4.2 AIR QUALITY · 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

County of Los Angeles Page 4.2-1 Vermont Corridor Project Draft Environmental Impact Report November 2017

4.2 AIR QUALITY

INTRODUCTION

This section examines the degree to which the Project may result in significant adverse changes to air quality. Both short-term construction emissions occurring from activities such as grading and haul truck trips as well as long-term effects related to the ongoing operation of the Project are discussed in this section. The analysis focuses on air pollution from two perspectives: daily emissions and pollutant concentrations. “Emissions” refer to the actual quantity of pollutant 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”), parts per billion (“ppb”), or micrograms per cubic meter (“µg/m3”).

The potential for the 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 region is non-attainment, or to expose sensitive receptors to substantial pollutant concentrations are also discussed. Air quality data utilized in the preparation of this section is included as Appendix 4.2-1 to this Draft EIR.

ENVIRONMENTAL SETTING

Air Pollutants

The Project Sites are located in the South Coast Air Basin (the “Basin”), named so because its geographical formation is that of a basin, with the surrounding mountains trapping the air and its pollutants in the valleys below. This Basin includes all of Orange County and the non-desert portions of Los Angeles, San Bernardino, and Riverside Counties. The regional climate within the Basin is considered to be semi-arid and is characterized by warm summers, mild winters, infrequent seasonal rainfall, moderate daytime onshore breezes, and moderate humidity. The air quality within the Basin is primarily influenced by a wide range of emissions sources – such as dense population centers, heavy vehicular traffic, and industry – and weather.

Air pollutant emissions in the Basin are generated by stationary and mobile sources. Stationary sources can be divided into two major subcategories: point sources and area sources. Point sources occur at an identified location and are usually associated with manufacturing and industry. Examples of point sources are boilers or combustion equipment that produce electricity or generate heat. Area sources are widely distributed and produce many small emissions. Examples of area sources include residential and commercial water heaters, painting operations, lawn mowers, agricultural fields, landfills, and consumer products, such as barbeque lighter fluid and hair spray. Mobile sources are emissions from motor vehicles, including tailpipe and evaporative emissions, and are classified as either on-road or off-road. On-road sources may be legally operated on roadways and highways. Off-road sources include aircraft, ships, trains, race cars, and self-propelled construction equipment. 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.

Both the federal and State governments have established ambient air quality standards for outdoor concentrations of various pollutants in order to protect public health and welfare. These pollutants are referred to as “criteria air pollutants” as a result of the specific standards or criteria that have been adopted for them. Federal and State standards have been set at levels considered safe to protect public

PRELIMINARY WORKING DRAFT 4.2 Air Quality


health, including the health of “sensitive” populations, such as asthmatics, children, and the elderly with a margin of safety; and to protect public welfare, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.

Criteria Air Pollutants

Criteria air pollutants that are most relevant to current air quality planning and regulation in the Basin include ozone (“O3”), carbon monoxide (“CO”), nitrogen dioxide (“NO2”), respirable particulate matter (“PM10”), fine particulate matter (“PM2.5”), sulfur dioxide (“SO2”), and lead (“Pb”). In addition, toxic air contaminants (“TACs”) are a concern in the Basin. The characteristics of each of these pollutants are briefly described below.

Ozone is a highly reactive and unstable gas that is formed when reactive organic gases (“ROGs”), sometimes referred to as volatile organic compounds (“VOC”), and nitrogen oxides (“NOx”),

byproducts of internal combustion engine exhaust, undergo slow photochemical reactions in the presence of sunlight. O3 concentrations are generally highest during the summer months when direct sunlight, light wind, and warm temperature conditions are favorable to the formation of this pollutant.

Carbon monoxide 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 O3, 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.

Nitrogen dioxide is a nitrogen oxide compound 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 compounds, 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.

Respirable and fine particulate matter PM10 and PM2.5 consist of extremely small, suspended particles or droplets 10 microns and 2.5 microns or smaller in diameter, respectively. Some sources of particulate matter, like pollen and windstorms, are

naturally occurring. However, in populated areas, most particulate matter is caused by road dust, diesel soot, combustion products, abrasion of tires and brakes, and construction activities.

Sulfur dioxide 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 SO2 oxidizes in the atmosphere, it forms sulfates (SO4). Collectively, these pollutants are referred to as sulfur oxides (“SOx”).

Lead occurs in the atmosphere as particulate matter. The combustion of leaded gasoline is the primary source of airborne Pb 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 racecars. However, because leaded gasoline was emitted in large amounts from vehicles when leaded gasoline was used for on-road motor vehicles, Pb is present in many urban soils and can be re-suspended in the air. Other sources of Pb include the manufacturing and recycling of batteries, paint, ink, ceramics, ammunition, and the use of secondary lead smelters.

O3

CO

NO2

PM10 and PM2.5

SO2

Pb

O3

CO

NO2

PM10 and PM2.5

SO2

Pb



Pb is also found in lead-based paint, which is considered to be a health hazard for people, especially children. From the turn of the century through the 1940s, paint manufacturers used lead as a primary ingredient in many oil-based paints. Use of lead in paint decreased but was still used until 1978, when it was banned from residential use. Remodeling, renovations, or demolition activities in older buildings could disturb lead-based paint surfaces.

Toxic Air Contaminants 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. TACs 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. TACs are different from “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.

Health Effects of Criteria Pollutants

The health effects of criteria pollutants (i.e., O3, CO, PM10 and PM2.5, NO2, SO2, and Pb) and TACs are described below. In addition, a list of the harmful effects of each criteria pollutant is provided in Table 4.2-1, Summary of Health Effects of Criteria Pollutants.

Ozone

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

Table 4.2-1 Summary of Health Effects of Criteria Pollutants

Pollutants Primary Health and Welfare Effects

Ozone (O3) • Aggravation of respiratory and cardiovascular diseases • Reduced lung function • Increased cough and chest discomfort

Carbon Monoxide (CO)

• Aggravation of some heart disease (angina) • Reduced tolerance for exercise • Impairment of mental function • Impairment of fetal development • Death at high levels of exposure

Nitrogen Dioxide (NO2) • Aggravation of respiratory illness

Respirable and Fine Particulate Matter (PM10 and PM2.5)

• Reduced lung function • Aggravation of respiratory and cardio-respiratory diseases • Increases in mortality rate • Reduced lung function growth in children

Sulfur Dioxide (SO2) • Aggravation of respiratory diseases (asthma, emphysema) • Reduced lung function

Lead (Pb) • Behavioral and hearing disabilities in children • Nervous system impairment

Source: South Coast Air Quality Management District, Guidance Document for Air Quality Issues in General Plans and Local Planning, Appendix C, 2005.

TAC TAC



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 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 observed responses mentioned above. Animal studies suggest that exposure 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

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.

Nitrogen Dioxide

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 individuals. 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.

Particulate Matter

A consistent correlation between elevated ambient respirable and fine particulate matter (PM10 and 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 PM10 and PM2.5.

Sulfur Dioxide

A few minutes exposure to low levels of SO2 can result in airway constriction in some asthmatics, all of who 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, 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

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 levels. 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 the 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.

Sulfates

Most of the health effects associated with fine particles and SO2 at ambient levels are also associated with SO4. Thus, both mortality and morbidity effects have been observed with an increase in ambient SO4



concentrations. However, efforts to separate the effects of SO4 from the effects of other pollutants have generally not been successful.

Clinical studies of asthmatics exposed to sulfuric acid suggest that adolescent asthmatics are possibly a subgroup susceptible to acid aerosol exposure. Animal studies suggest that acidic particles, such as sulfuric acid aerosol and ammonium bisulfate, are more toxic than non-acidic particles like ammonium sulfate. Whether the effects are attributable to acidity or to particles remains unresolved.

Toxic Air Contaminants

TACs are a broad class of compounds known to cause or contribute to cancer or non-cancer health effects such as birth defects, genetic damage, and other adverse health effects. As discussed previously, effects from TACs may be both chronic and acute on human health. Acute health effects are attributable to sudden exposure to high quantities of air toxics. These effects include nausea, skin irritation, respiratory illness, and, in some cases, death. Chronic health effects result from low-dose, long-term exposure from routine releases of air toxics. The effect of major concern for this type of exposure is cancer, which requires a period of 10 to 30 years after exposure to develop.

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 ARB, and are listed as carcinogens either under the State’s Proposition 65 or under the federal Hazardous Air Pollutants programs. The United States Environmental Protection Agency (“U.S. EPA”) has adopted Ultra Low Sulfur Diesel (“ULSD”) fuel standards that went into effect in June 2006 in an effort to reduce diesel particulate matter substantially. As of June 1, 2006, refiners and importers nationwide have been required by the U.S. EPA to ensure that at least 80 percent of the volume of the highway diesel fuel they produce or import would be ULSD-compliant. As of December 10, 2010, only ULSD fuel was available for highway use nationwide. In California, which was an early adopter of ULSD fuel and engine technologies, 100 percent of the diesel fuel sold – downstream from refineries, up to and including fuel terminals that store diesel fuel – was ULSD fuel since July 15, 2006. Since September 1, 2006, all diesel fuel offered for sale at retail outlets in California have been ULSD fuel.

Existing Conditions

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 pollutants. Exhaust emissions from mobile sources generate the majority of ROG, CO, NOx, and SOx both in the Basin generally and specifically the Los Angeles County portion of the Basin. Area-wide sources generate the most airborne particulates (i.e., PM10 and PM2.5) in both the Basin and Los Angeles County. Measurements of ambient concentrations of the criteria pollutants are used by the U.S. EPA and the ARB to assess and classify the



air quality of each 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 being in “attainment.” If the pollutant concentration exceeds the standard, the area is classified as a “non-attainment” area. If there is 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 ARB use different standards for determining whether the Basin is in attainment. Federal and State standards are summarized in Table 4.2-2, Ambient Air Quality Standards. The attainment status for the Los Angeles County portion of the Basin with regard to the national ambient air quality standards (“NAAQS”) and California ambient air quality standards (“CAAQS”) are shown in Table 4.2-3, Attainment Status for the South Coast Air Basin (Los Angeles County Portion).

