HomeMy WebLinkAboutItem No. 11 Attachment 2 - Resolution No. 2021-57; Exhibits A-DFinal Environmental Impact Report
A Community Development Project of the
San Manuel Band of Mission Indians
San Bernardino, California
Lead Agency
City of San Bernardino
201 North E Street, 3rd Floor
San Bernardino, CA 92401
CEQA Consultant
T&B Planning, Inc.
3200 El Camino Real, Suite 100
Irvine, CA 92602
Project Applicant
San Manuel Band of Mission Indians
26569 Community Center Drive
Highland, CA 92346
Lead Agency Discretionary Permits
General Plan Amendment No. 20-02
Development Code/Zoning Map Amendment No. 20-03
Specific Plan Amendment No. 20-01
Development Plan No. 20-02
Date: January 28, 2021
The Landing by San Manuel
Final Environmental Impact Report Table of Contents
Lead Agency: City of San Bernardino SCH No. 2020100067
Page i
TABLE OF CONTENTS
Page
F.0 Final Environmental Impact Report ................................................................................ F-1
F.1 Introduction ............................................................................................................................ F-1
F.2 Responses to Draft EIR Comments ........................................................................................ F-1
F.2.1 CEQA Requirements Regarding Comments and Responses ..................................... F-3
F.2.2 Responses to Comments on the Draft EIR ................................................................ F-4
F.3 Additions, Corrections, and Revisions to the DEIR ........................................................... F-135
F.4 No Recirculation of Draft EIR Required ............................................................................ F-143
Tables
F-1 Agencies, Organizations, and Persons that Commented on the Draft EIR ......................................... F-2
F-2 Errata Table of Additions, Corrections, and/or Revisions to the Draft EIR ................................... F-135
Attachments
Attachment 1 – Substantively Revised Pages of the Draft EIR
Attachment 2 – CalEEMod Outputs Calculating Potential Hauling Emissions
Attachment 3 – Potential Regional Criteria Pollutant Emissions from TRUs Associated with the Project
Including Totals Reported in the Draft EIR
Attachment 4 – Exhibits Attached to Comment Letter E
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-1
F.0 FINAL ENVIRONMENTAL IMPACT REPORT
F.1 INTRODUCTION
This Final Environmental Impact Report (FEIR) prepared for The Landing by San Manuel project (hereafter,
the “Project” or “proposed Project”) was prepared in accordance with the California Environmental Quality
Act (CEQA) as amended (Public Resources Code § 21000 et seq.) and CEQA Guidelines (Title 14, California
Code of Regulations, § 15000 et seq.). The proposed Project consists of applications for a General Plan
Amendment (GPA 20-02), Development Code/Zoning Map Amendment (DCA 20-063), an amendment to the
San Bernardino Alliance California Specific Plan (SPA 20-01), and Development Permit Type-D (DP-D 20-
02) to allow for future development of a proposed 1,153,644 s.f. warehouse building and associated site
improvements.
According to CEQA Guidelines § 15132, the FEIR shall consist of:
a. The Draft (EIR) or revision of the draft;
b. Comments and recommendations received on the DEIR either verbatim or in summary;
c. A list of persons, organizations, and public agencies commenting on the DEIR;
d. The responses of the Lead Agency to significant environmental points raising in the review and
consultation process; and
e. Any other information added by the Lead Agency.
This Section contains responses to comments received on the Draft Environmental Impact Report (DEIR) for
the proposed Project, and also provides a summary of revisions made to the DEIR in response to public
comments. These comments were received during the public review period for the DEIR, which commenced
on November 23, 2020 and concluded on January 6, 2021. This FEIR document was prepared in accordance
with CEQA and the CEQA Guidelines and represents the independent judgement of the CEQA Lead Agency
(City of San Bernardino). This FEIR and the DEIR comprise the Final Environmental Impact Report for the
proposed Project, in accordance with CEQA Guidelines § 15132.
F.2 RESPONSES TO DRAFT EIR COMMENTS
CEQA Guidelines § 15088 requires the Lead Agency (City of San Bernardino) to evaluate comments on
environmental issues received from public agencies and interested parties who reviewed the DEIR. This FEIR
provides all comments received on the DEIR and the City’s responses to each comment. A list of agencies,
organizations, and persons that submitted comments on the DEIR during the public review period is presented
in Table F-1, Agencies, Organizations, and Persons that Commented on the Draft EIR.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-2
Table F-1 Agencies, Organizations, and Persons that Commented on the Draft EIR
COMMENT
LETTER COMMENTING ORGANIZATION, PERSON, OR PUBLIC AGENCY DATE
A California Air Resources Board January 5, 2021
B San Bernardino County Department of Public Works October 27, 2020
C San Bernardino International Airport Authority December 30, 2020
D Inland Empire Biking Alliance November 20, 2020
E Cool World Institute December 31, 2020
F CREED LA November 18, 2020
G Earthjustice January 6, 2021
H1 Blum Collins and Golden State Environmental Justice Alliance January 4, 2021
H2 Adam Salcido January 5, 2001
I Robert Patterson December 7, 2020
J Warehouse Worker Resource Center January 6, 2021
J1 Rocio Aguayo January 6, 2021
J2 Anthony Victoria January 6, 2021
J3 Samuel Rodriguez January 6, 2021
J4 Roxana Barrera January 6, 2021
J5 Darby Osnaya January 6, 2021
J6 Mike Chavez January 6, 2021
J7 Paul Venegas January 6, 2021
J8 Anysia Aguirre January 6, 2021
J9 Alondra Zaragoza January 6, 2021
J10 Guadalupe Dolan January 6, 2021
J11 Leonardo Penaloza January 6, 2021
J12 Michael Rivera January 6, 2021
J13 James Kilbane January 6, 2021
J14 Daisy Lopez January 6, 2021
J15 Maria D. Ortiz January 6, 2021
J16 Lety Escobar January 6, 2021
J17 Salley I. Sukdol January 6, 2021
J18 Kristina M. Montańo January 6, 2021
J19 Socorro Anchondo January 6, 2021
J20 Yvonne Miranda January 6, 2021
J21 Alexandra G. Beltran January 6, 2021
J22 Ada Trujillo January 6, 2021
J23 Catherine Gudis January 6, 2021
J24 Angie Balderas January 6, 2021
J25 Phillip Hubbard III January 6, 2021
J26 Breanna Hall January 6, 2021
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-3
J27 Martha Romero January 6, 2021
J28 Anette (no last name provided) January 6, 2021
J29 Abigail Medina Rosales January 6, 2021
J30 Felipe Avila January 6, 2021
J31 Peter Mendoza January 6, 2021
J32 Ellen Reese January 6, 2021
J33 Maria Luisa Ramirez January 6, 2021
J34 Jennifer Cheek January 6, 2021
J35 Ann Kaneko January 6, 2021
J36 Janette Mckaig January 6, 2021
J37 Athena Tan January 6, 2021
J38 Jody Isenberg January 6, 2021
J39 Julia Vega January 6, 2021
J40 Andrea Vidauree January 6, 2021
K Jim Brown January 18, 2021*
* Received after the close of the public review period.
F.2.1 CEQA REQUIREMENTS REGARDING COMMENTS AND RESPONSES
CEQA Guidelines § 15024(a) outlines parameters for submitting comments, and notes the focus of review and
comment of EIRs should be:
…on the sufficiency of the document in identifying and analyzing possible impacts on the environment
and ways in which the significant effects of the project might be avoided or mitigated. Comments are
most helpful when they suggest additional specific alternatives or mitigation measures that would
provide better ways to avoid or mitigate the significant environmental effects. At the same time,
reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably
feasible…CEQA does not require a lead agency to conduct every test or perform all research, study,
and experimentation recommended or suggested by commenters. When responding to comments, lead
agencies need only respond to significant environmental issues and do not need to provide all
information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.
CEQA Guidelines § 15204(c) further advises that, “Reviewers should explain the basis for their comments,
and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion
supported by facts in support of the comments. Pursuant to CEQA Guidelines § 15064, “an effect shall not be
considered significant in the absence of substantial evidence.” CEQA Guidelines § 15204(d) also notes that,
“Each responsible agency and trustee agency shall focus its comments on environmental information germane
to that agency’s statutory responsibility.” CEQA Guidelines § 15204(e) states that, “This section shall not be
used to restrict the ability of reviewers to comment on the general adequacy of a document or of the lead
agency to reject comments not focused as recommended by [CEQA Guidelines § 15204].”
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-4
Pursuant to CEQA Guidelines § 15088(b), the City of San Bernardino will provide copies of the written
responses to commenting public agencies and other interested parties at least ten (10) days prior to certifying
the FEIR. The responses will be provided along with an electronic copy of this FEIR, as permitted by CEQA,
and conform to the legal standards established for response to comments on DEIRs.
F.2.2 RESPONSES TO COMMENTS ON THE DRAFT EIR
CEQA Guidelines § 15088 requires the Lead Agency (City of San Bernardino) to evaluate comments on
environmental issues received from public agencies and interested parties who review the DEIR and to provide
written response to any substantive comments received. Eleven comment letters are included and responded
to as part of this FEIR. Comment Letter B was a comment letter on the DEIR’s Notice of Preparation (NOP)
but was inadvertently not listed in the DEIR, so Letter B is herein treated as a comment letter to the FEIR.
Comment Letter J was received in a single e-mail that requested that each signatory be treated as an individual
commenter; thus, Comment Letters J-1 through J-40 are listed in Table F-1. Comment Letter K was received
after the close of the DEIR public comment period, but is nonetheless included and responded to herein.
On the following pages is a copy of each comment letter with bracketed comment numbers in the right margin,
followed by the City’s response to each comment as indexed by the bracketed comment number in the letter.
Comment letters and specific comments are given letters and numbers for reference purposes.
Page F-5
Comment Letter A
A-1
A-2
•• ••
The Landing by San Manuel
Final Environmental Impact Report
January 5, 2021
Elizabeth Mora-Rodriguez
Associate Planner
City of San Bernardino -Planning Division
290 North D Street
San Bernardino , California 91764
Submitted via email : Mora-Rodriguez_El@sbcity.org
Dear Elizabeth Mora -Rodriguez:
Gavin Newsom, Governor
Jared Blumenfeld, Cal EPA Secretary
Liane M. Randolph, Chair
Thank you for providing the California Air Resources Board (CARB) with the opportunity to
comment on the Landing by San Manuel Project (Project) Draft Environmental Impact Report
(DEIR), State Clearinghouse No. 2020100067 . The Project would allow for the construction
and operation of 1 ,153 ,644 square feet of warehouse building space on approximately
53 acres of land . Once in operation, the Project would introduce 2 ,458 daily vehicle trips ,
including 582 daily heavy-duty truck trips , along local roadways . The Project is located within
the City of San Bernardino (City), California, which is the lead agency for Californ ia
Environmental Quality Act (CEQA) purposes .
Freight facilities , like the one proposed in the Project, can result in high vo lumes of heavy-duty
diesel trucks and operation of on-site equipment (e.g., forklifts and yard tractors) that em it tox ic
diesel emissions , and contribute to regional air pollution and global climate change .1 CARB
has reviewed the DEIR and is concerned about the air pollution and health risk impacts that
would result should the City approve the Project.
I. The Project Would Increase Exposure to Air Pollution in Disadvantaged
Communities
The Project , if approved , will expose nearby disadvantaged communities to elevated levels of
air pollution. Residences are located north of the Project with the closest residences located
approx imately 100 feet from the Project's northern boundary. In addition , six schools (Indian
Springs High School , Lankershim Elementary School , Cypress Elementary School, Cole
Elementary School , Saint Adelaide School , and Thompson Elementary School) are located
w ith in two miles of the Project. The commun ities near the Project are exposed to existing toxic
diesel particulate matter (diesel PM) emissions from existing industrial facilities , vehicular
1· With regard to greenhouse gas em issions from this project, CARB has been clear that loca l governments and project proponen ts have a
responsibility to properly miti gate these impacts. CARB's guidance, set ou t in detail in the Scoping Plan issued in 20 17, makes clear that in
CAR B's expert view, local mitigation is critical to achieving climate goals and red ucing greenhouse gases below levels of significance .
arb .ca.g ov 1001 I Str ee t• P.O. Box 281 5 • Sacramento, California 95812 (800) 242-4450
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-6
Comment Letter A
A-3
A-4
A-5
A-2(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Elizabeth Mora-Rodriguez
January 5, 2021
Page 2
traffic along State Route 210 (SR-210), and aircraft operations at the San Bernardino
International Airport .
Due to the Project's proximity to residences and schools already burdened by air pollution ,
CARB is concerned with the potential cumulative health impacts associated with the
construction and operation of the Project.
The State of Californ ia has placed additional emphasis on protecting local communities from
the harmful effects of air pollution through the passage of Assembly Bill (AB) 617 (Garcia ,
Chapter 136, Statutes of 2017 ). AB 617 is a significant piece of air quality legislation that
highlights the need for further emission reductions in commun ities with high exposure burdens ,
like those in which the Project is located . Diesel PM emissions generated during the
construction and operation of the Project would negatively impact the community , which is
already disproportionally impacted by air pollution from existing industrial facilities, vehicular
traffic along State Route 210 (SR-210), and aircraft operations at the San Bernardino
International Airport .
Through its authority under Health and Safety Code section 39711 , the California
Env ironmental Protection Agency (Ca l EPA) is charged with the duty to identify disadvantaged
communities . CalEPA bases its identification of these communities on geographic ,
socioeconomic , public health , and environmental hazard criteria (Health and Safety Code ,
section 39711 , subsection (a)). In this capac ity , CalEPA currently defines a disadvantaged
community , from an environmental hazard and socioeconomic standpoint , as a community that
scores w ithin the top 25 percent of the census tracts , as analyzed by the California
Communities Environmental Health Screen ing Tool Version 3 .0 (CalEnviroScreen).
CalEnviroScreen uses a screening methodology to help identify California communities
currently disproportionately burdened by multiple sources of pollution . The census tract
containing the Project is within the top 5 percent for Pollu t ion Burden 2 and is considered a
disadvantaged community ; therefore , CARB urges the City to ensure that the Proj ect does not
adversely impact neighboring disadvantaged communities .
II. The DEIR Did Not Account for All Air Pollutant Emissions from Heavy-Duty
Trucks During the Project 's On-site Grading Construction Phase
The DEIR did not account for mobile air pollutant emissions emitted during the transport of soil
during the Project's construction grading phase . According to the DEIR , it was assumed that
8 ,000 cubic yards would be imported/exported from the Project site during its grading
construction phase . It was also assumed 100 tons of demolished material would need to be
removed from the Project site during the site preparation construction phase . Based on
CARB 's review of the California Emissions Estimator Model (CalEEMod) outputs found in
Appendix B1 (Air Quality Impact Analysis) of the DEIR , the City and applicant assumed a total
2· Pollution Burden repre sents the potential exposure to pollutants and the adverse environmenta l conditions caused by pollutio n.
J
J
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-7
Comment Letter A
A-6
A-7
A-8
A-5(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Elizabeth Mora-Rodriguez
January 5, 2021
Page 3
of 10 one-way heavy-duty truck trucks trips would be required during the Project's combined
site preparation/grad ing construction phase. Although the total 10 one-way heavy-duty truck
trips account for the 100 tons of demolished material that wou ld be removed from the Project ,
it does not account for the 8 ,000 cubic yards of soil imported/exported from the Project s ite .
Assuming each heavy-duty truck has a capacity of 16 cubic yards , the Project would require a
total of 1,000 one-way heavy-duty truck trips to import/export 8 ,000 cubic yards to /from the
Project s ite. To account for all of the air pollutant emissions emitted during the Project's
construction activities , GARB urges the City and applicant to account for air pollutant
emissions from heavy-duty trucks importing/exporting 8,000 cubic yards of soil to the Project
site in the Final Environmental I mpact Report (FEIR).
Ill. The Health Risk Assessment Used Inappropriate Assumptions When Modeling the
Project 's Health Risk Impacts
Chapter 3 (Project Description ) of the DEIR states that approximately 384 ,548 square feet of
the proposed warehouse bu ilding space would be used for cold storage . Warehouses
containing cold storage are serviced by trucks with transport refrigeration units (TRU) to
transport frozen goods to and from the facility. 3 Based on CARB 's research , TRUs on trucks
and trailers can emit large quantities of diesel exhaust while operating within a facility.
Res idences and other sensitive receptors (e .g., daycare fac ilit ies , senior care facilities , and
schools) located near the Project wou ld be exposed to diesel exhaust emiss ions that would
result in sign ificant cancer risk . GARB has reviewed the Project's HRA and has concerns
regarding the assumptions used to estimate the Project's health impacts.
The HRA assumed all heavy-duty trucks w ith TRUs visiting the Project site would not idle
longer than 30 m inutes . Data ob tained by GARB indicates that trucks with TRUs can operate
for as long as two hours per visit , wh ich is well above the 30-minute duration assumed in the
HRA. Unless the applicant and City restrict on -site TRU idling to less than 30 minutes, the
Project's HRA should be revised .
The HRA assumed 79 of the Project's 582 total daily heavy-duty truck traffic (approx imately
14 percent) would consist of trucks equipped with TRUs . It is unclear in the HRA how th is
estimate was derived . Due to t he large size of the proposed warehouse development, GARB
is concerned that the number of TRUs visiting the Project site may be underestimated in the
HRA . GARB urges the City and applicant to provide substantial evidence to support this
assumption.
The HRA states that diesel PM emissions from on and off-site TRU activities were accounted
for in the Project's air dispersion modeling . To estimate the emissions from Project-related
TR Us , the HRA assumed 60 percent of the TRUs accessing the Project si te would have a
3· TR Us are refrige rati on systems powe red by in tegral diesel engines tha t protect perishab le goods during tra nsport in an insulated truck and
trailer vans , rai l cars , and domestic shipping containers .
Final EIR
]
l
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-8
Comment Letter A
A-9
A-10
A-8(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Elizabeth Mora-Rodriguez
January 5, 2021
Page4
power rating of 34 horsepower (hp) and the other 40 percent would have a power rat ing of
23 hp. Based on this mix, the City calculated the average idling emission factor of
Project-related TRUs to be 0.62 grams per brake horsepower-hour (g/bhp-hr). Table 2-2 of the
HRA summarizes the combined diesel PM emission rates from on and off-site heavy-duty
trucks and TRUs for the year 2022 . However, the footnote of each table states the assumed
time each TRU will be within the Project site , but does not provide the assumed time each
TRU will operate off-site. Therefore , it is unclear how the 0.62 g/bhp-hr TRU-emission factor
was used to calculate the diesel PM emiss ion rates presented in the tables . Due to the lack of
clarity , CARB urges the City and applicant to revise the HRA to include spec ific details of the
assumptions used to calculate the cancer risk impacts , supported by substantial evidence .
IV. The DEIR Does Not Analyze Potential Air Quality Impacts from the Project's
Transport Refrigeration Units
Although the HRA prepared for the Project evaluated cancer risks from the operation of on-site
and off-s ite TRUs , the City and applican t d id not model and report air pollutant emissions from
TRUs in the DEIR. The air pollutant emission estimates , found in Table 4 .1-10 (Peak
Operational Emissions Summary) of the DEIR , were modeled using CalEEMod. Although
CalEEMod can estimate air pollu tant emissions from area , energy , and mobile sources , the
current version of CalEEMod does not account for air pollutant emissions from TRUs. Since a
port ion of the Project will be used for cold storage , CARB urges the City and appl icant to
model and report the Project's air pollution emissions from TRUs using CARB's latest emission
factors. The City and applicant should assume that a conservative percentage of the Project's
truck fleet is equipped with TRUs , as well as a conservative idling duration for each TRU .
V. Recommend Mitigation Measures
The DEIR includes a list of nine mit igation measures (4.1 -1 through 4.1-9) to reduce the
Project's significant impact on air quality. These mitigation measures include : requiring large
off-road equipment that is equipped with Tier 4 engines , or Tier 3 or cleaner engines where
Tier 4 equipment is not available during Project construction ; restricting truck idling times to
5 minutes ; requiring all indoor and outdoor cargo handling equipment to be electric or
non-diesel fueled ; and including the minimum number of automobile electric vehicle charging
states required by Title 24 of the California Code of Regulations . Although these mitigation
measures would reduce the Project's air pollutant emissions , the DEIR concludes that the
Project's impact on air quality would remain significant after mitigation . Even where impacts
w ill remain significant and unavoidable after mitigation , CEQA requires that all feasible
mitigation measures be incorporated (see California Public Resources Code§ 2108 1;
14 CCR§ 15126.2(b)). To meet this requirement , CARB urges the City and applicant to add
the applicable emission reduction measures listed in Attachment A of this letter in the Final
Environmental Impact Report (FEIR).
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-9
Comment Letter A
A-11
A-12
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Elizabeth Mora-Rodriguez
January 5, 2021
Page 5
VI. Conclusion
CARB is concerned about the potential public health impacts should the City approve the
Project. The cancer risk impacts presented in the HRA should be based on realistic on-site
idling time for TRUs . The HRA should also assume a conservative percentage of the trucks
visiting the Project site are equipped with TRUs and report the findings in the FEIR. The
Project's air quality impact analysis does not account for air pollutant emissions from the
operation of on -site and off-site TRUs. The FEIR should account for mobile air pollutant
emissions emitted during the transport of soil during the Project's construction grading phase .
Lastly , the revised FEIR analysis presented in the FEIR should include all feasible mitigation
measures listed in Attachment A of this letter to reduce the Project's significant and
unavoidable impact on air quality.
Given the breadth and scope of projects subject to CEQA review throughout California that
have air quality and greenhouse gas impacts coupled with CARB 's limited staff resources to
substantively respond to all issues associated with a project , CARB must prioritize its
substantive comments here based on staff time , resources , and its assessment of impacts .
CARB 's deliberate decision to substantively comment on some issues does not constitute an
admission or concession that it substantively agrees with the lead agency's findings and
conclusions on any issues on which CARB does not substantively submit comments.
CARB appreciates the opportunity to comment on the DEIR for the Project and can provide
assistance on zero-emission technologies and emission reduction strategies , as needed . If
you have questions , please contact Stanley Armstrong , Air Pollution Specialist, at
stanley .armstrong@arb .ca .gov .
Sincerely,
Heather Arias , Chief
Transportation and Toxics Division
Attachment
cc: See next page .
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-10
Comment Letter A
A-12(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Elizabeth Mora-Rodriguez
January 5, 2021
Page 6
cc : State Clearinghouse
state.clearinghouse@opr.ca.gov
Carlo De La Cruz
Senior Campaign Representative
Sierra Club
carlo .delacruz@sierraclub.org
Lijin Sun
Program Supervisor
CEQA Intergovernmental Review
South Coast Air Quality Management District
lsun@aqmd.gov
Morgan Capilla
NEPA Reviewer
U .S . Environmental Protection Agency
Air Division , Region 9
capilla.morgan@epa.gov
Taylor Thomas
Research and Policy Analyst
East Yard Communities for Environmental Justice
tbt homas@eycej .org
Andrea Vidaurre
Policy Analyst
Center for Community Action and Environmental Justice
andrea .v@ccaej .org
Stanley Armstrong
Air Pollution Specialist
Exposure Reduction Section
Transportation and Toxics Division
stanley.armstrong@arb .ca .gov
Lead Agency: City of San Bernardino
Final EIR
SCH No. 2020100067
Page F-11
Comment Letter A
A-14
A-17
A-15
A-18
A-16
A-13
•• ••
The Landing by San Manuel
Final Environmental Impact Report
ATTACHMENT A
Recommended Air Pollution Emission Reduction Measures
for Warehouses and Distribution Centers
The California Air Resources Board (CARB) recommends developers and government
planners use all existing and emerging zero to near-zero emission technologies during
project construction and operation to minimize public exposure to air pollution . Below
are some measures, currently recommended by CARB , specific to warehouse and
distribution center projects. These recommendations are subject to change as new
zero-emission technologies become available .
Recommended Construction Measures
1. Ensure the cleanest possible construction practices and equipment are used.
This includes eliminating the idling of diesel -powered equipment and providing
the necessary infrastructure (e .g ., electrical hookups) to support zero and
near-zero equipment and tools.
2 . Implement, and plan accordingly for, the necessary infrastruct ure to support the
zero and near-zero emission technology vehicles and equipment that will be
operating on site. Necessary infrastructure may include the physical
(e .g., needed footprint), energy , and fueling infrastructure for construction
equipment, on-site vehicles and equipment, and medium-heavy and heavy-heavy
duty trucks .
3 . In construction contracts , include language that requires all off-road
diesel-powered equipment used during construction to be equipped with Tier 4 or
cleaner engines , except for specialized construction equipment in which Tier 4
engines are not available . In place of T ier 4 engines , off-road equipment can
incorporate retrofits , such that , emission reductions achieved equal or exceed
that of a Tier 4 engine .
4. In construction contracts, include language that requires all off-road equipment
with a power rating below 19 kilowatts (e.g., plate compactors , pressure
washers) used during project construction be battery powered.
5. In construction contracts , include language that requires all heavy-duty trucks
entering the construction site , during the grading and building construction
phases be model year 2014 or later. All heavy-duty haul trucks should also meet
CARB 's lowest optional low-oxides of nitrogen (NO x) standard starting in the year
2022 .1
'-In 20 13, CARB adopted optional low-NO, em ission standards for on-road heavy-d uty engines . CARB encourages e ngi ne
manufa cturers to introduce new technologies to reduce NOx emissions below th e curre nt mand atory on -road heavy-duty diesel
engine em iss ion sta nd ards fo r model -year 20 10 and later. CARB 's optio nal low-NO J emis sion sta ndard is avail able at:
https://www.arb.ca .gov/msprog /onroad/optionnox/optionno x.htm .
Attachment -1
Final EIR
J
J
]
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-12
Comment Letter A
A-19
A-20
•• ••
The Landing by San Manuel
Final Environmental Impact Report
6 . In construction contracts, include language that requires all construction
equipment and fleets to be in compliance with all current air quality regulations .
CARB is available to assist in implementing this recommendation .
Recommended Operation Measures
1. Include contractual language in tenant lease agreements that requires tenants to
use the cleanest technologies available , and to provide the necessary
infrastructure to support zero-emission vehicles and equipment that will be
operating on site .
2 . Include contractual language in tenant lease agreements that requires all
loading/unloading docks and trailer spaces be equipped with electrical hookups
for trucks with transport refrigeration units (TRU) or auxiliary power units . This
requirement will substantially decrease the amount of time that a TRU powered
by a fossil-fueled internal combustion engine can operate at the project site . Use
of zero-emission all-electric plug-in TRUs , hydrogen fuel cell transport
refrigeration , and cryogenic transport refrigeration are encouraged and can also
be included in lease agreements .2
3 . Include contractual language in tenant lease agreements that requires all TRUs
entering the project site be plug-in capable.
4 . Include contractual language in tenant lease agreements that requires future
tenants to exclusively use zero-em ission light and medium-duty delivery trucks
and vans .
5 . Include contractual language in tenant lease agreements requiring all
TRUs , trucks , and cars entering the project site be zero-emission.
6. Include contractual language in tenant lease agreements that requires all service
equipment (e.g ., yard hostlers, yard equipment, forklifts , and pallet jacks) used
within the project site to be zero -emission. This equipment is widely available.
7. Include contractual language in tenant lease agreements that requires all
heavy-duty trucks entering or on the project site to be model year 2014 or later,
expedite a transition to zero-emission vehicles , and be fully zero-emiss ion
beginning in 2030.
2• CARB 's tech nology assessme nt for transpo rt refrigerato rs provides informa tion on the c urre nt and projected develo pmen t of
TR Us, in cl udi ng curren t and anti cipa ted costs . The as sess ment is avail able at:
https://www.arb.ca .gov/msprog /tech /techreport/tru_07292015 .pdf.
Attachment -2
Final EIR
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Comment Letter A
A-21
A-23
A-24
A-25
A-22
•• ••
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Final Environmental Impact Report
8 . Include contractual language in tenant lease agreements that requires t he tenant
be in , and monitor compliance with , all current air quality regulations for on -road
trucks including CARB 's Heavy-Duty (Tractor-Trailer) Greenhouse Gas
Regulation ,3 Periodic Smoke Inspection Program (PSIP),4 and the Statewide
Truck and Bus Regulation .5
9 . Include contractual language in tenant lease agreements restricting trucks and
support equipment from idling longer than five minutes while on site.
1 O. Include contractual language in tenant lease agreements that limits on-site TRU
diesel engine runt ime to no longer than 15 minutes. If no cold storage operations
are planned , include contractual language and permit conditions that prohibit cold
storage operations unless a hea lt h risk assessment is conducted , and the hea lth
impacts fully mitigated .
11 . Include rooftop solar panels fo r each proposed warehouse to the extent feasible ,
with a capac ity that matches the maximum allowed for distributed solar
connections to the grid .
12 . Including language in tenant lease agreements , requ iring the installing of
vegetative walls 6 or other effective barriers that separate loading docks and
people living or working nearby.
'· In Decem ber 2008 . CARS adopted a regulation to reduce greenhouse gas emissions by im proving the fuel efficiency of
heavy-duty tractors that pull 53-foot or longer box-type tra ilers. The regu lation applies primarily to owners of 53-foot or longer
box-type trail ers , inclu ding both dry-va n and refrigerated-van trailers , and owners of the heavy-duty tractors that pu ll them on
California highways . CARB 's Hea vy -Duty (T ractor-Trailer) Greenho use Gas Regulation is available at:
https:l/www.arb .ca .gov /cc/hdghgl hdghg . htm .
4· The PSIP program requires that diese l and bus fleet owners conduct annual smoke opacity ins pe ctio ns of their vehicles and repa ir
those wit h excessive smoke em issions to ensure compliance . CARB 's PS IP program is ava il ab le at:
https:l/www.arb .ca .gov /enflhdvipl hdvip .htm .
5 The regu lation req uires that newer heavier trucks and buses must meet particu late matte r fi lt er requi rements begi nning
January 1, 2012 . Lighter a nd older heavier trucks must be re placed starting Janua ry 1, 2015 . By January 1, 2023 , nearly all trucks
and buses will need to have 2010 mode l-year engines or equivale nt. CARB's Statewide Truck and Bus Regulatio n is available at:
https:l/www.arb .ca .gov/msprogl onrdiesell onrdiesel .htm .
•· Effectiveness of Sound Wall-Vegetation Combinati on Barriers as Near-Road way Pollutant Miti gation Strateg ies (2017) is available
at : https :l/ww2 .arb. ca.govlsites/defaulUfiles /c lassic/l resea rchl aprl pasU13-306.pdf.
Attachment -3
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Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
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RESPONSES TO COMMENT LETTER A
A-1 This introductory comment describes information from the Project Description presented in the DEIR,
factually notes that diesel-fueled trucks and equipment emit diesel emissions, and expresses CARB’s
general concern about air pollution and health risks.
A-2 The commenter states that the Project will expose disadvantaged communities and school sites to air
pollution. The commenter does not note the context of the Project Site, being located on property that
was the former location of Norton Air Force Base, located immediately north of the San Bernardino
International Airport, and located immediately east and west of other industrial developments and
northwest of resource extraction operations. These nearby land uses do not house a resident population
or a school population. The residential uses and school sites to which the commenter refers are located
north of the Project Site and north of 3rd Street. DEIR Subsection 4.1, Air Quality, and DEIR Technical
Appendix B1, Air Quality Impact Analysis, and Technical Appendix B2, Health Risk Assessment (HRA),
evaluate the Project’s air pollutant emissions and associated risks to human health during Project
construction and operation. As concluded in these studies and summarized on DEIR Pages 4.1-32
through 34, the Project would have a less than significant impact to all residential land uses and all
school sites using the significance criteria promogulated by the SCAQMD for carcinogenic risk of 10
in one million. The SCAQMD is the agency charged with bringing air quality levels in the South Coast
Air Basin to acceptable levels. Non-cancer risks were also evaluated and determined to be far below
the SCAQMD non-cancer health risk index threshold of 1.0.
A-3 The commenter expresses a general concern about air pollution burden and cumulative impacts. No
specific comments are made that warrant a response or revision to the DEIR. Refer to Response A-2,
above. Also, DEIR Subsection 4.1(D)(1), Regional Air Quality, Pages 4.1-5 to 4.2-13 and Technical
Appendix B1 document the substantial improvement in air quality that has occurred across the South
Coast Air Basin over the past several decades, and the improvement trend that is projected to continue
as a result of increasingly stringent federal and State regulations that have been put in place to reduce
air pollution concurrently with population and business growth.
A-4 The commenter notes the passage of AB 617 (2017) “Community Air Monitoring” and denotes the
surrounding area as disadvantaged per CalEPA’s CalEnviroScreen mapping tool. CalEviroScreen is a
general mapping tool developed by the California Office of Environmental Health Hazard (OEHHA)
to help identify California communities that are affected by sources of air pollution. CalEviroScreen
3.0 indeed shows the vicinity of the Project Site as having a high pollution burden. The commenter
also is correct that the Project Site and its immediately surrounding area is designated by CalEPA as
being part of a disadvantaged community. SB 535 targets disadvantaged communities in California
for investment of proceeds from the State’s cap-and-trade program to improve public health, quality
of life and economic opportunity in California’s most burdened communities while at the same time
reducing pollution. The proposed Project entails the development of one warehouse building that
would bring jobs and other economic opportunities to the local area without State assistance and
investment. As explained in Response A-2, the Project’s health risk impacts associated with air
pollution were calculated in DEIR Technical Appendix B2 and determined to be less than significant
compared to SCAQMD significance criteria. The environmental effects of the proposed Project are
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fully evaluated in the DEIR and feasible mitigation measures are identified for significant impacts that
are within the City of San Bernardino’s jurisdictional authority to impose and enforce as required by
the State CEQA Statute and Guidelines.
A-5 The commenter notes that the Project has the potential to require up to 8,000 cubic yards of soil import
or export. As stated in the DEIR and underlying Technical Appendix B1, the Project’s grading operation
is expected to balance; however, the DEIR notes that up to 8,000 cubic yards of soil import/export is
conservatively estimated, which if needed would be available from areas approved for disturbance on
the adjacent San Bernardino International Airport (SBIA) property or immediate area. Notwithstanding
the fact that earthwork is expected to balance on-site, for disclosure purposes, the potential emissions
that could occur from the hauling of up to 8,000 cubic yards of soil (1,000 two-way haul truck trips
traveling to the adjacent SBIA or immediate area) have been calculated in the table below. It should
be noted that the commenter is not correct in stating 8,000 cubic yards of import/export assuming 16
cubic yards of soil capacity equals 1,000 one-way truck trips. 8,000 cubic yards ÷ 16 cubic yards per
truck = 500 truckloads (one-way) or 1,000 two-way hauling truck trips. As shown in the table below,
the addition of these emissions would be negligible and would not change the findings and conclusions
of the DEIR. The additional CalEEmod outputs calculating the potential hauling emissions are included
as Attachment 2 to these response to comments.
PEAK CONSTRUCTION EMISSIONS SUMMARY
WITH ADDITIONAL HAULING EMISSIONS
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Maximum Daily Emissions Total from DEIR (Table 4.1-13) 50.09 94.00 109.61 0.31 18.38 6.84
Emissions Estimates from potential Soil Hauling 0.04 1.87 0.26 <0.01 <0.01 <0.01
Maximum Daily Emissions 50.13 95.87 109.87 0.31 18.38 6.84
SCAQMD Regional Threshold 75 100 550 150 150 55
Threshold Exceeded? NO NO NO NO NO NO
Source: Urban Crossroads, Inc (2021)
A-6 The commenter acknowledges that the DEIR and its technical analyses assumed that up to 33% of the
proposed building (up to 384,582 square feet of building space) could be used for cold storage, and
expresses a general and broad concern about the assumption. No specific comments are made that
warrant a response or revision to the DEIR.
Additionally, the 15-minute idling period utilized in the Project’s analysis was appropriate – and
conservative – as CARB’s anti-idling rules prohibit idling for more than 5- minutes. Further, as noted
above, the DEIR includes a mitigation measure that requires loading docks for trailers with TRUs to
be outfitted with electrical hook-ups that can be used to power TRUs during loading/unloading
activities to minimize pollutant emissions from TRU operations. Based on the foregoing, no revisions
to the DEIR or its supporting technical air quality analyses are warranted.
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Page F-16
A-7 The commenter asks for clarification on how the HRA arrived at the assumption of 79 trucks with
TRUs of the 582 truck trips. First, as summarized in the DEIR (see Table 4.8-1, Page 4.8-17) it should
be noted that the 582 represents two-way truck trips (291 trucks inbound and 291 trucks outbound)
which are associated with the total Project. The total truck trips associated with the 384,548 square
feet of High-Cube Cold Storage Space are assumed to be 288 two-way truck trips (144 trucks inbound
and 144 trucks outbound). The 288 two-way truck trips are further disaggregated by 2, 3, and 4+-axle
trucks, and includes 100 2-axle truck trips, 32 3-axle truck trips, and 156 4+-axle truck trips. For
analytical purposes, it was conservatively assumed that all 156 4+-axle truck trips include a potential
refrigerated TRU. The 79 trucks with TRU number is representative of one-way trips, as stated in
Technical Appendix B2, page 14. Therefore, the analysis conservatively assumes that all 156 4+-axle
truck trips would include TRUs. As such, the modeling in the HRA is correct and consistent with the
assumptions for the High-Cube Cold Storage Warehouse use. No revision to the DEIR is required.
A-8 The commenter asks how the TRU emissions factor was used to calculate diesel particulate matter
(DPM) emissions. The assumptions utilized in the DEIR and Technical Appendix B2, Health Risk
Assessment are consistent with the industry standard for warehouse distribution facilities. The average
horsepower rating of 34 horsepower (HP) is a reasonable estimate and consistent with CARB’s
regulatory requirements for TRUs. In fact, based on CARB-published data, the majority of TRUs are
already greater than 25 HP and, as such, the assumption used in the Project’s analysis was appropriate.
Lastly, it is appropriate to consider emissions from the TRUs as it relates to on-site usage because the
majority of the emissions are a function of the on-site idling and travel activity. DPM TRU emissions
from both on-site idling/travel and off-site travel along the modeled routes were included in the HRA.
Based on the foregoing, no revisions to the DEIR or its supporting air quality analyses are warranted.
A-9 The commenter correctly summarizes that CalEEMod does not separately account for emissions
associated with TRUs. However, the Project’s Health Risk Assessment attached to the DEIR as
Technical Appendix B2 accounts for the potential diesel exhaust and associated impacts from the
operation of TRUs and therefore impacts from TRUs are accounted for in the DEIR.
Emissions from TRUs can be estimated based on the operation of 156 two-way trucks with TRUs (the
total trucks presumed to accommodate refrigerated space) per day. For criteria pollutants, the
aggregated Instate Trailer TRU emission rates were generated from the CARB’s OFFROAD2017,
Version 1.0.1 emissions estimator model. Potential regional criteria pollutant emissions from TRUs
associated with the Project are summarized in the table below. Refer to Attachment 3 of these response
to comments, which includes the totals from the DEIR:
As shown by the Table below compared to Attachment 3 to these responses to comments, the addition
of potential TRU-related criteria pollutant emissions would be negligible when added to the operational
emissions estimates presented in the DEIR and would therefore not affect the findings and conclusions
presented in the DEIR.
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Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-17
PEAK OPERATIONAL EMISSIONS INCLUDING
ADDITIONAL EMISSIONS FROM TRUS
Emissions (lbs/day)
VOC NOX CO SOX PM10 PM2.5
Maximum Daily Emissions Total from DEIR (Table 4.1-10) 37.31 161.32 126.64 0.87 46.37 14.14
Emissions Estimates from TRUs 0.65 5.24 8.02 <0.01 0.08 0.08
Maximum Daily Emissions 37.96 166.56 134.66 0.87 46.45 14.22
SCAQMD Regional Threshold 55 55 550 150 150 55
Threshold Exceeded? NO YES NO NO NO NO
Source: Urban Crossroads, Inc (2021)
A-10 The commenter notes the DEIR’s conclusion that after application of the nine mitigation measures
listed in the DEIR to address air pollutant emissions, impacts would still be significant and
unavoidable. The commenter asks the City to consider additional mitigation measures suggested in an
attachment to the comment letter. Refer to Responses A-13 to A-25, below, which address each
mitigation measures suggested by the commenter.
A-11 The commenter summarizes its comments and concerns. Refer to Responses A-2 through A-10, above,
for responses to those comments.
A-12 The commenter provides closing comments and offers assistance to the Lead Agency as needed. No
specific comments are made that warrant a response or revision to the DEIR.
A-13 The commenter requests that the City consider additional mitigation measures to address air pollution
emissions. Responses to the specific items suggested by the commenter are provided in Responses A-
14 to A-25, below.
A-14 The commenter requests that the City consider mitigation measures that require the cleanest possible
construction practices and to provide necessary infrastructure to support zero- and near-zero emission
construction equipment and tools. First, please note that as shown on DEIR Table 4.1-13 (DEIR p.
4.1-41), the data for which is supported by substantial evidence contained in Technical Appendix B1,
Project-related air pollutant emissions during construction would be less than significant after the
application of mitigation measures for NOx specified in the DEIR (Mitigation Measures MM 4.1-1
through 4.1-3).
The general request to incorporate a mitigation measure requiring “the cleanest possible construction
practices” is too vague to be enforceable, and the City is not obligated to consider and evaluate the
feasibility of every conceivable measure. Notwithstanding, The DEIR already addresses the
commenter’s request in part. As noted on DEIR Pages 4.1-37 through 4.1-38, the Project is required
to comply with SCAQMD Rule 403 for dust control, Rule 1186 for less polluting street sweepers, and
Rule 1113 for low VOC architectural coatings. Pursuant to Mitigation Measure MM 4.1-1, CARB
Tier IV construction equipment must be used unless it cannot be reasonably acquired. Pursuant to
Mitigation Measure 4.1-2, heavy-duty trucks with a gross vehicle weight over 14,000 pounds must be
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Page F-18
2010 or newer or be equipped with a particulate trap, as available. Also, pursuant to Mitigation
Measure 4.1-3, all construction equipment must comply with applicable CARB regulations.
In relation to the commenter’s general suggestion to provide infrastructure to support zero- and near-
zero emission construction equipment and tools (aka “electric”), the City finds that it is not feasible,
practical, or safe to string temporary overhead powerlines across a large construction site to deliver
power for electric equipment. However, the City finds that it is indeed feasible to designate an area of
the construction site, either near the construction trailer or another area of the construction site
identified by the construction contractor, where electric or non-diesel equipment and tools can be
fueled or charged. Accordingly, the following mitigation measure has been added to the FEIR.
MM 4.1-3A: Plans submitted for grading permit issuance and building permit issuance shall specify
a designated area of the construction site where electric or non-diesel vehicles,
equipment, and tools can be fueled or charged. The provision of temporary electric
infrastructure for such purpose shall be approved by the utility provider, Southern
California Edison (SCE). If SCE will not approve the installation of temporary power
for this purpose, the establishment of a temporary electric charging area will not be
required. If electric equipment will not be used on the construction site because the
construction contractor(s) does not have such equipment in its fleet (as specified in
Mitigation Measure MM 4.1-3B), the establishment of a temporary electric charging
area also will not be required. If electric-powered equipment is in the contractor(s)
equipment fleet, and SCE approval is secured, the temporary charging location is
required to be established upon issuance of grading permits and building permits.
A-15 The commenter requests that the City consider a mitigation measure that requires the installation of
necessary infrastructure to support zero- and near-zero emission construction equipment, including but
not limited to equipment, vehicles, and medium- and heavy-duty trucks. Refer to Response A-14,
above, and the addition of Mitigation Measure MM 4.1-3A. In response to this comment, an additional
mitigation measure has been added to the FEIR to require construction contractors to use electric or
non-diesel construction support equipment if such equipment is available.
MM 4.1-3B: If electric or non-diesel off-road trucks and construction support equipment, including
but not limited to hand tools, forklifts, aerial lifts, materials lifts, hoists, pressure
washers, plate compactors, and air compressors are available in the construction
contractor’s equipment fleet and can fulfill the Project’s construction requirements
during the building construction, paving, and architectural coating phases of Project
construction, such equipment shall be used during Project construction. This
requirement shall be noted on plans submitted for building permit issuance.
A-16 The commenter suggests that CARB Tier 4 or cleaner construction equipment be utilized. Pursuant to
DEIR Mitigation Measure MM 4.1-1, CARB Tier 4 construction equipment must be used if it can
reasonably be acquired. Because this suggestion was already a mitigation measure specified by the
DEIR, no revisions to the FEIR are warranted.
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A-17 The commenter suggests that all off-road construction equipment with a power-rating below 19
kilowatts be battery powered. Please refer to Response A-15, above, and added Mitigation Measure
4.1-3B, which addresses this suggestion.
A-18 The commenter suggests that the City require construction contractor on-road trucks to have 2014 or
newer engines. The City rejects this suggestion for impracticality because regulating and enforcing the
types of vehicles sold and permitted to operate on public roads in the State of California (and therefore
access the Project site) falls outside of the jurisdictional authority of the City of San Bernardino. The
City has no ability or capacity to exclude vehicles that are permitted to be driven on public roads from
accessing the Project site. It is the responsibility of federal and State agencies to regulate the types of
vehicles sold and driven in California. If CARB’s desire is to limit permitted engine types to 2014 or
newer, it is within CARB’s ability to do so. At present, compliance with CARB’s Truck and Bus
Regulation is required, which has phase-in timelines required by State regulation to ensure that any
heavy truck serving the Project would meet 2010 model year engine requirements or equivalent by
January 1, 2023. In June, 2020, CARB adopted a new Rule (Advanced Clean Trucks Regulation) that
is the strictest in the United States, requiring truck manufacturers to transition from diesel trucks and
vans to electric zero-emission trucks beginning in 2024.
A-19 The commenter suggests that the City require construction contracts to require compliance with current
air quality regulations. Because compliance with governing laws is mandatory, there is no reason to
involve the City in specifying legal mandates in private construction contracts. However, to assist in
complying with CARB’s anti-idling regulations on the construction site, the following mitigation
measure has been added to the FEIR.
MM 4.1-3C: Plans submitted for grading permit issuance and building permit issuance shall specify
the locations where anti-idling signs will be located. Signs shall be placed on the
construction site where medium and heavy-duty trucks and other heavy equipment will
stage, identifying applicable California Air Resources Board (CARB) anti-idling
regulations. At a minimum, each sign shall include: 1) instructions to shut off engines
when equipment is not in use; and 2) instructions to restrict idling to no more than five
(5) minutes.
A-20 The commenter suggests that seven items be included in tenant lease agreements for the Project’s
building in an effort to reduce air pollutant emissions during Project operation. As a practical matter,
the City of San Bernardino has no involvement in private lease negotiations among and between private
building owners and building tenants. Nonetheless, a response is provided below for each of the seven
items recommended by the commenter.
1. The commenter suggests that building lease agreements require tenants to use the cleanest
technologies possible and provide infrastructure to support zero-emission vehicles and equipment.
The general request to use “the cleanest technologies possible” is too vague to be enforceable,
particularly in light of the fact that zero-emission technologies are rapidly and dynamically
advancing in the marketplace. In regards to zero-emission vehicle and equipment infrastructure,
DEIR Mitigation Measure MM 4.4-1 already requires that the Project Applicant or successor in
interest provide documentation to the City demonstrating that the Project is designed to meet or
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Page F-20
exceed CALGreen Tier 2 standards in effect at the time of building permit application. These
standards include but are not limited to the provision of referential parking locations for carpool,
vanpool, EVs and CNG vehicles and the installation passenger vehicle EV charging stations
required by Title 24, and the installation of conduit at a minimum of five percent of the Project’s
total number of automobile parking spaces to accommodate the future installation of EV charging
infrastructure. To accommodate charging of battery-powered trucks, the Project’s design includes
a truck staging area in the southwest portion of the property, where EV charging stations for trucks
are planned to be accommodated. MM 4.4-1 requires that the building’s electrical room be
sufficiently sized to hold additional panels that may be needed to supply power for the future
installation of EV truck charging stations on the site at this location. The San Manuel Band of
Mission Indians is the Project Applicant and is voluntarily actively engaged with solar and electric
vehicle industry leaders, such as Tesla, to advance the accommodation of EV vehicles. To this
end, the Project’s building specifications include electrical switchgear and the truck staging area is
designed to accept a technologically advanced electrical charging system to meet prospective
building user requirements for EV truck charging. As a speculative development, it is not possible
to forecast what an actual future user of the building may need or require in terms of EV truck
charging, as the needs vary widely among building users and the technology is rapidly advancing.
The Project’s EV charging facilities for trucks will be tailored to the needs of the building user,
because committing to a system too early and then needing to retrofit it to meet building user
specifications is technologically and cost prohibitive. The Project Applicant’s commitment to
energy sensitive design is appreciated by the City, and is viewed as environmentally responsible.
2. The commenter suggests building lease agreements require dock doors to be equipped with
electrical hookups for auxiliary power units installed on Transport Refrigeration Units (TRUs).
This suggestion relates to a building permit item and not a leasing item. In response to this
comment, the following mitigation measure has been added to the FEIR.
MM 4.4-2: Prior to the issuance of a building permit for warehouse building space that contains
refrigerated or freezer storage, an electrical hookup shall be provided at all loading
dock doors that are designated for the loading/unloading of trailers holding
refrigerated/frozen goods, for the purpose of plugging the refrigeration units installed
on such trailers into the building’s electrical system. If refrigerated/freezer warehouse
space is not proposed, electrical hookups at dock doors will not be required.
3. The commenter suggests that building lease agreements require all TRUs entering the Project Site
to be plug-in capable. Please refer to Response A-20(2), above, and the addition of Mitigation
Measure 4.4-2 to the Final EIR. DEIR Mitigation Measure MM 4.1-4 already requires that signs
be placed at truck access gates, loading docks, and truck parking areas that identify the applicable
CARB anti-idling regulations, which limit idling to 5 minutes or less. Therefore, TRUs will require
auxiliary power units with chargeable batteries in order to keep the trailer cool. With Mitigation
Measures MM 4.1-4 and MM 4.4-2 in place, trucks carrying trailers with TRUs will need to have
plug-in capability auxiliary power units to effectively keep the trailer refrigerated. Therefore, the
commenter’s objective is achieved.
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4. The commenter requests that building lease agreements require building tenants to exclusively use
zero-emission light- and medium-duty delivery trucks and vans. The City rejects this suggestion
for impracticality because regulating and enforcing the types of vehicles sold and permitted to
operate on public roads in the State of California (and therefore access the Project Site) falls outside
of the jurisdictional authority of the City of San Bernardino. The City has no ability, capacity, or
enforcement mechanism to exclude vehicles that are permitted to be driven on public roads from
accessing the Project Site. It is the responsibility of federal and State agencies to regulate the types
of vehicles sold and driven in California. Notwithstanding, the Project’s design includes a truck
staging area in the southwest corner of the property where electric truck charging stations are
intended to be accommodated. DEIR Mitigation Measure MM 4.4-1 encourages the use of zero-
emission vehicles and on-site charging facilities by ensuring that the building’s electrical room is
sized to accommodate panels that may be needed to serve future truck charging needs and requiring
that conduit be installed from where the panel would be located to the southwest corner of the
Development Site where the charging facilities are planned be located and where electric-powered
trucks would park and connect to charging facilities.
5. The commenter suggests that building lease agreements require all TRUs, trucks, and cars entering
the Project Site to be zero-emission. For the reasons summarized in Response A-20(4), above, the
City determines this request to be infeasible and no changes have been made to the DEIR.
6. The commenter suggests that tenant lease agreements require all service equipment to be zero-
emission. DEIR Mitigation Measure MM 4.1-7 requires that all outdoor cargo handling equipment
(e.g., yard trucks, hostlers, yard goats, pallet jacks, forklifts) be non-diesel-powered, which the
City finds sufficient as a practical means to reduce air pollutant emissions associated with such
equipment. Although the commercial availability of zero-emission equipment is increasing as
technology advances, there is still uncertainty in the marketplace regarding the supply and demand
for such equipment and therefore the City rejects the commenter’s suggestion. As an example, the
Port of Long Beach, which has an exponentially larger fleet of service equipment than would the
proposed Project, just put zero-emission top handlers into use in early 2020 as a “test” as part of
the Port’s Off-Road Technology Demonstration Project.1 The size, scale, and funding of Port
projects are massive in scale compared to the proposed Project and are funded by millions of dollars
annually to test, pilot, and demonstrate new technologies, which are continually emerging and
advancing such as those recommended in this comment. For these reasons, the City finds that MM
4.1-7 as written is sufficient.
7. The commenter suggests that tenant lease agreements require 2014 or newer truck engines and an
expedited transition to zero-emission vehicles. The City rejects this suggestion for impracticality
because regulating and enforcing the types of vehicles sold and permitted to operate on public
roads in the State of California (and therefore access the Project Site) falls outside of the
jurisdictional authority of the City. The City has no ability or capacity to exclude vehicles that are
1 https://www.polb.com/port-info/news-and-press/zero-emissions-yard-equipment-enters-port-service-02-25-2020/
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permitted to be driven on public roads from accessing the Project Site. It is the responsibility of
federal and State agencies to regulate the types of vehicles sold and driven in California. If
CARB’s desire is to limit permitted engine types to 2014 or newer, or zero-emission only, it is
within CARB’s ability to do so. At present, compliance with CARB’s Truck and Bus Regulation
is in place, which will require the Project’s future building user(s) to comply with the applicable
phase-in timeline required by State regulation to ensure that any heavy trucks serving the Project
would meet 2010 model year engine requirements or equivalent by January 1, 2023. In June, 2020,
CARB adopted a new Rule (Advanced Clean Trucks Regulation) that is the strictest in the United
States, requiring truck manufacturers to transition from diesel trucks and vans to electric zero-
emission trucks beginning in 2024. By 2045, every new truck sold in California will be required
to be zero-emission. When commercial availability of electric-powered long-haul trucks is more
readily available in the future, it is expected that such trucks will be part of the Project’s normal
course of operation. The Project Applicant and City of San Bernardino have applied forethought
in developing the Project’s design features and mitigation measures to assist in advancing the use
of zero-emission vehicles at the Project Site, as explained in Response A-20(4), above. Also refer
to Response G-3, below.
A-21 The commenter suggests that the City require building lease agreements to require compliance with
current air quality regulations. Because compliance with governing laws is mandatory, there is no
reason to involve the City in specifying legal mandates in private lease agreements. The City makes
the reasonable assumption that all private businesses that may operate on the Project Site will comply
with all applicable State programs and regulations related to air pollution control. Further, CEQA does
not require that mitigation measures duplicate the provisions of mandatory regulatory requirements
that must be complied with as a matter of law.
A-22 The commenter suggests that the City require building lease agreements to restrict truck and equipment
idling longer than 5 minutes. Compliance with CARB’s anti-idling regulations are mandated by State
law. The City has applied Mitigation Measure MM 4.1-4, which requires the Project developer and all
successors in interest to install and maintain signs at truck access gates, loading docks, and truck
parking areas that identify applicable CARB anti-idling regulations. As such, the commenter’s
objective is accomplished.
A-23 The commenter suggests that the City require building lease agreements to limit idling of TRU diesel
engines to no longer than 15 minutes. Refer to Responses A-20(2) and A-20(3), above. The
commenter also asks for a preparation of a health risk assessment (HRA) if cold storage warehouse
uses are planned. Refer to Comment A-6, wherein CARB acknowledges that DEIR and its technical
analyses assumed that up to 33% of the proposed building (up to 384,582 square feet of building space)
could be used for cold storage. The Project’s HRA, inclusive of analysis of cold storage uses, is
included as Technical Appendix B2 to the DEIR.
A-24 The commenter suggests that the Project’s building include rooftop solar panels. Refer to Mitigation
Measure MM 4.4-1(d), which requires that the building’s roof be designed and constructed to
accommodate the potential future construction of photovoltaic (PV) solar arrays. In response to this
comment, Mitigation Measure 4.4-1 has been expanded in the Final EIR to include the following. The
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-23
City is not requiring more than a 24 KV system as part of the shell building for an indeterminate tenant
because committing to a system too early and then needing to retrofit it to meet building user
specifications is technologically and cost prohibitive.
MM 4.4-1(d): As part of shell building permit issuance, and subject to the approval of the Federal
Aviation Administration for the installation of rooftop solar panels near an airport, the
applicant shall be required to install a rooftop photovoltaic system providing a
minimum of 24,000 watts (24 KW) of power per year….
A-25 The commenter suggests that the City require building lease agreements to require the installation of a
vegetative wall or other barrier between loading docks and sensitive off-site uses. This request is
accommodated as part of the Project’s design. As discussed in DEIR Section 3.0, Project Description,
Page 3-6 and Figure 3-10 (Page 3-21, Preliminary Landscape Plan), and as further detailed on the
Project’s application materials on file with the City of San Bernardino, the Development Site’s frontage
along 3rd Street would include 10-14’ high tilt-up screen wall panels in an artistic, thematic design with
modern wall features including tile art elements. Landscaping would occur between the wall and the
sidewalk along 3rd Street.
Page F-24
Comment L etter B
B-1
B-3
B-2
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Main Office -825 East Thi rd Street, San Bernardino , CA 924 15-0835 I Phone : 909 .387 .79 10 Fax : 909.387 .7911
Department of Public Works
• Floo d Control
• Operations
• Solid Waste Ma nage ment
• Sp ec ial Di st ricts
• Surveyor
• Transportatio n
October 27 , 2020
City of San Bernardino , Planning Div ision ,
Clo Elizabeth Mora-Rodriguez
290 North D Street
San Bernardino , CA 92401
Mora -Rodriguez El@sbcity .org .
Transmitted Via Email
www.SBCounty.gov
Brendon Biggs, M.S., P.E.
Director
David Doublet, M.S ., P.E.
Assistant Di rector
File : 1 0(ENV)-4.01
RE: CEQA-NOTICE OF PREPARATION OF A DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE
LANDING BY SAN MANUEL PROJECT
Dear Ms. Mora-Rodriquez:
Thank you for allowing the San Bernardino County Department of Public Works the opportunity to comment J
on the above-referenced project . We received this request on October 05 , 2020 and pursuant to our
review , we have the following comments:
Flood Control Planning & Water Resources Division (Michael Fam, Chief, 909-387-8120):
The Project's northern border is part of the Comprehens ive Storm Drain Plan (CSDP) #6 .
1. We are aware there may be storm drains in and around the site that may be affected by the proposed
Project. When planning for or altering existing or future storm drains , be advised that the Project is
subject to the Comprehensive Storm Drain Plan No . 6, dated August 31 , 2001 . It is to be used as a
guideline for drainage in the area and is available at the San Bernardino County Department of Public
Works-Flood Control Planning Section . Any revision to the drainage should be reviewed and approved
by the jurisdictional agency in which the revision occurs . Should construction of new, or alterations to
existing storm drains be necessary as part of the Proposed Project , their imp acts and any required
mitigation should be discussed within the EIR before the document is adopted by the Lead Agency .
2 . According to the most recent FEMA Flood Insurance Rate Map (FIRM), Panels 06071C8701 J (dated ]
September 2, 2016) and 06071C8702H (dated August 28 , 2008), the Project lies w ithin Zones A, X-
shaded (500-yr. floodplain), X-unshaded, and the Regulatory Floodway. This occurrence and any
potential impact of the proposed projects location within Regulatory Floodway should be included in the
DEIR prior to adoption and certification.
BOARll OF SUPLRVISORS
R OBERT A LOVI NGOOD )ANICE R UTHERFORD D AWN R owE CURT H AGMAN )OSIE GONZALES
First Dis t rict Second District Third D1str1ct Chairman. Fou rt h District Vice C hair. Fifth Dist rict
Leonard X. Hernandez
Chief bec:uhve Officer
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-25
Comment L etter B
B-4
B-5
•• ••
The Landing by San Manuel
Final Environmental Impact Report
City of San Bernardino
October 27 , 2020
Page 2 of 2
Permits/Operations Support Division (Sameh Basta, Chief, 909-387-7995):
1. The proposed Project is adjacent to a San Bernardino County Flood Control District (SBCFCD) facility ]
and right-of-way City Creek Channel (2-603-IA). Be advised that any encroachments includ ing but not
limited to access and utility crossings on SBCFCD's facilities or right-of-way will require a permit from
the SBCFCD prior to start of the project. The necessity for such a permit , and any impacts associated
with the permit , should be addressed in the DEIR prior to adoption and cert ification .
We respectfully request to be included on the circulation list for all project notices , publ ic reviews , or public ]
hearings. In closing , I would like to thank you again for allowing the San Bernardino County Department of
Public Works the opportun ity to comment on the above-referenced project. Should you have any questions
or need additional c larification, please contact the individuals who provided the specific comment , as listed
above .
Sincerely,
~A 7
MICHAEL R. PERRY
Supervising Planner
Environmental Management
MP :AJ :nl
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-26
RESPONSES TO COMMENT LETTER B
B-1 This comment letter was received by the City in response to the DEIR’s Notice of Preparation (NOP).
Because the City inadvertently did not list the letter in DEIR Table 1-1, it is hereby treated as a
comment letter on the DEIR.
B-2 The commenter asks for clarifications about the Project’s storm drain improvements subject to
Comprehensive Storm Drain Plan #6. Alterations to the existing storm facilities within Victoria
Avenue and W Street will be limited to relocation of existing curb inlets and pipe extensions as a result
of the proposed W Street widening. The physical impacts associated with these improvements are
considered part of the Project evaluated in the DEIR.
B-3 The commenter provides information about Federal Emergency Management Agency (FEMA)
floodplain maps and requests that potential floodplain impacts be evaluated. The DEIR addresses
floodplains on DEIR Page 2-14 under Subsection 2.5.6, Hydrology, and in DEIR Subsection 4.5,
Hydrology and Water Quality. Impacts are determined to be less than significant.
B-4 The commenter advises that any encroachments into San Bernardino County Flood Control District
(SBFCD) right of way will require a permit. Project-related improvements within the SBCFCD’s
easement and above the existing flood control facility is limited to grading operations only. The
existing ground elevation will increase by approximately two feet in this area. The physical impacts
associated with these improvements are considered part of the Project evaluated in the DEIR. The
SBFCD is listed as a Responsible Agency for the Project on DEIR Page 1-4.
B-5 The commenter requests to be included on notification lists for the Project. The City of San Bernardino
will include the County of San Bernardino County Department of Public Works on all future public
notices concerning the proposed Project.
Page F-27
Comment Letter C
C-1
•• ••
The Landing by San Manuel
Final Environmental Impact Report
~F/SBO
'nt; rn I i
December 30, 2020
City of San Bernardino
c/o Elizabeth Mora-Rodriguez
290 North D Street
San Bernardino , CA 92401
Dear Ms . Mora-Rodriguez :
San Bernardino International Airport Authority
1601 E . Th ird Street, San Bernardino, CA 92408
(909) 382-4100 phone I (909) 382-4106 fax
Subsequent to previous correspondence , the San Bernardino International Airport (SBIA or Airport) in
coordination with our environmental consultant, Tom Dodson and Associates , have reviewed the Draft
Environmental Impact Report (DEIR) prepared for The Landing by San Manuel and submits the
following comments to the City of San Bernardino . This project includes an approximately 1,153,644
square foot warehouse building and support facilities (proposed project) that will involve a total of
about 62.49 acres located within the boundary of former Norton Air Force Base . As you are aware ,
the SBIA is a responsible agency under the California Environmental Quality Act (CEQA). The San
Bernardino International Airport Authority (SBIAA) operates the Airport, a commercial airport
certificated by the Federal Aviation Administration (FAA) which is proximate to the proposed project.
The Airport is a 24-hour operation serving various types of aeronautical activities including air cargo ,
law enforcement air support , and essential US Forest Service aerial fire responses .
These comments are submitted in furtherance of the proposed project and in compliance with SBIA's
FAA requirements and applicable Airport rules and regulations . For ease of understanding and
convenience, SBIAA has consolidated the comments in the attached document which has been
annotated and cross-referenced for the benefit of the applicant and the City.
The Airport appreciates the opportun ity to submit these comments with the goal of producing the
highest quality DEIR to support approval of the proposed project's entitlements and any future second-
tier environmental approvals . Should you have any questions or require any further information from
the Airport , please do not hesitate to contact my office at (909) 382-4100 .
rrows
Chief Executive Officer
San Bernardino International Airport Authority
info@sbdairport.com 1.www .sbdairport.com
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-28
Comment Letter C
C-2
C-3
C-13
C-4
C-5
C-6
C-7
C-9
C-12
C-10
C-8
C-11
•• ••
The Landing by San Manuel
Final Environmental Impact Report
COMMENTS ON THE LANDING DEIR , November 2020
Chapter 1
p.1-2
p.1-5
p.1-11
Chapter 2
p.2-1
p.2-5
Chapter 3
p.3-5
p.3-8
p.3-10
Chapter4
-SPA 20-01 para , line 3 : insert "on " between "l ocated " and "the "
-Second para , last line : insert "and " between "NOP" and "the"
-Para coming on page: suggest incorporating in this text that the location where the
referenced document can be accessed be added to this section
-The Specific Plan area has been expanded by approximately 9 acres, located in
the City of San Bernardino , i.e., 194 acres
-Bottom para : there is no loca l feature called "Highland Creek" -it sounds like a
reference to the City Creek Bypass
-Figure 2-3 : probably needs a legend to prevent confusion regarding areas
bordered by red lines
-Para 2 , bottom : It is not clear whether the driveway along the eastern boundary
will be fenced for A irport access only ; please clarify . Who will man the security
gate; Airport personnel or warehouse security? Will any project-related
construction be required on Airport property?
-Under heading "B": As worded , it is not clear whether the existing features to be
demolished consist of 100 tons of material or not; please clarify.
-I nstallat ion of secondary access to Airport SW corner; please ensure that the Airport
property line is properly controlled/secured per Airport requirements .
-Table 3-3 : Project Approvals/Permits; include SBIAA review and approval of utility
service and connection agreements and airport-owned street improvement permits.
Proper fair share contributions for mitigation of impacts to Airport properties (airport
roadways , sewer, stormdrains , etc) must be payable by applicant directly to the
Airport and should be included in any conditions of approval issued by the City of
San Bernardino for the proposed project.
p.4 .1-5 -0 3 is not a directly emitted pollutant; suggest deleting from th is statement or revise
statement.
p.4 .1-10 -First para, line 4: text is garbled ; please correct re : decrease.
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Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-29
Comment Letter C
C-23
C-14
C-17
C-18
C-21
C-24
C-22
C-20
C-15
C-19
C-16
•• ••
The Landing by San Manuel
Final Environmental Impact Report
p.4 .1-26 -The total square feet increased by over 100 ,000 sf due to the change in total
acreage to IL and the FAR; suggest including these points in this paragraph
p.4 .1-33 -Para 2 , last sentence : this sentence contains a leap of logic regarding cumulative
impacts that is not substantiated ; no data has been presented regarding
cumulative trips and background concentrations ; need to expand
p.4 .1-34 -Para 1, the question arises -whether the school TAC evaluation should be based
on the project site or distance to the nearest roadway carrying substantial truck
traffic
p.4 .1-36 -Cumu lative analysis does not include a discussion ofTACs and cumulative
projects 2nd para on page
-Para 5 continues this train of thought
p.4 .1-40 -Mitigation measure 4 .1-7 recommends including hydrogen fueling as a specific
alternative
-Bottom of page: why not include solar at facility to affect both NOx and CO 2
emissions from electricity and Natural gas use? Possibly require phase in of
electric trucks as available?
Bio Resources 14.2)
p. 4.2-4 -Aside from the area not functioning as a W ildlife movement corridor, the site does
not connect to any habitat to the North , South, East or West; nearest corridors are
City Creek and Santa Ana River channe ls and maybe the City Creek Bypass
Greenhouse Gas (4 .4)
p.4.4-31 -Table 4.4-5 consistency Summary-most findings indicate no conflict w ith
prescribed action ; however, is no conflict the correct measure of consistency?
Hydrology and Water Quality 14 .5)
p.4 .5-2
p.4 .5-7
p.4 .5-8
-Para 1, line 5 : "700 miles" should this be 70 miles for the river itself or does this
include all the various tributaries?
-First para on page , line 11 : change "floor" to "flood "
-At several locations on this page the statement is made: "the Project would not
involve the storage of potential pollutants outside of the proposed building." How
will this requirement be enforced? Who w ill be responsib le for ensuring that all
polluting materials are stored inside and not left outside exposed to flood hazards?
-Threshold b, line 1 1: previous statements indicated no pollutants wou ld be stored
outside . Here the statement is that "uncontained storage" would not be allowed .
Please clar ify which circumstance is correct and if the latter, please clearly define
what the term "unconfined " means .
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Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-30
Comment Letter C
C-36
C-34
C-26
C-28
C-25
C-32
C-27
C-31
C-38
C-35
C-37
C-29
C-33
C-30
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Land Use & Plann ing (4 .6)
p.4 .6-2 First para , line 7 : change "670 " to "679"; also, there is no "Highland Creek" only
City Creek Bypass
-Line 10: change (±185) to (±194 )
-Bottom of para : refer to attached aerial showing location and partners in the 5th
Street Improvements
p. 4.6-4 -Bottom of first para : should "mode' be "component" or "element"?
-SCAQMD last line : should "Subsection 4.8" be "Subsection 4.6 "? Also , it would
seem appropriate to provide the finding of the analysis in Subchapter 4 .1, i.e.,
inconsistent with the AQMP
p.4 .6-8 -Bottom para : where or how did the City reach a conclusion regarding potential
conflicts w ith the Natural Resources & Conservation Element based on
unavoidable s ignificant impacts under the Air Quality issue?
p.4 .6-9 -Municipal Code para : please reference where the City Staff's review and
determination conclusions can be independently reviewed .
p.4 .6-10 -Top of page: How does project integrate transfer network with land use patterns,
etc. This section inappropriately references 10,000 tons threshold when the
threshold used is 3 ,900 tons; correct reference . Might explain how referencing EIR
disclosure prevents conflicts with SCAG RTP/SCS .
-Table 4.6-1 , item 5: the project cannot claim to reduce GHG & improved Air
Quality; misleading . Same for item 6 ; need to reference TAC studies in Air Quality
subchapter
p.4 .6-13 -Cumu lative impact conclusion not well supported
Noise {4 .7)
p.4 .7-21 -Recommend running through City noise ordinance standards to fully demonst rate -
substantive conclusion -finding
p.4 .7-29 -Horizon Year (2040), para 1, line 5 : change "segment is " to "segments are "
p.4 .7-31 -Operational-related Vibration Impacts , lines 3 and 4 : change "vibration " to
"vibrations"
-Bottom para : The analysis and conclusion regarding offsite truck traffic is limited .
Under present conditions , 5th and 3rd Streets are well paved east of Victoria , but
roadways like Central and Lankersh im are not. Also , the analysis would have
better supported general data conclusions with some background field
measurements .
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Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-31
Comment Letter C
C-48
C-40
C-45
C-47
C-42
C-43
C-39
C-44
C-50
C-51
C-46
C-41
C-49
•• ••
The Landing by San Manuel
Final Environmental Impact Report
p.4 .7-32 -Para 2 : suggest providing updates for the recent Eastgate project at the airport
(most or all exterior construction is complete and will not overlap with The Landing ;
the AGSP has no potential to be fully implemented by 2022; however, some
warehouse projects have been constructed in the general project area by others
(one on 6th Street, one on 5th Street, and two east of Palm & 5th ) these should be
referenced as part of the existing cumulative projects related to this project .
Transportation (4.8)
p.4 .8-6 -A. para 2, line 3: suggest deleting "with "
-Para 3: suggest identifying closest "major transit stop " and/or the nearest high
quality transit corridor existing stop
-Last para , line 1: suggest "identifies" to "identify"
p.4 .8-9 -Please refer to comments on Land Use consistency, including the RTP-SCS
p.4 .8-10 -Para 3 : The finding of consistency suffers f rom a flawed assumption regarding
payment of DIF . Fair-share funding is deemed adequate mitigation for cumulative
impacts, such a traffic (1 5130(a)(3)). However, this finding ignores the failure of
Lead Agencies to fund and install circulation system improvements in a timely
manner. Thus , a required cumulative circulation improvement may not be installed
before a project in itiates its trips and an actual significant im pact result.
p.4 .8-11 -Policy 6 .5.4 , line 7 : insert "no " between "to" and "more"
p.4 .8-12 -Threshold c, para 2 , line 8: please provide a definition or basis for concluding the
truck staging area is "ample"
-Line 12: change "existing " to "e xiting "
p.4 .8-13 -Section 4.8.9 , para 2 , line 2: delete "under"
p.4 .8-14 -Section 4.8.10 , line 1: again , note potential for disconnect of project operations
beginning prior to cumulative improvements be installed
p.4 .8-15 -Next to last sentence on page suggests qualifying conclusion in this sentence by
stating enhanced jobs-housing balance may reduce VMT by some unquantifiable
amount
p.4 .8-18 -Tables 4 .8-2 and 4.8-3 ; there is some confusion because there is a Cumulative
2040 analysis under Table 4.8-2. Do the data in Table 4.8-3 eliminate the
cumulative impact finding in Table 4 .8-2 , or is it a different cumulative impact
finding? Seems like a discussion of this seeming disparity shou ld be provided or
referenced . After looking at the maps , did the document discuss the freeway
system effects and if so , where?
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Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-32
Comment Letter C
C-55
C-56
C-57
C-58
C-59
C-60
C-61
C-52
C-53
C-54
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Chapte r 5
p.5-4
p .5-1 8
p.5-24
Cha pter6
p.6-5
p .6-8
p.6-10
p.6-11
p.6-13
-Para 3 , bottom sentence : There has been no substant ia t ion to support the
conclus ion that most new employees at The Landing already live in the project
area . Cons ide r provi ding substantiation for this concl usion or reassess the issue .
-First para , last sentence: was the updated Phase 1 prepared? Didn 't see a
reference to th is report .
-Bottom para : The County Fire HMO handles business plans and hazardous
material issues , not County EHS .
-Threshold e : Does the draft WQMP include sampling runoff discharged to the
A irport runoff system to ensure it does not violate discharge requirements of the
A irport 's industrial permit? Please clarify as sampling should be included to protect
the Airport and the owner. Are proper on-site stormwater monitoring po ints
included in desion of the orooosed oroiect?
-Para 1: Who determines infeasibi lity to construct and operate?
-A lternative sites: ignores SBMI property across 3rd as an alternative
-Hydro: discussion conveniently did not discuss Dam failure hazard
- A ir Quality: througho ut the DE IR, the document claims that there is not additional
feasible mitigation to reduce NOx emissions . In fact, there are several measures ,
such as: solar systems to reduce energy consumption and electrica l vehicle at a
certa i n percentage of all vehicles to further red uce NOx . The EIR does not
address feasibility related to this issue , and should .
-Greenhouse Gas: Solar and electrical vehicles are likely feas ible mitigation
measures to substantially reduce GHG emissions .
-Transportation : I believe the term "Vehic le Miles Traveled " is already plural , so the
acronym should be "VMT' not "VMTs"
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Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-33
RESPONSES TO COMMENT LETTER C
C-1 The commenter identifies themselves as a Responsible Agency under CEQA. The City acknowledges
that the San Bernardino International Airport Authority (SBIAA) is a Responsible Agency for the
proposed Project, and appreciates the SBIAA’s comments on the DEIR. Please refer to the individual
responses to the comments raised in the attachment to this comment letter.
C-2 The commenter points out a typographical error. This minor text revision has been incorporated into
the FEIR, as indicated in Table F-2.
C-3 The commenter points out a typographical error. This minor text revision has been incorporated into
the FEIR, as indicated in Table F-2.
C-4 The commenter asks where the DEIR technical appendices are found. No revision is needed pursuant
to this comment. The location where the DEIR and technical appendices are available for review is
included in the last paragraph on DEIR Page 1-12.
C-5 The commenter clarifies the acreage of the proposed Airport Gateway Specific Plan. The description
of the size of the Airport Gateway Specific Plan (AGSP) has been corrected in the FEIR on Page 2-1.
C-6 The commenter points out a typographical error. The reference to the City Creek Bypass has been
corrected in the FEIR on Page 2-1.
C-7 The commenter asks for clarification of the red lines on DEIR Figure 2-3. No revision has been made
to Figure 2-3. Figure 2-3 depicts the Project’s location on the USGS Topographic Map. Areas outlined
in red on Figure 2-3 are labeled on the USGS map as “US Mil Res” which refers to United States
Military Reserves.
C-8 The commenter asks about the purpose of the proposed driveway in the eastern portion of the
Development Site. The driveway proposed paralleling the eastern boundary of the Development Site
is for SBIA use and access only. The road is intended to be used and maintained by SBIA-authorized
personnel only. Security of the road will be provided by a remote access key pad and electric gate
operator. As part of the proposed Project, access will be provided from this road to W Street across
SBIA property as shown in the Project’s application materials and on DEIR Figure 3-11.
C-9 The commenter asks for clarification regarding the amount of demolition debris. No revision is
required pursuant to this comment. As indicated on DEIR Page 3-5, demolition of the existing water
tower would result in 300 tons of demolished concrete footing material while the physical building
construction activities associated with the relocated or replaced water tower would result in 100 tons
of demolished material.
C-10 The commenter recommends securing the easterly proposed driveway. Refer to Response C-7. No
changes to the SBIA property line are proposed in the southwest corner of the Development Site. W
Street will be maintained on the western side of the Development Site to ensure continued access to
the businesses on leased airport land located on the southern side of W Street.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-34
C-11 The commenter asks for the SBIAA to be named on DEIR Table 3-3. Table 3-3 has been revised in
the FEIR to indicate that the SBIAA would be responsible for approving utility service and connection
agreements, and would be responsible for approving airport-related street improvement permits. The
City acknowledges that fair share fee payments made by the Applicant for improvements to airport-
owned roads would be paid to the SBIAA.
C-12 The commenter states that O3 is not directly emitted. The text on DEIR Page 4.1-5 has been corrected
so as not to imply that O3 is a directly emitted pollutant.
C-13 The commenter points out a typographical error. The text has been revised accordingly on DEIR Page
4.1-10, as summarized in Table F-2.
C-14 The commenter requests a numerical correction. The text under the analysis of Consistency Criterion
No. 2 has been revised in the FEIR to disclose the increase in building area for “Industrial Light (IL)”
land uses.
C-15 The commenter questions the DEIR’s air quality cumulative impact analysis. The City disagrees with
the commenter’s assertion that the conclusion of cumulative significance is not substantiated. As
indicated in the Project’s Health Risk Assessment (“HRA”; EIR Technical Appendix B2):
The AQMD has published a report on how to address cumulative impacts from air pollution: White
Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution. In this
report the AQMD states (Page D-3):
“…the AQMD uses the same significance thresholds for project specific and cumulative
impacts for all environmental topics analyzed in an Environmental Assessment or EIR. The
only case where the significance thresholds for project specific and cumulative impacts differ
is the Hazard Index (HI) significance threshold for toxic air contaminant (TAC) emissions. The
project specific (project increment) significance threshold is HI > 1.0 while the cumulative
(facility-wide) is HI > 3.0. It should be noted that the HI is only one of three TAC emission
significance thresholds considered (when applicable) in a CEQA analysis. The other two are
the maximum individual cancer risk (MICR) and the cancer burden, both of which use the same
significance thresholds (MICR of 10 in 1 million and cancer burden of 0.5) for project specific
and cumulative impacts.
Projects that exceed the project-specific significance thresholds are considered by the
SCAQMD to be cumulatively considerable. This is the reason project-specific and cumulative
significance thresholds are the same. Conversely, projects that do not exceed the project-
specific thresholds are generally not considered to be cumulatively significant.”
The analysis presented for the Project’s Operational Health Risk Assessment demonstrates that the
maximum incremental cancer risk attributable to the DPM emissions from Project-related trucks
traveling to/from the Development Site is calculated to be 7.04 in one million, which would not exceed
the SCAQMD cancer risk threshold of 10 in one million for a project. The DEIR also discloses that
the non-cancer health risk index would be 0.003, which would not exceed the SCAQMD non-cancer
health risk index threshold of 1.0 for a project. Therefore, because the Project would not exceed the
applicable thresholds, and based on SCAQMD guidance, the Project’s cancer and non-cancer risks
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would be less-than-cumulatively considerable. No revisions to the DEIR are warranted pursuant to
this comment.
C-16 The commenter asks if evaluation of school site health risks was based on the Project’s on-site
operational activities or off-site traffic distribution. The modeling used to estimate cancer and non-
cancer risks at the nearest school accounts for Project-related truck traffic along roadway segments in
the Project vicinity. As explained in subsection 2.2.1 of the Project’s HRA (EIR Technical Appendix
B2) and depicted on Exhibit 2-A of the Project’s HRA, roadways that would accommodate substantial
Project-related truck traffic were modeled as line sources, and the “…DPM emission rate for each
volume source was calculated by multiplying the emission factor (based on the average travel speed
along the roadway) by the number of trips and the distance traveled along each roadway segment and
dividing the result by the number of volume sources along that roadway…” (HRA at Page 11). No
revision to the DEIR is warranted pursuant to this comment.
C-17 The commenter questions the DEIR’s air quality cumulative impact analysis. Please refer to the
response to Comment C-15. As indicated, the SCAQMD thresholds of significance are used to
determine both Project-specific and cumulatively-considerable health risk impacts. Because the
Project would not exceed the SCAQMD cancer risk threshold of 10 in one million or the SCAQMD
non-cancer health risk index threshold of 1.0, the Project’s health risk impacts would be less than
significant on both a direct and cumulatively-considerable basis. Accordingly, no revisions to the
DEIR are warranted pursuant to this comment.
C-18 The commenter asks about alternative energy sources for on-site operations related to Mitigation
Measure MM 4.1-7. No revision to Mitigation Measure MM 4.1-7 is warranted pursuant to this
comment. The mitigation specifies that all indoor and outdoor forklifts and all outdoor cargo-handling
equipment shall be electric or non-diesel fueled. Use of hydrogen fueling would be allowed under
Mitigation Measure MM 4.1-7 as a “non-diesel” fuel.
C-19 The commenter asks if the Project can incorporate a solar facility and accommodates for EV truck
charging. Refer to Mitigation Measure MM 4.4-1(d) which requires that the building’s roof be
designed and constructed to accommodate the potential future construction of photovoltaic (PV) solar
arrays. In response to this comment, Mitigation Measure 4.4-1(d) has been expanded in the Final EIR
to include the following. The City is not requiring more than a 24 KV system as part of the shell
building for an indeterminate tenant because committing to a system too early and then needing to
retrofit it to meet building user specifications is technologically and cost prohibitive.
MM 4.4-1(d): As part of shell building permit issuance, and subject to the approval of the Federal
Aviation Administration for the installation of rooftop solar panels near an airport, the
applicant shall be required to install a rooftop photovoltaic system providing a
minimum of 24,000 watts (24 KW) of power per year….
In addition, Mitigation Measure MM 4.4-1(e) requires that the building’s electrical room be
sufficiently sized to hold additional panels that may be needed in the future to supply power for the
future installation of EV truck charging stations on the site. The Project’s design includes a truck
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Page F-36
staging area in the southwest portion of the property, where EV charging stations for trucks are planned
to be accommodated.
C-20 The commenter notes that the Project site is not located near any wildlife corridors. Additional text
has been added to DEIR Page 4.2-4 to further substantiate that the Project Site does not serve as a
component of any wildlife linkages or corridors.
C-21 The commenter asks why DEIR Table 4.4-5 uses the term “no conflict” instead of “consistent”. As
indicated in DEIR Subsection 4.4.3, the applicable threshold of significance pursuant to Appendix G
to the CEQA Guidelines is whether a project would “conflict with an applicable plan, policy, or
regulation adopted for the purpose of reducing the emissions of greenhouse gases.” EIR Table 4.4-5
demonstrates that the Project would not conflict with any components of the Scoping Plan.
Furthermore, a number of the Scoping Plan measures are not applicable at the project level, as indicated
in Table 4.4-5. Because the analysis in Table 4.4-5 addresses the threshold question included in
Appendix G to the CEQA Guidelines, no revisions are warranted pursuant to this comment.
C-22 The commenter points out a typographical error. The text on Page 4.5-2 has been modified to clarify
that the Santa Ana River flows for over 100 miles, and that the total length of the Santa Ana River and
its major tributaries is approximately 700 miles.
C-23 The commenter points out a typographical error. The text on Page 4.5-7 has been revised to change
“floor” to “flood.”
C-24 The commenter asks for clarification about the potential for hazardous solid, liquid or gas storage.
While the building is a speculative development and the building’s occupant/tenant is undetermined at
this time, the building owner can and typically does impose restrictions on what types and quantities
of hazardous materials may be stored/used, as well as the manner in which they are stored. This is
routinely done as part of lease agreement language that incorporates references to current legal statutes
requiring the proper storage of hazardous materials as well as response actions in the event of an
inadvertent release. Additionally, a Hazardous Materials Management Plan (HMMP, aka; a "Business
Plan") must be prepared pursuant to State requirements with oversight by the County Fire Department.
