure Screening Analysis
bullet CEQA Thresholds of Significance and determination of Significant Effect
Note: The Board-adopted thresholds were originally  published in the FRAQMD ISR Guidelines. The ISR Guidelines may be viewed/downloaded here.
bullet Recommended BAMM "Point-Value List" (MS Excel 2002 or Adobe PDF) Operational and Area Source Mitigation Measures with assigned emission reduction values
bullet Recommended Standard Mitigation Measures for All Projects
bullet Recommended Construction Phase Mitigation Measures - Recommended "best available mitigation measures" for Construction Phase activities especially for any project requiring a refined URBEMIS analysis and/or all feasible measures.
bullet Recommended Operational and Area Source Mitigation Measures - BAMM for Operational and Area Phase activities.
bullet Voluntary Offsite Mitigation Project Sample Evaluation and Approved Project Types
bullet Carl Moyer Program Guidelines http://www.arb.ca.gov/msprog/moyer/moyer.htm
bullet

"Mandatory" Fugitive Dust Control Plan:  "Requirements for the Control of Fugitive Dust Emissions", FugitiveDustControlPlan.doc (MS Word; 88 Kb) or FugitiveDustControlPlan.pdf (Adobe PDF; 165 Kb).

With few exceptions, All projects will require
submittal of a Fugitive Dust Control Plan.

bullet Asbestos Dust Mitigation Plan - review all applicable sections of the Asbestos airborne toxic control measure and see Section 93105(e)(4) for Plan requirements.

ASBESTOS AIRBORNE TOXIC CONTROL MEASURE FOR CONSTRUCTION, GRADING, QUARRYING, AND SURFACE MINING OPERATIONS - Final Regulation Order (Effective: July 29, 2002) http://www.arb.ca.gov/toxics/atcm/asb2atcm.htm
bullet AP-42 Compilation of Air Pollutant Emission Factors, Fifth Edition, Volume I: Stationary Point and Area Sources
bullet CEQA Guidelines  The California Environmental Quality Act Statutes and Guidelines
bullet Download the latest URBEMIS Model and Guidelines
bullet Low-Ozone Forming Potential (low-emission) Trees and Shrubs and other useful resources
bullet State Air Resource Board Adopted Heavy-Duty Diesel Idling Control Measure
bullet Statewide Portable Equipment Registration Program (PERP)
bullet Title 24 Part 6 California's Energy Efficiency Standards for Residential and Nonresidential Buildings http://www.energy.ca.gov/title24/standards/index.html
bullet FRAQMD Rules and Regulations

bulletInterim Air Quality Evaluation Exemption List: the following projects will not require an emissions evaluation submittal.
  1. A single-family residential project of two (2) homes or less (including mobile homes), a duplex, or a quadruplex.
     
  2. City and County Government Administrative Activities: The administrative component of subdividing or rezoning of parcels or the acquisition of new parcels into the city limits, where no air pollution generating activities occur in the procedure (paperwork).

Other Resources:
http://www.ciwmb.ca.gov/PermitToolbox/CheckItems/CEQA/Default.htm#Resources

Quotation:

If you are planning for a year, sow rice; if you are planning for a decade, plant trees; if you are planning for a lifetime, educate people.

- Chinese Proverb

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