Table 4.2-2 Ambient Air Quality Standards

Air Pollutant Averaging Time State Standard Federal Standard

Ozone (O3) 1 Hour 0.09 ppm -- 8 Hour 0.07 ppm 0.07 ppm

Carbon Monoxide (CO) 1 Hour 20.0 ppm 35.0 ppm 8 Hour 9.0 ppm 9.0 ppm

Nitrogen Dioxide (NO2) 1 Hour 180 ppb 100 ppb

Sulfur Dioxide (SO2) 1 Hour 250 ppb 75 ppb

24 Hour 40 ppb 140 ppb Respirable Particulate Matter (PM10) 24 Hour 50 μg/m3 150 μg/m3

Fine Particulate Matter (PM2.5)

24 Hour -- 35 μg/m3

Annual Arithmetic Mean 12 μg/m3 12 μg/m3 (primary)

15 μg/m3 (secondary)

Lead

30 Day Average 1.5 μg/m3 --

Calendar Quarter -- 1.5 μg/m3

(for certain areas) Rolling 3-Month Average -- 0.15 μg/m3

Sulfates 24 Hour 0.03 ppm -- Notes: ppm = parts per million ppb = parts per billion μg/m3 = microgram per cubic meter Source: California Air Resources Board, Ambient Air Quality Standards, website: https://www.arb.ca.gov/research/aaqs/aaqs2.pdf, accessed May 12, 2017.

Table 4.2-3 Attainment Status for the South Coast Air Basin

Pollutant Attainment Status

NAAQS CAAQS Ozone (1-Hour) Non-Attainment (Extreme) Non-Attainment Ozone (8-Hour) Pending – Expect Non-Attainment

(Extreme) Non-Attainment

Carbon Monoxide (1- & 8-hour) Attainment (Maintenance) Attainment

Nitrogen Dioxide (1-Hour) Unclassifiable/Attainment Attainment Nitrogen Dioxide (Annual) Attainment (Maintenance) Attainment



Sulfur Dioxide (1-Hour) Designations Pending (expect Unclassified/Attainment)

Attainment

Sulfur Dioxide (24-Hour & Annual) Unclassified/Attainment Attainment PM10 (24-Hour) Attainment (Maintenance) Non-Attainment PM10 (Annual) N/A Non-Attainment PM2.5 (24-Hour) Non-Attainment (Serious) N/A PM2.5 (Annual) Non-Attainment (Moderate) Non-Attainment Lead Non-Attainment (Partial) Attainment Source: SCAQMD, Air Quality Management Plan Appendix II website: http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/2016-air-quality-management-plan/final-2016-aqmp/appendix-ii.pdf?sfvrsn=4, accessed: May 30, 2017.

Existing Local Air Quality

The SCAQMD divides the Basin into 38 source receptor areas (“SRAs”), wherein 38 monitoring stations operate to monitor the various concentrations of air pollutants in the region. The Project Sites are located is located in SRA 1, which covers Central Los Angeles. SCAQMD Station No. 087 collects ambient air quality data for SRA 1. This station monitors emission levels of O3, CO, NO2, SO2, Sulfates, Lead, PM10, and PM2.5. Table 4.2-4 (Summary of Ambient Air Quality in the Project Vicinity) identifies the federal and State ambient air quality standards for the relevant air pollutants, along with the ambient pollutant concentrations that were measured between 2014 and 2016, the most current year data available.

According to air quality data from the SCAQMD Station No. 087 shown in Table 4.2-4, the previous national 1-hour ozone standard was not exceeded between 2014 and 2016 and the state 1-hour ozone standard was exceeded on seven days between 2014 and 2016. The national 8-hour ozone standard was exceeded on 16 days from 2014 to 2016 and the State 8-hour ozone standard was exceeded on 15 days during that time period. The national 24-hour PM10 standard was not exceeded from 2014 to 2016 and the State 24-hour PM10 standard was exceeded on 76 days during that time period. For PM2.5, the national 24-hour standard was exceeded on 15 days from 2014 to 2016. National or State standards for CO, NO2, or SO2 were not exceeded from 2014 to 2016.

Table 4.2-4 Summary of Ambient Air Quality in the Project Vicinity

Air Pollutants Monitored Within SRA 1 (Central Los Angeles Area)

Year 2014 2015 2016

Ozone (O3) Maximum 1-hour concentration measured 0.113 ppm 0.104 ppm 0.103 ppm Number of days exceeding previous national 0.124 ppm 1-hour standard 0 0 0

Number of days exceeding State 0.09 ppm 1-hour standard 3 2 2 Maximum 8-hour concentration measured 0.094 ppm 0.074 ppm 0.078 ppm Number of days exceeding national 0.07 ppm 8-hour standard 6 6 4 Number of days exceeding State 0.07 ppm 8-hour standard 7 6 2 Suspended Particulates (PM10) Maximum 24-hour concentration measured 87.0 µg/m3 88.0 µg/m3 67.0 µg/m3 Number of days exceeding national 150 µg/m3 24-hour standard 0 0 0 Number of days exceeding State 50 µg/m3 24-hour standard 32 26 18

Annual Arithmetic Mean (AAM) 35.4 µg/m3 33.1 µg/m3 32.4 µg/m3 Does measured AAM exceed national 150 µg/m3 AAM standard? No No No



Table 4.2-4 Summary of Ambient Air Quality in the Project Vicinity

Air Pollutants Monitored Within SRA 1 (Central Los Angeles Area)

Year 2014 2015 2016

Does measured AAM exceed State 20 µg/m3 AAM standard? Yes Yes Yes Fine Particulates (PM2.5) Maximum 24-hour concentration measured 59.9 µg/m3 56.4 µg/m3 44.4 µg/m3 Number of days exceeding national 35.0 µg/m3 24-hour standard 6 7 2

Annual Arithmetic Mean (AAM) 12.36 µg/m3 12.38 µg/m3 11.83 µg/m3 Does measured AAM exceed national 15 µg/m3 AAM standard? No No No Does measured AAM exceed State 12 µg/m3 AAM standard? Yes Yes No Carbon Monoxide (CO) Maximum 1-hour concentration measured 3 3.2 1.9 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 2.0 ppm 1.8 ppm 1.4 ppm Number of days exceeding national 9.0 ppm 8-hour standard 0 0 0 Number of days exceeding State 9.0 ppm 8-hour standard 0 0 0 Nitrogen Dioxide (NO2) Maximum 1-hour concentration measured 82.1 ppb 79.1 ppb 64.7 ppb Number of days exceeding State 180 ppb 1-hour standard 0 0 0 Annual average 22.2 ppb 22.2 ppb 20.8 ppb Does measured annual average exceed national 100 ppb annual average standard? No No No

Does measured annual average exceed State 30 ppb annual average standard? No No No

Sulfur Dioxide (SO2) Maximum 1-hour concentration measured 5.4 ppb 12.6 ppb 13.4 ppb Number of days exceeding national 75 ppb 1-hour standard 0 0 0 Number of days exceeding state 40 ppb 24-hour standard 0 0 0 Sulfates Maximum 24-hour concentration measured 11.0 µg/m3 6.1 µg/m3 5.8 µg/m3 Number of days exceeding state 25 µg/m3 24-hour standard 0 0 0 Lead Maximum monthly average concentration measured 0.01 µg/m3 0.01 µg/m3 0.02 µg/m3 Number of days exceeding state 1.5 μg/m3 30 day standard 0 0 0 Maximum 3-month rolling average measured 0.01 µg/m3 0.01 µg/m3 0.01 µg/m3 Number of days exceeding national 0.15 μg/m3 3-month rolling average standard 0 0 0

ppm = parts by volume per million of air ppb = parts by volume per billion of air µg/m3=micrograms per cubic meter n/a = data not available or not collected by the District Source: SCAQMD Historical Data by Year, website: http://www.aqmd.gov/home/library/air-quality-data-studies/historical-data-by-year, accessed: October 2017.

Site 1 is currently occupied by a two-story abandoned structure with roof parking, a two-story office building occupied by County Department of Parks and Recreation (“DPR”) staff, open parking areas, and carport in the north parking area, and an existing seven-story parking structure at 523 Shatto Place that



is connected to the site. Site 2 is currently occupied by two office buildings, which house County Department of Mental Health (“DMH”) and Workforce Development Aging and Community Services (“WDACS”) staff, respectively. Site 3 is currently occupied by an office building housing DPR staff. The average daily emissions generated by the existing uses at each Project Site have been estimated utilizing the California Emissions Estimator Model (“CalEEMod”) 2016.3.1 model recommended by the SCAQMD. Existing emissions are summarized in Tables 4.2-5 through 4.2-8 below.

Table 4.2-5 Existing Daily Operational Emissions - Site 1

Emissions Source Emissions in Pounds per Day

ROG NOx CO SOx PM10 PM2.5

Area Sources 0.82 <0.01 0.11 <0.01 <0.01 <0.01 Energy Demand 0.01 0.10 0.09 <0.01 <0.01 <0.01 Mobile (Motor Vehicles) 0.37 1.65 4.84 0.01 0.95 0.27 Total Site 1 Emissions 1.19 1.75 5.03 0.01 0.96 0.27 CalEEMod data included in Appendix 4.2-1 to this Draft EIR. Column totals may not add due to rounding from the model results. Source: Pomeroy Environmental Services, 2017.




Area Sources 4.63 <0.01 0.03 0.00 <0.01 <0.01 Energy Demand 0.06 0.58 0.49 <0.01 0.04 0.04 Mobile (Motor Vehicles) 9.67 43.33 127.08 0.33 14.49 4.42 Total Site 2 Emissions 14.36 43.91 127.59 0.33 14.53 4.46 CalEEMod data included in Appendix 4.2-1 to this Draft EIR. Column totals may not add due to rounding from the model results. Source: Pomeroy Environmental Services, 2017.




Area Sources 0.66 <0.01 <0.01 0.00 <0.01 <0.01 Energy Demand <0.01 0.08 0.07 <0.01 <0.01 <0.01 Mobile (Motor Vehicles) 0.44 1.99 5.83 0.01 1.14 0.32 Total Site 3 Emissions 1.11 2.07 5.91 0.02 1.15 0.33 CalEEMod data included in Appendix 4.2-1 to this Draft EIR. Column totals may not add due to rounding from the model results. Source: Pomeroy Environmental Services, 2017.

Table 4.2-8 Existing Daily Operational Emissions – Total All Sites



Site 1 1.19 1.75 5.03 0.01 0.96 0.27 Site 2 14.36 43.91 127.59 0.33 14.53 4.46



Table 4.2-8 Existing Daily Operational Emissions – Total All Sites



Site 3 1.11 2.07 5.91 0.02 1.15 0.33 Total Existing Emissions 16.66 47.73 138.53 0.36 16.64 5.06 CalEEMod data included in Appendix 4.2-1 to this Draft EIR. Column totals may not add due to rounding from the model results. Source: Pomeroy Environmental Services, 2017.

Regulatory Framework

Air quality in the United States is governed by the Federal Clean Air Act (“CAA”). In addition to being subject to the requirements of the CAA, air quality in California is also governed by more stringent regulations under the California Clean Air Act (“CCAA”). At the federal level, the CAA is administered by the U.S. EPA. In California, the CCAA is administered by CARB at the state level and by the Air Quality Management Districts at the regional and local levels.