The Hazardous Materials Division of the San Bernardino County Fire Department is designated by the
State Secretary for Environmental Protection as the Certified Unified Program Agency or "CUPA" for
the County of San Bernardino. The requirement to prepare and adhere to a HMMP is applicable to
the storage of more than 55-gallons of liquid hazardous material, 200 cubic feet of gas, or 500-pounds
of solid material, which must be detailed in the HMMP, with the HMMP updated at least annually (or
more frequently in the event of a change in quantity) and submitted to the County Fire Department. If
a HMMP is required, the HMMP details the types and quantities of materials and where they are stored
on the property. With the mandated preparation of a HMMP with oversight by the San Bernardino
County Fire Department for the storage of more than 55-gallons of liquid hazardous material, 200
cubic feet of gas, or 500-pounds of solid material, potential impacts would be less than significant
through regulatory compliance.
C-25 The commenter points out an acreage correction and a typographical error. The acreage of the Airport
Gateway Specific Plan (AGSP) and the reference to the City Creek Bypass has been corrected have
been corrected on DEIR Page 4.6-2.
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Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-37
C-26 The commenter points out an acreage correction. The text has been revised to refer to the portion of
the AGSP within the limits of the City of San Bernardino as +/- 194 acres.
C-27 The commenter asks for additional details about the 5th Street improvement project. No revision is
warranted pursuant to this comment, as the specific location and partners in the 5th Street Improvements
are not relevant to the Project’s potential impacts to land use and planning.
C-28 The commenter asks for a minor wording change. Text on DEIR Page 4.6-4 has been revised to change
the word “mode” to “component.”
C-29 The commenter points out a typographical error and asks that an analysis conclusion be repeated. The
text on DEIR Page 4.6-4 has been revised to correctly refer to EIR Subsection 4.6. The conclusion
regarding consistency with the SCAQMD’s AQMP is provided in EIR Subsection 4.1, Air Quality,
and does not require repetition in Subsection 4.6. Nonetheless, DEIR Page 4.6-4 has been revised to
reference the conclusion reached in Subsection 4.1.
C-30 The commenter asks for clarification of the General Plan consistency conclusion. The text on DEIR
Page 4.6-4 has been revised to include a reference to the conclusion reached in EIR Subsection 4.1 that
the Project would result in significant and unavoidable impacts to air quality. As with potential noise
impacts, because impacts to air quality were fully disclosed in EIR Subsection 4.1, no additional
impacts due to General Plan policy consistency related to air quality are identified in EIR Subsection
4.6. As stated on DEIR Page 4.6-8, there are no significant environmental impacts that would result
as a specific consequence of the proposed changes to the Project Site’s General Plan land use
designation. The Project entails changing the land use designation of 4.97 acres from Industrial Light
(IL) to Public Facility/Quasi-Public (PF) and changing the land use designation of 12.89 acres from
PF to IL. The net result is a change of 7.92 acres from PF to IL, whereas the significant environmental
impacts disclosed in the DEIR would result from the development of a proposed industrial warehouse
building on a larger 52.97-acre area.
C-31 The commenter asks where records can be found confirming that the City has reviewed the Project for
consistency with the City’s Municipal Code. The text on DEIR Pages 4.6-9 and 4.6-10 has been
revised to indicate where the public may view City departmental comments on the Project’s application
materials, and the Project Applicant’s responses thereto.
C-32 The commenter asks for a specific clarification regarding consistency with the Southern California
Association of Governments (SCAG’s) 2020-2045 Regional Transportation Plan/Sustainable
Communities Strategy (“RTP/SCS”; hereafter, “Connect SoCal”). The text on DEIR Page 4.6-10 has
been modified to clarify that because the Project would entail the development of a light industrial
warehouse building within an area that is already developed with similar uses, the Project would be
consistent with the Connect SoCal provisions related to land use integration. The text also was
modified to correctly refer to the threshold of significance used for the analysis of impacts due to
greenhouse gas (GHG) emissions in DEIR Subsection 4.4. Text also was added to clarify the Project’s
GHG impacts are fully disclosed in DEIR Subsection 4.4.
C-33 The commenter questions the Project’s consistency with SCAG’s Connect SoCal goal related to the
reduction of GHG emissions and the improvement of air quality. This goal does not preclude
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Page F-38
development projects, such as the proposed Project, that may have significant and unavoidable impacts
under CEQA. Rather, the Connect SoCal strategies for reducing regional GHG and air quality
emissions rely on compact development patterns and investments in transportation facilities throughout
the SCAG region. The Project would be consistent with the Connect SoCal strategies for compact land
use patterns through the development of warehouse uses in an area with similar uses and with direct
access to the San Bernardino International Airport. Furthermore, and as noted in EIR Table 4.6-1, the
Project incorporates mitigation measures to reduce air quality impacts and GHG emissions to the
maximum feasible extent. Although the Project would result in significant and unavoidable impacts
to air quality and due to GHG emissions, as fully disclosed in EIR Subsections 4.1, Air Quality, and
4.4, Greenhouse Gas Emissions, there are no components of the proposed Project that would result in
a conflict with the Connect SoCal goals or strategies related to air quality and GHG emissions. A
revision has been made in DEIR Table 4.6-1 to the discussion of Goal 6 to reference the conclusion
reached in EIR Subsection 4.1 that the Project would not result in any localized air quality impacts
affecting sensitive receptors.
C-34 The commenter suggests that the conclusion made for cumulative land use and planning impact needs
more support. The City disagrees with the commenter’s assertion that the cumulative impact
conclusion is not well supported. The analysis of the Project’s cumulatively-considerable impacts to
land use and planning concludes that because the Project would result in less-than-significant impacts
due to a conflict with any land use plan, policy or regulation adopted for the purpose of avoiding or
mitigating an environmental effect, the Project also would not result in cumulatively-considerable
impacts due to such a conflict. There is no evidence in this comment letter or in the Project’s
administrative record demonstrating that the Project would have cumulatively-considerable impacts
due to a conflict with any land use plan, policy or regulation adopted for the purpose of avoiding or
mitigating an environmental effect. Accordingly, no revision to the DEIR is warranted pursuant to this
comment.
C-35 The commenter suggests that more support be provided to conclude that the Project’s construction will
be consistent with the City’s Noise Ordinance. DEIR Subsection 4.7.4 presents the thresholds of
significance used to evaluate potential construction-related noise impacts, which are summarized in
DEIR Table 4.7-6, Significance Criteria Summary. As indicated, the City’s Noise Ordinance
establishes hours of the day (between 7:00 a.m. and 8:00 p.m.) during which construction-related noise
is considered exempt from restrictions. Because the City’s Noise Ordinance does not establish a
numerical level at which construction noise during daytime hours would be considered significant, a
threshold of significance of 80 dBA Leq was established for analysis in the DEIR, based on the Federal
Transit Administration (FTA) Transit Noise and Vibration Impact Assessment Manual (2018).
Impacts were found to be less than significant. As such, Project-related construction activities would
not conflict with the City’s Noise Ordinance, and no revisions to the DEIR are warranted pursuant to
this comment.
C-36 The commenter points out a typographical error. The discussion on DEIR Page 4.7-29 has been revised
to state “segments are” instead of “segment is.”
C-37 The commenter points out a typographical error. The reference to “vibration” has been changed to
“vibrations” on DEIR Page 4.7-31.
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Page F-39
C-38 The commenter suggests that more support be provided for the assumed distribution of Project-related
truck traffic and for vibration analysis. All roadways that would accommodate Project-related truck
traffic consist of paved roadways that are regularly maintained by the City of San Bernardino and/or
the City of Highland. None of the roadways that are assumed to accommodate Project-related truck
traffic exhibit frequent potholes in the road or other physical deterrents to truck travel. Also, designated
truck routes were considered in the directional distribution assumptions. The analysis presented at the
bottom of DEIR Page 4.7-31 relies upon the FTA Transit Noise and Vibration Impact Assessment
Manual (2018), which indicates that rubber-tired traffic is rarely perceptible on smooth roadways, and
would not create vibration that exceeds 70 VdB; thus, Project-related truck traffic would not exceed
the identified vibration significance criteria of 78 VdB for daytime hours or 72 VdB for nighttime
hours. Therefore, the City finds that there is substantial evidence presented in the DEIR demonstrating
that vibration effects associated with Project truck traffic would be less than significant. No revisions
to the DEIR are warranted pursuant to this comment.
C-39 The commenter supplies information about the Eastgate Building 1 project to the west, which was
considered in the DEIR’s cumulative impact assessments. This comment provides additional support
to the DEIR’s conclusion that cumulatively-considerable construction-related noise impacts would be
less than significant. While it is acknowledged that most construction activities at the Eastgate
Building 1 project are complete, the analysis nonetheless demonstrates that in the unlikely event
construction activities would overlap, the resulting noise levels experienced at nearby sensitive
receptors would be below the identified thresholds of significance. Further, and as noted by this
comment, there is no potential that the AGSP project would be under construction at the same time as
the proposed Project, particularly in consideration of the fact that the AGSP project is not yet approved
and the NOP for the AGSP EIR is not yet released for public review. Furthermore, for the warehouse
projects referenced in the latter part of this comment, construction activities have been completed; thus,
these developments would not be under construction at the same time as the proposed Project, and
there is no potential for cumulatively-considerable noise impacts associated with these developments.
Accordingly, no revision to the DEIR is warranted pursuant to this comment.
C-40 The commenter points out a typographical error. The term “with” has been deleted on DEIR Page 4.8-
6.
C-41 The commenter asks for clarification about transit classification locations. Revisions have been made
on DEIR Page 4.8-6 to explain why the bus routes in the local area do not meet the definitions for a
“major transit stop” or “high-quality transit corridor.”
C-42 The commenter points out a typographical error. The term “identifies” has been changed to “identify”
on DEIR Page 4.8-7.
C-43 The commenter refers to Comments C-25 through C-34. Please refer to the responses to Comments
C-25 through C-34, above. No revisions to the DEIR are warranted pursuant to this comment.
C-44 The commenter suggests that the City may have erred in determining that the use of DIF fees will
mitigate roadway level of service (LOS) deficiencies. The City disagrees with the commenter’s
assertion that the Project would result in significant near-term impacts to transportation due to the
timing of identified improvements funded by DIF fees. The Project Applicant would be conditioned
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Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-40
to pay DIF fees and fair-share fees to address the Project’s contribution to Level of Service (LOS)
deficiencies, in conformance with City requirements. The improvements identified in EIR Subsection
4.18 would achieve an acceptable LOS in conformance with the LOS standards identified by the City’s
General Plan. The commenter is correct that certain needed transportation improvements may not be
in place at the time of Project occupancy, and that certain study area facilities may not achieve the
desired LOS as identified by the City’s General Plan in the near term. However, pursuant to Senate
Bill 743 and CEQA Guidelines Section 15064.3(a), “…a project’s effect on automobile delay [i.e.,
LOS] shall not constitute a significant environmental impact.” Therefore, any near-term LOS
deficiencies at study area intersections would not represent a significant impact under CEQA, including
any deficiencies that may result from the delayed implementation of needed improvements.
Furthermore, the timing of required improvements to the transportation network would be determined
by City of San Bernardino and/or City of Highland staff, and is not within the control of the Project
Applicant. Further, any delay in implementation of required transportation improvements would not
be caused by Project implementation, as the Project Applicant would contribute fair-share and DIF
fees toward the cost of required improvements. Accordingly, no revisions to the DEIR are warranted
pursuant to this comment.
C-45 The commenter points out a typographical error. The text on DEIR Page 4.8-11 has been revised as
requested by this comment.
C-46 The commenter asks about capacity of the Project’s proposed truck staging area. The text on DEIR
Page 4.8-12 has been modified to more clearly explain that parking areas in the southwestern portion
of the Development Site would serve as a truck staging area that would preclude the need for trucks to
queue on public streets.
C-47 The commenter points out a typographical error. The term “existing” has been changed to “exiting”
on DEIR Page 4.8-13.
C-48 The commenter points out a typographical error. The term “under” has been deleted under subsection
4.8.9 on DEIR Page 4.8-13.
C-49 The commenter repeats Comment C-44. Please refer to the response to Comment C-44, above. As
indicated, pursuant to Senate Bill 743 and CEQA Guidelines Section 15064.3(a), deficient LOS is not
considered a significant environmental impact under CEQA. Because the Project would contribute
DIF fees and fair share contributions for improvements that would achieve an acceptable LOS at study
area facilities, the Project would not conflict with General Plan policies related to LOS, and therefore
Project impacts would be less than significant on both a direct and cumulatively-considerable basis.
No revisions are warranted pursuant to this comment.
C-50 The commenter suggests that the Project would achieve some amount of VMT reduction by approving
the local jobs to housing balance. The text on EIR Page 4.8-16 has been supplemented with an
explanation that although the Project would improve the local jobs-housing balance, the reduction in
VMT associated with expanded employment opportunities on site cannot be quantified.
C-51 The commenter asks for clarification of the cumulative impact conclusion for VMT impacts, and also
asks if the freeway system was analyzed. The freeway system level of service was not analyzed
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Page F-41
because the Project would contribute fewer than 50 peak hour trips to State Highway System facilities,
and the significance analysis methodology is based on VMT. Pertaining to VMT, please refer to DEIR
Subsection 4.8.4 which explains the City’s methodology for calculating VMT impacts. As explained
therein, the City uses two measures for evaluating the significance of impacts due to VMT. The first
is an assessment of VMT that would be generated by a development project, and the second is an
assessment of a project’s effect on VMT within the City. The data presented in DEIR Table 4.8-2
provides an assessment of Project-generated VMT and discloses the Project-generated VMT per
service population (i.e., Project-related employees). Per the City Guidelines for VMT, the Project’s
ratio of VMT per service population must be conducted for both the baseline year and for General Plan
Buildout, and then compared to the estimated VMT per service population that would result from
buildout of the City’s General Plan. Under the City’s methodology, VMT impacts would be significant
if a project’s VMT per service population were to exceed the City of San Bernardino General Plan
buildout VMT per service population. As indicated in Table 4.8-2, the Project would exceed the
General Plan buildout VMT per service population under both the Baseline (2020) and Cumulative
(2040) scenarios, thereby resulting in a significant impact. The data presented in DEIR Table 4.8-3
shows the Project’s net effect on VMT per service population within the City of San Bernardino.
Whereas the data presented in Table 4.8-2 discloses the ratio of Project-related VMT to the Project’s
service population, the data in Table 4.8-3 discloses the ratio of total VMT within the City to the City-
wide service population (i.e., residents and employees). As shown in Table 4.8-3, the Project and other
cumulative developments would result in a net reduction in the ratio of Citywide VMT per service
population, which pursuant to the City Guidelines represents a less-than-significant impact. However,
because the Project-generated VMT assessment (DEIR Table 4.8-2) shows that the Project’s VMT per
service population would exceed the City’s threshold of significance, impacts due to VMT are
disclosed as a significant impact. No revision to the DEIR is warranted pursuant to this comment.
C-52 The commenter asks for substantiation of the DEIR’s statement that the Project’s employees will live
in the local area. The text on DEIR Page 5-4 has been revised to provide additional discussion to
support the EIR’s determination that a majority of Project-generated jobs would be filled by existing
or future residents of the local area. Specifically, the City supplies a relatively high number of housing
units when compared to the number of jobs provided in the City. Thus, it can be concluded that there
is a sufficient local labor pool from which Project-generated employment opportunities can be filled.
In addition, as of November 2020, the unemployment rate in the Riverside-San Bernardino region is
7.9 percent as reported by the U.S. Bureau of Statistics 2 and in the City of Highland is 13.4 percent.
Due to the size of the local labor pool and the local unemployment rates, Project-generated jobs likely
would be filled by existing or planned residents, and therefore the Project is unlikely to result in
substantial growth in the area.
C-53 The commenter asks if an updated Phase I Environmental Site Assessment (ESA) was prepared for the
Development Site. The text on DEIR Page 5-18 has been revised to incorporate the findings of the
Project’s updated Phase I ESA, which was appended as DEIR Technical Appendix H. As noted in the
2 U.S. Bureau of Labor Statistics, November 2020 Unemployment Rate for Riverside-San Bernardino-Ontario CA found at
https://www.bls.gov/eag/eag.ca_riverside_msa.htm.
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revisions, the updated Phase I ESA demonstrates that the Development Site does not contain any
Recognized Environmental Conditions (RECs), consistent with the findings of the 2004 Phase I ESA
report.
C-54 The commenter clarifies the authoritative agency for HMMPs. The text on DEIR Page 5-18 has been
corrected to identify the Hazardous Materials Division of the San Bernardino County Fire Department
as the regulating agency for hazardous materials within the City.
C-55 The commenter asks if water discharge sampling will be conducted for water discharged to the
SBIAA’s runoff system. Sampling is not required at this phase of the entitlement process because the
Development Site does not directly drain to a water of the United States.3 Pursuant to the Project’s
WQMP included as DEIR Technical Appendix I1, all of the Development Site’s runoff will be treated
on-site prior to discharge. Sampling will occur as part of the construction permit’s Stormwater
Pollution Prevention Plan (SWPPP), which is required by City of San Bernardino Municipal Code
Chapter 8.80 (Storm Water Drainage System), discussed on DEIR Pages 5-16, 5-21, and 5-22.
C-56 The commenter asks for clarification about the decision-making process for alternative feasibility. The
text on DEIR Pages 6-4 and 6-5 has been modified to indicate that the City evaluated the feasibility of
alternatives as part of the DEIR’s deliberative preparation process. The text also was revised to explain
the reasons why alternatives to the proposed Project may be infeasible to construct or operate.
C-57 The commenter asks if property owned by the Project Applicant north of 3rd Street was considered as
an alternative site for the proposed Project. As indicated in DEIR Subsection 6.2, alternatives were
rejected from consideration if they could not achieve the Project’s objectives, would not have resulted
in a reduction of significant adverse environmental impacts, or if the alternative was determined to be
infeasible. While it is correct that the Project Applicant owns property north of 3rd Street, the sizes of
such properties are too small (about half as small) to accommodate the proposed Project. Also, many
of those properties are designated and zoned for residential use and could not accommodate the
proposed Project absent legislative actions to change the land use and zoning designations to industrial
designations and replace the reduction in planned residential housing units pursuant to SB 330, the
Housing Crisis Act of 2019. In addition, development of the proposed Project on an alternative site
north of 3rd Street would not reduce the Project’s adverse environmental effects. The development
would still generate traffic and vehicle miles traveled, would still generate air quality pollutant
emissions and greenhouse gas emissions, and would still generate traffic noise, regardless if the
building were located in its currently proposed location south of 3rd Street or in another nearby location
north of 3rd Street. As explained in DEIR Subsection 6.2.1, development of the Project at an alternative
location would not reduce the Project’s significant and unavoidable impacts to air quality, due to
greenhouse gas emissions, due to Project-related traffic noise, or due to VMT. No revision to the DEIR
is warranted pursuant to this comment.
C-58 The commenter notes that the DEIR text did not address dam inundation hazards. Text has been added
on DEIR Page 6-8 to disclose that the No Development Alternative (NDA) would result in reduced
3 Communication from David Evans Associates to T&B Planning, Inc., via e-mail January 13, 2021.
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Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-43
impacts associated with inundation due to potential failure of the Seven Oaks Dam, because no
development would be located on the Development Site that could be affected by inundation.
C-59 The commenter suggests that additional feasible mitigation is available to address NOx emissions,
generally mentioning the use of solar systems and electric powered vehicles (EV). Both of these
measures are already included in the DEIR. Refer to Mitigation Measure MM 4.4-1(d) and the addition
thereto presented in Response C-19, which requires that the shell building include a PV system
providing a minimum of 24 KW of power per year, and that the remainder of the building’s roof be
designed and constructed to accommodate the potential future construction of photovoltaic (PV) solar
arrays. In addition, Mitigation Measure MM 4.4-1(e) requires that the building’s electrical room be
sufficiently sized to hold additional panels that may be needed in the future to supply power for the
future installation of EV truck charging stations on the site. The Project’s design includes a truck
staging area in the southwest portion of the property, where EV charging stations for trucks are planned
to be accommodated. Additionally, the Project is required to comply with the California Green
Building Standards Code (CALGreen), which requires that a certain number of EV charging stations
for passenger vehicles be installed.
C-60 The commenter suggests that additional feasible mitigation is available to address GHG emissions,
generally mentioning the use of solar systems, purchase of offsets, and uses of electric powered
vehicles (EV). Solar and EV accommodations are already addressed in the DEIR. Refer to Mitigation
Measure MM 4.4-1(d), which requires that the building’s roof be designed and constructed to
accommodate the potential future construction of photovoltaic (PV) solar arrays, and the addition to
MM 4.4-1(d) described in Response C-19, above. In addition, Mitigation Measure MM 4.4-1(e)
requires that the building’s electrical room be sufficiently sized to hold additional panels that may be
needed in the future to supply power for the future installation of EV truck charging stations on the
site. The Project’s design includes a truck staging area in the southwest portion of the property, where
EV charging stations for trucks are planned to be accommodated. Additionally, the Project is required
to comply with the California Green Building Standards Code (CALGreen), which requires that a
certain number of EV charging stations for passenger vehicles be installed.
C-61 The commenter points out a typographical error. The DEIR has been corrected throughout to use the
term “VMT” in lieu of “VMTs.”
Page F-44
C omment Letter D
D-1
D-2
•• ••
The Landing by San Manuel
Final Environmental Impact Report
~ INLAND EMPIRE Y BIKING ALLIANCE
29 November 2020
Elizabeth Mora-Rodriguez
City of San Bernardino, Planning Division
290 North D Street
San Bernardino, CA 92401
Re : The Landing by San Manual Draft Environmental Impact Report SCH No. 20200100067
Dear Elizabeth,
I am writing on behalf of the Inland Empire Biking Alliance , a local nonprofit dedicated to ensuring
that cycling is an accessible activity for people from all rolls of life . This letter is in response to the
Draft Environmental Impact Report ("DEIR") which has been prepared for the The Landing by San
Manuel project ("Project") that is available for public review and comment. After a close inspection
of the documents, we are providing the following comments in response to the DEIR.
By farour biggest concern remains the provision of the City Creek Trail ("Trail ") which is planned to
run alon g the drainage channel which fronts the Project site along grd Street and then crosses to the
north side approximately 600 feet east of the intersection with Victoria A venue . In our previous
comment letter dated October 6, 2020, we provided the evidence that the Trail has been en visioned
on planning documents for the C ity of San Bernardino, the San Bernardino County Transportation
Authority, and the City of Highland for more than a decade. While the Traffic Analysis ("TIA ")
prepared by Urban Crossroads and dated November 4 ,202 does now at least acknowledge the
existence of this prior planning which had been overlooked in the Traffic Analysis which was
prepared for the Initial Study for the Project , we maintain th,at the provided remedies and mitigations
do not adequately address the issue of the Project cutting off the location for the Trail as is mapped
on those documents.
In section 4.8.8 Impact Analysis of the DEIR, it states that "[n]ear the Victoria Avenue and 3rd Street
intersection , the planned trail is designed to cross to the north side of 3rd Street north of the
Development Site. Other than at the 3rd Street and Victoria Avenue intersection where the planned
crossing is to occur, and where the Project Applicant plans to enhance the pavement markings to
denote the bike crossing , the planned City Creek Trail is not planned to occur within or abut the
Development Site boundaries." However, this statement cannot possibly be true for a number of
reasons .
First , while no project-level planning has been done for the Trail , it is evident from both the maps
provided by the cities and SBCT A as well as the physical realities of the existing conditions that the
intended and most logical path would be for the Trail to cross 3 rd Street at the same location as the
P.O. BOX 9266 Redlands, CA 92375 www.iebike.org 909.800.4322
Final EIR
Lead Agenc y : C ity o f San Be rn ardino SCH No . 202010006 7
Page F-45
C omment Letter D
D-3
D-4
D-5
D-2(cont)
•• ••
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Final Environmental Impact Report
~ INLAND EMPIRE Y BIKING ALLIANCE
City Creek itself which is located approximately 600 feet east of the intersection of 3 rd Street and
Victoria Avenue and continue on the path the Creek travels . If the Trail were to follow the City Creek
as planned , it would obviously abut the Project site along 3rd Street to that location because that is
precisely what the City Creek does, in direct contradiction to what is asserted in the DEIR.
Additionally, a site visit to the area on December 12 , 2020 confirmed that there are currently a
number of structures located on the north side of3 rd Street east of Victoria Avenue which constrains
the ability for the Trail to be placed on the north side of 3rd Street , yet no additional information is
provided about how that oversight would be remedied. It also again begs the question of why the
Trail would be shifted to the north side of 3rd Street which is not where the City Creek is given that
doing so would present significant hurdles to completion via a need to potentially remove structures
and/or present many more driveway conflicts.
Thus , we strongly dispute the assertion that the impacts to the Trail by the Project would be "less than
significant" as the DEIR currently states. In fact , the Project as currently planned woul d present a
significant impact to the Trail by causing it to be broken without adequate connection from the
intersection of 3rd Street and Victoria A venue to what should be the future intersection of 3 rd Street
and the Trail . This is in direct violation of Policies 8.3 .1, 8.3.2, 8.3 .3, 8.3.4, 8 .3.9, 8.3 .11 , and 8.4.4 of
City of San Bernardino General Plan which together make it clear that it is the intention of the City
that the trail network and facilities be constructed as part of other ongoing development when that
occurs .
Additionally, the DEIR presents MM 4.8-2 which states that "[a]s part of street improvement plans
for the 3rd Street and Victoria Avenue intersection and with concurrence of the City of Highland , the
developer to enhance the intersection pavement markings to demark bike lane crossings across 3rd
Street at the intersection" (p. 4.8-15), but this does precisely nothing to connect the Trail from the
point where the City Creek meets 3rd Street to the intersection with Victoria Avenue. While it is true
that sidewalks and Class II bike lanes currently exist in that area, neither of those meet the standards
for trails which are set forth by either the City of Highland or the City of San Bernardino. Thus , the
failure of providing an actual trail facility for the Trail is a significant impact that as currently
p lanned , remains unmitigated.
In section 6.5 Traffic Signal Warrant Analysis section of the TIA , it is stated that no additional
signals are warranted in the 2022 condition. However, as detailed above , the appropriate path for the
Trail to take is to follow the City Creek along 3rd Street from the intersection of Victoria Avenue to
where it crosses to the north side of3 rd Street . While trail crossings are sometimes considered to be
"mid block " locations and thus face a desire to shift them to be concurrent with existing intersections
(e .g. as MM 4 .8-2 proposes), the CA MUTCD standard only recommends that they be further than
300 feet from a nearby intersection. The location where the Trail would cross 3rd Street is located
approximately 600 feet from the intersection with Victoria A venue to the west.
P.O. BOX 9266 Redlands, CA 92375 www.iebike.org 909.800.4322
Final EIR
Lead Agency: C ity of San Bernardino SCH No . 2020100067
Page F-46
C omment Letter D
D-6
D-7
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Final Environmental Impact Report
~ INLAND EMPIRE Y BIKING ALLIANCE
Per the CA MUTCD Section 4C.05 Warrant 4, Pedestrian Volume , it is highly likel y that the point
where the Trail would cross 3'd Street would indeed meet the warrant for a full signal (which in
conjunction with bicycle signal faces , would be an ideal option for a trail crossing) based on Figure
4C-6. Warrant 4 , Pedestrian Four-Hour Volume (70% Factor) and would certainly meet the warrant
for a pedestrian hybrid beacon ("PHB ") per Section 4F.0l Application of Pedestrian Hybrid Beacons ,
Figure 4F-2. Guidelines for Installation of Pedestrian Hybrid Beacons on High-Speed Roadways.
(Based on the existing speed limit on 3'd Street as well as the forecast traffic counts shown in Exhibit
6-4: EAPC [2022] Traffic Volumes [In PCE], it is appropriate to use the 70% factor and high -speed
roadways warrants in this instance.) This is a vio lation of Policy 6.2 .7 of the City of San
Bernardino 's General Plan and an oversight which is in need of additional study to remedy.
The same oversight and violation of Policy 6:2.7 is repeated in section 7.5 Traffic Signal Warrant
Analysis where though the need for additional traffic signals is found to be warranted in the 2040
horizon yea r, the analysis fails to include the intersection of the Trail and 3rd Street for study.
Accordingly, this again needs to be planned for inclusion because as detailed in Ex hibit 7-4: Horizon
Year (2040) With Project Traffic Volumes (In PCE) the vo lume s forecast for 3rd Street clearly exceed
the same warrants from Figure 4C-6. Warrant 4 , Pedestrian Four-H our Volume (70% Factor) and
Figure 4F-2. Guidelines for Installation of Ped estrian Hybrid Beacons on High-Speed Roadways that
are already forecast to be met by the EAPC (2022) conditions.
In summary , though the DEI R ha s at least improved on the NOP and 1;1ow acknowledges the fact that
the Trail has been envisioned and planned for years, it does no t adequately miti gate the impacts
which the Project would have on its completion . We remain concerned that this Project will cause
irreparable harm to the Trail which will not only be a step backwards for bic yclists and other users,
but also hamper the ability forthe Project to achieve targets for VMT and GHG re duction s which
would be easier to accomplish with additional investment to create low-stress facilities linkin g the
Project with the region.
Sincerely,
Marven E . Norman , Exec utive Direct or
CC: CityofHighland ,City of San Bernardino , Assemblymember James Ramos , SenatorRosilicie
Ochoa Bogh
P.O. BOX 9266 Redlands, CA 92375 www.iebike.org 909.800.4322
Final EIR
Lead Agen c y : C ity of San Be rn ardino SCH No . 202010006 7
Page F-47
C omment Letter D
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The Landing by San Manuel
Final Environmental Impact Report
~ INLAND EMPIRE Y BIKING ALLIANCE
References
California Department of Transportation . (2017). Part 4: Highway Traffic Signals. In California
Manual on Uniform Traffic Control Devices (CAMUTCD). Retrieved online from
https://dot.ca.gov/-/media/dot-media/programs/safety-programs/documents/ca-mutcd /rev-
5/camutcd2014-part4-rev5 .pd f.
City of Highland. (2006). Chapter 5: Conservation and Open Space Element. In City of Highland
General Plan. Retrieved online from
https ://www .cityofhigh land. org/DocumentCenterN iew /148/Conservation -and-Open-Space-
Element-PDF.
City of San Bernardino. (2005). City of San Bernardino General Plan . Retrieved online from
http ://sbcity.org/civicax/filebank/blobd load .aspx?b lobid =26199.
City of San Bernardino. (2020). Draft Environmenta l Impact Report SCH No. 20200 I 0006 7: The
Landing by San Manue l. Retrieved on line from
http ://sbcity.org/civicax/filebank/blobdload.aspx?b lobid=29072.
Urban Crossroads fo r City of San Bernardino . (2020). The Landing by San Manue l Traffic Impact
Analysis. Retrieved online from
http ://www .s bcity .org/civicax/filebank/b lob d load .aspx?b lobid=29088 .
P.O. BOX 9266 Redlands, CA 92375 www.iebike.org 909.800.4322
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-48
RESPONSES TO COMMENT LETTER D
D-1 The commenter expresses concern about the planned alignment of the City Creek Trail bike crossing
of 3rd Street and suggests that the Project accommodate the crossing approximately 600 feet east of
the intersection of 3rd Street and Victoria Avenue.
The City Creek Trail is identified as a Class I bike trail in the San Bernardino County Active
Transportation Plan (2020) developed by the San Bernardino County Transportation Authority
(SBCTA) and in the City of Highland Active Transportation Plan (2020) which was published in
December 2020 after the DEIR was released for public review. In the vicinity of the Project Site, the
City Creek Class I Trail is planned to run in the southwesterly direction along the City Creek Drainage
Channel north of the Project Site, cross 3rd Street, and continue west along the south side of 3rd Street.
A general illustration was provided in Exhibit 3-6 of Project’s Traffic Impact Analysis (TIA) attached
as Technical Appendix K-2 to the DEIR. Class II bike lanes already exist on both sides of 3rd Street
along the Project Site frontage. The proposed Project includes the enhancement of pavement markings
for a bike crossing at the 3rd Street/Victoria Avenue intersection to assist in bicycle safety at the present
time, as the City Creek Trail is a planned trail and not an existing trail and implementation of the Trail
by the City of Highland is shown in the City of Highland’s Active Transportation Plan (2020) on Page
166, as having a priority score of 20 (out of 65) which indicates it is on the lowest tier of projects for
the City of Highland.
The City of San Bernardino expects that a technical alignment study will be prepared by the involved
agencies (such as the Cities of San Bernardino, Highland and SBCTA) as required to determine final
trail alignment, roadway crossing locations, merging locations with city streets and all traffic control
devices. The installation of pedestrian beacons or other traffic control devices at this time, when final
trail alignment or preferred crossing locations are not known, is not recommended without approved
technical studies by all responsible agencies. The author of the City of Highland’s Active
Transportation Plan was contacted and indicated that “while there are typically design guidelines for
trails, there needs to be additional planning, design, and engineering for any of the trails projects.”4
Regardless, the implementation of the proposed Project will not preclude the future installation of the
Class I trail segment planned on the south side of 3rd Street between Victoria Avenue and the location
of the City Creek Channel. As shown on the below exhibit, the Project’s design plans that would be
approved by the City of San Bernardino as part of the proposed Project allocate a 10-foot width of land
available for a trail along the south side of 3rd Street along the Development Site’s frontage between
Victoria Avenue and the City Creek Trail drainage channel. The Project Applicant is not proposing to
construct the trail segment or a mid-block crossing because at present time there has not yet been a
technical study prepared by the involved agencies as noted in the preceding paragraph.
4 E-mail communication from Samuel Zneimer, Senior Planner, Alta Planning+Design, to Tracy Zinn, Principal, T&B
Planning, dated January 20, 2021.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-49
Source: David Evans & Associates, 2021
For conceptual purposes only, the below exhibit shows how a 10-foot-wide trail could be positioned
between the back of the existing sidewalk and the Development Site, between the intersection of 3rd
Street and Victoria Avenue and the location of the existing drainage channel.
Source: David Evans & Associates, 2021
D-2 The commenter provides additional information advocating that the planned alignment of the City
Creek Trail bike crossing of 3rd Street is to be located approximately 600 feet east of the intersection
of 3rd Street and Victoria Avenue. As indicated in Response D-1 above, the proposed Project
accommodates area for a future trail will not preclude the future establishment of the trail or the
crossing.
D-3 The commenter opines that the Project’s impacts to the planned trail should be deemed a significant
impact. This topic of applicable circulation system plans is discussed in the DEIR under Subsection
4.8, Threshold a), but the planned City Creek Trail was not discussed because it is a planned trail by
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-50
the City of Highland and County of San Bernardino, whereas the Project Site is located in the City of
San Bernardino and subject to the City of San Bernardino’s General Plan, which is less specific on the
trail location. Nonetheless, as explained in Response D-1, the Project’s design makes spacing
accommodation for the future trail and will not preclude the establishment of the trail in its currently
planned location. As such, impacts are less than significant.
D-4 The commenter accurately notes that the proposed Project does not include provisions for a mid-block
crossing of 3rd Street by the City Creek Trail. As indicated in Response D-1 above, the proposed
Project will not preclude the future establishment of the trail or the crossing.
D-5 The commenter advocates for a planned bike crossing for the City Creek Trail across 3rd Street mid-
block approximately 600 feet west of the Victoria Avenue/3rd Street intersection. As indicated in
Response D-1 above, the proposed Project will not preclude the future establishment of the trail or the
crossing.
D-6 The commenter provides a closing comment that advocates for a planned bike crossing for the City
Creek Trail across 3rd Street mid-block approximately 600 feet west of the Victoria Avenue/3rd Street
intersection, with a traffic signal. As indicated in Response D-1 above, the proposed Project allocates
a 10-foot-wide area for the future implementation of the trail. As such, the Project will not preclude
the future establishment of the trail or the crossing and is consistent with, and not in conflict with, the
General Plan pertaining to the planned trail.
Page F-51
C omment Letter e
E-1
E-2
E-3
•• ••
The Landing by San Manuel
Final Environmental Impact Report
December 3 1, 2020
City of San Bernardino
Community & Economic Development
Plan n ing Div ision
290 North D St reet
San Bernardino, CA 92401
Via U.S . M ail and ema il to mora -rodriguez_e ls@sbc ity.o rg
Re: Comments o n The Landing by San Manue l EIR
Dea r City Planner:
COOL ---
WORLD --
INSTITUTE ---
Cool W orld In st itute, a project of Advocates for the Envi ro nme nt , subm its the
co mm e nts in this letter regarding the proposed Land ing by San Ma nuel Project (the
Project) and the Draft En vironmental Impact Repo rt t he City approved for this Project
(the EI R).
Cool W orld Institute is part of a no n-profit env ironme nta l law f irm and advocacy
organ iz ation w it h a focus on fighting cl imate change in Californ ia. Cool World Institute
submits t hese comments to public agencies in order to e ncou rage them to co nsider
climate-change effects throughout their work, reduce gree nh o use-gas emiss io ns in their
proj ects , and improve thei r own ana lyse s of g ree nh o us e-g as im p acts in C EQA
documents.
The Project wo uld redevelop a forme r A ir-Fo rce base into a major industria l center
within the City of Sa n Bernardino . It would involve the co nst ruction of a large warehouse
on t he site with approxima tely 218 load in g bays for large ind ust ria l trucks. Th e project
site occupies approximate ly 62.49 acres within t he City of San Be rn ardino.
Climate Change
Clim at e change is th e change in the average long-t erm weather con dit ions across
th e Earth. Wh ile t he Ea rth 's climate natural ly cha nges so mewhat over time, the re have
bee n extremely ra pid and unusua l changes over the last ce ntu ry. The Earth's tempe ra t ure
has inc re ased 2.0° Fa h re nhe it since 1880, and the twenty wa rmest yea rs in our Earth's
history have all occ u rred sin ce 1998. Climate change ca uses extreme wea t he r, droughts,
ris in g sea levels, more acidic oceans, health threats, increase d wil d life ext inction risks, air
pol lution, and mo re. Specifically, in Californ ia, there have been record-b reaking high
temperatures t his past year, increased wi ldfi res, hea lt h im p acts from extreme heat and
smoke from fi res, declining wa t er supply, reduced ag ricultu ral impacts, e ros io n in coastal
areas, and more t ha t ca n all be linked t o t he increasing effect s of climate change.
10211 Su nl and Blvd ., Shadow Hills, CA USA +l {818) 650-0030 XlOl dw@aenv .org
Final EIR
]
Lead Agency: C ity of San Bernard ino SCH No . 2020100067
Page F-52
C omment Letter e
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E-3(cont)
•• ••
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Final Environmental Impact Report
CEQA Comment Letter: The Landing by San M anuel D raft EI R
December 3 1, 2020
Page 2
G reen house-gas (G HG) e mi ssi ons generat ed by h uman activity, incl ud in g com bu stion of
fossi l fu els such as na t u ral gas, are a lea d ing ca use o f cl imate cha nge.
The Project Would Have Huge Climate Impacts
The EIR concl udes t hat Proj ect's G HG emi ss ions wou ld const itute a sig ni ficant
cum u lat ive im p act under CEQA (EIR pp. 4 .4-27, 4 .4 -33.) It adopt s a sign ificance thresho ld
of 3,000 MTCO2e p er yea r. (EIR p . 4.4-2 1.) The Proj ect's estima t ed em issions of
23,51 4.1 5 MTCO2e/year (EIR p . 4 .4-28) excee d th is th reshold by a factor of more than
e ight . Th e largest sha re of the Pro ject's G HG e m issio ns co me fro m mobil e sou rces (ca rs
and tru cks), b ut t he Pro j ect's d irect energy usage , for heating, coo ling, l ightin g, etc.,
est ima t ed as 7,020.44 MTCO2 e, by its e lf is more t han t wice t he t hres ho ld amount. It
appears t hat the 23,5 14.15 MTCO2e est imate is th e EI R's est imate for t he Project's G HG
em iss io ns, t aking into acco unt the m it igatio n measures and ap p licable reg u latio ns list ed
in the EIR .
23,5 14 MTCO2e is a huge amo unt . Em itting G HGs is, in econom ic t erms, an
ext e rn al it y, a cost of the Project that t he applica nt d oes not p ay b ut, inst ead, imposes on
t he wo rl d at lar g e . Usi ng t he U.S. $86/t on ne socia l cost of ca rbon fro m a 201 8 article in
N atu re Climate Cha nge,1 the project wo u ld impose 23,514 X $86 = j ust over $2 m il lion in
cost s p er year on others, for t he life of th e Pro j ect . The Proj ect's sha re of wor ld-wide
G HG emissio ns m ay be sma l l, but t hose e m iss io ns affect every o ne of t he 7 b illio n
in habita nts o f th is pla net.
The EIR Mistakenly Cla ims the Project is Consistent with the CARS
2017 Scoping Plan
The EIR correctly co ncludes that the Project's em issions are sig n ifica nt unde r
Thresho ld a, but wrong ly concludes, u nder Th res ho ld b , t ha t t he Project is consist ent wit h
t he CA RB 2017 Sco p ing Plan, whi ch is attached to t his letter as Exhi bit 1. 2
The EIR, in Tab le 4.4 -5, on pages 4.4-28 -4 .4-32, lists ways t hat t he Proj ect is
com p atib le with the CARB 2017 Scopi ng Plan, but fa ils to pro p e rly ana lyze
in cons iste nc ies . T he re are ma ny incons iste ncies , in cl ud ing the fo llowi ng:
• Th e Sco p ing Plan st at es t hat VMT red uctions w ill b e necessary to ac hieve its goals
(p. 75), b ut t he Proj ec t great ly inc reases VMT. The Pro j ect w il l resul t in a net
inc rease of 2,458 actua l ve hicu lar t rips per day and 3,432 passenger car
equ iva le nt (PCE) veh icu la r trips per d ay. (D EIR Table 4.8-1.) The Project's VMT per
serv ice popu lat ion values wou ld excee d the City's adopted th res ho ld by 33% for
basel in e (202 0) cond it io ns and 25 .9% for cum ulative (20 40) cond iti o ns. (D EIR
Tab le 4 .8-2 .) Th is add iti on of a la rge amo un t of t raffic is not consist en t wi t h the
1 Kat hari ne Ricke, Laurent Dr ouet , Ken Caldeira, an d Massi mo Tavo ni, Co untry-level social cos t of carbo n,
Nature Climat e Chan ge, avai lab le at < https://doi.org/10 .1 0 38/s41558-018-02 82-y l >
2 For the hard-co py versi on of this le tter, sent t o t he City vi a USPS ma il , t he Exhi bit s are on a CD i ncl uded
wi th the letter. Please incl ud e th em in t he re cord fo r this ca se.
10211 Su nland Blvd ., Shadow Hil ls, CA USA +1 (818) 650-0030 XlOl dw@aenv.org
Final EIR
J
Lead Agency: C ity of San Bernardino SCH No . 2020100067
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C omment Letter e
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Final Environmental Impact Report
CEQA Comment Letter: The Landing by San M anuel Draft EI R
December 3 1, 2020
sta t ew ide goals outl ined in t he 20 17 Scop ing Plan t o red uce t raffic by
approx imate ly 30 %
Page 3
• The Sco pi ng Plan estab lishes st atewide G HG e miss io ns target s of 6
MTCO2e /ca p ita b y 2030 and 2 MTCO2e /capita by 20 50 (p. 99.) Fo r a ware ho use
proj ect with no one l ivi ng on-site a "per serv ice p opu lat ion" metric is more
appropriat e t han a "pe r capita" t arget, bu t the Project 's huge levels of GHG
emiss io ns g uarantee it will exceed any re aso nable service -popu lat ion metric .
The El R's incorrect analysis of the Pro j ect's cons iste ncy with t he CARB 2017
Sco p ing Pla n vio lates C EOA by fai lin g to p rovide co rrect info rmatio n t o t he pu b lic and
t he d ec ision-ma ke rs.
Failure to Require Mitigation for the Project's GHG Impacts
CEQA requi res all feasib le mi t iga t ion for si g nificant impacts . A ll m itigat ion
measures t hat d o not re nder t he p roject im p ract ica l or unprof itable are feas ib le .
The EIR concl udes, in t wo sente nces, cit ing no support ing information , th at no
add it io nal miti gation m eas ures are feas ib le :
No other mit igati on measu res ar e ava ilable tha t are feas ible for t he City of
Sa n Bernard ino to enforce that have a pro p ortional nex us to t he Pro j ect's
leve l of imp act. According ly, t he Ci t y of Sa n Berna rdi no f inds tha t t he
Proj ect 's GHG emi ss ions represen t a sig nifican t an d unavoidable
cum ulat ively -co nsiderab le impact for wh ich no add it iona l feas ible m itigation
is ava ilab le. (EI R p . 4.4-35 .)
There are many meas u res the City co u ld requ ire th at wo uld m itigat e t he Project's
GHG im pacts, fo r example:
• Requi ring sola r p anels t hat ge nerate at least as muc h e lectri ca l energy as t he
Project consu mes (i.e. net zero );
• Requi ring t he insta llation of a large number of elect ri c-ve hicl e charg ing stat ions
o n-s ite;
• Inst al lin g e lect ri c-ve h icle charg in g sta t ions in appro priate loca t io ns off-s ite;
• Requi ring t he applicant to retrofit energy-inefficie nt b ui ld ings off-site in San
Berna rd ino Cou nty;
• Requ iring t he p urchase of offsets;
• Requi ring su b sidiz ies for the p urchase of e lectric bu ses to be operat ed by p ub lic
agencies in t he area.
The CA RB 201 7 Scopi ng Pl an recommen d s t hat loca l agencies pri oritize loca l G HG
mit igation:
Reg ionally, add itiona l GHG reductions ca n be ac hi eved t hro ug h direct
investme nt in loca l b ui ld ing re t rofit prog rams t hat can pay for coo l roofs ,
solar p anels, sola r wa t er heate rs, smart met ers, energy efficient lighting,
ene rgy effi cie nt ap p liances, ene rgy efficient w ind ows, insu la t ion , and water
co nservation measures for homes within th e geogra ph ic area of t he proj ect.
These invest me nts generate rea l dema nd side be nefit s and local j obs, wh ile
cre ating t he ma rket signa ls for energy efficient products, some of whic h are
prod uce d in Ca lifo rn ia. Other examp les of loca l di rect inves t ments incl ude
10211 Su nl and Blvd ., Shadow Hills, CA USA +l (818) 650-0030 XlOl dw@aenv .org
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C omment Letter e
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•• ••
The Landing by San Manuel
Final Environmental Impact Report
CEQA Comment Letter: The Landing by San M anuel D raft EI R
December 3 1, 2020
Page 4
fi nancing ins t al lation of regiona l electri c veh icl e (EV) charg ing stat io ns, pay ing
for elect rifi cat io n of public sc hool buses , and invest ing in loca l u rb an fo rests.
(p . 102 .)
I have attached, as Ex hibit 2 to th is letter, a document co ntai n ing se lections from
t he Gree nh o use Gas Emissions Tec hn ical Report prepare d for the large Newhall Ranch
proj ect. The El Rs fo r t hat proj ect origi nall y co ncl uded t ha t the GHG emiss io ns from the
largest mixed-use deve lopment project eve r approve d in Ca li fo rn ia would not be
significa nt under CEQA. After th e Ca lifo rni a Sup reme Court invalidated th e El Rs, N ewha ll
Ranch d ec ided on the net-zero approac h outl in ed in t he atta c hed Tech nical Report. Th e
mitigatio n measu res fi nally adopted for N ewhal l Ranch are a templat e showing how G HG
emiss io ns ca n b e m itigat ed t o zero. Many of t hem wo u ld b e feasib le fo r t his Project. T his
is t he approach we u rge the City of Sa n Berna rd ino to ad o pt for t he Landi ng by Sa n
Man uel Proj ect.
Conclusion
Fo r t he reasons g iven in t his letter, the City sho uld deny ap proval o f t he EI R and
work w ith t he A pplica nt to identify appropriat e m it igation measures t hat ca n reduce the
Project's G HG emissions to net-ze ro.
Since re ly,
~w~
Dea n W all raff, Executive D irecto r
Coo l Wo rld Inst itute
10211 Su nland Blvd ., Shadow Hil ls, CA USA +l (818) 650-0030 XlOl dw@aenv.org
Final EIR
J
J
Lead Agency: C ity of San Bernardino SCH No . 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-55
RESPONSES TO COMMENT LETTER E
E-1 This comment introduces the commenter as being part of a non-profit law firm and advocacy
organization. No specific comments are made that warrant a response or revision to the DEIR.
E-2 This comment provides Project summary information. No specific comments are made that warrant a
response or revision to the DEIR. For clarification, the Project Site comprises only a portion of the
much larger former Norton Air Force Base (AFB) which has been redeveloping into an industrial center
since the AFB was closed in 1994.
E-3 The commenter provides a general description of climate change. Climate change is discussed in DEIR
Subsection 4.4 on Pages 4.4-1 through 4.4-8 and in the Project’s Greenhouse Gas (GHG) Analysis
appended to the DEIR as Technical Appendix G. No specific comments are made that warrant a
response or revision to the DEIR.
E-4 The commenter summarizes the DEIR’s conclusion that the Project would result in a significant and
unavoidable GHG emissions impact and then characterizes the impact as “huge” and impactful to every
person on planet Earth. The City is aware that climate change is a global phenomenon. As
acknowledged in DEIR Subsection 4.4, Page 4.4-1, the text factually states that an individual project
like the proposed Project cannot generate enough GHG emissions to affect a discernible change in
global climate. However, the proposed Project has the potential to make an incremental contribution
of GHGs combined with the cumulative increase of all other sources of GHGs worldwide, which when
taken together constitute potential influences on climate change. DEIR Table 4.4.2 supplies numerical
data on GHG emissions contributed by top GHG producing countries in the world. The Project’s
23,514 MTCO2e would represent approximately 3.64 one-hundred-thousand of one percent
(0.000364%) of the total 6,456,718 gigagrams of GHG emissions produced in United States annually
as reported by the Intergovernmental Panel on Climate Change (DEIR Page 4.4-7).
E-5 The commenter questions the DEIR’s conclusion that the Project does not conflict with CARB’s 2017
Scoping Plan. The purpose of illustrating consistency with the 2017 Scoping Plan is to identify the
Project’s lack of conflict with, or lack of obstruction to, the State’s ability to realize the Statewide goals
of the 2017 Scoping Plan. The intent is not to demonstrate consistency on a Project-specific level with
each and every Scoping Plan measure. Several of the 2017 Scoping Plan measures are regional or
Statewide measures and are not applicable to development projects such as the proposed Project on a
project-specific level. Refer to DEIR Table 4.4-5 on Pages 4.4-28 through 4.4-32 for a discussion of
the Project’s relationship to the 2017 Scoping Plan.
E-6 The commenter broadly and generally claims that the Project is not consistent with CARB’s 2017
Scoping Plan because the Project will increase vehicle miles traveled (VMT), and that VMT reductions
are needed [Statewide] to meet CARB’s goals. While it is true that the Project will increase VMT and
result in a significant and unavoidable impact based on the City’s threshold of significance for VMT,
there is no information in the Project’s administrative record or offered by the commenter to suggest
that the Project’s VMT would render the Project in conflict with the entire Scoping Plan. Refer to
Response E-5 above, which explains that it is not necessary to demonstrate consistency with each and
every goal of the Scoping Plan in order to deem that a project does not conflict with the Plan.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-56
E-7 The commenter differentiates between “service population” and “per capita” in term of analyses
metrics for GHG emissions (however these terms are generally used interchangeably and represent an
efficiency metric), notwithstanding, the commenter agrees with the DEIR’s conclusion that the Project
would result in a significant and unavoidable GHG impact regardless of whether a service population
or per capita threshold were to be used. The fact that the Project will have a significant and unavoidable
GHG impact, however, does not automatically render the Project in conflict with the 2017 Scoping
Plan. Also refer to Response E-5 above.
E-8 The commenter claims that the DEIR should have determined the Project in conflict with CARB’s
2017 Scoping Plan and as such, provided incorrect information. The City disagrees with the
commenter and determined for the reasons set forth in DEIR Subsections 4.1 and 4.4 and supported by
Technical Appendix B1 and Technical Appendix G and the citations provided therein, that the Project
does not conflict with the Scoping Plan. Also, refer to Comment Letter A from CARB, in which they
do not assert that the Project is in conflict with their Scoping Plan.
E-9 The commenter suggests that additional feasible mitigation measures are available to reduce the
Project’s GHG impact. CEQA does not require adoption of every imaginable mitigation measure.
CEQA’s requirement applies only to feasible mitigation that will “substantially lessen” a project’s
significant effects. (Public Resources Code, § 21002.) As explained by one court: A lead agency's
“duty to condition project approval on incorporation of feasible mitigation measures only exists when
such measures would [avoid or] ‘substantially lessen’ a significant environmental effect.” (San
Franciscans for Reasonable Growth v. City and County of San Francisco (1989) 209 Cal.App.3d 1502,
1519.) “Thus, the agency need not, under CEQA, adopt every nickel and dime mitigation scheme
brought to its attention or proposed in the project EIR.” (Ibid.) Rather, an EIR should focus on
mitigation measures that are feasible, practical, and effective. (Napa Citizens for Honest Government
v. Napa County Board of Supervisors (2001) 91 Cal.App.4th 342, 365.) Refer to Response E-10 for
responses to the commenter’s specific suggestions.
E-10 The commenter suggests six mitigation measures for the City to consider to reduce the Project’s GHG
impacts.
1. The commenter’s first suggestion is to require solar panels that generate as much energy as the
Project consumes. The City finds this suggestion infeasible because the Project is being entitled
as a speculative building and it is not possible to calculate how much energy the indeterminate
building occupant will use, whether there is enough area on the building roof to accommodate the
extent of EV panels to generate that amount of electricity, and whether the utility provider, SCE,
will approve the metering system. Further, the Development Site is located in close proximity to
the San Bernardino International Airport, and the Federal Aviation Administration (FAA) requires
a formal review of any solar panel installations to ensure that resulting glare will not interfere with
aircraft operations, and it is unknown how much solar coverage if any the FAA would approve.
Regardless, DEIR Mitigation Measure MM 4.4-1(d) and the addition thereto presented in Response
C-19, requires that the shell building include a PV system to provide a minimum of 24 KW of
power per year (subject to FAA approval), and that the remainder of the building’s roof be designed
and constructed to accommodate the potential future construction of additional photovoltaic (PV)
solar arrays. The City is not requiring more than a 24 KV system as part of the shell building for
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-57
an indeterminate tenant because committing to a system too early and then needing to retrofit it to
meet building user specifications is technologically and cost prohibitive. Since every prospective
building occupant will have a specific electrical power requirement, a speculative project cannot
prespecify an electrical system. Nonetheless, the proposed building will be properly designed to
maximize the use of alternative power generation systems.
2. The commenter’s second suggestion is to install EV charging stations on-site. The City agrees,
and this is already accounted for by the Project design and DEIR mitigation measures. The
Project’s design includes a truck staging area in the southwest portion of the property, where EV
charging stations for trucks are planned to be accommodated. MM 4.4-1 requires that the
building’s electrical room be sufficiently sized to hold additional panels to supply power for the
future installation of EV truck charging stations on the site at this location. The San Manuel Band
of Mission Indians is the Project Applicant and is voluntarily actively engaged with solar and
electric vehicle industry leaders, such as Tesla, to advance the accommodation of EV vehicles. To
this end, the Project’s building specifications include electrical switchgear and the truck staging
area is designed to accept a technologically advanced electrical charging system to meet
prospective building user requirements for EV truck charging. As a speculative development, it is
not possible to forecast what an actual future user of the building may need or require in terms of
EV truck charging, as the needs vary widely among building users and the technology is rapidly
advancing. The Project’s EV charging facilities for trucks will be tailored to the needs of the
building user, because committing to a system too early and then needing to retrofit it to meet
building user specifications is technologically and cost prohibitive. The Project Applicant’s
commitment to energy sensitive design is appreciated by the City, and is viewed as
environmentally responsible.
The Project also will include EV charging facilities for passenger vehicles. The proposed
warehouse building is required by law to comply with CALGreen. DEIR Mitigation Measure MM
4.4-1 requires that the Project Applicant provide documentation to the City demonstrating that the
Project is designed to meet or exceed CALGreen Tier 2 standards in effect at the time of building
permit application. These standards include but are not limited to the provision of referential
parking locations for carpool, vanpool, EVs and CNG vehicles, the installation of passenger vehicle
EV charging stations, and the installation of conduit at a minimum of five percent of the Project’s
total number of automobile parking spaces to accommodate the future installation of additional EV
charging infrastructure.
3. The commenter’s third suggestion is to install EV charging stations off-site. This suggestion is
rejected by the City because it is beyond the scope of the Project and Project Site.
4. The commenter’s fourth suggestion is to retrofit energy-inefficient buildings elsewhere in the
County. This suggestion is rejected by the City because it is beyond the scope of the Project and
Project Site and outside of the ability of the City to enforce or control.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-58
5. The commenter’s fifth suggestion is to require the purchase of GHG offsets. The City rejects this
suggestion because the primary market for offset purchases in California is Cap-and-Trade. This
means that the vast majority of offsets in California are specifically designed for “Compliance
Offsets,” which are not available for CEQA mitigation because they are all allocated towards the
State’s Cap-and-Trade program.5 To meet the additionality requirements of CEQA, GHG offsets
must come from a voluntary offset program, and there are not sufficient voluntary offset programs
in California to meet CEQA mitigation requirements Statewide. Also, there is a lack of
performance standards in voluntary programs to ensure that the mitigation would actually be
accomplished. In addition, as explained in a Court of Appeal decision, the use of out-of-state
carbon offsets is generally not an effective way to mitigate GHG impacts, in part because of the
inability to take enforcement action if an offset is false, fails, or otherwise is inadequate. (See
Golden Door Properties, LLC v. County of San Diego (2020) 50 Cal.App.5th 467, 510, 562.)
6. The commenter’s sixth suggestion is to require the Project Applicant to subsidize the purchase of
electric buses for public agencies. This suggestion is rejected by the City because it is beyond the
scope of the Project and Project Site and because the purchasing, deployment, and operation of
public transit agency busses is beyond the control of the Project Applicant and the City. The City
is unaware of any fee payment program in San Bernardino County that has been established by
public transit agencies for the mitigation of GHG impacts by private development projects.
E-11 The commenter states that CARB’s 2017 Scoping Plan recommends prioritization of local GHG
mitigation, and goes on to list several general examples of items that reduce GHG emissions on a
regional level such as retrofit programs for existing buildings. The proposed Project does not involve
an existing building that could be retrofitted, and no specific comments are made that warrant a
response or revision to the DEIR. Construction of the Project is required by law to comply with the
California Building Standards Code (CALGreen) and DEIR Mitigation Measure MM 4.4-1 requires
that the Project Applicant or successor in interest provide documentation to the City demonstrating
that the Project is designed to meet or exceed CALGreen Tier 2 standards in effect at the time of
building permit application. CALGreen was the first building code in the United States to mandate
reductions in GHG emissions through building design and associated code compliance.6 Compliance
by the Project will reduce GHG emissions as intended by the State of California.
E-12 The commenter attaches exhibits from a GHG technical report prepared for the Landmark Village
(Newhall Ranch) project in Valencia (northwest Los Angeles County) California (2016), claiming it is
applicable to the proposed Project. The commenter’s attachment is attached as Attachment 4 to this
FEIR. Newhall Ranch is a mixed-use project that proposed 1,444 residential homes, over 1,000,000
square feet of commercial retail/office space, an elementary school, community park, fire station, and
other mixed uses. Given the character of Newhall Ranch, the City finds that it is not directly
comparable to the proposed Project, which is a different land use (industrial warehouse), is one building
5 California Air Resources Board website, “Compliance Offset Program.” https://ww2.arb.ca.gov/our-
work/programs/compliance-offset-program
6 https://www.dgs.ca.gov/BSC/Resources/Page-Content/Building-Standards-Commission-Resources-List-Folder/CALGreen
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-59
as compared to well over 1,500 buildings proposed by Newhall Ranch, and located in a different county
(San Bernardino County). The capabilities and feasibility of mitigating GHG impacts for Newhall
Ranch are vastly different than those for the proposed Project.
E-13 The commenter suggests that the City not certify the EIR unless additional mitigation measures for
GHG emissions are included. The commenter’s opinion is noted. Please refer to four mitigation
measures added in response to Comments A-14, A-15, A-19, and A-20(1).
Page F-60
Comment L etter F
F-1
•• ••
The Landing by San Manuel
Final Environmental Impact Report
November 18, 2020
Via Email and U.S. Mail
City of San Bernardino
Attn : Elizabeth Mora-Rodriguez
290 North D St.
San Bernardino, CA 92301
mora-rodri guez iii,s bc il\.org
CREEDLA i
RE: Public Records Act Request and Request for Mailed Notice of Public Hearings
and Actions -Victoria Ave and E 3rd St Highland CA 92346
Dear Ms. Mora-Rodriguez,
CREED LA is writing to request a copy of any and all records related to the Landing by San
Manuel at Victoria Avenue and East 3rd Street in San Bernardino. The project will be the
construction of a 1,153,700 sf warehouse building and associated site improvements. We are also
writing to request copies of all communications and mailed notice of any and all hearings and/or
actions related to the Project.
Our request for mailed notice of all hearings includes hearings, study sessions and community
meetings related to the Project, certification of the MND (or recirculated DEIR), and approval of
any Project entitlements. This request is made purs uan t to Public Resources Code Sections
21092 .2, 21080.4, 21083.9, 21092, 21108 and 21152 and Government Code Section 65092,
which require local agencies to mail such notices to any person who has filed a written request
for them with the clerk of the agency's governing body. Our request includes notice to any City
actions, hearings or other proceedings regarding the Project, Project approvals and any actions
taken , or additional documents released pursuant to the California Environmental Quality Act.
Our request for all records related to the Project is made pursuant to the California Public
Records Act. (Government Code § 6250 et seq.) This request is also made pursuant to Article I,
section 3(b) of the California Constitution, which provides a constitutional right of access to
information concerning the conduct of government. Article I, section 3(b) provides that any
statutory right to information shall be broadly construed to provide the greatest access to
government information and further requires that any statute that limits the right of access to
information shall be narrowly construed.
We will pay for any direct costs of duplication associated with filling this request yp to $200.
However, please contact me at (877) 810-7473 with a cost estimate before copying/scanning the
materials.
50, Shatto,
(877)
Su ,le 'lO, ~~ Angel
cree~I 1@cree
002
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-61
Comment L etter F
F-1(cont)
• • The Landing by San Manuel • D Final Environmental Impact Report
Pursuant to Government Code Section 6253.9, if the requ ested documents are in electronic
format and are 10 MB or le ss (or can be easily broken into sections of 10 MB or les s), please
email them to me as attachments .
My contact information is:
U.S.Mail
Jeff Modrzejewsk.i
CREED LA
50 l Shatto Place, Suite 200
Los Angeles, CA. 90020
Email
crccc\liiJcrcc dl · c m
Please call me if you have any questions . Thank you for your assistance with this matter.
Sincerely,
Jeff Modrzejewski
Executive Director
301 no Pl ;J
Lead Agency: City of San Bernardino
, s Ange les. )(1
Final EIR
SCH No . 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-62
RESPONSE TO COMMENT LETTER F
F-1 The commenter requests a copy of the City’s records pertaining to the proposed Project. No specific
comments are made that warrant a response or revision to the DEIR.
Page F-63
Comment Letter G
G-1
G-2
G-3
•• ••
The Landing by San Manuel
Final Environmental Impact Report
C, EARTHJUSTICE
January 6, 2021
Via E-Mail
Elizabeth Mora-Rodriguez
Associate Planner
City of San Bernardino -Plannin g Di vision
290 North D Street
San Bernardino, CA 91764
Email: Mora-Rodriguez_ El @ sbcity.org
ALASKA CALIFOR NI A FL ORIDA MIO-PACIFIC NOR THEAS T NORTHERN ROCK IE S
NORTHWEST ROCKY MOUNTA I N WAS H INGTO N, O.C. I NTERNATIONA L
RE: The Landing Project Draft Environmental Impact Report (State
Clearinghouse 20200100067)
Dear Ms . Mora-Rodriguez :
I respectfully submit the following comments to the Draft Environmental Impact Report
("DEIR") for the Landing Project ("Landing" or "Project"). This development will bring
additional pollution and impacts to an already overburdened community. Because of this , it is
vital to properly disclose the environmental consequences of the proposed action and to ide ntify
an d adopt all feasible mitigation measures , and alternatives . Unfortunately , the DECR fails in its
duty to comply with the California Environmenta l Quality Act ("CEQA"). As such, the City
cannot rely on the document as a form of environmental impact review for the purpose of Project
approval , and must engage in a ne w Draft Environmental Impact Report ("DEIR") to allow the
public an d decision-makers an opportunity for meaningful review of the Project's impacts.
I. The Greenhouse Gas ("GHG") and Air Quality Emissions Ana lysis Are Unlawful.
Seeking to obfuscate the full impacts from this Project, the DEIR reduces the GHG
emissions in a manner that contradicts the core ofCEQA. In particular, the construction
emissions analysis for both criteria and GHG pollutants omits many trips that should be
considered as outlined in the letter from the California Air Resources Board. Moreover, the
significant air quality and GHG impacts have not been mitigated usin g all feasible mitigation
measures.
II. Requiring the Usage of Zero-Emission Class 7 and 8 trucks at the Project Site is a
Feasible Mitigation Measure nnder CEQA for the Project's Significant GHG and Air
Quality Impacts
Under CEQA, potential mitigation measures cannot be properly lab ell ed miti ga ti on
measures unless they are at least partially effective in reducing the significance of the impacts at
issue . 1 Here, the Project 's two relevant impacts are GHG and air quality impacts, due largely to
1 Sierra Club v. Co un ty ofFresno, 431 P.3d 1151 , 11 66 (Cal. 20 I 8).
LOS ANGELES OFF I CE 7 0 7 W I LSH I RE BLV D .. SU I TE 4300 LOS ANGE LES. CA 90017
T : 415 .2 17 .2 000 F : 41 5.2 17 .2 040 CAOFF ICE @ EARTH J UST I CE .ORG WWW .EART HJ USTICE .ORG
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-64
Comment Letter G
G-3(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
the increased amount of diesel-fueled semi-truck trips associated with the Project. The DEIR
indicates that the air quality impacts associated with the construction and operation of the Project
will not be mitigated to a level of insignificance. Thus, the Project as currently proposed has both
significant GHG and air quality impacts. Requiring the usage ofzero-emission Class 7 and 8
semi-trucks in lieu of diesel semi-trucks is therefore an effective miti gation meas ure under
CEQA because these vehicles have no tailpipe emissions , and much lower life-cycle GHG
emissions .
According to the Union of Concerned Scientists, battery-electric Class 7 and 8 trucks
have lower life cycle GHG emissions than diesel trucks no matter the operating characteristics of
the vehicle or the electric grid . 2 While battery-electric vehicles do not have tailpipe GHG
emissions like diesel vehicles, there are still GHG emissions associated with the generation of
the electricity used to power the vehicle. With the current mix of electricity generation sources in
the United States, the Un ion of Concerned Scientists found that a battery-electric semi -truck
operating locally offers 65% life cycle GHG reductions compared its diesel collllterpart. 3
Battery-electric semi-trucks operating on hi g hways offer 50% GHG reductions compared to
diesel semi-trucks .4 These reductions are likely even higher in California, since California has a
larger proportion of renewable electricity generation sources than the national average. 5 Further,
the GHG reductions associated with operating battery-electric semi-trucks will on ly increase as
California moves closer to its goal of ending its dependence on fossil fue ls for electricity
ge neration. Thus, requiring battery -electric C lass 7 and 8 semi-trucks in lieu of semi-trucks
fueled by diesel would significantly reduce the amollllt of GHG emissions associated with the
Project, making it effective mitigation under CEQA for the Project's significant GHG impacts.
Zero-emission vehic les , including Class 7 and 8 battery-electric semi-trucks, also cause
significantly less air pollution than diesel semi-trucks . Diesel semi-trucks are a major source of
both Particulate Matter2.5 , and well as Nitrogen Oxides ("NOx''), a precursor for ozone.6 These
air po ll utants have serious health consequences, as exposure to them is associated with asthma,
bronchitis , increased cancer risk, increased hospitalization, and even premature death. 7 Battery-
e lectric semi-trucks have no tailpipe emiss ions. 8 The only significant air pollutant associated
with the operation of battery-electric semi-trucks is the Particulate Matter emitted from brake
wear. 9 However, according to CARB, zero emission vehicles produce 50% le ss Particulate
2 Union of Concerned Citizens , Ready f or Work : Now is th e Tim e for Heavy Duty Electric Vehicles , at 6
(Dec . 11 , 20 19) https ://www .uc susa.org/sites/defaul t/files /20 19-1 2/ReadyforWorkFullReport .pdf.
3 Id. at 7.
4 Id.
5 Nuclear Energy Institute, State Elec tricity Generation Fu el Shares
https://www .nei.o rg/resources/statistics/state-e lectricity-generatio n-fu el-sha res .
6 Union of Concerned Scientists, supra note 14 at 2.
7 Id.
8 California Air Resources Board , Updated Costs and Ben efits Analysis for th e Prop osed Advanced Clean
Tru ck Regulation , at 3 (A pril 28, 2020) http s ://ww3 .arb.ca .gov/regac t/20 I 9/act20 I 9/30dayattc .pdf.
9 Id.
2
Final EIR
Lead Agency: C ity of San Bernardino SCH No . 2020100067
Page F-65
Comment Letter G
G-3(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Matter from brake wear when compared to diesel vehicles. 10 This is because zero emission
vehicles utilize "regenerative braking", which reduces brake usage.11 Thus , requiring zero
emission Class 7 and 8 semi-trucks in lieu of diesel semi-trucks would greatly reduce the
significant air quality impacts associated with the Project, and is therefore effective mitigation
underCEQA.
1. Requ iring the Usage of Class 7 and 8 Zero-Emission Trucks at the Project Site is a
Feasible Mitigation Measure under CEQA
Under CEQA, a public agency cannot approve a project as proposed if there are "feasible
mitigation measures which substantially lessen the significant environmental effects " of the
project.12 Feasibility is defined under CEQA as , "capable of being accomplished in a successful
manner within a reasonable period of time, taking into account economic, environmental , social ,
and technological factors".13 The CEQA Guidelines add "le ga l" factors to this definition .14
Public agencies have the power and duty to assess the adequacy of miti gation measures, subject
on ly to judicial re v iew for abuse of discretion. 15 A determination on the feasibility of a particular
mitigation meas ure will be uphe ld by a reviewin g court if a "fair argument" can be made to
s upport the public agency's conclusion. 16
Requirin g the usage of Class 7 and 8 battery-electric site at the Project site is a feasible
mitigation measure under CEQA for a multitude of factors . First, numerous studies show that the
current total cost of ownership for a large battery-electric semi-truck is less than a diesel
equivalent. As the decade pro gresses , the cost of battery-electric semi-trucks will drop even
lower, whereas diese l trucks are expected to increase in cost, or remain stagnant. Second, the two
largest technological barriers to widespread usage of battery-electric semi-trucks, which are the
existence of cheap batteries that can sustain long range freight movement, and sufficient
charging infrastructure to support battery-electric semi-trucks , have been overcome with
immense public and private investment. Third, there are currently numerous Class 7 and 8
battery-electric truck models available for purchase, and many freight facilities have already
committed to utilizing these trucks. Finally, government agencies in California are aggressively
pushing for widespread usage of large battery-electric semi-trucks , through regulatory mandates,
grant programs, and financial incentives.
A. Th e Current Total Cos t of Ownership of Battery-Electric Semi-Trucks is less than
Diesel Semi-Trucks
io Id.
II Id.
12 CAL. PUB . RE s. COD E § 2 1002 (Wes t. 2020).
13 CAL. P UB . REs. COD E§ 2 I 06.1 (West. 2020)
14 CAL . COD E REGS. tit. 14, § 15364 {2020).
15 City of Marina v. Board of Trustees of Cal ifornia State Uni vers ity, 13 8 P.3d 692 , 705 (Cal. 2006).
16 CAL. COD E REG . tit. 14, § 153 84 (2020).
3
Final EIR
Lead Agency: C ity of San Bernard ino SCH No . 2020100067
Page F-66
Comment Letter G
G-3(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Numerous studies have compared battery-electric semi-trucks with their diesel and
natural gas counterparts using a Total Cost of Ownership ("TCO") analysis. A T CO analysis
attempts to capture the total cost of purchasing and operating a vehicle throu ghout its entire life.
While each study has slightl y varied methodology, each TCO analysis generally consists of
vehicle purchase cost, li fe time fuel and maintenance costs, and necessary infrastrncture costs.
Some studies analyze additional factors , including California 's available financial incentives, the
charging infrastructure investments made by California 's utilities, and the environmental
externalities associated wi th C las s 7 and 8 se mi-trncks. Multiple comprehensive studies show
that, w ith financial incentives, electric semi-trucks currently ha ve a lower, TCO than both diesel
and natural gas semi-trncks. Fu.rther , these studies indicate that the cost of battery-electric C las s
7 and 8 semi-trucks wi II continue to decrease as the 2020s progress, whereas the cost of diesel
trucks will either increase or remain stagnant.
CARB undertook a TCO analysis that compared battery-electric and diesel C lass 8 Day
Cab semi-trncks.17 Day Cabs are a type of truck generally used for day trips less than 250 miles ,
and are also known as regional-haul or s hort-haul trucks . The study compared the TCO of this
type of semi-truck in three different scenarios : if the vehicle is purchased in 2018 , 2024, and
2030. 18 The study concluded that the TCO for a battery-electric C lass 8 Day Cab purchased in
20 18 is about $200,000 more than its diesel counterpa.rt .19 The TCO for a battery-electric truck
purchased in 2024 is about $100,000 less than a diesel truck.20 For 2030, the TCO is about
$150,000 le ss than a diesel truck.21
A study done by the International Council on Clean Transportation ("ICCT") has s imilar
results .22 The ICCT study compares the TCO of Class 8 long-haul battery-e lectric an d diesel
semi-trucks in three scenarios: if the vehicle is purchased in 2020, 2025 , and 2030. 23 In 2020, the
study indicates the TCO of a battery-electric lon g-haul truck is about $150,000 more than a
diesel equivalent. 24 In 2025 , the TCO for a battery-e lectric truck is about $50,000 more than a
diesel truck ; in 2030, battery-electric trucks have a favorable TCO, which is about $20,000 less
than a diesel truck. 25
Both of these studies indicate the current TCO of a battery electric semi-trnck is
significantly more than a diesel equivalent, but that b attery-electric semi-trucks will have a
17 Ca lifornia Air Resourced Board, Draft Advanced Clean Tru cks Total Cos t of Ownership Discussion
Docum ent (Oct. 22 , 2019) https://ww3.arb .ca.go v/rcgact/20I9/act20 19/apph.pdf.
18 Id. at I.
19 i d. at 2.
20 Id.
21 Id.
22 The International Co uncil on Clean Transportation , Es timating th e i nfrastructure Needs and Cos ts for
th e Launch of Zero-Emiss ion Trucks (A ug. 9, 20 19)
https ://theicct.or g/s ites/defaul t/file s/publicatio ns /TCCT EV HDV s Infr as tructu re 20190809.pdf.
23 Id. at 20.
24 Id.
2, Id.
4
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favorable TCO sometime within the next decade. However, these conclusions are misleading.
The ICCT study does not take into account the financial incentives available in California, and
the CARB study only considers the Low Carbon Fuel Standard. California has many more
incentives available, with the most prominent being the Hybrid and Zero-Emission Truck and
Bus Voucher Ince ntive Project ("HVTP"). 26 For certain Class 7 battery-electric trucks , this HVIP
program provides $95 ,000 as a voucher to offset some of the purchase price. 27 For certain Class
8 battery-electric trucks, the voucher amount is $150,000 .2 8 Further, in their respective analyses
of charging infrastn1cture costs, neither study incorporates the hundreds of million s of dollars
which California utilities have already committed to support the development heavy-duty
charging infrastrucn1re. 29
A study conducted by !CF finds that, when the HVIP program and the utilities ' charging
infrastrucnrre investments are incorporated into a TCO analysis , battery-electric semi-trucks
currently have a favorable TCO compared to d ieset.30 ICF's study compares the TCO ofbattery-
electric and diesel Class 8 short-haul semi-trucks and Class 8 long-haul semi-trucks purchased in
2019 and 2030. 31 For battery-electric short-haul trucks purchased in 20 19, the TCO is about
$150,000 less than a diesel equivalent. 32 For battery-electric short-haul trucks purchased in 2030,
the TCO is about $200,000 less than a diesel equivalent.33 For battery-electric long-haul trucks
purchased in 2019, the TCO is about $200 ,000 less than a diesel truck. 34 For battery-electric
trucks purchased in 2030, the TCO is about $300,000 less than an equivalent diesel truck.35 This
study finds that, when HVIP incenti ves , and the cumulative hundreds of millions California
util ities have in vested to build charging infrastructure are included in a TCO analysis , large
battery-electric semi-trucks currently have a favorab le TCO compared to diesel. Further,
consistent with the findings ofCARB and ICCT, ICF indicates that battery-electric trucks should
be able to compete without HVIP incentives on a TCO basis by 2030.36
In addition to financial incentives and uti lity charging infrastructure investment, when the
environmental externalities of air pollution and GHG emissions are monetized and incorporated
26 California Hybrid and Zero-Emission Truck and Bus Voucher Program
https ://www.cal iforniah vip.orf!/.
27 See generally , Ca liforn ia HV[P Eligible Vehicle Catalog https ://www.califomi ahvip.orf!/how-to-
participate/#Eligib le-Vehicle -Cata log .
2s Id.
29 California Pub lic Utilities Commission , Transportation Electrification Activities Pursuant LO Senate
Bill 350 https ://www.cpuc.ca.gov/sb3 50te/.
30 !CF, Comparison of Medium and H eavy-Duty Technolog ies in California, Part Two: Total Cost of
Ownership Analysis (December 20 19) https ://cal etc .com/wp-content/upl oa ds/2019 /12/IC F-Truck-
Report Final Decem be r-20 19.p df.
31 Id. at
32 Id. at 20.
33 Id.
34 Id. at 19 .
3s Id.
36 ld. at 32.
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Lead Agency: C ity of San Bernardino SCH No . 2020100067
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into a TCO ana lysis, battery-electric trucks are even cheaper compared to diesel. A study done
by the Lawrence Berkeley National Laboratory ("LBNL") monetizes the reductions in GHG
emissions and air pollution associated with battery-electric trucking in three different scenarios :
when electricity comes from 90% renewab le sources and I 0% gas , when it comes from I 00%
gas , and when it comes from I 00% coal. 37 The study found that , when battery-electric trucks are
fueled by electricity generated with 90% renewables and I 0% gas , these trucks save $0 .28 per
mile compared to diesel.38 When battery-electric trucks are powered by electrici ty generated with
100% gas , these trucks save $0.20 per mi le compared to diesel.39 California 's elec tricity
generation mix is somewhere in between these two extremes of 100 % gas and 90% renewable . 40
Therefore, battery-electric trucks operating within California would likely save somewhere
between $0.20 and $0.28 per mile in GHG and air pollution costs compared to a diesel truck
operating in California. Further, even without the monetization of environmental externalities,
the LBNL study concludes that the current TCO of a Class 8 semi-truck with a 400-mile range is
about 20% less than a diese l equivalent.4 1
When analyzed cumu lati vely , these studies show that battery-electric Class 7 and 8 semi-
trucks are curren tly an economically feasible alternative to diesel and natural gas semi-trucks. If
incentive programs like the HVIP and LCFS , as well as the significant investment made by
California utilities in charging infrastructure are incorporated into a TCO analysis , battery-
electric trucks are currently cheaper than diesel equivalents. As the 2020s progress , battery-
e lectric trucks will become even cheaper, as diese l trucks become more expensive. Further, by
2030, battery-electric semi-trucks are expected to compete with diesel semi-trucks on a TCO
bas is without any financia l incenti ves .
A. The Most Significant Technological Barriers to Widespread Us age of Battery-Eleclric
Semi-Trucks Have Been Overcome with immense Public and Pri vate inves tm ent
1. Battery Pack Prices are Expected to Continue Declining Significantly, and Battery
Technology has Advanced to Support Long Range Freight Movement
According to CARB , the co st of battery packs is the most important factor in the price of
a battery-electric semi-truck. 42 The price of battery packs for se mi -trucks, and all heavy-d uty
vehicles , has significantly declined over the past decade, and is expected to continue declinin g
over the next decade . Between 20 IO and 2018, battery pack prices declined approximately 80
percent. 43 A report conducted by the Rock y Mountain Institute indicates that the cost of
37 Lawrence Berkel ey National Laboratory, Long-Hau / Ba1te1 y Jilectric 1i't,cks are Technically Feasible
and Economically Co mp ellin g, at IO https ://eta -
pub li catio ns.lbl.gov/sites/defa ul t/files/wo rking paper 005 batter y electric trucks 906 0.pdf.
3s i d.
39 id.
40 Nuclear Energy institute, supra not e 17 .
41 Lawrence Berk eley, supra not e 49 at 3.
42 California Air Resourc es Board , Clean Tru ck Total Cos t of Ownership Discuss ion, supra note 17 at 6.
43 i d.
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manufacturing battery capacity wi ll drop 50% between 20 18 an d 2023.4 4 This unexpected , rapid
scalin g of battery manufacturing is du e large ly to the fac t that "total manufacturing in vestment,
both previous and planned until 2023 , represents about $150 billion dollars."45 As battery prices
continue to decline , battery-electric tru cks wi ll beco me an even more favorable option when
compared to di esel or natura l gas trucks .
Not only are battery prices falling sign ificantl y, but battery techn o logy is progressing to
s uch an ex tent that it is technologically feasible for battery-e lectric se mi-tru cks to operate
effectively over the lon g ranges necessary for so me kind s of freight movement. The L BNL study
referenced above found that "rece nt techno lo gical deve lopments indicate that electric trucks , like
electric cars, can be full y charged in thirty minutes."46 This is consistent with cl ai ms by Tesla
that it s Tes la Semi can be fully charged in under thirty minutes . 47 Fast-charging is crucial for
freight movement, as approximately 40% of large semi-trucks travel 500 miles or more per
trip . 48 Each thirty-minute charging session is estimated to pro vi de 4-6 hours of dri ving time ,
allowing lon g-haul battery-electric truck operators to effectively compete wi th operators using
die sel and/or natural gas trn cks. 49 The ICCT stud y referenced above fo und that wi th fas t
charging, a battery-electric sem i-truck o perator wo uld spend a pprox im ately two hours charg in g
on a trip between Los Angeles an d C hi cago. 50 A lthough two ho urs is more time than a die se l o r
natural gas semi-trnck o perator wo uld spend refueling, ICCT concludes this time "does not
significantl y affect total dai ly dri vi ng time w ithin le ga l limits ."5 1 Therefore, not only are battery
prices falling dramati ca ll y, but battery technology is advancing exponenti a ll y, makin g it
te chno logically feasible fo r battery-electric trnck s to operate over both s hort and lon g ranges.
11. California 's Electric Utilities Have Committed Hundreds of Millions of Do llars to
Build Medium and H eavy-Duty C harging Infrastructure
While it has be en s hown that battery price s are falling signi fican tl y, and battery
techno logy is increas in g rapidl y, thi s means litt le if there is in sufficient charging infrastrucn1re .
Accordin g to CARB , chargi ng infrastructure ha s e merged as th e largest current iss ue preventing
the widespread usage of heavy-duty battery-electric trucks. 52 Fortunately, there has bee n
sign ificant in vestm ent by California public utilities in medium and heavy-du ty charging
infra structure . Further, the cost of charging infrastructure per ve hi cle dimini shes significantly as
44 Rock y Mou nt ain inst itute, Breakth rough Ba11eri es , at 14 (20 I 9) https://rmi .org/insight/breakthrou gh-
batteri es .
4; Id. at 7.
46 Lawrence Berke ley , s upra note 49 at 4.
41 Id.
48 Shashank Sripad and Vekatas ubramani an Viswanathan , Quantifying th e Economic Case for Electric
Semi-Trucks , at 149 (a vailable at htrps ://pubs.acs.org/doi /pd f/10.102 l /acsene rgy lett.8b02 146).
49 Lawrence Berkeley , s upra note 37 at 4.
50 The international Co un cil on Clean Transportation , supra note 4 at 17.
s1 Id.