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 improving the air quality in the Basin are discussed below.

Federal

The U.S. EPA is responsible for setting and enforcing the federal ambient air quality standards for atmospheric pollutants. 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 other than California.

As part of its enforcement responsibilities, the U.S. EPA requires each state with nonattainment areas to prepare and submit a State Implementation Plan that demonstrates the means to attain the federal standards. The State Implementation Plan 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 State Implementation Plan.

State

The CCAA requires all areas of the State to achieve and maintain the CAAQS by the earliest practicable date. The 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 the CAAQS, compiles emission inventories, develops suggested control measures, provides oversight of local programs, and prepares the State Implementation Plan. The CARB establishes emissions standards for motor vehicles sold in California, consumer products (such as hair spray, aerosol paints, and barbecue lighter fluid), and various types of commercial equipment. It also sets fuel specifications to further reduce vehicular emissions.



Although not originally intended to reduce air emissions, California Code of Regulations (“CCR”) Title 24 Part 6: California’s Energy Efficiency Standards for Residential and Nonresidential Buildings, was first adopted in 1978 in response to a legislative mandate to reduce California’s energy consumption. Since then, Title 24 has been amended with recognition that energy-efficient buildings require less electricity and reduce fuel consumption, which, in turn, decreases air emissions.

In compliance with Title 24, new development projects constructed within California after January 1, 2017 are subject to the mandatory planning and design, energy efficiency, water efficiency and conservation, material conservation and resources efficiency, and environmental quality measures of the California Green Building Standards Code (“CALGreen”) (CCR, Title 24, Part 11).

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, community development, and the environment.

Although 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 Transportation Plan/Sustainable Communities Strategy (“RTP/SCS”) identifies growth forecasts that are used in the development of air quality-related land use and transportation control strategies by the SCAQMD.

South Coast Air Quality Management District (“SCAQMD”)

The 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 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.

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”). The most recent of these was adopted by the Governing Board of the SCAQMD on March 3, 2017. This AQMP, referred to as the 2016 AQMP, was prepared to comply with the federal and State Clean Air 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 2016 AQMP identifies the control measures that will be implemented over a 15-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.

The future air quality levels projected in the 2016 AQMP are based on several assumptions. For example, the SCAQMD assumes that new development within the Basin will occur in accordance with population growth and transportation projections identified by the SCAG in its most current version of the RTP/SCS, which was adopted April 7, 2016. The 2016 AQMP also assumes that development projects will include



strategies (mitigation measures) to reduce emissions generated during construction and operation in accordance with SCAQMD and local jurisdiction regulations, which are designed to address air quality impacts and pollution control measures.

Although SCAQMD is responsible for regional air quality planning efforts, it does not have the authority to directly regulate the air quality issues associated with plans and new development projects within its jurisdiction. Instead, SCAQMD has used its expertise and prepared the CEQA Air Quality Handbook and newer thresholds of significance to indirectly address these issues in accordance with the projections and programs of the AQMPs. The purpose of the CEQA Air Quality Handbook and newer thresholds of significance is 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.

Specifically, the CEQA Air Quality Handbook and newer thresholds of significance explain the procedures that the SCAQMD recommends be followed during environmental review processes required by CEQA. The CEQA Air Quality Handbook and newer thresholds of significance provide direction on how to evaluate potential air quality impacts, how to determine whether these impacts are significant, and how to mitigate these impacts. SCAQMD intends that by providing this guidance, the air quality impacts of plans and development proposals will be analyzed accurately and consistently throughout the region, and adverse impacts will be minimized.

Local

County of Los Angeles

Air Quality Element of the County General Plan

The Air Quality Element of the County of Los Angeles General Plan (“County Air Quality Element”) was adopted in October 2015. The County Air Quality Element of the County of Los Angeles General Plan summarizes air quality issues and outlines the goals and policies that will improve air quality and reduce greenhouse gas emissions. The County Air Quality Element identifies mobile sources as the leading contributors to air pollution in the region. Additionally, highly congested freeways and highways further contribute to the conditions that produce air pollution. Developing land and transportation systems to reduce the need for vehicle trips and provide alternative modes of transportation can improve air quality. Moreover, integrating land use plans, transportation plans, and air quality management plans can help minimize exposure to toxic air pollutant emissions from industrial and other stationary sources.

The County’s General Plan also includes Mobility and Land Use Elements, which provide transportation-based policies to reduce vehicle miles travelled, such as improving the efficiency of the County roadway network; mobility management, such as increased ridesharing and vanpools; and improving the jobs-housing balance. The County Air Quality Element also identifies continued population growth projected for the County could overwhelm air quality gains unless careful attention is paid to voluntary and regulatory measures that reduce transportation-related emissions.

The County Air Quality Element establishes three goals:

• Protection from exposure to harmful air pollutants;

• The reduction of air pollution and mobile source emissions through coordinated land use, transportation and air quality planning; and

• Implementation of plans and programs to address the impacts of climate change.



Los Angeles County Green Building Standards Code

In response to the mandates set forth in CALGreen, the Board of Supervisors adopted the Los Angeles County Green Building Standards Code (“Title 31”), thus codifying certain provisions of the 2016 CALGreen Code. The provisions of this Code apply to the planning, design, operation, construction, use, and occupancy of every newly constructed building or structure, unless otherwise indicated this Code.

The purpose of this Code is to improve public health, safety, and general welfare by enhancing the design and construction of buildings through the use of building concepts having a reduced negative impact, or positive environmental impact, and encouraging sustainable construction practices in the following categories: planning and design, energy efficiency, water efficiency and conservation, material conservation and resource efficiency, and environmental air quality. The Los Angeles County Green Building Standards Code contains both mandatory and voluntary green building measures for the reduction of emissions through energy conservation. For an analysis of potential project impacts regarding greenhouse gas (“GHG”) emissions, please refer to Section 4.6 (Greenhouse Gas Emissions) in this Draft EIR.

City of Los Angeles

Local jurisdictions, such as the City of Los Angeles, have the authority and responsibility to reduce air pollution through their police power and decision-making authority. Specifically, the City is responsible for the assessment and mitigation of air emissions resulting from its land use decisions. The City is also responsible for the implementation of transportation control measures as outlined in the AQMP. Examples of such measures include bus turnouts, energy-efficient streetlights, and synchronized traffic signals.

Air Quality Element of the City General Plan

The Air Quality Element of the City of Los Angeles General Plan (“City Air Quality Element”) was adopted on November 24, 1992 and sets forth the goals, objectives and policies that guide the City in the implementation of its air quality improvement programs and strategies. The City 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 City 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 City 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;



• Minimize 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 monitors and enforces implementation of such mitigation. The City uses the CEQA Air Quality Handbook as the guidance document for the environmental review of plans and development proposals within its jurisdiction. The City does not, however, have the specific technical expertise to develop plans, programs, procedures, and methodologies to ensure that air quality within the county and region will meet federal and State standards. Instead, the City relies upon the expertise of the SCAQMD, uses the CEQA Air Quality Handbook, and SCAQMD recommended thresholds of significance as the guidance for the environmental review of plans and development proposals.

Plan for a Healthy Los Angeles

The Plan for a Healthy Los Angeles (adopted by City Council on March 31, 2015) lays the foundation to create healthier communities for all residents in the City. As an element of the General Plan, it provides high-level policy vision, along with measurable objectives and implementation programs, to elevate health as a priority for the City’s future growth and development. With a focus on public health and safety, the Plan for a Healthy Los Angeles provides a roadmap for addressing the most basic and essential quality-of-life issues: safe neighborhoods, a clean environment, access to health services, affordable housing, healthy and sustainably produced food, and the opportunity to thrive.

LA Green Plan

The City 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 (“LA Green Plan”). 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.

Los Angeles Green Building Code

In December 2010, the Los Angeles City Council adopted various provisions of the CALGreen Code as part of Ordinance No. 181,480, thus codifying certain provisions of the CALGreen Code as the new Los Angeles Green Building Code (“LA Green Building Code”). As a result of continuing updates to the CALGreen Code, the City adopted the pertinent provisions of the 2016 CALGreen standards through Ordinance No.



184,691, approved December 19, 2016. The LA Green Building Code is applicable to the construction of every new building, every new building alteration with a permit valuation of over $200,000, and every building addition unless otherwise noted. Specific mandatory requirements and elective measures are provided for three categories: (1) low-rise residential buildings; (2) nonresidential and high-rise residential buildings; and (3) additions and alterations to nonresidential and high-rise residential buildings.

ENVIRONMENTAL IMPACTS

Methodology

This analysis focuses on the nature and magnitude of the change in the air quality environment due to implementation of the Project. Air pollutant emissions associated with the Project would result from Project operations and traffic volumes. Construction activities would also generate air pollutant emissions at each Project Site and on roadways resulting from construction traffic. The increase in emissions at each Project Site generated by these activities and other secondary sources has been quantitatively estimated and compared to thresholds of significance recommended by SCAQMD. A detailed description of the calculations used in this analysis is provided in Appendix 4.2-1 to this Draft EIR.

Construction Emissions

The regional construction emissions associated with the project were calculated using CalEEMod 2016.3.1 as recommended by the SCAQMD. CalEEMod was developed in collaboration with the air districts of California as a statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and GHG emissions associated with both construction and operations from a variety of land use projects. Construction activities associated with demolition, site preparation, grading/excavation, and building construction would generate pollutant emissions. Specifically, these construction activities would temporarily create emissions of dusts, fumes, equipment exhaust, and other air contaminants. These construction emissions were compared to the regional thresholds established by the SCAQMD. Because the Project Sites are located in the Basin, these thresholds apply.

In addition to the SCAQMD’s regional significance thresholds, the SCAQMD has established localized significance criteria in the form of ambient air quality standards for criteria pollutants. To minimize the need for detailed air quality modeling to assess localized impacts, SCAQMD developed mass-based localized significance thresholds (“LSTs”). These thresholds are defined as the amount of pounds of emissions per day that can be generated by a project that would cause or contribute to adverse localized air quality impacts.

These localized thresholds, which are found in the mass rate look-up tables in the “Final Localized Significance Threshold Methodology” document prepared by the SCAQMD,1 apply to daily construction areas that are less than or equal to five acres in size and are only applicable to the following criteria pollutants: NOx, CO, PM10, and PM2.5. LSTs represent the maximum emissions from a project that are not expected to cause or contribute to an exceedance of the most stringent applicable federal or state ambient air quality standards, and are developed based on the ambient concentrations of that pollutant for each SRA.