52 Ca li fornia Air Resourc es Bo ard , Heavy -Duty Investm ent Strategy, at D-4 1 (Sep . 20 , 2019)
ht s://ww2.a rb .ca . ov/sites /defau lt/fi les/20 I 9-09 / I 920fu ndin Ian-a d. df.
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the volume of vehicles increases . Therefore, the utilities ' investment allows the battery-electric
semi-truck market to circumvent the high costs currently associated with early charging
infrastructure development, and helps to create economies of scale for future buyers .
The California Public Utilities Commission ("CPUC") has approv ed significant
investments proposed by California 's major pub li c utilities in medium and heavy-duty charging
infrastructure. 53 For example, in 2018 , the CPUC approved Pacific Gas & Electric 's ("PG&E")
proposed investment of$236 million to support medium and heavy-duty charging infrastructure
installations across the ir service territory. 54 The CPUC in 20 18 also approved Southern
California Edison 's ("SCE") proposed investment of$343 million to support medium and heavy-
duty charging infrastructure installations in its service territory. 55 ln 2019, the CPUC approved a
similar program proposed by the San Diego Gas and Electric ("SDG&E"), although the exact
do ll ar amount is unclear at this point. 56 Altogether, these investments will support the
deve lopment of charging infrastructure for at least 18,000 trucks and busses . Therefore, although
charging infrastructure is a significant barrier to widespread usage of heavy-duty vehicles, the
almost $ I billion dollars already committed to building this infrastructure by California 's utilities
is a huge step in overcoming this barrier.
This investment by California's utilities is vital because it has been shown that the cost of
charging infrastructure per truck diminishes significantly as the amount of infrastructure
installations increases . In the ICCT study referenced above , the ICCT calculates the expected
cost of charging infrastructure per C lass 8 long-haul battery-electric truck . With 100 trucks and
150 charging installations, the cost of infrastructure per vehicle is $189 ,000 .57 With 1,000 trucks
and 1,200 installations, the cost drops to$ I 14 ,000 per truck ; with I 0,000 trucks and 9,700
installations, the cost drops even further to $7 1,000 per truck . 58 The economies of scale
associated with charging infrastructure shows why the utilities ' inve stments are so crucial in
ensuring the technological feasibi I ity of battery-electric semi-trucks . The uti I ities ' committed
investment will help early battery-electric truck purchasers avoid the hi gh costs currently
associated with charging infrastructure. Further, the investment will aid the battery-electric
market generally, as these hundreds of mi llions of do ll ars will create the economies of scale
needed to significantly lower the cost of charging infrastructure for future buyers. This is part ly
why, as the ICF study shows, when these uti lity investments are incorporated into a TCO
analysis , large battery-electric semi-trucks currently have a favorable TCO when compared to
diesel. Thus, with these investments, the cost of charging infrastructure is no longer an obstacle
to the widespread usage of C lass 7 and 8 battery-electric semi-trucks at freight faci li ties.
53 In Concordance with SB 350 (D e Leon , Chapter 547 , Statu tes of2015),
https://www.cpuc.ca.go v/sb350te/.
54 Id.
s5 Id.
56 Id.
57 The International Counci l on Clean Transportation , supra not e 4 at i.
5 Id.
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B. Class 7 and Class 8 Baue,y-E/ectric Semi -Truck Models are Available for Purchase, and
Many Freight Facilities are Have Co mmilted to Ut ilizing these Tru cks
There are numerou s models of C lass 7 and 8 Battery-Electric semi-trucks that are
c urrentl y available for purchase, and are already in operation across the nation . Based on
company announcements , th e re are at lea st ten C la ss 7 or 8 models with ranges up to 55 0 m ile s
that are slated for commercial deploy ment by 202 1. 59 As early as January of 2018, 19 companies
had a lready ordered 375 Tesla Semis, w ith UPS ordering 125 and Pepsi Co ordering 100.60 BYD,
a Chinese zero-emission vehicle m anufacturer, announced in January 2 0 20 that it had deli vered
its I 00111 battery-e lectric truck within the U nited States, which was a second generation C las s 8
semi-truck. 6 1 The German company Daimler announced it delivered its first battery-electric
semi-truck in 2019, and had deli vered five more by early 2020. 62 Daimler is planning on
sign ificantl y increas ing the volume of its battery-e lectric semi-trucks on the road in 2021 . 63
Not only are there multiple C la ss 7 and 8 battery-electric semi-truck models available for
purchase and currently on the road, but many freight facilities have already committed to
incorporating th ese trucks into their fleets. Walm a rt announced that it will be opening a
fulfillment center in Britis h Columbia in 2 022 w hich will feature afully electric fleet.64
Anh e user-Busch announced in 20 18 that it had ordered 800 e le ctric and hydrogen semi-trucks. 65
Frito-Lay is currently working on upg rading a n ex istin g freight facility, wh ich w ill in c lude u se of
15 Tes la Semis and a I Megawatt photovo ltaic array with charging in fras tructure.66 Loblaw, a
Can adian supermarket company, has committed to full y transforming its fleet to zero em iss ion
vehicl es b y 2030, and had a lready ordered 25 Tes la Semis by late 20 17. 67 Further, the Port of
Los Angeles has committed to deployin g ten Kenworth and Toyota C lass 8 fuel cell trucks, and
59 Id. at 2 .
60 Bu siness Insider, Companies that Have Ordered Tesla Semis (A pril 25 , 20 18),
https :/ lwww.b usinessinsi der.com/companies-th a t-o rd ere d-tesla -semi -20 I 7-12.
61 BY D, BYD Delivers ifs JO(l h Bat1e1y-Electric Truck in th e United S tates (Ja n. 8, 2020),
https ://en . byd. com/news-pos ts/byd-de Ii vers-1 00th-ba tte ry-e lec tric -truck-in-the-uni ted-states/.
62 Electrek, Daim ler Delivers More Electric Freightliner eCascadia Sem i-Tn,cks (Mar. 4, 2020),
https ://electrek.co/2020/03 /04/daimler-electric-freightliner-semi -truck s-ecasca di a/.
63 Jd.
64 C leanTechni ca , Walman Orders 30 More Tesla Semi Electric Trucks (Sep. 7, 20 18),
https ://c leantec hnic a.com/2018/09/07 /walmart-ord ers-30 -more-tes la -se mi-electric-truck s/.
65 Transport Topics , Anheuser-Busch, N iko la , BYD Co mplete First Zero-Em ission Run (Nov. 2 1, 20 19),
http s://www.ttnews.com/articles/a nheuser-bu sc h-niko la-byd-complete-first-zero -em iss ion -beer-run .
66 Frito-Lay, Frito-lay Transforms California Production Site into First-of-its-Kind Showcase for
Sustainabilily (Oct. 3, 20 19), https://www .fritolay.com/news/fr it o-l ay -transforms-califomia-production-
site-into-first-of-its-kind-showcase-for-sustainability .
67 Financial Post, lob/aw Says it Ordered 25 Tesla Semis, Wan ts Fully Electric Flee t by 2030 (Nov . 17,
2017), http s://bus ine ss .financialpost.com/news /retail-marketing/loblaw-says-it-ordered-25-tes la-electric -
trucks-wants-ful ly-electric-fl eet-by-2030 .
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two battery-electric yard trac tors. 68 The South Coast Air Quality Management District has
committed to deployin g 23 Class 8 Volvo battery-electric trucks to move freight across the
Inland Empire. 69
In addition to multiple studies demonstratin g that battery-electric semi-trucks are cheaper
on a lifetime basis than diesel semi -trucks , these examples of semi-tmcks currently available for
purchase, and facilities committed to transforming their fleets , indicate that widespread usage of
Class 7 and 8 battery-electric tru cks at freight faci Ii ties is currently feasible .
C. California Regulatory Agencies are Aggressively Pushing for In creased Utilization of
Battery-Electric Semi-Tn1cks
Multiple government agencies within California are attempting to increase the number of
battery-electric semi-trucks on the road , through regu latory mandates , grant programs, and
incentive programs . These are in addition to the Low Carbon Fuel Standard, the HVIP program,
and the utility investments in charging infrastructure referenced above . In addition to the
favorab le TCO of battery-electric sem i-trucks, these various agency actions increase the
feasibi lity of widespread usage of these type s of truck s at freight faci lities .
The South Coast Air Quality Management District ("SCAQMD") has recentl y proposed
an Indirect Source Rule that would apply to freight facilities within the South Coast region,
where the Project is located. 70 Under this rule , freight facilities above I 00,000 square feet would
be required to accumulate a certain number of Warehouse Actions and Investments to Reduce
Emissions ("W AIRE") points per year. 71 W AIRE points can be generated through the purchase
and usage of zero-emission and near zero-emission equipment, including vehicles and charging
infra stmcture. 72 Zero-emissions and near-zero-emi ss ion truck trips also generate WA IRE points .
The most points that can be allocated for a singular action is for the purchase and usage of C lass
8 battery-e lectric or fuel cell trucks.73
SCAQMD cites the commercial availability of battery electric Class 7 and 8 trucks in the
technical document supplementing the regulatory language. 74 While the specific acquisition and
68 Ca lifornia Air Resourc es Board , CARB Announces M ore than $200 Million in New Funding for Clean
Freight J)·a nsportation (Sep . 26 , 2018), https ://ww2.arb.ca.gov/news /carb-announces-more -200 -milli on -
new-fundi ng-clea n-freight-tra nsportation .
69 Id.
70 South Coast Air Quality Mana gement Dis trict , Proposed Rul e 2305: Warehouse Indirect Source Rule
(Nov . I 0, 2019), http://www .agmd.gov/doc s/default-source/plannin g/fbmsm-docs /ware ho use-is r prelim-
1 st-draft.pdf?sfvrsn=6.
7 1 i d. at 2305 -3 .
72 South Coast Air Quality Management Di stric t, Draft W AIRE M enu Technical R ep ort al I (Mar. 3,
2020), h11p ://www.agm d.gov/docs /default-source/planning/fbmsm-docs /wa ire -men u-t ec hni ca l-
report draft 3-3-20.pdf?sfvrsn=6.
73 Id. at 2.
74 i d. at 4.
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Lead Agency: C ity of San Bernardino SCH No . 2020100067
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usage of Class 7 and Class 8 zero-emission tru cks is not per se required , this rule would strongly
incentivize, if not force , many freight facilities to acquire these types of trucks and/or ensure that
a certain number of truck trips made to their warehouse each year are by these trucks. With the
proposal of this rule , SCAQMD indicates that increased usage of Class 7 and 8 battery electric
trucks is feasible, and seeks to ensure more of these trucks are on the road.
SCAQMD is not the only California agency attempting to increase th e usage ofbattery-
electric trucks in the state. CARB has adopted its Advanced Clean Truck rule, which will
increase the number of zero-emission veh icl e s that medium-duty a nd heavy-duty manufacturers
are required to sell into California. 75 Further, CARB oversees an over $200 million program
designed to faci litate the transition to zero-emission frei ght fleets. 76 This CARB program funded
the deployment of zero-emission semi-trucks done by the Port of Los Angeles and the
SCAQMD, referenced above. CARB a lso oversees a grant program called the Carl Moyer
Memorial A ir Qua lity Standards Attainment Program. 77 This program provides funding to
vehicles that have less particulate matter and NOx emissions than is currently required by state
and federal law. ln addition, CARB oversees the Air Quality Improvement Program ("AQIP"),
which is almost exclusively used to provide financing for small fleet owners to purchase clean
fleets . 78
This is certainly not an exhaustive list of the grant programs and incentives avail ab le in
California. Altogether, CARB indicates that more than a dozen California agencies issue
hundreds of millions of dollars annually to support the deployment of heavy-duty vehicles. 79
These grant programs, regulations , and incentives further illustrate the feasibility of widespread
usage of battery-electric semi-trucks at freig ht faci li t ies. None of the TCO studies analyzed
above in corporate these programs and regulations into their calculation. Even without
consideri ng any of these, the TCO of a battery-electric semi-truck is currently less than a diesel
equivalent. W hen these programs , regulations , and incentives are also considered, the case for
the feasibility ofrequiring C lass 7 and 8 battery-electric semi-trucks at freight facilities becomes
even stronger.
i. There are Multiple Co-Benefits Associated with th e Widespread Us age of
Class 7 and 8 Zero-Emission Semi-Trucks at th e Proj ec t sit e
15 See generally Ca lifornia Air Resources Board , Advanced Clean Trucks Regula/ion ,
https ://ww2.ar b.ca.gov/rulcmakin g/2019 /advance dcl cantrucks .
76 California Air Resources Board , CARB A nn oun ces More th an $200 Million in New Funding /or Clean
fai ·eig ht Transportatio n (Sep . 26, 20 18), http s://ww2.a rb .ca .gov/ne ws /carb-announces-more-200 -million -
new-funding-clean -freight -transporr ation .
77 California Air Resources Board , Carl Moyer Air Quality Standards Attainment Program ,
https ://ww2 .arb .ca.gov/our-work/programs/carl-moyer-memorial-air-guality-standards-attainment-
program .
7s California Air Resourc es Board , AQIP Form al Regulatory Do cum ents ,
http s://ww2 .arb.ca.gov/resources/docum ent s/agip -forma l-regula to ry -documents .
79 California Air Resourc es Board , Heavy -Duty Investm ent Strategy, at D-90 (Sep . 20 , 20 19)
ht s ://ww2.a rb .ca . ov/sites/defau lt/fi les/20 I 9-09 / I 920fu ndin Ian-a d. df.
11
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A. Requiring the Usage of Class 7 and 8 /Jatte,y-1:,"lectric Semi-Trucks will Reduce local Air
Pollution
The operation of Class 7 and 8 diesel sem i-trucks within and around communities has
devastating, sometimes deadl y, air quality impacts. As mentioned above , diesel semi-trucks are
significant sources of particulate matter and NO, pollution. The impacts of these pollutants are
so severe that the International Agency for Research on Cancer, which is part of the World
Health Organization, ha s classified diesel exhaust as carcinogenic to humans . 80 According to the
California Office ofEnvirom11ental Health Hazard Assessment ("OEHHA"), particulate matter
pollution is linked to increased hospi tal vis its , emergency room visits , asthma attacks , and
premature death s among those suffe rin g from respiratory illne sses. 81 Children are especially
susceptible to this harmfol pollution, as their lungs and respiratory systems are still developi ng .82
NOx emissions are also quite harmfol , and can damage lun g tissue , lower the body's resistance to
respiratory infection, and worsen chronic lun g diseases . Further, NOx reacts with other pollutants
in the atmosphere to form ozone, a precursor to smog.83
C la ss 7 and 8 zero-emiss ion semi-trucks almost fully eliminate the creation of these
potentially deadl y pollutants. As referenced above, zero-emission ve hicles , including battery-
electric trucks , have no tailpipe emissions. The only significant air pollutant associated with
these semi-trucks is the particulate matter caused by braking. However, according to CARB ,
battery-electric trucks emit about 50% less particulate matter from braking than diesel semi-
trucks, through the use of "regenerative braking". Therefore, requiring the usage of C las s 7 and 8
zero -emission semi -truck s is not only economically and tech nologi ca lly feasible , but will provide
sign ificant health benefits to the people of Moreno Valley and surrounding areas . Thus , requiring
the usage of these trucks is not only required under CEQA as a feasible mitigation measure, but
is a moral imperative. No person within the community should be subjected to asthma, lung
cancer, or worse, when it is clearly possible to avoid th is .
8 . Requiring Us age of Class 7 and 8 Bat1e 1y -Electric Semi-Trucks will Aid California in
Reaching its GHG and Air Pollution Reduction Goals
California has multiple stringent GHG and air pollution reduction goals , and
electrification of freight fleets is a vi tal component to achieving these goals. California is
mandated under the federal C lean Air Act to reduce its air pollution consistent with the National
80 American Cancer Society, Di esel Exhaust and Cancer, https://www .cancer.org/cancer/cancer-
causes/diesel-e xhaust-and-
cancer.html#:~:text=The %20EP A %20classifies%20diesel%20exhaust ,a%20 %E2 %80%9Cpotential %20o
ccupationa l%20carcinogen.%E2 %80 %9D .
8 1 California Offic e of Health Hazard Assessment , Healih Effects of Diesel Exhaust (May 2 1, 200 I ),
https ://oehha.ca.gov /air/health-effects-diesel-exhaus t.
82 Id.
83 f d.
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Ambient Air Quality Standards ("NAAQS"). 84 Currently, the South Coast and Valley Air
Districts are out of compliance with the eight-hour and twenty-four-hour ozone standard. 85
According to CARB, an 80% reduction in truck and bus NOx tailpipe emissions is required by
2031 from 2019 levels to meet the NAAQS for the South Coast region . 86 As mentioned above,
diesel semi-trucks are a s ignificant source ofNOx tailpipe emissions, whereas battery-electric
semi-trucks have zero tailpipe emissions. Thus, requiring the usage of these vehicles at the
Project site will aid California in achieving compliance with the federal NAAQS.
California also has aggressive GHG reduction goals. State Bill 32 mandates that GHG
emissions be reduced 40% below 1990 levels by 2030. Executive Order S-3-05 mandates that
GHG emissions be reduced 80 % below 1990 levels by 2050 . Executive Order B-55-18 mandates
that California achieve economy-wide carbon neutrality by 2045 . According to a report by the
Energy Futures Initiative , meeting the goals for 2045 and 2050 will be "extremely
challenging."87 According to the ICF study mentioned above, deployment of I 00,000 electric
medium and heavy-duty vehicles is necessary to achieve both the 2030 and 2050 GHG reduction
goals. 88 Heav y-duty vehicles , including diesel semi-trucks , are a significant source of GHG
emissions. According to the Union of Concerned Scientists, heavy-duty vehicles constitute 10%
of vehicles in the United States , but emit 28 % of vehicle-related GHG emissions. 89 Battery-
electric trucks, as shown above , have significantly less life cycle GHG emissions than diesel
semi-trucks, and the GHG emissions from battery-electric trucks will continue to decrease as
California increases the proportion of electricity generated by renewable sources. Thus , requiring
usage of battery-electric semi-trucks at the Project site will aid California in meeting its
aspirational GHG emissions reduct ion goals .
C. Electrification of Freig ht Fleets has Po s itive Economic Impacts for California
In addition to the TCO calculation, the ICF study referenced above also analyzes the
economic impacts associated with electrification of freight fleets in the state of California. The
report concluded that widespread electrification has multiple positive economic impacts. For
one, transitioning from petroleum fuels to electricity allows funds that would otherwise flow out
of California 's economy to be retained within the state. 9° Further, investment in battery-electric
vehicles results in greater net employment, Gross Regional Product, and industrial activity per
dollar invested , when compared to investment in natural gas vehicles.9 1 Also , in vestment in the
84 ICF , s upra note 42 at 3.
8; Id.
86 id.
87 En ergy Futures Initiati ve, Optionality, Fl exibility, and Inn ovatio n: Path ways f o r Deep Decarbonizalion
in California at x (April 2019),
https ://stat ic 1.sguarespace.com/static/58ec I 23cb3db2bd94e057628 /t/5ca deb d04cd 61 c000 17a563b/ 15 549
0 1977873/EFI+Ca li forn ia +Summary+DE+PM.pd f.
88 ICF , supra note 42 at 28 .
89 Union of Concern ed Sci entists , s upra note 14 at 2.
90 ICF , s upra note 42 at 6.
91 Id.
13
Final EIR
Lead Agency: C ity of San Bernard ino SCH No . 2020100067
Page F-76
Comment Letter G
G-10
G-11
G-12
G-13
G-14
G-9(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
electrification of freight fleets results in a doubling of jobs in the medium and heavy-duty sectors
re lative to investment in natural gas and diesel ve h icles . 92 These economic benefits are consistent
with the findings of the LBNL. ln a letter to CARB regarding its Advanced Clean Truck Rule ,
LBNL indicates th at a mandate that manufacturers must sell 100% zero-emission vehicles across
all truck classes would result in $49 bi ll ion in savings to the state economy compared when to a
"business-as -usual " scenario. 93
This deep flaw in the DEIR is especia ll y rel evant beca use the scope of air quality and
GHG im pacts from this project.
III. The DEIR Sho uld Require Use of Solar Power.
The DElR includes no comm itment to use so lar power as a way to mitigate a ir quality
and GHG impacts. So lar is a common mitigation measure in simi lar warehouse projects, and as
such sho uld be implemented in this project as a mandatory mitigation measure .
IV. The DEIR Should Require Use of Zero-Emission Yard Equipment, Not Just
Alternative Fueled Yard Equipment as a Mitigation Measure.
The Project should requ ire the use of zero-emission cargo handling equipment as a
mitigation measure . This is a feasible mitigation measure and several comparab le projects are
ut ili zin g these types of technologies instead of re lying on combustion trucks .
V. The DEIR Must Includ e Additional Mitigation for Co ld Storage.
Cold storage facilities pose particularly acu te impacts to communities. As such , this
project does not include sufficient mitigation , including electrification ofTRUs and other
protections for the community.
VI. The DEIR Failed to Include its VMT Analysis
The DEIR failed to include a draft VMT technical analysis for public review and
comment. When clicking on the link to Appendix K-1 on the San Bernardino City website , a
wastewater flow assessment document comes up . As th e City is aware VMT ana lysis are critical
parts of the EIR process. The failure to include the un derlying technical report that forms the
bas is for the VMT analysis resu lts in a lack of meaningful process . The City should repost the
DEIR w ith the actual VMT ana lys is provided to the public for review .
92 Id.
93 Lawrence Berkeley Nationa l Laboratory, Letter lo CARB Regarding Proposed Am endments lo th e A CT
Standard Yi eld $! I Billion in Sa vings and 50% Emissons Reducli ons over Original Siandards (May 20 ,
2020), h s://www .arb .ca. ov/li sts /com-attac h/4122-ac t2 019-A WBdOAZ zAzMKYwF s. df.
14
Final EIR
]
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-77
Comment Letter G
G-15
•• ••
The Landing by San Manuel
Final Environmental Impact Report
We appreciate your consideration of these comments. Please do not hesitate to contact us J
at amartinez@earthjustice.org if you have questions about this comment letter.
Sincere ly,
~;(-~
Adrian Martinez
Attorneys for Earthjustice
15
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-78
RESPONSES TO COMMENT LETTER G
G-1 The commenter generally states that the Project will increase air pollution and that the DEIR needs to
address all feasible mitigation measures and alternatives and opines that the City should prepare a new
DEIR. There is no information provided in these comments or responses thereto that would warrant
recirculation of the DEIR. The DEIR circulated for public review was fundamentally and basically
adequate, and as such, recirculation of the DEIR is not warranted set forth in §15088.5 of the State
CEQA Guidelines.
G-2 The commenter accuses the DEIR of obfuscating impact disclosure, refers to the CARB comment
letter, and generally states that additional feasible mitigation is available to reduce air quality and GHG
impacts. Please refer above to Responses A-1 through A-25, which respond to comments submitted
by CARB and address the topic of feasible mitigation.
G-3 The commenter accurately states that the Project will result in air quality and GHG impacts associated
with vehicle travel to and from the site (tailpipe emissions) and opines that a requirement for zero-
emission (electric) vehicles would eliminate the impacts. The commenter then provides information
from various cited sources about Class 7 and 8 battery-electric semi trucks. To the commenter’s first
point, the City does not disagree that electric vehicle (EV) trucks are less impactful to air quality and
climate change than diesel-fueled trucks, but the City also recognizes that the production and disposal
of lithium-ion batteries used in electric vehicles produce GHG emissions and have other adverse
environmental consequences. To the commenter’s second point, the City rejects the suggestion that the
Project be required to only be serviced by EV trucks as infeasible based on the fact that EV trucks are
not yet in widespread commercial operation. According to the International Council on Clean
Transportation and the ZEV Alliance, it is recognized that although EV manufacturers are scaling up
production, battery technologies are improving, and heavier-duty vehicle applications with larger
battery capacities are being developed, no vehicle segment is fully prepared for market
commercialization (ZEV Alliance, 2000).7
Also, the City has no ability or capacity to exclude vehicles that are permitted to be driven on public
roads from accessing the Project Site. It is the responsibility of federal and State agencies to regulate
the types of vehicles sold and driven in California. In June, 2020, CARB adopted a new Rule
(Advanced Clean Trucks Regulation) that is the strictest in the United States, requiring truck
manufacturers to transition from diesel trucks and vans to electric zero-emission trucks beginning in
2024. By 2045, every new truck sold in California will be required to be zero-emission. When
commercial availability of electric-powered long-haul trucks is more readily available in the future, it
is expected that such trucks will be part of the Project’s normal course of operation.
The Project Applicant and City of San Bernardino have applied forethought in developing the Project’s
design features and mitigation measures to assist in advancing the use of zero-emission trucks. The
southwestern corner of the Development Site is designed as a truck staging area where truck charging
7 ZEV Alliance, “Moving Zero-Emission Freight Toward Commercialization,” December 20, 2020
TThe Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-79
stations will be accommodated. DEIR Mitigation Measure MM 4.4-1 requires that the building’s
electrical room be sufficiently sized to hold additional panels to supply power for the future installation
of EV truck charging stations on the site at this location. The San Manuel Band of Mission Indians is
the Project Applicant and is voluntarily actively engaged with solar and electric vehicle industry
leaders, such as Tesla, to advance the accommodation of EV vehicles. To this end, the Project’s
building specifications include electrical switchgear and the truck staging area is designed to accept a
technologically advanced electrical charging system to meet prospective building user requirements
for EV truck charging. As a speculative development, it is not possible to forecast what an actual
future user of the building may need or require in terms of EV truck charging, as the needs vary widely
among building users and the technology is rapidly advancing. The Project’s EV charging facilities
for trucks will be tailored to the needs of the building user, because committing to a system too early
and then needing to retrofit it to meet building user specifications is technologically and cost
prohibitive. The Project Applicant’s commitment to energy sensitive design is appreciated by the City,
and is viewed as environmentally responsible.
G-4 The commenter provides information from various cited sources about California’s public utility
companies’ investments in EV charging infrastructure. The City appreciates this information, and as
noted in Response G-3 above, is committed to the Project’s design accommodating electric trucks and
charging stations by providing a truck staging area with charging station infrastructure in the
southwestern corner of the Project Site.
G-5 The commenter provides information about manufacturing companies that are deploying electric
trucks to the United States and about large companies that are ordering electric trucks from these
manufacturers. The commenter also provides information about California governmental agencies’
efforts to increase the utilization of battery-electric semi-trucks. The City appreciates this information.
As stated above in Response G-3, the City is aware, and agrees with the commenter that EV
manufacturers are scaling up production, battery technologies are improving, and heavier-duty vehicle
applications with larger battery capacities are being developed. However, and as commenter notes,
some of the largest companies in the United States (UPS, PepsiCo, etc.) have only ordered a few
hundred of these trucks, whereas there are nearly 3.63 million registered (non-electric) Class 8 trucks
in the country.8 This clearly shows that there is not yet widespread commercialization. As noted in
Response G-3, the Project Applicant and City of San Bernardino have applied forethought in
developing the Project’s design features and mitigation measures to assist in attracting zero-emission
trucks to the Project Site. The southwestern corner of the Development Site is designed as a truck
staging area where truck charging stations will be accommodated. Also, DEIR Mitigation Measure
MM 4.4-1 requires that the building’s electrical room be sufficiently sized to hold additional panels to
supply power for the future installation of EV truck charging stations on the site.
G-6 The commenter supplies general information about the air quality emissions and associated effects on
human health resulting from diesel-fueled vehicle tailpipe emissions, and states that zero-emission
vehicles have fewer human health effects. DEIR Subsection 4.1, Air Quality, and DEIR Technical
Appendix B1, Air Quality Impact Analysis, and Technical Appendix B2, Health Risk Assessment (HRA),
HYDOXDWHWKHWKH3URMHFW¶VDLUSROOXWDQWHPLVVLRQVDQGDVVRFLDWHGULVNVWRKXPDQKHDOWKGXULQJ3URMHFW
8 Owner-Operator Independent Drivers Association, “Trucking Facts” https://www.ooida.com/trucking-facts/
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-80
construction and operation. As concluded in these studies and summarized on DEIR Pages 4.1-32 and
33, the Project would have a less than significant impact human health using the significance criteria
promogulated by the SCAQMD for carcinogenic risk of 10 in one million. The SCAQMD is the
agency charged with bringing air quality levels in the South Coast Air Basin to acceptable levels. Non-
cancer risks were also evaluated and determined to be far below the SCAQMD non-cancer health risk
index threshold of 1.0.
G-7 The commenter states that using Class 7 and Class 8 zero-emission semi trucks for the Project’s
operation will provide health benefits to the residents of Moreno Valley. The proposed Project is
located in the City of San Bernardino, and it is unclear how the City of Moreno Valley would be
benefited. Regardless, and as noted above in Responses G-3 through G-6, the City of San Bernardino
has determined because EV trucks are not yet in widespread commercial operation and because the
City has no ability, capacity, or jurisdictional authority to exclude vehicles from the Project site that
are permitted to be driven on public roads in California, limiting the Project’s operation to only zero-
emission semi trucks is infeasible. When commercial availability of electric-powered long-haul trucks
is more readily available in the future, it is expected that such trucks will be part of the Project’s normal
course of operation. The Project Applicant and City of San Bernardino have applied forethought in
developing the Project’s design features and mitigation measures to assist in advancing the use of zero-
emission trucks. The southwestern corner of the Development Site is designed as a truck staging area
where truck charging stations will be accommodated. Also, DEIR Mitigation Measure MM 4.4-1
requires that the building’s electrical room be sufficiently sized to hold additional panels to supply
power for the future installation of EV truck charging stations on the site.
G-8 The commenter provides information about air pollution in the South Coast Air Basin particularly
related to NOx from vehicle tailpipes. The commenter also provides information about Statewide
GHG reduction goals and cites information indicating that the transition to electric vehicles will help
to meet those goals, concluding that the City should only require battery-electric semi trucks to operate
at the Project site. Refer to Responses G-3, G-4, and G-7, above. In summary, the City has determined
that because EV trucks are not yet in widespread commercial operation and because the City has no
ability, capacity, or jurisdictional authority to exclude vehicles from the Project site that are permitted
to be driven on public roads in California, limiting the Project’s operation to only zero-emission semi
trucks is infeasible from both technological and enforcement ability standpoints.
G-9 The commenter supplies general information about the economic benefits of using battery-electric semi
trucks. No specific comments are made that warrant a response or revision to the DEIR.
G-10 The commenter states that the DEIR is flawed due the scope of the Project’s air quality and GHG
impacts. The City disagrees. The DEIR is supported by several technical studies and technical
modeling prepared by professional experts in the fields of air quality and GHG emissions. Refer to
DEIR Technical Appendix B1, Air Quality Impact Analysis, Technical Appendix B2, Health Risk
Assessment (HRA), and Technical Appendix G, Greenhouse Gas Analysis. The analytical results show
that the Project will result in significant and unavoidable air quality emissions and GHG emissions, as
reported in the DEIR. As CEQA Lead Agency, it is the City of San Bernardino’s obligation to adopted
Findings and a Statement of Overriding Considerations should the City decide to certify the EIR and
approve the Project.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-81
G-11 The commenter indicates that there is no requirement to use solar power. Refer to Mitigation Measure
MM 4.4-1(d) and the addition thereto presented in Response C-19, which requires that the shell
building include a PV system providing a minimum of 24 KW of power per year (subject to FAA
approval), and that the remainder of the building’s roof be designed and constructed to accommodate
the potential future construction of additional photovoltaic (PV) solar arrays.
G-12 The commenter suggests that the Project’s outdoor cargo handling equipment be electric. DEIR
Mitigation Measure MM 4.1-7 requires that the Project developer and all successors in interest stipulate
in building sale and lease agreements that all indoor and outdoor forklifts and all outdoor cargo-
handling equipment (e.g., yard trucks, hostlers, yard goats, pallet jacks, forklifts) be electric or non-
diesel fueled. Because the City has no involvement in private lease negotiations among and between
private building owners and building tenants, it is recognized that this mitigation measure will not be
enforceable by the City. Nonetheless, this type of equipment is in widespread commercial circulation,
is not prohibitively expensive, and is commonly used in new warehouse operations; as such, there is
reasonable assurance that the provision will be complied with as part of the normal course of business
operations.
G-13 The commenter states that the DEIR applies insufficient mitigation to address TRUs. In response to
this comment, the following mitigation measure has been added to the FEIR.
MM 4.4-2: Prior to the issuance of a building permit for warehouse building space that contains
refrigerated or freezer storage, an electrical hookup shall be provided at all loading dock
doors that are designated for the loading/unloading of trailers holding refrigerated/frozen
goods, for the purpose of plugging the refrigeration units installed on such trailers into
the building’s electrical system. If refrigerated/freezer warehouse space is not proposed,
electrical hookups at dock doors will not be required.
G-14 The commenter states that DEIR Appendix K-1 was incorrectly posted on the City’s website. The City
corrected the website link on January 7, 2021. The public notices for the DEIR listed the City’s contact
information and stated that copies of the DEIR and Technical Appendices were available for review at
the City. As such, the public had adequate access to Appendix K-1 even though there was an initial
error in the website posting.
G-15 This is a closing comment that provides the commenter’s contact information.
Page F-82
Comment Letter H1
H1-1
H1-2
H1-3
•• ••
The Landing by San Manuel
Final Environmental Impact Report
BLUM CO LLINS , LLP
ATTORNEYS AT LAW
AON CENTER
707 WILSH IRE BOU LEVA RD, SUITE4880
LOS ANGE LES, CA LI FORN IA 9001 7
(213) 572 -0400
J an ua1y 11., 202 1
Elizabe th Mora-R o dri guez
Cily of San B e llladino, Pl anning Di vision
290 o rth D Street
San Bellladin o, CA 9240 I
Re: The L111mi1g by Sa11 Af.wuel Prqject (SCH N umbe1: 20200100067)
D ear Ms. Mo ra -Rod1igu ez:
On be half of the G o ld e n State E nvi ro nme ntal Justi ce Allian ce ("GSEJA"), we he re by submi t
conune n ts unde r the Californi a Enviro1m1e ntal Quality Act ("CEQA") o n th e Draft
Environme ntal Impac t Re p ort ("DEIR") fo r The Landing by San Manuel Project ("Proj ect").
GSEJA believes that tl1 c Proj ect's air quali ty, hea lth risk , and gTc c nhousc gas impac ts ar c no t
ad e quately evaluate d by !h e D E ffi. See th e co nm1 e nts o f Soil vVate r Air Protection Enterpri se
("S \iVAPE") whi ch we are submitting herewith and incorporating by refe re nce.
For the fo rego ing reason s, GSEJA be li eves th e DEIR is fl awed and an am e nde d DEIR must be
pre pare d fo r th e p roposed proj ect and rec ir culate d fo r publi c revi ew. CS_EJA requests to b e
added to tl1 e p ubli c inte rest list regarding an y subseque nt e nvironm e ntal d o cume nts, publi c
notices, publi c heaiings, and no ti ces o f d eterminatio n lo r t11is project. Send all communica tions to
Golden State Envir o nme ntal]us ti ce Al li ance, P .O. Box 79222, Corona , CA 92877.
Since rely,
Gar y Ho
Blum I Collins , LLP
J
J
Final EIR
Lead Agency: City of San Bernardino SCH No , 2020100067
Page F-83
Comment Letter H1
H1-4
H1-5
•• ••
The Landing by San Manuel
Final Environmental Impact Report
I SWAP E I Technical Consu ltation , Data Analysis and
Litigation Support for the Environment .__ _____ _.
January 4, 2021
Gary Ho
Blu m Co ll i ns LLP
707 Wi lsh i re Blvd, Ste . 4880
Los Ange les, CA 90017
2656 29 th Street, Suite 201
Sa nta Monica , CA 90405
Matt Hagemann , P.G, C.Hg .
(949) 88 7-9013
mhageman n@swape .com
Pau l E. Rosenfeld, PhD
(310) 795-2335
prosenfeld@ swape.com
Subject : Comments on The Land in g by San Manuel Project (SCH No . 20200 100067)
Dear Mr. Ho,
We have reviewe d the Draft En vironmental Impact Report ("D EI R") for The Landing by San Manuel
{"Project") located in the City of San Bernardino ("C ity"). The Project proposes to con struct 1,153,644-SF
of warehouse space, 365 truck trailer parking stalls, and 422 passenger ve hicle parking spaces on the
52 .97-acre site.
Our review concludes that the DE IR fails to adequately eval uate the Project's air quality, health r isk, and
greenhouse gas i m pacts. As a result, emissions and health risk i mpacts associated with construction and
operation of t he proposed Project are underest imated and inadequately addressed. An updated EIR
shou ld be prepared to adequately assess and m itigate the potential air quality, health risk, and
greenhouse gas i m pacts that the project may have on the surrou nding environment.
Air Quality
Unsubstantiated Input Parameters Used to Estimate Project Emissions
The DEIR's air q uality analysis re li es on emissions calc ul ated with CalEEMod .2016 .3 .2 (p. 4.4-22).1
CalEEMod provides recommended default values b ased on site-specific information, such as land use
typ e, meteorologica l data, total lot acreage, project type and typical equ i pment associated with project
t ype . If more spec ific project information is known, the user can change the default values and input
proj ect-specific val ues, but t he California Env i ronmental Qua l ity Act ("CEQA") req uires that suc h changes
1 CAPCOA (November 2017) CalEEMod User's Guide , http://www.aqmd.gov/docs/default-
sou rce/ca lee mod/01 _ user-39-s-g u ide 2016-3-2 _ 15 nave mbe r2 017. pdf? sfvrsn=4 .
Final EIR
Lead Agency: C ity of San Bernardino SCH No . 2020100067
Page F-84
Comment Letter H1
H1-6
H1-5(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
be justified by substantial evidence.2 Once all of the value s are inputted into the mode l, the Project's
construction and operational emissions are calcu lated, and "output files" are generated . These output
fi les di sclose to the reader what pa rameters were util ized in ca lculating the Project's air pollutant
emissions and make known which default values were changed as well as provide justification for the
value s selected .'
When reviewing the Project's CalEEMod output files, provided in the Air Quality Impact Analysi s
("AQIA") as Appendix Bl to the DEIR , we found that severa l model i nputs were not consistent with
information disclosed in the DEIR . As a result, the Project's construction and operational emission s are
underestim ated. An updated EIR should be prepared to include an updated air quality analysis that
adequately evaluates the impacts that con struction and operation of the Project will have on local and
regional air quality.
Unsubstantiated Changes to Individual Construction Phase Lengths
Revi ew of the CalEEMod output files de monstrates that ''The Landing at San Manuel {Wate r Tower
Re lo cation -Unmitigated)" model includes an unsubstantiated change to the anticipated demolition
construction phase length (see excerpt below) (Appendix Bl, pp . 130, 143 ).
Table Name Cot,mnName Default Value New Value
tblConstructlonPhase : NumDays : 10.00 15.00
------. ------. --.. -.. ---. -.. -. --.. -...... -.. -.... -... -..... ~-----------------------------
tblConstructionPhase : PhaseEndOate : 4/5/2021 4/12/2021
------. ---------.. -. ---. --.. -.:. --. --.. -.. --.. -.. -..... -. -.. -~-------------------------------------·
As a result of this change, the model includes a construction schedu le as follows (Appendi x Bl, pp . 133,
146):
Phase
Nu mber
Phase Name Phase Type Start Date End Date Num Days Num Days
Week
:Dis mantli ng Existing Water Tower :Demolition ;3123/202 1 ;4/1212021 s: 1s :
As demonstrated in the excerpts above, the demolition phase was increased by SO%, from the default
value of 10 to 15 days, in "The Landing at San Manuel {Water Tower Relocation -Unmitigated)" model.
Similarly, review of the CalEEMod output files demonstrates that "The Landing by San Manuel
{Const ruction -Mitigated)" model includes un substantiated changes to the anticipated individual
construction phase length s (see excerpt below) {Appendi x Bl, pp. 307, 382 ).
2 CalEEMod User Guide , available at: http ://www.caleemod.com/, p. 1, 9.
3 CalEEMod User Guide, available at: http://www.caleemod .com/, p. 11, 12 -13. A key feature of the Ca lEEMod
program is the "re mar ks" feature , where the user explains why a default setting was replaced by a "user defined "
value . The se remar ks are inc luded in the report.
2
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-85
Comment Letter H1
H1-6(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Table Name Coomn Name Default Value New Value I
I ....... :;~;_:;;;_~:_:_~ ....... l ........... ;;~_;;._ -.. --.. --. :_______ 1 .::·:00 ----!-......... _;:;_. -....... -I
tblConstruetionPhase : NumDays : 110.00 60.00 ----------------. ------------.; -----. --. -. ------------------+-------------------------------
As a re sult of these change s, the model includes a cons t ruction schedule as follows (Appendix Bl, pp.
358,433):
Phase
Num be r
Phase Nam e Phase Type St art Date End Date Num Days Num Days
Week
:Site Preparation/Grad ing :Grading :s/1/202 1 :1/231202 1 : s: so:
· - -- ---~ -- -- - · - -· --· --- - · -- · ----1---------•••• --•••• ····1------------4------------4--------4--------4 2 :Building Constr uction :Bu ilding Construction :7124/202 1 :4/29/2022 : s: 200 :
• • • • -••I • - • • • • • • • • • • • • • • · --• • • • • 1-----------------------1------------~------------.J--------~--------•
3 :Architectu ral Coati ng :Architect ural Coating : 10/2/202 1 :4129/2022 : s: 1so :
••••••• i, •••••.••.•••••••.••.•••• ~-·-------------·--------~--------·---I ---·----·----I ------·--· --·----·-I
4 ;Paving/Landscaping ;Paving ; 1115/2022 ;4129/2022 5; 75;
As demonstrated in the excerpts above, the site preparation/gradi ng pha se wa s decrea sed by
approximately 45 %, from the default value of 110 to 60 days; the building con struction pha se wa s
dec reased by approximately 82 %, from the default va lu e of 1,110 to 200 days; and the architectural
coating pha se wa s increa sed by 100%, from the default value of 75 to 150 days, i n "The Landing by San
Manuel (Construction -Mitigated)" model.
As previou sly mentioned, the CalEEMod User's Guid e requires any changes to model defaults be
justified .4 According to the "User Entered Comments & Non-Default Data " table for "The Landing at San
Manuel (Water Tower Relocation -Unmitigated)" model, the justification provided for this change is :
"Water Tower Relocation ant icipated to occur over a 15 day timeframe " (Appendix Bl, pp . 130, 143).
According to the "User Entered Comments & Non-Default Data" table for "The Landing by San Manuel
{Const ruction -Mitigated)" model, the justification provided for these change s is : "Con struction
schedule ba sed on information provided by the Project Appl ic ant" {Appendi x Bl, pp. 306, 381).
Furthermore, regarding the Project's ant icipated const ruction schedule, the AQIA states :
"For purposes of analysi s, Water Tower Relo cation activities will begin in Marc h 2021 and end in
Apri l 2021. Phy sical Building Construction activities are expected to commence in May 2021 and
w ill last through April 2022 " (p . 41).
As the ex cerpt above demon strates, while t he AIQA states the ove rall anticipated construction period,
the DEIR fail s to specify the individual con st r uction phase lengths. As a result, we cannot verify t he
revi sed individua l con stru ction pha se lengths included in the model s. Th es e un sub stantiated change s
pre sent an issue , as they improperly spread out construction em issions over a longer period of time for
4 CalEEMod Use r Guide , available a t: http://www.caleemod.com/, p. 2, 9
3
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-86
Comment Letter H1
H1-7
H1-6(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
some con struction pha ses and not others. According to the Ca l EEMod User's Guide, each con struction
phase is as sociated w ith different emiss ion s activit ies (see excerpt be low). 5
Demolition involves removing build ings or structures .
Site Pre paration involves clearing vegetation (gru bbin g and tree /stump removal) and
removing stones and other unwanted materia l or debris prior to grad ing .
~involves the cu t and fill of land to ensure that the proper base and slope is created
for the foundation.
Building Construction involves the construction of the foundat ion , struc tures and buildings .
Architectura l Coating involves the appl ication of coatings to both the interior and exterior of
buildings or structures . the painting of park ing lot or pa rking garage striping . associated
signage and curbs , and the pain ting of the walls or othe r compone nts such as sta ir rail ings
ins ide parking struc tures .
Pa vinq involves the laying of concre te or as pha lt such as in parking lots . roads . driveways ,
or sidewalks .
As such, by disproportionate ly altering i nd ividual constructi on pha se lengt hs without proper
justifica t io n, t he models' ca lculations are altered and un derest imate em ission s. Thus, by inclu d ing
unsubstantiated changes to t he Project's antici pated individual construction pha se lengths, the models
may u nd ere st i mate the Project's maximum d ai ly const r ucti on-related emi ss ions and shoul d not be
relied upon to d et erm i ne the significance of the Project's air quality impacts.
Unsubstantiated Reductions to Architectural Coating Emission Factors
Rev i ew of the CalEEMo d output files demonstrates that ''The Landing by San Man uel {Construction -
M itigated)" model includes manual reduct ion s to the Project's architect ura l coating emiss ion factors
(see exce rpt be low) (Appendix Bl, pp . 306, 381).
Table Name I Colim n Name I Default Value New Value
tblAtchitectu ralCoating : EF _Norvesidential_Exterior : 100.00 50.00
... -... -.. ---------. ---------~ --------. ---------. --.. -----. ~--------·---------------------
tblArch ilecturalCoating : EF _Nonresidential_lnlerior : 100.00 50.00
............. --.. -.. -.. ---. --.,. -. ---. --. ------. --.. -... -.... .S..-·---·----·---·--------------------------..
As you can see in the excerpt above , the nonresi dential exterio r and i nterior arc hitectura l coat ing
emiss ion factors were each manually re d uced from t he default value of 100 grams per l iter ("g/L") to 50
g/L. As previou sly mentioned , the Ca l EEMod User's Guide requires any changes to model defau lts be
just ified .6 According to t he "User Entered Comments and Non-Defau lt Data" tab le, the justification
provided fo r t hese changes is: "Rule 1113" (Appendix Bl, pp . 305, 380). Furthermore, the DEIR includes
Regu latory Requirements & De sign Requirement ("RRDR") 4 .1-3, w hich states:
"Th e Project is required to comply with the provisi ons of SCAQ M D Rule 1113, "Tab le of
Standards for A rchitectural Coatings, Volatile Organic Compound (VOC) Limits." Prior to bu ild i ng
permit issuance, the City of San Bernard ino shall verify that a note is provided on all bu i ld ing
5 "CalEEMod User 's Gu ide ." CAP COA, November 2017, available at: http:ljwww.agmd .gov/doc s/default-
source/ca leemod/Ol user-39 -s-guide2016-3 -2 1Snovember2017 .pdf?sfvrsn=4, p. 31.
6 CalEEMod Use r Guide , available a t: http://www.caleemod.com/, p. 2, 9
4
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-87
Comment Letter H1
H1-8
H1-7(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
plans specifying that compliance with SCAQMD Rule 1113 is mandatory during application of all
architectural coatings . Project contractors shall be required to comply with the note and
m aintain written records of such comp liance that can be inspected by the City of San Bernardino
upon req uest. All architectural coatings sha ll comply with the VOC limits prescribed by SCAQMD
Ru le 1113" (p . S-16).
However, we cannot verify the accuracy of the revised architectural coating emission factors based on
SCAQMD Rul e 1113 alone . The SCAQMD Rule 1113 Table of Standards provides the required VOC limits
(grams ofVOC per liter of coating) for 57 d ifferent coating categories (e.g., Floor coatings, Fau x Finishing
Coatings, Fire-Proofing Coatings, Cement Coatings, Multi-Co lor Coatings, Prim ers, Sea lers, Recycled
Coatings, Shellac, Stains, Traffic Coatings, Waterproofing Sealers, Wood Coatings, etc.).7 The VOC lim it s
for each coating varie s from a minimum value of 50 g/L to a maximum value of 730 g/L. However, the
DEIR and associated documents fail to mention what type of coating will be used. As such, we cannot
verify that SCAQMD Rule 1113 substantiate s a reduction to the default coating values without more
information regarding what category of coating will be used. Absent additional information regarding
which categories of coating would be used for Project construction, we can not compare the revised
em iss ion factors with the SCAQMD Rule 1113 requirements for those categories .
These unsubstantiated reductions present an issue, as CalEEMod uses the architectural coat ing emission
factors to calculate the Project's reactive organic gas/vo la ti le organic compound ("ROG "/'VOC")
em issions.• Thus, by including unsubstantiated reductions to the Project's architectural emission factors,
the model s may underestimate the Project 's construction-related RO G/VOC emissions and should not
be relied upon to determine Project significance .
Unsubstantiated Reductions to Hauling Trip Numbers
Review of the CalEEMod output files demonstrates that "T he Landing at San Manuel (Water Tower
Re location -Unmitigated)" and ''T he Landing by San Manuel (Co ns t ru ction -Mitigated)" models include
manual reductions to the number of hau ling tri ps required for Project construction (see excerpts below)
(Appendix Bl, pp . 130, 143,308,383).
"The Landing at San Manuel (Water Tower Relocation -Unmitigated)" I Table Name I Coomn Name I Default Value New Value
r · --------tbITripsAnd VMT---. --.. ·; · -.. -.. "HiUunQTriPNUmt>ef -------; 40.00 30.00
"The Landing by San Manuel (Construction -Mitigated)" I Table Name I Col.lmn Name I Default Value New Value
[ ••••• _ ••
0
tb1TripsAndVM T •• _____ • l .. ___ . __ HaulingTripNu mber •••• _ •• .;_ ___________ 1,000 .00 ___________ _.i ____ ,o_.oo ___ _
7 SCAQMD Rul e 1113 Adv isory Notice ." SCAQMD, February 2016, available at:
http://www.agmd .gov/docs/default-source/rule-book/reg-xi/rl1l3 .pdf?sfvrsn=24 , p. 1113-14, Tab le of Standards
1.
8 CalEEMod User Guide, available at: http://www.agmd .gov/docs/default-source/caleemod/01 user-39-s -
guide2016-3-2 15november2017.pdf?sfvrsn=4 , p. 35, 40.
5
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-88
Comment Letter H1
H1-9
H1-10
H1-8(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
As you can see in the excerpts above, the number of hau ling trips required for water tower re l ocation
and Project const ruction were reduced by 10-and 990-trips, respectively . As previously mentioned, t he
CalEEMod User's Guide requires a ny changes to model defaults be j ust ified . 9 According to the
co rrespon d ing "User Entered Comme nts & Non-Defau lt Data" t abl es, the justificat ions provided for
these changes are: "Based on information provided by the Project Applicant, 300 tons demo materia l
hau led offsite, max of 10 miles during Water Tower Relocation activ ities" and "Ba sed on information
provided by the Project Applicant, 100 tons demo material hau led offsite, max of 10 miles during Site
Preparation/Grad ing activities," respect ively (Appendix Bl, pp . 130, 143, 306, 381). However, the DE IR
fa ils to d i sclose the applica nt-provided information o r mention the revised hauling trip numbers
whatsoever. As a resu lt, we cannot verify the revised hau l ing trip numbers. By including an
unsubstanti ated reduction to t he anticipat ed number of hauli ng trips, t he models may unde restimate
the Project's construction-related emissio ns an d sho ul d not be re lied upon to determine Project
significance.
Unsubstantiated Change to Operational Off-Road Equipment Fuel Type
Rev i ew of the Project's CalEEMod output fi les demonst ra t es that the "The Landing by San Manuel
(Operations -Passenger Cars)" and "The Lan d ing by San Manuel (Opera t ions -Trucks)" models assume
t hat the Project's operational off-road equipment fuel ty pe wil l be com pressed natural gas ("CNG "), as
opposed to t he defau lt diesel f uel type (see excerpt be low) (Appendix Bl, pp. 459, 521, 585, 648).
Table Name Cot,mn Name Default Value I New Value
CNG
As previous ly mentioned, the Ca l EEMod User's Guide requires any changes to model d efaults be
justified.10 According to the User Entered Comments and Non-Defau lt Data tab le, the justification
provided fo r this change is: "Based on SCAQMD High Cube Ware house Truck Trip Study White Pa per
Summary o f Business Survey Re sults (2014)" (Appendix Bl, pp . 458,520,584,647). However, review of
this source revea ls that the study fai ls to mention the use of compressed natural gas ("CNG")
w hatsoever." Thus, we cannot verify that the operational off-road equipment fuel type woul d be CNG
as clai med. By i nclud ing an unsubstantiated change to the defau lt operational off-road construction
equipment f uel type, the mode l may underestimate the Project's off-road operational em i ssio ns and
shou ld not be relied upon to determine Project significance.
Use of an Unsubstantiated Operational Vehicle Fleet Mix
Re vi ew of the Pro j ect's CalEEMod output fil es demonstrates that emissi ons were modeled assumi ng an
i ncorrect operationa l vehicle fleet mix. As a result, the models underestimate the Project's mob ile -
source operational emissions .
9 CalEEMod User Guide, available at: http://www.caleemod .co m/, p. 2, 9
1° CalEEMod User Guide, available at: http ://www.cal ee mod.com/, p. 2, 9
11 SCAQMD High Cube Warehouse Truck Trip Study White Paper Summary of Business Survey Results (2014),
available at: http ://www.agmd .gov/docs/default-source/cega/handbook/high-cube-warehouse-trip-rate-study-
for-a i r-g ual ity-a nal ysis/b usi ness-su rvey -s u mma ry . pdf
6
Final EIR
l
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-89
Comment Letter H1
H1-10(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Specifically, review of the Traffic Analysi s ("TA"), provided as Appendix K2 to the DEIR, demonstrates
that the Project relies upon the Western Riverside Council of Governments ("WRCOG") High -Cube
Warehouse Trip Generation Study for the proposed high-cube fulfillment center warehouse land use
fleet mix percentages (Appendix K2, p . 55). Specifica lly, the TA states:
"High -Cube Fulfillment Center Warehouse ha s been used to derive site specific trip generation
estimates for up to 769,096 square feet (2/3 of the total building square footage). The ITE Trip
Generation Manual Supplement (February 2020) has trip generation rates for high -cube
fulfillment center use for both non-sort and sort facilities (ITE land use code 155). While there is
sufficient data to support use of the trip generation rates for non-sort facilitie s, the sort faci lity
rate appears to be unreliable because they are based on limited data (i.e ., one to two surveyed
sites). The proposed Project is speculative and whether a non-sort or sort facility end -user
would occupy the buildings is not known at this time. Lastly, the IT E Trip Generation Handbook
recommend s the use of local data sources where avai lab le. (10) As such, the be st available
source for high -cube fulfilment center use would be the tri p-generation statistics published in
the High-Cube Warehouse Trip Generation Study (WSP. January 29. 2019) which was
commissioned by the Western Riverside Council of Governments (WRCOG/ in support of the
Transportation Un iform Mitigation Fee (TUMF) update in the County of Riverside" (emphasis
added) (Appendix K2, p. 55).
As you can see i n the excerpt above, t he DEIR relies upon the WSP High-Cube Warehouse Trip
Gen eration Study repo rt from 2019 .12 However, review of the 2019 WRCOG Technical Advi sory
Comm ittee Agenda, wh ich includes the above -mentioned study, demon strates that this study is not
recommended to repre sent high -cube fulfillment centers . Specifically, the Technical Advi sory Committee
Agenda states:
"For purposes of establishing traffic i mpacts or development fees, the group of facilities that the
con sul tant studied does NOT represent Fulfillment Centers. Thi s is also reinforced by the data
plot diagrams from the consultant's report" (emphasis added).13
As such , the DEIR's use of fleet mix pe rcentage value s provided by th is report for the Project's high -cube
fulfil l ment center warehouse is incorrect . As a result, we cannot verify the accuracy of the revised fleet
mi x percentage values in the model. By relying on unsubstantiated fleet mix percentages, the models
may underestimate the Project's mobile-source operational emissions, as CalEEMod use s the fleet mix
percentages to calcu late the Project's operational emissions as sociated with on -road vehicles ." As a
result, the model s should not be relied upon to determine Project si gnificance.
12 "AGENDA : Thur sday, February 21, 2019 ." We stern Riverside Council of Governments Technical Advisory
Committee, available at: https ://wrcog .us/AgendaCenterNiewFile/Agenda/ 02212019-292 , p. 64 .
13 "AGENDA : Thur sday, February 21, 2019 ." We stern River side Council of Governments Technical Advi sory
Committee, available at: https :ljwrcog.us/AgendaCenter/ViewFile/Agenda/ 02212019-292 , p. 64 .
14 "CalEEMod User's Gu ide." CAPCOA, November 2017, available at: http ://www.caleemod.com/, p. 35.
7
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-90
Comment Letter H1
H1-11
H1-12
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Unsubstantiated Reductions to Energy Use Values
Rev iew of the CalEEMod output files demonstrates t hat "The landing by San Manuel (Operations -
Passenge r Cars)" and "The l anding by San Manuel (Opera t ions -Trucks)" models include the following
unsubstantiated changes to the Project's energy use values (see excerpt below) (Appendix Bl, pp. 458,
520, 584, 647).
Table Name Coomn Name Default VaJue New Value
tb1En8fgyUse : Lighting Elect • 2.37 1.66
............................. " ............................. 4------------------------------
tblEnergyUse : LightingEleci : 1.17 0 .82
lblEn8fgyUse ; T24E ~ 1.06 0.74
tblEnergyUse ; T24E ~ 0.37 0.26
••••••••••••••••••••••••••••• 4, •••••••••••••••••••••• -•••••• +------------------------------
tblEnergyUse T24NG 3.25 33.96
... -..... -,blE",.~;gy·u~---. ------~ --------. --"T24NG .. --. ---. --. : 2.00-------------1.40 ••••••••••••••••••••••••••••• .s. •••••••••• -•••••••••••••••••• .,_ ________________ . _____ ..... _______ ..
As you can see in the exc erpt above , t he default energy use va lues were manually altered within the
model. As p revio usly mentioned, the CalEEMod User's Guide req ui re s any changes to model defau lts be
justified .15 Accord i ng to the correspond ing "User Entered Comments & Non-Defau lt Data " tab les, the
justifications provided for these changes are : "The Project will design bu ilding shells and building
components to meet 2019 Title 24 Standards which expects 30% less e nergy for nonresidential uses"
(Appendix Bl, pp . 130, 143,306,381). However, this just ification is i nsufficient. Simply because the 2019
Title 24 Standards expect nonresidentia l land uses to red uce energy use by 30%, does not guarantee
that this reduction wou ld occur locally on the Project site. W ithout any additional information regard ing
how the Project wou ld achieve a 30"/o reduction in energy use, we cannot verify the revised values.
These unsupported changes p resent an issue, as Ca lE EMod use s the energy use va l ues to calcu late the
Project's emi ss ions ass ociated with build ing electricity and non-hearth natural gas usage .16 Thu s, by
including u nsubstantiated reductions to the Project's energy use values, the models may underestimate
the Project 's energy-source operational emissions and shou ld not be re l ie d upon to determine Project
significance .
Failure to Implement All Feasible Mitigation to Reduce Emissions
As discussed above, the DEi R's air quality analysis relies upon an incorrect and unsubstantiated air
model to determine the si gnificance of the Project's criteria air po l lutant emissions. However, despite
the DEIR's flawed air model, the DEIR's operational emissions estimates indicate a significant air qua lity
impact. Specifically, the DE IR concludes that the proposed Project's operational NO x emiss ions would be
sig nificant and unavoidable, stating:
"Mitigation Measures MM 4.1-4 through MM 4.1-9 would reduce the Project's overall demand
for energy resources and would reduce the Project's ope rationa l NO x emissions (NO x is relea sed
during the combustion of certain types of ene rgy resource s). However, mobile source emissions
account for approximately 91 pe rcent, by weight, of the Project's total operational NO x
15 CalEEMod User Gu ide , available at: http :ljwww.caleemod .com/, p. 2, 9
16 CalEEMod User Gu ide , available at: http :ljwww.caleemod .com/, p. 43
8
Final EIR
Lead Agency: C ity of San Bernardino SCH No . 2020100067
Page F-91
Comment Letter H1
H1-12(cont)
H1-13
•• ••
The Landing by San Manuel
Final Environmental Impact Report
emissions. Mobile source emissions are regulated by standards imposed by federal and State
agencies, not local governments. No other mitigation measures related to vehicle tailpipe
emissions are available that are within the City of San Bernardino's iurisdictional authority that,
also, are feasible for the City of San Bernardino to enforce and have a proportional nexus to the
Proiect's level o(impact. As such, it is conc l uded that operation of the Project would generate
NO x emissions that would exceed the applicable SCAQMD regional air quality threshold on a
daily ba sis. The Project's operational-related NO x emissions a lso would cumulatively contribute
to an existing air quality violation in the SCAB (i.e., ozone concentrations), as well as
cumulatively contribute to the net increase of a criteria pollutant for which the SCAB is non-
attainment (i.e ., federal and State ozone concentrations). Accordingly, the Project's long-term
operational-related emissions of NO x are concluded to result in a significant and unavoidable
impact on both a direct and cumulatively-considerable basis" (emphasis added) (p . 4.1-41-4 .1-
42).
However, while we agree that the Project's operational emissions would result in significant air quality
impacts, the DEIR's conclusion that these impacts are "significant and unavoidable" is incorrect.
According to CEQA Guidelines§ 15096(g)(2):
"When an EIR has been prepared for a project, the Responsible Agency shall not approve the
project as proposed if the agency finds any feasible alternative or feasible mitigation measures
within its powers that would substantially lessen or avoid any significant effect the project
would have on the environment ."
As you can see , an impact can only be labeled as significant and unavoidable after all available, feasible
mitigation is considered . Here, the DEIR includes mitigation measures MM 4 .1-4 though MM 4 .1-9,
including mea sures related to CARB anti-idling regulations, on-site circulation, elect ric and non-diesel
equipment, and EV charging sta tion s (p . 4.1-39-4.1-40). However, the DEIR's conclusion that "[n]o
other mitigation measures related to vehicle tailpipe emissions are available that are within the City of
San Bernard ino's jurisd i ctional authority that, also, are feasible for the City of San Bernardino to enforce
and have a proportional nexus to the Project's level of impact" is incorrect (p. 4.1-41). Rather, additional
feasible mitigation measures exist, such as those sugge sted in the section of this letter tit led "Feasib le
Mitigation Measures Available to Reduce Emissions."17 that should be incorporated in order to reduce
the Project's operational NO x emissions to less-than-significant levels . Therefore, the DEIR's conclusion
that the Project's air quality impact is significant and unavoidable is u ns ubstantiated, as the Project fails
to implement all feasible mitigation . The Project should not be approved until an updated EIR is
prepared, i ncluding updated, accurate air modeling, as well as incorporating all feasible mitigation to
reduce emissions to less-than-significant levels .
17 See section titled "Feasible Mitigation Measures Available to Reduce Emissions" on p. 15 of this comme nt letter.
These measures would effectively reduce operational NO , emissions .
9
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-92
Comment Letter H1
H1-14
H1-15
H1-16
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated
The DEIR concludes that the proposed Project would have a less-than-significant health risk impact
based on q uantified health risk assessments ("HRA") est i mating the cancer risks resulting from Project
construction and proposed diesel -fueled truck trips (p. 4.1-32 -4.1-33). Specifically, the DEIR est imates
that the Project's construction activities and diese l-fue led truck trips would result in cancer risks of 3.9-
and 7.04-i n one million, re spectively (p . 4.1-32-4 .1-33 ). However, the DEi R's evaluation of t he Project's
potentia l hea lth risk i mpacts, as well as the subsequent l ess-t han-sign ificant impact conclusion, is
incorrect for two rea son s.
First, the DE IR's construction HRA is i ncorrect, as it relies upon an exhaust PM ,o estimate from flawed ai r
models, as discus se d above (Appendix B3, pp . 7). As previous ly di scu ss ed , when we reviewed the
Project's CalEEMod output files, provided in the AQIA as Ap pendix Bl to the DEIR, we found that several
of t he values inputted into the model are not consistent w ith information disclosed in the DEIR and
associated documents. Thus, the construct ion HRA utilizes an underestimated diese l particulate matter
("DPM ") concentration to calculate the health risk associated with Project construction . As such, the
DEIR's construction HRA, which relies upon an incorrect and un substantiated air model, should not be
rel ied upon to determine the significance of the Project's health ri sk impacts .
Second, review of the DE IR demonstrates that, while the Project did conduct construction and mobile-
source operational HRAs, the DEIR fails to eva luate the cumulative l ifetime cancer risk to nearby,
existing receptors as a result of all phase s of Project construction and operation together. According to
OEHHA guidance, as referenced by the DEi R's HRA , "the excess cancer risk is calculated separate ly for
each age grouping and then summed to yield cancer risk at the rece ptor location".18 However, the
DEIR's construction and operational HRAs fail to sum each age bi n to evaluate the total cancer risk over
the course of Project construction and operation . Thi s is incorrect and thus, an updated EIR shou ld be
prepared, quantifying the Project 's construction and operational cancer risks and summing them to
compare to t he SCAQMD threshold of 10 in one m ill ion .
Failure to Identify Significant Health Risk Impact
As previous ly described, the DE IR concludes that the Project would result in a co nstruction-re lated
cancer r isk of 3 .9 in one million and a mobi le-source operationa l cancer risk of 7 .04 in one million, both
of which would not exceed the SCAQMD threshold of 10 in one mill ion when evaluated in isolation .
However, as previou sly discu ss ed, the DE IR shou ld ha ve evaluated the cumulative co nstruction-related
and operationa l cancer risk resu lting from the Project. In order to correctly evaluate the Project's health
risk impact, we summed the DEIR's construction-related and operational cancer risk estimates and
found that the resulting cancer risk exceeds the SCAQMD t hreshold of 10 in one million (see table
below).
18 "Guidance Manual for preparation of Health Risk Assessments." OEHHA, February 2015, available at:
https ://oehha .ca .gov/media/downloads/crnr/2015guida ncemanual.pdf p. 8-4
10
Final EIR
Lead Agency: C ity of San Bernardino SCH No . 2020100067
Page F-93
Comment Letter H1
H1-17
H1-16(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
DEIR Cumulative Cancer Risk
HRA cancer Risk (in one
million)
Construction 3 .90
Mobile-Source Operations 7.04
Total 10.94
Th reshold 10
Exceed? Yes
As demonstrated in the table above, the resulting cumu lative cancer risk estimate exceeds the SCAQMD
t hreshold of 10 in one million, thus indicating a potentially significant health ri sk impact not previously
id e ntified or addressed by the DEIR . As such, the DEIR is required under CEQA to implement all feasible
mitigation to reduce impacts to a le ss-than-si gnificant level. According to CEQA Guidelines §
15096(g)(2):
"When an EIR ha s been prepared for a project, the Responsible Agency shall not approve the
project as proposed if the agency find s any feasible alternative o r feasible mitigation measures
within it s powers that would substantially lesse n or avoid any significant effect the project
would have on the environment ."
As you can see, the proposed Project should not be approved until all fea sib le mitigation ha s been
considered and incorporated where fea sible, such as tho se suggested i n the se ction of th is letter titled
"Feasible Mitigation Measures Available to Reduce Emi ss ions."19 As such, the DEIR fail s to identify and
adequately mitigate t he Project's health risk impac t, and the less-than-sign ificant impact conclusion
shou ld not be relied upon.
Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
The DEIR estimates that the Project would generate net annual g reen house ga s ("GHG ") em issions of
23,514.15 metric tons of CO , equivalents per year ("MT CO ,e/year"), which would exceed the SCAQMD
bright-line threshold of 3,000 MT CO,e/year (p. 4.4-27). After the i mplementation of Mitigation Measure
("MM") 4.4-1, the DEIR concludes that the Proj ect would re sult in significant and unavoidable GHG
emissions (p. 4.4-35). Specifically, the DEIR states:
"Implementation of applicabl e regu la tory requirements, Mitigation Mea sures MM 4 .1-1 throu gh
MM 4 .1-9, as well as Mitigation Measure MM 4.4-1, would redu ce t he Proj ec t 's operational
emissions of GHGs; however, these measures would not sub sta ntially reduce Project mobi le
source emiss ions (i.e., emissions from construction equipment, passenger cars, and trucks),
which co mprise more than 60 percent of the Project's anti cipated GHG emissions . Mobile
so urce GHG emissions are regulated by State and federa l fuel standard s and tailpipe emissions
19 See section titled "Feasible M itigation Measures Availab le to Reduce Em issi ons " on p . 15 of thi s letter . These
measures would effec t ively reduce the Proje ct's construction-re lated and operational health ri sk impacts.
11
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-94
Comment Letter H1
H1-18
H1-17(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
standards, and are outside of the control of the City of San Bernardino, the Project Applicant,
and f uture Project occupants. CEQA Guidelines Se ctions 15040(b}, 15041, and 15091 colle ctively
provide that mi t igation mea sures must be within the re spon si bility and jurisdiction of the Lead
Agency (i.e ., City of San Bernardino) in orde r to be im pl emented . No other mitigation measures
are available that are fea sibl e for the City of San Be rn ardino to enforce that have a proportiona l
nex us to the Project's level of impact. Accordingly, the City of San Bern ardino find s that the
Proj ect's GHG emi ss ion s represent a significant and unavoida ble cumulatively-con siderable
i mpact for w hich no additional fea sib le mitigation is ava i lable" (p . 4 .4-35).
Furthermore, the DEIR reli es upon the Project 's con sistency with CARB's 2017 Scoping Plan Update,
stating :
"[A] lead agency may rely on qualitative analysis or perfo rmance-ba sed standard s to determine
the signifi cance of impacts from GHG emission s. As such , the Project's consistency with CARB
2017 Scoping Plan Update is di scu ss ed be low. The 2017 Scoping Plan Update refle ct s the 2030
target of a 40% reduction below 1990 levels, set by Execut ive Orde r B-30-15 and codified by SB
32 . Table 4.4-5, Scoping Plan Consistency Summary, summari zes the project's consistency with
the 2017 Scopi ng Plan . As summarized , t he Project wou ld not conflict with any of the p rovi sion s
of the Scoping Plan and in fact supports seven of the action categories . (Urban Cro ss roads,
2020d , p . 54) ... [T]he Proje ct would not co nflict with any of the 2017 Scoping Plan elements as
any regulations adopted wou ld app ly di rect ly or indirectly to the Project . Further, re ce nt studi es
show that t he State's exi stin g and proposed regulatory framework wil l al low the State to red uce
its GHG emi ss ion s level to 40% below 1990 levels by 2030 . The refore, the Project would not
confl ict w ith an applicable plan, policy or regu lation adopted for the purpose of reducing the
emi ss ion s of greenhou se ga ses, and impacts would be less th an si gn ifi ca nt " (p . 4.4-27).
However, the DEIR 's q uantitative and qual itative GHG analyses are i ncorrect for three rea son s.
(1) The DEIR's quantitative GHG analy sis relies upon an in correct and un sub st antiated air model;
(2) Th e DE IR fail s to implement all fea sibl e mitigation to reduce the Proj ect 's GHG emi ss ion s; and
(3) The DEIR fail s to con sider the performance -ba sed standards under CARB 's 2017 Scoping Plan .
(1) Incorrect and Unsubstantiated Quantitative CHG Analysis
As prev iou sly stated , the DEIR estimates that the Project wou ld generate net annua l GHG emi ss ions of
23,514 .15 MT CO 2e/year (p . 4.4-27). However, the DEIR's quantitative GHG analysis should not be relied
upon, as it relies upon an unsub stantiated air model. As previousl y di scu ss ed, when we rev iewed the
Pr oj ect's CalEEMod output file s, provided in the AQIA as App endi x Bl to the DE IR, we fou nd that seve ral
of the val ue s inputted into the model are not con sistent with i nfo rmation di sclosed in the DEIR and
associated documents. As a re sult, the model underest imates the Project's GHG emissions, and the
DEIR 's qu antitative GHG analysi s shou ld not be relied up o n to determine Project significance . An
updated EIR should be pre pared that adequate ly as sess es the potentia l GHG impacts that constru ction
and operation of the proposed Project may have on the surrounding environment.
12
Final EIR
Lead Agency: C ity of San Bernard ino SCH No . 2020100067
Page F-95
Comment Letter H1
H1-19
H1-20
•• ••
The Landing by San Manuel
Final Environmental Impact Report
(2) Failure to Implement All Feasible Mitigation to Reduce Emissions
As disc ussed above, the DEIR's GHG analysis relies upon an incorrect and u nsubstantiated air model to
determine the significance of the Project's GHG emiss ions. However, despite the DE i R's flawed air
model, the DEIR's GHG emissions estimates indicate a significant GHG impact. As a result, the DEIR
concludes that the proposed Project's GHG emissions would be significant and unavoidable (p . 4 .4-35).
However, whi le we agree that the Project's GHG emiss ions wo uld be sign ificant, the DEIR 's conclus ion
that these impacts are "significant and unavoidable" is incorrect. As previo usly stated, according to
CEQA Guidelines§ 15096(g)(2):
"When a n EIR has been prepared for a project, the Responsible Agency shall not approve the
project as proposed if the agency finds any feas ible alternative or feasible mitigation measures
w ithi n its powers that would substantially lessen or avoid any significant effect the project
would have on the environment."
As you can see, an impact can only be labe led as sign ificant and unavoidable after all available, feasible
mitigation is considered. Here, the DEIR implements MM 4.4-1, which requires the Project to meet or
exceed CalGreen Tier 2 standards (p . 4.4-34-4.4-35). However, the DE IR's conclusion that "[n]o other
mitigation measures are available that are feasib le for the City of San Bernardino to enforce that have a
proportional nexus to the Project's level of impact" is incorrect (p. 4.4-35). Rather, additiona l feasible
mitigation measures exis t, such as those suggested in the section of this letter titled "Feasib le Mitigation
Measures Available to Reduce Emissions."20 that shou ld be incorporated in order to reduce the Project's
GHG emissions to less-than-significant levels. The re fore, the DEIR's conclusion that the Project's GHG
impact is significant and unavoidable is unsubstantiated, as the Project fails to implement all feasible
mitigation. The Project should not be approved until an updated EIR is prepared, including updated,
accurate air modeling, as well as incorporati ng all feasible mitigation to reduce emissions to less-than-
significant levels .
(3) Failure to Consider Performance-based Standards Under CARB 's 2017 Scoping Plan
As previous ly discussed , the DEIR relies upon the Project's consistency with CARB's 2017 Scoping Pion to
deter mine Project GHG significance. However, this is incorrect, as the DEIR fails to consider
performance-based measures proposed by CARB.
i. Passenger & Light Duty VMT Per Cap ita Benchma rks pe r SB 375
In reaching the State's long-term GHG emission reduction goa ls, CARB's 2017 Scoping Plan explicitly
cites to SB 375 and the VMT reductions an t icipated under the implementation of Sustainable
Community Strategies.21 CARB has identified the population and dai ly VMTfrom passenger autos and
light-duty vehicle s at the state and county level for each year between 2010 to 2050 under a "baseline
scenario" that incl udes "current projections ofVMT included in the existing Regional Transportation
Plans/Sustainable Communities Strategies (RTP/SCS s) adopted by the State's 18 Metropolitan Planning
20 See section titled "Feasible Mitigation Measures Available to Reduce Emissions" on p. 15 of this comment letter.
These mea sures would effective ly reduce GHG emissions.
21 CARB (Nov. 2017) 2017 Scoping Plan , p. 25, 98, 101-103,
https ://ww3.arb .ca .gov/cc/scop ingplan/scoping plan 2017 .pdf.
13
Final EIR
Lead Agency: C ity of San Bernard ino SCH No . 2020100067
Page F-96
Comment Letter H1
H1-20(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Organizations (MPOs) pursuant to SB 375 as of 2015."" By dividing the projected daily VMT by the
population, we ca lculated the daily VMT per cap ita for each year at the state and county level for 2010
(baseline year), 2022 (Project operationa l year), and 2030 (target year under SB 32 ) (see table below a nd
Attachment B).
2017 Scoping Plan Daily VMT Per Capita
San Bernardino County State
Year Population LDVVMT VMT Per Population LDVVMT VMT Per
Baseline Capita Baseline Capita
2010 2,043 ,484 55,741,307.23 27.28 37,335,085 836,463,980.46 22.40
2022 2,278,414 61,507,949 .89 27 .00 41,321,565 916,010,145.57 22 .17
2030 2,478,888 65,538,854.28 26.44 43 ,939,250 957,178,153.19 21.78
According to CAPCOA's CEQA & Climate Change report, servi ce popu lation is defined as "the sum of the
number of residents and the number of jobs supported by t he p roject ."23 The DEIR estimates that the
Proj ect wou ld employ approximately 1,120 peop le upon buildout (p. 3-9). As such, we relied upon a
service popu lation of 1,120 people.24 The below table compares the 2017 Scoping Plan daily VMT pe r
capita values against the daily VMT per cap ita values for the Project based o n the DEIR 's modeling (see
table below and Attachment C}.
22 CARB (Jan . 20 19) 2017 Scop ing Plan -I de ntified VMT Reductio ns and Relationship to State Climate Goals
("Supporting Calculations for 2017 Scoping Plan -Identified VMT Reductions"), Excel Sheet "Readme ",
https://ww2.arb .ca.gov/sites/default/files/2019-01/sp mss vmt calculations jan19 O.xlsx .
23 CAPCOA (Jan. 2008) CEQA & Climate Change, p. 71-72, http://www.capcoa .org/wp-
content/uploads/2012/03/CAPCOA-White-Paper.pdf.
24 Calculated : 0 residents+ 1,120 employees= 1,120 service population .
14
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-97
Comment Letter H1
H1-21
H1-20(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Daily VMT Per Capita from Passenger & Light-Duty Trucks,
Exceedances under 2017 Scoping Plan Performance-Based SB 375 Benchmarks
Sources
Project
DEIR
Annual VMT from Auto & Light-Duty Vehicles 13,135,363
Daily VMT from Auto & Light-Duty Vehicles 35,987
Se rvice Population 1,120.00
Daily VMT Per Capita 32 .13
2017 Scoping Plan Benchmarks, Statewide
22.40 VMT (2010 Baseline) Exceed? Yes
22 .17 VMT (2022 Projected) Exce ed? Yes
21.78 VMT (2030 Projected) Exceed? Yes
2017 Scoping Plan Benchmarks, San Bernardino County Specific
27.328 VMT (2010 Baseline) Exceed? Yes
27.00 VMT (2022 Projected) Exceed? Yes
26.44 VMT (2030 Projected) Exceed? Yes
As shown above, the DEIR's modeling shows that the Project exceeds the CARB 2017 Scoping Plan
projections for 2010, 2022, an d 2030. Because the exceeds the CARB 2017 Scoping Plan performance-
based daily VMT per capita projections, the Project conflicts with the CARB 2017 Scoping Plan and SB
375. As suc h, the DEi R's claim that the proposed Project would not conflict with the CARB 2017 Scoping
Plan is in correct and unsubstantiated . An EIR should be prepared for the propose d Project to provi de
additional information and analysis to conclude less than significant GHG impacts.
Feasible Mitigation Measures Available to Reduce Emissions
Our analysis demonstrates t hat the Project's air quality, health ri sk, and GHG emiss ions may result in
sign ificant impacts and should be mitigated further. In an effort to reduce the Project's emissions, we
identified several mitigation measures that are app licab l e to t he proposed Project . Feasible mitigation
measures can be found in CAPCOA's Quantifying Greenhouse Gas Mitigation Measures .25 Therefore, to
redu ce the Project's emiss ions, consideration of the following measures should be made:
25 http: ljwww .capcoa .org/wp-conte n t/u ploads/2010/11/CAPCOA-Qua ntification-Re port-9-14-Fi n al . pdf
15
Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-98
Comment Letter H1
H1-22
H1-23
H1-24
H1-25
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Measures -Energy
Building Ene r gy Use
Exceed Title-24 Building Enve lope En ergy Effic iency Sta ndards (Ca l ifornia Building Standards Code)
Inst all Progra m mable Thermostat Timers
Install Ene rgy Efficient Appliances
Install Ene rgy Efficient Boilers
Lighting
Inst all Higher Efficacy Public St reet an d Area Li g hting
Lim it Outdoo r Lig ht ing Req uireme nts
Replace Traffic Lights with LED Traffic Lights
Alternative Energy Generation
Esta blish Onsite Renewable or Carbon-Neutral Energy Systems
Establish Onsite Renewable Energy System -Solar Powe r
Esta blish Onsite Renewable Energy System -Wind Power
Uti li ze a Co mbined Heat and Power System
Esta blish Methane Recovery i n Land fills
Esta blish Meth ane Recovery i n W astewa t er Trea t ment Pla nts
Measures -Transportation
Land Use/Location
Increase Density
Inc rease Locatio n Efficiency
Increase Dive rsity of Urban and Suburban Develo pm ents {M ixed Use)
Increase Dest i nation Accessi bi lit y
Increase Transit Acces sibi lit y
Integrate Affordable and Be low Market Rate Housing
Ori e nt Proj ect To w ard Non-Auto Corridor
Loca t e Project near Bike Path/Bike Lane
Neighborhood/Site Enhancements
Provi de Pedestria n Network Improvement s, such as:
• Compac t , mixed -use communities
• Int erconnected street networ k
26 "Quan t ifying Green house Gas M itiga t ion Measu res ." Ca lifornia Air Poll ution Control Office rs Associa t ion
(CAPCOA), August 2010, available at: http://www.c apcoa .org/wp-content/uploads/2010/11/CAPCOA-
Quantification -Re port-9-14 -Fina l.pdf, p.
16
Lead Agency: City of San Bernardino
Final EIR
SCH No . 2020100067
Page F-99
Comment Letter H1
H1-26
H1-27
H1-25(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
• Narrower roadways and shorter block lengths
• Sidewalks
• Access ibility to transit and transit she lters
• Traffic calming measures and street trees
• Parks and public spaces
• Minimize pedestrian barrie rs
Implement a Neighborhood Electric Vehicle (NEV) Network.
Create Urban Non-Motorized Zones
Incorporate Bike Lane Street Design (on-site)
Dedicate Land for Bike Trails
Pa rking Po licy/Prici ng
Lim it Parking Supply through:
• Elimination (or reduction) of m in imum parking requirements
• Creation of maximum parking requirements
• Provision of shared parking
Unbundle Parking Costs from Property Cost
Implement Market Price Public Parking (On-Street)
Require Re sidential Area Parking Permits
Commute Trip Redu ction Prog rams
Implement Commute Trip Reduction (CTR) Program -Voluntary
• Carpooling encouragement
• Ride -matching assistance
• Preferential carpool parking
• Flexible work schedules for carpools . Half time t r ansportation coordinator
• Vanpool assistance
• Bicycle end-trip facilities (parking, showers and lockers)
• New employee orientation of trip reduction and alternative mode options
• Event promotions and publications . Flexib le work sc hedule for employees
• Transit subsidies
• Parking cash-out or priced parking
• Shuttles
• Emergency ride home
Implement Commute Trip Reduction (CTR) Program -Required Implementation/Monitoring . Established performance standards (e.g . trip reduction requirements)
• Required implementation
• Regular monitoring and reporting
Provide Ride -Sharing Programs
• Designate a certain percentage of parking spaces for r ide sharing vehicles
Final EIR
• De signating adequate pas se nger loading and un loading and waiting areas for ride -s haring veh icle s
• Providing a web site or messaging board for coordinating rides
17
Lead Agency: C ity of San Bernard ino SCH No . 2020100067
Page F-100
Comment Letter H1
H1-28
H1-27(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
• Permanent transportation management association membership and funding requirement .
Implement Subsidi zed or Di scou nted Transit Program
Provide Ent ofTrip Facilities, including : . Showers
• Secure bicycle locke rs
• Changing spaces
Encourage Telecommuting and Alternative Work Schedules, such as :
• Staggered starting times
• Flexible sche dules
• Compressed work weeks
Implement Commute Tri p Reduction Marketing, such as:
• New employee orientation of trip reduction and alternative mode options
• Event promotions
• Publications
Implement Car-Sharing Program
Implement School Pool Program
Provide Emp loyer-Sponso red Van pool/Shuttle
Implement Bike-Sharing Programs
Implement School Bus Program
Price Workplace Parking, such as:
• Explicitly charg ing for parking for its employees;
• Im plementing above m arket rate pricing; . Va lidating parking only for inv ited guests;
• Not providing employee parking and transportation allowances; and
• Educati ng employees about available alternatives .
Implement Emp loyee Parking "Cash-Out"
Transit System Improvements
Tran sit System Improvements, including:
• Grade-separated right-of-way, including bus only lanes (for buses, emergency vehicles, and
sometimes ta xis), and other Trans it Pri o rity measu res. Some syste ms use guideways whic h
automatically steer the bus on portions of the route.
• Frequent, high-capacity service
• High-quality vehicles that are easy to board, quiet, clean, and comfortab le to ride .
• Pre-paid fare collection to minimize boarding de lays .
• Integrated fare systems, allowing free or discounted tran sfe r s between ro utes and modes .
• Convenient user information and marketing program s .
• High quality bus stations w ith Tran sit Oriented Deve lopment in nearby areas .
• Modal integration, with BRT service coordinated w ith walking and cycling facilities, ta xi service s,
intercity bus, rail tran sit, and other transportation serv ices.
Expand Transit Network
Increase Transit Service Frequency/Speed
18
Lead Agency: City of San Bernardino
Final EIR
SCH No. 2020100067
Page F-101
Comment Letter H1
H1-29
H1-30
H1-31
H1-32
H1-28(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Provide Bike Parking Near Transit
Provide Local Shuttles
Road Pricing/Management
Implement Area or Cordon Pric ing
Improve Traffic Flow, such as:
• Signa lization improvements to reduce delay;
• Incide nt management t o increase response time to br eakdow ns and collisio ns;
• Intelligent Transportation Systems (IT S) to provide rea l-time information regarding road cond itions
and directions; and
• Speed management to reduce high free-fl ow speeds .
Required Project Contributions to Transportation Infra structure Improvement Projects
Install Park -and-Ride Lots
Vehicles
Utilize Alternative Fueled Vehicles, such as: . Biodiesel (B20)
• Liquefied Natural Gas (LNG)
• Compressed Na tural Ga s (CNG)
Utilize Electric or Hybrid Vehicles
Measures -Water
Water Supply
Use Reclaimed Water
Use Gray Wa ter
Use Locall y Sourced W ater Supp ly
Water Use
Inst all Low-F low Water Fixtures
Adopt a Water Conservation strategy
Design Water-Efficient Landscapes (see Cal iforn ia Department of Water Resources Model Water Efficient
Landsca pe Ordi nance), such as:
• Reducing lawn sizes ;
• Planting vegetation with minimal water needs, such as native species;
• Choosing vegetation appropriate for the climate of the project site;
• Choosing complimen t ary plants with simi lar wa t er needs or which can provide each other wit h
shade and/or water.
Use Water-Efficient Land scape Irrigation Systems ("Smart" irrigat ion control system s)
Reduce Turf in Landscapes and Lawns
Plant Native or Drought-Res istant Trees and Vegetation
Measures -Area Landscaping
Landscaping Equipment
19
Final EIR
J
]
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-102
Comment Letter H1
H1-33
H1-34
H1-37
H1-36
H1-35
H1-38
H1-32(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Prohibit Gas Powered Landscape Equipment
Implement Lawnmower Exc hange Program
Electric Yard Equipment Compatibility
Measures -Solid Waste
SolidWoste
Institute Recycling and Composting Serv ices
Recycle Demolished Construction Material
Measures -Vegetation
Vegetation
Urban Tree Planting
Create New Vegetated Open Space
Measures -Construction
Construction
Use Alternative Fuel s for Construction Equipment
Urban Tree Planting
Institute a Heavy -Duty Off-Road Vehicl e Plan, i ncl uding :
• Construction vehicle inventory tracking system;
• Requiring hour meters on equipment;
• Document t he se rial number, horse power, manufacture age, fuel, etc. of all onsite e quipment;
and
• Daily logging of the operating hours o f the equipment .
Implement a Construction Vehicle Inventory Tracking System
Measures -Miscellaneous
Miscellaneous
Establish a Carbon Seque stration Project, suc h as :
• Geologic sequestration or carbon capture and sto rage techniques, in which CO 2 from point
sources is captu red and inj ected underground;
• Terrestrial sequestrat ion in whi ch ecosys tems are establ ished or preserved to serve as CO , sinks;
• Novel techniques involving advanced chem ic al or biological pathways; or . Techno logies yet to be discovered .
Establish Off-Site Mitigation
Use Local and Sustainable Building Materials
Require best M anagement Practices in Agricu lture and Animal Operations
Require Env i ronmentally Re spon sib le Purcha sing, suc h as :
• Purcha sing prod ucts with sustainab le packaging;
• Purchasing post-consumer recycled copier paper, paper towel s, and st ationary;
• Purchasing and stocking communal kitchens with reusab le dishes and utensils;
• Choosing sustainable clean ing supplies;
• Leasing equipment from manufacturers who will re cycle the compo nents at their end of life;
• Choosing ENERGY STAR appliances and Water Sense -certified water fixt ures ;
20
Final EIR
J
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-103
Comment Letter H1
H1-40
H1-41
H1-39
H1-42
H1-38(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
• Choosing electronic appliances with bui lt in sle ep-mode timers;
• Purchasing 'green power' (e.g. electricity generated from renewable or hydropower) from the
utility; and
• Choosing locally-made and distributed products .
Implement an Inn ovative Strategy for GHG Mitigation
Measures -General Plans
General Plans
Fund Incentives for Energy Efficiency, such as:
• Retrofitting or designing new buildings, parking lots, streets, and public areas with energy-
efficie nt lighting;
• Retrofitting or designing new buildings with low-flow water fixtures and high-efficiency
appliances;
• Retrofitting or purchasing new low-em iss ion s equ ipment;
• Purchasing e lectric or hybrid vehicles;
• Investing in renewable energy systems
Establish a Local Farmer's Market
Establish Co mmunity Gardens
Plant Urban Shade Trees
Implement Strategies to Reduce Urban Heat-Island Effect, suc h as:
• Planting urban shade trees;
• Installing reflective roofs; and
• Using light-colored or high-albedo pavements and surfaces .
Furthermore, in an effort to reduce the Project's emissions, we identified severa l mitigation measures
that are applicable to the proposed Project from NEDC's Diesel Emission Controls in Construction
Projects.27 Therefore, to reduce the Project's emissions, consideration of the following measures sho uld
be made:
Measures -Diesel Emission Control Technology
a. Diesel Generators
All diese l generators on site for more than 10 tota l days must be equipped with emi ssion control t echno logy
verified by EPA or CAR B to reduce PM emiss ions by a minimum of 85%.
b. Upon confirming that the diesel vehicle, construction equipment, or generator has either an engine
meeting Tier 4 non road emission standards or emission control tech no logy, as specified above,
insta lled and functioning, the developer will issue a compliance sticke r. All diesel vehicles,
27 "Diesel Emission Controls in Construction Projects." Northeast Diesel Collaborative (NEDC), December 2010,
available at: https ://www .epa .gov/sites/production/files/2015-09/documents/nedc-model-contract-
sepcification .pdf.
28 "Diesel Emission Controls in Construction Projects ." Northeast Diesel Co llaborati ve (NEDC), December 2010,
available at: https :ljwww.epa .gov/sites/prod uct ion/fi les/2015-09/documen t s/nedc-model -contract-
sepcification .pdf.
21
Final EIR
J
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-104
Comment Letter H1
H1-43
H1-44
H1-42(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
construction equipment, and generators on site shall display the compliance sticker in a visible,
external location as designated by the deve loper.
C. Emission control technology shall be operated, maintained, and serviced as recommended by the
emission control technology manufacturer.
d . All diesel vehicles, construction equipment, and generators on site shall be fueled with ultra-low
sulfur d iese l fuel (ULSD) or a bi od iese l blend 29 approved by the original engine manufacturer with
sulfur content of 15 ppm or less .
M easures -Additiona l Dies el Re quirements
a. Construction shall not proceed until the contractor submits a certified list of all diesel vehicles,
construction equipment, and generators to be used on site. The list shall include the fol lowing :
i. Contractor and subcontractor name and address, plus contact person re sp onsibl e for the vehicle s
or equipment.
i i. Equipment type, equipment manufacturer, equipment serial number, engine manufactu re r,
engine model year, engine certification (Tier rating), horsepower, engine se rial number, and
expected fuel usage and hours of operation.
iii . For the emission control technology installed : technology type, se rial number, make, mode l,
manufacturer, EPA/CARB verification number/level, and in sta llation date and hour-meter reading
on installation date.
b. If the contractor subsequently needs to bring on site equipment not on the list, the contractor shall
submit written notification within 24 hours that attests the equipment complies with all contract
conditions and provide information.
C. All diesel equipment shall comply w ith all pertinent loca l, state, and federal regulations relative to
exhaust emission controls and safety.
d . The contractor shall establish generator sites and truck-staging zone s for vehicles waiting to load or
un load material on site. Such zones shall be located where diesel emissions have the least impa ct on
abutters, the general public, and especially sensitive re ce ptors such as hospitals, sc hools, daycare
facilities, elderly housing, and convale sc ent facilities.
Re porting
a. For each onroad diese l vehicle, nonroad construction equipment, or generator, the contractor sha ll
submit to the developer's rep resentative a report prior to bringing said equ ipment on site that
includes:
i. Equipment type, equipment manufacturer, equipment se rial number, engine manufacturer,
engine model year, engine certification (Tier rating), horsepower, and engin e serial number.
i i. The type of emission control technology i nsta lled, serial number, make, mode l, manufacturer,
and EPA/CARB veri fica tion number/level.
iii. The Certification Statement signe d and prin te d on the contractor's letterhead .
b . The contractor shall submit to the developer's representative a monthly report that, for each onroad
diese l vehicle , nonroad construction equipment, or generator onsi te, includes:
i. Hour-m eter readings on arrival on -s ite, the first and la st day of every month, and on off-si te date.
ii. Any problems with the equipment or emission control s.
iii . Certified copie s of fuel deliveries for the time period that identify:
29 Biod iese l blend s are on ly to be used in conjunction with the tech no logie s which have been verified fo r use with
biodiesel blends and are subject to the fo ll owing requi rements :
http://www.arb .ca.gov/diese l/verdev/reg/biodiese lcomp liance .pdf.
22
Final EIR
Lead Agen c y : C ity of San Bernard ino SCH No . 2020100067
Page F-105
Comment Letter H1
H1-45
H1-46
H1-44(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
1. Source of su pply
2. Quantity of fuel
3 . Quality of fuel , i ncluding su lfu r content (percent by weight)
These measures offer a cost-effective, feasible way to incorporate lower-emitting design features into
the proposed Project, which su bse quently, reduce emissions released during Project construction and
operation. An updated EIR should be prepared to include al l feasible mitigation measu re s, as well as
include an updated hea lth risk and GHG analysis to ensure that the necessary mitigation measures are
implemented to reduce emissions to below thresholds. The updated EIR should also demonstrate a
commitment to the implementation of these meas u res prior to Project approval, to ensure that the
Project's significant emissions are reduced to the maximum extent possible.
Disclaimer
SWAPE has received limited discovery regarding this project. Additional information may become
available in the future; thus, we retain the r ight to revise or amend this report when additional
information becomes available. Our professional services have been performed using that degree of
care and skill ordinarily exercise d, under similar circumstances, by reputable environmental consultants
practicing in this or similar localities at the time of se rvice . No other warranty, expressed or implied, is
made as to the sco pe of work, work methodologies and protocols, si te conditions, analytical testing
results, and findings presented. This report re flects efforts which were limited to information that was
reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or
otherwi se be incomplete due to the unavailability or uncertainty of i nformation obtained or provided by
third parties.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Paul E. Rosenfeld, Ph .D.
23
Final EIR
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Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-106
Comment Letter H1
H1-47
•• ••
The Landing by San Manuel
Final Environmental Impact Report
VMT CALC!J:LATIQNS:: DEIR M2d1:ling
Li ne (L) Value I Unit
Dally VMT Pe r capita From Passenger and Light Du ty Vehicles
1 19,809,530
roJect Total VMT
(CalEEMod Annual Output, Tbl. 4.2 Trip Summary)
2 66.31% assenger and Light-Duty VMT Flee t M ix {See Attachment DJ
3 13,135,363
VMT trom Passenger & light-Duty Ve hicles
!Cale: (Ll"L2))
4 35,987
Da lly VMT tram Passenger & llgnt-Duty Ve n1c1es
ICalc: (l3/365)]
5 1,120.00 service Population [O res1dent s + 1,110 long-term JobsJ
6 32.13
uauy vM I Per Lap1ta
l(Calc: L4/l5)]
Lead Agency: City of San Bernardino
Final EIR
SCH No . 2020100067
Page F-107
Comment Letter H1
H1-47(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
2017 Scoping Plan Daily VMT Per Capita
San Bernardino County
Year Population LOV VMT Baseline VMT Per Capita Population
2010 2,043,484 55,741,307.23 27.28 37,335,085
2022 2,278,414 61,507,949.89 27.00 41,321,565
2030 2,478,888 65,538,854.28 26.44 43,939,250
Lead Agency: City of San Bernardino
Final EIR
State
LOV VMT Baseline VMT Per Capita
836,463,980.46 22.40
916,010,145.57 22.17
957,178,153.19 21.78
-
SCH No. 2020100067
Page F-108
Comment Letter H1
H1-47(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Daily VMT Per Cap ita from Passenger & Light-Duty Trucks,
E>eceedance s under 2017 Scoping Plan Performance-Based SB 375 Benchmarks
Sources Project
DEIR
Annual VMT from Auto & Light-Duty Veh icles 13,135,363
Daily VMT from Auto & Light-Duty Vehicles 35,987
Service Population 1,120.00
Daily VMT Per capita 32.13
2017 Scoping Plan Benchmarks, Statewide
22.40 VMT (2010 Baseline) Exceed? I Yes
22 .17 VMT (2022 Projected} Exceed? I Yes
21.78 VMT (2030 Projected} Exceed? I Yes
2017 Scoping Plan Benchmarks, San Bernardino County Specttic
27.328 VMT (2010 Baseline) Exceed? I Yes
27.00 VMT (2022 Projected) Exceed? I Yes
26.44 VMT (2030 Projected) Exceed? Yes
Lead Agency: City of San Bernardino
Final EIR
SCH No. 2020100067
Page F-109
Comment Letter H1
H1-47(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Land Use Number of Trips Total Number of Trips
Passenger Cars 1875.98 2457.99
Trucks 582.01 2457.99
Total 2457 .99
Lead Agency: City of San Bernardino
Final EIR
Percentage of Total Passenger and Light Duty Fleet Mix Final Fleet Mix
0.763217100 1S0936 0.8688 0.6630830166111
0.236782899849064 0 0
1 0.6630830166111
SCH No . 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-110
RESPONSES TO COMMENT LETTER H-1
H1-1 The commenter introduces themselves as the legal counsel for the Golden State Environmental Justice
Alliance (GSEJA).
H1-2 The commenter provides a general statement that they do not believe the DEIR adequately evaluates
the topics of air quality, health risk, and greenhouse gas impacts. Refer to Responses H1-7 though H1-
47, which provide responses to the commenter’s specific comments and which substantiate that the
technical analyses prepared to support the DEIR are adequate and compliant with CEQA.
H1-3 The commenter suggests that the DEIR be recirculated and requests to receive Project-related public
notices. As demonstrated in these written responses and the FEIR, there were no comments made in
this letter or in other comments received by the City of San Bernardino on the DEIR that necessitates
recirculation of the DEIR. To the extent revisions occur in the Final EIR, they do not constitute
substantial new information, and recirculation is not necessary. The DEIR circulated for public review
was fundamentally and basically adequate, and as such, recirculation of the DEIR is not warranted as
set forth in Section 15088.5 of the CEQA Guidelines. As requested, the City will include Blum Collins,
LLP on the notification list for all Project-related public notices that are required to be distributed.
H1-4 The commenter provides a multi-page review from SWAPE consultants, this first comment of which
generally describes the proposed Project. The commenter also makes a broad assertion that the DEIR’s
supporting technical analyses are not adequate and suggests that the DEIR be updated. Refer to
Responses H1-4 though H1-47, which provide responses to the commenter’s specific comments and
substantiate that the technical analyses prepared to support the DEIR are adequate and compliant with
CEQA. As demonstrated in these responses to comment and in the FEIR, there were no comments
made in this letter or in other comments received by the City of San Bernardino on the DEIR that
necessitates recirculation of the DEIR. The DEIR circulated for public review was fundamentally and
basically adequate, and as such, recirculation of the DEIR is not warranted as set forth in Section
15088.5 of the CEQA Guidelines.
H1-5 The commenter claims that the DEIR’s air quality impacts are underestimated and requests preparation
of an updated DEIR based on the subsequent comments. There is no specific comment here that
warrants a response, as the commenter makes additional comments that follow that are responded to
accordingly.
H1-6 The commenter asks about model default changes used in the air quality analytical analysis. As noted
in the DEIR’s Technical Appendix B1, Air Quality Impact Analysis (see Page 41), the construction
duration and equipment utilized for the calculations represents a reasonable approximation of the
expected construction activity as required by CEQA. The specific construction schedule and associated
equipment list were modified from the CalEEMod defaults based on information provided by the
Project Applicant as noted in the CalEEMod outputs included in Technical Appendix B1 of the DEIR.
Changing defaults is appropriate since site-specific information is available, this is consistent with the
CalEEMod User’s Guide which states that CalEEMod was in fact designed to allow the user to change
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-111
the defaults to reflect site-specific information, when available (See Page 12 of the User’s Guide).9 he
commenter claims that changing the number of days of activity somehow necessitates changing the
assumed equipment utilized in the modeling, but provides no substantiation for this claim. As noted in
the DEIR and associated Technical Appendix B1, the construction schedule and equipment list are
based on a reasonable approximation and information provided by the Project Applicant.
H1-7 The commenter claims that the default 100 g/l VOC emission rate was adjusted to 50 g/l but that they
cannot verify the accuracy of the change. It should be noted that the CalEEMod default parameters are
based on the allowable g/l limit for “Building Envelope Coatings.” As stated in the DEIR and
underlying Technical Appendix B1, as cited by the commenter, the requirement of 50 g/l is found in
SCAQMD’s Rule 1113 which establishes a maximum if 50g/l for “Building Envelope Coatings”
effective 01/01/2019. As such, the DEIR correctly utilizes the 50 g/l VOC limit as required by
SCAQMD’s Rule 1113 and no further evaluation is required.
H1-8 The commenter claims that the hauling values for the Water Tower Relocation and hauling for soil
import/export are not appropriately quantified. As stated in DEIR Technical Appendix B1 (see Section
3.4, Page 40), the Water Tower Relocation would result in 300 tons of demolished concrete footing
material and the Physical Building Construction activities would result in another 100 tons of
demolished material (poles, gravel etc.) that would be hauled off-site approximately 10 miles. As such,
assuming a 20-ton haul capacity per truck, 300 tons ÷ 20-ton capacity per truck = 15 truckloads or 30
two-way haul trips. Similarly, 100 tons ÷ 20-ton capacity per truck = 5 truckloads or 10 two-way haul
trips. These are appropriately modeled in CalEEMod accordingly and are substantiated and disclosed
in the DEIR.
H1-9 The commenter claims that there is an unsubstantiated change made to the operational off-road
equipment fuel type. As identified in the DEIR and underlying Technical Appendix B1, DEIR
Mitigation Measure MM 4.1-7 requires the use of non-diesel (e.g., CNG or electric) on-site indoor and
outdoor forklifts and outdoor cargo handling equipment shall be electric or non-diesel fueled. As such,
the substantiation the commenter seeks is already in the DEIR and no further changes are required.
H1-10 The commenter asks about the operational fleet mix modeled. Mobile-source emissions are based on
the number of passenger car and truck trips generated by the Project consistent with the Project’s
Traffic Impact Analysis (TIA) provided as Technical Appendix K2 to the DEIR. As stated in the DEIR
Subsection 4.8.5, the TIA identifies two different truck categories for the High-Cube Fulfillment
Center Warehouse use. CalEEMod categorizes trucks by truck type, not by axle-type. In order to
account for emissions from LHDT, MHDT, and HHDT trucks, the analysis appropriately assumed a
reasonable forecast that 25% of the 2-4 axle trucks are LHDT, 25% are MHDT, and the remaining
50% are HHDT. This is a reasonable estimate because it is typically presumed that 2-axle trucks
represent LHDT, 3-axle trucks represent MHDT, and 4+ axle trucks represent HHDT. The truck mix
is consistent with the mix recommended by the South Coast Air Quality Management District, as noted
in Footnote 3 to Table 4-1 of the Project’s TIA (DEIR Technical Appendix K2).
9 California Air Pollution Control Officers Association (CAPCOA) CalEEMOD User’s Guide, November 2017. Available
online at http://www.aqmd.gov/docs/default-source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-112
H1-11 The commenter claims that the default energy values are inappropriately changed and not supported
by substantial evidence. As noted in the DEIR and underlying technical appendices, the 2019 version
of Title 24 which became effective on January 1, 2020 results in approximately 30% less energy
demand for non-residential buildings (DEIR Page 4.4-25). It is therefore appropriate to reduce the
CalEEMod defaults (which are based on the prior 2016 Title 24 standards) by 30% to account for
compliance with the regulation. The commenter provides no substantial evidence as to why these
reductions are improper, or that if the reductions had not been taken, the EIR analysis and conclusions
would have to be revised to render a new significant impact.
H1-12 The commenter quotes the DEIR with emphasis (underline) added to certain statements. No specific
comments are made that warrant a response or revision to the DEIR.
H1-13 The commenter suggests that the City of San Bernardino consider and apply 97 additional mitigation
measures to the Project, taken from a CAPCOA document published in 2010 and a NDECS list also
published in 2010. Refer to Responses H1-22 through H1-44. Of note, many of CAPCOA’s sample
mitigation measures under the headings Building Energy Use, Lighting, Vehicles, Water Use, and
Solid Waste are duplicative of requirements mandated by the California Green Buildings Standards
Code, Title 24, to which the Project must comply. Many of the other measures are regional in nature
or directed to regional planning efforts or policy formation by government bodies, or the daily business
operation practices of private enterprises that are outside the scope of the proposed Project. CEQA
does not require adoption of every imaginable mitigation measure. CEQA’s requirement applies only
to feasible mitigation that will “substantially lessen” a project’s significant effects. (Public Resources
Code, § 21002.) As explained by one court: A lead agency's “duty to condition project approval on
incorporation of feasible mitigation measures only exists when such measures would [avoid or]
‘substantially lessen’ a significant environmental effect.” (San Franciscans for Reasonable Growth v.
City and County of San Francisco (1989) 209 Cal.App.3d 1502, 1519.) “Thus, the agency need not,
under CEQA, adopt every nickel and dime mitigation scheme brought to its attention or proposed in
the project EIR.” (Ibid.) Rather, an EIR should focus on mitigation measures that are feasible, practical,
and effective. (Napa Citizens for Honest Government v. Napa County Board of Supervisors (2001) 91
Cal.App.4th 342, 365.)
H1-14 The commenter summarizes the health risks from Project construction and operations then claims that
the DEIR’s Health Risk Assessment is flawed because of previously identified comments made by the
commenter that render the air quality analysis inadequate. As noted in Responses H-1 through H-13
above, the commenter did not provide any substantive comments that would alter the findings of the
emissions calculations in the DEIR. As such, the use of the air quality modeling results is correct and
is appropriately relied upon.
H1-15 The commenter claims that the Project’s Health Risk Assessment should sum the risk estimates from
construction and operations and that if this was done that there would be a significant impact. The
commenter cites to OEHHA guidance and claims that the DEIR does not calculate excess risk by age
grouping and then sum the risk at a receptor location. To the contrary, the Project’s construction and
operational HRA presented as DEIR Technical Appendix B2 follow OEHHA’s guidance and calculate
risks by age bin and summarize the totals for each discrete activity. To the contrary, if the commenter
were correct and construction and operational health risks needed to be totaled, it would be
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Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-113
inappropriate to simply add the construction and operational risk values identified in the DEIR. This
is due to the fact that it would not follow the commenters own claim on methodological approach that
the risk should be calculated by age grouping at each receptor location. To this point, the impacts from
operational activities should only be added to age bins subsequent to 1.1 years of construction activity
that are expected. As such, the construction risk of 3.9 in one million + the operational risk for age bins
2 to 16 (3.1 in one million) and 16 to 30 (0.48 in one million) could be added, which would result in a
maximum risk of construction and operational activity of 7.48 in one million which does not exceed
the applicable threshold of significance and is consistent with the less than significant finding in the
DEIR.
H1-16 The commenter incorrectly claims that the Project would result in a significant health risk impact
because construction and operational risks should be combined. Refer to Response H1-15 above,
which explains why it is not appropriate to combine the values, and which indicates that the Project
does not result in a significant health risk impact as shown in the DEIR. As such, no further analysis
is required.
H1-17 The commenter quotes several portions of the DEIR and concludes saying that the DEIR’s GHG
analysis is inadequate for three reasons. Refer to Responses H1-18 through H1-20, which provide
detail responses to the commenter’s claims.
H1-18 The commenter incorrectly claims that the GHG emission calculations are underestimated because of
errors made in the air quality modeling. As noted in Responses H-1 through H-13 above, the
commenter did not provide any substantive comments that would alter the findings of the emissions
calculations in the DEIR. As such, the use of the air quality modeling results is correct and is
appropriately relied upon.
H1-19 The commenter states that the DEIR did not identify all feasible mitigation measures to reduce GHG
emission impacts. In the commenter’s attachment, the commenter suggests that the City of San
Bernardino consider and apply 97 additional mitigation measures to the Project, taken from a
CAPCOA document published in 2010 and a NDECS list also published in 2010. Refer to Responses
H1-22 through H1-44 for responses to the commenter’s suggested mitigation measures. Also, please
refer to four mitigation measures added in response to Comments A-14, A-15, A-19, and A-20(1).
H1-20 The commenter claims that the DEIR did not consider performance-based standards under CARB’s
2017 Scoping Plan. The DEIR presents a robust analysis of the Project’s consistency with the 2017
Scoping Plan (DEIR Pages 4.4-27 through 4.7-32) The commenter attempts to conflate scoping plan
consistency with how the Project’s VMT compares to the supposed 2017 Scoping Plan Performance-
Based SB 375 requirements. First, it is important to understand the intent and purpose of SB 375 (which
is to determine if a project is eligible for CEQA streamlining). As shown in the SB 375 CEQA Chart
published by the Office of Planning and Research (OPR) (https://opr.ca.gov/docs/SB375-Intro-
Charts.pdf), a project that does not qualify for SB 375 CEQA provisions simply needs to go through
the standard CEQA process to determine its project specific impacts. As such, even if a project is not
consistent with SB 375 and cannot rely on its CEQA streamlining provisions, this does not constitute
an inconsistency with the 2017 Scoping Plan. Furthermore, intent and goal of SB 375 is to provide
residential and mixed-use developments in the proximity of transit hubs to reduce VMT; SB 375 is not
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-114
necessarily applicable to individual development projects and instead its purpose is to create a regional
blueprint for agencies to follow. As such, the Project is not required to demonstrate consistency with
SB 375 and further, the VMT targets identified by the commenter are not applicable and based on any
substantial evidence by with the Project is required to comply.
H1-21 The commenter suggests that the City consider and apply 97 additional mitigation measures to the
Project, taken from a CAPCOA document published in 2010 and a NDECS list also published in 2010.
Refer to Responses H1-22 through H1-44 for responses to the commenter’s suggested mitigation
measures. Also, please refer to four mitigation measures added in response to Comments A-14, A-15,
A-19, and A-20(1).
It should be noted that the Project includes a litany of design features, mitigation measures, conditions
of approval, and other items that must be complied with as part of regulatory compliance that will serve
to reduce operational air pollutant and GHG emissions. These include but are not limited to: (a)
compliance with all energy efficiency requirements required by the City of San Bernardino Municipal
Code); (b) demonstration that the Project will meet or exceed the minimum Title 24 Building Energy
Efficiency Standards; (c) the provision of electrical hookups at loading dock doors that accommodate
refrigerated trailers if the Project is built with refrigerated warehouse space (Mitigation Measure MM
4.4-2); (d) the provision of on-site bicycle storage and accommodations for passenger vehicle EV
charging stations per Title 24; (e) the installation of sidewalk along the Development Site’s frontage
of Victoria Avenue with pedestrian accessibility to the interior of the Project and to an approximate
1.1-acre landscaped area planned at the northwest corner of the Development Site, which is designed
to include a walking path and picnic tables; (f) the reservation of a 10-foot area along 3rd Street
between Victoria Avenue and the City Creek drainage channel to accommodate the planned location
of a future City Creek Class I trail; (g) the provision of a bus stop for the Omnitrans Tripper route that
is planned on the Development Site’s frontage with Victoria Avenue, just south of 3rd Street.; (h)
demarcation of carpool and clean air vehicle spaces per Title 24; (i) mandatory compliance with waste
reduction (recycling) measures.; (j) the provision of a truck staging area where EV truck charging
stations can be accommodated; (k) the installation of a rooftop PV system (subject to FAA approval)
providing a minimum of 24 KW of power per year; (l) construction of the remaining building roof area
to accommodate the potential future construction of photovoltaic (PV) solar arrays; and (m) a
commitment to use non-diesel yard equipment (Mitigation Measure 4.1-7). Also, all on-road vehicles
accessing the site are subject to various federal and State laws regarding fuel efficiencies and fuel type,
and the standards applicable in California have become increasingly stringent over the years and will
likely continue to do so in the future. For example, in June, 2020, CARB adopted a new Rule
(Advanced Clean Trucks Regulation) that is the strictest in the country, requiring truck manufacturers
to transition from diesel trucks and vans to electric zero-emission trucks beginning in 2024. By 2045,
every new truck sold in California will be required to be zero-emission. When commercial availability
of electric-powered long-haul trucks is more readily available in the future, implementation of the
Advanced Clean Trucks Regulation is anticipated to substantially reduce air pollutant and GHG
emissions.
H1-22 The commenter suggests exceeding compliance with Title 24. This request is accommodated. DEIR
Mitigation Measure MM 4.4.1 requires that that Project be designed to meet or exceed CALGreen Tier
2 standards in effect at the time of building permit application.
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Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-115
H1-23 The commenter suggests the use of energy efficient lighting. This request is accommodated through
mandatory compliance with CALGreen.
H1-24 The commenter suggests the use of alternative energy systems. The off-site suggestions pertaining to
landfills, waste treatment plants, etc., go beyond the scope of the Project and Project Site and lack
nexus to the Project. The commenter suggests on-site systems such as wind or solar. Refer to
Mitigation Measure MM 4.4-1(d) and the addition thereto presented in Response C-19, which requires
that the shell building include a rooftop PV system providing a minimum of 24 KW of power per year
(subject to FAA approval), and that the remainder of the building’s roof be designed and constructed
to accommodate the potential future construction of additional photovoltaic (PV) solar arrays.
H1-25 The commenter lists regional planning concepts many of which go beyond the scope of Project and
Project Site or relate to a land use other than warehousing and are not applicable to the Project. The
Project Site is located in an infill development location on a portion of the much larger former Norton
Air Force Base (AFB) which has been redeveloping into an industrial center since the AFB was closed
in 1994. Sidewalks and bike lanes exist along the Project Site frontage with 3rd Street, and the Project
will provide a bus stop for the Omnitrans Tripper route that is planned on the Development Site’s
frontage with Victoria Avenue, just south of 3rd Street. The Project also makes spacing
accommodation for the future installation of a planned City Creek Trail segment along the
Development Site’s frontage with 3rd Street from Victoria Avenue east to the location of the City
Creek drainage channel, where a trail crossing is contemplated.
H1-26 The commenter makes broad and generalized suggestions related to parking concepts that are not
applicable to the proposed Project or acceptable to the City for this Project because they involve the
elimination of minimum parking requirements, shared parking between uses, the provision of public
parking, and residential parking permits. These concepts are not appropriate for a large, private
industrial warehouse building like the proposed Project.
H1-27 The commenter makes 41 suggestions related to carpooling, use of transit, flexible work schedules,
and other items related to commuter trip reduction. Many if not all of these items related to the private
business practices of the building user and are not within the City of San Bernardino’s authority to
require or control. As noted in Response H-25, sidewalks and bike lanes exist along the Project Site
frontage with 3rd Street, and the Project will provide a bus stop for the Omnitrans Tripper route that is
planned on the Development Site’s frontage with Victoria Avenue, just south of 3rd Street.
H1-28 The commenter makes 12 suggestions for the improvement of public transit systems. As noted in
Response H-25, the Project will provide a bus stop for the Omnitrans Tripper route that is planned on
the Development Site’s frontage with Victoria Avenue, just south of 3rd Street.
H1-29 The commenter makes broad suggestions about the improvement of traffic flow in public roadway
infrastructure systems that are beyond the scope of the Project or Project Site. As part of the Project,
improvements at the 3rd Street/Victoria Avenue intersection will occur, as well as improvements along
the Project’s frontage with Victoria Avenue and W Street.
H1-30 The commenter suggests the use of alternatively fueled vehicles including electric, biodiesel, liquefied
natural gas, and compressed natural gas. The Project would not preclude any vehicles using these fuel
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-116
types from accessing the Project site. DEIR Mitigation Measure MM 4.4-1 requires the Project to meet
or exceed CALGreen Tier 2 standards in effect at the time of building permit application. These
standards include but are not limited to the provision of referential parking locations for carpool,
vanpool, EVs and CNG vehicles and the installation passenger vehicle EV charging stations required
by Title 24, and the installation of conduit at a minimum of five percent of the Project’s total number
of automobile parking spaces to accommodate the future installation of EV charging infrastructure.
To accommodate charging of battery-powered trucks, the Project’s design includes a truck staging area
in the southwest portion of the property, where EV charging stations for trucks are planned to be
accommodated. MM 4.4-1 requires that the building’s electrical room be sufficiently sized to hold
additional panels to supply power for the future installation of EV truck charging stations on the site
at this location. The San Manuel Band of Mission Indians is the Project Applicant and is voluntarily
actively engaged with solar and electric vehicle industry leaders, such as Tesla, to advance the
accommodation of EV vehicles. To this end, the Project’s building specifications include electrical
switchgear and the truck staging area is designed to accept a technologically advanced electrical
charging system to meet prospective building user requirements for EV truck charging. As a
speculative development, it is not possible to forecast what an actual future user of the building may
need or require in terms of EV truck charging, as the needs vary widely among building users and the
technology is rapidly advancing. The Project’s EV charging facilities for trucks will be tailored to the
needs of the building user, because committing to a system too early and then needing to retrofit it to
meet building user specifications is technologically and cost prohibitive. The Project Applicant’s
commitment to energy sensitive design is appreciated by the City, and is viewed as environmentally
responsible.
H1-31 The commenter suggests the use of reclaimed water. Reclaimed water is not made available to the
Project site area by the San Bernardino Municipal Water Department.
H1-32 The commenter suggests the use of low water use fixtures and landscaping. This request is
accommodated. These items are required by regulation. Low water use fixtures are required by
CALGreen. Low water use landscaping is required by City of San Bernardino Municipal Code Section
19.28.120, Water Efficient Landscaping Standards.
H1-33 The commenter suggests tree planting and recycling efforts. This request is accommodated. As
depicted on DEIR Figure 3-10, Preliminary Landscape Plan, tree planting will occur in the Project’s
passenger vehicle parking areas, around the portions of the building visible from off-site areas, as well
as the site’s frontages with 3rd Street, Victoria Avenue, and W Street. Pertaining to recycling, the
Project would be subject to the City of San Bernardino’s solid waste regulations as set forth in Chapter
8.24 of the City of San Bernardino’s Municipal Code. Chapter 8.24 includes enforceable requirements
for the recycling and diversion of solid waste from the regional landfills. With mandatory compliance
with Chapter 8.24 of the City of San Bernardino’s Municipal Code, the Project would not generate
solid waste in excess of State or local standards.
H1-34 The commenter suggests the use of measures to reduce pollutant emissions during construction
including use of alternative fuels and a heavy-duty vehicle plan. This request is accommodated. As
noted on DEIR Page 4.1.37, the Project is required to comply with SCAQMD Rule 403 for dust control,
Rule 1186 for less polluting street sweepers, and Rule 1113 for low VOC architectural coatings.
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Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-117
Pursuant to Mitigation Measure MM 4.1-1, CARB Tier IV construction equipment must be used unless
it cannot be reasonably acquired. Pursuant to Mitigation Measure 4.1-2, heavy-duty trucks with a gross
vehicle weight over 14,000 pounds must be 2010 or newer or be equipped with a particulate trap. Also,
pursuant to Mitigation Measure 4.1-3, all construction equipment must comply with applicable CARB
regulations.
H1-35 The commenter suggests off-site mitigation and carbon sequestration, including geologic storage and
underground injection, terrestrial ecosystems, novel chemical, and biological means, and the use of
technologies that are not yet discovered. These suggestion goes beyond the scope of the Project
because no off-site mitigation suggestions were offered by the commenter and the sequestration
concepts involve complex systems for which no nexus has been established to the Project’s impacts
and for which no evidence of feasibility has been provided. CEQA does not require adoption of every
imaginable mitigation measure. CEQA’s requirement applies only to feasible mitigation that will
“substantially lessen” a project’s significant effects. (Public Resources Code, § 21002.) As explained
by one court: A lead agency's “duty to condition project approval on incorporation of feasible
mitigation measures only exists when such measures would [avoid or] ‘substantially lessen’ a
significant environmental effect.” (San Franciscans for Reasonable Growth v. City and County of San
Francisco (1989) 209 Cal.App.3d 1502, 1519.) “Thus, the agency need not, under CEQA, adopt every
nickel and dime mitigation scheme brought to its attention or proposed in the project EIR.” (Ibid.)
Rather, an EIR should focus on mitigation measures that are feasible, practical, and effective. (Napa
Citizens for Honest Government v. Napa County Board of Supervisors (2001) 91 Cal.App.4th 342,
365.) Of note, and as depicted on DEIR Figure 3-10, Preliminary Landscape Plan, trees and other
plantings will occur in the Project’s passenger vehicle parking areas, around the portions of the building
visible from off-site areas, as well as the site’s frontages with 3rd Street, Victoria Avenue, and W
Street, which will aid in carbon sequestration.
H1-36 The commenter suggests the use of local and sustainable building materials. It is beyond the authority
of the City of San Bernardino to stipulate building material sources, and the commenter provides no
data on proportional nexus between the Project’s impacts and this suggestion.
H1-37 The commenter suggests best practices in agriculture. The proposed Project is not an agricultural
project, so this suggestion does not apply.
H1-38 The commenter suggests environmentally responsible purchasing. It is beyond the authority of the City
to stipulate how consumer goods are packaged and used in daily business operations, and the
commenter provides no data on proportional nexus between the Project’s impacts and this suggestion.
H1-39 The commenter makes a broad statement about implementation of an innovative GHG mitigation
strategy. Refer to Response H1-21 for a list of some of the design features, mitigation measures,
conditions of approval, and other items that must be complied with as part of regulatory compliance
that will serve to reduce the Project’s GHG emissions. Also refer to Response H1-30 for a discussion
of the Project’s accommodation of EV charging.
H1-40 The commenter supplies suggestions for energy efficiency and reduction of urban heat islands. Refer
to Responses H1-21, H1-33, and H1-35.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-118
H1-41 The commenter introduces suggested mitigation measures from a NDECS list published in 2010. Refer
to Responses H1-22 through H1-44 for responses to the commenter’s suggested mitigation measures.
H1-42 The commenter suggests the use of diesel control technology during construction. This request is
accommodated. Pursuant to Mitigation Measure MM 4.1-1, CARB Tier IV construction equipment
must be used unless it cannot be reasonably acquired. Pursuant to Mitigation Measure MM 4.1-2,
heavy-duty trucks with a gross vehicle weight over 14,000 pounds must be 2010 or newer or be
equipped with a particulate trap. Pursuant to Mitigation Measure MM 4.1-3, all construction
equipment must comply with applicable CARB regulations. Also, pursuant to MM 4.1-3A, an area of
the construction site will be designated at which electric or non-diesel equipment and tools can be
fueled or charged and pursuant to Mitigation Measure MM 4.1-3B, contractors are required to use
electric or non-diesel off-road trucks and construction support equipment if such equipment is available
in the contractor’s fleet and can fulfill the Project’s construction requirements during the building
construction obligations.
H1-43 The commenter makes additional suggestions for the use of non-diesel equipment during construction.
Please refer above to Response H-42.
H1-44 The commenter suggests that construction equipment be reported. Reporting is not necessary. Pursuant
to Mitigation Measure MM 4.1-1, CARB Tier IV construction equipment must be used unless it cannot
be reasonably acquired as described in MM 4.1-1.
H1-45 The commenter makes a concluding comment and opines that the City should prepare an updated
DEIR. There is no information provided in these comments or responses thereto that would warrant
recirculation of the DEIR. The DEIR circulated for public review was fundamentally and basically
adequate, and as such, recirculation of the DEIR is not warranted set forth in §15088.5 of the State
CEQA Guidelines.
H1-46 SWAPE states that they reserve the right to make additional comments. The City acknowledges this
comment.
H-47 These tables are noted as part of Comment H1-20 and Response H1-20, above.
Page F-119
Comment Letter H2
H2-1
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Elizabeth Mora-Rodriguez
From:
Sent:
To:
Cc:
Subject:
adam salcido <asalcido .07@gmail.com>
Tuesday, January OS , 202110:39 AM
Elizabeth Mora-Rodriguez
Unknown ; jbourgeois029@gmail.com; Terrance Lucio; PATRICK HANING ER
The Landing by San Manuel
Caution -This email originated from outs ide the City -Verify that the Email display
name and Email address are consistent. -Use caution when opening attachments.
Greetings Ms. Mora-Rodriguez,
Please provide any updates to the above mentioned project .
I am requesting under Public Resource Code Section 21092.2 to add the email addresses and mailing address below to the
notification list, regarding any subsequent environmental documents, public notices, public hearings, and notices of determination
for this project.
t.lucio57@gmail.com
phaningerl@gmail.com
jbourg2271@aol.com
jbourgeois029@gmail.com
asalcido.07@gmail.com
Mailing Address:
P.O . Box 79222
Corona, CA 92877
Please confirm receipt of this email .
Thank You,
Adam Salcido
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-120
RESPONSE TO COMMENT LETTER H-2
H2-1 The commenter requests that several individuals be included on notification lists for the Project. The
City of San Bernardino will include the parties on all future public notices concerning the proposed
Project.
Page F-121
Comment L etter I
I-1
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Elizabeth Mora-Rodrig uez
From:
Sent:
To:
Subject:
robert patterson <rwpatterson84@gmail.com >
Monday, December 07, 2020 10:1 5 AM
Elizabeth Mora-Rodriguez
The Landing Draft Environmental Impact Report
Caution -This email originated from outside the City -Verify that the Email display
name and Email address are consistent. -Use caution when opening attachments .
Hi Elizabeth,
I am writing to provide comments on the draft Environmental Impact Report for the The Landing Project which has been proposed in
the city. It is vital that the Project NOT negatively impact the planned City Creek Bypass Trail which is listed on severa l planning
documents including the City's own General Plan . While the EIR has noted that the Trail is planned, we do not beli eve that the
potential impacts from the Project as planned have been adequately mitigated and want to see this addressed before final approvals
are given.
Thank you for your time.
Final EIR
]
Lead Agency: City of San Bernardino SCH No . 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-122
RESPONSE TO COMMENT LETTER I
I-1 The commenter requests additional analysis of the Project’s potential impact to the City Creek Trail.
Refer to Responses D-1 to D-6.
Page F-123
Comment Letter J
J
J2
J8
J4
J10
J6
J12
J13
J14
J1
J7
J3
J9
J5
J11
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Elizabeth Mora-Rodriguez
From:
Sent:
To:
Subject:
Andrea· Vidaurre < avidaurre@warehouseworkers.org>
Wednesday, January 06, 20214:47 PM
Elizabeth Mora-Rodriguez
Public Comment for "The Landing" DEIR
Caution -This email originated from outside the City -Verify that the Email display
name and Email address are consistent. -Use caution when opening attachments.
Dear Ms. Mora-Rodriguez,
Please accept the following 40 public comments for the Draft Environmental Impact Report SCH No. 20200100067 for the
project "The Landing" proposed by the San Manuel Band of Mission Indians.
Please accept each public comment as an individual comment from the individual who's address, number and email was
included.
Below, find the 40 public comments and subsequent additional comments from individuals.
"We, as residents of San Bernardino and surrounding communities, are concerned for our quality of life and the state of the local
economy. Our communities are facing significant environmental burdens and economic insecurity. Right now, the Landing does not
guarantee the good jobs and clean air that we need in order to truly thrive. We believe that "The Landing" project should have
legally enforceable guarantees on jobs and air quality in place so that it will actually improve our lives. The San Manuel Band of
Mission Indians has a history of taking leadership in addressing negative impacts in our communities and we look towards that
continued leadership as we work and learn together to address our concerns with this upcoming project."
Rocio Aguayo, 934 N. Perris St San Bernardino CA 92411 , 9093255813, ra gua004@ucr.edu
Anthony Victoria , 8360 Sylvan Drive Riverside, CA 92503, 9096376369, victoriaanthony9 1@ gmail.com
Samuel Rodriguez, 27391 Fisher St. Highland, CA 92346, 9096535131, rodriq uez.sam2014@qmail.com
Roxana Barrera, 1403 Union St. San Bernardino, CA, 9093002166, Roxana8arrera12@g mail.com
Darby Osnaya, 646 Walnut Street, 92324, 9095331119. vpdarby@qmail.com
Mike Chavez, 1074 E. La Cadena Dr. Suite 1, 9513150493, mchavez@ ielabor.org
Paula Venegas, 765 n. Meridian ave san bernardino ca , 9095229338, paula.venegas.alvarez@g mail.com
Anysia Aguirre , 506 E Pioneer Avenue, 9096749774, an ysiaa guirre@ gmail.com
Alondra Zaragoza, 944 Western Avenue, 9092763945, alondra.zara34@g mail.com
Guadalupe Dolan, 1991 North Kenwood Avenue, 9096998333, lu pedolanmiranda@g mail.com
Leonardo Penaloza, 1544 Genevieve st , 19094956597, leonardo.zp05@g mail.com
Miguel Rivera , 2272 w 2nd Ave, 9095629021 , M iq .r iverajr@gmail.com
James Kilbane, 37691 Stone lake, 2165715966, Jimkilbane03@aol.com
Daisy Lopez, Eastvale, 9092349094,
dlopez@warehouseworkers .org
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-124
Comment Letter J
J16
J18
J15
J17
J19
J20
J21
J22
J25
J28
J30
J26
J29
J31
J27
J23
J24
•• ••
The Landing by San Manuel
Final Environmental Impact Report
MARIA D. ORTIZ, 1281 massachusetts Ave. San bernardino ca. 92411 , 909 2721328, mariaortiz197890@g mail.com
Lety Escobar, PO Box 385 Yucaipa , Ca 92399, 9092054889, izel69hernandez@yahoo .com
SALLY I SUKDOL , 1189 Mesa Verde Ave ., San Bernardino , .CA 92404, 9096489172, ssukdol64 @q mail .com
Bernard De La Garza, 934 N. Perris St. San Bernardino, CA 92411 , 9094623992, Bernarddelag arza96 @q mail.com
Krystina M. Montano, 1700 e date st apartment 1047 San Bernardino ca 92404, 909.676.1392,
K rystinamontano511910@g mail.com
"You need to take into consideration the impact on children and the community by creating another warehouse."
-Socorro Anchondo, 9060 North Valencia Ave San Bernardino 92410, (909) 332-4202
"There's land out on Greenspot Rd out towards the East Valley Water District."
-Yvonne Miranda, 26731 Fleming St, Highland 92346, 909-206-9156, YvonneMiranda@USA.com
"I am deeply concerned about the proximity to schools and the safety of the children of the community."
-Alexandra G Beltran , 5564 N F St, San Bernardino, CA 92407, (909) 273-1302, beltranred5@g mail.com
"Porfavor dejen de contaminar y dejen de aprobar proyectos que daiian la salud de los residentes de San Bernardino no
es posible que esten dejando que en menos de una milla de una escuela se esten aprobado proyectos que van a
contaminar mas soy madre de 3 niiios y me preocupa la salud de ellos porque no estan pensando en el daiio que hacen
cuantas enfermedades respiratorias estan produciendo porque solo estan pensando en sus beneficios que nose ve que
ayuden a la ciudad masque tener mas contaminacion"
-Ada Trujillo, 2640 W Rialto Ave San Bernardino, 909 571 3309 , Adat2013 .at@gmail.com
"In addition, there are multiple ways in which the proposed warehouse will negatively impact the environment and
community: extensive paved areas do not allow for the recharge or replenishment of aquifers with groundwater, and
creates additional "heat islands" that also affect air quality; industries that utilize such distribution centers do not
additionally invest the capital gains from their business into the region, though we would urge you to find ways through
Community Benefits Agreements and maybe even, with economic creativity, additional tax base assurances; added traffic
at this site will not only impact other BIPOC in the area, but those living at San Manuel too. In other words, this will place a
huge environmental burden on Native people who have historically been subjected to this same form of environmental
racism at the hands of White businesses and industrialists in the past."
-Catherine Gudis, 900 University Avenue, Riverside, CA 92521 , 323-445-9557, cagudis@ucr.edu
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"Enough is enough of destroying out communities, when you come to someones home you respect it. Show us respect J
and give us what we deserve and a strong CBA"
-Angie, 7833 strathmore road , Highland, CA 909.7429092, An g ie.balderas@sierraclub.org
"Liveable wages and safe working environments are essential" J
-Phillip Hubbard 111, 5784 Carsten Court, Fontana CA 92336, 9512040966, ucla2dallas@g mail.com
~-~~~ J -Breanna Hall , 3313 Antler rd . San Bernardino, CA 9099693142, Brehall1081 @g mail.com
"After SMBMI, becomes a warehouse holder, how long before they in turn sell out to another company and is that J
company going to uphold the same agreement as SMBMI?"
-Annette, 26316 Cypress Street, Highland CA 92346, 909-725-5313 , Panyopolis2@sbcqlobal.net
"Our community needs a CBA now!!!" J
-Martha Romero , 27037 9th St. Highland CA 92346 , 9095017297 , lashka29@yahoo.com
"Let's do right by our community and let's stop destroying our land . We should also implement strong CSA for our J
communities . Let's build healthy sustainable communities together."
-Abigail medina Rosales , 2697 Rosemary Lane, 9097429092, abigailmmedina@aol.com
"No queremos mas contaminaci6n en nuestro aire" 7
2
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
Page F-125
Comment Letter J
J32
J36
J37
J40
J38
J39
J35
J33
J34
J31(cont)
•• ••
The Landing by San Manuel
Final Environmental Impact Report
• Felipe Avila, 773 w 8 Th St San Bernardino, 9097082825
''There needs to be adequate public sidewalks and room far from the street for walking on both sides of the road safely.
There should also be bike lanes ."
. Peter Mendoza, 6th St , Highland CA 92346, 19098311575, stpetermi@gmail.com
"Don 't pollute our community-protect it."
• Ellen Reese, 1936 Delta St, Los Angeles CA 90026, (213) 793-0326, ellenrivoli@qmail.com
"K no queremos mas contam inaci6n en nuestra c iudad"
-Maria Luisa Ramirez, 749 NH St San Bernardino, 7145748885, marialramirez0825@qmail.com
"As a tax paying concerned community member of San Bernardino county I am asking for there to be a community
benefits agreement which wou ld ensure health, safety and good paying jobs for our local community members! We all
need to work together to ensure that the developers, businesses and residents of this great county can all achieve the
very best for the betterment of everyone in our community!"
-Jennifer Cheek , 13335 Stoneridge Dr. Victorville, Ca 92395, 760-267-459, jennifercheek47@gmail.com
"Building more warehouses is only going to create more pollution . There are also no guarantees for workers . Please
consider the land and environment over money and profits ."
• Ann Kaneko, 12323 Culver Blvd ., Los Angeles , CA 90066, 3233334086, annkaneko@qmail.com
"My concern is the air pollution and street traffic this will bring to our City. We already have detoriating roads that are not
maintained ."
• Janette Mckaig , 3188 N Mountain View Ave, 5624999874, janettemckaigcep@hotmail.com
"I strongly urge the San Manuel Band of Mission Indians to set a precedent with The Landing project by ensuring it comes
with multi-generational benefits for our community. We're surrounded by so many dead-end jobs that wear people down
with no hope of anything better for their children . The effects of the pandemic show the urgent need to do things
differently. Please plan this development with good jobs that are for local residents and enable families to thrive . Please
plan a development that puts people's health and environmental sustainability first."
• Athena Tan , 690 N 2nd Ave, Upland CA 91786 (employed in San Bernard ino), 909-358-5456, athena.tan@gmail.com
'We take the burden of warehouses without getting any benefits . The majority of jobs in warehouses are low paying , part
time , and grueling . We cannot rebuild the region's economy with warehouse jobs. Our precious tax dollars go to repair
roads damaged by warehouse truck traffic and to mitigate traffic congestion caused by those same trucks . We suffer the
adverse health effects of significant increases in air pollution caused by truck and airplane traffic as well as the noise
pollution that affects our health and quality of life . We deserve and therefore demand our share of the benefits from
warehouse construction ."
• Jody Isenberg, 1278 Andreas Ave San Bernardino 92404, 909 838-2803, Jodyleei52@gmail.com
"Residents deserve clean air in their communities . As a city with high rates of asthma and some of the worst air quality in
the nation we should be helping resolve the issue not making it worse."
• Julia Vega , 26262 redlands blvd apt 127 Redlands CA 92373 , 9097896580, jveqa4816@gmail.com
Thank you for your time and please send me an email confirming that you received this email and that these public
comments were submitted for the record .
Best,
Andrea Vidaurre
Senior Policy Analyst
Warehouse Worker Resource Center
Cell : (909) 827-8812
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Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-126
RESPONSES TO COMMENT LETTER J
J The City acknowledges the comments provided on the proposed Project, and that the commenters have
concerns related to the Project’s environmental and economic effects. Please refer to the individual
responses to the concerns expressed by this comment letter (i.e., responses to Comments J1 through
J40). The comment does not raise any concerns with the DEIR’s analysis.
J1 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J2 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J3 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J4 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J5 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J6 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J7 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J8 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J9 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J10 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-127
J11 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J12 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J13 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J14 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J15 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J16 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J17 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J18 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J19 This commenter has been added to the list of parties that will be notified regarding future public
hearings for the proposed Project. As this comment does not identify any issues with the Draft EIR,
no revisions to the Draft EIR are warranted pursuant to this comment.
J20 This comment indicates that the Draft EIR should take into consideration the impact on children and
the community associated with the proposed Project. The Project’s impacts on the environment,
including impacts to sensitive receptors (i.e., residents and school children) are evaluated throughout
the Draft EIR. For example, the analysis of the Project’s impacts to air quality consider potential health
risk effects to nearby school children, and demonstrates that localized air quality impacts affecting
nearby school children would be less than significant. As this comment does not identify any potential
impacts to the community or children within the surrounding area that have not already been addressed
by the Draft EIR, no revisions to the Draft EIR are warranted pursuant to this comment.
J21 This comment indicates that there may be available land for development on Greenspot Road near the
East Valley Water District. Section 6.0 of the Draft EIR includes an analysis of Project alternatives,
and includes a discussion of alternative site locations. As indicated in Draft EIR subsection 6.2.1,
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-128
alternative site locations were rejected from detailed consideration in the EIR. In this particular case,
the Project Applicant does not own the land referenced by this comment. Furthermore, the analysis in
subsection 6.2.1 indicates that “development of the Project in an alternative location would reasonably
result in similar environmental impacts as would occur with implementation of the Project at its
proposed location because the Project’s significant and unavoidable impacts are related to air quality,
GHGs, traffic-related noise, and VMT” (Draft EIR at Pages 6-5 and 6-6). Under CEQA, in making
the decision to include or exclude an analysis of an alternative site, the “key question and first step in
analysis is whether any of the significant effects of the project would be avoided or substantially
lessened by putting the project in another location. Only locations that would avoid or substantially
lessen any of the significant effects of the project need to be considered for inclusion in the EIR”
(CEQA Guidelines Section 15126.6(f)(2)). Accordingly, because alternative site locations would not
meet CEQA requirements for alternatives, alternative site locations were excluded from detailed
analysis within the Draft EIR. No revision to the Draft EIR is warranted pursuant to this comment.
J22 This comment indicates concern about the Project’s proximity to schools and the potential
environmental effects the Project may have on children. As indicated in the response to Comment J20,
the Draft EIR considers potential impacts to schools and children. For example, the analysis of the
Project’s impacts to air quality considers potential health risk effects to nearby school children, and
demonstrates that localized air quality impacts affecting nearby school children would be less than
significant. Additionally, as indicated in Draft EIR subsection 5.4.14 (refer to the discussion of
Threshold a.(iii)), the Project Applicant would be required to contribute development impact fees to
the San Bernardino City Unified School District (SBCUSD), in compliance with California Senate Bill
50. Mandatory payment of school fees would be required prior to the issuance of a building permit.
Pursuant to Senate Bill 50, payment of school impact fees constitutes complete mitigation for project-
related impacts to school services. With mandatory payment of fees in accordance with California
Senate Bill 50, there would be no impacts to public schools. Accordingly, no revision to the Draft EIR
is warranted pursuant to this comment.
J23 This comment expresses concerns regarding pollution and associated health effects, as well as concerns
regarding the proximity of schools to the Project, particularly in relation to potential air quality effects.
Air quality impacts associated with the proposed Project are addressed in EIR Subsection 4.1, Air
Quality. As indicated in the analysis provided in subsection 4.1.5 (refer to the discussion of Threshold
c.), implementation of the Project: 1) would not exceed applicable SCAQMD localized criteria
pollution emissions thresholds during construction and operation; 2) would not expose sensitive
receptors (including potential health risks to school children) to toxic air contaminants (e.g., DPM)
from construction or long-term operations that exceed the applicable SCAQMD carcinogenic and non-
carcinogenic risk thresholds; and 3) would not cause or contribute to the formation of a CO “hot spot.”
As such, the Draft EIR discloses that localized air quality impacts associated with the Project would
be less than significant. As this comment does not identify any deficiencies under the analysis of
Threshold c. of subsection 4.1.5, no revisions to the Draft EIR are warranted pursuant to this comment.
J24 This comment expresses concerns related to aquifer recharge, heat island effects, and economic effects
associated with the proposed Project, requests a Community Benefits Agreement be adopted for the
Project, indicates concerns related to traffic, and identifies concerns related to environmental justice.
Project impacts associated with infiltration and groundwater are evaluated in EIR Subsection 5.4.9
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-129
(refer to the analysis of Threshold b.). As indicated therein, while development of the Project would
increase impervious surface coverage on the Project Site, which would, in turn, reduce the amount of
water percolating down into the underground aquifer that underlies the Project site and surrounding
areas (i.e., Bunker Hill Groundwater Basin), the Bunker Hill Basin is a part of the San Bernardino
Basin Area, and is among the most rigorously managed groundwater basins in the State. Planning and
management efforts evaluating needs and supplies have been established for most of the basins within
the watershed through the next 20 to 40 years. Groundwater is managed in accordance with a legal
settlement that, in part, identifies a natural safe yield and requires groundwater replenishment if
cumulative extractions exceed water rights allocation (WSC, 2017, pp. 2-7 to 2-8). Due to the
extensive management of the groundwater basin, implementation of the Project would not interfere
substantially with groundwater recharge such that the Project may impede sustainable groundwater
management of the basin. Additionally, the Project includes design features that would maximize the
percolation of on-site storm water runoff into the groundwater basin, such as detention/infiltration
basins and permeable landscape areas. Furthermore, runoff from the Project Site would be conveyed
to existing drainage facilities, which ultimately would convey flows to downstream areas where
infiltration would occur (e.g., the Santa River and Prado Dam). As this comment does not identify any
deficiencies in the Draft EIR’s analysis of potential effects to groundwater supplies, no revisions to the
Draft EIR are warranted pursuant to this comment.
With respect to potential “heat island” effects, draft EIR Mitigation Measure MM 4.4-1 includes a
requirement that the roof of the proposed building must be composed of light-colored roofing material.
Additionally, the Project would require extensive amounts of landscaping, which would further assist
in reducing any localized “heat island” effects. As this comment does not identify any deficiencies
with the analysis contained in the Draft EIR, no revision to the Draft EIR is warranted pursuant to this
comment.
An analysis of the Project’s potential impacts to transportation is provided in Draft EIR Subsection
4.8, Transportation. As indicated therein, the Project would be conditioned to contribute DIF fees as
well as fair share contributions towards improvements needed to achieve an acceptable Level of
Service (LOS) at all study area facilities. With implementation of the improvements identified in
subsection 4.8, all study area intersections would operate at an acceptable LOS. Subsection 4.8 also
discloses that the Project would result in significant and unavoidable impacts due to Vehicle Miles
Travelled (VMT). As this comment does not identify any deficiencies in the analysis of potential
impacts to transportation, no revision to the Draft EIR is warranted pursuant to this comment.
With respect to the commenter’s concerns related to environmental justice, the analysis provided
throughout the Draft EIR discloses and identifies the Project’s potential impacts to the environment.
For example, EIR Subsection 4.1, Air Quality, includes an extensive discussion of the Project’s
localized air quality effects, and demonstrates that the Project would result in less-than-significant
localized air quality impacts. No revisions to the Draft EIR are warranted pursuant to this comment.
The commenter’s recommendation for a Community Benefits Agreement will be considered by the
City decision-makers during their deliberations as to whether to approve the proposed Project. As such
an agreement would not affect the Project’s potential impacts to the environment, no revision to the
Draft EIR is warranted pursuant to this comment.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-130
J25 This comment indicates opposition to the proposed Project and recommends a CBA (which is
understood as a reference to a Collective Bargaining Agreement). As this comment does not identify
any deficiencies with the Draft EIR, no revisions to the Draft EIR are warranted pursuant to this
comment.
J26 This comment requests that the Project provide for livable wages and a safe working environment. As
this comment does not identify any deficiencies with the Draft EIR, no revisions to the Draft EIR are
warranted pursuant to this comment.
J27 This comment requests good jobs and clean air. EIR Subsection 4.1, Air Quality, provides an extensive
analysis of the Project’s potential impacts to air quality. As this comment does not identify any
deficiencies with the Draft EIR, no revisions to the Draft EIR are warranted pursuant to this comment.
J28 This comment indicates concern regarding ownership of the proposed Project and whether successors
in interest would be subject to the same requirements as the currently-proposed Project. All Project-
related requirements would be memorialized as part of conditions of approval that would be adopted
in conjunction with Project approval, and all future successors in interest would be required to comply
with the Project’s conditions of approval. As this comment does not identify any deficiencies with the
Draft EIR, no revisions to the Draft EIR are warranted pursuant to this comment.
J29 This comment expresses a preference for a CBA (which is understood as a reference to a Collective
Bargaining Agreement). As this comment does not identify any deficiencies with the Draft EIR, no
revisions to the Draft EIR are warranted pursuant to this comment.
J30 This comment indicates concerns over the Project’s impacts to the environment, and also expresses a
desire for a CBA (which is understood as a reference to a Collective Bargaining Agreement). The
Project’s potential impacts to the environment are evaluated throughout the Draft EIR. As this
comment does not identify any deficiencies with the Draft EIR or its analysis of potential impacts to
the environment, no revisions to the Draft EIR are warranted pursuant to this comment.
J31 This comment indicates a concern about potential air quality impacts associated with the Project. EIR
Subsection 4.1, Air Quality, provides an extensive analysis of the Project’s potential impacts to air
quality. As this comment does not identify any deficiencies with the Draft EIR or its analysis of
potential impacts to air quality, no revisions to the Draft EIR are warranted pursuant to this comment.
J32 This comment expresses a desire for adequate sidewalks, bicycle lanes, and pedestrian/bicycle safety.
Please refer to the discussion provided in EIR Subsection 3.5.4.F, which includes a description of
roadway improvements proposed as part of the Project. As indicated, the Project would accommodate
a bicycle crossing at the intersection of 3rd Street and Victoria Avenue, and a bicycle lane already exists
on both sides of 3rd Street. The Project also would allocate space for a future Class I bike trail along
3rd Street and would maintain the existing sidewalks along the Development Site’s frontages with 3rd
Street and Victoria Avenue. All improvements proposed as part of the Project would conform to
applicable City standards and requirements, which were adopted in order to provide for bicycle and
pedestrian safety. No revisions to the Draft EIR are warranted pursuant to this comment.
J33 This comment indicates concerns over pollution within the community. Project impacts to the
environment are evaluated throughout the Draft EIR. Air quality effects associated with the Project
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-131
are evaluated under Draft EIR Subsection 4.1, Air Quality. As this comment does not identify any
deficiencies with the Draft EIR or its analysis of potential impacts to the environment, no revisions to
the Draft EIR are warranted pursuant to this comment.
J34 This comment indicates a concern about potential air quality impacts associated with the Project. EIR
Subsection 4.1, Air Quality, provides an extensive analysis of the Project’s potential impacts to air
quality. As this comment does not identify any deficiencies with the Draft EIR or its analysis of
potential impacts to air quality, no revisions to the Draft EIR are warranted pursuant to this comment.
J35 This comment recommends that the Project be subject to a Community Benefits Agreement. The
commenter’s recommendation for a Community Benefits Agreement will be considered by the City
decision-makers during their deliberations as to whether to approve the proposed Project. As such an
agreement would not affect the Project’s potential impacts to the environment, no revision to the Draft
EIR is warranted pursuant to this comment.
J36 This comment expresses concerns over the Project’s potential for causing pollution, and indicates a
concern regarding guarantees for workers, presumably in reference to future wages. Project impacts
to the environment are evaluated throughout the Draft EIR. Air quality effects associated with the
Project are evaluated under Draft EIR Subsection 4.1, Air Quality. As this comment does not identify
any deficiencies with the Draft EIR or its analysis of potential impacts to the environment, no revisions
to the Draft EIR are warranted pursuant to this comment.
J37 This comment expresses concerns related to air pollution, traffic, and roadway maintenance. Air
quality effects associated with the Project are evaluated under Draft EIR Subsection 4.1, Air Quality,
while the Project’s impacts to transportation are evaluated in Draft EIR Subsection 4.8, Transportation.
As this comment does not identify any deficiencies with the analyses presented in Draft EIR Subsection
4.1 and 4.8, no revisions to the Draft EIR are warranted pursuant to this comment. With respect to
roadway maintenance, the proposed Project would result in an increase in tax revenue within the City,
portions of which would be used by the City to ensure adequate maintenance of local roads. There are
no components of the proposed Project that would interfere with the ability of the City of San
Bernardino or City of Highland to conduct roadway maintenance. No revisions to the Draft EIR are
warranted pursuant to this comment.
J38 This comment expresses a desire for the Project to include good paying jobs, and expresses concerns
over public health and quality of life. The Project’s potential impacts to the environment, including
potential impacts to public health, are addressed throughout the Draft EIR. As this comment does not
identify any deficiencies with the Draft EIR or its analysis of potential impacts to the environment, no
revisions to the Draft EIR are warranted pursuant to this comment.
J39 This comment expresses concerns regarding the quality of future Project-generated jobs, potential
impacts to roadway maintenance, and potential adverse health effects associated with Project-related
traffic, including air quality impacts and traffic-related noise impacts. Air quality impacts associated
with the proposed Project are addressed in EIR Subsection 4.1, Air Quality, while the Project’s traffic-
related noise impacts are evaluated in Draft EIR Subsection 4.7, Noise. As this comment does not
identify any deficiencies with the analyses provided in Draft EIR Subsections 4.1 and 4.7, no revisions
to the Draft EIR are warranted pursuant to this comment. With respect to roadway maintenance, the
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-132
proposed Project would result in an increase in tax revenue within the City, portions of which would
be used by the City to ensure adequate maintenance of local roads. There are no components of the
proposed Project that would interfere with the ability of the City of San Bernardino or City of Highland
to conduct roadway maintenance. No revisions to the Draft EIR are warranted pursuant to this
comment.
J40 This comment expresses concerns regarding air quality and potential localized air quality effects that
could adversely affect sensitive receptors, such as individuals with asthma. The Project’s potential
impacts to air quality, including localized air quality impacts affecting sensitive receptors, are
addressed in EIR Subsection 4.1, Air Quality. As this comment does not identify any deficiencies with
the analysis and conclusions presented in Draft EIR Subsection 4.1, no revisions to the Draft EIR are
warranted pursuant to this comment.
Page F-133
Comment Letter K
K-1
•• ••
The Landing by San Manuel
Final Environmental Impact Report
Elizabeth Mora-Rodriguez
From:
Sent:
To:
Subject:
Jim Brown <contrax35@gma il.com>
Monday, January 18, 2021 2:25 PM
Elizabeth Mora-Rodriguez
The Landing NOP
caution -This email originated from outside the City -Verify that the Email display
name and Email address are consistent. -Use caution when opening att achments.
Hi Elizabeth,
I am writing to provide comments on the Notice of Preparation for the The Landing Project which has been proposed in the city. It is ]
vital that the Project NOT negatively impact the planned City Creek Bypass Trail which is listed on several planning documents
including the City's own General Plan . Yet, that is not the case at present as the current plans sh ow that the Project would cut off the
Trail which is a Significant Impact under CEOA and an injustice to the community. This needs to be avoided and a different
alternative found which preserves the Trail and constructs it with any other onsite improvements.
Thank you for your time.
Final EIR
Lead Agency: City of San Bernardino SCH No . 2020100067
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-134
RESPONSE TO COMMENT LETTER K
I-1 The commenter requests additional analysis of the Project’s potential impact to the City Creek Trail.
Refer to Responses D-1 to D-6.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-135
F.3 ADDITIONS, CORRECTIONS, AND REVISIONS TO THE DRAFT EIR
Revisions made to the text, tables, and/or exhibits of the DEIR in response to public comments on the DEIR
are itemized in Table F-2, Errata Table of Additions, Corrections, and Revisions. Additions are shown in
Table F-2 as underline text and deletions are shown as stricken text. No corrections or additions made to the
DEIR are considered substantial new information requiring recirculation or additional environmental review
under CEQA Guidelines § 15088.5.
Table F-2 Errata Table of Additions, Corrections, and/or Revisions to the Draft EIR
REVISED
DEIR PAGE(S) SECTION(S) ADDITIONS, CORRECTIONS, AND/OR REVISIONS
Throughout Throughout The following minor typographical corrections have been made to the DEIR:
Page
1-2
1-5
4.5-7
4.7-29
4.7-31
4.8-6
Revisions
• Specifically, SPA 20-01 would add approximately 12.89 acres
located on the southern portion of the Development Site to the
SBAC-SP and remove approximately 4.97 acres located west
of the Development Site and west of Victoria Avenue from the
SBAC-SP.
• Regardless of whether or not an environmental or CEQA-
related comment is listed in the table, all relevant comments
received in response to the NOP and the EIR Scoping Meeting
are addressed in this EIR.
• The Seven Oaks Dam has been designed to resist an
earthquake measuring 8.0 on the Richter scale, and also is
designed to provide flood protection during 350-year floor
flood events.
• Based on the significance criteria for off-site traffic noise
presented in Table 4.7-6, the following study area roadway
segments is are shown to experience potentially significant off-
site cumulative traffic noise level increases.
• Since trucks rarely create vibrations that exceed 70 VdB
(unless there are bumps due to frequent potholes in the road),
it is expected that the on-site heavy trucks will be travelling at
very low speeds so activity would satisfy the maximum-
acceptable vibration criteria of 78 VdB for daytime and 72
VdB for nighttime for residential uses, and therefore, impacts
would be less than significant.
• For the purposes of this analysis, the initial VMT screening
process has been conducted with using the San Bernardino
County Transportation Authority (SBCTA) VMT Screening
Tool, which uses screening criteria consistent with the
screening thresholds recommended in the Technical Advisory
and City Guidelines.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-136
Table F-2 Errata Table of Additions, Corrections, and/or Revisions to the Draft EIR
REVISED
DEIR PAGE(S) SECTION(S) ADDITIONS, CORRECTIONS, AND/OR REVISIONS
4.8-7
4.8-11
4.8-12 and
4.8-13
4.8-13
Throughout
• The City Guidelines identifyies local serving retail projects
less than 50,000 square feet or other local serving uses (e.g.,
day care centers, student housing, public facilities, places of
worship, etc.) may be presumed to have a less than significant
impact absent substantial evidence to the contrary.
• Furthermore, pursuant to Title 13 of the California Code of
Regulations, Section 2485, large trucks would be limited to no
more than five minutes of idling.
• Because a sidewalk and bicycle lane occur along the
Development Site’s frontage in the 3rd Street public right-of-
way, there is a potential for increased hazards to occur
associated with trucks entering and existing exiting across the
sidewalk and bicycle lane.
• However, the cumulative link-level VMT per service
population within the City of San Bernardino does not
increase under with implementation of the Project; therefore,
the Project would have a less-than-significant cumulatively-
considerable impact due to VMTs.
• Throughout the DEIR, references to “VMTs” (Vehicle Miles
Travelled) has been corrected to instead use the acronym
“VMT.”
Page 2-1 Subsection 2.3 The following revision has been made to reflect the fact that the Airport Gateway
Specific Plan has been increased in size by approximately 9 acres, and to correct the
reference to the City Creek Bypass.
• This area is in the planning stages for a mix of industrial uses under the
IVDA’s proposed “Airport Gateway Specific Plan (AGSP),” which covers
approximately 670 679 acres generally bounded by 6th Street and Highland
Creekthe City Creek Bypass on the north, 3rd Street and the SBIA on the
south, State Route 210 (SR-210) on the east, and Tippecanoe Avenue on the
west. The Specific Plan area includes parcels in both the City of Highland
(±485 acres) and the City of San Bernardino (±185 194 acres).
Page 3-11 Table 3-3 The list of approvals required by the San Bernardino International Airport Authority
(SBIAA) has been expanded to include the following additional approvals:
• Approval of utility service and connection agreements.
• Approval of airport-related street improvement permits.
4.1-5 4.1.1.D.1 The text on Page 4.1-5 has been corrected to reflect the fact that O3 is not a directly
emitted pollutant:
• Emissions of O3, NOX, VOC, and CO, and ozone precursors have been
decreasing in the SCAB since 1975 and are projected to continue to decrease
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-137
Table F-2 Errata Table of Additions, Corrections, and/or Revisions to the Draft EIR
REVISED
DEIR PAGE(S) SECTION(S) ADDITIONS, CORRECTIONS, AND/OR REVISIONS
beyond 2020.
4.1-10 4.1.1.D.1 The following correction has been made to more clearly state the reduction of CO
concentrations in the SCAB:
• 8-hour CO concentrations in the SCAB have been decreased markedly – a
total decrease of by more about 80 percent in the peak 8-hour concentration
since 1986.
4.1-27 4.1.5
(Threshold a)
The following text has been added to the discussion of Consistency Criterion No. 2 to
more explicitly disclose the anticipated increase in “Industrial Light (IL)” building
area that would result from Project approval:
• Specifically, implementation of the proposed Project would result in a net
increase in areas designated for “IL” development, and the permitted
building square footage for IL land uses in the Third Street District would
increase from 1,080,288 s.f. to 1,252,350 s.f.
4.1-39
S-11
4.1.8 The following mitigation measure has been added:
• MM 4.1-3A: Plans submitted for grading permit issuance and building
permit issuance shall specify a designated area of the construction site where
electric or non-diesel vehicles, equipment, and tools can be fueled or
charged. The provision of temporary electric infrastructure for such purpose
shall be approved by the utility provider, Southern California Edison (SCE).
If SCE will not approve the installation of temporary power for this purpose,
the establishment of a temporary electric charging area will not be required.
If electric equipment will not be used on the construction site because the
construction contractor(s) does not have such equipment in its fleet (as
specified in Mitigation Measure MM 4.1-3B), the establishment of a
temporary electric charging area also will not be required. If electric-
powered equipment is in the contractor(s) equipment fleet, and SCE
approval is secured, the temporary charging location is required to be
established upon issuance of grading permits and building permits.
4.1-40
S-12
4.1-8 The following mitigation measure has been added:
• MM 4.1-3B: If electric or non-diesel off-road trucks and construction
support equipment, including but not limited to hand tools, forklifts, aerial
lifts, materials lifts, hoists, pressure washers, plate compactors, and air
compressors are available in the construction contractor’s equipment fleet
and can fulfill the Project’s construction requirements during the building
construction, paving, and architectural coating phases of Project
construction, such equipment shall be used during Project construction.
This requirement shall be noted on plans submitted for building permit
issuance.
4.1-40
S-12
4.1-8 The following mitigation measure has been added:
• MM 4.1-3C: Plans submitted for grading permit issuance and building
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-138
Table F-2 Errata Table of Additions, Corrections, and/or Revisions to the Draft EIR
REVISED
DEIR PAGE(S) SECTION(S) ADDITIONS, CORRECTIONS, AND/OR REVISIONS
permit issuance shall specify the locations where anti-idling signs will be
located. Signs shall be placed on the construction site where medium and
heavy-duty trucks and other heavy equipment will stage, identifying
applicable California Air Resources Board (CARB) anti-idling regulations.
At a minimum, each sign shall include: 1) instructions to shut off engines
when equipment is not in use; and 2) instructions to restrict idling to no
more than five (5) minutes.
4.2-4 4.2.1.G The following text has been added to clearly indicate that the Development Site does
not serve as a component of any wildlife linkages or corridors:
• Furthermore, the Development Site does not connect to any habitat to the
north, south, east, or west. The nearest areas that may facilitate wildlife
movement in the local area are the City Creek and Santa Ana River, and the
Development Site is separated from these features by existing roadways and
development.
4.4-35 4.4.7 Mitigation Measure 4.4.1(d) has been expanded”
• MM 4.4-1(d): As part of shell building permit issuance, and subject to the
approval of the Federal Aviation Administration for the installation of
rooftop solar panels near an airport, the applicant shall be required to
install a rooftop photovoltaic (PV) system providing a minimum of 24,000
watts (24 KW) of power per year. The remaining area of the building’s roof
shall be designed and constructed to accommodate the potential, future
construction of additional photovoltaic (PV) solar arrays taking into
consideration limitations imposed by other rooftop equipment, roof
warranties, building and fire code requirements, and other physical or legal
limitations. The building shall be designed to accommodate an electrical
system and other infrastructure sufficiently sized to accommodate the
potential installation of additional PV arrays in the future.
4.4-35
S-23
4.4.7 The following mitigation measure has been added:
• MM 4.4-2: Prior to the issuance of a building permit for warehouse building
space that contains refrigerated or freezer storage, an electrical hookup
shall be provided at all loading dock doors that are designated for the
loading/unloading of trailers holding refrigerated/frozen goods, for the
purpose of plugging the refrigeration units installed on such trailers into the
building’s electrical system. If refrigerated/freezer warehouse space is not
proposed, electrical hookups at dock doors will not be required.
4.5-2 4.5.1.A The following revision has been made to clarify the length of the Santa Ana River and
its major tributaries:
• The Santa Ana River flows over 100 miles, and Tthe total length of the Santa
Ana River and its major tributaries is approximately 700 miles.
4.6-2 4.6.1.A The following revisions were made to correct the acreage associated with the AGSP
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-139
Table F-2 Errata Table of Additions, Corrections, and/or Revisions to the Draft EIR
REVISED
DEIR PAGE(S) SECTION(S) ADDITIONS, CORRECTIONS, AND/OR REVISIONS
and to correctly identify the City Creek Bypass.
• This area is in the planning stages for a mix of industrial uses under the
proposed “Airport Gateway Specific Plan (AGSP),” which covers
approximately 670 679 acres generally bounded by 6th Street and the City
Creek BypassHighland Creek on the north, 3rd Street and the San
Bernardino International Airport (SBIA) on the south, State Route 210 (SR-
210) on the east, and Tippecanoe Avenue on the west.
4.6-2 4.6.1.A The text on Page 4.6-2 has been revised to list the correct acreage for the AGSP
within the City of San Bernardino, as follows:
• The Specific Plan area includes parcels in both the City of Highland (±485
acres) and the City of San Bernardino (±185 194 acres).
4.6-4 4.6.2.B.2 A minor text clarification was made on DEIR Page 4.6-4, as follows:
• …and are a major reason the region is a critical mode component in the
global supply chain.
4.6-4 4.6.2.B.3 The following minor correction has been made on DEIR Page 4.6-4:
• The Project’s consistency with the 2016 AQMP was analyzed in detail in EIR
Subsection 4.1, Air Quality, and as such is not further evaluated in this
Subsection 4.68.
4.6-4 4.6.2.B.3 The text on DEIR Page 4.6-4 has been amended to reference the conclusion reached
in EIR Subsection 4.1, Air Quality, related to the Project’s inconsistency with the
SCAQMD 2016 AQMP.
• The Project’s consistency with the 2016 AQMP was analyzed in detail in EIR
Subsection 4.1, Air Quality, and as such is not further evaluated in this
Subsection 4.68. As evaluated in EIR Subsection 4.1, the Project would
result in significant and unavoidable impacts due to a conflict with the
SCAQMD 2016 AQMP.
4.6-8 and 4.6-9 4.6.4,
Threshold a.
The following text has been added to the analysis of the Project’s consistency with the
City of San Bernardino General Plan to clarify that because the Project’s air quality
impacts are fully disclosed in EIR Subsection 4.1, Air Quality, no additional
significant environmental effects would occur due to a potential conflict with General
Plan policies related to air quality:
• Additionally, although the Project would result in significant and
unavoidable impacts due to operational emissions of NOX and due to a
conflict with the SCAQMD 2016 AQMP, Project impacts associated with air
quality are fully discussed and disclosed in EIR Subsection 4.1, Air Quality;
thus, because air quality impacts already are addressed in this EIR, no
additional impacts due to a conflict with General Plan policies related to air
quality are identified.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-140
Table F-2 Errata Table of Additions, Corrections, and/or Revisions to the Draft EIR
REVISED
DEIR PAGE(S) SECTION(S) ADDITIONS, CORRECTIONS, AND/OR REVISIONS
4.6-9 and 4.6-
10
4.6.4,
Threshold a.
The following text has been added to DEIR Pages 4.6-9 and 4.6-10 to clarify that the
City comment letters and the Project Applicant’s responses thereto are available for
public review, and to indicate the location where the documents may be reviewed:
• Copies of the City’s comment letters and the Project Applicant’s responses to
City comments are available at the City of San Bernardino Planning
Division, 201 North E Street, 3rd Floor, San Bernardino, CA 92401, during
the City’s regular business hours, or can be requested in electronic form by
contacting the City Planning Division.
4.6-10 4.6.4,
Threshold a.
The following revision was made to clarify how the Project integrates the
transportation network and related strategies that respond to projected growth, and to
correctly identify the threshold of significance utilized in EIR Subsection 4.4 to
evaluate the significance of the Project’s impacts due to GHG emissions:
• The Project would be consistent with Connect SoCal for integrating the
transportation network and related strategies with an overall land use
pattern that responds to projected growth, housing needs, changing
demographics, and transportation demands by locating a proposed light
industrial warehouse development in an area that is already developed with
similar land uses; however as detailed in Subsection 4.4, Table 4.4-4, the
estimated GHG emissions from Project operation (23,514.15 MTCO2e per
year) would exceed the SCAQMD threshold (103,000 MTCO2e per year).
4.6-10 4.6.4,
Threshold a.
The following revisions have been made to clarify that because Project impacts due to
GHG emissions were fully evaluated in EIR Subsection 4.5, no additional impacts to
land use and planning have been identified as the disclosure of the Project’s GHG
emissions impacts precludes a potential inconsistency with the SCAG 2016 SCS/RTP.
• However, because the Project’s significant and unavoidable impact due to
GHG emissions are fully evaluated and disclosed in EIR Subsection 4.5,
thereby precluding a potential conflict with the 2016 SCS/RTP. Therefore,
no significant impact to land use and planning is identified due to a conflict
with the SCAG 2016 RTP/SCS.
4.6-11 4.6.4,
Threshold a.
(Table 4.6-1)
The analysis of Project consistency with the SCAG RTP/SCS as presented DEIR
Table 4.6-1 has been modified under the analysis of Item 6 to reference the
conclusion reached in EIR Subsection 4.1, Air Quality, that the proposed Project
would not result in any localized impacts due to air quality emissions, including due
to the emissions of diesel particulate matter (DPM):
• No conflict identified. This policy pertains to health and equitable
communities, and these issues are addressed through goals and policies
outlined in the Safety Element of the City’s General Plan. Relevant to the
Project, the proposed building design would support the health of occupants
and users by using non-toxic building materials and finishes per the
California Building Code, and by using windows and design features to
maximize natural light and ventilation. Additionally, and as concluded in
The Landing by San Manuel
Final Environmental Impact Report Final EIR
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Page F-141
Table F-2 Errata Table of Additions, Corrections, and/or Revisions to the Draft EIR
REVISED
DEIR PAGE(S) SECTION(S) ADDITIONS, CORRECTIONS, AND/OR REVISIONS
EIR Subsection 4.1, Air Quality, implementation of the Project: 1) would not
exceed applicable SCAQMD localized criteria pollution emissions thresholds
during construction and operation; 2) would not expose sensitive receptors
to toxic air contaminants (e.g., DPM) from construction or long-term
operations that exceed the applicable SCAQMD carcinogenic and non-
carcinogenic risk thresholds; and 3) would not cause or contribute to the
formation of a CO “hot spot.”