1 SCAQMD, Final Localized Significance Threshold Methodology, June 2003, Revised July 2008.



In terms of NOx emissions, the two principal species of NOx are nitric oxide (“NO”) and NO2, with the vast majority (95 percent) of the NOx emissions being comprised of NO. However, because adverse health effects are associated with NO2, the analysis of localized air quality impacts associated with NOx emissions is focused on NO2 levels. NO is converted to NO2 by several processes, the two most important of which are (1) the reaction of NO with ozone and (2) the photochemical reaction of NO with hydrocarbons. When modeling NO2 emissions from combustion sources, the SCAQMD assumes that the conversion of NO to NO2 is complete at a distance of 5,000 meters from the source. For PM10 LSTs, the thresholds were derived based on requirements in SCAQMD Rule 403 — Fugitive Dust. For PM2.5 LSTs, the thresholds were derived based on a general ratio of PM2.5 to PM10 for both fugitive dust and combustion emissions. As described in more detail below, the resulting on-site construction emissions generated for each construction phase were analyzed against the applicable LST for each phase.

For the purposes of a CEQA analysis, the SCAQMD considers a sensitive receptor to be a receptor such as a residence, hospital, or convalescent facility where it is possible that an individual could remain for 24 hours. In addition, land uses such as primary and secondary schools, hospitals, and convalescent homes are considered to be sensitive 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. 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.

As shown in Figure 4.2-1, the sensitive receptors nearest to Sites 1 and 2 are:

• school to the south (85 feet); • religious use/school to the east (90 feet); • residences to the west (235 feet); • residences to the south (240 feet); • residences to the northeast (280 feet); • residences to the east (300 feet); • residences to the west (300 feet); • religious use to the north (320 feet); • residences to the southwest (345 feet); • religious use to the southeast (385 feet); and • hotel to the southwest (485 feet).

As shown in Figure 4.2-2, the sensitive receptors nearest to Site 3 are:

• residences to the west (50 feet); • religious use to the east (90 feet); • religious use to the northwest (270 feet); • residences to the north (300 feet); • residences to the south (335 feet); • religious use to the east (400 feet); and • recreation center to the northeast (415 feet).

Thus, according to the SCAQMD, the LSTs for PM10 and PM2.5, which are based on a 24-hour averaging period, would be appropriate to evaluate the localized air quality impacts of a project on nearby sensitive receptors. Additionally, because a sensitive receptor is considered to be present on-site for 24 hours, LSTs

Legend

Aerial Source: Google Earth 2017.

Noise Monitoring Locations

2nd Street

Approximate Scale (Feet)0 250 500

#

Religious/School use to the east (90 feet)23

1

1

School to the south (85 feet)1

2

Residences to the south (240 feet)4

4

2

6

5

Religious use to the southeast (385 feet)

Residences to the northeast (280 feet) 5

7

Residences to the west (300 feet) 7

S. Vermont Avenue

W. 5th Street

S. New

Ham

pshire Avenue

W. 5th Street

Shatto Place

Site 1

Site 2

W. 6th Street

109

Residences to the southwest (345 feet)9

Hotel use to the southwest (485 feet)11

S. Westm

oreland Avenue

4

11

Residences to the east (300 feet) 6

3

Residences to the west (235 feet)3

10

Religious use to the north (320 feet)8

8

Sites 1 & 2 Noise Monitoring andSensitive Receptor Location Map

Figure 4.2-1Sensitive Receptors in the Vicinity of Sites 1 and 2

Source: Pomeroy Environmental Services, 2017.


2nd Street

Site 3 Noise Monitoring andSensitive Receptor Location Map

Approximate Scale (Feet)500


LegendNoise Monitoring Locations

0 250

#

Religious use to the northwest (270 feet)14

Adjacent residences to the west 12

Residences to the north (300 feet)15

Residences to the south (335 feet)16

Religious use to the east (400 feet)17

1 2S. Vermont Avenue

W. 5th Street

S. New

Ham

pshire Avenue

Shatto Place

W. 4th Street

S. Berendo Street

12

14

13

15

Site 3

17

16

Religious use to the east (90 feet)13

Recreation Center to the northeast (415 feet)18

18

Figure 4.2-2Sensitive Receptors in the Vicinity of Site 3

Source: Pomeroy Environmental Services, 2017.



based on shorter averaging times, such as the one-hour NO2 or the one-hour and eight-hour CO ambient air quality standards, would also apply when evaluating localized air quality impacts on sensitive receptors. However, LSTs based on shorter averaging periods, such as the NO2 and CO LSTs, are applied to receptors such as industrial or commercial facilities since it is reasonable to assume that workers at these sites could be present for periods of one to eight hours.2 Therefore, this analysis evaluates localized air quality impacts from construction activities associated with the project on sensitive receptors for NO2, CO, PM10, and PM2.5, and on “non-sensitive” receptors (e.g., industrial or commercial facilities) for NO2 and CO.

Emissions From Project Operations

Emissions associated with Project operation were also calculated using CalEEMod 2016.3.1 and information provided in the traffic study prepared for the Project (Appendix 4.14-1 to this Draft EIR). Operation emissions associated with the Project would be comprised of mobile source emissions, energy demand, and other area source emissions. Mobile source emissions are generated by the net increase in motor vehicle trips to and from the Project Sites associated with operation of the Project. Area source emissions are generated by natural gas consumption for space and water heating, landscape maintenance equipment, and consumer products. To determine if a regional air quality impact would occur, the increase in emissions is compared with the SCAQMD’s recommended regional thresholds for operational emissions, which are applicable to the Project Sites.

As discussed above, the SCAQMD has developed LSTs that are based on the pounds of on-site emissions per day that can be generated by a project that would cause or contribute to adverse localized air quality impacts. For construction, this includes the emissions associated with operating construction equipment on-site throughout the construction period. For operations, this would include emissions associated with on-site stationary sources, and the operation of motor vehicles on-site. The Project includes office and retail uses on Site 1, residential and retail uses on Site 2, and an affordable housing and community recreation center project uses on Site 3. These uses include only limited stationary emissions sources (boilers, etc.), and the compact nature of the parking facilities provided on the Project Sites would result in limited vehicle operations on the Project Sites. Most of the Project’s emissions are generated by mobile sources that occur off-site and do not enter into calculations involving LSTs. In general, LSTs apply to the operational phase of a project only if the project includes numerous stationary sources or attracts mobile sources that may spend long periods queuing and idling at the site. For example, the LST methodology applies to operational projects such as warehouse/transfer facilities.3 Because the Project would include a typical urban mix of residential and commercial uses, an operational analysis utilizing the LST methodology would not apply and, thus, has not been included in this analysis.

Project Design Elements

No specific design elements related to air quality are included in the Project.

2 Ibid. 3 SCAQMD, Sample Construction Scenarios for Projects Less than Five Acres in Size, February 2005, page 1-3.



Thresholds of Significance

Appendix G to the State CEQA Guidelines

The potential for the Project to result in impacts associated with air quality is based on Appendix G of the State CEQA Guidelines, which are addressed in this section. These significance thresholds are listed below.

Threshold 4.2-1: Would the Project conflict with or obstruct implementation of the applicable air quality plan?

Threshold 4.2-2: Would the Project violate any air quality standard or contribute substantially to an existing or projected air quality violation? See also Table 4.2-9, SCAQMD Air Quality Significance Thresholds?

Threshold 4.2-3: Would the Project 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)?

Threshold 4.2-4: Would the Project expose sensitive receptors to substantial pollutant concentrations?

Threshold 4.2-5: Would the Project create objectionable odors affecting a substantial number of people?

An affirmative answer to any of these questions would represent a significant impact. As discussed in Section 6.5 (Effects Not Found to be Significant), the Project would have a less-than-significant impact with respect to odors (Threshold 4.2-5) because it does not include any substantial odor-generating use, such as an industrial facility or landfill.



Table 4.2-9 SCAQMD Air Quality Significance Thresholds

Mass Daily Thresholdsa

Pollutant Construction Operation

NOx 100 pounds/day 55 pounds/day VOC b 75 pounds/day 55 pounds/day PM10 150 pounds/day 150 pounds/day PM2.5 55 pounds/day 55 pounds/day SOx 150 pounds/day 150 pounds/day CO 550 pounds/day 550 pounds/day

Lead 3 pounds/day 3 pounds/day Toxic Air Contaminants and Odor Thresholds

Toxic Air Contaminants (including carcinogens and non-carcinogens)

Maximum Incremental Cancer Risk ≥ 10 in 1 million Cancer Burden > 0.5 excess cancer cases (in areas ≥ 1 in 1 million)

Hazard Index ≥ 1.0 (project increment) Odor Project creates an odor nuisance pursuant to SCAQMD Rule 402 GHG 10,000 MT/yr CO2eq for industrial facilities

Ambient Air Quality for Criteria Pollutantsc

NO2

1-hour average Annual arithmetic mean

SCAQMD is in attainment; project is significant if it causes or contributes to an exceedance of the following attainment standards:

0.10 ppm (federal)d 0.03 ppm (State)

PM10 24-hour average Annual average

10.4 µg/m3 (construction)e & 2.5 µg/m3 (operation)

1.0 µg/m3 PM2.5

24-hour average 10.4 µg/m3 (construction)e & 2.5 µg/m3 (operation) SO2

1-Hour average 24-hour average

0.25 ppm (state) & 0.075 ppm (federal – 99th percentile)

0.04 ppm (state) Sulfate

24-hour average 25 µg/m3 (state) CO

1-hour average 8-hour average

SCAQMD is in attainment; project is significant if it causes or contributes to an exceedance of the following attainment standards:

20 ppm (state) and 25 ppm (federal) 9.0 ppm (state/federal)

Lead 30-day Average

Rolling 3-month Average

1.5 µg/m3 (state)

0.15 µg/m3 (federal) Notes: ppm = parts per million by volume; µg/m3 = micrograms per cubic meter a SCAQMD CEQA Handbook (SCAQMD, 1993). b The definition of VOC includes ROG compounds and additional organic compounds not included in the definition of ROG.

However, for the purposes of this evaluation, VOC and ROG will be considered synonymous.

c Ambient air quality thresholds for criteria pollutants based on SCAQMD Rule 1303, table A-2 unless otherwise stated. d In January 2010, the U.S. EPA proposed a new 1-hour national air quality standard of 0.10 ppm for NO2, which is more

stringent than the state’s current 1-hour threshold of 0.18 ppm. For the purposes of conducting a conservative analysis, the more stringent national one-hour standard for NO2 is used as a threshold in the evaluation of the project’s air quality impacts.

e Ambient air quality threshold based on SCAQMD Rule 403. Source: SCAQMD CEQA Handbook (SCAQMD, 1993), SCAQMD Air Quality Significance Thresholds, website: http://aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance-thresholds.pdf?sfvrsn=2, revised March 2015 and accessed: May 2017.



Impact Analysis

Threshold 4.2-1: Would the Project conflict with or obstruct implementation of the applicable air quality plan?