4.8-6 4.8.4.A The following revisions were incorporated to explain why bus routes within 0.5 mile
of the Project Site do not comprise a “major transit stop” or a “high-quality transit
corridor”:
• Although local bus service is available in the Project area via Omnitrans
Route 15, which runs along Central Avenue north of 5th Street, Church
Avenue north of 5th Street, and 5th Street between Central Avenue and
Church Avenue, the bus stops within 0.5 mile of the Project Site do not meet
the definition of a “major transit stop” pursuant to Public Resources Code
Section 212064.3 because there is no intersection of two or more major bus
routes within 0.5 mile of the Project site. Additionally, the bus stops within
0.5 mile of the Project site do not meet the definition of a “high-quality
transit corridor” pursuant to Public Resources Code Section 21155 because
the bus routes do not meet the requirement for service intervals that are no
longer than 15 minutes during peak commute hours.
4.8-12 4.8.8,
Threshold c.
The following revisions have been incorporated to more clearly explain how on-site
parking areas would serve as a staging area to preclude trucks from queuing on public
streets:
• Further, because the southwestern portion of the Development Site is
proposed to contain expansive parking areas, and the Project has beenis
designed such that trucks entering the site from W Street could utilize the
parking aisles as a staging area in order to ensure thatas an ample on-site
truck staging area, trucks will not queue on the public street.
4.8-16 4.8.11 The following clarification has been made to explain that while the Project’s
employment-generating land uses would serve to improve the jobs-housing balance in
the local area, which in turn would reduce VMT, the level of VMT reduction cannot
be quantified.
• Thus, by providing for local employment opportunities, the Project would
assist the City in improving its jobs-housing balance, thereby resulting in
reduced VMTs associated with employee trips, although the level of VMT
reduction associated with the improvement in the local jobs-housing balance
cannot be quantified.
5-4 5.3 The following revisions have been incorporated to provide an explanation as to why it
is anticipated that the majority of jobs created by the Project would be filled by
existing or planned residents within the local area:
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Page F-142
Table F-2 Errata Table of Additions, Corrections, and/or Revisions to the Draft EIR
REVISED
DEIR PAGE(S) SECTION(S) ADDITIONS, CORRECTIONS, AND/OR REVISIONS
• In addition, and as noted in Appendix 7 to the City of San Bernardino
General Plan, the City of San Bernardino supplies a relatively high number
of housing units when compared to the number of jobs provided in the City
(City of San Bernardino, 2005a, Appendix 7, p. 11). tWhile the Project
would create approximately 1,120 jobs, due to the relatively high number of
housing units compared to the number of jobs within the City, it is
anticipated that a majority of which the Project-generated jobs would likely
be filled by residents of the housing units either already built or planned for
development within the City of San Bernardino and nearby cities and
unincorporated areas.
5-18 5.4.8,
Threshold a.
The following text on Page 5-18 has been updated to reference the Project’s updated
Phase I Environmental Site Assessment (ESA) and its conclusion that the
Development Site contains no Recognized Environmental Conditions (RECs):
• An updated Phase I ESA was prepared for the Project and is included as
Technical Appendix H to this EIR. The updated Phase I ESA confirmed the
findings of the 2004 report, and further demonstrates that the Development
Site does not contain any RECswill be prepared to verify this conclusion to
support the EIR.
5-18 5.4.8,
Threshold a.
The text on DEIR Page 5-18 has been corrected to identify the Hazardous Materials
Division of the San Bernardino County Fire Department as the regulating agency
within the City for hazardous materials.
• Uses that might use hazardous materials would be subject to standard San
Bernardino County Environmental Health Services (EHS) policies and
permitting procedures required by the Hazardous Materials Division of the
San Bernardino County Fire Department.
6-4 and 6-5 6.2 The following clarification has been made to DEIR Subsection 6.2 to more fully
explain the reasons alternatives may be considered infeasible to construct or operate.
• Alternatives were rejected because either: 1) they could not accomplish the
basic objectives of the Project, 2) they would not have resulted in a reduction
of significant adverse environmental impacts, or 3) they were considered by
the City infeasible to construct or operate based on economic, regulatory, or
other reasons.
6-8 6.3.1.E The following text has been added to the discussion of the No Development
Alternative (NDA) to explain that the Project’s less-than-significant impacts
associated with inundation due to failure of the Seven Oaks Dam would be reduced.
• While impacts due to dam inundation would be less than significant under
the proposed Project due to the low likelihood of dam failure, because there
would be no new development on site under the NDA, impacts associated
with inundation related to the failure of the Seven Oaks Dam would be
reduced in comparison to the proposed Project.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
Page F-143
F.4 NO RECIRCULATION OF THE DRAFT ENVIRONMENTAL IMPACT REPORT REQUIRED
CEQA Guidelines § 15088.5 describes the conditions under which a DEIR that was circulated for public
review is required to be re-circulated for additional public review and comment. CEQA Guidelines § 15088.5
states that new information added to a DEIR is not significant unless the DEIR is changed in a way that deprives
the public of a meaningful opportunity to comment upon a substantial adverse effect of the project or a feasible
way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents
have declined to implement. “Significant new information” requiring recirculation includes, for example, a
disclosure showing that:
a. A new significant environmental impact would result from the project or from a new mitigation measure
proposed to be implemented.
b. A substantial increase in the severity of an environmental impact would result unless mitigation
measures are adopted that reduce the impact to a level of insignificance.
c. A feasible project alternative or mitigation measure considerably different from the others previously
analyzed would clearly lessen the significant environmental impacts of the project, but the project’s
proponents decline to adopt it.
d. The DEIR was so fundamentally and basically inadequate and conclusory in nature that meaningful
public review and comment were precluded.
As summarized in subsection F.3, Additions, Corrections, and Revisions to the Draft EIR, and based on the
comment letters and responses thereto presented in Subsection F.2.2, Responses to Comments on the , there
were no public comments or changes to the text or analysis contained in the DEIR that resulted in the
identification of any new significant environmental effect or a substantial increase in the severity of
environmental effects that were disclosed in the DEIR. Only minor clarifications and amplifications have been
made to the DEIR in response to public comments. Furthermore, public comment letters on the DEIR did not
identify any alternatives to the proposed Project considerably different from those analyzed in the DEIR that
would substantially lessen the significant environmental impacts of the proposed Project while still attaining
the Project’s basic objectives. Additionally, the DEIR was fundamentally and basically adequate, and all
conclusions within the DEIR were supported by substantial evidence provided within the DEIR or the
administrative record for the proposed Project.
Based on the foregoing, recirculation of the DEIR is not warranted according to the guidance set forth in
§ 15088.5 of the CEQA Guidelines.
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
ATTACHMENT 1
SUBSTANTIVELY REVISED PAGES OF THE DRAFTEIR
The Landing by San Manuel
Draft Environmental Impact Report S.0 Executive Summary
Lead Agency: City of San Bernardino SCH No. 2020100067
Page S-11
Potential Environmental Impact
Significance
Determination
Mitigation Measures (MM) and Regulatory Requirements &
Design Requirements (RRDR)
Applicable to the Development Project
Responsible/
Monitoring
Parties
Implementation
Stage
would result in a significant and unavoidable impact on both a
direct and cumulatively-considerable basis.
Threshold c): Implementation of the Project: 1) would not
exceed applicable SCAQMD localized criteria pollution
emissions thresholds during construction and operation; 2)
would not expose sensitive receptors to toxic air contaminants
(i.e., DPM) that exceed the applicable SCAQMD carcinogenic
and non-carcinogenic risk thresholds; and 3) would not cause
or contribute to the formation of a CO “hot spot.” Impacts due
to localized air quality emissions would be less than
significant.
Less than
Significant
gross vehicle weight rating greater than 14,000 pounds with a
2010 model year engine or newer or shall be equipped with a
particulate matter trap, as available. This requirement also shall
be specified in bid documents issued to prospective construction
contractors. The grading contractor shall keep a copy of records
for all on-road heavy-duty diesel trucks with a gross vehicle
weight rating greater than 14,000 pounds to demonstrate
compliance with this requirement, and the records shall be made
available to the City or City’s designee for inspection upon
request.
MM 4.1-3: Prior to grading permit issuance, the City of San
Bernardino shall review grading plans to ensure that notification is
included requiring that all construction equipment shall comply
with all applicable California Air Resources Board (CARB) air
quality regulations. Also, the notes shall require that all Project
construction contractors must tune and maintain all construction
equipment in accordance with the equipment manufacturer’s
recommended maintenance schedule and specifications. These
requirements also shall be specified in bid documents issued to
prospective construction contractors. Maintenance records for all
pieces of equipment shall be kept on-site for the duration of
construction activities and shall be made available for periodic
inspection by City of San Bernardino staff or their designee.
MM 4.1-3A: Plans submitted for grading permit issuance and
building permit issuance shall specify a designated area of the
construction site where electric or non-diesel vehicles, equipment,
and tools can be fueled or charged. The provision of temporary
electric infrastructure for such purpose shall be approved by the
utility provider, Southern California Edison (SCE). If SCE will
not approve the installation of temporary power for this purpose,
the establishment of a temporary electric charging area will not be
required. If electric equipment will not be used on the
construction site because the construction contractor(s) does not
of San
Bernardino
Project Applicant,
Construction
Contractors/ City
of San
Bernardino
Project Applicant,
Construction
Contractors/ City
of San
Bernardino
activities
Prior to issuance
of grading permits
and during
construction
activities
Prior to issuance
of grading permit
issuance and
building permit
issuance and
during
construction
activities
The Landing by San Manuel
Draft Environmental Impact Report S.0 Executive Summary
Lead Agency: City of San Bernardino SCH No. 2020100067
Page S-12
Potential Environmental Impact
Significance
Determination
Mitigation Measures (MM) and Regulatory Requirements &
Design Requirements (RRDR)
Applicable to the Development Project
Responsible/
Monitoring
Parties
Implementation
Stage
have such equipment in its fleet (as specified in Mitigation
Measure MM 4.1-3B), the establishment of a temporary electric
charging area also will not be required. If electric-powered
equipment is in the contractor(s) equipment fleet, and SCE
approval is secured, the temporary charging location is required to
be established upon issuance of grading permits and building
permits.
MM 4.1-3B: If electric or non-diesel off-road trucks and
construction support equipment, including but not limited to hand
tools, forklifts, aerial lifts, materials lifts, hoists, pressure washers,
plate compactors, and air compressors are available in the
construction contractor’s equipment fleet and can fulfill the
Project’s construction requirements during the building
construction, paving, and architectural coating phases of Project
construction, such equipment shall be used during Project
construction. This requirement shall be noted on plans submitted
for building permit issuance.
MM 4.1-3C: Plans submitted for grading permit issuance and
building permit issuance shall specify the locations where anti-
idling signs will be located. Signs shall be placed on the
construction site where medium and heavy-duty trucks and other
heavy equipment will stage, identifying applicable California Air
Resources Board (CARB) anti-idling regulations. At a minimum,
each sign shall include: 1) instructions to shut off engines when
equipment is not in use; and 2) instructions to restrict idling to no
more than five (5) minutes.
MM 4.1-4: The Project developer and all successors in interest
shall install and maintain legible, durable, weather-proof signs at
truck access gates, loading docks, and truck parking areas that
identify applicable California Air Resources Board (CARB) anti-
idling regulations. At a minimum, each sign shall include
instructions for drivers of diesel-fueled trucks to restrict idling to
Project Applicant,
Construction
Contractors/ City
of San
Bernardino
Project Applicant,
Construction
Contractors/ City
of San
Bernardino
Project Applicant
and Successors in
Interest/City of
San Bernardino
Prior to building
permit issuance
and during
construction
activities
Prior to issuance
of grading permit
issuance and
building permit
issuance and
during
construction
activities
Prior to issuance
of occupancy
permits and during
long-term
operations
The Landing by San Manuel
Draft Environmental Impact Report S.0 Executive Summary
Lead Agency: City of San Bernardino SCH No. 2020100067
Page S-23
Potential Environmental Impact
Significance
Determination
Mitigation Measures (MM) and Regulatory Requirements &
Design Requirements (RRDR)
Applicable to the Development Project
Responsible/
Monitoring
Parties
Implementation
Stage
shall be U.S. EPA Certified WaterSense or equivalent.
MM 4.4-2: Prior to the issuance of a building permit warehouse
building space that contains refrigerated or freezer storage, an
electrical hookup shall be provided at all loading dock doors that
are designated for the loading/unloading of trailers holding
refrigerated/frozen goods, for the purpose of plugging the
refrigeration units installed on such trailers into the building’s
electrical system. If refrigerated/freezer warehouse space is not
proposed, electrical hookups at dock doors will not be required.
Project Applicant
or Developer/City
of San
Bernardino
Prior to issuance
of a building
permit
4.5 Hydrology and Water Quality
Threshold a): The Project would generally maintain the site’s
existing topography, and the Project Site is located at the
fringe of the Santa Ana River floodplain. As such, there would
be no substantial change to the site’s potential for inundation
during floods as compared to existing conditions. Because the
Project Site occurs at the fringe areas subject to inundation
during peak flood events, and because no substantial changes
are proposed to the site’s topography, the Project would not
impede or redirect any flood flows.
Threshold b): Less-Than-Significant Impact. The Project Site
would not be subject to inundation from tsunamis or seiches.
Although the Project Site is subject to inundation during peak
storm events, business operations on the Development Site
would be primarily conducted within the enclosed building,
except for traffic movement, parking, as well as loading and
unloading of trucks at designated loading bays. The Project
would not involve uncontained storage of potential pollutants
outside of the proposed building. As such, during peak flood
events, there is no reasonable potential that substantial
pollutants would not come into contact with water as the result
of the Project and release substantial amounts of pollutants
through water contact. Additionally, although the Project Site
is located within areas subject to inundation as a result of a
Less than
Significant
Less than
Significant
Impacts would be less than significant; therefore, mitigation
measures are not required.
N/A N/A
The Landing by San Manuel
Draft Environmental Impact Report 2.0 Environmental Setting
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 2-1
2.0 ENVIRONMENTAL SETTING
2.1 REGIONAL SETTING AND LOCATION
The Project Site is located in the City of San Bernardino, which is located within the Valley subregion of San
Bernardino County. The City of San Bernardino is situated north of the City of Loma Linda, northwest of the
City of Redlands, west of the City of Highland, south of the San Bernardino Mountains, and east of the City
of Rialto. The Project Site is located approximately 1 mile west of the 5th Street on/off-ramp to Insterstate-
210 (I-210) and approximately 2.6 miles north of Interstate-10 (I-10). The site’s location and regional context
are shown on Figure 2-1, Regional Map.
The Project Site is located in an urbanizing area of southern California commonly referred to as the “Inland
Empire.” The Inland Empire is an approximately 28,000 square-mile region comprising Riverside County,
San Bernardino County, and the eastern tip of Los Angeles County. According to U.S. Census data, the 2019
population of San Bernardino County was 2,180,085 (USCB, 2019). The Southern California Association of
Governments (SCAG) forecast models predict that the population of San Bernardino County will grow to
approximately 2,815,000 persons by the year 2045 (SCAG, 2020b, Demographics and Growth Forecast
Technical Report, Table 13).
2.2 LOCAL SETTING AND LOCATION
The Project Site is located immediately south of 3rd Street, north of the San Bernardino International Airport
(SBIA) property and W Street, east and west of Victoria Avenue, and approximately 0.5-mile west of Alabama
Street, as illustrated on Figure 2-2, Vicinity Map, and Figure 2-3, USGS Topographic Map. As also shown on
Figure 2-2 and Figure 2-3, the 52.97-acre Development Site portion of the Project Site is bounded by Victoria
Avenue to the west, 3rd Street to the north, private property to the east, the 3rd Street/Central Avenue
intersection to the northwest, and W Street to the south. The northern boundary of the Project Site is
coterminous with the jurisdictional boundary line between the City of San Bernardino and the City of Highland.
2.3 SURROUNDING LAND USES
Existing land uses in the immediate vicinity of the Project Site are illustrated on Figure 2-4, Surrounding Land
Uses, and are described below.
North: Immediately north of the Project Site is 3rd Street, which is a fully improved 4-lane road with
painted center median and curb, gutter, and sidewalk on both sides. The southern side of 3rd Street
forms the dividing line between the City of San Bernardino and the City of Highland to the north. On
the north side of 3rd Street is a mixture of business enterprises and undeveloped property, with a few
residential structures located east of the 3rd Street/Victoria Avenue intersection. This area is in the
planning stages for a mix of industrial uses under the IVDA’s proposed “Airport Gateway Specific
Plan (AGSP),” which covers approximately 670 679 acres generally bounded by 6th Street and
Highland Creekthe City Creek Bypass on the north, 3rd Street and the SBIA on the south, State Route
210 (SR-210) on the east, and Tippecanoe Avenue on the west. The Specific Plan area includes parcels
in both the City of Highland (±485 acres) and the City of San Bernardino (±185 194 acres). In addition,
The Landing by San Manuel
Draft Environmental Impact Report 3.0 Project Description
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 3-11
PUBLIC AGENCY APPROVALS AND DECISIONS
Other Agencies – Subsequent Approvals and Permits
Inland Valley Development Agency (IVDA) • Authorization for land use applications in the SBAC-SP
submitted to the City of San Bernardino.
San Bernardino International Airport Authority
(SBIAA)
• Airport safety review and approval.
• Approval of utility service and connection agreements.
• Approval of airport-related street improvement permits.
City of Highland • Encroachment Permits
• Street Improvement Permits
San Bernardino County Fire Department • Approval of fire hydrant locations and fire protection
measures.
Santa Ana Regional Water Quality Control
Board
• Issuance of a Construction Activity General Construction
Permit.
• Issuance of a National Pollutant Discharge Elimination
System (NPDES) Permit.
• Approval of WQMP
San Bernardino Municipal Water Department
(SBMWD)
• Approval of the Project’s proposed water and sewer
connections.
San Bernardino County Flood Control District
(SBCFCD)
• Approval of drainage improvements.
South Coast Air Quality Management District
(SCAQMD)
• Permits and approvals associated with stationary
equipment (if permits or approvals are required).
The Landing by San Manuel
Draft Environmental Impact Report 4.1 Air Quality
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 4.1-5
the same extent when exposed to photochemical processes. VOCs often have an odor, including such
common VOCs as gasoline, alcohol, and the solvents used in paints. Odors generated by VOCs can
irritate the eye, nose, and throat, which can reduce respiratory volume. In addition, studies have shown
that the VOCs that cause odors can stimulate sensory nerves to cause neurochemical changes that might
influence health, for instance, by compromising the immune system. (Urban Crossroads, 2020a, Table
2-1)
• Lead (Pb) is a heavy metal that is highly persistent in the environment. Historically, the primary
source of lead in the air was emissions from vehicles burning leaded gasoline. Currently, emissions of
lead are largely limited to stationary sources such as lead smelters. Exposure to low levels of lead can
adversely affect the development and function of the central nervous system, leading to learning
disorders, distractibility, inability to follow simple commands, and lower intelligence quotient. In
adults, increased lead levels are associated with increased blood pressure. Lead poisoning can cause
anemia, lethargy, seizures, and death. Fetuses, infants, and children are more sensitive than others to
the adverse effects of lead exposure. (Urban Crossroads, 2020a, Table 2-1)
D. Existing Air Quality
Air quality is evaluated in the context of ambient air quality standards published by the federal and state
governments. These standards are the levels of air quality that are considered safe, with an adequate margin
of safety, to protect the public health and welfare. The National Ambient Air Quality Standards (NAAQS)
and California Ambient Air Quality Standards (CAAQS) currently in effect are detailed in Table 4.1-1,
Ambient Air Quality Standards. In California, a region’s air quality is determined to be healthful or unhealthful
by comparing pollutant levels in ambient air samples to the applicable NAAQS and CAAQS (as presented in
Table 4.1-1).
1. Regional Air Quality
Criteria Pollutants
The SCAQMD monitors levels of various criteria pollutants at 37 monitoring stations and five (5) single-
pollutant source Pb air monitoring sites throughout its jurisdiction. The attainment status for criteria pollutants
within the SCAB is summarized in Table 4.1-2, SCAB Criteria Pollutant Attainment Status. (Urban
Crossroads, 2020a, p. 22)
The SCAB has been one of the most unhealthful air basins in the United States and has experienced unhealthful
air quality since World War II. However, as a result of the region’s air pollution control efforts over the last
60+ years, criteria pollutant concentrations in the SCAB have reduced dramatically and are expected to
continue to improve in the future as State regulations become more stringent. (Urban Crossroads, 2020a, pp.
27-36) Emissions of O3, NOX, VOC, and CO, and ozone precursors have been decreasing in the SCAB since
1975 and are projected to continue to decrease beyond 2020. These decreases result primarily from motor
vehicle controls and reductions in evaporative emissions. Although total vehicle miles traveled (VMT) in the
SCAB continue to
The Landing by San Manuel
Draft Environmental Impact Report 4.1 Air Quality
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 4.1-10
Figure 4.1-5 South Coast Air Basin PM2.5 (State Standard)
(Urban Crossroads, 2020a, Table 2-9)
The most recent CO concentrations in the SCAB are shown in Figure 4.1-6, South Coast Air Basin 24-Hour
Average CO Trend. It should be noted 2012 is the most recent year where 8-hour CO averages and related
statistics are available in the SCAB. 8-hour CO concentrations in the SCAB have been decreased markedly –
a total decrease of by more about 80 percent in the peak 8-hour concentration since 1986. The number of
exceedance days has also declined. The entire SCAB is now designated as attainment for both the State and
national CO standards. Ongoing reductions from motor vehicle control programs should continue the
downward trend in ambient CO concentrations. (Urban Crossroads, 2020a, p. 32)
The most recent NO2 data for the SCAB is shown in Figure 4.1-7, South Coast Air Basin NO2 Trend (Federal
Standard), and Figure 4.1-8, South Coast Air Basin NO2 Trend (State Standard). Over the last 50 years, NO2
values have decreased significantly; the peak 1-hour national and State averages for 2018 are approximately
82 percent lower than reported for 1963. The SCAB attained the State 1-hour NO2 standard in 1994, bringing
the entire State of California into attainment. A new State annual average standard of 0.030 parts per million
was adopted by the California Air Resources Board (CARB) in February 2007. The new standard is just barely
exceeded in the SCAB today. NO2 is formed from NOX emissions, which also contribute to O3. As a result,
the majority of the future emission control measures will be implemented by the State as part of the overall
ozone control strategy. Many of these control measures will target mobile (vehicle tailpipe) sources, which
account for more than three-quarters of California’s NOX emissions. These State-mandated control measures
are expected to bring the SCAB into attainment of the State annual average standard. (Urban Crossroads,
2020a, pp. 32-33)
The Landing by San Manuel
Draft Environmental Impact Report 4.1 Air Quality
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 4.1-27
use and/or increase the development intensity of an individual property may result in increased
stationary area source emissions and/or mobile source emissions when compared to the 2016 AQMP
assumptions. If a development project does not exceed the growth projections in the applicable local
general plan, then the project is considered to be consistent with the growth assumptions in the AQMP.
(Urban Crossroads, 2020a, p. 60)
Under existing conditions, approximately 49.6 acres of the Project Site is designated for “Light
Industrial (IL)” land use and approximately 12.89 acres of the Project Site is designated for “Public
Facility/Quasi-Public (PF)” by the City of San Bernardino’s General Plan Land Use Map. The Project
includes a request to change the approximate 12.89-acre area from “PF” to “IL” and the land use
designation of approximately 4.89 acres of the Project Site located west of Victoria Avenue from “IL”
to “PF,” which, if approved, would result in a land use and development intensity that was not
anticipated by the General Plan and, by extension, the growth models that were used in the 2016
AQMP. Specifically, implementation of the proposed Project would result in a net increase in areas
designated for “IL” development, and the permitted building square footage for IL land uses in the
Third Street District would increase from 1,080,288 s.f. to 1,252,350 s.f. Accordingly, implementation
of the Project would exceed the assumptions in the AQMP based on the years of Project buildout phase,
and therefore would conflict with Consistency Criterion No. 2. (Urban Crossroads, 2020a, p. 61)
In summary, because the proposed Project does not satisfy Consistency Criterion No. 1 or Consistency
Criterion No. 2, the Project is determined to be inconsistent with the 2016 AQMP. As such, the Project would
conflict with and could result in the obstruction of the applicable AQMP and a significant impact would occur
prior to mitigation.
Threshold b: 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?
The SCAB has a “non-attainment” designation for ozone (1- and 8-hour) and particulate matter (PM2.5 and
PM10) under existing conditions. Refer to Subsection 4.1.1D for more information on existing air quality
conditions in the SCAB.
A. Construction Emissions Impact Analysis
Peak Project construction emissions are summarized in Table 4.1-9, Peak Construction Emissions Summary.
Detailed air model outputs are presented in Appendices 3.1 and 3.2 of Technical Appendix B1.
As shown in Table 4.1-9, peak Project construction emissions of VOCs, CO, SOX, and particulate matter (PM10
and PM2.5) would not exceed the applicable SCAQMD regional thresholds. Accordingly, the Project’s
construction activities would not emit substantial concentrations of these pollutants and would not contribute
to an existing or projected air quality violation on a direct or cumulatively-considerable basis. Project
construction impacts related to emissions of VOCs, CO, SOX, PM10 and PM2.5 would be less than significant
and mitigation is not required.
The Landing by San Manuel
Draft Environmental Impact Report 4.1 Air Quality
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 4.1-39
MM 4.1-1 Prior to grading permit issuance, the City of San Bernardino shall review grading plans to
ensure that a notation is included requiring the grading contractor to utilize CARB Tier 4 Final
Compliant equipment in lieu of Tier 3 Compliant or Tier 4 Interim Compliant equipment if
Tier 4 equipment can be reasonably acquired by the Project contractor. If Tier 4 Final
Compliant equipment is not feasible to use during grading activity due to lack of local
availability of such equipment, the Project Applicant or grading contractor shall provide
evidence to the City of San Bernardino showing that the grading contractor attempted to secure
the use of Tier 4 Final Compliant equipment, but such equipment was not locally available
(within a 50 mile radius). The notations shall require that all Tier 3 Compliant and Tier 4
Interim Compliant equipment over 50 hp, if used, shall be fitted with the best available control
technology (BACT) devices, if technically feasible and if the BACT devices can be reasonably
acquired by the Project grading contractor, to minimize air pollutant emissions. These
requirements also shall be specified in bid documents issued to prospective grading contractors.
In order to demonstrate compliance, the grading contractor shall keep a copy of each unit’s
certified tier specification and CARB or SCAQMD operating permit (if applicable) on the
Development Site in a location available to the City or City designee for inspection upon
request. The City shall review and approve the list of equipment over 50 hp, their CARB tier
levels, and list of BACT devices installed on Tier 3 Compliant and Tier 4 Interim Compliant
equipment, prior to the mobilization of grading equipment to the site.
MM 4.1-2 Prior to grading permit issuance, the City of San Bernardino shall review grading plans to
ensure that notification is included requiring that all on-road heavy-duty diesel trucks with a
gross vehicle weight rating greater than 14,000 pounds with a 2010 model year engine or newer
or shall be equipped with a particulate matter trap, as available. This requirement also shall be
specified in bid documents issued to prospective construction contractors. The grading
contractor shall keep a copy of records for all on-road heavy-duty diesel trucks with a gross
vehicle weight rating greater than 14,000 pounds to demonstrate compliance with this
requirement, and the records shall be made available to the City or City’s designee for
inspection upon request.
MM 4.1-3 Prior to grading permit issuance, the City of San Bernardino shall review grading plans to
ensure that notification is included requiring that all construction equipment shall comply with
all applicable California Air Resources Board (CARB) air quality regulations. Also, the notes
shall require that all Project construction contractors must tune and maintain all construction
equipment in accordance with the equipment manufacturer’s recommended maintenance
schedule and specifications. These requirements also shall be specified in bid documents
issued to prospective construction contractors. Maintenance records for all pieces of
equipment shall be kept on-site for the duration of construction activities and shall be made
available for periodic inspection by City of San Bernardino staff or their designee.
MM 4.1-3A Plans submitted for grading permit issuance and building permit issuance shall specify a
designated area of the construction site where electric or non-diesel vehicles, equipment, and
The Landing by San Manuel
Draft Environmental Impact Report 4.1 Air Quality
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 4.1-40
tools can be fueled or charged. The provision of temporary electric infrastructure for such
purpose shall be approved by the utility provider, Southern California Edison (SCE). If SCE
will not approve the installation of temporary power for this purpose, the establishment of a
temporary electric charging area will not be required. If electric equipment will not be used
on the construction site because the construction contractor(s) does not have such equipment
in its fleet (as specified in Mitigation Measure MM 4.1-3B), the establishment of a temporary
electric charging area also will not be required. If electric-powered equipment is in the
contractor(s) equipment fleet, and SCE approval is secured, the temporary charging location is
required to be established upon issuance of grading permits and building permits.
MM 4.1-3B: If electric or non-diesel off-road trucks and construction support equipment, including but not
limited to hand tools, forklifts, aerial lifts, materials lifts, hoists, pressure washers, plate
compactors, and air compressors are available in the construction contractor’s equipment fleet
and can fulfill the Project’s construction requirements during the building construction, paving,
and architectural coating phases of Project construction, such equipment shall be used during
Project construction. This requirement shall be noted on plans submitted for building permit
issuance.
MM 4.1-3C: Plans submitted for grading permit issuance and building permit issuance shall specify the
locations where anti-idling signs will be located. Signs shall be placed on the construction site
where medium and heavy-duty trucks and other heavy equipment will stage, identifying
applicable California Air Resources Board (CARB) anti-idling regulations. At a minimum,
each sign shall include: 1) instructions to shut off engines when equipment is not in use; and
2) instructions to restrict idling to no more than five (5) minutes.
The following mitigation measures would reduce the Project’s operational-related NOX emissions and the
contributions of this pollutant to the SCAB’s non-attainment status for ozone.
MM 4.1-4 The Project developer and all successors in interest shall install and maintain legible, durable,
weather-proof signs at truck access gates, loading docks, and truck parking areas that identify
applicable California Air Resources Board (CARB) anti-idling regulations. At a minimum,
each sign shall include instructions for drivers of diesel-fueled trucks to restrict idling to no
more than five minutes. The Project developer or successor(s) in interest shall permit City of
San Bernardino staff to conduct a site inspection to ensure that the signs are in place and
maintained.
MM 4.1-5 The Project developer and all successors in interest shall install and maintain signs and/or
painting/striping at on-site driveways and drive aisles to clearly identify the on-site circulation
pattern to minimize unnecessary on-site vehicular travel. The Project developer or successor(s)
in interest shall permit City of San Bernardino staff to conduct a site inspection to ensure that
the signs/painting/striping are in place and maintained.
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F. Nesting Birds
The Development Site contains trees, shrubs, and ground cover that provide suitable habitat for nesting
migratory birds. Impacts to nesting birds are prohibited under the California Fish and Game Code1. Birds
anticipated to nest on the Development Site would be those that are common to disturbed areas and include
species such as European starling (Sturnus vulgaris), house finch (Haemorhous mexicanus), killdeer
(Charadrius vociferus), and mourning dove (Zenaida macroura).
G. Wildlife Linkages/Corridors and Nursery Sites
Habitat linkages are areas that provide a communication between two or more other habitat areas which are
often larger or superior in quality to the linkage. Such linkage sites can be quite small or constricted but can
be vital to the long-term health of connected habitats. Linkage values are often addressed in terms of “gene
flow” between populations, with movement taking potentially many generations. (GLA, 2020, pp. 32-33)
Corridors are similar to linkages but provide specific opportunities for individual animals to disperse or migrate
between areas, generally extensive but otherwise partially or wholly separated regions. Adequate cover and
tolerably low levels of disturbance are common requirements for corridors. Habitat in corridors may be quite
different than that in the connected areas, but if used by the wildlife species of interest, the corridor will still
function as desired. Wildlife nurseries are sites where wildlife concentrate for hatching and/or raising young,
such as rookeries, spawning areas, and bat colonies. Nurseries can be important to both special-status species
as well as commonly occurring species. (GLA, 2020, p. 33)
While some local wildlife movement is expected to occur within the Development Site, the relatively small
size and highly disturbed nature of the Development Site preclude it from providing migratory wildlife
corridors and/or wildlife nursery sites. Furthermore, the Development Site does not connect to any habitat to
the north, south, east, or west. The nearest areas that may facilitate wildlife movement in the local area are the
City Creek and Santa Ana River, and the Development Site is separated from these features by existing
roadways and development. (GLA, 2020, p. 33)
H. Critical Habitat
The Development Site occurs adjacent to lands located east of the site that are mapped as Critical Habitat by
the U.S. Fish and Wildlife Service (USFWS) for San Bernardino kangaroo rat (Dipodomys merriami parvus),
as shown on Exhibit 7, Critical Habitat Map, of the Project’s BTR (Technical Appendix C). Areas of USFWS’s
original Critical Habitat mapping (effective May 23, 2002) occur adjacent to the eastern Development Site
boundary; however, those offsite areas to the east have since been developed and no longer support Primary
Constituent Elements of Critical Habitat. San Bernardino kangaroo rat has no reasonable potential to occur on
1 The MBTA makes it unlawful to take, possess, buy, sell, purchase, or barter any migratory bird listed in 50 C.F.R. Part 10,
including feathers or other parts, nests, eggs, or products, except as allowed by implementing regulations (50 C.F.R.21). In
addition, sections 3505, 3503.5, and 3800 of the California Department of Fish and Game Code prohibit the take, possession,
or destruction of birds, their nests or eggs.
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d) As part of shell building permit issuance, and subject to the approval of the Federal
Aviation Administration for the installation of rooftop solar panels near an airport, the
applicant shall be required to install a rooftop photovoltaic (PV) system providing a
minimum of 24,000 watts (24 KW) of power per year. The remaining area of the
building’s roof shall be designed and constructed to accommodate the potential, future
construction of additional photovoltaic (PV) solar arrays taking into consideration
limitations imposed by other rooftop equipment, roof warranties, building and fire code
requirements, and other physical or legal limitations. The building shall be designed
to accommodate an electrical system and other infrastructure sufficiently sized to
accommodate the potential installation of additional PV arrays in the future.
e) The building’s electrical room shall be sufficiently sized to hold additional panels that
may be needed in the future to supply power for the future installation of EV truck
charging stations on the site. Conduit should be installed from the electrical room to
the tractor trailer staging area in the southwestern corner of the site for the purpose of
accommodating the future installation of EV truck charging stations at such time this
technology becomes commercially available and the building is being served by trucks
with electric-powered engines.
f) Use of light-colored roofing material.
g) Use of solar or light-emitting diode (LED) fixtures for outdoor lighting.
h) All heating, cooling, and lighting devices and appliances shall be Energy Star certified.
i) All fixtures installed in restrooms and employee break areas shall be U.S. EPA
Certified WaterSense or equivalent.
MM 4.4-2 Prior to the issuance of a building permit for warehouse building space that contains
refrigerated or freezer storage, an electrical hookup shall be provided at all loading dock doors
that are designated for the loading/unloading of trailers holding refrigerated/frozen goods, for
the purpose of plugging the refrigeration units installed on such trailers into the building’s
electrical system. If refrigerated/freezer warehouse space is not proposed, electrical hookups
at dock doors will not be required.
4.4.8 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Threshold a.: Significant and Unavoidable Cumulatively-Considerable Impact. Implementation of applicable
regulatory requirements, Mitigation Measures MM 4.1-1 through MM 4.1-9, as well as Mitigation Measures
MM 4.4-1 and 4.4-2, would reduce the Project’s operational emissions of GHGs; however, these measures
would not substantially reduce Project mobile source emissions (i.e., emissions from construction equipment,
passenger cars, and trucks), which comprise more than 60 percent of the Project’s anticipated GHG emissions.
Mobile source GHG emissions are regulated by State and federal fuel standards and tailpipe emissions
standards, and are outside of the control of the City of San Bernardino, the Project Applicant, and future Project
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4.5.1 EXISTING CONDITIONS
A. Regional Hydrology
The Project Site is located within the Santa Ana River watershed, which drains a 2,840 square-mile area and
is the principal surface flow water body in the region. The Santa Ana River rises in Santa Ana Canyon in the
southern San Bernardino Mountains and runs southwesterly across San Bernardino, Riverside, and Orange
Counties, and discharges into the Pacific Ocean at the City of Huntington Beach. The Santa Ana River flows
over 100 miles, and Tthe total length of the Santa Ana River and its major tributaries is approximately 700
miles. (SAWPA, 2019, p. 4-1) The location of the Project Site within the Santa Ana River watershed is
depicted on Figure 4.5-1, Santa Ana River Watershed Map. The Project Site and vicinity are within the
purview of the Santa Ana Regional Water Quality Control Board (RWQCB). The Santa Ana RWQCB’s Santa
Ana River Basin Water Quality Control Plan is the governing water quality plan for the region, which sets
forth goals and objectives for protecting the region’s water quality (RWQCB, 2019, p. 1.1).
B. Site Hydrology
Under existing conditions, runoff from the Project Site drains across the Project Site as surface flow from an
east to west direction with negligible offsite runoff entering the site. With exception of flows redirected north
by a concrete block wall and raised planter in the eastern portions of the Development Site, surface runoff from
the Development Site travels overland in a southwesterly direction into existing curbs and gutters before
entering the existing Victoria Avenue storm drain system via catch basins located at the intersection of Victoria
Avenue and W Street. Within the eastern portions of the Development Site, the existing concrete block wall
and raised planter direct flows northeasterly along the existing wall to existing storm drainage facilities within
3rd Street. (DEA, 2020a, p. 1)
C. Flooding
According to the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) Nos.
06071C8701J and 06071C8702H, a majority of the Project Site is located within “Flood Zone X (unshaded),”
which includes “[a]reas determined to be outside the 0.2% annual chance floodplain” (FEMA, 2016). The
easternmost portions of the Project Site are mapped within “Flood Zone X (shaded),” which includes “[a]reas
of 0.2% annual chance flood; areas of 1% annual chance with average depths of less than 1 foot or with
drainage areas less than 1 square mile; and areas protected by levees from 1% annual chance of flood” (FEMA,
2008). Based on these designations, the eastern portions of the Project Site are subject to inundation during
500-year flood events and could be subject to up to one foot of inundation during 100-year storm events.
D. Dam Inundation
According to the City of San Bernardino General Plan, the Project Site is located within an area subject to
inundation in the event of a failure at the Seven Oaks Dam (City of San Bernardino, 2005, Figure S-2). The
Seven Oaks Dam is located in unincorporated San Bernardino County northeast of the City of Highland,
approximately 6.8 miles east of the Project Site (Google Earth Pro, 2020).
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• North: Immediately north of the Project Site is 3rd Street, which is a fully improved 4-lane road with
painted center median and curb, gutter, and sidewalk on both sides. The southern side of 3rd Street
forms the dividing line between the City of San Bernardino and the City of Highland to the north. On
the north side of 3rd Street is a mixture of business enterprises and undeveloped property, with a few
residential structures located east of the 3rd Street/Victoria Avenue intersection. This area is in the
planning stages for a mix of industrial uses under the proposed “Airport Gateway Specific Plan
(AGSP),” which covers approximately 670 679 acres generally bounded by 6th Street and the City
Creek BypassHighland Creek on the north, 3rd Street and the San Bernardino International Airport
(SBIA) on the south, State Route 210 (SR-210) on the east, and Tippecanoe Avenue on the west. The
Specific Plan area includes parcels in both the City of Highland (±485 acres) and the City of San
Bernardino (±185 194 acres). In addition, a roadway improvement project is planned that will improve
5th Street from Victoria Avenue Church Avenue, 3rd Street from Church Avenue to just west of
Alabama Street, and Palm Avenue from just south of 3rd Street to just north of 5th Street.
• East: Industrial property located to the east of the Project Site is occupied by JB Hunt Transport
Services, Inc., and the NTS San Bernardino Rocket and Fluids test laboratory, which is a test facility
for aerospace propulsion development. Further to the east and southeast are heavy industry uses
including an asphalt plant in the City of Redlands.
• South: The SBIA abuts the Project Site’s southern border. The Airport serves cargo, business aviation,
general aviation, and commercial airlines, as well as aviation-related development around the airport.
The Santa Ana River and the City of Redlands are located further to the south.
• West: Property abutting the Project Site to the west on the west side of Victoria Avenue is owned by
the SBIAA, which is currently undeveloped and is being used for the temporary storage of truck trailers
and cargo containers. Further to the west and southwest is the planned location of an approximately
101.5-acre Amazon Air Regional Hub facility, which when constructed will connect to the Airport’s
Taxiway “E,” to support Amazon’s air cargo operations. The facility is approved by the SBIAA to
contain an approximately 658,000 s.f. warehouse that will be between 50’ and 63’ in height with dock
doors positioned on the northern and southern sides of the building.
4.6.2 REGULATORY SETTING
The following is a brief description of the federal, State, and local environmental laws and related regulations
related to land use and planning.
A. State Plans , Policies, and Regulations
1. California Planning and Zoning Law
The legal framework in which California cities and counties exercise local planning and land use functions is
set forth in the California Planning and Zoning Law, §§ 65000 - 66499.58. Under State of California planning
law, each city and county must adopt a comprehensive, long-term general plan. State law gives cities and
counties wide latitude in how a jurisdiction may create a general plan, but there are fundamental requirements
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2. SCAG Connect SoCal
Connect SoCal, is SCAG’s 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy
(RTP/SCS). Connect SoCal is supported by a combination of transportation and land use strategies that outline
how the region can achieve California’s greenhouse gas emission reduction goals and federal Clean Air Act
requirements. The plan also strives to achieve broader regional objectives, such as the preservation of natural
lands, improvement of public health, increased roadway safety, support for the region’s vital goods movement
industries, and more efficient use of resources. (SCAG, 2020a)
Connect SoCal includes a Technical Appendix titled “Goods Movement” that is applicable to the Project
because the Project entails a use that is closely associated with, and relies directly on the goods movement
system (e.g., manufacturing, construction, retail trade, wholesale trade and transportation, and warehousing).
In April 2018 SCAG published Industrial Warehousing in the SCAG Region. According to the document, the
SCAG region is a vibrant hub for international and domestic trade because of its large transportation base and
extensive multimodal transportation system. The SCAG region’s freight transportation system includes
warehouses and distribution centers; the Ports of Los Angeles, Long Beach, and Hueneme; airports; rail
intermodal terminals; rail lines, and local streets, state highways and interstates. Together the system enables
the movement of goods from source to market, facilitating uninterrupted global commerce. The region is home
to approximately 34,000 warehouses with 1.17 billion square feet of warehouse building space, and
undeveloped land that could accommodate an additional 338 million square feet of new warehouse building
space. These regions attract robust logistics activities, and are a major reason the region is a critical mode
component in the global supply chain. (SCAG, 2018, p. ES-1)
3. SCAQMD Air Quality Management Plan
An AQMP is a plan for the regional improvement of air quality. The SCAQMD 2016 AQMP is the applicable
AQMP for the South Coast Air Basin and was approved by the SCAQMD Governing Board in March 2017
(SCAQMD, 2017a). The Project’s consistency with the 2016 AQMP was analyzed in detail in EIR Subsection
4.1, Air Quality, and as such is not further evaluated in this Subsection 4.68. As evaluated in EIR Subsection
4.1, the Project would result in significant and unavoidable impacts due to a conflict with the SCAQMD 2016
AQMP.
4. City of San Bernardino General Plan
The City of San Bernardino General Plan, dated November 1, 2005, is a policy document that reflects the
City’s vision for the future of the City of San Bernardino. The General Plan is organized into 13 separate
elements that contain a series of policies to guide the City’s vision for future development. Each of the
elements from the City of San Bernardino General Plan are summarized below:
• Land Use Element: The Land Use Element of the General Plan functions as a guide to planners, the
general public, and decision makers as to the ultimate pattern of development. It designates general
site development standards and the distribution, location, and extent of land uses, such as housing,
business, industry, open space, natural resources, recreation, and public/quasi-public uses. The Land
Use Element also discusses the standards of residential density and non-residential intensity for the
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a. Cause a significant environmental impact due to a conflict with any land use plan, policy or
regulation adopted for the purpose of avoiding or mitigating an environmental effect.
The above-listed threshold is derived directly from Section XI. of Appendix G to the CEQA Guidelines and
addresses the typical, adverse effects related to land use and planning that could result from development
projects. Refer to the Project’s Initial Study (Technical Appendix A) for a discussion of one potential impact
associated with land use and planning (division of an established community) that was determined to have no
potential to be impacted by the Project through the Project’s scoping process.
4.6.4 IMPACT ANALYSIS
Threshold a: Would the Project cause a significant environmental impact due to a conflict with any land
use plan, policy or regulation adopted for the purpose of avoiding or mitigating an
environmental effect?
A. City of San Bernardino General Plan
The Project includes an amendment to the City of San Bernardino General Plan to change the General Plan
land use designation on the approximately 12.89 acres in the southern portions of the Development Site from
“Public Facility/Quasi-Public (PF)” to “Industrial Light (IL).” In addition, GPA 20-02 would change the land
use designation of approximately 4.89 acres of the Project Site located west of Victoria Avenue from
“Industrial Light (IL)” to “Public Facility/Quasi-Public (PF).” Approval of GPA 20-02 would facilitate the
reconfiguration of the Third Street District of the San Bernardino Alliance California Specific Plan (SBAC-
SP), and also would allow for construction of light industrial uses on the 12.89-acre portion of the Development
Site currently designated for PF uses. Approval of the proposed General Plan Amendment would eliminate
any potential inconsistency between proposed land uses and the site’s existing land use designations. Impacts
to the environment associated with the Project’s proposed General Plan Amendment are evaluated throughout
this EIR, and where significant impacts are identified, mitigation measures are imposed to reduce impacts to
the maximum feasible extent. There are no environmental impacts that would result as a specific consequence
of the proposed changes to the site’s General Plan land use designation, beyond what is already evaluated and
disclosed by this EIR.
Based on a review of the Project’s application materials conducted by City of San Bernardino staff, the Project
would not conflict with any specific objectives, policies, or actions that were adopted for the purpose of
avoiding or mitigating an environmental effect as contained in the General Plan’s Land Use Element; Housing
Element; Economic Development Element; Community Design Element; Circulation Element; Public
Facilities and Services Element; Parks, Recreation and Trails Element; Utilities Element; Safety Element;
Historical and Archaeological Resources Element; Natural Resources and Conservation Element; Energy and
Water Conservation Element; or Noise Element. Although the Project would result in significant and
unavoidable impacts due to Project-related traffic noise, impacts associated with traffic-related noise are fully
discussed and disclosed in EIR Subsection 4.7, Noise; thus, because impacts already are addressed in this EIR,
no additional impacts due to a conflict with the City’s General Plan Noise Element are identified. Additionally,
although the Project would result in significant and unavoidable impacts due to operational emissions of NOX
and due to a conflict with the SCAQMD 2016 AQMP, Project impacts associated with air quality are fully
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discussed and disclosed in EIR Subsection 4.1, Air Quality; thus, because air quality impacts already are
addressed in this EIR, no additional impacts due to a conflict with General Plan policies related to air quality
are identified. As such, impacts due to a conflict with any General Plan policies adopted for the purpose of
avoiding or mitigating an environmental effect would be less than significant.
B. San Bernardino Alliance California Specific Plan (SBAC-SP)
As previously indicated, an amendment to the SBAC-SP (SPA 20-01) is proposed in order to reconfigure the
boundaries of the Third Street District and SBAC-SP to encompass the entire 52.97-acre Development Site.
Specifically, proposed SPA 20-01 would add approximately 12.89 acres in the southern portion of the
Development Site to the boundaries of the Third Street District portion of the SBAC-SP, and would remove
approximately 4.97 acres located west of Victoria Avenue from the SBAC-SP boundaries. As a result, the
reconfigured Third Street District would comprise approximately 57.52 acres (the 52.97-acre Development
Site and 4.55 acres to the east). Due to the proposed boundary change and acreage adjustment for the Third
Street District, SPA 20-01 proposes to increase the permitted building square footage in the Third Street
District from 1,080,288 s.f. to 1,252,350 s.f., while maintaining the maximum FAR at 0.5. In addition, SPA
20-01 proposes to change the minimum setback for parking from Major Arterials (3rd Street) from 20 feet to
9 feet. The Project Applicant is proposing an enhanced landscape treatment along 3rd Street in part due to the
proposed setback reduction to 9 feet. These revisions to development standards would not manifest into any
physical environmental impacts not already discussed in the other Subsections of this EIR. With approval of
SPA 20-01, the Project would be in full compliance with the land use designations and related requirements
of the SBAC-SP. Accordingly, impacts would be less than significant.
C. City of San Bernardino Municipal Code
The Project includes a proposed Development Code/Zoning Amendment (DCA 20-03) to change the Zoning
Map classification of 12.89 acres of the Project Site from “Public Facilities” to “Specific Plan Alliance of
California – 3rd Street (SP-AC).” In addition, DCA 20-03 would change the zoning classification of
approximately 4.89 acres of the Project Site located west of Victoria Avenue from “SP-AC” to “Public
Facilities (PF).” Approval of DCA 20-03 would facilitate the reconfiguration of the Third Street District of
the San Bernardino Alliance California Specific Plan (SBAC-SP), and also would allow for construction of
light industrial uses on the 12.89-acre portion of the Development Site that is currently zoned for PF uses.
Approval of the requested Development Code/Zoning Amendment would eliminate any potential
inconsistency between the proposed Project and the site’s underlying zoning classifications. Impacts to the
environment associated with the Project’s proposed DCA are evaluated throughout this EIR, and where
significant impacts are identified, mitigation measures are imposed to reduce impacts to the maximum feasible
extent. There are no components of the Project’s proposed DCA that would result in impacts not already
evaluated and disclosed by this EIR. Furthermore, City of San Bernardino staff conducted a review of the
Project’s application materials, and determined that the Project would be in full compliance with the
requirements of Title 8 (Health and Safety) of the City’s Municipal Code, including requirements related to
noise (Municipal Code Chapter 8.54, Noise Control) and storm water drainage (Municipal Code Chapter 8.80,
Storm Water Drainage Systems). Copies of the City’s comment letters and the Project Applicant’s responses
to City comments are available at the City of San Bernardino Planning Division, 201 North E Street, 3rd Floor,
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San Bernardino, CA 92401, during the City’s regular business hours, or can be requested in electronic form
by contacting the City Planning Division. Impacts would be less than significant.
D. SCAG Regional Transportation Plan and Sustainable Communities Strategy
As shown in Table 4.6-1, SCAG’s RTP/SCS Goal Consistency Analysis, the Project would not conflict with
the adopted goals of Connect SoCal. SCAG intended that Connect SoCal ensure that the southern California
region attains the per capita vehicle miles targets for passenger vehicles identified by CARB, as required by
Senate Bill 375. The Project would be consistent with Connect SoCal for integrating the transportation
network and related strategies with an overall land use pattern that responds to projected growth, housing
needs, changing demographics, and transportation demands by locating a proposed light industrial warehouse
development in an area that is already developed with similar land uses; however as detailed in Subsection 4.4,
Table 4.4-4, the estimated GHG emissions from Project operation (23,514.15 MTCO2e per year) would exceed
the SCAQMD threshold (103,000 MTCO2e per year). Even with implementation of mitigation measures
identified in EIR Subsection 4.4, GHG emissions would be in excess of SCAQMD thresholds due to the size
of the Project; therefore, the Project would not be consistent with Connect SoCal’s Performance Measure
regarding criteria pollutants and GHG emissions. However, because the Project’s significant and unavoidable
impact due to GHG emissions are fully evaluated and disclosed in EIR Subsection 4.5, thereby precluding a
potential conflict with the 2016 SCS/RTP. Therefore, no significant impact to land use and planning is
identified due to a conflict with the SCAG 2016 RTP/SCS. The Project would not result in any other land use
and planning conflicts with the 2016 SCS/RTP or Connect SoCal that were not already disclosed in EIR
Subsection 4.4.
Table 4.6-1 SCAG’s RTP/SCS Goal Consistency Analysis
RTP/SCS
Goals Goal Statement Project Consistency Discussion
Connect SoCal
1 Encourage regional economic prosperity and
global competitiveness.
No conflict identified. This policy would be implemented
by cities and the counties within the SCAG region as part
of comprehensive local and regional planning efforts. It
should be noted that the Project would improve the
regional economy by creating a new warehouse facility.
2 Improve mobility, accessibility, reliability, and
travel safety for people and goods.
No conflict identified. EIR Subsection 4.8, Transportation,
evaluates Project-related transportation impacts. The
Project’s design includes intersection and road
improvements on 3rd Street and on Victoria Avenue that
the City will assure through conditions of approval placed
on the Project. EIR Subsection 4.8, Transportation, also
addresses measures to ensure pedestrian and bicycle safety
during Project construction and operation. Additionally,
the Project would improve the accessibility of goods to the
surrounding area by serving as a warehouse facility in the
local and regional supply chain system.
3 Enhance the preservation, security, and
resilience of the regional transportation system.
No conflict identified. This policy would be implemented
by cities and the counties within the SCAG region as part
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Table 4.6-1 SCAG’s RTP/SCS Goal Consistency Analysis
RTP/SCS
Goals Goal Statement Project Consistency Discussion
of the overall planning and maintenance of the regional
transportation system. The Project would have no adverse
effect on such planning or maintenance efforts.
4 Increase person and goods movement and
travel choices within the transportation system.
No conflict identified. The Project involves development
of a warehouse facility within an existing industrial area,
along designated truck routes, and in close proximity to the
State highway system, which would avoid or shorten truck-
trip lengths on other roadways. Sidewalks and bicycle lanes
already exist along 3rd Street, and the Project design
includes intersection and road improvements on Victoria
Avenue which would benefit travelers, visitors, and
pedestrians and bicyclists. As discussed in EIR Section
3.0, Project Description, a bus stop would be installed as
part of the Project on the east side of Victoria Avenue,
south of 3rd Street, in the location requested by Omnitrans
to serve an Omnitrans tripper route. As such, multiple
travel choices are accommodated by the Project’s design.
5 Reduce greenhouse gas emission and improve
air quality.
No conflict identified. Air quality is addressed in EIR
Subsection 4.1, Air Quality, and mitigation measures are
specified to reduce the Project’s air quality impacts to the
maximum feasible extent. Additionally, and as discussed
in EIR Subsection 4.5, Greenhouse Gas Emissions, the
Project would foreseeably incorporate various measures
related to building design, landscaping, and energy systems
to reduce greenhouse gas emissions to the maximum
feasible extent.
6 Support healthy and equitable communities. No conflict identified. This policy pertains to health and
equitable communities, and these issues are addressed
through goals and policies outlined in the Safety Element
of the City’s General Plan. Relevant to the Project, the
proposed building design would support the health of
occupants and users by using non-toxic building materials
and finishes per the California Building Code, and by using
windows and design features to maximize natural light and
ventilation. Additionally, and as concluded in EIR
Subsection 4.1, Air Quality, implementation of the Project:
1) would not exceed applicable SCAQMD localized
criteria pollution emissions thresholds during construction
and operation; 2) would not expose sensitive receptors to
toxic air contaminants (e.g., DPM) from construction or
long-term operations that exceed the applicable SCAQMD
carcinogenic and non-carcinogenic risk thresholds; and 3)
would not cause or contribute to the formation of a CO
“hot spot.”
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as the basis for their Circulation Element. Refer to Subsections 3.2 and 3.3 of Technical Appendix K2 for a
summary of the General Plan Circulation Elements for the City of San Bernardino and the City of Highland.
4.8.4 TRANSPORTATION IMPACT ANALYSIS METHODOLOGY
The Project’s VMT analysis, as provided in Technical Appendix K1 and summarized in this Subsection, relies
on the analysis methodologies described below.
A. Vehicle Miles Traveled (VMT) Evaluation Criteria and Methodology
In August 2020, the City of San Bernardino adopted the City of San Bernardino Traffic Impact Analysis
Guidelines, which describes specific “screening thresholds” that can be used to identify when a proposed land
use project is anticipated to result in a less-than-significant impact without conducting a more detailed project
level VMT analysis. Screening thresholds are described in the following three steps: (Urban Crossroads,
2020g, p. 2)
• Transit Priority Area (TPA) Screening
• Low VMT Area Screening
• Project Type Screening
Consistent with City Guidelines a land use project needs only to satisfy one of the above screening thresholds
to result in a less-than-significant impact. For the purposes of this analysis, the initial VMT screening process
has been conducted with using the San Bernardino County Transportation Authority (SBCTA) VMT Screening
Tool, which uses screening criteria consistent with the screening thresholds recommended in the Technical
Advisory and City Guidelines. (Urban Crossroads, 2020g, p. 2)
Projects located within a TPA (i.e., within 0.5-mile of an existing “major transit stop” or an existing stop along
a “high-quality transit corridor” may be presumed to have a less-than-significant impact absent substantial
evidence to the contrary. The Project Site is not located within 0.5-mile of an existing major transit stop or
along a high-quality transit corridor. Although local bus service is available in the Project area via Omnitrans
Route 15, which runs along Central Avenue north of 5th Street, Church Avenue north of 5th Street, and 5th
Street between Central Avenue and Church Avenue, the bus stops within 0.5 mile of the Project Site do not
meet the definition of a “major transit stop” pursuant to Public Resources Code Section 212064.3 because
there is no intersection of two or more major bus routes within 0.5 mile of the Project site. Additionally, the
bus stops within 0.5 mile of the Project site do not meet the definition of a “high-quality transit corridor”
pursuant to Public Resources Code Section 21155 because the bus routes do not meet the requirement for
service intervals that are no longer than 15 minutes during peak commute hours. (Urban Crossroads, 2020g,
p. 2)
The Technical Advisory also states that, “residential and office projects located within a low VMT generating
area may be presumed to have a less than significant impact absent substantial evidence to the contrary. In
addition, other employment related and mixed use projects may qualify for the use of screening if the project
can reasonably be expected to generate VMT per resident, per worker or per service population that is similar
The Landing by San Manuel
Draft Environmental Impact Report 4.8 Transportation
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 4.8-12
Threshold b: Would the Project conflict or be inconsistent with CEQA Guidelines section 15064.3,
subdivision (b)?
As previously discussed, SB 743, approved in 2013, was intended to change the way transportation impacts
are determined according to CEQA. Updates to the State CEQA Guidelines that were approved in December
2018 included the addition of CEQA Guidelines Section 15064.3, of which Subdivision b establishes criteria
for evaluating a project’s transportation impacts based on project type and using automobile VMT as the
metric. As a component of OPR’s revisions to the CEQA Guidelines, lead agencies were required to adopt
VMT thresholds of significance by July 1, 2020. The City of San Bernardino adopted its City of San
Bernardino Traffic Impact Analysis Guidelines in August 2020, which is used in this analysis to determine the
significance of Project-related VMT.
Table 4.8-2, Project VMT Analysis, summarizes the Project’s VMT per service population under baseline
(2020) and cumulative (2040) conditions. As shown in Table 4.8-2, the Project’s VMT per service population
values would exceed the City’s adopted threshold by 33.3% for baseline (2020) conditions and 25.9% for
cumulative (2040) conditions. Therefore, based on the City’s Guidelines, the Project would have a significant
direct impact due to VMTs.
Table 4.8-3, Cumulative VMT Analysis, summarizes the cumulative link-level boundary VMT per service
population within the City of San Bernardino with and without the Project. As shown in Table 4.8-3, the
cumulative link-level VMT per service population within the City of San Bernardino does not increase under
the plus Project condition. Therefore, based on the City’s Guidelines, the Project’s effect on VMT is
considered less than cumulatively considerable.
Threshold c: Would the Project substantially increase hazards to a geometric design feature (e.g., sharp
curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
All physical improvements planned as part of the Project would be in conformance with applicable City of San
Bernardino and/or City of Highland standards. The Development Site is surrounded by airport-related uses to
the south, industrial and manufacturing facilities to the east and west, and existing and planned industrial
development to the north, and as such the Project’s proposed warehouse building is a compatible use and the
use type in and of itself would not increase transportation-related hazards in the local area.
Pertaining to design features, the warehouse development would include two driveways at 3rd Street, two
driveways at Victoria Avenue, and one driveway at W Street in the southwest corner of the Development Site.
The driveway at the southwestern portion of the site connecting with W Street is designed as the primary truck
entry and exit driveway. The two driveways connecting with Victoria Avenue would accommodate passenger
vehicles, only. No safety hazards are anticipated at these driveways, as no trucks would be using the Victoria
Avenue driveways and the main truck entrance and exit would occur at W Street, where very low levels of
passenger car, pedestrian, and bicycle traffic is anticipated. Further, because the southwestern portion of the
Development Site is proposed to contain expansive parking areas, and the Project has beenis designed such
that trucks entering the site from W Street could utilize the parking aisles as a staging area in order to ensure
thatas an ample on-site truck staging area, trucks will not queue on the public street. The driveways at 3rd
Street would serve as secondary access points, provide for both left- and right-turn movements, and would
The Landing by San Manuel
Draft Environmental Impact Report 4.8 Transportation
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 4.8-16
of a transportation demand management program to reduce employee-related vehicle trips. Additionally, the
Project would accommodate a bus stop along the Development Site’s frontage with Victoria Avenue, which
would help to reduce Project-related employee vehicle trips by providing an alternative to single-passenger
vehicles. Class II bike lanes are already located along the Development Site’s frontage with 3rd Street and the
proposed enhanced pavement markings for the City Creek Trail crossing at the intersection of 3rd Street and
Victoria Avenue would be installed by the Project Applicant. This would assist in encouraging future
employees of the Project to commute via bicycle instead of automobiles. Furthermore, the Project consists of
an employment-generating land use. As noted in Appendix 7 to the City of San Bernardino General Plan, the
City of San Bernardino supplies a relatively high number of housing units when compared to the amount of
jobs provided in the City (City of San Bernardino, 2005a, Appendix 7, p. 11). Thus, by providing for local
employment opportunities, the Project would assist the City in improving its jobs-housing balance, thereby
resulting in reduced VMTs associated with employee trips, although the level of VMT reduction associated
with the improvement in the local jobs-housing balance cannot be quantified. Mitigation measures are not
available to reduce VMTs associated with Project-related truck traffic, as truck trip lengths would be dependent
on the distance between the Development Site and the destination/origin of the truck trips, which is outside the
control of the City of San Bernardino and the Project Applicant. There are no additional feasible mitigation
measures that would be effective in reducing the Project’s VMTs.
4.8.12 SIGNIFICANCE OF IMPACTS AFTER MITIGATION
Threshold b: Significant and Unavoidable Direct and Cumulatively-Considerable Impact. Mitigation measures
available to reduce VMT include developing pedestrian network improvements, removing physical barriers to
pedestrian circulation, and providing design features that encourage people to walk or bike instead of drive.
As discussed in this Subsection and in EIR Section 3.0, Project Description, various design features are
included in the Project to encourage pedestrian and bicycle activity (sidewalks, bike lanes and bicycle parking).
Encouraging businesses to allow telecommuting and alternative work week hours and to use ridesharing
programs also can reduce VMT, but the City of San Bernardino has no jurisdictional authority to mandate the
businesses practices of private enterprises. There are no additional mitigation measures available to reduce
the Project’s impacts due to VMTs. As such, Project impacts due to VMTs would be significant and
unavoidable.
Threshold c: Less-than-Significant Impact with Mitigation. Implementation of Mitigation Measure MM 4.8-
1 would ensure that appropriate measures are implemented during the Project’s construction phase to provide
for an adequate level of safety for pedestrians and bicyclists during the construction of the proposed driveways
along 3rd Street, and would reduce near-term impacts to below a level of significance. Implementation of
Mitigation Measure MM 4.8-2 would ensure that appropriate signs and painting/striping are implemented at
the Project’s driveways along 3rd Street warning truck drivers of the potential for pedestrian or bicycle traffic.
Implementation of the required mitigation would ensure that potential conflicts between pedestrians/bicyclists
and Project-related truck traffic are minimized during long-term operation of the Project, and would reduce
Project impacts to below a level of significance.
The Landing by San Manuel
Draft Environmental Impact Report 5.0 Other CEQA Considerations
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 5-4
energy. Accordingly, the Project would not result in a significant, irreversible change to the environment
related to energy use.
5.3 GROWTH-INDUCING IMPACTS OF THE PROJECT
CEQA requires a discussion of the ways in which the proposed Project could be growth inducing. The CEQA
Guidelines identify a project as growth inducing if it would foster economic or population growth or the
construction of additional housing, either directly or indirectly, in the surrounding environment (CEQA
Guidelines Section 15126.2(e)). New employees and new residential populations represent direct forms of
growth. These direct forms of growth have a secondary effect of expanding the size of local markets and
inducing additional economic activity in the area.
A project could indirectly induce growth at the local level by increasing the demand for additional goods and
services associated with an increase in population or employment and thus reducing or removing the barriers
to growth. This typically occurs in suburban or rural environs where population growth results in increased
demand for service and commodity markets responding to the new population of residents or employees.
According to regional population projections included in SCAG’s Connect SoCal, the City of San Bernardino’s
population is projected to grow by 14,200 residents between 2016 and 2045 (approximately 0.2% annual
growth). Over this same time period, employment in the City is expected to add 24,300 new jobs
(approximately 0.7% annual job growth) (SCAG, 2020b, Demographics and Growth Forecast Appendix, Table
14). Economic growth would likely take place as a result of the Project’s operation with high-cube fulfillment
center and high-cube cold storage uses. The Project’s employees (short-term construction and long-term
operational) would purchase goods and services in the region, but any secondary increase in employment
associated with meeting these goods and services demands is expected to be accommodated by existing goods
and service providers and, based on the amount of existing and planned future commercial and retail services
available in areas near the Development Site, would be highly unlikely to result in any unanticipated, adverse
physical impacts to the environment. In addition, and as noted in Appendix 7 to the City of San Bernardino
General Plan, the City of San Bernardino supplies a relatively high number of housing units when compared
to the number of jobs provided in the City (City of San Bernardino, 2005a, Appendix 7, p. 11). tWhile the
Project would create approximately 1,120 jobs, due to the relatively high number of housing units compared
to the number of jobs within the City, it is anticipated that a majority of which the Project-generated jobs would
likely be filled by residents of the housing units either already built or planned for development within the City
of San Bernardino and nearby cities and unincorporated areas. Accordingly, because it is anticipated that most
of the Project’s future employees would already be living in the City of San Bernardino or the larger Inland
Empire area, the Project’s introduction of employment opportunities on the Development Site would not
induce substantial growth in the area.
Under CEQA, growth inducement is not considered necessarily detrimental, beneficial, or of little significance
to the environment. Typically, growth-inducing potential of a project would be considered significant if it
fosters growth or a concentration of population in excess of what is assumed in applicable master plans, land
use plans, or in projections made by regional planning agencies such as SCAG. Significant growth impacts
also could occur if a project provides infrastructure or service capacity to accommodate growth beyond the
The Landing by San Manuel
Draft Environmental Impact Report 5.0 Other CEQA Considerations
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 5-18
5.4.8 HAZARDS AND HAZARDOUS MATERIALS
Threshold a: Would the Project create a significant hazard to the public or the environment through the
routine transport, use or disposal of hazardous materials?
A Phase I Environmental Site Assessment (ESA), dated September 17, 2004, was prepared for the
Development Site by EEI to evaluate the existing conditions of the Development Site with respect to hazardous
materials. The report determined that the only potential existing sources of site contamination were associated
with potential asbestos, lead based paints, and existing site utilities associated with buildings on the site that
have since been demolished and removed from the site. There were no other identified Recognized
Environmental Conditions (RECs); thus, impacts due to existing site contamination would be less than
significant. An updated Phase I ESA was prepared for the Project and is included as Technical Appendix H to
this EIR. The updated Phase I ESA confirmed the findings of the 2004 report, and further demonstrates that
the Development Site does not contain any RECswill be prepared to verify this conclusion to support the EIR.
Heavy equipment (e.g., dozers, excavators, tractors) would be operated on the subject property during the
construction phases of the Project. This heavy equipment would likely be fueled and maintained by petroleum‐
based substances such as diesel fuel, gasoline, oil, and hydraulic fluid, which is considered hazardous if
improperly stored or handled. In addition, materials such as paints, adhesives, solvents, and other substances
typically used in building construction would be located on the Project Site during construction. Improper use,
storage, or transportation of hazardous materials can result in accidental releases or spills, potentially posing
health risks to workers, the public, and the environment. This is a standard risk on all construction sites, and
there would be no greater risk for improper handling, transportation, or spills associated with the proposed
Project than would occur on any other similar construction site. Construction contractors would be required
to comply with all applicable federal, State, and local laws and regulations regarding the transport, use, storage,
and potential accidental upset of hazardous construction‐related materials. With mandatory compliance with
applicable hazardous materials regulations, the Project would not create a significant hazard to the public or
the environment through routine transport, use, or disposal of hazardous materials during the construction
phase. Impacts would be less than significant.
Although unlikely, it is possible that hazardous materials could be used during the course of a future building
occupant’s daily operations. Uses that might use hazardous materials would be subject to standard San
Bernardino County Environmental Health Services (EHS) policies and permitting procedures required by the
Hazardous Materials Division of the San Bernardino County Fire Department. State and federal Community-
Right-to-Know laws allow the public access to information about the amounts and types of chemicals in use
at local businesses. Regulations also are in place that require businesses to plan and prepare for possible
chemical emergencies. Any business that occupies the proposed warehouse building and that handles
hazardous materials (as defined in § 25500 of California Health and Safety Code, Division 20, Chapter 6.95)
would require permits from the San Bernardino County EHS in order to register the business as a hazardous
materials handler. Such businesses also are required to comply with California’s Hazardous Materials Release
Response Plans and Inventory Law, which requires immediate reporting to the San Bernardino County Fire
Department and the State Office of Emergency Services regarding any release or threatened release of a
hazardous material, regardless of the amount handled by the business. In addition, any business handling at
The Landing by San Manuel
Draft Environmental Impact Report 5.0 Other CEQA Considerations
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 5-4
energy. Accordingly, the Project would not result in a significant, irreversible change to the environment
related to energy use.
5.3 GROWTH-INDUCING IMPACTS OF THE PROJECT
CEQA requires a discussion of the ways in which the proposed Project could be growth inducing. The CEQA
Guidelines identify a project as growth inducing if it would foster economic or population growth or the
construction of additional housing, either directly or indirectly, in the surrounding environment (CEQA
Guidelines Section 15126.2(e)). New employees and new residential populations represent direct forms of
growth. These direct forms of growth have a secondary effect of expanding the size of local markets and
inducing additional economic activity in the area.
A project could indirectly induce growth at the local level by increasing the demand for additional goods and
services associated with an increase in population or employment and thus reducing or removing the barriers
to growth. This typically occurs in suburban or rural environs where population growth results in increased
demand for service and commodity markets responding to the new population of residents or employees.
According to regional population projections included in SCAG’s Connect SoCal, the City of San Bernardino’s
population is projected to grow by 14,200 residents between 2016 and 2045 (approximately 0.2% annual
growth). Over this same time period, employment in the City is expected to add 24,300 new jobs
(approximately 0.7% annual job growth) (SCAG, 2020b, Demographics and Growth Forecast Appendix, Table
14). Economic growth would likely take place as a result of the Project’s operation with high-cube fulfillment
center and high-cube cold storage uses. The Project’s employees (short-term construction and long-term
operational) would purchase goods and services in the region, but any secondary increase in employment
associated with meeting these goods and services demands is expected to be accommodated by existing goods
and service providers and, based on the amount of existing and planned future commercial and retail services
available in areas near the Development Site, would be highly unlikely to result in any unanticipated, adverse
physical impacts to the environment. In addition, and as noted in Appendix 7 to the City of San Bernardino
General Plan, the City of San Bernardino supplies a relatively high number of housing units when compared
to the number of jobs provided in the City (City of San Bernardino, 2005a, Appendix 7, p. 11). tWhile the
Project would create approximately 1,120 jobs, due to the relatively high number of housing units compared
to the number of jobs within the City, it is anticipated that a majority of which the Project-generated jobs would
likely be filled by residents of the housing units either already built or planned for development within the City
of San Bernardino and nearby cities and unincorporated areas. Accordingly, because it is anticipated that most
of the Project’s future employees would already be living in the City of San Bernardino or the larger Inland
Empire area, the Project’s introduction of employment opportunities on the Development Site would not
induce substantial growth in the area.
Under CEQA, growth inducement is not considered necessarily detrimental, beneficial, or of little significance
to the environment. Typically, growth-inducing potential of a project would be considered significant if it
fosters growth or a concentration of population in excess of what is assumed in applicable master plans, land
use plans, or in projections made by regional planning agencies such as SCAG. Significant growth impacts
also could occur if a project provides infrastructure or service capacity to accommodate growth beyond the
The Landing by San Manuel
Draft Environmental Impact Report 5.0 Other CEQA Considerations
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 5-18
5.4.8 HAZARDS AND HAZARDOUS MATERIALS
Threshold a: Would the Project create a significant hazard to the public or the environment through the
routine transport, use or disposal of hazardous materials?
A Phase I Environmental Site Assessment (ESA), dated September 17, 2004, was prepared for the
Development Site by EEI to evaluate the existing conditions of the Development Site with respect to hazardous
materials. The report determined that the only potential existing sources of site contamination were associated
with potential asbestos, lead based paints, and existing site utilities associated with buildings on the site that
have since been demolished and removed from the site. There were no other identified Recognized
Environmental Conditions (RECs); thus, impacts due to existing site contamination would be less than
significant. An updated Phase I ESA was prepared for the Project and is included as Technical Appendix H to
this EIR. The updated Phase I ESA confirmed the findings of the 2004 report, and further demonstrates that
the Development Site does not contain any RECswill be prepared to verify this conclusion to support the EIR.
Heavy equipment (e.g., dozers, excavators, tractors) would be operated on the subject property during the
construction phases of the Project. This heavy equipment would likely be fueled and maintained by petroleum‐
based substances such as diesel fuel, gasoline, oil, and hydraulic fluid, which is considered hazardous if
improperly stored or handled. In addition, materials such as paints, adhesives, solvents, and other substances
typically used in building construction would be located on the Project Site during construction. Improper use,
storage, or transportation of hazardous materials can result in accidental releases or spills, potentially posing
health risks to workers, the public, and the environment. This is a standard risk on all construction sites, and
there would be no greater risk for improper handling, transportation, or spills associated with the proposed
Project than would occur on any other similar construction site. Construction contractors would be required
to comply with all applicable federal, State, and local laws and regulations regarding the transport, use, storage,
and potential accidental upset of hazardous construction‐related materials. With mandatory compliance with
applicable hazardous materials regulations, the Project would not create a significant hazard to the public or
the environment through routine transport, use, or disposal of hazardous materials during the construction
phase. Impacts would be less than significant.
Although unlikely, it is possible that hazardous materials could be used during the course of a future building
occupant’s daily operations. Uses that might use hazardous materials would be subject to standard San
Bernardino County Environmental Health Services (EHS) policies and permitting procedures required by the
Hazardous Materials Division of the San Bernardino County Fire Department. State and federal Community-
Right-to-Know laws allow the public access to information about the amounts and types of chemicals in use
at local businesses. Regulations also are in place that require businesses to plan and prepare for possible
chemical emergencies. Any business that occupies the proposed warehouse building and that handles
hazardous materials (as defined in § 25500 of California Health and Safety Code, Division 20, Chapter 6.95)
would require permits from the San Bernardino County EHS in order to register the business as a hazardous
materials handler. Such businesses also are required to comply with California’s Hazardous Materials Release
Response Plans and Inventory Law, which requires immediate reporting to the San Bernardino County Fire
Department and the State Office of Emergency Services regarding any release or threatened release of a
hazardous material, regardless of the amount handled by the business. In addition, any business handling at
The Landing by San Manuel
Draft Environmental Impact Report 6.0 Alternatives
Lead Agency: City of San Bernardino SCH No. 2020100067
Page 6-8
C. Cultural Resources
Under the NDA, there would be no new development on the Project Site. Thus, the NDA would avoid the
Project’s less-than-significant impact to historical resources associated with the relocation or replacement of
the existing water tower on site. The Project Site does not contain any known archaeological resources, and
proposed grading throughout the Development Site would not involve disturbances to any native soils that
may have the potential to contain previously-undiscovered archaeological resources. As such, impacts to
known archaeological resources would be less than significant and similar under the Project and NDA.
D. Greenhouse Gas Emissions
Under the NDA, there would be no new development on the Project Site. As such, the NDA would not result
in the emissions of any new GHGs. As such, implementation of the NDA would avoid the Project’s significant
and unavoidable cumulatively-considerable impact due to GHG emissions. Both the Project and NDA would
be subject to compliance with applicable plans, policies, or regulations adopted for the purpose of reducing the
emissions of GHGs; however, because the NDA would not result in any new GHG emissions, the NDA would
have reduced impacts compared to the proposed Project as the NDA would have no potential to generate GHGs
that could interfere with the applicable regulatory requirements associated with the reduction of GHGs.
E. Hydrology and Water Quality
Under the NDA, there would be no change to the Development Site’s drainage patterns, and no new buildings
or structures would be developed on site. As such, the NDA would avoid the Project’s less-than-significant
impacts due to impeding or redirecting flood flows. The Development Site is not subject to inundation due to
tsunamis or seiches; thus, neither the Project nor the NDA would result in the release of pollutants due to
tsunami- or seiche-related inundation, and the level of impact would be similar. However, implementation of
the NDA would reduce the Project’s less-than-significant impacts due to the release of pollutants associated
during flood events because no new buildings or structures would be developed on site under the NDA. While
impacts due to dam inundation would be less than significant under the proposed Project due to the low
likelihood of dam failure, because there would be no new development on site under the NDA, impacts
associated with inundation related to the failure of the Seven Oaks Dam would be reduced in comparison to
the proposed Project.
F. Land Use and Planning
Implementation of the NDA would not be consistent with the Project Site’s existing General Plan,
Development Code/Zoning Code, or San Bernardino Alliance California Specific Plan land use designations
and classifications. However, the NDA would not conflict with any land use plan, policy, or regulation adopted
for the purpose of avoiding or mitigating an environmental effect. Impacts would be less than significant under
both the Project and the NDA, and the level of impact would be similar.
G. Noise
Under the NDA, there would be no new development on site and the Project Site would remain vacant. As
such, implementation of the NDA would avoid the Project’s less-than-significant noise impacts due to
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
ATTACHMENT 2
(Related to Response A-5)
CalEEMod Outputs Calculating Potential Hauling Emissions
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Refrigerated Warehouse-No Rail 384.55 1000sqft 8.83 384,548.00 0
Unrefrigerated Warehouse-No Rail 769.10 1000sqft 17.66 769,096.00 0
Other Asphalt Surfaces 791.77 1000sqft 18.18 791,767.00 0
Other Non-Asphalt Surfaces 47.22 1000sqft 1.08 47,220.00 0
Parking Lot 787.00 Space 7.22 314,800.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
10
Wind Speed (m/s)Precipitation Freq (Days)2.2 32
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Landing by San Manuel (Construction - Hauling Activity)
San Bernardino-South Coast County, Summer
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Summer
Project Characteristics -
Land Use - Total Project Area is 52.97 acres.
Construction Phase - Construction schedule based on information provided by the Project Applicant.
Off-road Equipment - Hours are based on an 8-hour workday.
Off-road Equipment - Construction equipment based on information provided by the Project Applicant. Water Trucks modeled as "Off-Highway Trucks".
Trips and VMT - Tips will be to SBIA, approximately 0.5 miles south of the Project site.
Grading - It is anticipated that 10 acres will be disturbed per day during Site Preparation/Graading activities.
Architectural Coating - Rule 1113
Vehicle Trips - Construction Run Only.
Vehicle Emission Factors - EMFAC2017
Vehicle Emission Factors - EMFAC2017
Vehicle Emission Factors - EMFAC2017
Road Dust -
Consumer Products -
Area Coating -
Energy Use - Construction Run Only.
Water And Wastewater - Construction Run Only.
Solid Waste - Construction Run Only.
Construction Off-road Equipment Mitigation - All equipment operating at >150 HP during Site Preparation/Grading activities are required to be equipped with Tier
3 engines.