2016 Air Quality Management Plan

The 2016 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 consistent with the AQMP would not interfere with attainment because this growth is included in the projections utilized in the formulation of the 2016 AQMP. Therefore, projects, uses, and 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 generate emissions exceeding the SCAQMD’s recommended daily emissions thresholds.

As discussed in detail in Section 4.11 (Population, Housing, and Employment) of this Draft EIR, SCAG estimated that the City of Los Angeles had a population of 3,845,500 persons, 1,325,500 households, and employment for 1,696,400 persons in 2012. SCAG forecasts that by the year 2020, the City will have a total population of 4,017,000 persons (an increase of 4.4 percent from 2012), 1,441,400 households (an increase of 8.7 percent), and will provide employment for 1,899,500 persons (an increase of 12 percent). For the period of 2020 to 2040, growth in the City of Los Angeles is forecasted to continue; the citywide population is expected to reach 4,609,400 persons (an increase of 14.7 percent between 2020 and 2040), households will total 1,690,300 (an increase of 17.2 percent), and employment will total 2,169,100 jobs (an increase of 14.2 percent).4

Site 1 would accommodate approximately 2,193 employees at full occupancy (office and retail) by 2023, which would represent a net increase of approximately 2,100 employees on the Site. The majority of these employees would be relocated from existing County offices within the Project area. The increase in employees would be within SCAG’s forecasts of 203,100 additional jobs in the City of Los Angeles between 2012 and 2020 and 269,600 additional jobs between 2020 and 2040 as it represents approximately 1.03 percent and 0.78 percent of the total jobs, respectively. The addition of 618 new residents on Site 2 would be within the SCAG population growth projection, representing approximately 0.10 percent of the Citywide total growth for the period of 2020 to 2040. The addition of 181 new residents on Site 3 would be within the SCAG population growth projection, representing approximately 0.03 percent of the Citywide total growth for the period of 2020 to 2040. Therefore, while the Project would increase employee, housing, and population totals in the City, Project-related growth would be within SCAG’s growth forecast for the City. The Project would comply with all SCAQMD rules and regulations that are in effect at the time of development; the Project Developers are not requesting any exemptions from the currently adopted or proposed rules. Therefore, the Project would not conflict with the 2016 AQMP and, as such, would not jeopardize attainment of State and national ambient air quality standards in the area under the jurisdiction of the SCAQMD. This would be a less-than-significant impact.

4 Southern California Association of Governments, Adopted 2016 RTP/SCS Growth Forecast by City, http://www.scag.ca.gov/Documents/2016_2040RTPSCS_FinalGrowthForecastbyJurisdiction.pdf, accessed: May 15, 2017.



County of Los Angeles General Plan Air Quality Element

The Air Quality Element of the County of Los Angeles General Plan summarizes air quality issues and outlines the goals and policies that will improve air quality and reduce greenhouse gas emissions. These goals and policies would be directly applicable to the Project on Sites 1 and 3. A detailed analysis of the consistency of the Project with relevant policies in the County’s Air Quality Element is presented in Table 4.2-10, Project Consistency with Applicable Policies of the County General Plan Air Quality Element.

Table 4.2-10 Project Consistency with Applicable Policies of the County General Plan Air Quality Element

Policy Consistency Analysis Policy 1.1: Minimize health risks to people from industrial toxic or hazardous air pollutant emissions, with an emphasis on local hot spots, such as existing point sources affecting immediate sensitive receptors.

Consistent. Site 1 and Site 3 do not involve the construction or operation of industrial uses, nor the placement of sensitive receptors near existing industrial toxic pollutants. Therefore, the Project would be consistent with this policy.

Policy 1.2: Encourage the use of low or no volatile organic compound (VOC) emitting materials.

Consistent. Construction activities on Sites 1 and 3 would be required to comply with the provisions under SCAQMD Rule 1113—Architectural Coatings, as set forth in Regulatory Requirement RR-AQ-2, requiring the use of low VOC architectural coatings. Therefore, the Project would be consistent with this policy.

Policy 1.3: Reduce particulate inorganic and biological emissions from construction, grading, excavation, and demolition to the maximum extent feasible.

Consistent. Construction activities on Sites 1 and 3 would be required to comply with the provisions under SCAQMD Rule 403—Fugitive Dust, as set forth in Regulatory Requirements RR-AQ-1, which would require appropriate dust control measures to be implemented during each phase of development. Consequently, particulate emissions at each of these Project Sites during construction of the Project would be minimized. Therefore, the Project would be consistent with this policy.

Policy 2.1: Encourage the application of design and other appropriate measures when siting sensitive uses, such as residences, schools, senior centers, daycare centers, medical facilities, or parks with active recreational facilities within proximity to major sources of air pollution, such as freeways.

Consistent/Not Applicable. Site 1 and Site 3 do not include the placement of sensitive uses within proximity to a freeway. As such, design features reducing such exposure would not be necessary. Therefore, the Project would be consistent with this policy.

Policy 2.4: Coordinate with different agencies to minimize fugitive dust from different sources, activities, and uses.

Consistent. Construction activities on Sites 1 and 3 would be required to comply with SCAQMD Rule 403—Fugitive Dust, as set forth in Regulatory Requirement RR-AQ-1, which would require appropriate dust control measures to be implemented during each phase of development. These dust control measures include daily watering of unpaved areas and reducing vehicle speed on unpaved areas to less than 15 miles per hour. Therefore, the Project would be consistent with this policy.

Policy 3.1: Facilitate the implementation and maintenance of the Community Climate Action Plan to ensure that the County reaches its climate change and greenhouse gas emission reduction goals.

Consistent. See Section 4.6 (Greenhouse Gas Emissions) for Project consistency with the Community Climate Action Plan.



Table 4.2-10 Project Consistency with Applicable Policies of the County General Plan Air Quality Element

Policy Consistency Analysis Policy 3.2: Reduce energy consumption in County operations by 20 percent by 2015.

Consistent. This policy is targeted at energy reduction for County operations, which is applicable only to the Site 1. Site 1 would be consistent with the County Green Building Code standards, as required by Regulatory Requirement RR-AQ-3, which are 25 percent more efficient for residential construction and 30 percent more efficient for non-residential construction as of 2013.a Therefore, the Project would be consistent with this policy.

Policy 3.3: Reduce water consumption in County operations.

Consistent. This policy only applies to Site 1. Site 1 would be required to comply with the County Green Building Code, as required by Regulatory Requirement RR-AQ-3, which includes water efficiency measures that result in an approximate 20percent reduction in indoor and outdoor water use. Therefore, the Project would be consistent with this policy.

Policy 3.4: Participate in local, regional and state programs to reduce greenhouse gas emissions.

Consistent. See Section 4.6 (Greenhouse Gas Emissions) for Project consistency with local, regional, and state programs for greenhouse gas reduction.

Policy 3.5: Encourage energy conservation in new development and municipal operations.

Consistent. Site 1 and Site 3 would be consistent with the County Green Building Code, as required by Regulatory Requirement RR-AQ-3, and will include several features to conserve energy. See also Section 4.6 (Greenhouse Gas Emissions). Therefore, the Project would be consistent with this policy.

Policy 3.6: Support rooftop solar facilities on new and existing buildings.

Consistent. Where feasible and applicable, Site 1 and Site 3 would include infrastructure to support rooftop solar panels in accordance with the County Green Building Code, as required by Regulatory Requirement RR-AQ-3. Therefore, the Project would be consistent with this policy.

a Computed from California Energy Demand, 2012–2022 Final Forecast, June 2012, Form 2.2 on Committed Energy Impacts. Source: County of Los Angeles, General Plan Air Quality Element, adopted October 2015.

Sites 1 and 3 development would be consistent with goals, objectives, and policies set forth in the County’s General Plan Air Quality Element, as discussed above. Therefore, no impact would occur with respect to consistency with the applicable air quality policies in the County General Plan.

City of Los Angeles General Plan Air Quality Element

The Air Quality Element of the City of Los Angeles General Plan sets forth the goals, objectives, and policies that would guide the City in the implementation of its air quality improvement programs and strategies. These goals, objectives and policies are directly applicable to Site 2. A detailed analysis of the consistency of the Project with relevant policies in the Air Quality Element is presented in Table 4.2-11, Project Consistency with Applicable Policies of the City General Plan Air Quality Element.



Table 4.2-11 Project Consistency with Applicable Policies of the City General Plan Air Quality Element

Policy Consistency Analysis Policy 1.3.1: Minimize particulate emissions from construction sites.

Consistent. Construction activities on Site 2 would be required to comply with SCAQMD Rule 403—Fugitive Dust, as set forth in Regulatory Requirement RR-AQ-1, which would require appropriate dust control measures to be implemented during each phase of development. Consequently, particulate emissions at Site 2 during construction of the Project would be minimized. Therefore, the Project would be consistent with this policy.

Policy 1.3.2: Minimize particulate emissions from unpaved roads and parking lots which are associated with vehicular traffic.

Consistent. Construction activities on Site 2 would be required to comply with SCAQMD Rule 403—Fugitive Dust, as set forth in Regulatory Requirement RR-AQ-1, which would require appropriate dust control measures to be implemented during each phase of development. These dust control measures include daily watering of unpaved areas and reducing vehicle speed on unpaved areas to less than 15 miles per hour. Therefore, the Project would be consistent with this policy.

Policy 4.2.2: Improve accessibility for the City’s residents to places of employment, shopping centers, and other establishments.

Consistent. Site 2 includes the redevelopment of an underutilized site in the Wilshire community and would provide a wide variety of compatible and complementary land uses. Site 2 is within walking distance of the Metro Rail Red and Purple Lines. Further, regional and local public bus transit stops are provided near Site 2. The proximity of the Site 2 to these transit stops would provide employees and residents easy access to the new development on Site 2. Therefore, the Project would be consistent with this policy.

Policy 4.2.3: Ensure that new development is compatible with pedestrians, bicycles, transit, and alternative fuel vehicles.

Consistent. Site 2 is a mixed-use development that would include residential, commercial, and retail land uses. Ground-floor retail land uses on Site 2 would be easily accessible to pedestrians. In addition, a plaza would be created along 6th Street to welcome visitors to Site 2. Site 2 is located within close proximity to multi-modal corridors, such as Vermont Avenue, 4th Street, and 6th Street. The characteristics of the nearby multi-modal corridors promote alternative transportation modes (e.g., pedestrian, bicycle, bus, and rail transit). The alternative transportation modes coexist and share the roadway, reinforcing the concept of a balanced and effective transportation system. In addition, Site 2 would provide long- and short-term bicycle parking spaces in accordance with the City Bicycle Ordinance. Therefore, the Project would be consistent with this policy.



Table 4.2-11 Project Consistency with Applicable Policies of the City General Plan Air Quality Element

Policy Consistency Analysis Policy 4.2.4: Require that air quality impacts be a consideration in the review and approval of all discretionary projects.

Consistent. The air quality analysis conducted for the Project in this Draft EIR serves to identify potential air quality impacts associated with construction and operation of residential and retail uses on Site 2. The analysis in this Draft EIR will be used by the City’s decision makers in the review and approval process for the Project. Therefore, the Project would be consistent with this policy.

Source: City of Los Angeles, General Plan Air Quality Element, adopted November 1992.

Site 2 development would be consistent with goals, objectives, and policies set forth in the City’s General Plan Air Quality Element, as discussed above. Therefore, no impact would occur with respect to consistency with the applicable air quality policies in the City General Plan.

Threshold 4.2-2: Would the Project violate any air quality standard or contribute substantially to an existing or projected air quality violation? See also Table 4.2-9, SCAQMD Air Quality Significance Thresholds?

Construction

Phase I

Phase I of the Project would include the construction of the new County office building, retail uses, and parking structure on Site 1, and the construction of new senior affordable housing and community recreation center on Site 3. Site 1 construction is anticipated to begin in the summer of 2018, and would take place over a period of approximately 36 months, with occupancy anticipated to be complete in the summer of 2021. Construction on Site 3 is anticipated to commence in the summer of 2019, and be completed and occupied in 2020.

Phase I construction activities on Sites 1 and 3 would include the demolition of existing buildings, parking structures and surface parking lots, excavation to accommodate the underground parking structures, construction of underground and aboveground parking structures, and framing and finishing of the new office and residential buildings. See Appendix 4.2-1 to this Draft EIR for a complete discussion of assumptions utilized in this analysis.

These construction activities would temporarily create emissions of dust, fumes, equipment exhaust, and other air contaminants. Construction activities involving grading and site preparation would primarily generate PM2.5 and PM10 emissions. Mobile sources (such as diesel-fueled equipment on-site and traveling to and from Sites 1 and 3) would primarily generate NOx emissions. The application of architectural coatings would primarily result in the release of ROG emissions. The amount of emissions generated on a daily basis would vary, depending on the amount and types of construction activities occurring at the same time. Table 4.2-12, Estimated Peak Daily Construction Emissions – Phase I, identifies daily emissions that are estimated to occur on peak construction days for each construction phase during Phase I at Sites 1 and 3. This table only addresses the discrete activities required to construct the individual projects on Sites 1 and 3. Emissions from construction activities on Sites 1 and 3 that would potentially overlap based on the construction schedules for Site 1 and Site 3 are addressed in Table 4.2-



13 below. As shown in Table 4.2-12, the individual construction activities on Sites 1 and 3, when considered separately, would not exceed the SCAQMD thresholds of significance.

Table 4.2-12 Estimated Peak Daily Construction Emissions – Phase I



SITE 1a Demolition Phase 2.71 29.15 16.79 0.04 3.27 1.68 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Grading/Excavation Phase 2.96 48.62 16.18 0.09 5.44 3.04 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Building Construction Phase 25.84 74.19 60.73 0.22 10.94 4.19 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No SITE 3b

Demolition Phase 1.07 10.52 8.55 0.03 1.35 0.67 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Grading/Excavation Phase 1.67 29.89 12.90 0.07 2.30 1.13 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Building Construction Phase 15.37 20.58 19.19 0.07 2.36 1.30 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No a See Table 1 in Appendix 4.2-1 for a breakdown of each construction phase. b See Table 3 in Appendix 4.2-1 for a breakdown of each construction phase. Note: Calculations assume compliance with SCAQMD Rule 403 – Fugitive Dust. Source: Pomeroy Environmental Services, 2017.

Based on the current conceptual construction schedule (see Appendix 4.2-1 to this Draft EIR), the construction of Site 1 and Site 3 may result in overlapping construction days, potentially resulting in higher peak daily regional construction emissions. Specifically, Site 3 demolition, grading, and building construction could overlap with Site 1 building construction activities. Therefore, Table 4.2-13, Estimated Peak Daily Construction Emissions - Overlapping Activities on Sites 1 and 3, identifies daily emissions estimated to occur on overlapping peak construction days during Phase I. As shown, the overlapping emissions would exceed the SCAQMD thresholds for NOx under the Grading Phase of Site 3, and the Building Construction Phase of Site 1.

Table 4.2-13 Estimated Peak Daily Construction Emissions – Overlapping Activities on Sites 1 and 3



Demolition Phase Site 3 1.07 10.52 8.55 0.03 1.35 0.67 Building Construction Phase Site 1

25.84 74.19 60.73 0.22 10.94 4.19

Total Emissions 26.91 84.71 69.28 0.25 12.29 4.86



Table 4.2-13 Estimated Peak Daily Construction Emissions – Overlapping Activities on Sites 1 and 3



SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No

Grading Phase Site 3 1.67 29.89 12.90 0.07 2.30 1.13 Building Construction Phase Site 1

25.84 74.19 60.73 0.22 10.94 4.19

Total Emissions 27.51 104.08 73.63 0.29 13.24 5.32 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No Yes No No No No

Building Construction Phase Site 3

15.37 20.58 19.19 0.07 2.36 1.30

Building Construction Phase Site 1

25.84 74.19 60.73 0.22 10.94 4.19

Total Emissions 41.21 94.77 79.92 0.29 13.30 5.49 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Note: Calculations assume compliance with SCAQMD Rule 403 – Fugitive Dust. Source: Pomeroy Environmental Services, 2017.

Phase II

Phase II of the Project would include the reuse and conversion of the existing twelve-story building for residential and retail use, and construction of new residential and retail uses and parking structure on Site 2. Construction on Site 2 is anticipated to commence in fall 2021, and be completed and occupied in late 2023. Construction on Site 2 cannot commence until the completion of the Site 1 office building and the relocation of existing County employees from Site 2 to Site 1. Accordingly, there would be no overlap between Phase I and Phase II construction activities on Sites 1 and 2.

Phase II construction activities on Site 2 would include demolition of the existing four-story WDACS office building, and two-story parking structure, excavation to accommodate the new underground parking structure, construction of a new underground and aboveground parking structure, framing and finishing of the new residential building, and demolition and reuse/conversion of the interior spaces of the existing DMH building. See Appendix 4.2-1 to this Draft EIR for a complete discussion of assumptions utilized in this analysis.

These construction activities would temporarily create emissions of dust, fumes, equipment exhaust, and other air contaminants. Construction activities involving grading and site preparation would primarily generate PM2.5 and PM10 emissions. Mobile sources (such as diesel-fueled equipment on-site and traveling to and from the Project Site 2) would primarily generate NOx emissions. The application of architectural coatings would primarily result in the release of ROG emissions. The amount of emissions generated on a daily basis would vary, depending on the amount and types of construction activities occurring at the same time. Table 4.2-14, Estimated Peak Daily Construction Emissions – Phase II,



identifies daily emissions estimated to occur on peak construction days for each construction phase during Phase II at Site 2. As shown, no significant emissions impact would occur during the Demolition Phase, Grading Phase, or Building Construction Phase on Site 2.

Table 4.2-14 Estimated Peak Daily Construction Emissions – Phase II



Site 2a Demolition Phase 2.13 22.42 15.63 0.04 2.33 1.22 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Grading Phase 2.01 35.96 11.93 0.08 4.28 2.17 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Building Construction Phase 25.11 25.45 30.20 0.10 4.61 1.82 SCAQMD Thresholds 75.00 100.00 550.00 150.00 150.00 55.00 Significant Impact? No No No No No No Note: Calculations assume compliance with SCAQMD Rule 403 – Fugitive Dust. a See Table 2 in Appendix 4.2-1 for a breakdown of each construction phase. Source: Pomeroy Environmental Services, 2017. The above calculations, for both Phase I and II, assume that appropriate dust control measures would be implemented as part of the project during each phase of development, as required by SCAQMD Rule 403 - Fugitive Dust (Regulatory Requirement RR AQ-1, below). Specific Rule 403 control requirements include, but are not limited to, applying water in sufficient quantities to prevent the generation of visible dust plumes (up to two times per day), applying soil binders to uncovered areas, reestablishing ground cover as quickly as possible, utilizing a wheel washing system to remove bulk material from tires and vehicle undercarriages before vehicles exit the Project Sites, and maintaining effective cover over exposed areas. The calculations also assume that low-emissions paints would be use as part of the project during the appropriate phases of development, as required by SCAQMD Rule 1113 – Architectural Coatings (Regulatory Requirement RR AQ-2, below). As shown in Table 4.2-13, construction-related daily emissions associated with the Project would exceed the SCAQMD significance threshold for NOx during the overlap of the Grading Phase of Site 3 and the Building Construction Phase of Site 1 during Phase I construction activities. As such, regional construction impacts would be significant.

Operation

Operational emissions generated by area sources, motor vehicles and energy demand would result from normal day-to-day activities of the Project. The analysis of daily operational emissions associated with the Project has been prepared utilizing CalEEMod 2016.3.1 as recommended by the SCAQMD. The results of these calculations are presented in Table 4.2-15, Estimated Daily Operational Emissions. The total emissions included in Table 4.2-15 for Phase I reflect the total operational emissions of Site 1 and Site 3. The table also reflects the emissions of the Phase I and Phase II buildout of all of the Project Sites, which represents the total Project operational emissions minus the emissions from the existing development. All of the emissions levels shown would be below the SCAQMD thresholds.



Table 4.2-15 Estimated Daily Operational Emissions



Phase I Site 1 Emissionsa 31.59 29.36 76.45 0.26 21.68 6.01 Less Existing Site 1 Emissions

(1.19) (1.75) (5.03) (0.01) (0.96) (0.27)

Net Change in Site 1 Emissions

30.40 27.61 71.42 0.25 20.72 5.74

SCAQMD Thresholds 55.00 55.00 550.00 150.00 150.00 55.00 Potentially Significant Impact?