Table Name Column Name Default Value New Value
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 8.00
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Summer
tblConstEquipMitigation Tier No Change Tier 3
tblConstEquipMitigation Tier No Change Tier 3
tblConstEquipMitigation Tier No Change Tier 3
tblConstEquipMitigation Tier No Change Tier 3
tblConstEquipMitigation Tier No Change Tier 3
tblConstEquipMitigation Tier No Change Tier 3
tblConstructionPhase NumDays 110.00 60.00
tblEnergyUse LightingElect 0.35 0.00
tblEnergyUse LightingElect 2.37 0.00
tblEnergyUse LightingElect 1.17 0.00
tblEnergyUse NT24E 36.52 0.00
tblEnergyUse NT24E 0.82 0.00
tblEnergyUse NT24NG 48.51 0.00
tblEnergyUse NT24NG 0.03 0.00
tblEnergyUse T24E 1.06 0.00
tblEnergyUse T24E 0.37 0.00
tblEnergyUse T24NG 3.25 0.00
tblEnergyUse T24NG 2.00 0.00
tblGrading MaterialImported 0.00 8,000.00
tblLandUse LotAcreage 7.08 7.22
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblSolidWaste SolidWasteGenerationRate 361.48 0.00
tblSolidWaste SolidWasteGenerationRate 722.95 0.00
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Summer
tblTripsAndVMT HaulingTripLength 20.00 0.50
tblVehicleEF HHD 1.21 0.03
tblVehicleEF HHD 0.04 0.14
tblVehicleEF HHD 0.10 0.00
tblVehicleEF HHD 3.29 5.95
tblVehicleEF HHD 0.57 0.67
tblVehicleEF HHD 1.82 3.7880e-003
tblVehicleEF HHD 6,933.41 1,124.17
tblVehicleEF HHD 1,475.79 1,484.27
tblVehicleEF HHD 5.54 0.03
tblVehicleEF HHD 26.50 6.08
tblVehicleEF HHD 2.50 3.42
tblVehicleEF HHD 20.21 2.10
tblVehicleEF HHD 9.7780e-003 3.6280e-003
tblVehicleEF HHD 0.06 0.06
tblVehicleEF HHD 0.04 0.04
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 5.1000e-005 1.0000e-006
tblVehicleEF HHD 9.3550e-003 3.4710e-003
tblVehicleEF HHD 0.03 0.03
tblVehicleEF HHD 8.8810e-003 8.8310e-003
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 4.7000e-005 1.0000e-006
tblVehicleEF HHD 8.5000e-005 5.0000e-006
tblVehicleEF HHD 3.1910e-003 1.6000e-004
tblVehicleEF HHD 0.84 0.43
tblVehicleEF HHD 5.2000e-005 3.0000e-006
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Summer
tblVehicleEF HHD 0.08 0.08
tblVehicleEF HHD 2.1700e-004 7.9100e-004
tblVehicleEF HHD 0.05 1.0000e-006
tblVehicleEF HHD 0.07 0.01
tblVehicleEF HHD 0.01 0.01
tblVehicleEF HHD 8.6000e-005 0.00
tblVehicleEF HHD 8.5000e-005 5.0000e-006
tblVehicleEF HHD 3.1910e-003 1.6000e-004
tblVehicleEF HHD 0.97 0.50
tblVehicleEF HHD 5.2000e-005 3.0000e-006
tblVehicleEF HHD 0.13 0.23
tblVehicleEF HHD 2.1700e-004 7.9100e-004
tblVehicleEF HHD 0.06 1.0000e-006
tblVehicleEF HHD 1.14 0.03
tblVehicleEF HHD 0.04 0.14
tblVehicleEF HHD 0.09 0.00
tblVehicleEF HHD 2.39 5.82
tblVehicleEF HHD 0.57 0.67
tblVehicleEF HHD 1.70 3.5770e-003
tblVehicleEF HHD 7,345.18 1,121.04
tblVehicleEF HHD 1,475.79 1,484.27
tblVehicleEF HHD 5.54 0.03
tblVehicleEF HHD 27.35 5.90
tblVehicleEF HHD 2.36 3.23
tblVehicleEF HHD 20.20 2.10
tblVehicleEF HHD 8.2750e-003 3.1750e-003
tblVehicleEF HHD 0.06 0.06
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 5 of 63
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tblVehicleEF HHD 0.04 0.04
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 5.1000e-005 1.0000e-006
tblVehicleEF HHD 7.9170e-003 3.0380e-003
tblVehicleEF HHD 0.03 0.03
tblVehicleEF HHD 8.8810e-003 8.8310e-003
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 4.7000e-005 1.0000e-006
tblVehicleEF HHD 1.6800e-004 1.0000e-005
tblVehicleEF HHD 3.5970e-003 1.8200e-004
tblVehicleEF HHD 0.79 0.45
tblVehicleEF HHD 1.1700e-004 7.0000e-006
tblVehicleEF HHD 0.08 0.08
tblVehicleEF HHD 2.2100e-004 8.1200e-004
tblVehicleEF HHD 0.05 1.0000e-006
tblVehicleEF HHD 0.07 0.01
tblVehicleEF HHD 0.01 0.01
tblVehicleEF HHD 8.4000e-005 0.00
tblVehicleEF HHD 1.6800e-004 1.0000e-005
tblVehicleEF HHD 3.5970e-003 1.8200e-004
tblVehicleEF HHD 0.91 0.52
tblVehicleEF HHD 1.1700e-004 7.0000e-006
tblVehicleEF HHD 0.13 0.23
tblVehicleEF HHD 2.2100e-004 8.1200e-004
tblVehicleEF HHD 0.06 1.0000e-006
tblVehicleEF HHD 1.31 0.02
tblVehicleEF HHD 0.04 3.3680e-003
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 6 of 63
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tblVehicleEF HHD 0.10 0.00
tblVehicleEF HHD 4.53 5.98
tblVehicleEF HHD 0.57 0.33
tblVehicleEF HHD 1.79 3.7590e-003
tblVehicleEF HHD 6,364.76 1,097.48
tblVehicleEF HHD 1,475.79 1,393.36
tblVehicleEF HHD 5.54 0.03
tblVehicleEF HHD 25.32 6.13
tblVehicleEF HHD 2.46 3.28
tblVehicleEF HHD 20.20 2.10
tblVehicleEF HHD 0.01 3.8650e-003
tblVehicleEF HHD 0.06 0.06
tblVehicleEF HHD 0.04 0.03
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 5.1000e-005 1.0000e-006
tblVehicleEF HHD 0.01 3.6980e-003
tblVehicleEF HHD 0.03 0.03
tblVehicleEF HHD 8.8810e-003 8.6000e-003
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 4.7000e-005 1.0000e-006
tblVehicleEF HHD 8.5000e-005 5.0000e-006
tblVehicleEF HHD 3.4760e-003 1.8700e-004
tblVehicleEF HHD 0.91 0.40
tblVehicleEF HHD 5.2000e-005 3.0000e-006
tblVehicleEF HHD 0.08 0.07
tblVehicleEF HHD 2.3300e-004 8.2900e-004
tblVehicleEF HHD 0.05 1.0000e-006
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 7 of 63
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tblVehicleEF HHD 0.06 0.01
tblVehicleEF HHD 0.01 0.01
tblVehicleEF HHD 8.5000e-005 0.00
tblVehicleEF HHD 8.5000e-005 5.0000e-006
tblVehicleEF HHD 3.4760e-003 1.8700e-004
tblVehicleEF HHD 1.05 0.46
tblVehicleEF HHD 5.2000e-005 3.0000e-006
tblVehicleEF HHD 0.13 0.08
tblVehicleEF HHD 2.3300e-004 8.2900e-004
tblVehicleEF HHD 0.06 1.0000e-006
tblVehicleEF LDA 4.2030e-003 2.5110e-003
tblVehicleEF LDA 5.6230e-003 0.05
tblVehicleEF LDA 0.57 0.67
tblVehicleEF LDA 1.19 2.11
tblVehicleEF LDA 251.29 265.15
tblVehicleEF LDA 57.15 54.12
tblVehicleEF LDA 0.05 0.04
tblVehicleEF LDA 0.08 0.18
tblVehicleEF LDA 1.6780e-003 1.5210e-003
tblVehicleEF LDA 2.2790e-003 1.8570e-003
tblVehicleEF LDA 1.5460e-003 1.4000e-003
tblVehicleEF LDA 2.0960e-003 1.7080e-003
tblVehicleEF LDA 0.04 0.06
tblVehicleEF LDA 0.10 0.10
tblVehicleEF LDA 0.03 0.05
tblVehicleEF LDA 0.01 9.5370e-003
tblVehicleEF LDA 0.03 0.21
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 8 of 63
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tblVehicleEF LDA 0.08 0.22
tblVehicleEF LDA 2.5170e-003 2.6060e-003
tblVehicleEF LDA 5.9200e-004 5.3200e-004
tblVehicleEF LDA 0.04 0.06
tblVehicleEF LDA 0.10 0.10
tblVehicleEF LDA 0.03 0.05
tblVehicleEF LDA 0.02 0.01
tblVehicleEF LDA 0.03 0.21
tblVehicleEF LDA 0.08 0.24
tblVehicleEF LDA 4.7900e-003 2.8350e-003
tblVehicleEF LDA 4.6890e-003 0.04
tblVehicleEF LDA 0.71 0.81
tblVehicleEF LDA 0.99 1.78
tblVehicleEF LDA 274.94 287.11
tblVehicleEF LDA 57.15 53.48
tblVehicleEF LDA 0.05 0.03
tblVehicleEF LDA 0.07 0.17
tblVehicleEF LDA 1.6780e-003 1.5210e-003
tblVehicleEF LDA 2.2790e-003 1.8570e-003
tblVehicleEF LDA 1.5460e-003 1.4000e-003
tblVehicleEF LDA 2.0960e-003 1.7080e-003
tblVehicleEF LDA 0.09 0.11
tblVehicleEF LDA 0.12 0.11
tblVehicleEF LDA 0.07 0.09
tblVehicleEF LDA 0.01 0.01
tblVehicleEF LDA 0.03 0.21
tblVehicleEF LDA 0.06 0.19
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 9 of 63
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tblVehicleEF LDA 2.7550e-003 2.8220e-003
tblVehicleEF LDA 5.8800e-004 5.2600e-004
tblVehicleEF LDA 0.09 0.11
tblVehicleEF LDA 0.12 0.11
tblVehicleEF LDA 0.07 0.09
tblVehicleEF LDA 0.02 0.02
tblVehicleEF LDA 0.03 0.21
tblVehicleEF LDA 0.07 0.21
tblVehicleEF LDA 4.0860e-003 2.4590e-003
tblVehicleEF LDA 5.5870e-003 0.05
tblVehicleEF LDA 0.54 0.64
tblVehicleEF LDA 1.18 2.12
tblVehicleEF LDA 245.70 261.06
tblVehicleEF LDA 57.15 54.13
tblVehicleEF LDA 0.05 0.04
tblVehicleEF LDA 0.08 0.18
tblVehicleEF LDA 1.6780e-003 1.5210e-003
tblVehicleEF LDA 2.2790e-003 1.8570e-003
tblVehicleEF LDA 1.5460e-003 1.4000e-003
tblVehicleEF LDA 2.0960e-003 1.7080e-003
tblVehicleEF LDA 0.05 0.06
tblVehicleEF LDA 0.11 0.11
tblVehicleEF LDA 0.03 0.05
tblVehicleEF LDA 0.01 9.3400e-003
tblVehicleEF LDA 0.04 0.24
tblVehicleEF LDA 0.08 0.22
tblVehicleEF LDA 2.4600e-003 2.5660e-003
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 10 of 63
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tblVehicleEF LDA 5.9100e-004 5.3200e-004
tblVehicleEF LDA 0.05 0.06
tblVehicleEF LDA 0.11 0.11
tblVehicleEF LDA 0.03 0.05
tblVehicleEF LDA 0.01 0.01
tblVehicleEF LDA 0.04 0.24
tblVehicleEF LDA 0.08 0.24
tblVehicleEF LDT1 0.01 7.5760e-003
tblVehicleEF LDT1 0.02 0.08
tblVehicleEF LDT1 1.54 1.52
tblVehicleEF LDT1 3.61 2.39
tblVehicleEF LDT1 313.68 314.63
tblVehicleEF LDT1 70.93 65.70
tblVehicleEF LDT1 0.16 0.13
tblVehicleEF LDT1 0.22 0.30
tblVehicleEF LDT1 2.7050e-003 2.3430e-003
tblVehicleEF LDT1 3.6920e-003 2.8390e-003
tblVehicleEF LDT1 2.4910e-003 2.1560e-003
tblVehicleEF LDT1 3.3960e-003 2.6100e-003
tblVehicleEF LDT1 0.18 0.19
tblVehicleEF LDT1 0.33 0.26
tblVehicleEF LDT1 0.13 0.14
tblVehicleEF LDT1 0.03 0.03
tblVehicleEF LDT1 0.20 0.86
tblVehicleEF LDT1 0.26 0.42
tblVehicleEF LDT1 3.1570e-003 3.0930e-003
tblVehicleEF LDT1 7.7300e-004 6.4600e-004
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 11 of 63
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tblVehicleEF LDT1 0.18 0.19
tblVehicleEF LDT1 0.33 0.26
tblVehicleEF LDT1 0.13 0.14
tblVehicleEF LDT1 0.05 0.05
tblVehicleEF LDT1 0.20 0.86
tblVehicleEF LDT1 0.28 0.47
tblVehicleEF LDT1 0.02 8.4640e-003
tblVehicleEF LDT1 0.02 0.07
tblVehicleEF LDT1 1.85 1.81
tblVehicleEF LDT1 2.97 2.00
tblVehicleEF LDT1 341.75 337.48
tblVehicleEF LDT1 70.93 64.87
tblVehicleEF LDT1 0.14 0.11
tblVehicleEF LDT1 0.20 0.28
tblVehicleEF LDT1 2.7050e-003 2.3430e-003
tblVehicleEF LDT1 3.6920e-003 2.8390e-003
tblVehicleEF LDT1 2.4910e-003 2.1560e-003
tblVehicleEF LDT1 3.3960e-003 2.6100e-003
tblVehicleEF LDT1 0.37 0.36
tblVehicleEF LDT1 0.41 0.31
tblVehicleEF LDT1 0.27 0.26
tblVehicleEF LDT1 0.04 0.04
tblVehicleEF LDT1 0.20 0.85
tblVehicleEF LDT1 0.21 0.36
tblVehicleEF LDT1 3.4420e-003 3.3180e-003
tblVehicleEF LDT1 7.6200e-004 6.3800e-004
tblVehicleEF LDT1 0.37 0.36
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 12 of 63
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tblVehicleEF LDT1 0.41 0.31
tblVehicleEF LDT1 0.27 0.26
tblVehicleEF LDT1 0.06 0.05
tblVehicleEF LDT1 0.20 0.85
tblVehicleEF LDT1 0.23 0.40
tblVehicleEF LDT1 0.01 7.4310e-003
tblVehicleEF LDT1 0.02 0.08
tblVehicleEF LDT1 1.47 1.47
tblVehicleEF LDT1 3.55 2.39
tblVehicleEF LDT1 307.06 310.38
tblVehicleEF LDT1 70.93 65.71
tblVehicleEF LDT1 0.15 0.12
tblVehicleEF LDT1 0.21 0.29
tblVehicleEF LDT1 2.7050e-003 2.3430e-003
tblVehicleEF LDT1 3.6920e-003 2.8390e-003
tblVehicleEF LDT1 2.4910e-003 2.1560e-003
tblVehicleEF LDT1 3.3960e-003 2.6100e-003
tblVehicleEF LDT1 0.19 0.19
tblVehicleEF LDT1 0.39 0.30
tblVehicleEF LDT1 0.12 0.13
tblVehicleEF LDT1 0.03 0.03
tblVehicleEF LDT1 0.23 1.00
tblVehicleEF LDT1 0.25 0.43
tblVehicleEF LDT1 3.0890e-003 3.0520e-003
tblVehicleEF LDT1 7.7200e-004 6.4600e-004
tblVehicleEF LDT1 0.19 0.19
tblVehicleEF LDT1 0.39 0.30
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 13 of 63
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tblVehicleEF LDT1 0.12 0.13
tblVehicleEF LDT1 0.05 0.05
tblVehicleEF LDT1 0.23 1.00
tblVehicleEF LDT1 0.28 0.47
tblVehicleEF LDT2 6.3270e-003 4.4090e-003
tblVehicleEF LDT2 8.1990e-003 0.07
tblVehicleEF LDT2 0.80 1.00
tblVehicleEF LDT2 1.67 2.71
tblVehicleEF LDT2 351.15 335.59
tblVehicleEF LDT2 79.39 70.25
tblVehicleEF LDT2 0.09 0.09
tblVehicleEF LDT2 0.14 0.30
tblVehicleEF LDT2 1.7270e-003 1.6010e-003
tblVehicleEF LDT2 2.4170e-003 1.9240e-003
tblVehicleEF LDT2 1.5880e-003 1.4740e-003
tblVehicleEF LDT2 2.2220e-003 1.7690e-003
tblVehicleEF LDT2 0.06 0.10
tblVehicleEF LDT2 0.13 0.14
tblVehicleEF LDT2 0.05 0.08
tblVehicleEF LDT2 0.02 0.02
tblVehicleEF LDT2 0.07 0.45
tblVehicleEF LDT2 0.11 0.33
tblVehicleEF LDT2 3.5180e-003 3.2990e-003
tblVehicleEF LDT2 8.2200e-004 6.9100e-004
tblVehicleEF LDT2 0.06 0.10
tblVehicleEF LDT2 0.13 0.14
tblVehicleEF LDT2 0.05 0.08
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 14 of 63
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tblVehicleEF LDT2 0.02 0.03
tblVehicleEF LDT2 0.07 0.45
tblVehicleEF LDT2 0.12 0.36
tblVehicleEF LDT2 7.1840e-003 4.9540e-003
tblVehicleEF LDT2 6.8290e-003 0.06
tblVehicleEF LDT2 0.97 1.20
tblVehicleEF LDT2 1.38 2.28
tblVehicleEF LDT2 383.36 357.71
tblVehicleEF LDT2 79.39 69.39
tblVehicleEF LDT2 0.08 0.08
tblVehicleEF LDT2 0.13 0.28
tblVehicleEF LDT2 1.7270e-003 1.6010e-003
tblVehicleEF LDT2 2.4170e-003 1.9240e-003
tblVehicleEF LDT2 1.5880e-003 1.4740e-003
tblVehicleEF LDT2 2.2220e-003 1.7690e-003
tblVehicleEF LDT2 0.13 0.18
tblVehicleEF LDT2 0.15 0.16
tblVehicleEF LDT2 0.11 0.15
tblVehicleEF LDT2 0.02 0.02
tblVehicleEF LDT2 0.07 0.45
tblVehicleEF LDT2 0.09 0.29
tblVehicleEF LDT2 3.8420e-003 3.5160e-003
tblVehicleEF LDT2 8.1700e-004 6.8200e-004
tblVehicleEF LDT2 0.13 0.18
tblVehicleEF LDT2 0.15 0.16
tblVehicleEF LDT2 0.11 0.15
tblVehicleEF LDT2 0.03 0.03
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 15 of 63
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tblVehicleEF LDT2 0.07 0.45
tblVehicleEF LDT2 0.10 0.31
tblVehicleEF LDT2 6.1560e-003 4.3220e-003
tblVehicleEF LDT2 8.1410e-003 0.07
tblVehicleEF LDT2 0.75 0.96
tblVehicleEF LDT2 1.64 2.72
tblVehicleEF LDT2 343.55 331.47
tblVehicleEF LDT2 79.39 70.27
tblVehicleEF LDT2 0.08 0.08
tblVehicleEF LDT2 0.14 0.30
tblVehicleEF LDT2 1.7270e-003 1.6010e-003
tblVehicleEF LDT2 2.4170e-003 1.9240e-003
tblVehicleEF LDT2 1.5880e-003 1.4740e-003
tblVehicleEF LDT2 2.2220e-003 1.7690e-003
tblVehicleEF LDT2 0.06 0.09
tblVehicleEF LDT2 0.14 0.16
tblVehicleEF LDT2 0.05 0.08
tblVehicleEF LDT2 0.02 0.02
tblVehicleEF LDT2 0.08 0.52
tblVehicleEF LDT2 0.11 0.33
tblVehicleEF LDT2 3.4410e-003 3.2580e-003
tblVehicleEF LDT2 8.2200e-004 6.9100e-004
tblVehicleEF LDT2 0.06 0.09
tblVehicleEF LDT2 0.14 0.16
tblVehicleEF LDT2 0.05 0.08
tblVehicleEF LDT2 0.02 0.03
tblVehicleEF LDT2 0.08 0.52
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 16 of 63
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tblVehicleEF LDT2 0.12 0.37
tblVehicleEF LHD1 5.2170e-003 5.0850e-003
tblVehicleEF LHD1 0.01 6.1020e-003
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 0.14 0.18
tblVehicleEF LHD1 1.07 0.75
tblVehicleEF LHD1 2.60 1.03
tblVehicleEF LHD1 9.23 9.25
tblVehicleEF LHD1 609.20 652.45
tblVehicleEF LHD1 30.40 11.21
tblVehicleEF LHD1 0.09 0.07
tblVehicleEF LHD1 2.12 1.25
tblVehicleEF LHD1 0.99 0.32
tblVehicleEF LHD1 9.6500e-004 8.9000e-004
tblVehicleEF LHD1 0.01 9.8770e-003
tblVehicleEF LHD1 0.01 9.8260e-003
tblVehicleEF LHD1 9.5800e-004 2.6000e-004
tblVehicleEF LHD1 9.2400e-004 8.5100e-004
tblVehicleEF LHD1 2.5390e-003 2.4690e-003
tblVehicleEF LHD1 0.01 9.3750e-003
tblVehicleEF LHD1 8.8100e-004 2.3900e-004
tblVehicleEF LHD1 3.7070e-003 3.0390e-003
tblVehicleEF LHD1 0.11 0.08
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 1.8240e-003 1.5810e-003
tblVehicleEF LHD1 0.08 0.06
tblVehicleEF LHD1 0.35 0.55
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 17 of 63
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tblVehicleEF LHD1 0.27 0.08
tblVehicleEF LHD1 9.2000e-005 9.0000e-005
tblVehicleEF LHD1 5.9760e-003 6.3570e-003
tblVehicleEF LHD1 3.5300e-004 1.1100e-004
tblVehicleEF LHD1 3.7070e-003 3.0390e-003
tblVehicleEF LHD1 0.11 0.08
tblVehicleEF LHD1 0.02 0.03
tblVehicleEF LHD1 1.8240e-003 1.5810e-003
tblVehicleEF LHD1 0.10 0.08
tblVehicleEF LHD1 0.35 0.55
tblVehicleEF LHD1 0.29 0.09
tblVehicleEF LHD1 5.2170e-003 5.0990e-003
tblVehicleEF LHD1 0.01 6.2280e-003
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 0.14 0.18
tblVehicleEF LHD1 1.09 0.76
tblVehicleEF LHD1 2.43 0.98
tblVehicleEF LHD1 9.23 9.25
tblVehicleEF LHD1 609.20 652.47
tblVehicleEF LHD1 30.40 11.12
tblVehicleEF LHD1 0.09 0.07
tblVehicleEF LHD1 1.98 1.17
tblVehicleEF LHD1 0.94 0.31
tblVehicleEF LHD1 9.6500e-004 8.9000e-004
tblVehicleEF LHD1 0.01 9.8770e-003
tblVehicleEF LHD1 0.01 9.8260e-003
tblVehicleEF LHD1 9.5800e-004 2.6000e-004
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 18 of 63
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tblVehicleEF LHD1 9.2400e-004 8.5100e-004
tblVehicleEF LHD1 2.5390e-003 2.4690e-003
tblVehicleEF LHD1 0.01 9.3750e-003
tblVehicleEF LHD1 8.8100e-004 2.3900e-004
tblVehicleEF LHD1 7.3080e-003 5.4780e-003
tblVehicleEF LHD1 0.13 0.10
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 4.1220e-003 3.0450e-003
tblVehicleEF LHD1 0.09 0.06
tblVehicleEF LHD1 0.36 0.56
tblVehicleEF LHD1 0.25 0.08
tblVehicleEF LHD1 9.2000e-005 9.0000e-005
tblVehicleEF LHD1 5.9770e-003 6.3570e-003
tblVehicleEF LHD1 3.5000e-004 1.1000e-004
tblVehicleEF LHD1 7.3080e-003 5.4780e-003
tblVehicleEF LHD1 0.13 0.10
tblVehicleEF LHD1 0.02 0.03
tblVehicleEF LHD1 4.1220e-003 3.0450e-003
tblVehicleEF LHD1 0.11 0.08
tblVehicleEF LHD1 0.36 0.56
tblVehicleEF LHD1 0.28 0.08
tblVehicleEF LHD1 5.2170e-003 5.0870e-003
tblVehicleEF LHD1 0.01 6.1100e-003
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 0.14 0.18
tblVehicleEF LHD1 1.07 0.75
tblVehicleEF LHD1 2.55 1.02
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:34 AMPage 19 of 63
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tblVehicleEF LHD1 9.23 9.25
tblVehicleEF LHD1 609.20 652.45
tblVehicleEF LHD1 30.40 11.20
tblVehicleEF LHD1 0.09 0.07
tblVehicleEF LHD1 2.08 1.23
tblVehicleEF LHD1 0.97 0.31
tblVehicleEF LHD1 9.6500e-004 8.9000e-004
tblVehicleEF LHD1 0.01 9.8770e-003
tblVehicleEF LHD1 0.01 9.8260e-003
tblVehicleEF LHD1 9.5800e-004 2.6000e-004
tblVehicleEF LHD1 9.2400e-004 8.5100e-004
tblVehicleEF LHD1 2.5390e-003 2.4690e-003
tblVehicleEF LHD1 0.01 9.3750e-003
tblVehicleEF LHD1 8.8100e-004 2.3900e-004
tblVehicleEF LHD1 4.0430e-003 3.1520e-003
tblVehicleEF LHD1 0.13 0.10
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 1.7940e-003 1.6100e-003
tblVehicleEF LHD1 0.08 0.06
tblVehicleEF LHD1 0.38 0.60
tblVehicleEF LHD1 0.26 0.08
tblVehicleEF LHD1 9.2000e-005 9.0000e-005
tblVehicleEF LHD1 5.9760e-003 6.3570e-003
tblVehicleEF LHD1 3.5200e-004 1.1100e-004
tblVehicleEF LHD1 4.0430e-003 3.1520e-003
tblVehicleEF LHD1 0.13 0.10
tblVehicleEF LHD1 0.02 0.03
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tblVehicleEF LHD1 1.7940e-003 1.6100e-003
tblVehicleEF LHD1 0.10 0.08
tblVehicleEF LHD1 0.38 0.60
tblVehicleEF LHD1 0.29 0.09
tblVehicleEF LHD2 3.5950e-003 3.6950e-003
tblVehicleEF LHD2 4.6110e-003 4.1040e-003
tblVehicleEF LHD2 8.1370e-003 0.01
tblVehicleEF LHD2 0.12 0.15
tblVehicleEF LHD2 0.50 0.50
tblVehicleEF LHD2 1.20 0.67
tblVehicleEF LHD2 14.27 14.14
tblVehicleEF LHD2 608.52 665.25
tblVehicleEF LHD2 24.46 8.76
tblVehicleEF LHD2 0.11 0.10
tblVehicleEF LHD2 1.49 1.36
tblVehicleEF LHD2 0.53 0.22
tblVehicleEF LHD2 1.2830e-003 1.3100e-003
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 4.0000e-004 1.3700e-004
tblVehicleEF LHD2 1.2280e-003 1.2540e-003
tblVehicleEF LHD2 2.6860e-003 2.6560e-003
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 3.6800e-004 1.2600e-004
tblVehicleEF LHD2 1.3070e-003 1.7040e-003
tblVehicleEF LHD2 0.04 0.05
tblVehicleEF LHD2 0.01 0.02
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tblVehicleEF LHD2 7.0300e-004 9.2000e-004
tblVehicleEF LHD2 0.06 0.06
tblVehicleEF LHD2 0.09 0.32
tblVehicleEF LHD2 0.11 0.05
tblVehicleEF LHD2 1.3900e-004 1.3500e-004
tblVehicleEF LHD2 5.9200e-003 6.4300e-003
tblVehicleEF LHD2 2.6700e-004 8.7000e-005
tblVehicleEF LHD2 1.3070e-003 1.7040e-003
tblVehicleEF LHD2 0.04 0.05
tblVehicleEF LHD2 0.02 0.02
tblVehicleEF LHD2 7.0300e-004 9.2000e-004
tblVehicleEF LHD2 0.07 0.07
tblVehicleEF LHD2 0.09 0.32
tblVehicleEF LHD2 0.12 0.06
tblVehicleEF LHD2 3.5950e-003 3.7050e-003
tblVehicleEF LHD2 4.6760e-003 4.1460e-003
tblVehicleEF LHD2 7.7630e-003 0.01
tblVehicleEF LHD2 0.12 0.15
tblVehicleEF LHD2 0.50 0.50
tblVehicleEF LHD2 1.13 0.64
tblVehicleEF LHD2 14.27 14.14
tblVehicleEF LHD2 608.52 665.25
tblVehicleEF LHD2 24.46 8.70
tblVehicleEF LHD2 0.11 0.10
tblVehicleEF LHD2 1.40 1.28
tblVehicleEF LHD2 0.50 0.21
tblVehicleEF LHD2 1.2830e-003 1.3100e-003
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tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 4.0000e-004 1.3700e-004
tblVehicleEF LHD2 1.2280e-003 1.2540e-003
tblVehicleEF LHD2 2.6860e-003 2.6560e-003
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 3.6800e-004 1.2600e-004
tblVehicleEF LHD2 2.5220e-003 3.0730e-003
tblVehicleEF LHD2 0.04 0.06
tblVehicleEF LHD2 0.01 0.02
tblVehicleEF LHD2 1.5220e-003 1.7630e-003
tblVehicleEF LHD2 0.06 0.06
tblVehicleEF LHD2 0.09 0.32
tblVehicleEF LHD2 0.10 0.05
tblVehicleEF LHD2 1.3900e-004 1.3500e-004
tblVehicleEF LHD2 5.9200e-003 6.4300e-003
tblVehicleEF LHD2 2.6500e-004 8.6000e-005
tblVehicleEF LHD2 2.5220e-003 3.0730e-003
tblVehicleEF LHD2 0.04 0.06
tblVehicleEF LHD2 0.02 0.02
tblVehicleEF LHD2 1.5220e-003 1.7630e-003
tblVehicleEF LHD2 0.07 0.07
tblVehicleEF LHD2 0.09 0.32
tblVehicleEF LHD2 0.11 0.05
tblVehicleEF LHD2 3.5950e-003 3.6960e-003
tblVehicleEF LHD2 4.6180e-003 4.1080e-003
tblVehicleEF LHD2 8.0640e-003 0.01
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tblVehicleEF LHD2 0.12 0.15
tblVehicleEF LHD2 0.50 0.50
tblVehicleEF LHD2 1.19 0.67
tblVehicleEF LHD2 14.27 14.14
tblVehicleEF LHD2 608.52 665.25
tblVehicleEF LHD2 24.46 8.75
tblVehicleEF LHD2 0.11 0.10
tblVehicleEF LHD2 1.46 1.33
tblVehicleEF LHD2 0.52 0.22
tblVehicleEF LHD2 1.2830e-003 1.3100e-003
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 4.0000e-004 1.3700e-004
tblVehicleEF LHD2 1.2280e-003 1.2540e-003
tblVehicleEF LHD2 2.6860e-003 2.6560e-003
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 3.6800e-004 1.2600e-004
tblVehicleEF LHD2 1.3460e-003 1.7140e-003
tblVehicleEF LHD2 0.04 0.06
tblVehicleEF LHD2 0.01 0.02
tblVehicleEF LHD2 6.8700e-004 9.2200e-004
tblVehicleEF LHD2 0.06 0.06
tblVehicleEF LHD2 0.10 0.34
tblVehicleEF LHD2 0.11 0.05
tblVehicleEF LHD2 1.3900e-004 1.3500e-004
tblVehicleEF LHD2 5.9200e-003 6.4300e-003
tblVehicleEF LHD2 2.6600e-004 8.7000e-005
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tblVehicleEF LHD2 1.3460e-003 1.7140e-003
tblVehicleEF LHD2 0.04 0.06
tblVehicleEF LHD2 0.02 0.02
tblVehicleEF LHD2 6.8700e-004 9.2200e-004
tblVehicleEF LHD2 0.07 0.07
tblVehicleEF LHD2 0.10 0.34
tblVehicleEF LHD2 0.12 0.06
tblVehicleEF MCY 0.43 0.34
tblVehicleEF MCY 0.16 0.24
tblVehicleEF MCY 20.55 19.26
tblVehicleEF MCY 9.93 8.60
tblVehicleEF MCY 167.73 212.03
tblVehicleEF MCY 46.45 60.73
tblVehicleEF MCY 1.16 1.13
tblVehicleEF MCY 0.31 0.26
tblVehicleEF MCY 1.8610e-003 1.9650e-003
tblVehicleEF MCY 3.6730e-003 2.9600e-003
tblVehicleEF MCY 1.7420e-003 1.8380e-003
tblVehicleEF MCY 3.4650e-003 2.7870e-003
tblVehicleEF MCY 1.45 1.42
tblVehicleEF MCY 0.84 0.80
tblVehicleEF MCY 0.80 0.78
tblVehicleEF MCY 2.23 2.33
tblVehicleEF MCY 0.49 1.91
tblVehicleEF MCY 2.16 1.84
tblVehicleEF MCY 2.0770e-003 2.0980e-003
tblVehicleEF MCY 6.9000e-004 6.0100e-004
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tblVehicleEF MCY 1.45 1.42
tblVehicleEF MCY 0.84 0.80
tblVehicleEF MCY 0.80 0.78
tblVehicleEF MCY 2.74 2.87
tblVehicleEF MCY 0.49 1.91
tblVehicleEF MCY 2.35 2.01
tblVehicleEF MCY 0.42 0.34
tblVehicleEF MCY 0.14 0.21
tblVehicleEF MCY 20.68 19.28
tblVehicleEF MCY 9.05 7.90
tblVehicleEF MCY 167.73 211.90
tblVehicleEF MCY 46.45 58.88
tblVehicleEF MCY 0.99 0.97
tblVehicleEF MCY 0.29 0.25
tblVehicleEF MCY 1.8610e-003 1.9650e-003
tblVehicleEF MCY 3.6730e-003 2.9600e-003
tblVehicleEF MCY 1.7420e-003 1.8380e-003
tblVehicleEF MCY 3.4650e-003 2.7870e-003
tblVehicleEF MCY 3.14 2.77
tblVehicleEF MCY 1.27 1.11
tblVehicleEF MCY 2.13 1.77
tblVehicleEF MCY 2.17 2.28
tblVehicleEF MCY 0.49 1.88
tblVehicleEF MCY 1.86 1.62
tblVehicleEF MCY 2.0770e-003 2.0970e-003
tblVehicleEF MCY 6.6700e-004 5.8300e-004
tblVehicleEF MCY 3.14 2.77
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tblVehicleEF MCY 1.27 1.11
tblVehicleEF MCY 2.13 1.77
tblVehicleEF MCY 2.67 2.81
tblVehicleEF MCY 0.49 1.88
tblVehicleEF MCY 2.02 1.76
tblVehicleEF MCY 0.42 0.34
tblVehicleEF MCY 0.15 0.24
tblVehicleEF MCY 19.63 18.76
tblVehicleEF MCY 9.55 8.44
tblVehicleEF MCY 167.73 211.17
tblVehicleEF MCY 46.45 60.38
tblVehicleEF MCY 1.12 1.09
tblVehicleEF MCY 0.31 0.26
tblVehicleEF MCY 1.8610e-003 1.9650e-003
tblVehicleEF MCY 3.6730e-003 2.9600e-003
tblVehicleEF MCY 1.7420e-003 1.8380e-003
tblVehicleEF MCY 3.4650e-003 2.7870e-003
tblVehicleEF MCY 1.71 1.57
tblVehicleEF MCY 1.13 1.06
tblVehicleEF MCY 0.72 0.74
tblVehicleEF MCY 2.19 2.31
tblVehicleEF MCY 0.56 2.18
tblVehicleEF MCY 2.08 1.81
tblVehicleEF MCY 2.0610e-003 2.0900e-003
tblVehicleEF MCY 6.8200e-004 5.9800e-004
tblVehicleEF MCY 1.71 1.57
tblVehicleEF MCY 1.13 1.06
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tblVehicleEF MCY 0.72 0.74
tblVehicleEF MCY 2.69 2.84
tblVehicleEF MCY 0.56 2.18
tblVehicleEF MCY 2.27 1.98
tblVehicleEF MDV 0.01 5.5200e-003
tblVehicleEF MDV 0.02 0.09
tblVehicleEF MDV 1.35 1.14
tblVehicleEF MDV 3.25 3.25
tblVehicleEF MDV 483.94 415.10
tblVehicleEF MDV 107.92 87.32
tblVehicleEF MDV 0.17 0.11
tblVehicleEF MDV 0.32 0.38
tblVehicleEF MDV 1.8260e-003 1.6850e-003
tblVehicleEF MDV 2.5170e-003 2.0310e-003
tblVehicleEF MDV 1.6830e-003 1.5540e-003
tblVehicleEF MDV 2.3150e-003 1.8680e-003
tblVehicleEF MDV 0.10 0.11
tblVehicleEF MDV 0.20 0.17
tblVehicleEF MDV 0.08 0.10
tblVehicleEF MDV 0.03 0.02
tblVehicleEF MDV 0.11 0.50
tblVehicleEF MDV 0.25 0.44
tblVehicleEF MDV 4.8500e-003 4.0780e-003
tblVehicleEF MDV 1.1370e-003 8.5900e-004
tblVehicleEF MDV 0.10 0.11
tblVehicleEF MDV 0.20 0.17
tblVehicleEF MDV 0.08 0.10
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tblVehicleEF MDV 0.05 0.03
tblVehicleEF MDV 0.11 0.50
tblVehicleEF MDV 0.28 0.48
tblVehicleEF MDV 0.01 6.2110e-003
tblVehicleEF MDV 0.02 0.08
tblVehicleEF MDV 1.64 1.35
tblVehicleEF MDV 2.69 2.72
tblVehicleEF MDV 526.85 438.45
tblVehicleEF MDV 107.92 86.27
tblVehicleEF MDV 0.16 0.10
tblVehicleEF MDV 0.30 0.35
tblVehicleEF MDV 1.8260e-003 1.6850e-003
tblVehicleEF MDV 2.5170e-003 2.0310e-003
tblVehicleEF MDV 1.6830e-003 1.5540e-003
tblVehicleEF MDV 2.3150e-003 1.8680e-003
tblVehicleEF MDV 0.20 0.21
tblVehicleEF MDV 0.23 0.19
tblVehicleEF MDV 0.17 0.19
tblVehicleEF MDV 0.04 0.03
tblVehicleEF MDV 0.11 0.49
tblVehicleEF MDV 0.21 0.38
tblVehicleEF MDV 5.2830e-003 4.3080e-003
tblVehicleEF MDV 1.1260e-003 8.4800e-004
tblVehicleEF MDV 0.20 0.21
tblVehicleEF MDV 0.23 0.19
tblVehicleEF MDV 0.17 0.19
tblVehicleEF MDV 0.05 0.04
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tblVehicleEF MDV 0.11 0.49
tblVehicleEF MDV 0.23 0.41
tblVehicleEF MDV 0.01 5.4050e-003
tblVehicleEF MDV 0.02 0.09
tblVehicleEF MDV 1.28 1.09
tblVehicleEF MDV 3.20 3.26
tblVehicleEF MDV 473.93 410.75
tblVehicleEF MDV 107.92 87.35
tblVehicleEF MDV 0.16 0.10
tblVehicleEF MDV 0.32 0.38
tblVehicleEF MDV 1.8260e-003 1.6850e-003
tblVehicleEF MDV 2.5170e-003 2.0310e-003
tblVehicleEF MDV 1.6830e-003 1.5540e-003
tblVehicleEF MDV 2.3150e-003 1.8680e-003
tblVehicleEF MDV 0.10 0.11
tblVehicleEF MDV 0.22 0.18
tblVehicleEF MDV 0.08 0.10
tblVehicleEF MDV 0.03 0.02
tblVehicleEF MDV 0.13 0.57
tblVehicleEF MDV 0.25 0.44
tblVehicleEF MDV 4.7490e-003 4.0360e-003
tblVehicleEF MDV 1.1360e-003 8.5900e-004
tblVehicleEF MDV 0.10 0.11
tblVehicleEF MDV 0.22 0.18
tblVehicleEF MDV 0.08 0.10
tblVehicleEF MDV 0.04 0.03
tblVehicleEF MDV 0.13 0.57
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tblVehicleEF MDV 0.27 0.48
tblVehicleEF MH 0.04 3.6580e-003
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 3.07 0.35
tblVehicleEF MH 6.43 0.00
tblVehicleEF MH 1,045.05 970.21
tblVehicleEF MH 59.49 0.00
tblVehicleEF MH 1.54 4.24
tblVehicleEF MH 0.91 0.00
tblVehicleEF MH 0.01 0.02
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.1740e-003 0.00
tblVehicleEF MH 3.2230e-003 4.0000e-003
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.0790e-003 0.00
tblVehicleEF MH 1.47 0.00
tblVehicleEF MH 0.09 0.00
tblVehicleEF MH 0.51 0.00
tblVehicleEF MH 0.10 0.08
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.37 0.00
tblVehicleEF MH 0.01 9.1720e-003
tblVehicleEF MH 7.0700e-004 0.00
tblVehicleEF MH 1.47 0.00
tblVehicleEF MH 0.09 0.00
tblVehicleEF MH 0.51 0.00
tblVehicleEF MH 0.14 0.09
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tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.40 0.00
tblVehicleEF MH 0.04 3.6580e-003
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 3.19 0.35
tblVehicleEF MH 5.84 0.00
tblVehicleEF MH 1,045.05 970.21
tblVehicleEF MH 59.49 0.00
tblVehicleEF MH 1.41 4.00
tblVehicleEF MH 0.86 0.00
tblVehicleEF MH 0.01 0.02
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.1740e-003 0.00
tblVehicleEF MH 3.2230e-003 4.0000e-003
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.0790e-003 0.00
tblVehicleEF MH 2.91 0.00
tblVehicleEF MH 0.11 0.00
tblVehicleEF MH 1.21 0.00
tblVehicleEF MH 0.11 0.08
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.34 0.00
tblVehicleEF MH 0.01 9.1720e-003
tblVehicleEF MH 6.9700e-004 0.00
tblVehicleEF MH 2.91 0.00
tblVehicleEF MH 0.11 0.00
tblVehicleEF MH 1.21 0.00
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tblVehicleEF MH 0.15 0.09
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.38 0.00
tblVehicleEF MH 0.04 3.6580e-003
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 3.08 0.35
tblVehicleEF MH 6.36 0.00
tblVehicleEF MH 1,045.05 970.21
tblVehicleEF MH 59.49 0.00
tblVehicleEF MH 1.51 4.17
tblVehicleEF MH 0.89 0.00
tblVehicleEF MH 0.01 0.02
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.1740e-003 0.00
tblVehicleEF MH 3.2230e-003 4.0000e-003
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.0790e-003 0.00
tblVehicleEF MH 1.75 0.00
tblVehicleEF MH 0.11 0.00
tblVehicleEF MH 0.53 0.00
tblVehicleEF MH 0.10 0.08
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.37 0.00
tblVehicleEF MH 0.01 9.1720e-003
tblVehicleEF MH 7.0600e-004 0.00
tblVehicleEF MH 1.75 0.00
tblVehicleEF MH 0.11 0.00
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tblVehicleEF MH 0.53 0.00
tblVehicleEF MH 0.15 0.09
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.40 0.00
tblVehicleEF MHD 0.02 2.5070e-003
tblVehicleEF MHD 3.5160e-003 3.3210e-003
tblVehicleEF MHD 0.05 6.4670e-003
tblVehicleEF MHD 0.32 0.31
tblVehicleEF MHD 0.27 0.32
tblVehicleEF MHD 5.32 0.74
tblVehicleEF MHD 156.91 68.92
tblVehicleEF MHD 1,101.52 974.57
tblVehicleEF MHD 52.43 6.35
tblVehicleEF MHD 0.60 0.52
tblVehicleEF MHD 0.99 1.61
tblVehicleEF MHD 11.88 1.50
tblVehicleEF MHD 3.8600e-004 1.2310e-003
tblVehicleEF MHD 5.0030e-003 0.04
tblVehicleEF MHD 7.6400e-004 7.5000e-005
tblVehicleEF MHD 3.6900e-004 1.1780e-003
tblVehicleEF MHD 4.7830e-003 0.03
tblVehicleEF MHD 7.0300e-004 6.9000e-005
tblVehicleEF MHD 1.2800e-003 4.5300e-004
tblVehicleEF MHD 0.04 0.01
tblVehicleEF MHD 0.02 0.02
tblVehicleEF MHD 6.5100e-004 2.4000e-004
tblVehicleEF MHD 0.04 0.06
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tblVehicleEF MHD 0.02 0.08
tblVehicleEF MHD 0.32 0.03
tblVehicleEF MHD 1.5080e-003 6.5300e-004
tblVehicleEF MHD 0.01 9.2620e-003
tblVehicleEF MHD 6.1700e-004 6.3000e-005
tblVehicleEF MHD 1.2800e-003 4.5300e-004
tblVehicleEF MHD 0.04 0.01
tblVehicleEF MHD 0.03 0.02
tblVehicleEF MHD 6.5100e-004 2.4000e-004
tblVehicleEF MHD 0.04 0.07
tblVehicleEF MHD 0.02 0.08
tblVehicleEF MHD 0.35 0.04
tblVehicleEF MHD 0.02 2.3860e-003
tblVehicleEF MHD 3.5800e-003 3.3450e-003
tblVehicleEF MHD 0.05 6.2100e-003
tblVehicleEF MHD 0.24 0.26
tblVehicleEF MHD 0.28 0.33
tblVehicleEF MHD 4.97 0.70
tblVehicleEF MHD 166.20 69.59
tblVehicleEF MHD 1,101.52 974.58
tblVehicleEF MHD 52.43 6.28
tblVehicleEF MHD 0.62 0.52
tblVehicleEF MHD 0.92 1.52
tblVehicleEF MHD 11.85 1.49
tblVehicleEF MHD 3.2500e-004 1.0410e-003
tblVehicleEF MHD 5.0030e-003 0.04
tblVehicleEF MHD 7.6400e-004 7.5000e-005
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tblVehicleEF MHD 3.1100e-004 9.9600e-004
tblVehicleEF MHD 4.7830e-003 0.03
tblVehicleEF MHD 7.0300e-004 6.9000e-005
tblVehicleEF MHD 2.5300e-003 8.2800e-004
tblVehicleEF MHD 0.05 0.02
tblVehicleEF MHD 0.02 0.02
tblVehicleEF MHD 1.5010e-003 4.7800e-004
tblVehicleEF MHD 0.04 0.06
tblVehicleEF MHD 0.02 0.08
tblVehicleEF MHD 0.30 0.03
tblVehicleEF MHD 1.5950e-003 6.5900e-004
tblVehicleEF MHD 0.01 9.2620e-003
tblVehicleEF MHD 6.1100e-004 6.2000e-005
tblVehicleEF MHD 2.5300e-003 8.2800e-004
tblVehicleEF MHD 0.05 0.02
tblVehicleEF MHD 0.03 0.02
tblVehicleEF MHD 1.5010e-003 4.7800e-004
tblVehicleEF MHD 0.04 0.07
tblVehicleEF MHD 0.02 0.08
tblVehicleEF MHD 0.33 0.04
tblVehicleEF MHD 0.02 2.6830e-003
tblVehicleEF MHD 3.5220e-003 3.3210e-003
tblVehicleEF MHD 0.05 6.4200e-003
tblVehicleEF MHD 0.45 0.37
tblVehicleEF MHD 0.27 0.32
tblVehicleEF MHD 5.23 0.74
tblVehicleEF MHD 144.06 68.00
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tblVehicleEF MHD 1,101.52 974.57
tblVehicleEF MHD 52.43 6.34
tblVehicleEF MHD 0.57 0.52
tblVehicleEF MHD 0.97 1.59
tblVehicleEF MHD 11.87 1.50
tblVehicleEF MHD 4.7000e-004 1.4940e-003
tblVehicleEF MHD 5.0030e-003 0.04
tblVehicleEF MHD 7.6400e-004 7.5000e-005
tblVehicleEF MHD 4.4900e-004 1.4300e-003
tblVehicleEF MHD 4.7830e-003 0.03
tblVehicleEF MHD 7.0300e-004 6.9000e-005
tblVehicleEF MHD 1.3890e-003 4.7100e-004
tblVehicleEF MHD 0.05 0.02
tblVehicleEF MHD 0.03 0.02
tblVehicleEF MHD 6.4000e-004 2.4400e-004
tblVehicleEF MHD 0.04 0.06
tblVehicleEF MHD 0.02 0.09
tblVehicleEF MHD 0.32 0.03
tblVehicleEF MHD 1.3860e-003 6.4400e-004
tblVehicleEF MHD 0.01 9.2620e-003
tblVehicleEF MHD 6.1600e-004 6.3000e-005
tblVehicleEF MHD 1.3890e-003 4.7100e-004
tblVehicleEF MHD 0.05 0.02
tblVehicleEF MHD 0.04 0.02
tblVehicleEF MHD 6.4000e-004 2.4400e-004
tblVehicleEF MHD 0.04 0.07
tblVehicleEF MHD 0.02 0.09
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tblVehicleEF MHD 0.35 0.04
tblVehicleEF OBUS 0.01 8.8190e-003
tblVehicleEF OBUS 9.9110e-003 6.5960e-003
tblVehicleEF OBUS 0.03 0.02
tblVehicleEF OBUS 0.26 0.52
tblVehicleEF OBUS 0.63 0.77
tblVehicleEF OBUS 6.27 2.45
tblVehicleEF OBUS 70.35 76.06
tblVehicleEF OBUS 1,121.50 1,406.90
tblVehicleEF OBUS 70.70 20.49
tblVehicleEF OBUS 0.28 0.34
tblVehicleEF OBUS 0.97 1.24
tblVehicleEF OBUS 1.93 0.68
tblVehicleEF OBUS 6.4000e-005 5.8900e-004
tblVehicleEF OBUS 4.6440e-003 0.01
tblVehicleEF OBUS 9.2900e-004 2.1800e-004
tblVehicleEF OBUS 6.1000e-005 5.6400e-004
tblVehicleEF OBUS 4.4220e-003 0.01
tblVehicleEF OBUS 8.5400e-004 2.0100e-004
tblVehicleEF OBUS 2.1800e-003 2.6020e-003
tblVehicleEF OBUS 0.02 0.02
tblVehicleEF OBUS 0.04 0.05
tblVehicleEF OBUS 9.3100e-004 1.1160e-003
tblVehicleEF OBUS 0.04 0.05
tblVehicleEF OBUS 0.05 0.29
tblVehicleEF OBUS 0.38 0.12
tblVehicleEF OBUS 6.8400e-004 7.2500e-004
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tblVehicleEF OBUS 0.01 0.01
tblVehicleEF OBUS 8.1700e-004 2.0300e-004
tblVehicleEF OBUS 2.1800e-003 2.6020e-003
tblVehicleEF OBUS 0.02 0.02
tblVehicleEF OBUS 0.05 0.07
tblVehicleEF OBUS 9.3100e-004 1.1160e-003
tblVehicleEF OBUS 0.06 0.07
tblVehicleEF OBUS 0.05 0.29
tblVehicleEF OBUS 0.42 0.13
tblVehicleEF OBUS 0.01 8.8750e-003
tblVehicleEF OBUS 0.01 6.7350e-003
tblVehicleEF OBUS 0.03 0.02
tblVehicleEF OBUS 0.26 0.51
tblVehicleEF OBUS 0.65 0.79
tblVehicleEF OBUS 5.74 2.28
tblVehicleEF OBUS 73.50 75.90
tblVehicleEF OBUS 1,121.50 1,406.93
tblVehicleEF OBUS 70.70 20.20
tblVehicleEF OBUS 0.29 0.34
tblVehicleEF OBUS 0.90 1.16
tblVehicleEF OBUS 1.88 0.67
tblVehicleEF OBUS 5.4000e-005 5.0100e-004
tblVehicleEF OBUS 4.6440e-003 0.01
tblVehicleEF OBUS 9.2900e-004 2.1800e-004
tblVehicleEF OBUS 5.1000e-005 4.7900e-004
tblVehicleEF OBUS 4.4220e-003 0.01
tblVehicleEF OBUS 8.5400e-004 2.0100e-004
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tblVehicleEF OBUS 4.2350e-003 4.6860e-003
tblVehicleEF OBUS 0.02 0.03
tblVehicleEF OBUS 0.03 0.05
tblVehicleEF OBUS 2.1330e-003 2.2090e-003
tblVehicleEF OBUS 0.05 0.05
tblVehicleEF OBUS 0.05 0.29
tblVehicleEF OBUS 0.36 0.11
tblVehicleEF OBUS 7.1400e-004 7.2400e-004
tblVehicleEF OBUS 0.01 0.01
tblVehicleEF OBUS 8.0800e-004 2.0000e-004
tblVehicleEF OBUS 4.2350e-003 4.6860e-003
tblVehicleEF OBUS 0.02 0.03
tblVehicleEF OBUS 0.05 0.07
tblVehicleEF OBUS 2.1330e-003 2.2090e-003
tblVehicleEF OBUS 0.06 0.07
tblVehicleEF OBUS 0.05 0.29
tblVehicleEF OBUS 0.40 0.12
tblVehicleEF OBUS 0.01 8.7740e-003
tblVehicleEF OBUS 9.9380e-003 6.6000e-003
tblVehicleEF OBUS 0.03 0.02
tblVehicleEF OBUS 0.28 0.53
tblVehicleEF OBUS 0.63 0.77
tblVehicleEF OBUS 6.22 2.45
tblVehicleEF OBUS 66.00 76.30
tblVehicleEF OBUS 1,121.50 1,406.90
tblVehicleEF OBUS 70.70 20.50
tblVehicleEF OBUS 0.27 0.35
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tblVehicleEF OBUS 0.96 1.22
tblVehicleEF OBUS 1.91 0.68
tblVehicleEF OBUS 7.7000e-005 7.1200e-004
tblVehicleEF OBUS 4.6440e-003 0.01
tblVehicleEF OBUS 9.2900e-004 2.1800e-004
tblVehicleEF OBUS 7.4000e-005 6.8100e-004
tblVehicleEF OBUS 4.4220e-003 0.01
tblVehicleEF OBUS 8.5400e-004 2.0100e-004
tblVehicleEF OBUS 2.3200e-003 2.7390e-003
tblVehicleEF OBUS 0.02 0.03
tblVehicleEF OBUS 0.04 0.05
tblVehicleEF OBUS 9.4100e-004 1.1650e-003
tblVehicleEF OBUS 0.04 0.05
tblVehicleEF OBUS 0.05 0.30
tblVehicleEF OBUS 0.38 0.12
tblVehicleEF OBUS 6.4200e-004 7.2700e-004
tblVehicleEF OBUS 0.01 0.01
tblVehicleEF OBUS 8.1600e-004 2.0300e-004
tblVehicleEF OBUS 2.3200e-003 2.7390e-003
tblVehicleEF OBUS 0.02 0.03
tblVehicleEF OBUS 0.05 0.07
tblVehicleEF OBUS 9.4100e-004 1.1650e-003
tblVehicleEF OBUS 0.06 0.07
tblVehicleEF OBUS 0.05 0.30
tblVehicleEF OBUS 0.42 0.13
tblVehicleEF SBUS 0.84 0.06
tblVehicleEF SBUS 0.01 8.5840e-003
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tblVehicleEF SBUS 0.07 6.1570e-003
tblVehicleEF SBUS 5.71 2.50
tblVehicleEF SBUS 0.65 0.78
tblVehicleEF SBUS 5.33 0.82
tblVehicleEF SBUS 1,258.13 345.06
tblVehicleEF SBUS 1,136.31 1,112.17
tblVehicleEF SBUS 37.11 4.79
tblVehicleEF SBUS 11.70 3.29
tblVehicleEF SBUS 4.77 5.20
tblVehicleEF SBUS 15.02 0.91
tblVehicleEF SBUS 0.01 4.3580e-003
tblVehicleEF SBUS 0.01 0.01
tblVehicleEF SBUS 0.03 0.03
tblVehicleEF SBUS 5.1700e-004 4.0000e-005
tblVehicleEF SBUS 0.01 4.1690e-003
tblVehicleEF SBUS 2.7560e-003 2.7010e-003
tblVehicleEF SBUS 0.03 0.03
tblVehicleEF SBUS 4.7500e-004 3.6000e-005
tblVehicleEF SBUS 2.9260e-003 1.2420e-003
tblVehicleEF SBUS 0.02 9.5120e-003
tblVehicleEF SBUS 0.68 0.28
tblVehicleEF SBUS 1.3050e-003 5.9000e-004
tblVehicleEF SBUS 0.11 0.11
tblVehicleEF SBUS 9.3510e-003 0.06
tblVehicleEF SBUS 0.27 0.04
tblVehicleEF SBUS 0.01 3.2890e-003
tblVehicleEF SBUS 0.01 0.01
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tblVehicleEF SBUS 4.6300e-004 4.7000e-005
tblVehicleEF SBUS 2.9260e-003 1.2420e-003
tblVehicleEF SBUS 0.02 9.5120e-003
tblVehicleEF SBUS 0.97 0.40
tblVehicleEF SBUS 1.3050e-003 5.9000e-004
tblVehicleEF SBUS 0.13 0.13
tblVehicleEF SBUS 9.3510e-003 0.06
tblVehicleEF SBUS 0.30 0.04
tblVehicleEF SBUS 0.84 0.06
tblVehicleEF SBUS 0.01 8.7140e-003
tblVehicleEF SBUS 0.06 5.1550e-003
tblVehicleEF SBUS 5.56 2.47
tblVehicleEF SBUS 0.66 0.80
tblVehicleEF SBUS 3.65 0.60
tblVehicleEF SBUS 1,322.00 352.98
tblVehicleEF SBUS 1,136.31 1,112.20
tblVehicleEF SBUS 37.11 4.41
tblVehicleEF SBUS 12.08 3.36
tblVehicleEF SBUS 4.47 4.88
tblVehicleEF SBUS 14.99 0.90
tblVehicleEF SBUS 0.01 3.6810e-003
tblVehicleEF SBUS 0.01 0.01
tblVehicleEF SBUS 0.03 0.03
tblVehicleEF SBUS 5.1700e-004 4.0000e-005
tblVehicleEF SBUS 9.6490e-003 3.5220e-003
tblVehicleEF SBUS 2.7560e-003 2.7010e-003
tblVehicleEF SBUS 0.03 0.03
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tblVehicleEF SBUS 4.7500e-004 3.6000e-005
tblVehicleEF SBUS 5.6170e-003 2.2080e-003
tblVehicleEF SBUS 0.02 9.9850e-003
tblVehicleEF SBUS 0.67 0.28
tblVehicleEF SBUS 2.8800e-003 1.1130e-003
tblVehicleEF SBUS 0.11 0.11
tblVehicleEF SBUS 8.5310e-003 0.06
tblVehicleEF SBUS 0.22 0.03
tblVehicleEF SBUS 0.01 3.3630e-003
tblVehicleEF SBUS 0.01 0.01
tblVehicleEF SBUS 4.3500e-004 4.4000e-005
tblVehicleEF SBUS 5.6170e-003 2.2080e-003
tblVehicleEF SBUS 0.02 9.9850e-003
tblVehicleEF SBUS 0.97 0.40
tblVehicleEF SBUS 2.8800e-003 1.1130e-003
tblVehicleEF SBUS 0.13 0.13
tblVehicleEF SBUS 8.5310e-003 0.06
tblVehicleEF SBUS 0.24 0.03
tblVehicleEF SBUS 0.84 0.06
tblVehicleEF SBUS 0.01 8.5760e-003
tblVehicleEF SBUS 0.07 6.3440e-003
tblVehicleEF SBUS 5.91 2.56
tblVehicleEF SBUS 0.65 0.78
tblVehicleEF SBUS 5.37 0.86
tblVehicleEF SBUS 1,169.92 334.13
tblVehicleEF SBUS 1,136.31 1,112.17
tblVehicleEF SBUS 37.11 4.85
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tblVehicleEF SBUS 11.19 3.19
tblVehicleEF SBUS 4.69 5.12
tblVehicleEF SBUS 15.02 0.91
tblVehicleEF SBUS 0.01 5.2920e-003
tblVehicleEF SBUS 0.01 0.01
tblVehicleEF SBUS 0.03 0.03
tblVehicleEF SBUS 5.1700e-004 4.0000e-005
tblVehicleEF SBUS 0.01 5.0630e-003
tblVehicleEF SBUS 2.7560e-003 2.7010e-003
tblVehicleEF SBUS 0.03 0.03
tblVehicleEF SBUS 4.7500e-004 3.6000e-005
tblVehicleEF SBUS 2.9580e-003 1.2070e-003
tblVehicleEF SBUS 0.02 0.01
tblVehicleEF SBUS 0.68 0.28
tblVehicleEF SBUS 1.2820e-003 6.0100e-004
tblVehicleEF SBUS 0.11 0.11
tblVehicleEF SBUS 0.01 0.08
tblVehicleEF SBUS 0.28 0.04
tblVehicleEF SBUS 0.01 3.1850e-003
tblVehicleEF SBUS 0.01 0.01
tblVehicleEF SBUS 4.6400e-004 4.8000e-005
tblVehicleEF SBUS 2.9580e-003 1.2070e-003
tblVehicleEF SBUS 0.02 0.01
tblVehicleEF SBUS 0.98 0.40
tblVehicleEF SBUS 1.2820e-003 6.0100e-004
tblVehicleEF SBUS 0.13 0.13
tblVehicleEF SBUS 0.01 0.08
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tblVehicleEF SBUS 0.31 0.04
tblVehicleEF UBUS 1.83 4.45
tblVehicleEF UBUS 0.08 0.01
tblVehicleEF UBUS 9.26 34.75
tblVehicleEF UBUS 14.34 0.89
tblVehicleEF UBUS 1,846.39 1,692.13
tblVehicleEF UBUS 136.37 11.77
tblVehicleEF UBUS 5.87 0.38
tblVehicleEF UBUS 13.57 0.14
tblVehicleEF UBUS 0.52 0.07
tblVehicleEF UBUS 0.01 0.03
tblVehicleEF UBUS 0.07 2.6550e-003
tblVehicleEF UBUS 1.4030e-003 1.4100e-004
tblVehicleEF UBUS 0.22 0.03
tblVehicleEF UBUS 3.0000e-003 6.6220e-003
tblVehicleEF UBUS 0.06 2.5280e-003
tblVehicleEF UBUS 1.2900e-003 1.3000e-004
tblVehicleEF UBUS 8.0860e-003 1.6780e-003
tblVehicleEF UBUS 0.11 9.5390e-003
tblVehicleEF UBUS 3.9450e-003 7.3700e-004
tblVehicleEF UBUS 0.61 0.07
tblVehicleEF UBUS 0.02 0.04
tblVehicleEF UBUS 1.15 0.04
tblVehicleEF UBUS 0.01 3.0250e-003
tblVehicleEF UBUS 1.6240e-003 1.1700e-004
tblVehicleEF UBUS 8.0860e-003 1.6780e-003
tblVehicleEF UBUS 0.11 9.5390e-003
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tblVehicleEF UBUS 3.9450e-003 7.3700e-004
tblVehicleEF UBUS 2.50 4.54
tblVehicleEF UBUS 0.02 0.04
tblVehicleEF UBUS 1.25 0.04
tblVehicleEF UBUS 1.83 4.45
tblVehicleEF UBUS 0.08 9.2350e-003
tblVehicleEF UBUS 9.36 34.75
tblVehicleEF UBUS 11.74 0.76
tblVehicleEF UBUS 1,846.39 1,692.13
tblVehicleEF UBUS 136.37 11.55
tblVehicleEF UBUS 5.45 0.38
tblVehicleEF UBUS 13.45 0.13
tblVehicleEF UBUS 0.52 0.07
tblVehicleEF UBUS 0.01 0.03
tblVehicleEF UBUS 0.07 2.6550e-003
tblVehicleEF UBUS 1.4030e-003 1.4100e-004
tblVehicleEF UBUS 0.22 0.03
tblVehicleEF UBUS 3.0000e-003 6.6220e-003
tblVehicleEF UBUS 0.06 2.5280e-003
tblVehicleEF UBUS 1.2900e-003 1.3000e-004
tblVehicleEF UBUS 0.02 3.0610e-003
tblVehicleEF UBUS 0.14 0.01
tblVehicleEF UBUS 9.3320e-003 1.4840e-003
tblVehicleEF UBUS 0.62 0.07
tblVehicleEF UBUS 0.02 0.04
tblVehicleEF UBUS 1.02 0.03
tblVehicleEF UBUS 0.01 3.0250e-003
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tblVehicleEF UBUS 1.5790e-003 1.1400e-004
tblVehicleEF UBUS 0.02 3.0610e-003
tblVehicleEF UBUS 0.14 0.01
tblVehicleEF UBUS 9.3320e-003 1.4840e-003
tblVehicleEF UBUS 2.52 4.54
tblVehicleEF UBUS 0.02 0.04
tblVehicleEF UBUS 1.12 0.04
tblVehicleEF UBUS 1.83 4.45
tblVehicleEF UBUS 0.08 0.01
tblVehicleEF UBUS 9.27 34.75
tblVehicleEF UBUS 13.86 0.90
tblVehicleEF UBUS 1,846.39 1,692.13
tblVehicleEF UBUS 136.37 11.80
tblVehicleEF UBUS 5.76 0.38
tblVehicleEF UBUS 13.55 0.14
tblVehicleEF UBUS 0.52 0.07
tblVehicleEF UBUS 0.01 0.03
tblVehicleEF UBUS 0.07 2.6550e-003
tblVehicleEF UBUS 1.4030e-003 1.4100e-004
tblVehicleEF UBUS 0.22 0.03
tblVehicleEF UBUS 3.0000e-003 6.6220e-003
tblVehicleEF UBUS 0.06 2.5280e-003
tblVehicleEF UBUS 1.2900e-003 1.3000e-004
tblVehicleEF UBUS 9.2250e-003 1.6870e-003
tblVehicleEF UBUS 0.14 0.01
tblVehicleEF UBUS 4.1190e-003 7.4500e-004
tblVehicleEF UBUS 0.61 0.07
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tblVehicleEF UBUS 0.03 0.05
tblVehicleEF UBUS 1.13 0.04
tblVehicleEF UBUS 0.01 3.0250e-003
tblVehicleEF UBUS 1.6160e-003 1.1700e-004
tblVehicleEF UBUS 9.2250e-003 1.6870e-003
tblVehicleEF UBUS 0.14 0.01
tblVehicleEF UBUS 4.1190e-003 7.4500e-004
tblVehicleEF UBUS 2.50 4.54
tblVehicleEF UBUS 0.03 0.05
tblVehicleEF UBUS 1.24 0.04
tblVehicleTrips CC_TL 8.40 0.00
tblVehicleTrips CC_TL 8.40 0.00
tblVehicleTrips CC_TL 8.40 0.00
tblVehicleTrips CC_TL 8.40 0.00
tblVehicleTrips CC_TL 8.40 0.00
tblVehicleTrips CNW_TL 6.90 0.00
tblVehicleTrips CNW_TL 6.90 0.00
tblVehicleTrips CNW_TL 6.90 0.00
tblVehicleTrips CNW_TL 6.90 0.00
tblVehicleTrips CNW_TL 6.90 0.00
tblVehicleTrips CNW_TTP 41.00 0.00
tblVehicleTrips CNW_TTP 41.00 0.00
tblVehicleTrips CW_TL 16.60 0.00
tblVehicleTrips CW_TL 16.60 0.00
tblVehicleTrips CW_TL 16.60 0.00
tblVehicleTrips CW_TL 16.60 0.00
tblVehicleTrips CW_TL 16.60 0.00
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2.0 Emissions Summary
tblVehicleTrips CW_TTP 59.00 0.00
tblVehicleTrips CW_TTP 59.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 92.00 0.00
tblVehicleTrips PR_TP 92.00 0.00
tblVehicleTrips ST_TR 1.68 0.00
tblVehicleTrips ST_TR 1.68 0.00
tblVehicleTrips SU_TR 1.68 0.00
tblVehicleTrips SU_TR 1.68 0.00
tblVehicleTrips WD_TR 1.68 0.00
tblVehicleTrips WD_TR 1.68 0.00
tblWater IndoorWaterUseRate 88,927,187.50 0.00
tblWater IndoorWaterUseRate 177,854,375.00 0.00
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2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 0.0351 1.8659 0.1715 2.8800e-
003
0.0227 7.5000e-
004
0.0235 4.4000e-
003
7.2000e-
004
5.1200e-
003
0.0000 304.8999 304.8999 0.0478 0.0000 306.0955
Maximum 0.0351 1.8659 0.1715 2.8800e-
003
0.0227 7.5000e-
004
0.0235 4.4000e-
003
7.2000e-
004
5.1200e-
003
0.0000 304.8999 304.8999 0.0478 0.0000 306.0955
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 0.0351 1.8659 0.1715 2.8800e-
003
0.0135 7.5000e-
004
0.0143 3.0100e-
003
7.2000e-
004
3.7300e-
003
0.0000 304.8999 304.8999 0.0478 0.0000 306.0955
Maximum 0.0351 1.8659 0.1715 2.8800e-
003
0.0135 7.5000e-
004
0.0143 3.0100e-
003
7.2000e-
004
3.7300e-
003
0.0000 304.8999 304.8999 0.0478 0.0000 306.0955
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 40.49 0.00 39.20 31.59 0.00 27.15 0.00 0.00 0.00 0.00 0.00 0.00
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2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 26.2951 2.6000e-
003
0.2842 2.0000e-
005
0.0000 1.0200e-
003
1.0200e-
003
0.0000 1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.0000 0.6485
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 26.2951 2.6000e-
003
0.2842 2.0000e-
005
0.0000 1.0200e-
003
1.0200e-
003
0.0000 1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.0000 0.6485
Mitigated Operational
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Summer
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Site Preparation/Grading Grading 5/1/2021 7/23/2021 5 60
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Site Preparation/Grading Crawler Tractors 0 8.00 212 0.43
Site Preparation/Grading Excavators 0 8.00 158 0.38
Site Preparation/Grading Graders 0 8.00 187 0.41
Site Preparation/Grading Off-Highway Trucks 0 8.00 402 0.38
Site Preparation/Grading Rubber Tired Dozers 0 8.00 247 0.40
Site Preparation/Grading Scrapers 0 8.00 367 0.48
Site Preparation/Grading Tractors/Loaders/Backhoes 0 8.00 97 0.37
Trips and VMT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 26.48
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3.2 Site Preparation/Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.0151 0.0000 0.0151 2.2800e-
003
0.0000 2.2800e-
003
0.0000 0.0000
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0151 0.0000 0.0151 2.2800e-
003
0.0000 2.2800e-
003
0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
3.1 Mitigation Measures Construction
Use Cleaner Engines for Construction Equipment
Water Exposed Area
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Site
Preparation/Grading
0 0.00 0.00 1,000.00 14.70 6.90 0.50 LD_Mix HDT_Mix HHDT
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3.2 Site Preparation/Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0351 1.8659 0.1715 2.8800e-
003
7.6400e-
003
7.5000e-
004
8.3900e-
003
2.1200e-
003
7.2000e-
004
2.8400e-
003
304.8999 304.8999 0.0478 306.0955
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0351 1.8659 0.1715 2.8800e-
003
7.6400e-
003
7.5000e-
004
8.3900e-
003
2.1200e-
003
7.2000e-
004
2.8400e-
003
304.8999 304.8999 0.0478 306.0955
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 5.8800e-
003
0.0000 5.8800e-
003
8.9000e-
004
0.0000 8.9000e-
004
0.0000 0.0000
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 5.8800e-
003
0.0000 5.8800e-
003
8.9000e-
004
0.0000 8.9000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
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4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
3.2 Site Preparation/Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0351 1.8659 0.1715 2.8800e-
003
7.6400e-
003
7.5000e-
004
8.3900e-
003
2.1200e-
003
7.2000e-
004
2.8400e-
003
304.8999 304.8999 0.0478 306.0955
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0351 1.8659 0.1715 2.8800e-
003
7.6400e-
003
7.5000e-
004
8.3900e-
003
2.1200e-
003
7.2000e-
004
2.8400e-
003
304.8999 304.8999 0.0478 306.0955
Mitigated Construction Off-Site
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Other Asphalt Surfaces 0.00 0.00 0.00
Other Non-Asphalt Surfaces 0.00 0.00 0.00
Parking Lot 0.00 0.00 0.00
Refrigerated Warehouse-No Rail 0.00 0.00 0.00
Unrefrigerated Warehouse-No Rail 0.00 0.00 0.00
Total 0.00 0.00 0.00
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Other Asphalt Surfaces 0.00 0.00 0.00 0.00 0.00 0.00 0 0 0
Other Non-Asphalt Surfaces 0.00 0.00 0.00 0.00 0.00 0.00 0 0 0
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0 0 0
Refrigerated Warehouse-No
Rail
0.00 0.00 0.00 0.00 0.00 0.00 0 0 0
Unrefrigerated Warehouse-No
Rail
0.00 0.00 0.00 0.00 0.00 0.00 0 0 0
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5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
NaturalGas
Unmitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
5.1 Mitigation Measures Energy
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Other Asphalt Surfaces 0.553113 0.036408 0.180286 0.116335 0.016165 0.005101 0.018218 0.063797 0.001357 0.001565 0.005903 0.000808 0.000944
Other Non-Asphalt Surfaces 0.553113 0.036408 0.180286 0.116335 0.016165 0.005101 0.018218 0.063797 0.001357 0.001565 0.005903 0.000808 0.000944
Parking Lot 0.553113 0.036408 0.180286 0.116335 0.016165 0.005101 0.018218 0.063797 0.001357 0.001565 0.005903 0.000808 0.000944
Refrigerated Warehouse-No Rail 0.553113 0.036408 0.180286 0.116335 0.016165 0.005101 0.018218 0.063797 0.001357 0.001565 0.005903 0.000808 0.000944
Unrefrigerated Warehouse-No
Rail
0.553113 0.036408 0.180286 0.116335 0.016165 0.005101 0.018218 0.063797 0.001357 0.001565 0.005903 0.000808 0.000944
Historical Energy Use: N
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5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Refrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Summer
6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Refrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Summer
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Unmitigated 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
3.0179 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
23.2508 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0264 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Total 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Unmitigated
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Summer
8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
3.0179 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
23.2508 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0264 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Total 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Summer
11.0 Vegetation
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Summer
1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population
Refrigerated Warehouse-No Rail 384.55 1000sqft 8.83 384,548.00 0
Unrefrigerated Warehouse-No Rail 769.10 1000sqft 17.66 769,096.00 0
Other Asphalt Surfaces 791.77 1000sqft 18.18 791,767.00 0
Other Non-Asphalt Surfaces 47.22 1000sqft 1.08 47,220.00 0
Parking Lot 787.00 Space 7.22 314,800.00 0
1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
10
Wind Speed (m/s)Precipitation Freq (Days)2.2 32
1.3 User Entered Comments & Non-Default Data
1.0 Project Characteristics
Utility Company Southern California Edison
2022Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)
0.006N2O Intensity
(lb/MWhr)
The Landing by San Manuel (Construction - Hauling Activity)
San Bernardino-South Coast County, Winter
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
Project Characteristics -
Land Use - Total Project Area is 52.97 acres.
Construction Phase - Construction schedule based on information provided by the Project Applicant.
Off-road Equipment - Hours are based on an 8-hour workday.
Off-road Equipment - Construction equipment based on information provided by the Project Applicant. Water Trucks modeled as "Off-Highway Trucks".
Trips and VMT - Tips will be to SBIA, approximately 0.5 miles south of the Project site.
Grading - It is anticipated that 10 acres will be disturbed per day during Site Preparation/Graading activities.
Architectural Coating - Rule 1113
Vehicle Trips - Construction Run Only.
Vehicle Emission Factors - EMFAC2017
Vehicle Emission Factors - EMFAC2017
Vehicle Emission Factors - EMFAC2017
Road Dust -
Consumer Products -
Area Coating -
Energy Use - Construction Run Only.
Water And Wastewater - Construction Run Only.
Solid Waste - Construction Run Only.
Construction Off-road Equipment Mitigation - All equipment operating at >150 HP during Site Preparation/Grading activities are required to be equipped with Tier
3 engines.