No No No No No No

Site 3 Emissionsb 4.10 4.16 15.94 0.03 2.52 0.73 Less Existing Site 3 Emissions

(1.11) (2.07) (5.91) (0.02) (1.15) (0.33)


2.99 2.09 10.03 0.01 1.37 0.40


No No No No No No

Total Phase I Emissions (net increase in Site 1 emissions + net increase in Site 3 emissions)

33.39 29.70 81.45.45 0.26 22.10 6.14


No No No No No No

Phase II

Site 2 Emissionsc 12.65 21.67 84.13 0.25 12.56 3.80 Less Existing Site 2 Emissions

(14.36) (43.91) (127.59) (0.33) (14.53) (4.46)


(1.71) (22.24) (43.46) (0.08) (1.97) (0.66)

Site 1 – Addition of Office Employeesd

0.23 1.02 3.07 0.01 1.04 0.28

Total Phase II Emissions

(1.48) (21.22) (40.39) (0.07) (0.93) (0.38)


No No No No No No

Phases I and II Total Phase I Emissions

33.39 29.70 81.45 0.26 22.10 6.14



Table 4.2-15 Estimated Daily Operational Emissions



Total Phase II Emissions

(1.48) (21.22) (40.39) (0.07) (0.93) (0.38)

Total Net Project Emissions

31.91 8.21 40.06 0.19 21.17 5.76


No No No No No No

Calculation data provided in Appendix 4.2-1 to this Draft EIR. Column totals may not add due to rounding from the model results. a See Tables 4 and 7 in Appendix 4.2-1 for a breakdown of Site 1 operational emissions. b See Tables 6 and 9 in Appendix 4.2-1 for a breakdown of Site 3 operational emissions. c See Tables 5 and 8 in Appendix 4.2-1 for a breakdown of Site 2 operational emissions. d As noted in the Project Traffic Study, after Phase II completion, approximately 103 employees would be added to Site 1 office building resulting in 150 added vehicle trips. Source: Pomeroy Environmental Services, 2017.

The Project would also incorporate Transportation Demand Management (“TDM”) programs to reduce vehicle trip generation, as outlined in Section 4.14 (Transportation, Traffic and Parking) of this Draft EIR. TDM program elements could include bicycle amenities, incentives for alternative travel modes, parking incentives, etc. Furthermore, the mixed-use design of the Project would also reduce total Vehicle Miles Travelled by shortening potential trips (i.e., by linking trips in multi-purpose trip chains). The Project is also located near transit opportunities, including the Metro Red and Purple Lines and buses, and would include bicycle parking; all of which would support a decrease in automobile dependence.

Operational emissions generated by the Project would not exceed the regional thresholds of significance set by the SCAQMD under all scenarios. Therefore, impacts associated with regional operational emissions from the Project would be less than significant.

Construction and Operation Overlap

Because the Project would occur over two phases of development, Sites 1 and 3 would be operational during the demolition, grading and building construction phases of Site 2. Moreover, Site 3 would become operational during the Building Construction Phase of Site 1. Therefore, the Project could result in daily operational and construction emissions at the same time. As such, impacts associated with overlapping Project construction and operational emissions are shown in Table 4.2-16, Construction & Operational Overlapping Emissions. This analysis has conservatively applied the SCAQMD operational thresholds of significance to this scenario, which are lower than the construction thresholds of significance.

Table 4.2-16 Construction & Operational Overlapping Emissions

Emissions Source a Emissions in Pounds per Day


Site 1 Building Construction 25.84 74.19 60.73 0.22 10.94 4.19 Site 3 Operational Emissions 4.10 4.16 15.94 0.03 2.52 0.73

Total Emissions 29.94 78.35 76.67 0.25 13.46 4.92



Table 4.2-16 Construction & Operational Overlapping Emissions

Emissions Source a Emissions in Pounds per Day


SCAQMD Thresholds b 55.00 55.00 550.00 150.00 150.00 55.00

Potentially Significant Impact? No Yes No No No No Phase II Demolition 2.13 22.42 15.63 0.04 2.33 1.22

Phase I Operational Emissions 33.39 29.70 81.45 0.26 22.10 6.14

Total Emissions 35.52 52.12 97.08 0.30 24.43 7.36 SCAQMD Thresholds b 55.00 55.00 550.00 150.00 150.00 55.00 Potentially Significant Impact? No No No No No No

Phase II Grading Phase 2.01 35.96 11.93 0.08 4.28 2.17 Phase I Operational Emissions 33.39 29.70 81.45 0.26 22.10 6.14 Total Emissions 35.40 65.66 93.38 0.34 26.38 8.31 SCAQMD Thresholds b 55.00 55.00 550.00 150.00 150.00 55.00 Potentially Significant Impact? No Yes No No No No

Phase II Building Construction Phase 25.11 25.45 30.20 0.10 4.61 1.82 Phase I Operational Emissions 33.39 29.70 81.45 0.26 22.10 6.14 Total Emissions 58.50 55.15 111.65 0.36 26.71 7.96 SCAQMD Thresholds b 55.00 55.00 550.00 150.00 150.00 55.00 Potentially Significant Impact? Yes Yes No No No No Calculation data provided in Appendix 4.2-1 to this Draft EIR. Column totals may not add due to rounding from the model results. a See Table 4.2-9 above for Phase II construction phase emissions and Table 4.2-11 above for Phase I operational emissions. b SCAQMD thresholds for operational emissions are utilized here as they are more conservative than construction thresholds. Source: Pomeroy Environmental Services, 2017

As shown in Table 4.2-16, an exceedance in the NOx SCAQMD threshold of significance may occur after Site 3 is operational and Site 1 is under construction. Additionally, an exceedance in the ROG and NOx SCAQMD thresholds of significance may occur after Sites 1 and 3 are operational and Site 2 is under construction. As such, impacts during construction and operation overlap would be significant.

Threshold 4.2-3: Would the Project 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)?

The geographic extent of potential cumulative air quality impacts is the Basin. Because the Basin is currently in nonattainment for ozone, PM10, and PM2.5, other new projects in the local vicinity could exceed an air quality standard or contribute to an existing or projected air quality exceedance. With regard to determining the significance of the Project contribution, SCAQMD recommends that a project’s potential contribution to cumulative impacts be assessed utilizing the same significance criteria as those



for project-specific impacts. Furthermore, the SCAQMD states that if an individual development project generates less-than-significant construction or operational emissions impacts, then the development project would not contribute to a cumulatively considerable increase in emissions for those pollutants for which the Basin is in nonattainment.

Construction

As discussed above, construction emissions associated with the project would exceed the SCAQMD’s thresholds of significance for NOx during overlapping construction on Site 1 and Site 3, and NOx and ROG during construction and operation overlapping phases. Because these pollutants are classified as ozone precursors and because the Basin in nonattainment for ozone, this would be considered a potentially significant cumulative impact.

Operation

As discussed above, operational emissions generated by the Project would not violate an air quality standard or exceed an SCAQMD threshold of significance. However, an exceedance in the ROG and NOx SCAQMD thresholds of significance may occur after Sites 1 and 3 are operational and Site 2 is under construction. Because these pollutants are classified as ozone precursors and because the Basin in nonattainment for ozone, this would be considered a potentially significant cumulative impact.

Threshold 4.2-4: Would the Project expose sensitive receptors to substantial pollutant concentrations?

Construction

Land uses that are considered to be more sensitive to changes in air quality than others are referred to as “sensitive receptors.” Primary and secondary schools, hospitals, and convalescent homes, are considered to be sensitive 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 land uses are considered to be 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.

Because Sites 1 and 2 are adjacent to each other, the nearest sensitive receptors for both sites are identified together. The sensitive receptors nearest to Sites 1 and 2 are: school to the south of Site 2 (85 feet), school to the east of Site 1 (90 feet), residences to the south (240 feet), residences to the east (280 feet), residences to the east (300 feet), residences to the west (300 feet), residences to the southwest (345 feet), and hotel to the southwest (485 feet). The nearest sensitive receptors to Site 3 are: residences to the west (50 feet), residences to the north (300 feet), residences to the south (335 feet), and recreational uses to the northeast (450 feet). Locations of sensitive receptors relative to Sites 1, 2 and 3 are shown in Figures 4.2-1 and 4.2-2 above.

Phase I

Emissions from construction activities have the potential to generate localized emissions that may expose sensitive receptors to harmful pollutant concentrations. 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 Source Receptor



Area (SRA) and various distances from the source of emissions. In the case of this analysis, the Project Sites are located within SRA 1 covering the Central Los Angeles area. The sensitive receptor nearest to Site 1 is a school approximately 90 feet to the east. As mentioned previously, Site 1 is 2.5 acres in size. Therefore, consistent with SCAQMD recommendations, the LSTs for a two-acre site in SRA 1 with receptors located within 25 meters have been used to address the potential localized NOx, CO, PM10, and PM2.5 emissions for Site 1. As shown in Table 4.2-17, Site 1 Localized On-Site Peak Daily Construction

Table 4.2-17 Site 1 Localized On-Site Peak Daily Construction Emissions

Construction Phase a Total On-site Emissions (Pounds per Day)

NOx b CO PM10 PM2.5

Demolition Emissions 24.36 15.11 2.84 1.56 SCAQMD Localized Thresholds 108.00 1,048.00 8.00 5.00 Potentially Significant Impact? No No No No Grading/Excavation/Foundation Preparation Emissions 24.29 10.38 3.99 2.58 SCAQMD Localized Thresholds 108.00 1,048.00 8.00 5.00 Potentially Significant Impact? No No No No Building Construction Emissions 24.96 21.86 1.42 1.35 SCAQMD Localized Thresholds 108.00 1,048.00 8.00 5.00 Potentially Significant Impact? No No No No Note: Calculations assume compliance with SCAQMD Rule 403 – Fugitive Dust. Building construction emissions include architectural coatings and paving. a The Project Site is 2.5 acres. Consistent with SCAQMD recommendations, the localized thresholds for Site 1 are based on a two-acre site with a receptor distance of 25 meters (82 feet) in SCAQMD’s SRA 1. b The localized thresholds listed for NOx in this table takes into consideration the gradual conversion of NOx to NO2, and are provided in the mass rate look-up tables in the “Final Localized Significance Threshold Methodology” document prepared by the SCAQMD. As discussed previously, the analysis of localized air quality impacts associated with NOx emissions is focused on NO2 levels as they are associated with adverse health effects. Source: Pomeroy Environmental Services, 2017.

Emissions, peak daily emissions generated on Site 1 during construction activities for each phase would not exceed the applicable construction LSTs in SRA 1. Therefore, localized air quality impacts from Site 1 construction activities on the off-site sensitive receptors would be less than significant.

The sensitive receptors nearest to Site 3 are residential uses 50 feet to the west. As mentioned previously, Site 3 is 0.5 acres in size. Therefore, consistent with SCAQMD recommendations, the LSTs for a one-acre site in SRA 1 with receptors located within 25 meters have been used to address the potential localized NOx, CO, PM10, and PM2.5 emissions for Site 3. As shown in Table 4.2-18, Site 3 Localized On-Site Peak Daily Construction Emissions, peak daily emissions generated within Site 3 during construction activities for each phase would not exceed the applicable construction LSTs in SRA 1. Therefore, localized air quality impacts from Site 3 construction activities on the off-site sensitive receptors would be less than significant.