Table Name Column Name Default Value New Value
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 1.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 2.00
tblConstEquipMitigation NumberOfEquipmentMitigated 0.00 8.00
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblConstEquipMitigation Tier No Change Tier 3
tblConstEquipMitigation Tier No Change Tier 3
tblConstEquipMitigation Tier No Change Tier 3
tblConstEquipMitigation Tier No Change Tier 3
tblConstEquipMitigation Tier No Change Tier 3
tblConstEquipMitigation Tier No Change Tier 3
tblConstructionPhase NumDays 110.00 60.00
tblEnergyUse LightingElect 0.35 0.00
tblEnergyUse LightingElect 2.37 0.00
tblEnergyUse LightingElect 1.17 0.00
tblEnergyUse NT24E 36.52 0.00
tblEnergyUse NT24E 0.82 0.00
tblEnergyUse NT24NG 48.51 0.00
tblEnergyUse NT24NG 0.03 0.00
tblEnergyUse T24E 1.06 0.00
tblEnergyUse T24E 0.37 0.00
tblEnergyUse T24NG 3.25 0.00
tblEnergyUse T24NG 2.00 0.00
tblGrading MaterialImported 0.00 8,000.00
tblLandUse LotAcreage 7.08 7.22
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 1.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblOffRoadEquipment OffRoadEquipmentUnitAmount 2.00 0.00
tblSolidWaste SolidWasteGenerationRate 361.48 0.00
tblSolidWaste SolidWasteGenerationRate 722.95 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 3 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblTripsAndVMT HaulingTripLength 20.00 0.50
tblVehicleEF HHD 1.21 0.03
tblVehicleEF HHD 0.04 0.14
tblVehicleEF HHD 0.10 0.00
tblVehicleEF HHD 3.29 5.95
tblVehicleEF HHD 0.57 0.67
tblVehicleEF HHD 1.82 3.7880e-003
tblVehicleEF HHD 6,933.41 1,124.17
tblVehicleEF HHD 1,475.79 1,484.27
tblVehicleEF HHD 5.54 0.03
tblVehicleEF HHD 26.50 6.08
tblVehicleEF HHD 2.50 3.42
tblVehicleEF HHD 20.21 2.10
tblVehicleEF HHD 9.7780e-003 3.6280e-003
tblVehicleEF HHD 0.06 0.06
tblVehicleEF HHD 0.04 0.04
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 5.1000e-005 1.0000e-006
tblVehicleEF HHD 9.3550e-003 3.4710e-003
tblVehicleEF HHD 0.03 0.03
tblVehicleEF HHD 8.8810e-003 8.8310e-003
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 4.7000e-005 1.0000e-006
tblVehicleEF HHD 8.5000e-005 5.0000e-006
tblVehicleEF HHD 3.1910e-003 1.6000e-004
tblVehicleEF HHD 0.84 0.43
tblVehicleEF HHD 5.2000e-005 3.0000e-006
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 4 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF HHD 0.08 0.08
tblVehicleEF HHD 2.1700e-004 7.9100e-004
tblVehicleEF HHD 0.05 1.0000e-006
tblVehicleEF HHD 0.07 0.01
tblVehicleEF HHD 0.01 0.01
tblVehicleEF HHD 8.6000e-005 0.00
tblVehicleEF HHD 8.5000e-005 5.0000e-006
tblVehicleEF HHD 3.1910e-003 1.6000e-004
tblVehicleEF HHD 0.97 0.50
tblVehicleEF HHD 5.2000e-005 3.0000e-006
tblVehicleEF HHD 0.13 0.23
tblVehicleEF HHD 2.1700e-004 7.9100e-004
tblVehicleEF HHD 0.06 1.0000e-006
tblVehicleEF HHD 1.14 0.03
tblVehicleEF HHD 0.04 0.14
tblVehicleEF HHD 0.09 0.00
tblVehicleEF HHD 2.39 5.82
tblVehicleEF HHD 0.57 0.67
tblVehicleEF HHD 1.70 3.5770e-003
tblVehicleEF HHD 7,345.18 1,121.04
tblVehicleEF HHD 1,475.79 1,484.27
tblVehicleEF HHD 5.54 0.03
tblVehicleEF HHD 27.35 5.90
tblVehicleEF HHD 2.36 3.23
tblVehicleEF HHD 20.20 2.10
tblVehicleEF HHD 8.2750e-003 3.1750e-003
tblVehicleEF HHD 0.06 0.06
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 5 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF HHD 0.04 0.04
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 5.1000e-005 1.0000e-006
tblVehicleEF HHD 7.9170e-003 3.0380e-003
tblVehicleEF HHD 0.03 0.03
tblVehicleEF HHD 8.8810e-003 8.8310e-003
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 4.7000e-005 1.0000e-006
tblVehicleEF HHD 1.6800e-004 1.0000e-005
tblVehicleEF HHD 3.5970e-003 1.8200e-004
tblVehicleEF HHD 0.79 0.45
tblVehicleEF HHD 1.1700e-004 7.0000e-006
tblVehicleEF HHD 0.08 0.08
tblVehicleEF HHD 2.2100e-004 8.1200e-004
tblVehicleEF HHD 0.05 1.0000e-006
tblVehicleEF HHD 0.07 0.01
tblVehicleEF HHD 0.01 0.01
tblVehicleEF HHD 8.4000e-005 0.00
tblVehicleEF HHD 1.6800e-004 1.0000e-005
tblVehicleEF HHD 3.5970e-003 1.8200e-004
tblVehicleEF HHD 0.91 0.52
tblVehicleEF HHD 1.1700e-004 7.0000e-006
tblVehicleEF HHD 0.13 0.23
tblVehicleEF HHD 2.2100e-004 8.1200e-004
tblVehicleEF HHD 0.06 1.0000e-006
tblVehicleEF HHD 1.31 0.02
tblVehicleEF HHD 0.04 3.3680e-003
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 6 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF HHD 0.10 0.00
tblVehicleEF HHD 4.53 5.98
tblVehicleEF HHD 0.57 0.33
tblVehicleEF HHD 1.79 3.7590e-003
tblVehicleEF HHD 6,364.76 1,097.48
tblVehicleEF HHD 1,475.79 1,393.36
tblVehicleEF HHD 5.54 0.03
tblVehicleEF HHD 25.32 6.13
tblVehicleEF HHD 2.46 3.28
tblVehicleEF HHD 20.20 2.10
tblVehicleEF HHD 0.01 3.8650e-003
tblVehicleEF HHD 0.06 0.06
tblVehicleEF HHD 0.04 0.03
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 5.1000e-005 1.0000e-006
tblVehicleEF HHD 0.01 3.6980e-003
tblVehicleEF HHD 0.03 0.03
tblVehicleEF HHD 8.8810e-003 8.6000e-003
tblVehicleEF HHD 0.01 0.03
tblVehicleEF HHD 4.7000e-005 1.0000e-006
tblVehicleEF HHD 8.5000e-005 5.0000e-006
tblVehicleEF HHD 3.4760e-003 1.8700e-004
tblVehicleEF HHD 0.91 0.40
tblVehicleEF HHD 5.2000e-005 3.0000e-006
tblVehicleEF HHD 0.08 0.07
tblVehicleEF HHD 2.3300e-004 8.2900e-004
tblVehicleEF HHD 0.05 1.0000e-006
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 7 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF HHD 0.06 0.01
tblVehicleEF HHD 0.01 0.01
tblVehicleEF HHD 8.5000e-005 0.00
tblVehicleEF HHD 8.5000e-005 5.0000e-006
tblVehicleEF HHD 3.4760e-003 1.8700e-004
tblVehicleEF HHD 1.05 0.46
tblVehicleEF HHD 5.2000e-005 3.0000e-006
tblVehicleEF HHD 0.13 0.08
tblVehicleEF HHD 2.3300e-004 8.2900e-004
tblVehicleEF HHD 0.06 1.0000e-006
tblVehicleEF LDA 4.2030e-003 2.5110e-003
tblVehicleEF LDA 5.6230e-003 0.05
tblVehicleEF LDA 0.57 0.67
tblVehicleEF LDA 1.19 2.11
tblVehicleEF LDA 251.29 265.15
tblVehicleEF LDA 57.15 54.12
tblVehicleEF LDA 0.05 0.04
tblVehicleEF LDA 0.08 0.18
tblVehicleEF LDA 1.6780e-003 1.5210e-003
tblVehicleEF LDA 2.2790e-003 1.8570e-003
tblVehicleEF LDA 1.5460e-003 1.4000e-003
tblVehicleEF LDA 2.0960e-003 1.7080e-003
tblVehicleEF LDA 0.04 0.06
tblVehicleEF LDA 0.10 0.10
tblVehicleEF LDA 0.03 0.05
tblVehicleEF LDA 0.01 9.5370e-003
tblVehicleEF LDA 0.03 0.21
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 8 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF LDA 0.08 0.22
tblVehicleEF LDA 2.5170e-003 2.6060e-003
tblVehicleEF LDA 5.9200e-004 5.3200e-004
tblVehicleEF LDA 0.04 0.06
tblVehicleEF LDA 0.10 0.10
tblVehicleEF LDA 0.03 0.05
tblVehicleEF LDA 0.02 0.01
tblVehicleEF LDA 0.03 0.21
tblVehicleEF LDA 0.08 0.24
tblVehicleEF LDA 4.7900e-003 2.8350e-003
tblVehicleEF LDA 4.6890e-003 0.04
tblVehicleEF LDA 0.71 0.81
tblVehicleEF LDA 0.99 1.78
tblVehicleEF LDA 274.94 287.11
tblVehicleEF LDA 57.15 53.48
tblVehicleEF LDA 0.05 0.03
tblVehicleEF LDA 0.07 0.17
tblVehicleEF LDA 1.6780e-003 1.5210e-003
tblVehicleEF LDA 2.2790e-003 1.8570e-003
tblVehicleEF LDA 1.5460e-003 1.4000e-003
tblVehicleEF LDA 2.0960e-003 1.7080e-003
tblVehicleEF LDA 0.09 0.11
tblVehicleEF LDA 0.12 0.11
tblVehicleEF LDA 0.07 0.09
tblVehicleEF LDA 0.01 0.01
tblVehicleEF LDA 0.03 0.21
tblVehicleEF LDA 0.06 0.19
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 9 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF LDA 2.7550e-003 2.8220e-003
tblVehicleEF LDA 5.8800e-004 5.2600e-004
tblVehicleEF LDA 0.09 0.11
tblVehicleEF LDA 0.12 0.11
tblVehicleEF LDA 0.07 0.09
tblVehicleEF LDA 0.02 0.02
tblVehicleEF LDA 0.03 0.21
tblVehicleEF LDA 0.07 0.21
tblVehicleEF LDA 4.0860e-003 2.4590e-003
tblVehicleEF LDA 5.5870e-003 0.05
tblVehicleEF LDA 0.54 0.64
tblVehicleEF LDA 1.18 2.12
tblVehicleEF LDA 245.70 261.06
tblVehicleEF LDA 57.15 54.13
tblVehicleEF LDA 0.05 0.04
tblVehicleEF LDA 0.08 0.18
tblVehicleEF LDA 1.6780e-003 1.5210e-003
tblVehicleEF LDA 2.2790e-003 1.8570e-003
tblVehicleEF LDA 1.5460e-003 1.4000e-003
tblVehicleEF LDA 2.0960e-003 1.7080e-003
tblVehicleEF LDA 0.05 0.06
tblVehicleEF LDA 0.11 0.11
tblVehicleEF LDA 0.03 0.05
tblVehicleEF LDA 0.01 9.3400e-003
tblVehicleEF LDA 0.04 0.24
tblVehicleEF LDA 0.08 0.22
tblVehicleEF LDA 2.4600e-003 2.5660e-003
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 10 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF LDA 5.9100e-004 5.3200e-004
tblVehicleEF LDA 0.05 0.06
tblVehicleEF LDA 0.11 0.11
tblVehicleEF LDA 0.03 0.05
tblVehicleEF LDA 0.01 0.01
tblVehicleEF LDA 0.04 0.24
tblVehicleEF LDA 0.08 0.24
tblVehicleEF LDT1 0.01 7.5760e-003
tblVehicleEF LDT1 0.02 0.08
tblVehicleEF LDT1 1.54 1.52
tblVehicleEF LDT1 3.61 2.39
tblVehicleEF LDT1 313.68 314.63
tblVehicleEF LDT1 70.93 65.70
tblVehicleEF LDT1 0.16 0.13
tblVehicleEF LDT1 0.22 0.30
tblVehicleEF LDT1 2.7050e-003 2.3430e-003
tblVehicleEF LDT1 3.6920e-003 2.8390e-003
tblVehicleEF LDT1 2.4910e-003 2.1560e-003
tblVehicleEF LDT1 3.3960e-003 2.6100e-003
tblVehicleEF LDT1 0.18 0.19
tblVehicleEF LDT1 0.33 0.26
tblVehicleEF LDT1 0.13 0.14
tblVehicleEF LDT1 0.03 0.03
tblVehicleEF LDT1 0.20 0.86
tblVehicleEF LDT1 0.26 0.42
tblVehicleEF LDT1 3.1570e-003 3.0930e-003
tblVehicleEF LDT1 7.7300e-004 6.4600e-004
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 11 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF LDT1 0.18 0.19
tblVehicleEF LDT1 0.33 0.26
tblVehicleEF LDT1 0.13 0.14
tblVehicleEF LDT1 0.05 0.05
tblVehicleEF LDT1 0.20 0.86
tblVehicleEF LDT1 0.28 0.47
tblVehicleEF LDT1 0.02 8.4640e-003
tblVehicleEF LDT1 0.02 0.07
tblVehicleEF LDT1 1.85 1.81
tblVehicleEF LDT1 2.97 2.00
tblVehicleEF LDT1 341.75 337.48
tblVehicleEF LDT1 70.93 64.87
tblVehicleEF LDT1 0.14 0.11
tblVehicleEF LDT1 0.20 0.28
tblVehicleEF LDT1 2.7050e-003 2.3430e-003
tblVehicleEF LDT1 3.6920e-003 2.8390e-003
tblVehicleEF LDT1 2.4910e-003 2.1560e-003
tblVehicleEF LDT1 3.3960e-003 2.6100e-003
tblVehicleEF LDT1 0.37 0.36
tblVehicleEF LDT1 0.41 0.31
tblVehicleEF LDT1 0.27 0.26
tblVehicleEF LDT1 0.04 0.04
tblVehicleEF LDT1 0.20 0.85
tblVehicleEF LDT1 0.21 0.36
tblVehicleEF LDT1 3.4420e-003 3.3180e-003
tblVehicleEF LDT1 7.6200e-004 6.3800e-004
tblVehicleEF LDT1 0.37 0.36
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 12 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF LDT1 0.41 0.31
tblVehicleEF LDT1 0.27 0.26
tblVehicleEF LDT1 0.06 0.05
tblVehicleEF LDT1 0.20 0.85
tblVehicleEF LDT1 0.23 0.40
tblVehicleEF LDT1 0.01 7.4310e-003
tblVehicleEF LDT1 0.02 0.08
tblVehicleEF LDT1 1.47 1.47
tblVehicleEF LDT1 3.55 2.39
tblVehicleEF LDT1 307.06 310.38
tblVehicleEF LDT1 70.93 65.71
tblVehicleEF LDT1 0.15 0.12
tblVehicleEF LDT1 0.21 0.29
tblVehicleEF LDT1 2.7050e-003 2.3430e-003
tblVehicleEF LDT1 3.6920e-003 2.8390e-003
tblVehicleEF LDT1 2.4910e-003 2.1560e-003
tblVehicleEF LDT1 3.3960e-003 2.6100e-003
tblVehicleEF LDT1 0.19 0.19
tblVehicleEF LDT1 0.39 0.30
tblVehicleEF LDT1 0.12 0.13
tblVehicleEF LDT1 0.03 0.03
tblVehicleEF LDT1 0.23 1.00
tblVehicleEF LDT1 0.25 0.43
tblVehicleEF LDT1 3.0890e-003 3.0520e-003
tblVehicleEF LDT1 7.7200e-004 6.4600e-004
tblVehicleEF LDT1 0.19 0.19
tblVehicleEF LDT1 0.39 0.30
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 13 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF LDT1 0.12 0.13
tblVehicleEF LDT1 0.05 0.05
tblVehicleEF LDT1 0.23 1.00
tblVehicleEF LDT1 0.28 0.47
tblVehicleEF LDT2 6.3270e-003 4.4090e-003
tblVehicleEF LDT2 8.1990e-003 0.07
tblVehicleEF LDT2 0.80 1.00
tblVehicleEF LDT2 1.67 2.71
tblVehicleEF LDT2 351.15 335.59
tblVehicleEF LDT2 79.39 70.25
tblVehicleEF LDT2 0.09 0.09
tblVehicleEF LDT2 0.14 0.30
tblVehicleEF LDT2 1.7270e-003 1.6010e-003
tblVehicleEF LDT2 2.4170e-003 1.9240e-003
tblVehicleEF LDT2 1.5880e-003 1.4740e-003
tblVehicleEF LDT2 2.2220e-003 1.7690e-003
tblVehicleEF LDT2 0.06 0.10
tblVehicleEF LDT2 0.13 0.14
tblVehicleEF LDT2 0.05 0.08
tblVehicleEF LDT2 0.02 0.02
tblVehicleEF LDT2 0.07 0.45
tblVehicleEF LDT2 0.11 0.33
tblVehicleEF LDT2 3.5180e-003 3.2990e-003
tblVehicleEF LDT2 8.2200e-004 6.9100e-004
tblVehicleEF LDT2 0.06 0.10
tblVehicleEF LDT2 0.13 0.14
tblVehicleEF LDT2 0.05 0.08
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 14 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF LDT2 0.02 0.03
tblVehicleEF LDT2 0.07 0.45
tblVehicleEF LDT2 0.12 0.36
tblVehicleEF LDT2 7.1840e-003 4.9540e-003
tblVehicleEF LDT2 6.8290e-003 0.06
tblVehicleEF LDT2 0.97 1.20
tblVehicleEF LDT2 1.38 2.28
tblVehicleEF LDT2 383.36 357.71
tblVehicleEF LDT2 79.39 69.39
tblVehicleEF LDT2 0.08 0.08
tblVehicleEF LDT2 0.13 0.28
tblVehicleEF LDT2 1.7270e-003 1.6010e-003
tblVehicleEF LDT2 2.4170e-003 1.9240e-003
tblVehicleEF LDT2 1.5880e-003 1.4740e-003
tblVehicleEF LDT2 2.2220e-003 1.7690e-003
tblVehicleEF LDT2 0.13 0.18
tblVehicleEF LDT2 0.15 0.16
tblVehicleEF LDT2 0.11 0.15
tblVehicleEF LDT2 0.02 0.02
tblVehicleEF LDT2 0.07 0.45
tblVehicleEF LDT2 0.09 0.29
tblVehicleEF LDT2 3.8420e-003 3.5160e-003
tblVehicleEF LDT2 8.1700e-004 6.8200e-004
tblVehicleEF LDT2 0.13 0.18
tblVehicleEF LDT2 0.15 0.16
tblVehicleEF LDT2 0.11 0.15
tblVehicleEF LDT2 0.03 0.03
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 15 of 63
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tblVehicleEF LDT2 0.07 0.45
tblVehicleEF LDT2 0.10 0.31
tblVehicleEF LDT2 6.1560e-003 4.3220e-003
tblVehicleEF LDT2 8.1410e-003 0.07
tblVehicleEF LDT2 0.75 0.96
tblVehicleEF LDT2 1.64 2.72
tblVehicleEF LDT2 343.55 331.47
tblVehicleEF LDT2 79.39 70.27
tblVehicleEF LDT2 0.08 0.08
tblVehicleEF LDT2 0.14 0.30
tblVehicleEF LDT2 1.7270e-003 1.6010e-003
tblVehicleEF LDT2 2.4170e-003 1.9240e-003
tblVehicleEF LDT2 1.5880e-003 1.4740e-003
tblVehicleEF LDT2 2.2220e-003 1.7690e-003
tblVehicleEF LDT2 0.06 0.09
tblVehicleEF LDT2 0.14 0.16
tblVehicleEF LDT2 0.05 0.08
tblVehicleEF LDT2 0.02 0.02
tblVehicleEF LDT2 0.08 0.52
tblVehicleEF LDT2 0.11 0.33
tblVehicleEF LDT2 3.4410e-003 3.2580e-003
tblVehicleEF LDT2 8.2200e-004 6.9100e-004
tblVehicleEF LDT2 0.06 0.09
tblVehicleEF LDT2 0.14 0.16
tblVehicleEF LDT2 0.05 0.08
tblVehicleEF LDT2 0.02 0.03
tblVehicleEF LDT2 0.08 0.52
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 16 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF LDT2 0.12 0.37
tblVehicleEF LHD1 5.2170e-003 5.0850e-003
tblVehicleEF LHD1 0.01 6.1020e-003
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 0.14 0.18
tblVehicleEF LHD1 1.07 0.75
tblVehicleEF LHD1 2.60 1.03
tblVehicleEF LHD1 9.23 9.25
tblVehicleEF LHD1 609.20 652.45
tblVehicleEF LHD1 30.40 11.21
tblVehicleEF LHD1 0.09 0.07
tblVehicleEF LHD1 2.12 1.25
tblVehicleEF LHD1 0.99 0.32
tblVehicleEF LHD1 9.6500e-004 8.9000e-004
tblVehicleEF LHD1 0.01 9.8770e-003
tblVehicleEF LHD1 0.01 9.8260e-003
tblVehicleEF LHD1 9.5800e-004 2.6000e-004
tblVehicleEF LHD1 9.2400e-004 8.5100e-004
tblVehicleEF LHD1 2.5390e-003 2.4690e-003
tblVehicleEF LHD1 0.01 9.3750e-003
tblVehicleEF LHD1 8.8100e-004 2.3900e-004
tblVehicleEF LHD1 3.7070e-003 3.0390e-003
tblVehicleEF LHD1 0.11 0.08
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 1.8240e-003 1.5810e-003
tblVehicleEF LHD1 0.08 0.06
tblVehicleEF LHD1 0.35 0.55
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 17 of 63
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tblVehicleEF LHD1 0.27 0.08
tblVehicleEF LHD1 9.2000e-005 9.0000e-005
tblVehicleEF LHD1 5.9760e-003 6.3570e-003
tblVehicleEF LHD1 3.5300e-004 1.1100e-004
tblVehicleEF LHD1 3.7070e-003 3.0390e-003
tblVehicleEF LHD1 0.11 0.08
tblVehicleEF LHD1 0.02 0.03
tblVehicleEF LHD1 1.8240e-003 1.5810e-003
tblVehicleEF LHD1 0.10 0.08
tblVehicleEF LHD1 0.35 0.55
tblVehicleEF LHD1 0.29 0.09
tblVehicleEF LHD1 5.2170e-003 5.0990e-003
tblVehicleEF LHD1 0.01 6.2280e-003
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 0.14 0.18
tblVehicleEF LHD1 1.09 0.76
tblVehicleEF LHD1 2.43 0.98
tblVehicleEF LHD1 9.23 9.25
tblVehicleEF LHD1 609.20 652.47
tblVehicleEF LHD1 30.40 11.12
tblVehicleEF LHD1 0.09 0.07
tblVehicleEF LHD1 1.98 1.17
tblVehicleEF LHD1 0.94 0.31
tblVehicleEF LHD1 9.6500e-004 8.9000e-004
tblVehicleEF LHD1 0.01 9.8770e-003
tblVehicleEF LHD1 0.01 9.8260e-003
tblVehicleEF LHD1 9.5800e-004 2.6000e-004
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 18 of 63
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tblVehicleEF LHD1 9.2400e-004 8.5100e-004
tblVehicleEF LHD1 2.5390e-003 2.4690e-003
tblVehicleEF LHD1 0.01 9.3750e-003
tblVehicleEF LHD1 8.8100e-004 2.3900e-004
tblVehicleEF LHD1 7.3080e-003 5.4780e-003
tblVehicleEF LHD1 0.13 0.10
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 4.1220e-003 3.0450e-003
tblVehicleEF LHD1 0.09 0.06
tblVehicleEF LHD1 0.36 0.56
tblVehicleEF LHD1 0.25 0.08
tblVehicleEF LHD1 9.2000e-005 9.0000e-005
tblVehicleEF LHD1 5.9770e-003 6.3570e-003
tblVehicleEF LHD1 3.5000e-004 1.1000e-004
tblVehicleEF LHD1 7.3080e-003 5.4780e-003
tblVehicleEF LHD1 0.13 0.10
tblVehicleEF LHD1 0.02 0.03
tblVehicleEF LHD1 4.1220e-003 3.0450e-003
tblVehicleEF LHD1 0.11 0.08
tblVehicleEF LHD1 0.36 0.56
tblVehicleEF LHD1 0.28 0.08
tblVehicleEF LHD1 5.2170e-003 5.0870e-003
tblVehicleEF LHD1 0.01 6.1100e-003
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 0.14 0.18
tblVehicleEF LHD1 1.07 0.75
tblVehicleEF LHD1 2.55 1.02
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tblVehicleEF LHD1 9.23 9.25
tblVehicleEF LHD1 609.20 652.45
tblVehicleEF LHD1 30.40 11.20
tblVehicleEF LHD1 0.09 0.07
tblVehicleEF LHD1 2.08 1.23
tblVehicleEF LHD1 0.97 0.31
tblVehicleEF LHD1 9.6500e-004 8.9000e-004
tblVehicleEF LHD1 0.01 9.8770e-003
tblVehicleEF LHD1 0.01 9.8260e-003
tblVehicleEF LHD1 9.5800e-004 2.6000e-004
tblVehicleEF LHD1 9.2400e-004 8.5100e-004
tblVehicleEF LHD1 2.5390e-003 2.4690e-003
tblVehicleEF LHD1 0.01 9.3750e-003
tblVehicleEF LHD1 8.8100e-004 2.3900e-004
tblVehicleEF LHD1 4.0430e-003 3.1520e-003
tblVehicleEF LHD1 0.13 0.10
tblVehicleEF LHD1 0.02 0.02
tblVehicleEF LHD1 1.7940e-003 1.6100e-003
tblVehicleEF LHD1 0.08 0.06
tblVehicleEF LHD1 0.38 0.60
tblVehicleEF LHD1 0.26 0.08
tblVehicleEF LHD1 9.2000e-005 9.0000e-005
tblVehicleEF LHD1 5.9760e-003 6.3570e-003
tblVehicleEF LHD1 3.5200e-004 1.1100e-004
tblVehicleEF LHD1 4.0430e-003 3.1520e-003
tblVehicleEF LHD1 0.13 0.10
tblVehicleEF LHD1 0.02 0.03
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tblVehicleEF LHD1 1.7940e-003 1.6100e-003
tblVehicleEF LHD1 0.10 0.08
tblVehicleEF LHD1 0.38 0.60
tblVehicleEF LHD1 0.29 0.09
tblVehicleEF LHD2 3.5950e-003 3.6950e-003
tblVehicleEF LHD2 4.6110e-003 4.1040e-003
tblVehicleEF LHD2 8.1370e-003 0.01
tblVehicleEF LHD2 0.12 0.15
tblVehicleEF LHD2 0.50 0.50
tblVehicleEF LHD2 1.20 0.67
tblVehicleEF LHD2 14.27 14.14
tblVehicleEF LHD2 608.52 665.25
tblVehicleEF LHD2 24.46 8.76
tblVehicleEF LHD2 0.11 0.10
tblVehicleEF LHD2 1.49 1.36
tblVehicleEF LHD2 0.53 0.22
tblVehicleEF LHD2 1.2830e-003 1.3100e-003
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 4.0000e-004 1.3700e-004
tblVehicleEF LHD2 1.2280e-003 1.2540e-003
tblVehicleEF LHD2 2.6860e-003 2.6560e-003
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 3.6800e-004 1.2600e-004
tblVehicleEF LHD2 1.3070e-003 1.7040e-003
tblVehicleEF LHD2 0.04 0.05
tblVehicleEF LHD2 0.01 0.02
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tblVehicleEF LHD2 7.0300e-004 9.2000e-004
tblVehicleEF LHD2 0.06 0.06
tblVehicleEF LHD2 0.09 0.32
tblVehicleEF LHD2 0.11 0.05
tblVehicleEF LHD2 1.3900e-004 1.3500e-004
tblVehicleEF LHD2 5.9200e-003 6.4300e-003
tblVehicleEF LHD2 2.6700e-004 8.7000e-005
tblVehicleEF LHD2 1.3070e-003 1.7040e-003
tblVehicleEF LHD2 0.04 0.05
tblVehicleEF LHD2 0.02 0.02
tblVehicleEF LHD2 7.0300e-004 9.2000e-004
tblVehicleEF LHD2 0.07 0.07
tblVehicleEF LHD2 0.09 0.32
tblVehicleEF LHD2 0.12 0.06
tblVehicleEF LHD2 3.5950e-003 3.7050e-003
tblVehicleEF LHD2 4.6760e-003 4.1460e-003
tblVehicleEF LHD2 7.7630e-003 0.01
tblVehicleEF LHD2 0.12 0.15
tblVehicleEF LHD2 0.50 0.50
tblVehicleEF LHD2 1.13 0.64
tblVehicleEF LHD2 14.27 14.14
tblVehicleEF LHD2 608.52 665.25
tblVehicleEF LHD2 24.46 8.70
tblVehicleEF LHD2 0.11 0.10
tblVehicleEF LHD2 1.40 1.28
tblVehicleEF LHD2 0.50 0.21
tblVehicleEF LHD2 1.2830e-003 1.3100e-003
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tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 4.0000e-004 1.3700e-004
tblVehicleEF LHD2 1.2280e-003 1.2540e-003
tblVehicleEF LHD2 2.6860e-003 2.6560e-003
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 3.6800e-004 1.2600e-004
tblVehicleEF LHD2 2.5220e-003 3.0730e-003
tblVehicleEF LHD2 0.04 0.06
tblVehicleEF LHD2 0.01 0.02
tblVehicleEF LHD2 1.5220e-003 1.7630e-003
tblVehicleEF LHD2 0.06 0.06
tblVehicleEF LHD2 0.09 0.32
tblVehicleEF LHD2 0.10 0.05
tblVehicleEF LHD2 1.3900e-004 1.3500e-004
tblVehicleEF LHD2 5.9200e-003 6.4300e-003
tblVehicleEF LHD2 2.6500e-004 8.6000e-005
tblVehicleEF LHD2 2.5220e-003 3.0730e-003
tblVehicleEF LHD2 0.04 0.06
tblVehicleEF LHD2 0.02 0.02
tblVehicleEF LHD2 1.5220e-003 1.7630e-003
tblVehicleEF LHD2 0.07 0.07
tblVehicleEF LHD2 0.09 0.32
tblVehicleEF LHD2 0.11 0.05
tblVehicleEF LHD2 3.5950e-003 3.6960e-003
tblVehicleEF LHD2 4.6180e-003 4.1080e-003
tblVehicleEF LHD2 8.0640e-003 0.01
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tblVehicleEF LHD2 0.12 0.15
tblVehicleEF LHD2 0.50 0.50
tblVehicleEF LHD2 1.19 0.67
tblVehicleEF LHD2 14.27 14.14
tblVehicleEF LHD2 608.52 665.25
tblVehicleEF LHD2 24.46 8.75
tblVehicleEF LHD2 0.11 0.10
tblVehicleEF LHD2 1.46 1.33
tblVehicleEF LHD2 0.52 0.22
tblVehicleEF LHD2 1.2830e-003 1.3100e-003
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 4.0000e-004 1.3700e-004
tblVehicleEF LHD2 1.2280e-003 1.2540e-003
tblVehicleEF LHD2 2.6860e-003 2.6560e-003
tblVehicleEF LHD2 0.01 0.01
tblVehicleEF LHD2 3.6800e-004 1.2600e-004
tblVehicleEF LHD2 1.3460e-003 1.7140e-003
tblVehicleEF LHD2 0.04 0.06
tblVehicleEF LHD2 0.01 0.02
tblVehicleEF LHD2 6.8700e-004 9.2200e-004
tblVehicleEF LHD2 0.06 0.06
tblVehicleEF LHD2 0.10 0.34
tblVehicleEF LHD2 0.11 0.05
tblVehicleEF LHD2 1.3900e-004 1.3500e-004
tblVehicleEF LHD2 5.9200e-003 6.4300e-003
tblVehicleEF LHD2 2.6600e-004 8.7000e-005
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tblVehicleEF LHD2 1.3460e-003 1.7140e-003
tblVehicleEF LHD2 0.04 0.06
tblVehicleEF LHD2 0.02 0.02
tblVehicleEF LHD2 6.8700e-004 9.2200e-004
tblVehicleEF LHD2 0.07 0.07
tblVehicleEF LHD2 0.10 0.34
tblVehicleEF LHD2 0.12 0.06
tblVehicleEF MCY 0.43 0.34
tblVehicleEF MCY 0.16 0.24
tblVehicleEF MCY 20.55 19.26
tblVehicleEF MCY 9.93 8.60
tblVehicleEF MCY 167.73 212.03
tblVehicleEF MCY 46.45 60.73
tblVehicleEF MCY 1.16 1.13
tblVehicleEF MCY 0.31 0.26
tblVehicleEF MCY 1.8610e-003 1.9650e-003
tblVehicleEF MCY 3.6730e-003 2.9600e-003
tblVehicleEF MCY 1.7420e-003 1.8380e-003
tblVehicleEF MCY 3.4650e-003 2.7870e-003
tblVehicleEF MCY 1.45 1.42
tblVehicleEF MCY 0.84 0.80
tblVehicleEF MCY 0.80 0.78
tblVehicleEF MCY 2.23 2.33
tblVehicleEF MCY 0.49 1.91
tblVehicleEF MCY 2.16 1.84
tblVehicleEF MCY 2.0770e-003 2.0980e-003
tblVehicleEF MCY 6.9000e-004 6.0100e-004
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tblVehicleEF MCY 1.45 1.42
tblVehicleEF MCY 0.84 0.80
tblVehicleEF MCY 0.80 0.78
tblVehicleEF MCY 2.74 2.87
tblVehicleEF MCY 0.49 1.91
tblVehicleEF MCY 2.35 2.01
tblVehicleEF MCY 0.42 0.34
tblVehicleEF MCY 0.14 0.21
tblVehicleEF MCY 20.68 19.28
tblVehicleEF MCY 9.05 7.90
tblVehicleEF MCY 167.73 211.90
tblVehicleEF MCY 46.45 58.88
tblVehicleEF MCY 0.99 0.97
tblVehicleEF MCY 0.29 0.25
tblVehicleEF MCY 1.8610e-003 1.9650e-003
tblVehicleEF MCY 3.6730e-003 2.9600e-003
tblVehicleEF MCY 1.7420e-003 1.8380e-003
tblVehicleEF MCY 3.4650e-003 2.7870e-003
tblVehicleEF MCY 3.14 2.77
tblVehicleEF MCY 1.27 1.11
tblVehicleEF MCY 2.13 1.77
tblVehicleEF MCY 2.17 2.28
tblVehicleEF MCY 0.49 1.88
tblVehicleEF MCY 1.86 1.62
tblVehicleEF MCY 2.0770e-003 2.0970e-003
tblVehicleEF MCY 6.6700e-004 5.8300e-004
tblVehicleEF MCY 3.14 2.77
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tblVehicleEF MCY 1.27 1.11
tblVehicleEF MCY 2.13 1.77
tblVehicleEF MCY 2.67 2.81
tblVehicleEF MCY 0.49 1.88
tblVehicleEF MCY 2.02 1.76
tblVehicleEF MCY 0.42 0.34
tblVehicleEF MCY 0.15 0.24
tblVehicleEF MCY 19.63 18.76
tblVehicleEF MCY 9.55 8.44
tblVehicleEF MCY 167.73 211.17
tblVehicleEF MCY 46.45 60.38
tblVehicleEF MCY 1.12 1.09
tblVehicleEF MCY 0.31 0.26
tblVehicleEF MCY 1.8610e-003 1.9650e-003
tblVehicleEF MCY 3.6730e-003 2.9600e-003
tblVehicleEF MCY 1.7420e-003 1.8380e-003
tblVehicleEF MCY 3.4650e-003 2.7870e-003
tblVehicleEF MCY 1.71 1.57
tblVehicleEF MCY 1.13 1.06
tblVehicleEF MCY 0.72 0.74
tblVehicleEF MCY 2.19 2.31
tblVehicleEF MCY 0.56 2.18
tblVehicleEF MCY 2.08 1.81
tblVehicleEF MCY 2.0610e-003 2.0900e-003
tblVehicleEF MCY 6.8200e-004 5.9800e-004
tblVehicleEF MCY 1.71 1.57
tblVehicleEF MCY 1.13 1.06
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tblVehicleEF MCY 0.72 0.74
tblVehicleEF MCY 2.69 2.84
tblVehicleEF MCY 0.56 2.18
tblVehicleEF MCY 2.27 1.98
tblVehicleEF MDV 0.01 5.5200e-003
tblVehicleEF MDV 0.02 0.09
tblVehicleEF MDV 1.35 1.14
tblVehicleEF MDV 3.25 3.25
tblVehicleEF MDV 483.94 415.10
tblVehicleEF MDV 107.92 87.32
tblVehicleEF MDV 0.17 0.11
tblVehicleEF MDV 0.32 0.38
tblVehicleEF MDV 1.8260e-003 1.6850e-003
tblVehicleEF MDV 2.5170e-003 2.0310e-003
tblVehicleEF MDV 1.6830e-003 1.5540e-003
tblVehicleEF MDV 2.3150e-003 1.8680e-003
tblVehicleEF MDV 0.10 0.11
tblVehicleEF MDV 0.20 0.17
tblVehicleEF MDV 0.08 0.10
tblVehicleEF MDV 0.03 0.02
tblVehicleEF MDV 0.11 0.50
tblVehicleEF MDV 0.25 0.44
tblVehicleEF MDV 4.8500e-003 4.0780e-003
tblVehicleEF MDV 1.1370e-003 8.5900e-004
tblVehicleEF MDV 0.10 0.11
tblVehicleEF MDV 0.20 0.17
tblVehicleEF MDV 0.08 0.10
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tblVehicleEF MDV 0.05 0.03
tblVehicleEF MDV 0.11 0.50
tblVehicleEF MDV 0.28 0.48
tblVehicleEF MDV 0.01 6.2110e-003
tblVehicleEF MDV 0.02 0.08
tblVehicleEF MDV 1.64 1.35
tblVehicleEF MDV 2.69 2.72
tblVehicleEF MDV 526.85 438.45
tblVehicleEF MDV 107.92 86.27
tblVehicleEF MDV 0.16 0.10
tblVehicleEF MDV 0.30 0.35
tblVehicleEF MDV 1.8260e-003 1.6850e-003
tblVehicleEF MDV 2.5170e-003 2.0310e-003
tblVehicleEF MDV 1.6830e-003 1.5540e-003
tblVehicleEF MDV 2.3150e-003 1.8680e-003
tblVehicleEF MDV 0.20 0.21
tblVehicleEF MDV 0.23 0.19
tblVehicleEF MDV 0.17 0.19
tblVehicleEF MDV 0.04 0.03
tblVehicleEF MDV 0.11 0.49
tblVehicleEF MDV 0.21 0.38
tblVehicleEF MDV 5.2830e-003 4.3080e-003
tblVehicleEF MDV 1.1260e-003 8.4800e-004
tblVehicleEF MDV 0.20 0.21
tblVehicleEF MDV 0.23 0.19
tblVehicleEF MDV 0.17 0.19
tblVehicleEF MDV 0.05 0.04
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tblVehicleEF MDV 0.11 0.49
tblVehicleEF MDV 0.23 0.41
tblVehicleEF MDV 0.01 5.4050e-003
tblVehicleEF MDV 0.02 0.09
tblVehicleEF MDV 1.28 1.09
tblVehicleEF MDV 3.20 3.26
tblVehicleEF MDV 473.93 410.75
tblVehicleEF MDV 107.92 87.35
tblVehicleEF MDV 0.16 0.10
tblVehicleEF MDV 0.32 0.38
tblVehicleEF MDV 1.8260e-003 1.6850e-003
tblVehicleEF MDV 2.5170e-003 2.0310e-003
tblVehicleEF MDV 1.6830e-003 1.5540e-003
tblVehicleEF MDV 2.3150e-003 1.8680e-003
tblVehicleEF MDV 0.10 0.11
tblVehicleEF MDV 0.22 0.18
tblVehicleEF MDV 0.08 0.10
tblVehicleEF MDV 0.03 0.02
tblVehicleEF MDV 0.13 0.57
tblVehicleEF MDV 0.25 0.44
tblVehicleEF MDV 4.7490e-003 4.0360e-003
tblVehicleEF MDV 1.1360e-003 8.5900e-004
tblVehicleEF MDV 0.10 0.11
tblVehicleEF MDV 0.22 0.18
tblVehicleEF MDV 0.08 0.10
tblVehicleEF MDV 0.04 0.03
tblVehicleEF MDV 0.13 0.57
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tblVehicleEF MDV 0.27 0.48
tblVehicleEF MH 0.04 3.6580e-003
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 3.07 0.35
tblVehicleEF MH 6.43 0.00
tblVehicleEF MH 1,045.05 970.21
tblVehicleEF MH 59.49 0.00
tblVehicleEF MH 1.54 4.24
tblVehicleEF MH 0.91 0.00
tblVehicleEF MH 0.01 0.02
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.1740e-003 0.00
tblVehicleEF MH 3.2230e-003 4.0000e-003
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.0790e-003 0.00
tblVehicleEF MH 1.47 0.00
tblVehicleEF MH 0.09 0.00
tblVehicleEF MH 0.51 0.00
tblVehicleEF MH 0.10 0.08
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.37 0.00
tblVehicleEF MH 0.01 9.1720e-003
tblVehicleEF MH 7.0700e-004 0.00
tblVehicleEF MH 1.47 0.00
tblVehicleEF MH 0.09 0.00
tblVehicleEF MH 0.51 0.00
tblVehicleEF MH 0.14 0.09
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tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.40 0.00
tblVehicleEF MH 0.04 3.6580e-003
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 3.19 0.35
tblVehicleEF MH 5.84 0.00
tblVehicleEF MH 1,045.05 970.21
tblVehicleEF MH 59.49 0.00
tblVehicleEF MH 1.41 4.00
tblVehicleEF MH 0.86 0.00
tblVehicleEF MH 0.01 0.02
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.1740e-003 0.00
tblVehicleEF MH 3.2230e-003 4.0000e-003
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.0790e-003 0.00
tblVehicleEF MH 2.91 0.00
tblVehicleEF MH 0.11 0.00
tblVehicleEF MH 1.21 0.00
tblVehicleEF MH 0.11 0.08
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.34 0.00
tblVehicleEF MH 0.01 9.1720e-003
tblVehicleEF MH 6.9700e-004 0.00
tblVehicleEF MH 2.91 0.00
tblVehicleEF MH 0.11 0.00
tblVehicleEF MH 1.21 0.00
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tblVehicleEF MH 0.15 0.09
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.38 0.00
tblVehicleEF MH 0.04 3.6580e-003
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 3.08 0.35
tblVehicleEF MH 6.36 0.00
tblVehicleEF MH 1,045.05 970.21
tblVehicleEF MH 59.49 0.00
tblVehicleEF MH 1.51 4.17
tblVehicleEF MH 0.89 0.00
tblVehicleEF MH 0.01 0.02
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.1740e-003 0.00
tblVehicleEF MH 3.2230e-003 4.0000e-003
tblVehicleEF MH 0.04 0.11
tblVehicleEF MH 1.0790e-003 0.00
tblVehicleEF MH 1.75 0.00
tblVehicleEF MH 0.11 0.00
tblVehicleEF MH 0.53 0.00
tblVehicleEF MH 0.10 0.08
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.37 0.00
tblVehicleEF MH 0.01 9.1720e-003
tblVehicleEF MH 7.0600e-004 0.00
tblVehicleEF MH 1.75 0.00
tblVehicleEF MH 0.11 0.00
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tblVehicleEF MH 0.53 0.00
tblVehicleEF MH 0.15 0.09
tblVehicleEF MH 0.03 0.00
tblVehicleEF MH 0.40 0.00
tblVehicleEF MHD 0.02 2.5070e-003
tblVehicleEF MHD 3.5160e-003 3.3210e-003
tblVehicleEF MHD 0.05 6.4670e-003
tblVehicleEF MHD 0.32 0.31
tblVehicleEF MHD 0.27 0.32
tblVehicleEF MHD 5.32 0.74
tblVehicleEF MHD 156.91 68.92
tblVehicleEF MHD 1,101.52 974.57
tblVehicleEF MHD 52.43 6.35
tblVehicleEF MHD 0.60 0.52
tblVehicleEF MHD 0.99 1.61
tblVehicleEF MHD 11.88 1.50
tblVehicleEF MHD 3.8600e-004 1.2310e-003
tblVehicleEF MHD 5.0030e-003 0.04
tblVehicleEF MHD 7.6400e-004 7.5000e-005
tblVehicleEF MHD 3.6900e-004 1.1780e-003
tblVehicleEF MHD 4.7830e-003 0.03
tblVehicleEF MHD 7.0300e-004 6.9000e-005
tblVehicleEF MHD 1.2800e-003 4.5300e-004
tblVehicleEF MHD 0.04 0.01
tblVehicleEF MHD 0.02 0.02
tblVehicleEF MHD 6.5100e-004 2.4000e-004
tblVehicleEF MHD 0.04 0.06
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tblVehicleEF MHD 0.02 0.08
tblVehicleEF MHD 0.32 0.03
tblVehicleEF MHD 1.5080e-003 6.5300e-004
tblVehicleEF MHD 0.01 9.2620e-003
tblVehicleEF MHD 6.1700e-004 6.3000e-005
tblVehicleEF MHD 1.2800e-003 4.5300e-004
tblVehicleEF MHD 0.04 0.01
tblVehicleEF MHD 0.03 0.02
tblVehicleEF MHD 6.5100e-004 2.4000e-004
tblVehicleEF MHD 0.04 0.07
tblVehicleEF MHD 0.02 0.08
tblVehicleEF MHD 0.35 0.04
tblVehicleEF MHD 0.02 2.3860e-003
tblVehicleEF MHD 3.5800e-003 3.3450e-003
tblVehicleEF MHD 0.05 6.2100e-003
tblVehicleEF MHD 0.24 0.26
tblVehicleEF MHD 0.28 0.33
tblVehicleEF MHD 4.97 0.70
tblVehicleEF MHD 166.20 69.59
tblVehicleEF MHD 1,101.52 974.58
tblVehicleEF MHD 52.43 6.28
tblVehicleEF MHD 0.62 0.52
tblVehicleEF MHD 0.92 1.52
tblVehicleEF MHD 11.85 1.49
tblVehicleEF MHD 3.2500e-004 1.0410e-003
tblVehicleEF MHD 5.0030e-003 0.04
tblVehicleEF MHD 7.6400e-004 7.5000e-005
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tblVehicleEF MHD 3.1100e-004 9.9600e-004
tblVehicleEF MHD 4.7830e-003 0.03
tblVehicleEF MHD 7.0300e-004 6.9000e-005
tblVehicleEF MHD 2.5300e-003 8.2800e-004
tblVehicleEF MHD 0.05 0.02
tblVehicleEF MHD 0.02 0.02
tblVehicleEF MHD 1.5010e-003 4.7800e-004
tblVehicleEF MHD 0.04 0.06
tblVehicleEF MHD 0.02 0.08
tblVehicleEF MHD 0.30 0.03
tblVehicleEF MHD 1.5950e-003 6.5900e-004
tblVehicleEF MHD 0.01 9.2620e-003
tblVehicleEF MHD 6.1100e-004 6.2000e-005
tblVehicleEF MHD 2.5300e-003 8.2800e-004
tblVehicleEF MHD 0.05 0.02
tblVehicleEF MHD 0.03 0.02
tblVehicleEF MHD 1.5010e-003 4.7800e-004
tblVehicleEF MHD 0.04 0.07
tblVehicleEF MHD 0.02 0.08
tblVehicleEF MHD 0.33 0.04
tblVehicleEF MHD 0.02 2.6830e-003
tblVehicleEF MHD 3.5220e-003 3.3210e-003
tblVehicleEF MHD 0.05 6.4200e-003
tblVehicleEF MHD 0.45 0.37
tblVehicleEF MHD 0.27 0.32
tblVehicleEF MHD 5.23 0.74
tblVehicleEF MHD 144.06 68.00
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tblVehicleEF MHD 1,101.52 974.57
tblVehicleEF MHD 52.43 6.34
tblVehicleEF MHD 0.57 0.52
tblVehicleEF MHD 0.97 1.59
tblVehicleEF MHD 11.87 1.50
tblVehicleEF MHD 4.7000e-004 1.4940e-003
tblVehicleEF MHD 5.0030e-003 0.04
tblVehicleEF MHD 7.6400e-004 7.5000e-005
tblVehicleEF MHD 4.4900e-004 1.4300e-003
tblVehicleEF MHD 4.7830e-003 0.03
tblVehicleEF MHD 7.0300e-004 6.9000e-005
tblVehicleEF MHD 1.3890e-003 4.7100e-004
tblVehicleEF MHD 0.05 0.02
tblVehicleEF MHD 0.03 0.02
tblVehicleEF MHD 6.4000e-004 2.4400e-004
tblVehicleEF MHD 0.04 0.06
tblVehicleEF MHD 0.02 0.09
tblVehicleEF MHD 0.32 0.03
tblVehicleEF MHD 1.3860e-003 6.4400e-004
tblVehicleEF MHD 0.01 9.2620e-003
tblVehicleEF MHD 6.1600e-004 6.3000e-005
tblVehicleEF MHD 1.3890e-003 4.7100e-004
tblVehicleEF MHD 0.05 0.02
tblVehicleEF MHD 0.04 0.02
tblVehicleEF MHD 6.4000e-004 2.4400e-004
tblVehicleEF MHD 0.04 0.07
tblVehicleEF MHD 0.02 0.09
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tblVehicleEF MHD 0.35 0.04
tblVehicleEF OBUS 0.01 8.8190e-003
tblVehicleEF OBUS 9.9110e-003 6.5960e-003
tblVehicleEF OBUS 0.03 0.02
tblVehicleEF OBUS 0.26 0.52
tblVehicleEF OBUS 0.63 0.77
tblVehicleEF OBUS 6.27 2.45
tblVehicleEF OBUS 70.35 76.06
tblVehicleEF OBUS 1,121.50 1,406.90
tblVehicleEF OBUS 70.70 20.49
tblVehicleEF OBUS 0.28 0.34
tblVehicleEF OBUS 0.97 1.24
tblVehicleEF OBUS 1.93 0.68
tblVehicleEF OBUS 6.4000e-005 5.8900e-004
tblVehicleEF OBUS 4.6440e-003 0.01
tblVehicleEF OBUS 9.2900e-004 2.1800e-004
tblVehicleEF OBUS 6.1000e-005 5.6400e-004
tblVehicleEF OBUS 4.4220e-003 0.01
tblVehicleEF OBUS 8.5400e-004 2.0100e-004
tblVehicleEF OBUS 2.1800e-003 2.6020e-003
tblVehicleEF OBUS 0.02 0.02
tblVehicleEF OBUS 0.04 0.05
tblVehicleEF OBUS 9.3100e-004 1.1160e-003
tblVehicleEF OBUS 0.04 0.05
tblVehicleEF OBUS 0.05 0.29
tblVehicleEF OBUS 0.38 0.12
tblVehicleEF OBUS 6.8400e-004 7.2500e-004
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tblVehicleEF OBUS 0.01 0.01
tblVehicleEF OBUS 8.1700e-004 2.0300e-004
tblVehicleEF OBUS 2.1800e-003 2.6020e-003
tblVehicleEF OBUS 0.02 0.02
tblVehicleEF OBUS 0.05 0.07
tblVehicleEF OBUS 9.3100e-004 1.1160e-003
tblVehicleEF OBUS 0.06 0.07
tblVehicleEF OBUS 0.05 0.29
tblVehicleEF OBUS 0.42 0.13
tblVehicleEF OBUS 0.01 8.8750e-003
tblVehicleEF OBUS 0.01 6.7350e-003
tblVehicleEF OBUS 0.03 0.02
tblVehicleEF OBUS 0.26 0.51
tblVehicleEF OBUS 0.65 0.79
tblVehicleEF OBUS 5.74 2.28
tblVehicleEF OBUS 73.50 75.90
tblVehicleEF OBUS 1,121.50 1,406.93
tblVehicleEF OBUS 70.70 20.20
tblVehicleEF OBUS 0.29 0.34
tblVehicleEF OBUS 0.90 1.16
tblVehicleEF OBUS 1.88 0.67
tblVehicleEF OBUS 5.4000e-005 5.0100e-004
tblVehicleEF OBUS 4.6440e-003 0.01
tblVehicleEF OBUS 9.2900e-004 2.1800e-004
tblVehicleEF OBUS 5.1000e-005 4.7900e-004
tblVehicleEF OBUS 4.4220e-003 0.01
tblVehicleEF OBUS 8.5400e-004 2.0100e-004
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tblVehicleEF OBUS 4.2350e-003 4.6860e-003
tblVehicleEF OBUS 0.02 0.03
tblVehicleEF OBUS 0.03 0.05
tblVehicleEF OBUS 2.1330e-003 2.2090e-003
tblVehicleEF OBUS 0.05 0.05
tblVehicleEF OBUS 0.05 0.29
tblVehicleEF OBUS 0.36 0.11
tblVehicleEF OBUS 7.1400e-004 7.2400e-004
tblVehicleEF OBUS 0.01 0.01
tblVehicleEF OBUS 8.0800e-004 2.0000e-004
tblVehicleEF OBUS 4.2350e-003 4.6860e-003
tblVehicleEF OBUS 0.02 0.03
tblVehicleEF OBUS 0.05 0.07
tblVehicleEF OBUS 2.1330e-003 2.2090e-003
tblVehicleEF OBUS 0.06 0.07
tblVehicleEF OBUS 0.05 0.29
tblVehicleEF OBUS 0.40 0.12
tblVehicleEF OBUS 0.01 8.7740e-003
tblVehicleEF OBUS 9.9380e-003 6.6000e-003
tblVehicleEF OBUS 0.03 0.02
tblVehicleEF OBUS 0.28 0.53
tblVehicleEF OBUS 0.63 0.77
tblVehicleEF OBUS 6.22 2.45
tblVehicleEF OBUS 66.00 76.30
tblVehicleEF OBUS 1,121.50 1,406.90
tblVehicleEF OBUS 70.70 20.50
tblVehicleEF OBUS 0.27 0.35
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tblVehicleEF OBUS 0.96 1.22
tblVehicleEF OBUS 1.91 0.68
tblVehicleEF OBUS 7.7000e-005 7.1200e-004
tblVehicleEF OBUS 4.6440e-003 0.01
tblVehicleEF OBUS 9.2900e-004 2.1800e-004
tblVehicleEF OBUS 7.4000e-005 6.8100e-004
tblVehicleEF OBUS 4.4220e-003 0.01
tblVehicleEF OBUS 8.5400e-004 2.0100e-004
tblVehicleEF OBUS 2.3200e-003 2.7390e-003
tblVehicleEF OBUS 0.02 0.03
tblVehicleEF OBUS 0.04 0.05
tblVehicleEF OBUS 9.4100e-004 1.1650e-003
tblVehicleEF OBUS 0.04 0.05
tblVehicleEF OBUS 0.05 0.30
tblVehicleEF OBUS 0.38 0.12
tblVehicleEF OBUS 6.4200e-004 7.2700e-004
tblVehicleEF OBUS 0.01 0.01
tblVehicleEF OBUS 8.1600e-004 2.0300e-004
tblVehicleEF OBUS 2.3200e-003 2.7390e-003
tblVehicleEF OBUS 0.02 0.03
tblVehicleEF OBUS 0.05 0.07
tblVehicleEF OBUS 9.4100e-004 1.1650e-003
tblVehicleEF OBUS 0.06 0.07
tblVehicleEF OBUS 0.05 0.30
tblVehicleEF OBUS 0.42 0.13
tblVehicleEF SBUS 0.84 0.06
tblVehicleEF SBUS 0.01 8.5840e-003
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tblVehicleEF SBUS 0.07 6.1570e-003
tblVehicleEF SBUS 5.71 2.50
tblVehicleEF SBUS 0.65 0.78
tblVehicleEF SBUS 5.33 0.82
tblVehicleEF SBUS 1,258.13 345.06
tblVehicleEF SBUS 1,136.31 1,112.17
tblVehicleEF SBUS 37.11 4.79
tblVehicleEF SBUS 11.70 3.29
tblVehicleEF SBUS 4.77 5.20
tblVehicleEF SBUS 15.02 0.91
tblVehicleEF SBUS 0.01 4.3580e-003
tblVehicleEF SBUS 0.01 0.01
tblVehicleEF SBUS 0.03 0.03
tblVehicleEF SBUS 5.1700e-004 4.0000e-005
tblVehicleEF SBUS 0.01 4.1690e-003
tblVehicleEF SBUS 2.7560e-003 2.7010e-003
tblVehicleEF SBUS 0.03 0.03
tblVehicleEF SBUS 4.7500e-004 3.6000e-005
tblVehicleEF SBUS 2.9260e-003 1.2420e-003
tblVehicleEF SBUS 0.02 9.5120e-003
tblVehicleEF SBUS 0.68 0.28
tblVehicleEF SBUS 1.3050e-003 5.9000e-004
tblVehicleEF SBUS 0.11 0.11
tblVehicleEF SBUS 9.3510e-003 0.06
tblVehicleEF SBUS 0.27 0.04
tblVehicleEF SBUS 0.01 3.2890e-003
tblVehicleEF SBUS 0.01 0.01
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tblVehicleEF SBUS 4.6300e-004 4.7000e-005
tblVehicleEF SBUS 2.9260e-003 1.2420e-003
tblVehicleEF SBUS 0.02 9.5120e-003
tblVehicleEF SBUS 0.97 0.40
tblVehicleEF SBUS 1.3050e-003 5.9000e-004
tblVehicleEF SBUS 0.13 0.13
tblVehicleEF SBUS 9.3510e-003 0.06
tblVehicleEF SBUS 0.30 0.04
tblVehicleEF SBUS 0.84 0.06
tblVehicleEF SBUS 0.01 8.7140e-003
tblVehicleEF SBUS 0.06 5.1550e-003
tblVehicleEF SBUS 5.56 2.47
tblVehicleEF SBUS 0.66 0.80
tblVehicleEF SBUS 3.65 0.60
tblVehicleEF SBUS 1,322.00 352.98
tblVehicleEF SBUS 1,136.31 1,112.20
tblVehicleEF SBUS 37.11 4.41
tblVehicleEF SBUS 12.08 3.36
tblVehicleEF SBUS 4.47 4.88
tblVehicleEF SBUS 14.99 0.90
tblVehicleEF SBUS 0.01 3.6810e-003
tblVehicleEF SBUS 0.01 0.01
tblVehicleEF SBUS 0.03 0.03
tblVehicleEF SBUS 5.1700e-004 4.0000e-005
tblVehicleEF SBUS 9.6490e-003 3.5220e-003
tblVehicleEF SBUS 2.7560e-003 2.7010e-003
tblVehicleEF SBUS 0.03 0.03
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tblVehicleEF SBUS 4.7500e-004 3.6000e-005
tblVehicleEF SBUS 5.6170e-003 2.2080e-003
tblVehicleEF SBUS 0.02 9.9850e-003
tblVehicleEF SBUS 0.67 0.28
tblVehicleEF SBUS 2.8800e-003 1.1130e-003
tblVehicleEF SBUS 0.11 0.11
tblVehicleEF SBUS 8.5310e-003 0.06
tblVehicleEF SBUS 0.22 0.03
tblVehicleEF SBUS 0.01 3.3630e-003
tblVehicleEF SBUS 0.01 0.01
tblVehicleEF SBUS 4.3500e-004 4.4000e-005
tblVehicleEF SBUS 5.6170e-003 2.2080e-003
tblVehicleEF SBUS 0.02 9.9850e-003
tblVehicleEF SBUS 0.97 0.40
tblVehicleEF SBUS 2.8800e-003 1.1130e-003
tblVehicleEF SBUS 0.13 0.13
tblVehicleEF SBUS 8.5310e-003 0.06
tblVehicleEF SBUS 0.24 0.03
tblVehicleEF SBUS 0.84 0.06
tblVehicleEF SBUS 0.01 8.5760e-003
tblVehicleEF SBUS 0.07 6.3440e-003
tblVehicleEF SBUS 5.91 2.56
tblVehicleEF SBUS 0.65 0.78
tblVehicleEF SBUS 5.37 0.86
tblVehicleEF SBUS 1,169.92 334.13
tblVehicleEF SBUS 1,136.31 1,112.17
tblVehicleEF SBUS 37.11 4.85
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tblVehicleEF SBUS 11.19 3.19
tblVehicleEF SBUS 4.69 5.12
tblVehicleEF SBUS 15.02 0.91
tblVehicleEF SBUS 0.01 5.2920e-003
tblVehicleEF SBUS 0.01 0.01
tblVehicleEF SBUS 0.03 0.03
tblVehicleEF SBUS 5.1700e-004 4.0000e-005
tblVehicleEF SBUS 0.01 5.0630e-003
tblVehicleEF SBUS 2.7560e-003 2.7010e-003
tblVehicleEF SBUS 0.03 0.03
tblVehicleEF SBUS 4.7500e-004 3.6000e-005
tblVehicleEF SBUS 2.9580e-003 1.2070e-003
tblVehicleEF SBUS 0.02 0.01
tblVehicleEF SBUS 0.68 0.28
tblVehicleEF SBUS 1.2820e-003 6.0100e-004
tblVehicleEF SBUS 0.11 0.11
tblVehicleEF SBUS 0.01 0.08
tblVehicleEF SBUS 0.28 0.04
tblVehicleEF SBUS 0.01 3.1850e-003
tblVehicleEF SBUS 0.01 0.01
tblVehicleEF SBUS 4.6400e-004 4.8000e-005
tblVehicleEF SBUS 2.9580e-003 1.2070e-003
tblVehicleEF SBUS 0.02 0.01
tblVehicleEF SBUS 0.98 0.40
tblVehicleEF SBUS 1.2820e-003 6.0100e-004
tblVehicleEF SBUS 0.13 0.13
tblVehicleEF SBUS 0.01 0.08
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tblVehicleEF SBUS 0.31 0.04
tblVehicleEF UBUS 1.83 4.45
tblVehicleEF UBUS 0.08 0.01
tblVehicleEF UBUS 9.26 34.75
tblVehicleEF UBUS 14.34 0.89
tblVehicleEF UBUS 1,846.39 1,692.13
tblVehicleEF UBUS 136.37 11.77
tblVehicleEF UBUS 5.87 0.38
tblVehicleEF UBUS 13.57 0.14
tblVehicleEF UBUS 0.52 0.07
tblVehicleEF UBUS 0.01 0.03
tblVehicleEF UBUS 0.07 2.6550e-003
tblVehicleEF UBUS 1.4030e-003 1.4100e-004
tblVehicleEF UBUS 0.22 0.03
tblVehicleEF UBUS 3.0000e-003 6.6220e-003
tblVehicleEF UBUS 0.06 2.5280e-003
tblVehicleEF UBUS 1.2900e-003 1.3000e-004
tblVehicleEF UBUS 8.0860e-003 1.6780e-003
tblVehicleEF UBUS 0.11 9.5390e-003
tblVehicleEF UBUS 3.9450e-003 7.3700e-004
tblVehicleEF UBUS 0.61 0.07
tblVehicleEF UBUS 0.02 0.04
tblVehicleEF UBUS 1.15 0.04
tblVehicleEF UBUS 0.01 3.0250e-003
tblVehicleEF UBUS 1.6240e-003 1.1700e-004
tblVehicleEF UBUS 8.0860e-003 1.6780e-003
tblVehicleEF UBUS 0.11 9.5390e-003
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tblVehicleEF UBUS 3.9450e-003 7.3700e-004
tblVehicleEF UBUS 2.50 4.54
tblVehicleEF UBUS 0.02 0.04
tblVehicleEF UBUS 1.25 0.04
tblVehicleEF UBUS 1.83 4.45
tblVehicleEF UBUS 0.08 9.2350e-003
tblVehicleEF UBUS 9.36 34.75
tblVehicleEF UBUS 11.74 0.76
tblVehicleEF UBUS 1,846.39 1,692.13
tblVehicleEF UBUS 136.37 11.55
tblVehicleEF UBUS 5.45 0.38
tblVehicleEF UBUS 13.45 0.13
tblVehicleEF UBUS 0.52 0.07
tblVehicleEF UBUS 0.01 0.03
tblVehicleEF UBUS 0.07 2.6550e-003
tblVehicleEF UBUS 1.4030e-003 1.4100e-004
tblVehicleEF UBUS 0.22 0.03
tblVehicleEF UBUS 3.0000e-003 6.6220e-003
tblVehicleEF UBUS 0.06 2.5280e-003
tblVehicleEF UBUS 1.2900e-003 1.3000e-004
tblVehicleEF UBUS 0.02 3.0610e-003
tblVehicleEF UBUS 0.14 0.01
tblVehicleEF UBUS 9.3320e-003 1.4840e-003
tblVehicleEF UBUS 0.62 0.07
tblVehicleEF UBUS 0.02 0.04
tblVehicleEF UBUS 1.02 0.03
tblVehicleEF UBUS 0.01 3.0250e-003
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tblVehicleEF UBUS 1.5790e-003 1.1400e-004
tblVehicleEF UBUS 0.02 3.0610e-003
tblVehicleEF UBUS 0.14 0.01
tblVehicleEF UBUS 9.3320e-003 1.4840e-003
tblVehicleEF UBUS 2.52 4.54
tblVehicleEF UBUS 0.02 0.04
tblVehicleEF UBUS 1.12 0.04
tblVehicleEF UBUS 1.83 4.45
tblVehicleEF UBUS 0.08 0.01
tblVehicleEF UBUS 9.27 34.75
tblVehicleEF UBUS 13.86 0.90
tblVehicleEF UBUS 1,846.39 1,692.13
tblVehicleEF UBUS 136.37 11.80
tblVehicleEF UBUS 5.76 0.38
tblVehicleEF UBUS 13.55 0.14
tblVehicleEF UBUS 0.52 0.07
tblVehicleEF UBUS 0.01 0.03
tblVehicleEF UBUS 0.07 2.6550e-003
tblVehicleEF UBUS 1.4030e-003 1.4100e-004
tblVehicleEF UBUS 0.22 0.03
tblVehicleEF UBUS 3.0000e-003 6.6220e-003
tblVehicleEF UBUS 0.06 2.5280e-003
tblVehicleEF UBUS 1.2900e-003 1.3000e-004
tblVehicleEF UBUS 9.2250e-003 1.6870e-003
tblVehicleEF UBUS 0.14 0.01
tblVehicleEF UBUS 4.1190e-003 7.4500e-004
tblVehicleEF UBUS 0.61 0.07
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 48 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
tblVehicleEF UBUS 0.03 0.05
tblVehicleEF UBUS 1.13 0.04
tblVehicleEF UBUS 0.01 3.0250e-003
tblVehicleEF UBUS 1.6160e-003 1.1700e-004
tblVehicleEF UBUS 9.2250e-003 1.6870e-003
tblVehicleEF UBUS 0.14 0.01
tblVehicleEF UBUS 4.1190e-003 7.4500e-004
tblVehicleEF UBUS 2.50 4.54
tblVehicleEF UBUS 0.03 0.05
tblVehicleEF UBUS 1.24 0.04
tblVehicleTrips CC_TL 8.40 0.00
tblVehicleTrips CC_TL 8.40 0.00
tblVehicleTrips CC_TL 8.40 0.00
tblVehicleTrips CC_TL 8.40 0.00
tblVehicleTrips CC_TL 8.40 0.00
tblVehicleTrips CNW_TL 6.90 0.00
tblVehicleTrips CNW_TL 6.90 0.00
tblVehicleTrips CNW_TL 6.90 0.00
tblVehicleTrips CNW_TL 6.90 0.00
tblVehicleTrips CNW_TL 6.90 0.00
tblVehicleTrips CNW_TTP 41.00 0.00
tblVehicleTrips CNW_TTP 41.00 0.00
tblVehicleTrips CW_TL 16.60 0.00
tblVehicleTrips CW_TL 16.60 0.00
tblVehicleTrips CW_TL 16.60 0.00
tblVehicleTrips CW_TL 16.60 0.00
tblVehicleTrips CW_TL 16.60 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 49 of 63
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2.0 Emissions Summary
tblVehicleTrips CW_TTP 59.00 0.00
tblVehicleTrips CW_TTP 59.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips DV_TP 5.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PB_TP 3.00 0.00
tblVehicleTrips PR_TP 92.00 0.00
tblVehicleTrips PR_TP 92.00 0.00
tblVehicleTrips ST_TR 1.68 0.00
tblVehicleTrips ST_TR 1.68 0.00
tblVehicleTrips SU_TR 1.68 0.00
tblVehicleTrips SU_TR 1.68 0.00
tblVehicleTrips WD_TR 1.68 0.00
tblVehicleTrips WD_TR 1.68 0.00
tblWater IndoorWaterUseRate 88,927,187.50 0.00
tblWater IndoorWaterUseRate 177,854,375.00 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 50 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
2.1 Overall Construction (Maximum Daily Emission)
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 0.0396 1.7906 0.2571 2.5400e-
003
0.0227 9.0000e-
004
0.0236 4.4000e-
003
8.6000e-
004
5.2600e-
003
0.0000 268.8567 268.8567 0.0542 0.0000 270.2111
Maximum 0.0396 1.7906 0.2571 2.5400e-
003
0.0227 9.0000e-
004
0.0236 4.4000e-
003
8.6000e-
004
5.2600e-
003
0.0000 268.8567 268.8567 0.0542 0.0000 270.2111
Unmitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year lb/day lb/day
2021 0.0396 1.7906 0.2571 2.5400e-
003
0.0135 9.0000e-
004
0.0144 3.0100e-
003
8.6000e-
004
3.8700e-
003
0.0000 268.8567 268.8567 0.0542 0.0000 270.2111
Maximum 0.0396 1.7906 0.2571 2.5400e-
003
0.0135 9.0000e-
004
0.0144 3.0100e-
003
8.6000e-
004
3.8700e-
003
0.0000 268.8567 268.8567 0.0542 0.0000 270.2111
Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 40.49 0.00 38.95 31.59 0.00 26.43 0.00 0.00 0.00 0.00 0.00 0.00
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 26.2951 2.6000e-
003
0.2842 2.0000e-
005
0.0000 1.0200e-
003
1.0200e-
003
0.0000 1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.0000 0.6485
Unmitigated Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Area 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Energy 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mobile 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 26.2951 2.6000e-
003
0.2842 2.0000e-
005
0.0000 1.0200e-
003
1.0200e-
003
0.0000 1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.0000 0.6485
Mitigated Operational
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 52 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
3.0 Construction Detail
Construction Phase
Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Site Preparation/Grading Grading 5/1/2021 7/23/2021 5 60
OffRoad Equipment
Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor
Site Preparation/Grading Crawler Tractors 0 8.00 212 0.43
Site Preparation/Grading Excavators 0 8.00 158 0.38
Site Preparation/Grading Graders 0 8.00 187 0.41
Site Preparation/Grading Off-Highway Trucks 0 8.00 402 0.38
Site Preparation/Grading Rubber Tired Dozers 0 8.00 247 0.40
Site Preparation/Grading Scrapers 0 8.00 367 0.48
Site Preparation/Grading Tractors/Loaders/Backhoes 0 8.00 97 0.37
Trips and VMT
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Residential Indoor: 0; Residential Outdoor: 0; Non-Residential Indoor: 0; Non-Residential Outdoor: 0; Striped Parking Area: 0 (Architectural
Coating ±sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 0
Acres of Paving: 26.48
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 53 of 63
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3.2 Site Preparation/Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 0.0151 0.0000 0.0151 2.2800e-
003
0.0000 2.2800e-
003
0.0000 0.0000
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0151 0.0000 0.0151 2.2800e-
003
0.0000 2.2800e-
003
0.0000 0.0000 0.0000 0.0000
Unmitigated Construction On-Site
3.1 Mitigation Measures Construction
Use Cleaner Engines for Construction Equipment
Water Exposed Area
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Site
Preparation/Grading
0 0.00 0.00 1,000.00 14.70 6.90 0.50 LD_Mix HDT_Mix HHDT
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 54 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
3.2 Site Preparation/Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0396 1.7906 0.2571 2.5400e-
003
7.6400e-
003
9.0000e-
004
8.5400e-
003
2.1200e-
003
8.6000e-
004
2.9800e-
003
268.8567 268.8567 0.0542 270.2111
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0396 1.7906 0.2571 2.5400e-
003
7.6400e-
003
9.0000e-
004
8.5400e-
003
2.1200e-
003
8.6000e-
004
2.9800e-
003
268.8567 268.8567 0.0542 270.2111
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Fugitive Dust 5.8800e-
003
0.0000 5.8800e-
003
8.9000e-
004
0.0000 8.9000e-
004
0.0000 0.0000
Off-Road 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 5.8800e-
003
0.0000 5.8800e-
003
8.9000e-
004
0.0000 8.9000e-
004
0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated Construction On-Site
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
3.2 Site Preparation/Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Hauling 0.0396 1.7906 0.2571 2.5400e-
003
7.6400e-
003
9.0000e-
004
8.5400e-
003
2.1200e-
003
8.6000e-
004
2.9800e-
003
268.8567 268.8567 0.0542 270.2111
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Worker 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0396 1.7906 0.2571 2.5400e-
003
7.6400e-
003
9.0000e-
004
8.5400e-
003
2.1200e-
003
8.6000e-
004
2.9800e-
003
268.8567 268.8567 0.0542 270.2111
Mitigated Construction Off-Site
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
4.2 Trip Summary Information
4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Other Asphalt Surfaces 0.00 0.00 0.00
Other Non-Asphalt Surfaces 0.00 0.00 0.00
Parking Lot 0.00 0.00 0.00
Refrigerated Warehouse-No Rail 0.00 0.00 0.00
Unrefrigerated Warehouse-No Rail 0.00 0.00 0.00
Total 0.00 0.00 0.00
Miles Trip %Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by
Other Asphalt Surfaces 0.00 0.00 0.00 0.00 0.00 0.00 0 0 0
Other Non-Asphalt Surfaces 0.00 0.00 0.00 0.00 0.00 0.00 0 0 0
Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0 0 0
Refrigerated Warehouse-No
Rail
0.00 0.00 0.00 0.00 0.00 0.00 0 0 0
Unrefrigerated Warehouse-No
Rail
0.00 0.00 0.00 0.00 0.00 0.00 0 0 0
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
5.0 Energy Detail
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
NaturalGas
Mitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
NaturalGas
Unmitigated
0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
5.1 Mitigation Measures Energy
4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH
Other Asphalt Surfaces 0.553113 0.036408 0.180286 0.116335 0.016165 0.005101 0.018218 0.063797 0.001357 0.001565 0.005903 0.000808 0.000944
Other Non-Asphalt Surfaces 0.553113 0.036408 0.180286 0.116335 0.016165 0.005101 0.018218 0.063797 0.001357 0.001565 0.005903 0.000808 0.000944
Parking Lot 0.553113 0.036408 0.180286 0.116335 0.016165 0.005101 0.018218 0.063797 0.001357 0.001565 0.005903 0.000808 0.000944
Refrigerated Warehouse-No Rail 0.553113 0.036408 0.180286 0.116335 0.016165 0.005101 0.018218 0.063797 0.001357 0.001565 0.005903 0.000808 0.000944
Unrefrigerated Warehouse-No
Rail
0.553113 0.036408 0.180286 0.116335 0.016165 0.005101 0.018218 0.063797 0.001357 0.001565 0.005903 0.000808 0.000944
Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 58 of 63
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5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Refrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unmitigated
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
6.1 Mitigation Measures Area
6.0 Area Detail
5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr lb/day lb/day
Other Asphalt
Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Other Non-
Asphalt Surfaces
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Parking Lot 0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Refrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Unrefrigerated
Warehouse-No
Rail
0 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Total 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 60 of 63
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ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category lb/day lb/day
Mitigated 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Unmitigated 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
3.0179 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
23.2508 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0264 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Total 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Unmitigated
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8.1 Mitigation Measures Waste
7.1 Mitigation Measures Water
7.0 Water Detail
8.0 Waste Detail
6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Total Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory lb/day lb/day
Architectural
Coating
3.0179 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Consumer
Products
23.2508 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Landscaping 0.0264 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Total 26.2951 2.6000e-
003
0.2842 2.0000e-
005
1.0200e-
003
1.0200e-
003
1.0200e-
003
1.0200e-
003
0.6083 0.6083 1.6000e-
003
0.6485
Mitigated
9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type
10.0 Stationary Equipment
Fire Pumps and Emergency Generators
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/14/2021 9:33 AMPage 62 of 63
The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
11.0 Vegetation
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type
User Defined Equipment
Equipment Type Number
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The Landing by San Manuel (Construction - Hauling Activity) - San Bernardino-South Coast County, Winter
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
ATTACHMENT 3
(Related to Response A-9)
Potential Regional Criteria Pollutant Emissions from TRUs
Associated with the Project Including Totals Teported in the
Draft EIR
TRU Type 2 Unit Annual
Number of Units 78 ROG NOX CO SOX PM10 PM2.5 MT CO2
Operating Time Each Unit 2 TRU - Instate Trailer TRU 0.65 5.24 8.02 0.00 0.08 0.08 123.44
TRU - Instate Truck TRU 0.00 0.00 0.00 0.00 0.00 0.00 0.00
TRU Type 3 TRU - Instate Van TRU 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Number of Units 0 TRU - Instate Van TRU 0.00 0.00 0.00 0.00 0.00 0.00 0.00
Operating Time Each Unit 0
TRU Type 4
Number of Units 0
Operating Time Each Unit 0
TRU Type 4
Number of Units 0
Operating Time Each Unit 0
Emissions Pounds per Day
Daily Emission Rates
Year Type ROG CO NOX CO2 PM10 PM2.5 SOX
2022 TRU - Instate Genset TRU 5.94E-03 9.35E-02 6.94E-02 1.91E+00 3.11E-04 2.86E-04 1.76E-05
2022 TRU - Instate Trailer TRU 1.52E-02 1.87E-01 1.22E-01 2.87E+00 1.93E-03 1.77E-03 2.64E-05
2022 TRU - Instate Truck TRU 7.47E-03 6.04E-02 7.25E-02 1.45E+00 2.94E-03 2.71E-03 1.33E-05
2022 TRU - Instate Van TRU 4.77E-03 3.86E-02 4.63E-02 9.26E-01 1.88E-03 1.73E-03 8.50E-06
2022 TRU - Out-of-State Genset TRU 5.91E-03 9.33E-02 6.94E-02 1.91E+00 3.10E-04 2.85E-04 1.76E-05
2022 TRU - Out-of-State Trailer TRU 1.28E-02 1.72E-01 1.13E-01 2.87E+00 8.60E-04 7.91E-04 2.64E-05
2022 TRU - Railcar TRU 1.28E-02 1.72E-01 1.13E-01 2.87E+00 8.60E-04 7.91E-04 2.64E-05
Unit Average HP Average HP-Hr/D
Vehicle Class
Total Hr/day
Hr/Day/ Vehicle
Class
2022 TRU - Instate Genset TRU 31.5 22366.86 710.06 2.14
2022 TRU - Instate Trailer TRU 34 185845.42 5466.04 3.63
2022 TRU - Instate Truck TRU 14.1 20739.54 1470.89 3.73
2022 TRU - Instate Van TRU 9 480.13 53.35 3.73
2022 TRU - Out-of-State Genset TRU 31.5 14093.97 447.43 0.34
2022 TRU - Out-of-State Trailer TRU 34 116093.34 3414.51 0.57
2022 TRU - Railcar TRU 34 12017.16 353.45 0.88
Hourly Emissions Rates
Code Year Type ROG CO NOX CO2 PM10 PM2.5 SOX
1 2022 TRU - Instate Genset TRU 2.78E-03 4.37E-02 3.25E-02 8.92E-01 1.45E-04 1.34E-04 8.24E-06
2 2022 TRU - Instate Trailer TRU 4.17E-03 5.14E-02 3.36E-02 7.91E-01 5.31E-04 4.89E-04 7.26E-06
3 2022 TRU - Instate Truck TRU 2.00E-03 1.62E-02 1.94E-02 3.89E-01 7.89E-04 7.25E-04 3.57E-06
4 2022 TRU - Instate Van TRU 1.28E-03 1.03E-02 1.24E-02 2.48E-01 5.03E-04 4.63E-04 2.28E-06
5 2022 TRU - Out-of-State Genset TRU 1.74E-02 2.75E-01 2.05E-01 5.64E+00 9.15E-04 8.42E-04 5.20E-05
6 2022 TRU - Out-of-State Trailer TRU 2.23E-02 2.99E-01 1.97E-01 5.00E+00 1.50E-03 1.38E-03 4.60E-05
7 2022 TRU - Railcar TRU 1.45E-02 1.94E-01 1.28E-01 3.25E+00 9.74E-04 8.96E-04 2.99E-05
Lookup data
1 TRU - Instate Genset TRU
2 TRU - Instate Trailer TRU
3 TRU - Instate Truck TRU
4 TRU - Instate Van TRU
5 TRU - Out-of-State Genset TRU
6 TRU - Out-of-State Trailer TRU
7 TRU - Railcar TRU
OFFROAD2017 (v1.0.1) Emissions Inventory
Region Type: County
Region: San Bernardino
Calendar Year: 2022
Scenario: All Adopted Rules - Exhaust
Vehicle Classification: OFFROAD2017 Equipment Types
Units: Emissions: tons/day, Fuel Consumption: gallons/year, Activity: hours/year, HP-Hours: HP-hours/year
Region CalYr VehClass MdlYr HP_Bin Fuel HC_tpd ROG_tpd TOG_tpd CO_tpd NOx_tpd CO2_tpd PM10_tpd PM2_5_tpd PM_tpd SOx_tpd NH3_tpd Fuel_gpy Total_Activity_hpyTotal_Population Horsepower_Hours_hhpy
San Bernardino 2022 TRU - Instate Genset TRU AggregatedAggregatedDiesel 0.001742 0.002108 0.002509 0.033211 0.024651 0.677749 0.00011037 0.00010154 0.00011037 6.25589E-06 5.5688E-06 430.2106 259171.5824 331.9645464 8163904.845
San Bernardino 2022 TRU - Instate Trailer TRU AggregatedAggregatedDiesel 0.034222 0.041409 0.04928 0.50985 0.333189 7.84982 0.005270302 0.004848678 0.005270302 7.20356E-05 6.44989E-05 4982.781 1995105.277 1505.872833 67833579.41
San Bernardino 2022 TRU - Instate Truck TRU AggregatedAggregatedDiesel 0.004539 0.005492 0.006536 0.044442 0.0533 1.066442 0.002162406 0.001989413 0.002162406 9.78975E-06 8.76254E-06 676.9386 536874.6392 394.4707121 7569932.412
San Bernardino 2022 TRU - Instate Van TRU AggregatedAggregatedDiesel 0.000105 0.000127 0.000151 0.001029 0.001234 0.024689 5.00612E-05 4.60563E-05 5.00612E-05 2.2664E-07 2.02859E-07 15.6716 19472.13717 14.3072279 175249.2345
San Bernardino 2022 TRU - Out-of-State Genset TRU AggregatedAggregatedDiesel 0.001092 0.001322 0.001573 0.020877 0.015523 0.427068 6.93593E-05 6.38106E-05 6.93593E-05 3.94217E-06 3.50905E-06 271.0874 163311.0695 1320.817577 5144298.688
San Bernardino 2022 TRU - Out-of-State Trailer TRU AggregatedAggregatedDiesel 0.018109 0.021912 0.026077 0.293043 0.193312 4.903601 0.001468696 0.001351201 0.001468696 4.5097E-05 4.0291E-05 3112.628 1246296.196 5939.729183 42374070.67
San Bernardino 2022 TRU - Railcar TRU AggregatedAggregatedDiesel 0.001875 0.002268 0.002699 0.030334 0.02001 0.507586 0.000152029 0.000139867 0.000152029 4.66812E-06 4.17064E-06 322.1971 129007.7114 400.110757 4386262.187
The Landing by San Manuel
Final Environmental Impact Report Final EIR
Lead Agency: City of San Bernardino SCH No. 2020100067
ATTACHMENT 4
(Related to Comment E-12)
Exhibits Attached to Comment Letter E
arb.ca.gov November 2017
The strategy for achieving California’s
2030 greenhouse gas target
California’s 2017
Climate Change
Scoping Plan
Contents
Executive Summary ES1
Decades of Leadership ES1
The Climate Imperative – We Must Act ES2
California is on Track – But There is More to Do ES3
California’s Path to 2030 ES4
California’s Climate Vision ES5
Enhance Industrial Efficiency & Competitiveness ES7
Prioritize Transportation Sustainability ES8
Continue Leading on Clean Energy ES10
Put Waste Resources to Beneficial Use ES12
Support Resilient Agricultural and Rural Economies and Natural and Working Lands ES13
Secure California’s Water Supplies ES14
Cleaning the Air and Public Health ES15
Successful Example of Carbon Pricing and Investment ES16
Fostering Global Action ES17
Unleashing the California Spirit ES18
Chapter 1: Introduction 1
Background 1
Climate Legislation and Directives 1
Initial Scoping Plan and First Update to the Scoping Plan 5
Building on California’s Environmental Legacy 5
Purpose of the 2017 Scoping Plan 5
Process for Developing the 2017 Scoping Plan 6
Updated Climate Science Supports the Need for More Action 6
California’s Greenhouse Gas Emissions and the 2030 Target 9
Progress Toward Achieving the 2020 Limit 9
Greenhouse Gas Emissions Tracking 12
California’s Approach to Addressing Climate Change 12
Integrated Systems 12
Promoting Resilient Economic Growth 13
Increasing Carbon Sequestration in Natural and Working Lands 13
Improving Public Health 14
Environmental Justice 14
Setting the Path to 2050 18
Intergovernmental Collaboration 19
International Efforts 19
Chapter 2: The Scoping Plan Scenario 22
Scoping Plan Scenario 23
Scenario Modeling 31
Policy Analysis of Scoping Plan Scenario 33
Chapter 3: Evaluations 35
Programs for Air Quality Improvement in California 35
AB 197 Measure Analyses 37
Estimated Emissions Reductions for Evaluated Measures 37
Estimated Social Costs of Evaluated Measures 39
Estimated Cost Per Metric Ton by Measure 44
Health Analyses 47
Potential Health Impacts of Reductions in Particulate Matter Air Pollution 47
Potential Health Impacts of Reductions in Toxic Air Pollution 48
Potential Health Impacts of Active Transportation 48
Future Health Activities 50
Economic Analyses 50
Public Health 57
Environmental Analysis 60
Chapter 4: Key Sectors 62
Low Carbon Energy 65
Industry 69
Transportation Sustainability 73
Natural and Working Lands Including Agricultural Lands 81
Waste Management 88
Water 92
Chapter 5: Achieving Success 96
Ongoing Engagement with Environmental Justice Communities 96
Enabling Local Action 97
Climate Action through Local Planning and Permitting 99
Implementing the Scoping Plan 103
A Comprehensive Approach to Support Climate Action 104
Conclusion 106
Abbreviations 107
ES1
Decades of Leadership
From the first law to protect rivers from the impact of gold mining in 1884, to decades of
work to fight smog, the Golden State has set the national – and international – standard
for environmental protection. California pushes old boundaries, encounters new ones,
and figures out ways to break through those as well.
This is part of the reason why California has grown
to become both the 6th largest economy in the
world, and home to some of the world’s strongest
environmental protections. And, we have seen our
programs and policies adopted by others as they seek
to protect public health and the environment.
California’s approach to climate change channels
and continues this spirit of innovation, inclusion, and
success. The 2030 target of 40 percent emissions
reductions below 1990 levels guides this Scoping Plan, as the economy evolves to reduce greenhouse gas (GHG) emissions in every sector. It also demonstrates that we are doing our part in the global effort under the Paris Agreement to reduce GHGs and limit global
temperature rise below 2 degrees Celsius in this century.
California’s 2017 Climate Change Scoping Plan: The Strategy for Achieving California’s 2030 Greenhouse
Gas Target (Plan) builds on the state’s successes to date, proposing to strengthen major
programs that have been a hallmark of success, while further integrating efforts to reduce
both GHGs and air pollution. California’s climate efforts will:
• Lower GHG emissions on a trajectory to avoid the worst impacts of climate change;
• Support a clean energy economy which provides
more opportunities for all Californians;
• Provide a more equitable future with good jobs
and less pollution for all communities;• Improve the health of all Californians by reducing air and water pollution and making it easier to bike and walk; and• Make California an even better place to live, work, and play
by improving our natural and working lands.
2% Recycling & Waste
California Carbon Emissions
2015 Total Emissions
440.4 MMTCO2e
11% Electricity Generation
21% Industrial
8% Agriculture
37% Transportation
In State8% Electricity Generation
Imports
9% Commercial & Residential
4% High-GWP
Governor Brown signs SB 32 recommitting California’s efforts to curb climate change.
C alifornia Carbon Emissions by sCoping plan sEC tor
ES2
The Climate Imperative – We Must Act
The evidence that the climate is changing is undeniable. As
evidence mounts, the scientific record only becomes more definitive – and makes clear the need to take additional action now.
In California, as in the rest of the world, climate change is contributing to an escalation of
serious problems, including raging wildfires, coastal erosion, disruption of water supply,
threats to agriculture, spread of
insect-borne diseases, and continuing
health threats from air pollution.
The drought that plagued California for years devastated the state’s agricultural and rural communities, leaving some of them with no drinking water at all. In 2015 alone,
the drought cost agriculture in the
Central Valley an estimated $2.7
billion, and more than 20,000 jobs.
Last winter, the drought was broken
by record-breaking rains, which led to
flooding that tore through freeways,
threatened rural communities, and
isolated coastal areas. This year,
California experienced the deadliest
wildfires in its history. Climate change is making events like these more frequent, more
catastrophic and more costly. Climate change impacts all Californians, and the impacts
are often disproportionately borne by the state’s most vulnerable and disadvantaged populations.
is already experiencing
CLIMATE CHANGE
the impacts of
CALIFORNIA
WILDFIRES
HEAT WAVES
RISING
SEA LEVELS
DROUGHT
REDUCED
SNOWPACK
IN 2015 THE DROUGHT COST THE
AGRICULTURE INDUSTRY IN THE
CENTRAL VALLEY AN ESTIMATED
$2.7 BILLION & 20,000 JOBS
ES3
California is on Track – But There is More to Do
Although the California Global Warming Solutions Act of 2006 – also known as AB
32 – marked the beginning of an integrated climate change program, California has
had programs to reduce GHG emissions for decades. The state’s energy efficiency
requirements, Renewable Portfolio Standard, and clean car standards have reduced
air pollution and saved consumers money, while also lowering GHG emissions.
AB 32 set California’s first GHG target called on the state to reduce emissions to 1990
levels by 2020. California is on track to exceed its 2020 climate target, while the economy
continues to grow. Since the launch of many of the state’s major climate programs, including
Cap-and-Trade, economic growth in California has consistently outpaced economic growth
in the rest of the country. The state’s average annual growth rate has been double the
national average – and ranks second in the
country since Cap-and-Trade took effect
in 2012. In short, California has succeeded
in reducing GHG emissions while also
developing a cleaner, resilient economy that
uses less energy and generates less pollution.
Importantly, the State’s 2020 and 2030 targets
have not been set in isolation. They represent
benchmarks, consistent with prevailing climate
science, charting an appropriate trajectory forward that is in line with California’s role in stabilizing global warming below dangerous thresholds. As we consider efforts to reduce emissions to meet the State’s near-term
requirements, we must do so with an eye
toward reductions needed beyond 2030.
The Paris Agreement – which calls for limiting
global warming to well below 2 degrees
Celsius and pursuing efforts to limit it to
1.5 degrees Celsius – frames our
path forward.Trillion (2009 $)tonnes CO2e/million $ GDP0.0
0.5
1.0
1.5
2.0
2.5
0
100
200
300
400
500
600
2000 20022001 2004 200620052003 201020092007 2008 2014201320122011 2015
Emissions per unit GDP
GDP
EnvironmEntal progrEss and a rEsiliEnt EConomy
The California economy has grown while becoming less carbon intensive.
2020 Target
2030 Target
0
100
200
300
400
500
2000 2010 2020 2030Annual GHG Emissions (MMTCO2e)2020 Target
2030 Target
2010 2020 2030
C alifornia’s path forward
ES4
California’s Path to 2030
Executive Order B-30-15 and SB 32 extended the goals of AB 32 and set a 2030 goal of
reducing emissions 40 percent from 2020 levels. This action keeps California on target to
achieve the level of reductions scientists
say is necessary to meet the Paris
Agreement goals. This is an ambitious
goal – calling on the State to double
the rate of emissions reductions.
Nevertheless, it is an achievable goal.
This Plan establishes a path that will
get California to its 2030 target. Given
our ambitious goals, this Plan is built
on unprecedented outreach and
coordination. Over 20 state agencies
collaborated to produce the Plan, informed by 15 state agency-sponsored workshops and more than 500 public comments. The broad range of state agencies involved reflects the complex
nature of addressing climate change,
and the need to work across institutional
boundaries and traditional economic sectors to effectively reduce GHG emissions. As part
of the Plan development, alternative strategies were considered and evaluated, ranging
from carbon taxes to individual facility caps to relying solely on sector-specific regulations.
In addition, efforts were made to ensure that the Plan would benefit all Californians. To this
end, the Environmental Justice Advisory Committee (EJAC), a Legislatively created advisory
body, convened almost 20 community meetings throughout California to discuss the climate
strategy, and held 19 meetings of its own to provide recommendations on the Plan.
This Plan draws from the experiences in developing and implementing previous plans
to present a path to reaching California’s 2030 GHG reduction target. The Plan is a
package of economically viable and
technologically feasible actions to not
just keep California on track to achieve
its 2030 target, but stay on track for a low- to zero-carbon economy by involving every part of the state. Every sector, every local government, every region, every resident is part
of the solution. The Plan underscores
that there is no single solution but
rather a balanced mix of strategies
to achieve the GHG target. This Plan
highlights the fact that a balanced
mix of strategies provides California
with the greatest level of certainty in
meeting the target at a low cost while
also improving public health, investing
in disadvantaged and low-income communities, protecting consumers, and supporting
economic growth, jobs and energy diversity. Successful implementation of this Plan relies,
in part, on long-term funding plans to inform future appropriations necessary to achieve California’s long-term targets.
SOURCE: ADVANCED ENERGY ECONOMY
employing 500,000 Californians
MORE THAN THE MOTION PICTURE& AGRICULTURAL INDUSTRIES COMBINED
CREATING31,000 DIRECT JOBS &57,000 INDIRECT JOBS
+#1 IN CLEAN ENERGY JOBSCalifornia is
GENERATED renewable energy projects
FROM 2002-2015 SAN JOAQUIN VALLEY
$11.6 BILLION
in economic activity
Double building efficiency
50% renewable power
More clean, renewable fuels
Cleaner zero or near-zero emission
cars, trucks, and buses
Walkable/Bikeable communities
with transit
Cleaner freight and goods movement
Slash potent “super-pollutants” from dairies,
landfills and refrigerants
Cap emissions from transportation, industry,
natural gas, and electricity
Invest in communities to reduce emissions
C alifornia’s ClimatE poliCy portfolio
ES5
California’s Climate Vision
Create Inclusive Policies and Broad Support for Clean Technologies
Remarkable progress over the past 10 years has put
the global energy and transportation sector on a
transformative path to cleaner energy. Far outpacing
previous predictions, today solar and wind power are
often less expensive than coal or natural gas, and they
now comprise the majority of global investment in
the power sector. Electric vehicle battery costs have
tumbled even more quickly than solar costs, while
performance has improved dramatically, and the auto industry is committed to an electric future.
California’s policies have created markets for energy
efficiency, energy storage, low carbon fuels, renewable power – including utility-scale and residential-scale solar – and zero-emission vehicles. Our companies are thriving, making those markets grow. California is home to nearly half of the zero-emission vehicles in the U.S.,
40 percent of North American clean fuels investments,
the world’s best known electric car manufacturer, and
the world’s leading ride-sharing services. California is further advancing efficient land use
policies that reduce auto dependency. Altogether, we’re unleashing nonlinear transitions
to clean energy and clean transportation technologies that will put California on the path
to meeting our 2030 target and the goals of the Paris Agreement.
California policymaking has succeeded through thoughtful planning, bolstered by an open
public process that solicits the best ideas from a wide array of sources, and by integrating
effective regulation with targeted investments to provide broad market support for clean
technologies. A key element of California’s approach continues to be careful monitoring and
reporting on the results of our programs and a willingness to make mid-course adjustments.
As the State looks to 2030 and beyond, all sectors of the economy must benefit from these
ideas to create a new and better future.
OF TOTAL U.S. INVESTMENT IN
CLEAN TRANSPORTATION
50%
OF THE ZEVs
IN THE U.S.