NOx b CO PM10 PM2.5

Demolition Emissions 8.60 7.69 1.13 0.60 SCAQMD Localized Thresholds 74.00 680.00 5.00 3.00 Potentially Significant Impact? No No No No Grading/Excavation/Foundation Preparation Emissions 8.60 7.69 0.91 0.70 SCAQMD Localized Thresholds 74.00 680.00 5.00 3.00





NOx b CO PM10 PM2.5

Potentially Significant Impact? No No No No Building Construction Emissions 15.78 13.56 0.96 0.89 SCAQMD Localized Thresholds 74.00 680.00 5.00 3.00 Potentially Significant Impact? No No No No Note: Calculations assume compliance with SCAQMD Rule 403 – Fugitive Dust. Building construction emissions include architectural coatings and paving. a The Project Site is 0.5 acre. Consistent with SCAQMD recommendations, the localized thresholds for Site 3 are based on a one-acre site with a receptor distance of 25 meters (82 feet) in SCAQMD’s SRA 1. b The localized thresholds listed for NOx in this table takes into consideration the gradual conversion of NOx to NO2, and are provided in the mass rate look-up tables in the “Final Localized Significance Threshold Methodology” document prepared by the SCAQMD. As discussed previously, the analysis of localized air quality impacts associated with NOx emissions is focused on NO2 levels as they are associated with adverse health effects. Source: Pomeroy Environmental Services, 2017.

Phase II

The sensitive receptor nearest to Site 2 is a school approximately 85 feet to the south. As mentioned previously, Site 2 is one acre in size. Therefore, consistent with SCAQMD recommendations, the LSTs for a one-acre site in SRA 1 with receptors located within 25 meters have been used to address the potential localized NOx, CO, PM10, and PM2.5 emissions for Site 2. As shown below in Table 4.2-19, Site 2 Localized On-Site Peak Daily Construction Emissions, peak daily emissions generated within Site 2 during construction activities for each phase would not exceed the applicable construction LSTs in SRA 1. Therefore, localized air quality impacts from Site 2 construction activities on the off-site sensitive receptors would be less than significant.


Construction Phasea Total On-site Emissions (Pounds per Day)

NOx b CO PM10 PM2.5

Demolition Emissions 19.70 14.49 2.00 1.12 SCAQMD Localized Thresholds 74.00 680.00 5.00 3.00 Potentially Significant Impact? No No No No Grading/Excavation/Foundation Preparation Emissions 14.33 6.33 2.72 1.71 SCAQMD Localized Thresholds 74.00 680.00 5.00 3.00 Potentially Significant Impact? No No No No Building Construction Emissions 16.62 18.32 0.80 0.77 SCAQMD Localized Thresholds 74.00 680.00 5.00 3.00 Potentially Significant Impact? No No No No Note: Calculations assume compliance with SCAQMD Rule 403 – Fugitive Dust. Building construction emissions include architectural coatings and paving. a The Project Site is 1 acre. Consistent with SCAQMD recommendations, the localized thresholds for Site 2 are based on a one- acre site with a receptor distance of 25 meters (82 feet) in SCAQMD’s SRA 1. b The localized thresholds listed for NOx in this table takes into consideration the gradual conversion of NOx to NO2, and are provided in the mass rate look-up tables in the “Final Localized Significance Threshold Methodology” document prepared by the SCAQMD. As discussed previously, the analysis of localized air quality impacts associated with NOx emissions is focused on NO2 levels as they are associated with adverse health effects. Source: Pomeroy Environmental Services, 2017.



Although Site 1 and Site 2 are adjacent to one another, no overlap in construction activities on Sites 1 and 2 would occur since construction on Site 2 cannot commence until the construction on Site 1 is complete and the existing employees on Site 2 have been relocated to the new Site 1 office building.

Operation

Localized Carbon Monoxide Impacts

The Project would not result in potentially significant CO “hot spots” and a Project-specific CO “hot spots” analysis is not needed to reach this conclusion. It has long been recognized that CO exceedances (“hot spots”) are caused by vehicular emissions, primarily when idling at intersections. Vehicle emissions standards have become increasingly more stringent in the last twenty years. With the turnover of older vehicles, introduction of cleaner fuels and implementation of control technology on industrial facilities, CO concentrations in the Project vicinity have steadily declined. For reference, in SRA 1 (Central Los Angeles Area), maximum 1-hour CO concentrations were 3.0 ppm in 2014 and 3.2 ppm in 2015 (1-Hour was not measured in 2013). The national 1-hour standard is 35.0 ppm and the state 1-hour standard is 20.0 ppm. Maximum 8-hour CO concentrations were 2.0 ppm in 2013, 2.0 ppm in 2014, and 1.8 ppm in 2015. The national 8-hour standard is 9.0 ppm and the state 8-hour standard is 9.0 ppm. Also, see Table 4.2-4. Based on these maximum measured concentrations, the 1-hour and 8-hour CO concentrations in SRA 1 have historically been in decline and are substantially within the national and state standards. Accordingly, with the steadily decreasing CO emissions from vehicles, even very busy intersections do not result in localized exceedances of the CO standards. Therefore, the Project would not have the potential to cause or contribute to an exceedance of the California one-hour or eight-hour CO standards of 20 or 9.0 ppm, respectively; or generate an incremental increase equal to or greater than 1.0 ppm for the California one-hour CO standard, or 0.45 ppm for the eight-hour CO standard at any local intersection. Impacts with respect to localized CO concentrations would be less than significant.

Toxic Air Contaminants

As the Project would consist of the development of commercial and residential land uses, and would not include any industrial or other land uses involving the use, storage, or processing of carcinogenic or non-carcinogenic toxic chemicals or air contaminants, or the generation of high levels of diesel truck activity, no toxic airborne emissions would result from its implementation. In addition, operational activities associated with the Project would be typical of other similar commercial and residential developments in the City, and would be subject to the regulations and laws relating to toxic air pollutants at the regional, State, and federal level that would protect sensitive receptors from substantial concentrations of these emissions. Therefore, impacts to sensitive receptors associated with the release of TACs from the Project Sites would be less than significant.

CUMULATIVE IMPACTS

Construction

Because the Los Angeles County portion of the Basin is currently in non-attainment for O3, PM10, and PM2.5, cumulative development could violate an air quality standard or contribute to an existing or projected air quality violation. This would be considered a significant cumulative impact. According to the SCAQMD, individual construction projects that exceed the SCAQMD recommended daily thresholds for project-specific impacts would cause a cumulatively considerable increase in emissions for those pollutants for which the Basin is in non-attainment. As previously discussed, construction emissions



associated with the Project would exceed the SCAQMD’s thresholds of significance for NOx during overlapping construction on Site 1 and Site 3, and NOx and ROG during construction and operation overlapping phases. NOx and ROG are considered O3 precursors and the Basin is in non-attainment for O3. Therefore, the cumulative impact of the Project’s construction emissions would be considered significant.

With respect to TACs, the greatest potential for TAC emissions at related projects would involve diesel particulate emissions associated with trucks and heavy equipment. Construction activities associated with the Project and related projects would be similar to other development projects in the City, and would be subject to the regulations and laws relating to toxic air pollutants at the regional, state, and federal level that would protect sensitive receptors from substantial concentrations of these emissions. In addition, and similar to the Project, related projects construction activity would not result in long-term substantial sources of TAC emissions (i.e., 9, 30 or 70 years) and would not combine with the Project to generate ongoing TAC emissions. Therefore, cumulative TAC emissions from the Project and related projects would be less than significant.

With respect to cumulative odor impacts, potential sources that may emit odors during construction activities at each related project include the use of architectural coatings and solvents. SCAQMD Rules 1108 and 1113 limit the amount of volatile organic compounds from cutback asphalt and architectural coatings and solvents, respectively. Based on mandatory compliance with SCAQMD Rules, it is anticipated that construction activities and materials used in the construction of the project and related projects would not combine to create objectionable odors. Therefore, cumulative odor impacts would be less than significant.

Operation

Due to the non-attainment status of O3, PM10, and PM2.5, the generation of daily operational emissions associated with cumulative development would result in a cumulative significant impact associated with the cumulative net increase of any criteria pollutant for which the region is in non-attainment. With respect to operational emissions, the SCAQMD has indicated that, if an individual project results in air emissions of criteria pollutants (CO, ROG, NOx, SOx, PM10, and PM2.5) that exceed the SCAQMD recommended daily thresholds for project-specific impacts, then it would also result in a cumulatively considerable net increase of these criteria pollutants for which the project region is in non-attainment under an applicable federal or state ambient air quality standard.

As previously discussed, operational emissions associated with the Project would not exceed the established SCAQMD thresholds of significance. However, as noted above, Project emissions would exceed the SCAQMD’s thresholds of significance for NOx and ROG during the overlap of the operation phase of Phase I and the construction phase for Phase II. Once Project construction is complete (both Phases), full buildout operational emissions would not exceed established SCAQMD thresholds of significance. Therefore, the long-term cumulative impact of the Project’s operational emissions would be less than significant.

PROJECT DESIGN FEATURES AND REGULATORY REQUIREMENTS

Project Design Features

No specific Project Design Features are proposed relevant to air quality.



Regulatory Requirements

As noted above, the analysis of Project air emissions incorporates the following regulatory compliance measures:

RR AQ-1: The Project shall comply with SCAQMD Rule 403 regarding fugitive dust.

RR AQ-2: The Project shall comply with SCAQMD Rule 1113 regarding Architectural Coatings.

RR AQ-3: Project construction shall comply with the County of Los Angeles Green Building Standards Code (Sites 1 and 3) and City of Los Angeles Green Building Code (Site 2).

MITIGATION MEASURES

The following mitigation measure has been identified to reduce off-road construction emission impacts to the extent feasible.

MM AQ-1: Developer shall use Tier IV off-road equipment with the following features if reasonably available: alternative fuels (biodiesel, compressed natural gas, propane, etc.), electric equipment, diesel oxidation catalyst, and newer tier engines with more stringent U.S. EPA tier emissions standards than is anticipated from the statewide fleet mix.

LEVEL OF SIGNIFICANCE AFTER MITIGATION

Project impacts related to air quality would be potentially significant with respect to regional construction emissions. Specifically, construction emissions associated with the project would exceed the SCAQMD’s thresholds of significance for NOx during overlapping construction on Site 1 and Site 3, and NOx and ROG during construction and operation overlapping phases. These emissions are primarily associated with off-road construction equipment. As such, MM AQ-1 would reduce these impacts. No other feasible mitigation measures are available to address this impact. Because measurable reductions from this measure cannot be guaranteed at this time (due to unknown market availability and economic feasibility), this analysis has conservatively concluded that regional construction air quality impacts would be significant and unavoidable.

Impacts would be less than significant with respect to localized construction and operational emissions, regional operational emissions, and plan consistency.