California is home to
OF NORTH AMERICAN
40%
INVESTMENTS
CLEAN FUEL
&&90%NEARLYPROJECTIONS
20132011 2015 2019 20212017 20252023
0
500,000
1 M
1.5 M
2 M
2.5 M
3 M
3.5 M
Navigant Research
Bloomberg New Energy Finance
U.S. Energy Information Administration
Minimum Compliance Scenario
Historical Data
Edison Electric Institute Experience has shown clean technology and markets continue to outpace expectations.
CumulativE California ZEv salEs projEC tions
ES6
The benefits of innovative technologies need to reach
all residents and businesses. Air pollution reductions
and the associated health benefits should be targeted
to communities where they are needed most. All
Californians need access to clean transportation
options that enable healthy communities to develop
and thrive, including walking, cycling, transit, rail, and
clean vehicle options.
Although GHG reductions can help to reduce harmful
air pollution, California must concurrently employ
other strategies to accelerate reductions of pollutants
from large industrial sources that adversely impact
communities. Newly passed AB 617 strengthens
existing criteria and toxic air pollutant programs and
our partnerships with local air districts to further reduce
harmful air pollutants and protect communities. More
fundamentally, AB 617 establishes a comprehensive statewide program – the first of its kind – to address air pollution where it matters most: in neighborhoods with the most heavily polluted air.
C alifornia’s goals
California’s environmental justice and equity movement is establishing a blueprint for
the nation and world. The State is pioneering targeted environmental and economic
development programs to help those most in need. So far, half of all California Climate
Investments, stemming from the State’s Cap-and-Trade-Program, have been used to
provide benefits in the 25 percent of California communities that are most disadvantaged
by environmental and socio-economic burdens. By increasingly engaging with, and investing in, these communities – investing in technical assistance resources, holding listening sessions, improving our programs, and accelerating our efforts to bring the cleanest technologies to mass market – all California residents can have clean air to breathe, clean water to drink, and opportunities to participate in the cleaner economy.
SAVE WATERMAKE CALIFORNIA
MORE RESILIENT
CREATE JOBSSUPPORT
VULNERABLE
COMMUNITIES
TRANSFORM TO A
CLEAN ENERGY ECONOMY
GIVE CONSUMERS
CLEAN ENERGY CHOICES
Principles
DRAFT
aChiEving suCCEss in Equity and aCCEss
• Continue to engage local organizations and invest in disadvantaged
communities to ensure broad access to clean technologies;
• Ensure air pollution reductions happen where they are needed the most;
• Integrate across programs and agencies to ensure complementary policies
provide maximum benefits to disadvantaged communities;
• Implement California Energy Commission and CARB recommendations
to overcome barriers to clean energy and clean transportation options for
low-income residents;
• Provide energy-efficient affordable housing near job centers and transit; and
• Implement AB 617 to dramatically improve air quality in local communities
through targeted action plans.
lEgislativE lEadErship on ClimatE
The California Legislature has shaped the State’s
climate change program, setting out clear policy
objectives over the next decade:
• 40% reduction in GHG emissions by 2030;
• 50% renewable electricity;
• Double energy efficiency savings;
• Support for clean cars;
• Integrate land use, transit, and affordable
housing to curb auto trips;
• Prioritize direct reductions;
• Identify air pollution, health, and social
benefits of climate policies;
• Slash “super pollutants”;
• Protect and manage natural and working lands;
• Invest in disadvantaged communities; and
• Strong support for Cap-and-Trade.
ES7
Enhance Industrial Efficiency & Competitiveness
California leads the country in manufacturing and industrial efficiency. For every dollar spent on electricity, our manufacturers produce 55 percent more value than the national average. And the efficiency of California industry continues to grow at rates faster than the
national average. High efficiency rates, coupled with the Cap-and-Trade Program’s firm
emission cap, allow economic activity to increase without
corresponding increases in GHG emissions. In other words,
the more California produces, the better it is for the planet.
Maintaining and extending our successful programs –
from the Cap-and-Trade Program and Low Carbon Fuel
Standard to zero-emission, renewable energy and energy
efficiency programs – will reduce GHGs, increase energy
cost savings, offer businesses flexibility to reduce emissions
at low cost and provide clear policy and market direction,
and certainty, for business planning and investment.
This will encourage continued research, evaluation, and deployment of innovative strategies and technology to further reduce emissions in the industrial sector through advances in energy efficiency and productivity, increased access to cleaner fuels, and carbon capture, utilization and
storage.
aCtion on hfCs
Hydrofluorocarbons (HFCs) represent one of
the biggest opportunities to reduce GHGs
in the State through 2030 due to their high
climate impacts, and in many cases, offer energy efficiency and financial savings, as well. The world recently agreed to phase down their use, but California has committed to move more quickly, in line with the scope of
the opportunity for cost-effective emissions
reductions in the State.
aChiEving suCCEss in industrial EffiCiEnCy and CompEtitivEnEss
• Evaluate and implement policies and measures to continue reducing GHG,
criteria, and toxic air contaminant emissions from sources such as refineries;
• Improve productivity and strengthen economic competitiveness by further
improving energy efficiency and diversifying fuel supplies with low carbon
alternatives;
• Prioritize procurement of goods that have lower carbon footprints
• Support and attract industry that produces goods needed to reduce GHGs; and
• Cut energy costs and GHG emissions by quickly transitioning to efficient
HFC alternatives.
ES8
Prioritize Transportation Sustainability
California’s transportation system underpins our economy. The extensive freight
system moves trillions of dollars of goods each year and supports nearly one-third of
the state economy and more than 5 million jobs. The way we plan our communities
impacts everything from household budgets to infrastructure needs, productivity lost
to congestion, protection of natural and working landscapes, and our overall health and
well-being. And transportation is the largest source of GHG, criteria, and toxic diesel
particulate matter emissions in the state.
California’s ability to remain an economic
powerhouse and environmental leader
requires additional efforts to improve
transportation sustainability with a
comprehensive approach that includes
regulation, incentives, and investment.
This approach addresses a full range of transportation system improvements relating to efficient land use, affordable housing, infrastructure for cyclists and pedestrians, public transit, new vehicle technologies, fuels and freight. One example is the deployment of the nation’s first high-speed rail system, which will include seamless connections to local transit.
The approach is working: California is home to nearly half of the country’s zero-emission vehicles. Innovative alternative fuel producers and oil companies are bringing more low carbon fuels to market than required by the Low Carbon Fuel Standard. And, the State
has committed to investing billions in zero-emission vehicles and infrastructure, land use
planning, and active transportation options such as walking and biking. In fact, renewable
fuels in the heavy-duty vehicle sector are displacing diesel fossil fuel as quickly as
renewable power is replacing fossil fuels on the electricity grid. California’s climate policies
will also reduce fossil fuel use and decouple the state from volatile global oil prices.
CARB’s analyses show fossil fuel demand will decrease by more than 45 percent by 2030,
which means Californians will be using less gasoline and diesel resulting in healthier air and
cost-savings on transportation fuels. These benefits will be further amplified as we move
away from light-duty combustion vehicles.
By re-doubling our efforts, California can make sure that markets tip quickly and
definitively in the favor of electric cars, trucks, buses, and equipment, while increasing the
use of clean, low carbon fuels where zero-emissions options are not yet available. Local
transportation planning can make communities become healthier and more vibrant and
connected – encouraging housing, walking, biking and transit policies that reduce GHGs
and promote good quality of life. And, we can work to ensure that an efficient sustainable
freight system continues to power our ever-growing economy.
DRAFT
RENEWABLE DIESEL USE
Source: CARB
has increased 7000% since 2011
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Achieving SucceSS in TrAnSporTATion SuSTAinAbiliT y
• Connect California’s communities with a state-of-the-art high-speed rail system;
• Promote vibrant communities and landscapes through better planning efforts
to curb vehicle-miles-traveled and increase walking, biking and transit;
• Build on the State’s successful regulatory and incentive-based policies to
quickly make clean cars, trucks, buses, and fuels definitive market winners;
• Coordinate agency activities to ensure that emerging automated and
connected vehicle technologies reduce emissions; and
• Improve freight and goods movement efficiency and sustainability to enable
California’s continued economic growth.
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Continue Leading on Clean Energy
California is well ahead of schedule in meeting its renewable energy targets. Wind
and solar generation have grown exponentially in recent years, while hydroelectric, geothermal, and biomass have consistently contributed renewable power to our energy supply. Californians are the ones who will take action to meet energy efficiency targets, integrate renewable power through demand response, and drive demand for net zero energy buildings. This includes self-generation which also grew exponentially in recent
years with installed solar totaling 2,000 megawatts (MW) in 2014 and 5,100 MW of the
total statewide self-generation installed solar in 2015. By June 2017, solar installed in
California was about 5,800 MW, far exceeding the State’s goals.
1983 1990 2000 2010 2016GWh 0
10,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
SOLAR
WIND
GEOTHERMAL
SMALL HYDRO
BIOMASS
Increasing Renewable Electricity Generation (In-State and Out-of State)inCrEasing rEnEwablE ElECtriCity gEnEration (in & out of state)
The Renewable Portfolio Standard, Carbon Pricing, and lower costs for renewable technology are delivering real environmental benefits.
ES11
While at this time natural gas is an important energy source, we must move toward
cleaner heating fuels and replicate the progress underway for electricity. As with
electricity, this starts with efficiency and demand reduction, including building and
appliance electrification where these advancements make sense. It calls for minimizing
fugitive methane leaks throughout the system, including beyond California’s borders
where 90 percent of the natural gas used here originates. And, it includes using more
renewable gas – a valuable in-state resource made from waste products – especially in the
transportation sector. Replacing fossil fuels with renewable gas can reduce potent short-
lived climate pollutants, and state policies should support this effort. Reducing demand
for natural gas, and moving toward renewable natural gas, will help California achieve its 2030 climate target. However, switching from natural gas to electricity – where feasible and demonstrated to reduce GHGs – is needed to stay on track to achieve our long-term goals.
50% GOAL33% GOAL
20302020
Reaching California’s Clean Electricity Goals
29% PROGRESS
2016
aChiEving suCCEss in ClEan EnErgy
• Effectively integrate at least 50 percent renewables as the primary source of
power in the State through coordinated planning, additional deployments of
energy storage, and grid regionalization;
• Utilize distributed resources and engage customers by making net zero energy
buildings standard, implement Existing Buildings Energy Efficiency Action
Plan to double existing building efficiency, and increase access to energy
efficiency, renewable energy, and energy use data; and
• Reduce the use of heating fuels while concurrently making what is used cleaner
by minimizing fugitive methane leaks, prioritizing natural gas efficiency and
demand reduction, and enabling cost-effective access to renewable gas.
The State’s 3 largest investor-owned utilities are on track to achieve a 50% RPS by 2020.
ES12
aChiEving suCCEss in putting wastE rEsourCEs to bEnEfiCial usE
• Develop and implement programs, including edible food waste recovery,
to divert organics from landfills and reduce methane emissions;
• Develop and implement a packaging reduction program; and
• Identify a sustainable funding mechanism to support waste management
programs, including infrastructure development to support organics diversion.
Put Waste Resources to Beneficial Use
Effectively managing waste streams is perhaps the most basic of environmental tenets.
“Reduce, re-use, and recycle” is a mantra known even to elementary school students.
For decades California law has reduced waste reaching landfills and recaptured value
from waste streams through recycling and composting. California law requires reducing,
recycling, or composting 75 percent of solid waste generated by 2020. The State also has specific goals for diverting organic waste, which decomposes in landfills to produce the super pollutant methane. State law also directs edible food to hungry families rather than having it discarded.
Capturing value from waste makes sense. As described in the Healthy Soils Initiative, compost from organic matter provides soil amendments to revitalize farmland, reduces irrigation and landscaping water demand, and potentially increases long-term carbon storage in rangelands. Organic matter can also provide a clean, renewable energy source
in the form of bioenergy, biofuels, or renewable natural gas.
California should take ownership of its waste and adhere to a waste “loading order” that prioritizes waste reduction, re-use, and material recovery over landfilling. The State can take steps to reduce waste from packaging, which constitutes about one-quarter
of California’s waste stream. It can invest in and streamline in-state infrastructure
development to support recycling, remanufacturing, composting, anaerobic digestion,
and other beneficial uses of organic waste. And, it can help communities in their efforts to
recover food for those in need.
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Support Resilient Agricultural and Rural
Economies and Natural and Working Lands
California’s natural and working landscapes, like forests and farms, are home to the
most diverse sources of food, fiber, and renewable energy in the country. They underpin
the state’s water supply and support clean air, wildlife habitat, and local and regional
economies. They are also the frontiers of climate change. They are often the first to
experience the impacts of climate change, and they hold the ultimate solution to
addressing climate change and its impacts. In order to stabilize the climate, natural and
working lands must play a key role.
Work to better quantify the carbon stored in natural and working
lands is continuing, but given the long timelines to change
landscapes, action must begin now to restore and conserve these
lands. We should aim to manage our natural and working lands in
California to reduce GHG emissions from business-as-usual by at
least 15-20 million metric tons in 2030, to complement the measures
described in this Plan.
Natural and working lands can be better incorporated into California’s
climate change mitigation efforts by encouraging collaboration with
local and regional organizations and increasing investment to protect,
enhance, and innovate in our rural landscapes and communities.
The State is partnering with tribes to preserve carbon, protect tribal
forest lands and increase their land base. Transportation and land use planning should minimize the footprint of the built environment, while supporting and investing in efforts to restore, conserve and strengthen natural and working lands. California’s forests should be healthy carbon sinks that minimize black carbon emissions
where appropriate, supply new markets for woody waste and non-
merchantable timber, and provide multiple ecosystem benefits.
Rehabilitating and strengthening wetlands and tidal environments, and incorporating
natural landscapes into urban environments will also help make natural and working lands
part of the state’s climate solution. Finally, California farmers can be a powerful force in
the fight against climate change, in how they manage their lands, tend their crops, and
husband their livestock.
aChiEving suCCEss in supporting rEsiliEnt agriCultural and rural EConomiEs and natural and working l ands
• Protect, enhance and innovate on California’s natural and working lands to
ensure natural and working lands become a net carbon sink over the long-term;
• Develop and implement the Natural and Working Lands Implementation Plan
to maintain these lands as a net carbon sink and avoid at least 15-20 metric
tons of GHG emissions by 2030;
• Measure and monitor progress by completing CARB’s Natural and Working
Lands Inventory and implementing tracking and performance monitoring
systems; and
• Unleash opportunity in the agricultural sector by improving manure
management, boosting soil health, generating renewable power, electrifying
operations, utilizing waste biomass, and increasing water, fertilizer, and energy
use efficiency to reduce super pollutants.
Improved forest management on
tribal lands has preserved almost
3 million metric tons of carbon in
California and the revenues from the
carbon offsets have been used to
secure ownership of ancestral lands.
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thE watEr-EnErgy nExus
• About 12% of the total energy
used in the state is related to water,
with 2% for conveyance, treatment
and distribution, and 10% for
end-customer uses like heating
and cooling.
• The water-energy nexus provides
opportunities for conservation
of these natural resources as well as
reduction of GHGs.
aChiEving suCCEss in sECuring California’s watEr suppliEs
• Increase water savings by certifying innovative technologies for water
conservation and developing and implementing new conservation targets,
updated agricultural water management plans, and long term conservation
regulations;
• Develop a voluntary registry for GHG emissions from energy use associated
with water; and
• Continue to increase the use of renewable energy to operate the State
Water Project.
Secure California’s Water Supplies
Water is California’s lifeblood. It sustains communities and drives the economy. An
elaborate network of storage and delivery systems has enabled the state to prosper and
grow. But this aging system was built for a previous time and is increasingly challenged by
the realities of climate change and population growth.
Producing, moving, heating and treating water demands
significant energy and produces commensurately significant
emissions. As California looks to the future, meeting new
demands and sustaining prosperity requires increased water
conservation and efficiency, improved coordination and
management of various water supplies, greater understanding of
the water-energy nexus, and deployment of new technologies in
drinking water treatment, groundwater remediation and recharge,
and potentially brackish and seawater desalination. State efforts
must support systemic shifts toward conservation, efficiency, and renewable energy in the water sector.
ES15
Climate Plan Provides Health Benefits in 2030
$1.2-1.8 billion
VALUE OF AVOIDED
HEALTH IMPACTS
$1.9-11.2 billion
VALUE OF AVOIDED
DAMAGES USING
SOCIAL COST OF CARBON
3,300~
AVOIDED
PREMATURE DEATHS
Cleaning the Air and Public Health
The benefits of this
Plan are broader than
just climate change
– implementation of
the Plan will also help
improve public health.
The Plan incorporates
freight and mobile
source strategies which
will deliver reductions in criteria and toxic air pollutants to improve air quality.
California continues to seek ways to improve implementation of its climate program and its ability to address the unique set of impacts facing the state’s most pollution burdened communities. In addition, CARB’s environmental justice efforts are intended to reach far beyond climate change. While this Plan provides a path for reducing GHG emissions in disadvantaged communities, it also includes new tools that will complement the Plan and
lead to further air quality improvements.
In particular, implementation of AB 617 will improve air quality in local communities, in partnership with local air districts, using targeted investments in neighborhood-level
air monitoring and the development of air pollution reduction action plans with strong
enforcement programs. These plans will require pollution reductions from both mobile and
stationary sources. Through these efforts, CARB anticipates, and will work for, increased
data transparency and the adoption of new statewide air pollutant emission controls that
will not only confer short-term benefits to those most in need of improvement, but which
will ultimately benefit all Californians.
Under the leadership of CARB’s first executive-level environmental justice liaison,
the agency is also laying a roadmap to better serve California’s environmental justice
communities in the design and implementation across its broader programs.
ES16
Successful Example of Carbon
Pricing and Investment
The Cap-and-Trade Program is fundamental to meeting California’s long-range climate targets at low cost. The Cap-and-Trade Program includes GHG emissions from transportation, electricity, industrial, agricultural, waste, residential and commercial
sources, and caps them while complementing the other measures
needed to meet the 2030 GHG target. Altogether, the emissions
covered by the Cap-and-Trade program total 80 percent of all
GHG emissions in California. California’s response to climate
change has led to many innovative programs designed to reduce
GHG emissions, including the Renewable Portfolio and Low
Carbon Transportation Standards, but the Cap-and-Trade Program
guarantees GHG emissions reductions through a strict overall
emissions limit that decreases each year, while trading provides
businesses with flexibility in their approach to reducing emissions.
The Cap-and-Trade Program also generates revenue when the
allowances to emit pollution are auctioned. Some of the revenue is returned directly to electricity ratepayers, and the rest is dedicated to reducing GHG emissions by making Legislatively directed investments in California with an emphasis on programs or projects that benefit disadvantaged and low-income communities.
Including the latest budget, approximately $5 billion has been appropriated to reduce GHG emissions, reduce air pollutant emissions where reductions are needed most, grow markets for clean technologies, and spur emissions reductions in sectors not covered by Cap-and-Trade. These investments are strengthening the economy and improving public
health – especially in the areas of the state most burdened by pollution. So far, half of the
$1.2 billion spent provides benefits to disadvantaged communities, and one-third of those
investments were made directly in those communities.
Cap-and -tradE program
• Firm, declining cap provides
highest certainty to achieve
2030 target.
• Low cost GHG emission
reductions minimize impact on
consumers and economy.
• Flexibility for businesses
• Can be linked with similar
programs worldwide.
PROCEEDS
INVESTMENTS
FIRM LIMIT ON
80% OF EMISSIONS
California’s C arbon priCing & invEstmEnts ovErviEw
ES17
California’s Cap-and-Trade Program
is the most comprehensive,
effective, and well-designed
carbon market on the planet.
Today, the Program is linked with
a similar program in Quebec and
will link with a similar program
in Ontario beginning in 2018.
Nearly 40 countries and over 20 subnational entities – altogether representing nearly a quarter of global emissions – have developed, or are developing, emissions trading
programs. Each of them looks to
California and our linked Western
Climate Initiative Partners as they
design, implement, and refine their
own programs.
Fostering Global Action
Through the State’s leadership in the Cap-and-Trade Program, innovative sector-specific
policies that are reducing technology costs and GHG emissions, and community-scale
engagement and investments to reduce GHGs and promote equity, California is playing a
significant role in addressing global climate change.
Governor Brown has stated that climate change is
the most important issue of our lifetime, and has
promoted scientifically sound approaches to address
climate change in California and beyond. He has
participated in international climate discussions at
the United Nations headquarters in New York, the
United Nations Climate Change Conference in Paris,
the Vatican, and the Climate Summit of the Americas
in Canada – calling on other subnational and national leaders to join California in the fight against climate change. He has signed climate change agreements with leaders from Chile, China, the Czech Republic, Israel, Japan, Mexico, the Netherlands, other North
American states and provinces, and Peru. He has
joined an unprecedented alliance of heads of state,
city and state leaders – convened by the World Bank
Group and International Monetary Fund – to urge
countries and companies around the globe to put a
price on carbon. And California is a founding member
of the International Zero Emission Vehicle (ZEV) Alliance, a coalition of national and
subnational governments working to accelerate the adoption of ZEVs and make all new
Nearly 30,000 projects installing efficiency measures in homes
105,000+ rebates issued for zero-emission and plug-in hybrid vehicles
16,000+ acres of land preserved or restored
6,200+ trees planted in urban areas
200+ transit agency projects funded, adding or expanding transit options
1,100+ new affordable housing units under contract
140,000+ total projects implemented
50% of projects benefiting Disadvantaged Communities ($614M)
REGIONS REPRESENT
1.20
That’s 39 % of the global economy
BILLIONPEOPLE
AND$28.8 IN GDPTRILLION
To nd out more visit: Under2MOU.org
C ap-and -tradE dollars at work (2017)
ES18
cars zero emissions. Delegations from around the world travel to Sacramento to meet with
the architects and implementers of California’s climate policies to learn how to successfully
combine strong greenhouse gas policies with a strong economy.
Perhaps most significant is the Under2Coalition. It is a global climate pact – spearheaded
by Governor Brown – among states, provinces, countries, and cities all committing to do
their part to limit the increase in global average temperatures below the dangerous levels.
Signatories commit to either reducing greenhouse gas emissions 80 to 95 percent below
1990 levels by 2050 or achieving a per capita annual emission target of less than 2 metric tons
by 2050. More than 200 jurisdictions from 38 countries and six continents have now signed
or endorsed the agreement. Together, members of the Under2Coalition represent more than
1.2 billion people and $28.8 trillion in GDP, equivalent to 39 percent of the global economy.
Unleashing the California Spirit
This Plan is a declaration of California’s path forward. It builds on the State’s successful
approach to addressing climate change and harnesses the California spirit to propel a
cleaner economy, while serving as an example for others.
But this Plan will not be successful on its own. Our collective, and individual, efforts must
reach every sector of California’s economy, and every community in the state. As California
faces the challenge of climate change, it will succeed as it always has – through open,
inclusive processes, through support of clean technology markets, and through a relentless
pursuit of a healthy California for all.
There should be no doubt that California is united in understanding the need to act, and in
the will to act. Investments in clean, low-carbon options will pay off – for the environment
and the economy. Investments and training in education and workforce development for a
lower carbon economy are a critical part of this transition.
This Plan is only the beginning. All of the measures in the Plan will be developed in
their own public process, shaped not just by the vision of this Plan, but also by the best
understanding of the technology, costs and impacts on communities – and by input from a
broad range of stakeholders and perspectives with the recognition that achieving the 2030
target is a milestone on our way to the deeper GHG reductions needed to protect the
environment and our way of life. The Plan also proposes developing a long-term funding
plan to inform future appropriations necessary to achieve our long-term targets, which will
send clear market and workforce development signals.
Climate change presents unprecedented challenges, but just as we have always done,
Californians will tackle them with innovation, inclusion and ultimately, success.
1
Chapter 1
Background
In November 2016, California Governor Edmund G. Brown affirmed California’s role in the fight against climate
change in the United States, noting, “We will protect the precious rights of our people and continue to confront
the existential threat of our time–devastating climate change.” By working to reduce the threat facing the
State and setting an example, California continues to lead in the climate arena. This Scoping Plan for Achieving
California’s 2030 Greenhouse Gas Target (Scoping Plan or 2017 Scoping Plan) identifies how the State can
reach our 2030 climate target to reduce greenhouse gas (GHG) emissions by 40 percent from 1990 levels, and
substantially advance toward our 2050 climate goal to reduce GHG emissions by 80 percent below 1990 levels.
By selecting and pursuing a sustainable and clean economy path for 2030, the State will continue to successfully
execute existing programs, demonstrate the coupling of economic growth and environmental progress, and
enhance new opportunities for engagement within the State to address and prepare for climate change.
This Scoping Plan builds on and integrates efforts already underway to reduce the State’s GHG, criteria
pollutant, and toxic air contaminant emissions. Successful implementation of existing programs has put
California on track to achieve the 2020 target. Programs such as the Low Carbon Fuel Standard and
Renewables Portfolio Standard are delivering cleaner fuels and energy, the Advanced Clean Cars Program has put more than a quarter million clean vehicles on the road, and the Sustainable Freight Action Plan will result in efficient and cleaner systems to move goods throughout the State. Enhancing and implementing these ongoing efforts puts California on the path to achieving the 2030 target. This Scoping Plan relies on these, and other, foundational programs paired with an extended, more stringent Cap-and-Trade Program,
to deliver climate, air quality, and other benefits.
In developing this Scoping Plan, it is paramount that we continue to build on California’s success by taking effective actions. We must rapidly produce real results to avoid the most catastrophic impacts of climate change. The Scoping Plan identifies policies based on solid science and identifies additional research needs,
while also recognizing the need for flexibility in the face of a changing climate. Ongoing research to better
understand systems where our knowledge is weaker will allow for additional opportunities to set targets and
identify actionable policies. Further, a long-term funding plan to inform future appropriations is critical to
achieve our long-term targets, which will send clear market and workforce development signals.
Climate Legislation and Directives
California has made progress on addressing climate change during periods of both Republican and Democratic national and State administrations. California’s governors and legislature prioritize public health and the environment. A series of executive orders and laws have generated policies and actions across State government, among local and regional governments, and within industry. These policies also have encouraged collaboration with federal agencies and spurred partnerships with many jurisdictions beyond
California’s borders. Moving forward, California will continue its pursuit of collaborations and advocacy for
action to address climate change. The following list provides a summary of major climate legislation and
executive orders that have shaped California’s climate programs.
Assembly Bill 32 (AB 32) (Nuñez, Chapter 488, Statutes of 2006), the California Global
Warming Solutions Act of 2006.
• Cut the State’s GHG emissions to 1990 levels by 2020 with
maintained and continued reductions post 2020.
• First comprehensive climate bill in California, a defining moment in the State’s long history of environmental stewardship.
I ntroduct I on
2
• Secured the State’s role as a national and global leader in reducing GHGs.
Pursuant to AB 32, the California Air Resources Board (CARB or Board) prepared and adopted the initial Scoping Plan to “identify and make recommendations on direct emissions reductions measures, alternative
compliance mechanisms, market-based compliance mechanisms, and potential monetary and non-monetary
incentives” in order to achieve the 2020 goal, and to achieve “the maximum technologically feasible and
cost-effective GHG emissions reductions” by 2020 and maintain and continue reductions beyond 2020. AB 32
requires CARB to update the Scoping Plan at least every five years.
Executive Order B-30-15
In his January 2015 inaugural address, Governor Brown identified actions in five key climate change strategy “pillars” necessary to meet California’s ambitious climate change goals. These five pillars are:
• Reducing today’s petroleum use in cars and trucks by up to 50 percent.
• Increasing from one-third to 50 percent our electricity derived from renewable sources.
• Doubling the efficiency savings achieved at existing buildings and making heating fuels cleaner.
• Reducing the release of methane, black carbon, and other short-lived climate pollutants.
• Managing farm and rangelands, forests, and wetlands so they can store carbon.
Consistent with these goals, Governor Brown signed Executive Order B-30-15 in April 2015:
• Establishing a California GHG reduction target of 40 percent below 1990 levels by 2030.
• Calling on CARB, in coordination with sister agencies, to update the
AB 32 Climate Change Scoping Plan to incorporate the 2030 target.
• Building out the “sixth pillar” of the Governor’s strategy–to safeguard California
in the face of a changing climate–highlighting the need to prioritize actions to
reduce GHG emissions and build resilience in the face of a changing climate.
Senate Bill 350 (SB 350) (De Leon, Chapter 547, Statutes of 2015),
Golden State Standards
• Required the State to set GHG reduction planning targets through Integrated Resource Planning in the electricity sector as a whole and among individual utilities and other electricity providers (collectively known as load serving entities).• Codified an increase in the Renewables Portfolio Standard (RPS) to 50 percent
by 20301 and doubled the energy savings required in electricity and natural
gas end uses as discussed in the Governor’s inaugural address.
Senate Bill 32 (SB 32) (Pavley, Chapter 249, Statutes of 2016), California Global Warming
Solutions Act of 2016: emissions limit and Assembly Bill 197 (AB 197) (E. Garcia, Chapter
250, Statutes of 2016), State Air Resources Board: greenhouse gases: regulations.
SB 32 affirms the importance of addressing climate change by codifying into statute the GHG emissions
reductions target of at least 40 percent below 1990 levels by 2030 contained in Governor Brown’s Executive
Order B-30-15. The 2030 target reflects the same science that informs the agreement reached in Paris by
the 2015 Conference of Parties to the United Nations Framework Convention on Climate Change (UNFCCC),
aimed at keeping the global temperature increase below 2 degrees Celsius (°C). The California 2030 target
represents the most ambitious GHG reduction goal for North America. Based on the emissions reductions
directed by SB 32, the annual 2030 statewide target emissions level for California is 260 million metric tons of carbon dioxide equivalent (MMTCO2e).
The companion bill to SB 32, AB 197, provides additional direction to CARB on the following areas related to
the adoption of strategies to reduce GHG emissions.
• Requires annual posting of GHG, criteria, and toxic air contaminant data
throughout the State, organized by local and sub-county level for stationary
sources and by at least a county level for mobile sources.• Requires CARB, when adopting rules and regulations to achieve emissions reductions
1 http://www.cpuc.ca.gov/renewables/
3
and to protect the State’s most affected and disadvantaged communities, to
consider the social costs of GHG emissions and prioritize both of the following:
• Emissions reductions rules and regulations that result in direct
GHG emissions reductions at large stationary sources of GHG
emissions and direct emissions reductions from mobile sources.
• Emissions reductions rules and regulations that result in direct GHG
emissions reductions from sources other than those listed above.
• Directs CARB, in the development of each scoping plan, to
identify for each emissions reduction measure:
• The range of projected GHG emissions reductions that result from the measure.• The range of projected air pollution reductions that result from the measure.• The cost-effectiveness, including avoided social costs, of the measure.
CARB has begun the process to implement the provisions of AB 197. For instance, CARB is already posting GHG, criteria pollutant and toxic air contaminant data. CARB also incorporated air emissions data into a visualization tool in December 2016 in response to direction in AB 197 to provide easier access to this data.2
Senate Bill 1383 (SB 1383) (Lara, Chapter 395, Statutes of 2016), Short-lived climate
pollutants: methane emissions: dairy and livestock: organic waste: landfills
• Requires the development, adoption, and implementation
of a Short-Lived Climate Pollutant Strategy.3, 4
• Includes the following specific goals for 2030 from 2013 levels:
• 40 percent reduction in methane.
• 40 percent reduction in hydrofluorocarbon gases.
• 50 percent reduction in anthropogenic black carbon.5
Short-lived climate pollutants (SLCPs), such as black carbon, fluorinated gases, and methane, are powerful
climate forcers that have a dramatic and detrimental effect on air quality, public health, and climate change.
These pollutants create a warming influence on the climate that is many times more potent than that of
carbon dioxide. In March 2017, the Board adopted the Short-Lived Climate Pollutant Reduction Strategy (SLCP
Strategy) establishing a path to decrease GHG emissions and displace fossil-based natural gas use. Strategies include avoiding landfill methane emissions by reducing the disposal of organics through edible food recovery, composting, in-vessel digestion, and other processes; and recovering methane from wastewater treatment facilities, and manure methane at dairies, and using the methane as a renewable source of natural gas to
fuel vehicles or generate electricity. The SLCP Strategy also identifies steps to reduce natural gas leaks from
oil and gas wells, pipelines, valves, and pumps to improve safety, avoid energy losses, and reduce methane
emissions associated with natural gas use. Lastly, the SLCP Strategy also identifies measures that can reduce
hydrofluorocarbon (HFC) emissions at national and international levels, in addition to State-level action that
includes an incentive program to encourage the use of low-Global Warming Potential (GWP) refrigerants, and
limitations on the use of high-GWP refrigerants in new refrigeration and air-conditioning equipment.
Assembly Bill 1504 (AB 1504) (Skinner, Chapter 534, Statutes of 2010):
Forest resources: carbon sequestration
• Requires the Board of Forestry and Fire Protection to adopt district forest practice rules and regulations in accordance with specified policies to, among other things, assure the continuous growing and harvesting of commercial forest tree species.• Requires the Board of Forestry and Fire Protection to ensure that its rules and regulations that
govern the harvesting of commercial forest tree species consider the capacity of forest resources to
sequester carbon dioxide emissions sufficient to meet or exceed the sequestration target of 5 million
metric tons of carbon dioxide annually, as established in the first AB 32 Climate Change Scoping Plan.
2 CARB. 2016. CARB’s Emission Inventory Activities. www.arb.ca.gov/ei/ei.htm3 CARB. Reducing Short-Lived Climate Pollutants in California. www.arb.ca.gov/cc/shortlived/shortlived.htm4 Senate Bill No. 605. leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201320140SB6055 Senate Bill No.1383. leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160SB1383
4
Senate Bill 1386 (SB 1386) (Wolk, Chapter 545, Statutes of 2016): Resource conservation,
natural and working lands
• Declares it the policy of the State that protection and management of natural and working
lands, as defined, is an important strategy in meeting the State’s GHG reduction goals.
• Requires State agencies to consider protection and management of natural and working lands in
establishing policies and grant criteria, and in making expenditures, and “implement this requirement
in conjunction with the State’s other strategies to meet its greenhouse gas emissions reduction goals.”
Assembly Bill 398 (AB 398) (E. Garcia, Chapter 135, Statutes of 2017): California Global
Warming Solutions Act of 2006: market-based compliance mechanisms: fire prevention fees:
sales and use tax manufacturing exemption
• Clarifies the role of the State’s Cap-and-Trade Program from January 1, 2021, through December 31, 2030, continuing elements of the current program, but requiring CARB to make some post-2020 refinements.
• Establishes a Compliance Offsets Protocol Task Force to provide guidance to CARB in approving
new offset protocols that increase projects with direct, in-state environmental benefits.
• Establishes the Independent Emissions Market Advisory Committee to report annually on the
environmental and economic performance of the Cap-and-Trade Program and other climate policies.
• Identifies legislative priorities for allocating auction revenue proceeds, to include but not be
limited to: air toxic and criteria air pollutants from stationary and mobile sources; low- and zero-
carbon transportation alternatives; sustainable agricultural practices that promote transition to clean
technology, water efficiency, and improved air quality; healthy forests and urban greening; short-
lived climate pollutants; climate adaptation and resiliency; and climate and clean energy research.
In addition, AB 398 requires CARB to designate the Cap-and-Trade Program as the mechanism for reducing
GHG emissions from petroleum refineries and oil and gas production facilities in this update to the Scoping
Plan. With respect to local air districts, AB 398 states that it does not limit or expand the district’s existing authority, including the authority to regulate criteria pollutants and toxic air contaminants, except that it prohibits an air district from adopting or implementing a rule for the specific purpose of reducing emissions of carbon dioxide from stationary sources that are subject to the Cap-and-Trade Program.
Assembly Bill 617 (AB 617) (C. Garcia, Chapter 136, Statutes of 2017):
Nonvehicular air pollution: criteria air pollutants and toxic air contaminants.
This bill was passed as a companion to AB 398 (E. Garcia, 2017) to strengthen air quality monitoring and
reduce air pollution at a community level, in communities affected by a high cumulative burden of exposure
to pollution. CARB is required to prepare a monitoring plan by October 1, 2018, that assesses the State’s
current air monitoring network with recommendations for a set of high-priority locations around the State
to deploy community focused air monitoring systems. Local air districts must deploy air monitoring systems
in the selected high priority locations by July 1, 2019. Thereafter, CARB will evaluate and select additional
locations for community air monitoring on an annual basis. The air districts must also deploy air monitoring systems within one year of CARB’s selection of the high-priority locations. In addition to the monitoring plan, the bill requires CARB to develop a statewide strategy to reduce criteria pollutants and toxic air contaminants (TACs) in communities affected by high cumulative exposure burdens through approved community
emissions reduction programs developed by local air districts, in partnership with residents in the affected
communities; requires CARB to establish a uniform system of annual reporting of criteria pollutants and TACs
for the existing statewide air monitoring network; and expedites implementation of best available retrofit
control technology in non-attainment areas.
Tables summarizing the legislation described in this section, along with other climate related legislation and
programs are included in Appendix H and organized by sector.
5
Initial Scoping Plan and First Update to the Scoping Plan
The Initial Scoping Plan6 in 2008 presented the first economy-wide approach to reducing emissions and highlighted the value of combining both carbon pricing with other complementary programs to meet
California’s 2020 GHG emissions target while ensuring progress in all sectors. The coordinated set of policies
in the Initial Scoping Plan employed strategies tailored to specific needs, including market-based compliance
mechanisms, performance standards, technology requirements, and voluntary reductions. The Initial Scoping
Plan also described a conceptual design for a cap-and-trade program that included eventual linkage to other
cap-and-trade programs to form a larger regional trading program.
AB 32 requires CARB to update the scoping plan at least every five years. The First Update to the Scoping
Plan7 (First Update), approved in 2014, presented an update on the program and its progress toward meeting
the 2020 limit. It also developed the first vision for long-term progress beyond 2020. In doing so, the First
Update laid the groundwork for the goals set forth in Executive Orders S-3-058 and B-16-2012 9. It also
identified the need for a 2030 mid-term target to establish a continuum of actions to maintain and continue
reductions, rather than only focusing on targets for 2020 or 2050.
Building on California’s Environmental Legacy
California’s successful climate policies and programs have already delivered emissions reductions resulting
from cleaner, more fuel-efficient cars and zero emission vehicles (ZEVs), low carbon fuels, increased renewable
energy, and greater waste diversion from landfills; water conservation; improved forest management; and improved energy efficiency of homes and businesses. Beyond GHG reductions, these policies and programs also provide an array of benefits including improved public health, green jobs, and more clean
energy choices. The 2030 GHG emissions reduction target in SB 32 will ensure that the State maintains this
momentum beyond 2020, mindful of the State’s population growth and needs. This Scoping Plan identifies a
path to simultaneously make progress on the State’s climate goals as well as complement other efforts such
as the State Implementation Plans (SIPs) and community emissions reduction programs to help improve air
quality in all parts of the State.
California’s future climate strategy will require continued contributions from all sectors of the economy,
including enhanced focus on zero- and near-zero emission (ZE/NZE) vehicle technologies; continued
investment in renewables, such as solar roofs, wind, and other types of distributed generation; greater use
of low carbon fuels; integrated land conservation and development strategies; coordinated efforts to reduce
emissions of short-lived climate pollutants (methane, black carbon, and fluorinated gases); and an increased
focus on integrated land use planning to support livable, transit-connected communities and conservation of
agricultural and other lands. Requirements for GHG reductions at stationary sources complement efforts of
local air pollution control and air quality management districts (air districts) to tighten criteria and toxics air pollution emission limits on a broad spectrum of industrial sources, including in disadvantaged communities historically located adjacent to large stationary sources. Finally, meeting the State’s climate, public health, and
environmental goals will entail understanding, quantifying, and addressing emissions impacts from land use
decisions at all governmental levels.
Purpose of the 2017 Scoping Plan
This Scoping Plan incorporates, coordinates, and leverages many existing and ongoing efforts and identifies
new policies and actions to accomplish the State’s climate goals. Chapter 2 of this document includes a
description of a suite of specific actions to meet the State’s 2030 GHG limit. In addition, Chapter 4 provides
a broader description of the many actions and proposals being explored across the sectors, including the
natural resources sector, to achieve the State’s mid and long-term climate goals.
Guided by legislative direction, the actions identified in this Scoping Plan reduce overall GHG emissions
in California and deliver policy signals that will continue to drive investment and certainty in a low carbon
6 CARB. Initial AB 32 Climate Change Scoping Plan. Available at: www.arb.ca.gov/cc/scopingplan/document/adopted_scoping_plan.pdf7 CARB. First Update to the AB 32 Scoping Plan. Available at: www.arb.ca.gov/cc/scopingplan/document/updatedscopingplan2013.htm8 www.gov.ca.gov/news.php?id=18619 www.gov.ca.gov/news.php?id=17472
6
economy. This Scoping Plan builds upon the successful framework established by the Initial Scoping Plan
and First Update, while identifying new, technologically feasible, and cost-effective strategies to ensure
that California meets its GHG reduction targets in a way that promotes and rewards innovation, continues
to foster economic growth, and delivers improvements to the environment and public health, including in
disadvantaged communities. The Plan includes policies to require direct GHG reductions at some of the State’s
largest stationary sources and mobile sources. These policies include the use of lower GHG fuels, efficiency
regulations, and the Cap-and-Trade Program, which constrains and reduces emissions at covered sources.
Process for Developing the 2017 Scoping Plan
This Scoping Plan was developed in coordination with State agencies, through engagement with the
Legislature, and with open and transparent opportunities for stakeholders and the public to engage in
workshops and other meetings. Development also included careful consideration of, and coordination with,
other State agency plans and regulations, including the Cap-and-Trade Program, Low Carbon Fuel Standard (LCFS), State Implementation Plan, California Sustainable Freight Action Plan, California Transportation Plan 2040, Forest Carbon Plan, and the Short-Lived Climate Pollutant Strategy, among others.
To inform this Scoping Plan, CARB, in collaboration with the Governor’s Office and other State agencies, solicited comments and feedback from affected stakeholders, including the public, and the Environmental Justice Advisory Committee (EJAC or Committee). The process to update the 2017 Scoping Plan began with the Governor’s Office Pillar Symposia, which included over a dozen public workshops, and featured a series of
Committee and environmental justice community meetings.10
One key message conveyed to CARB during engagement with the legislature, EJAC, and environmental justice communities was the need to emphasize reductions at large stationary sources, with a particular focus on
multi-pollutant strategies for these sources to reduce GHGs and harmful criteria and toxic air pollutants that
result in localized health impacts, especially in disadvantaged communities. Other consistent feedback for
CARB included the need for built and natural infrastructure improvements that enhance quality of life, increase
access to safe and viable transportation options, and improve physical activity and related health outcomes.
Updated Climate Science Supports the Need for More Action
Climate scientists agree that global warming and other shifts in the climate system observed over the past century are caused by human activities. These recorded changes are occurring at an unprecedented rate.11
According to new research, unabated GHG emissions could allow sea levels to rise up to ten feet by the end
of this century–an outcome that could devastate coastal communities in California and around the world.12
California is already feeling the effects of climate change, and projections show that these effects will
continue and worsen over the coming centuries. The impacts of climate change have been documented by
the Office of Environmental Health Hazard Assessment (OEHHA) in the Indicators of Climate Change Report,
which details the following changes that are occurring already:13
• A recorded increase in annual average temperatures, as well as
increases in daily minimum and maximum temperatures.
• An increase in the occurrence of extreme events, including wildfire and heat waves.
• A reduction in spring runoff volumes, as a result of declining snowpack.
• A decrease in winter chill hours, necessary for the
production of high-value fruit and nut crops.
• Changes in the timing and location of species sightings, including migration
upslope of flora and fauna, and earlier appearance of Central Valley butterflies.
10 www.arb.ca.gov/cc/scopingplan/scopingplan.htm11 Cook, J., et al. 2016. Consensus on consensus: A synthesis of consensus estimates on human-caused global warming. Environmental Research Letters 11:048002 doi:10.1088/1748-9326/11/4/048002. iopscience.iop.org/article/10.1088/1748-9326/11/4/048002.12 California Ocean Protection Council. 2017. Rising Seas in California: An Update On Sea-Level Rise Science. www.opc.ca.gov/webmaster/ftp/pdf/docs/rising-seas-in-california-an-update-on-sea-level-rise-science.pdf13 Office of Environmental Health Hazard Assessment, Indicators of Climate Change (website): oehha.ca.gov/climate-change/document/indicators-climate-change-california
7
In addition to these trends, the State’s current conditions point to a changing climate. California’s recent
historic drought incited land subsidence, pest invasions that killed over 100 million trees, and water shortages
throughout the State. Recent scientific studies show that such extreme drought conditions are more likely
to occur under a changing climate.14,15 The total statewide economic cost of the 2013–2014 drought was
estimated at $2.2 billion, with a total loss of 17,100 jobs.16 In the Central Valley, the drought cost California
agriculture about $2.7 billion and more than 20,000 jobs in 2015, which highlights the critical need for
developing drought resilience.17 Drought affects other sectors as well. An analysis of the amount of water
consumed in meeting California’s energy needs between 1990 and 2012 shows that while California’s
energy policies have supported climate mitigation efforts, the performance of these policies have increased
vulnerability to climate impacts, especially greater hydrologic uncertainty.18
Several publications carefully examined the potential role of climate change in the recent California drought.
One study examined both precipitation and runoff in the Sacramento and San Joaquin River basins, and
found that 10 of the past 14 years between 2000 and 2014 have been below normal, and recent years have been the driest and hottest in the full instrumental record from 1895 through November 2014.19 In another study, the authors show that the increasing co-occurrence of dry years with warm years raises the risk of drought, highlighting the critical role of elevated temperatures in altering water availability and increasing
overall drought intensity and impact.20 Generally, there is growing risk of unprecedented drought in the
western United States driven primarily by rising temperatures, regardless of whether or not there is a clear
precipitation trend.21
According to the U.S. Forest Service report, National Insect and Disease Forest Risk Assessment, 2013–
2027,22 California is at risk of losing 12 percent of the total area of forests and woodlands in the State due to
insects and disease, or over 5.7 million acres. Some species are expected to lose significant amounts of their
total basal area (e.g., whitebark pine is projected to lose 60 percent of its basal area; and lodgepole pine is
projected to lose 40 percent). While future climate change is not modeled within the risk assessment, and
current drought conditions are not accounted for in these estimates, the projected climate changes over a 15
year period (2013-2027) are expected to significantly increase the number of acres at risk, and will increase
the risk from already highly destructive pests such as the mountain pine beetle. Extensive tree mortality is
already prevalent in California. The western pine beetle and other bark beetles have killed a majority of the ponderosa pine in the foothills of the central and southern Sierra Nevada Mountains. A recent aerial survey by the U.S. Forest Service identified more than 100 million dead trees in California.23 As there is usually a lag time between drought years and tree mortality, we are now beginning to see a sharp rise in mortality from
the past four years of drought. In response to the very high levels of tree mortality, Governor Brown issued
an Emergency Proclamation on October 30, 2015, that directed state agencies to identify and take action to
reduce wildfire risk through the removal and use of the dead trees.
14 Diffenbaugh, N., D. L. Swain, and D. Touma. 2015. Anthropogenic Warming has Increased Drought Risk in California. Proceedings of the National Academy of Sciences 112(13): 3931–3936.15 Cayan, D., T. Das, D. W. Pierce, T. P. Barnett, M. Tyree, and A. Gershunov. 2010. Future Dryness in the Southwest US and Hydrology of the Early 21st Century Drought. Proceedings of the National Academy of Sciences 107(50): 21272–21276.16 Howitt, R., J. Medellin-Azuara, D. MacEwan, J. Lund, and D. Summer. 2014. Economic Impacts of 2014 Drought on California Agriculture. watershed.ucdavis.edu/files/biblio/DroughtReport_23July2014_0.pdf.17 Williams, A. P., et al. 2015. Contribution of anthropogenic warming to California drought during 2012– 2014. Geophysical Research Letters http://onlinelibrary.wiley.com/doi/10.1002/2015GL064924/abstract.18 Fulton, J., and H. Cooley. 2015. The water footprint of California’s energy system, 1990–2012 Environmental Science & Technology 49(6):3314–3321. pubs.acs.org/doi/abs/10.1021/es505034x.19 Mann, M. E., and P. H. Gleick. 2015. Climate change and California drought in the 21st century. Proceedings of the National Academy of Sciences of the United States of America, 112(13):3858–3859. doi.org/10.1073/pnas.1503667112 .20 Diffenbaugh, N. S., D. L. Swain, and D. Touma. 2015. Anthropogenic warming has increased drought risk in California. Proceedings of the National Academy of Sciences of the United States of America. 10.1073/ pnas.1422385112. www.pnas.org/content/112/13/3931.full.pdf21 Cook, B. I., T. R. Ault, and J. E. Smerdon. 2015. Unprecedented 21st century drought risk in the American Southwest and Central Plains. Science Advances 1(1), e1400082, doi:10.1126/sciadv.1400082.22 Krist, F.J. Jr., J.R. Ellenwood, M.E. Woods, A.J. McMahan, J.P. Cowardin, D.E. Ryerson, F.J. Sapio, M.O. Zweifler, S.A. Romero. 2014. FHTET 2013 – 2027 National Insect & and Disease Forest Risk Assessment. FHTET-14-01 January 2014. Available at: http://www.fs.fed.us/foresthealth/technology/pdfs/2012_RiskMap_Report_web.pdf23 USDA. 2016. New Aerial Survey Identifies More Than 100 Million Dead Trees in California. www.usda.gov/wps/portal/usda/usdahome?contentid=2016/11/0246.xml&contentidonly=true
8
A warming climate also causes sea level to rise; first, by warming the
oceans which causes the water to expand, and second, by melting
land ice which transfers water to the ocean. Even if storms do not
become more intense or frequent, sea level rise itself will magnify the
adverse impact of any storm surge and high waves on the California
coast. Some observational studies report that the largest waves are
already getting higher and winds are getting stronger.24 Further, as
temperatures warm and GHG concentrations increase more carbon
dioxide dissolves in the ocean, making it more acidic. More acidic
ocean water affects a wide variety of marine species, including species that people rely on for food. Recent projections indicate that if no significant GHG mitigation efforts are taken, the San Francisco Bay Area may experience sea level rise between 1.6 to 3.4 feet, and
in an extreme scenario involving the rapid loss of the Antarctic ice
sheet, sea levels along California’s coastline could rise up to 10 feet
by 2100.25 This change is likely to have substantial ecological and
economic consequences in California and worldwide.26
While more intense dry periods are anticipated under warmer
conditions, extremes on the wet end of the spectrum are also
expected to increase due to more frequent warm, wet atmospheric
river events and a higher proportion of precipitation falling as rain
instead of snow. In recent years, atmospheric rivers have also been
recognized as the cause of the large majority of major floods in rivers
all along the U.S. West Coast and as the source of 30-50 percent of all precipitation in the same region.27
These extreme precipitation events, together with the rising snowline, often cause devastating floods in major river basins (e.g., California’s Russian River). It was estimated that the top 50 observed floods in the U.S. Pacific Northwest were due to atmospheric rivers.28 Looking ahead, the frequency and severity of atmospheric rivers on the U.S. West Coast will increase due to higher atmospheric water vapor that occurs
with rising temperature, leading to more frequent flooding.29, 30
Climate change can drive extreme weather events such as coastal storm surges, drought, wildfires, floods, and heat waves, and disrupt environmental systems including our forests and oceans. As GHG emissions continue
to accumulate and climate disruption grows, such destructive events will become more frequent. Several
recent studies project increased precipitation within hurricanes over ocean regions.31, 32 The primary physical
mechanism for this increase is higher water vapor in the warmer atmosphere, which enhances moisture
convergence in a storm for a given circulation strength. Since hurricanes are responsible for many of the most
extreme precipitation events, such events are likely to become more extreme. Anthropogenic warming by
24 National Research Council of the National Academy of Sciences. 2012. Sea-Level Rise for the Coasts of California, Oregon, and Washington: Past, Present, and Future. National Academies Press.25 California Ocean Protection Council. 2017. Rising Seas in California: An Update On Sea-Level Rise Science. www.opc.ca.gov/webmaster/ftp/pdf/docs/rising-seas-in-california-an-update-on-sea-level-rise-science.pdf26 Chan, F., et al. 2016. The West Coast Ocean Acidification and Hypoxia Science Panel: Major Findings, Recommendations, and Actions. California Ocean Science Trust, Oakland, California, USA.27 Dettinger, M. D. 2013. Atmospheric rivers as drought busters on the U.S. West Coast. Journal of Hydrometeorology 14:1721 1732, doi:10.1175/JHM-D-13-02.1. journals.ametsoc.org/doi/abs/10.1175/
JHM-D-13-02.1.28 Warner, M. D., C. F. Mass, and E. P. Salath´e. 2012. Wintertime extreme precipitation events along the Pacific Northwest coast: Climatology and synoptic evolution. Monthly Weather Review 140:2021–43. http://journals.ametsoc.org/doi/abs/10.1175/MWR-D-11-00197.1.29 Hagos, S. M., L. R. Leung, J.-H. Yoon, J. Lu, and Y. Gao, 2016: A projection of changes in landfalling atmospheric river frequency and extreme precipitation over western North America from the Large Ensemble CESM simulations. Geophysical Research Letters, 43 (3), 357-1363, http://onlinelibrary.wiley.com/doi/10.1002/2015GL067392/epdf.30 Payne, A. E., and G. Magnusdottir, 2015: An evaluation of atmospheric rivers over the North Pacific in CMIP5 and their response to warming under RCP 8.5. Journal of Geophysical Research: Atmospheres, 120 (21), 11,173-111,190, http://onlinelibrary.wiley.com/doi/10.1002/2015JD023586/epdf.31 Easterling, D.R., K.E. Kunkel, M.F. Wehner, and L. Sun, 2016: Detection and attribution of climate extremes in the observed record. Weather and Climate Extremes, 11, 17-27. http://dx.doi.org/10.1016/j.wace.2016.01.001.32 NAS, 2016: Attribution of Extreme Weather Events in the Context of Climate Change. The National Academies Press, Washington, DC, 186 pp. http://dx.doi.org/10.17226/21852.
Climate impaC ts at the Community level
The California Energy
Commission Cal-Adapt tool
provides information about future
climate conditions to help better
understand how climate will impact local communities.
cal-adapt.org
9
the end of the 21st century will likely cause tropical cyclones globally to become more intense on average.
This change implies an even larger percentage increase in the destructive potential per storm, assuming no
changes in storm size.33,34 Thus, the historical record, which once set our expectations for the traditional range
of weather and other natural events, is becoming an increasingly unreliable predictor of the conditions we will
face in the future. Consequently, the best available science must drive effective climate policy.
California is committed to further supporting new research on ways to mitigate climate change and how
to understand its ongoing and projected impacts. California’s Fourth Climate Change Assessment and
Indicators of Change Report will further update our understanding of the many impacts from climate
change in a way that directly informs State agencies’ efforts to safeguard the State’s people, economy, and
environment.35, 36
Together, historical data, current conditions, and future projections provide a picture of California’s changing
climate, with two important messages:
• Change is already being experienced and documented across California, and
some of these changes have been directly linked to changing climatic conditions.
• Even with the uncertainty in future climate conditions, every
scenario estimates further change in future conditions.
It is critical that California continue to take steps to reduce GHG emissions in order to avoid the worst of the
projected impacts of climate change. At the same time, the State is taking steps to make the State more
resilient to ongoing and projected climate impacts as laid out by the Safeguarding California Plan.37 The Safeguarding California Plan is being updated in 2017 to present new policy recommendations and provide a roadmap of all the actions and next steps that state government is taking to adapt to the ongoing and inevitable effects of climate change. The Draft Safeguarding California Plan38 is available and will be finalized
after workshops and public comments. California’s continuing efforts are vital steps toward minimizing the
impact of GHG emissions and a three-pronged approach of reducing emissions, preparing for impacts, and
conducting cutting-edge research can serve as a model for action.
California’s Greenhouse Gas Emissions and the 2030 Target
Progress Toward Achieving the 2020 Limit
AB 32 directs CARB to develop and track GHG emissions and progress toward the 2020 statewide
GHG target. California is on track to achieve the target while also reducing criteria pollutants and toxic
air contaminants and supporting economic growth. As shown in Figure 1, in 2015, total GHG emissions
decreased by 1.5 MMTCO2e compared to 2014, representing an overall decrease of 10 percent since peak levels in 2004. The 2015 GHG Emission Inventory and a description of the methodology updates can be accessed at: www.arb.ca.gov/cc/inventory/inventory.htm.
Per California Health and Safety Code section 38505, CARB monitors and regulates seven GHGs to reduce emissions: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and nitrogen trifluoride (NF3). The fluorinated gases are also referred to as “high global warming potential gases” (high-GWP gases). California’s annual statewide
GHG emission inventory has historically been the primary tool for tracking GHG emissions trends. Figure 1
provides the GHG inventory trend. Additional information on the methodology for the GHG inventory can
also be found at: www.arb.ca.gov/cc/inventory/data/data.htm.
33 Sobel, A.H., S.J. Camargo, T.M. Hall, C.-Y. Lee, M.K. Tippett, and A.A. Wing, 2016: Human influence on tropical cyclone intensity. Science, 353, 242-246.34 Kossin, J. P., K. A. Emanuel, and S. J. Camargo, 2016: Past and projected changes in western North Pacific tropical cyclone exposure. Journal of Climate, 29 (16), 5725-5739, https://doi.org/10.1175/JCLI-D-16-0076.1 .35 California’s Fourth Climate Change Assessment. http://resources.ca.gov/climate/safeguarding/research/36 Office of Environmental Health Hazard Assessment, Indicators of Climate Change (website): https://oehha.ca.gov/climate-change/document/indicators-climate-change-california37 California Natural Resources Agency. 2017. Safeguarding California. http://resources.ca.gov/climate/safeguarding/38 http://resources.ca.gov/climate/safeguarding/
10
Figure 1: CaliFornia ghg inventory trend
Carbon dioxide is the primary GHG emitted in California, accounting for 84 percent of total GHG emissions
in 2015, as shown in Figure 2 below. Figure 3 illustrates that transportation, primarily on-road travel, is the
single largest source of CO2 emissions in the State. Upstream transportation emissions from the refinery and
oil and gas sectors are categorized as CO2 emissions from industrial sources and constitute about 50 percent
of the industrial source emissions. When these emissions sources are attributed to the transportation sector,
the emissions from that sector amount to approximately half of statewide GHG emissions. In addition to transportation, electricity production, and industrial and residential sources also are important contributors to CO2 emissions.
Figures 2 and 3 show State GHG emission contributions by GHG and sector based on the 2015 GHG Emission Inventory. Emissions in Figure 3 are depicted by Scoping Plan sector, which includes separate categories for high-GWP and recycling/waste emissions that are otherwise typically included within other economic sectors.
Figure 2: emissions by ghg
2000 2002 2008 2010 2012 2014 2016 2018 202020062004Annual GHG Emissions (MMTCO2e)200
300
400
500
2030 Limit
2020 Limit
Total GHG Emissions
2.7% N2O
9.0% CH4
84.0% CO2
4.3% High-GWP
2015 Total Emissions
440.4 MMTCO2e
11
Figure 3: emissions by sCoping plan seCtor
In addition, CARB has developed a statewide emission inventory for black carbon in support of the SLCP
Strategy, which is reported in two categories: non-forestry (anthropogenic) sources and forestry sources.39
The black carbon inventory will help support implementation of the SLCP Strategy, but is not part of
the State’s GHG Inventory that tracks progress towards the State’s climate targets. The State’s major
anthropogenic sources of black carbon include off-road transportation, on-road transportation, residential
wood burning, fuel combustion, and industrial processes (Figure 4). The forestry category includes non-
agricultural prescribed burning and wildfire emissions.
Figure 4: CaliFornia 2013 anthropogeniC blaCk Carbon emission sourCes*
The exchange of CO2 between the atmosphere and California’s natural and working lands sector is currently
unquantified and therefore, excluded from the State’s GHG Inventory. A natural and working lands carbon
inventory is essential for monitoring land-based activities that may increase or decrease carbon sequestration
over time. CARB staff is working to develop a comprehensive inventory of GHG fluxes from all of California’s
39 Per SB 1383, the SLCP Strategy only addresses anthropogenic black carbon.
2% Recycling & Waste
California Carbon Emissions
2015 Total Emissions
440.4 MMTCO2e
11% Electricity Generation
21% Industrial
8% Agriculture
37% Transportation
In State8% Electricity Generation
Imports
9% Commercial & Residential
4% High-GWP
2013
10.7 MMTCO2e
36% Off-Road Mobile
18% On-Road Diesel
15% Fireplaces & Woodstoves
14% Fuel Combustion/Industrial
6% Miscelaneous
4% Commercial Cooking
3% Agricultural Burning
2% On-Road Brake & Tire
4% On-Road Gasoline
*Using 100-year GWP
12
natural and working lands using the Intergovernmental Panel on Climate Change (IPCC) design principles.
CARB released the Natural and Working Lands Inventory with the 2030 Target Scoping Plan Update
Discussion Draft.40 This inventory provides an estimate of GHG emissions reductions and changes in carbon
stock from some carbon pools in agricultural and natural and working lands. The CARB Natural and Working
Lands Inventory includes an inventory of carbon stocks, stock-change (and by extension GHG flux associated
with stock-change) with some attribution by disturbance process for the analysis period 2001-2010.
Disturbance processes include activities such as conversion from one land category to a different category,
fire, and harvest. The CARB Natural and Working Lands Inventory covers varieties of forests and woodlands,
grasslands, and wetlands (biomass-stock-change only). The Inventory includes default carbon densities for
croplands and urban/developed lands to facilitate stock-change estimation for natural lands that convert to cropland, natural lands that convert to developed lands, and for croplands that convert to developed lands.
Greenhouse Gas Emissions Tracking
As described above, California maintains an economy-wide GHG inventory for the State that is consistent with IPCC practices to allow for comparison of statewide GHG emissions with those at the national level and with other international GHG inventories. Statewide GHG emissions calculations use many data sources,
including data from other State and federal agencies. However, the primary source of data comes from
reports submitted to CARB through the Regulation for the Mandatory Reporting of GHG Emissions (MRR).
MRR requires facilities and entities with more than 10,000 metric tons of carbon dioxide equivalent (MTCO2e)
of combustion and process emissions, all facilities belonging to certain industries, and all electric power
entities to submit an annual GHG emissions data report directly to CARB. Reports from facilities and entities
that emit more than 25,000 MTCO2e are verified by a CARB-accredited third-party verification body. More
information on MRR emissions reports can be found at: www.arb.ca.gov/cc/reporti\ng/ghg-rep/reported-
data/ghg-reports.htm.
All data sources used to develop the GHG Emission Inventory are listed in inventory supporting
documentation at: www.arb.ca.gov/cc/inventory/data/data.htm.
Other State agencies, nonprofit organizations, and research institutions are developing and testing
methodologies and models to quantify GHG fluxes from California’s natural and working lands. CARB’s
ongoing work on the Natural and Working Lands Inventory will serve as one source of data to gauge the
scope of GHG reduction potential from California’s natural and working lands and monitor progress over
time. CARB will evaluate other data sources and methodologies to validate or support the CARB inventory or project-scale tracking. Interagency work is also underway to integrate and account for the land use and management impacts of development, transportation, housing, and energy policies.
Greenhouse gas mitigation action may cross geographic borders as part of international and subnational collaboration, or as a natural result of implementation of regional policies. In addition to the State’s existing GHG inventory, CARB has begun exploring how to build an accounting framework that also utilizes existing program data to better reflect the broader benefits of our policies that may be happening outside of
the State. For GHG reductions outside of the State to be attributed to our programs, those reductions
must be real and quantifiable, without any double counting, including claims to those reductions by other
jurisdictions. CARB is collaborating with other jurisdictions to ensure GHG accounting rules are consistent
with international best practices. Robust accounting rules will instill confidence in the reductions claimed and
maintain support for joint action across jurisdictions. Consistency and transparency are critical as we work
together with other jurisdictions on our parallel paths to achieve our GHG targets.
California’s Approach to Addressing Climate Change
Integrated Systems
The State’s climate goals require a comprehensive approach that integrates and builds upon multiple ongoing State efforts. As we address future mobility, we identify how existing efforts – such as the California Sustainable Freight Action Plan, Mobile Source Strategy, California Transportation Plan 2040, High-Speed
40 CARB. 2016. California Greenhouse Gas Inventory - Forests and Other Lands. www.arb.ca.gov/cc/inventory/sectors/forest/forest.htm
13
Rail,41 urban planning, housing, and goals for enhancement of the natural environment – can complement
each other while providing multiple environmental benefits, including air quality and climate benefits. The
collective consideration of these efforts illuminates the synergies and conflict s between policies. For example,
land disturbance due to increased renewables through utility scale wind and solar and transmission can
release GHGs from soil and disturb grasslands and rangelands that have the potential to sequester carbon.
Further, policies that support sustainable land use not only reduce vehicle miles traveled (VMT) and its related
emissions, but may also avoid land disturbance that could result in GHG emissions or loss of sequestration
potential in the natural environment. Identifying these types of trade-offs, and designing policies and
implementation strategies to support goals across all sectors, will require ongoing efforts at the local,
regional, and State level to ensure that sustainable action across both the built and natural environments help
to achieve the State’s long-term climate goals.
Promoting Resilient Economic Growth
California’s strategic vision for achieving at least a 40 percent reduction in GHG emissions by 2030 is based on the principle that economic prosperity and environmental sustainability can be achieved together. Policies, strategies, plans and regulations to reduce GHG emissions help California businesses compete in a
global economy and spur new investments, business creation, and jobs to support a clean energy economy.
California’s portfolio-based climate strategy can achieve great success when accompanied by consistent and
rigorous GHG monitoring and reporting, a robust public process, and an effective enforcement program
for the few that attempt to evade rules. The transition to a low-carbon future can strengthen California’s
economy and infrastructure and produce other important environmental benefits such as reductions in
criteria pollutants and toxic air contaminants, especially in California’s most vulnerable communities.
Actions that are presented in this Scoping Plan provide economic opportunities for the future, but progress
toward our goals is already evident today. For example, in 2015, California added more than 20,000
new jobs in the solar sector. This was more than half of the new jobs in this industry across the nation.
Employment in the clean economy grew by 20 percent between 2002 and 2012, which included the period of
economic recession around 2008.42 Shifting to clean, local, and efficient uses of energy reinvests our energy
expenditures in our local economies and reduces risks to our statewide economy associated with exposure to volatile global and national oil and gas commodity prices. Indeed, a clean economy is a resilient economy.
Successfully driving economic transition will require cleaner and more efficient technologies, policies and
incentives that recognize and reward innovation, and prioritizing low carbon investments. Enacting policies and incentives at multiple jurisdictional levels further ensures the advancement of land use and natural resource management objectives for GHG mitigation, climate adaptation, and other co-benefits. Intentional synergistic linkages between technological advances and resource stewardship can result in sustainable
development. The development and implementation of Sustainable Communities Strategies (SCSs) pursuant
to Senate Bill (SB) 375, which link transportation, housing, and climate policy, are designed to reduce per
capita GHG emissions while improving air quality and expanding transportation and housing options. This
Scoping Plan identifies additional ways, beyond SB 375, to promote the technologies and infrastructure
required to meet our collective climate goals, while also presenting the vision for California’s continuing
efforts to foster a sustainable, clean energy economy.
Increasing Carbon Sequestration in Natural and Working Lands
California’s natural and working lands make the State a global leader in agriculture, a U.S. leader in forest
products, and a global biodiversity hotspot. These lands support clean air, wildlife and pollinator habitat,
rural economies, and are critical components of California’s water infrastructure. Keeping these lands and
waters intact and at high levels of ecological function (including resilient carbon sequestration) is necessary for the well-being and security of Californians in 2030, 2050, and beyond. Forests, rangelands, farms,
41 California’s High-Speed Rail is part of the International Union of Railways (UIC) and California signed the Railway Climate Responsibility Pledge, which was commended by the Secretary of the UN Framework Convention on Climate Change as part of achieving global 2050 targets.42 California Business Alliance for a Clean Economy. 2015. Clean Energy and Climate Change Summary of Recent Analyses for California. clean-economy.org/wp-content/uploads/2015/01/Clean-Energy-Climate-
Change-Analyses_January2015.pdf
14
wetlands, riparian areas, deserts, coastal areas, and the ocean store substantial carbon in biomass and soils.
Natural and working lands are a key sector in the State’s climate change strategy. Storing carbon in trees, other vegetation, soils, and aquatic sediment is an effective way to remove carbon dioxide from the atmosphere. This Scoping Plan describes policies and programs that prioritize protection and enhancement
of California’s landscapes, including urban landscapes, and identifies next steps to ensure management
actions are taken to increase the sequestration potential of those resources. We cannot ignore the
relationships between energy, transportation, and natural working lands sectors or the adverse impacts that
climate change is having on the environment itself. We must consider important trade-offs in developing the
State’s climate strategy by understanding the near and long-term impacts of various policy scenarios and
actions on our State and local communities.
Improving Public Health
The State’s drive to improve air quality and promote community health and well-being as we address climate
change remains a priority, as it has for almost 50 years. The State is committed to addressing public health
issues, including addressing chronic and infectious diseases, promoting mental health, and protecting
communities from exposure to harmful air pollutants and toxins. Several of the strategies included in this
Plan were primarily developed to help California achieve federal and State ambient air quality standards for air pollutants with direct health impacts, but they will also deliver GHG reductions. Likewise, some climate strategies, such as GHG reduction measures that decrease diesel combustion from mobile sources, produce
air quality co-benefits in the form of concurrent reductions in criteria pollutants and toxic air contaminants.
Climate change itself is already affecting the health of our communities and is exacerbating existing health inequities. Those facing the greatest health burdens include low-income individuals and households, the
very young and the very old, communities of color, and those who have been marginalized or discriminated
against based on gender or race/ethnicity.43 Economic factors, such as income, poverty, and wealth, are
among the strongest determinants of health. Addressing climate change presents an important opportunity
to improve public health for all of California’s residents and to further our work toward making our State the
healthiest in the nation.
The major provisions of AB 617 (C. Garcia, 2017), to be completed by 2020, will ensure that as the State
seeks to advance climate policy to meet the 2030 target, we will also act locally to improve neighborhood air
quality. AB 617 requires strengthening and expanding community level air monitoring; expediting equipment
retrofits at large industrial sources that are located in areas that are in nonattainment for the federal and
State ambient air quality standards; requiring development of a statewide strategy to further reduce criteria
pollutants and toxic air contaminants in communities faced with high cumulative exposure levels; and local
air district-developed community emissions reductions plans that identify emissions reductions targets, measures, implementation schedules, and enforcement plans for these affected communities. By identifying and addressing the disproportionate impacts felt today and by planning, designing, and implementing actions for a sustainable future that considers both climate and air quality objectives, we can be part of the
solution to make public health inequities an issue of the past.
Environmental Justice
Fair and equitable climate action requires addressing the inequities that create and intensify community
vulnerabilities. The capacity for resilience in the face of climate change is driven by living conditions and
the forces that shape them. These include, but are not limited to, access to services such as health care,
healthy foods, air and water, and safe spaces for physical activity; income; education; housing; transportation;
environmental quality; and good health status. Strategies to alleviate poverty, increase access to economic
opportunities, improve living conditions, and reduce health and social inequities will result in more climate-
resilient communities. The transition to a low carbon California economy provides an opportunity to not
only reduce GHG emissions, but also to reduce emissions of criteria pollutants and air toxins, and to create a
healthier environment for all of California’s residents, especially those living in the State’s most disadvantaged communities. Policies designed to facilitate this transition and state-wide, regional, and local reductions,
43 California Department of Public Health (CDPH). 2015. The Portrait of Promise: The California Statewide Draft Plan to Promote Health and Mental Health Equity. A Report to the Legislature and the People of California by the Office of Health Equity. Sacramento, CA: California Department of Public Health, Office of Health Equity.
15
must also be appropriately tailored to address
the unique characteristics of economically
distressed communities throughout the
State’s diverse geographic regions, including
both rural and highly-urbanized areas. Equity
considerations must likewise be part of the
deliberate and thoughtful process in the design
and implementation of all policies and measures
included in the Scoping Plan. And CARB must
ensure that its ongoing engagement with
environmental justice communities will continue beyond the development of the Scoping Plan and be included in all aspects of its various air
pollution programs. Additional detail on CARB’s
efforts to achieve these goals is provided in
Chapter 5.
It is critical that communities of color, low-income
communities, or both, receive the benefits of the
cleaner economy growing in California, including
its environmental and economic benefits.
Currently, low-income customers enrolled in the
California Alternate Rates for Energy (CARE)
Program or the Family Electric Rate Assistance
(FERA) Program are also eligible to receive a
rebate under the California Climate Credit, or a credit on residential and small business electricity bills resulting from the sale of allowances received by investor-owned utilities as part of the
Cap-and-Trade Program. SB 1018 (Committee on
Budget and Fiscal Review, Chapter 39, Statutes of
2012) and other implementing legislation requires
that Cap-and-Trade Program auction monies
deposited into the Greenhouse Gas Reduction
Fund (GGRF) be used to further the purposes of
AB 32 and facilitate reduction of GHG emissions.
Investments made with these funds not only
reduce GHG emissions, but also provide other environmental, health, and economic benefits including, fostering job creation by promoting in-state GHG emissions reduction projects carried out by California workers and businesses.
Further, SB 535 (De Leon, Chapter 830, Statutes of 2012) and AB 1550 (Gomez, Chapter 369, Statutes of 2016) direct State and local agencies to make significant investments using GGRF monies to assist California’s most vulnerable communities. Under SB 535 (de León, Chapter 830, Statutes of 2012), a minimum of 25 percent of the total investments were required to benefit disadvantaged communities; of that, a minimum of 10 percent were
required to be located within and provide benefits to those communities. Based on cumulative data reported
by agencies as of March 2016, the State is exceeding these targets. Indeed, 50 percent of the $1.2 billion dollars
spent on California Climate Investments projects provided benefits to disadvantaged communities; and 34
percent of this funding was used on projects located directly in disadvantaged communities.44
Environmental Justice Advisory Committee
AB 32 calls for CARB to convene an Environmental Justice Advisory Committee (EJAC), to advise the Board
in developing the Scoping Plan, and any other pertinent matter in implementing AB 32. It requires that
the Committee be comprised of representatives from communities in the State with the most significant
exposure to air pollution, including, but not limited to, communities with minority populations or low-income
44 www.arb.ca.gov/cc/capandtrade/auctionproceeds/cci_annual_report_2017.pdf
environmental JustiCe advisory Committee
Martha Dina
Argüello
Physicians for Social
Responsibility Los Angeles
Colin Bailey The Environmental
Justice Coalition for
Water
Sacramento
Gisele Fong End Oil Los Angeles
Tom Frantz Association of Irritated
Residents Central Valley
Katie Valenzuela
Garcia (Served
until May 2017)
Oak Park Neighborhood
Association Sacramento
Sekita Grant
(Served until
June 2017)
The Greenlining
Institute Statewide
Kevin Hamilton Central California
Asthma Collaborative Central Valley
Rey León Valley LEAP Central Valley
Luis Olmedo Comité Civico Del Valle Salton Sea
Region
Kemba Shakur Urban Releaf Bay Area
Mari Rose Taruc Asian Pacific
Environmental Network Bay Area
Eleanor Torres The Incredible Edible
Community Garden Inland Empire
Monica Wilson Global Alliance for
Incinerator Alternatives Bay Area
16
populations, or both. CARB consulted 13 environmental justice and disadvantaged community representatives
for the 2017 Scoping Plan process, starting with the first Committee meeting in December 2015. In February
and April 2017, members of the California Air Resources Board held joint public meetings with the EJAC to
discuss options for addressing environmental justice and disadvantaged community concerns in the Scoping
Plan. The full schedule of Committee meetings and meeting materials is available on CARB’s website.45
Starting in July 2016, the Committee hosted a robust community engagement process, conducting 19
community meetings throughout the State. To enhance this community engagement, CARB staff coordinated
with staff from local government agencies and sister State agencies. At the community meetings, staff from
State and local agencies participated in extensive, topic-specific “world café” discussions with local groups
and individuals. The extensive dialogue between the EJAC, State agencies, and local agencies provided
community residents the opportunity to share concerns and provide input on ways California can meet its
2030 GHG target while addressing a number of environmental and equity issues.
Environmental Justice Advisory Committee Recommendations
The Committee’s recommendations for the Scoping Plan were informed by comments received at community
meetings described above and Committee member expertise. Recommendations were provided for the
sector focus areas, overarching environmental justice policy, and California Climate Investments. The
Committee also sorted their recommendations into five themes: partnership with environmental justice
communities, equity, economic opportunity, coordination, and long-term vision. Finally, the Committee
provided direction that their recommendations are intended “to be read and implemented holistically and not independently of each other.” The EJAC’s recommendations, in their entirety, are included in Appendix A and available at www.arb.ca.gov/cc/ejac/meetings/04262017/ejac-sp-recommendations033017.pdf.
The Committee’s overarching recommendations for partnership with environmental justice communities, equity, coordination, economic opportunity, and long-term vision include the following recommendations:• Encourage long-term community engagement, a culture shift in California, and neighborhood-level solutions to promote the implementation of the
State’s climate plans, using strategies identified by the Committee.
• Improve the balance of reducing GHGs and compliance costs with other AB 32 goals of improving
air quality in environmental justice communities while maximizing benefits for all Californians.
• Consider public health impacts and equity when examining issues in any sector and have CARB
conduct an equity analysis on the Scoping Plan and each sector, with guidance from the Committee.
• Develop metrics to ensure actions are meeting targets and develop contingency plans for
mitigation and adjustment if emissions increases occur as programs are implemented.
• Develop a statewide community-based air monitoring network to support regulatory
efforts and monitor neighborhood scale pollution in disadvantaged communities.• Coordinate strategies between State, federal, and local agencies for strong, enforceable, evidence-based policies to prevent and address sprawl with equity at the center.• Maximize the accessibility of safe jobs, incentives, and economic benefits for Californians and the
development of a just transition for workers and communities in and around polluting industries.
• Prioritize improving air quality in environmental justice communities and analyze
scenarios at a neighborhood scale for all California communities.
• Ensure that AB 32 economic reviewers come from various areas around the State to
represent insights on economic challenges and opportunities from those regions.
• Do not limit the Scoping Plan to examining interventions and impacts until 2030, or even 2050.
Plan and analyze on a longer-term scale to prevent short-sighted mistakes and reach the long-
term vision, as actions today and for the next 30 years will have impacts for seven generations.
• The Scoping Plan must prioritize GHG reductions and investments in California environmental justice communities first, before other California communities; and the innovation of new technologies or strategies to reach even deeper emissions cuts, whenever possible.• Convene the Committee beyond the Scoping Plan development process.
The Committee’s key Energy sector recommendations include:• Developing aggressive energy goals toward 100 percent renewable energy by 2030, including a vision for a clean energy economy, and prioritizing actions in disadvantaged communities.
45 www.arb.ca.gov/cc/ejac/ejac.htm
17
• Setting goals for green buildings.
• Enforcing GHG reduction targets for existing buildings, and providing upgrades that
enable buildings to use renewable energy technologies and water capture.
• Prioritizing and supporting community-owned technologies, such as
community-owned solar, for environmental justice communities.
Key Water sector recommendations include:
• Encouraging water conservation and recycling.
• Prioritizing safe drinking water for all.
The Committee’s key Industry sector recommendations include:
• Prioritizing direct emissions reductions in environmental justice communities.
• Replacing the Cap-and-Trade Program with a carbon tax or fee and dividend program.
• Eliminating offsets and the allocation of free allowances if the Cap-and-Trade Program continues.
• Analyze where GHG emissions are increasing and identify strategies to prevent
and reduce such emissions in environmental justice communities.
• Committing to reductions in petroleum use.
The Committee’s key Transportation sector recommendations include:
• Increasing access to affordable, reliable, clean, and safe
mobility options in disadvantaged communities.
• Community-engaged land use planning.• Maximizing electrification.• Restricting sprawl and examining transportation regionally.• Considering the development of green transportation hubs that integrate urban greening
with transportation options and implement the recommendations of the SB 350 studies.
The Committee’s key Natural and Working Lands, Agriculture, and Waste sector recommendations include:• Reducing waste and mandating that local jurisdictions manage the waste they create.
• Returning carbon to the soil.
• Not burning biomass or considering it a renewable resource.
• Supporting healthy soils as a critical element to land and waste management.
• Integrating urban forestry within local communities.
• Exploring ways to allow and streamline the process for cultural and prescribed
burning for land management and to prevent large-scale wildfires.
• Including an annual reduction of 5 million metric tons of CO2e from natural and working lands.
The Committee’s recommendations for California Climate Investments include:
• Ensuring near-term technologies do not adversely impact communities
and long-term investments move toward zero emissions.
• Requiring GGRF projects to be transformative for disadvantaged
communities as defined by each community.• Eliminating funding for AB 32 regulated entities.• Providing technical assistance to environmental justice communities so they can better access funding and resources.
• Prioritizing projects identified by communities and ensuring all applicants
have policies to protect against displacement or gentrification.
In April 2017, EJAC members provided a refined list of priority changes for the Scoping Plan from the full list
of EJAC recommendations. CARB staff responded to each priority recommendation, describing additions
to the Scoping Plan or suggested next steps for recommendations beyond the level of detail in the Plan.
Appendix A includes the Priority EJAC Recommendations with CARB Responses and full list of EJAC
Recommendations.
More information about the Committee and its recommendations on the previous Scoping Plans and this
Scoping Plan is located at: www.arb.ca.gov/ejac.
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Setting the Path to 2050
The State’s 2020 and 2030 targets have not been set in isolation. They represent benchmarks, consistent with prevailing climate science, charting an appropriate trajectory forward that is in-line with California’s role in
stabilizing global warming below dangerous thresholds. As we consider efforts to reduce emissions to meet
the State’s near-term requirements, we must do so with an eye toward reductions needed beyond 2030,
as well. The Paris Agreement – which calls for limiting global warming to well below 2 degrees Celsius and
aiming to limit it below a 1.5 degrees Celsius – frames our path forward.
While the Scoping Plan charts the path to achieving the 2030 GHG emissions reduction target, we also need
momentum to propel us to the 2050 statewide GHG target (80 percent below 1990 levels). In developing
this Scoping Plan, we considered what policies are needed to meet our mid-term and long-term goals. For
example, though Zero Net Carbon Buildings are not feasible at this time and more work needs to be done
in this area, they will be necessary to achieve the 2050 target. To that end, work must begin now to review
and evaluate research in this area, establish a planning horizon for targets, and identify implementation
mechanisms. Concurrently, we must consider and implement policies that not only deliver critical reductions
in 2030 and continue to help support the State’s long-term climate objectives, but that also deliver other
health, environmental and economic benefits. We should not just be planning to put 1.5 million ZEVs on the road by 2025 or 4.2 million on the road by 2030 – but rather, we should be comprehensively facilitating the market-wide transition to electric drive that we need to see materialize as soon as possible. This means that
we need to be working towards making all fuels low carbon as quickly as possible, even as we incrementally
ramp up volume requirements through the Low Carbon Fuel Standard. And it means that we need to support
the broad array of actions and strategies identified in Chapter 4, and new ones that may emerge – to keep
us on track to achieve deeper GHG reductions to protect the environment and our way of life. As with all
investments, the approach taken must balance risk, reward, longevity, and timing.
Figure 5 illustrates the potential GHG reductions that are possible by making consistent progress between
2020 and 2050, versus an approach that begins with the 2030 target and then makes progress toward the
2050 level included in Executive Order S-3-05. Depending on our success in achieving the 2030 target, taking
a consistent approach may be possible. It would achieve the 2050 target earlier, and together with similar
actions globally, would have a greater chance of preventing global warming of 2°C. The strategy for achieving
the 2050 target should leave open the possibility for both paths. Note that Figure 5 does not include
emissions or sequestration potential from the natural and working lands sector or black carbon.
Figure 5: plotting CaliFornia’s path Forward
2020 Target
0
100
200
300
400
500
2000 2010 2020 2030Annual GHG Emissions (MMTCO2e)2020 Target
2030 Target
2050 Target
2010 2040 2050
Executive OrderS-3-05
19
Intergovernmental Collaboration
Federal, state, Tribal, and local action can be complementary. We have seen federal action through the Clean Air Act, regulations for GHG emissions from passenger cars and trucks, development of the Clean Power Plan to limit GHGs from power plants, and the advancement of methane rules for oil and gas production. We
have also seen recent federal efforts to delay or reverse some of these actions. As we have done in the past,
California, working with other climate leaders, can take steps to advance more ambitious federal action and
protect the ability of states to move forward to address climate change. Both collaboration and advocacy will
mark the road ahead. However, to the extent that California cannot implement policies or measures included
in the Scoping Plan because of the lack of federal action, we will develop alternative measures to achieve the
reductions from the same sectors to ensure we meet our GHG reduction targets.
Regional, Tribal, and local governments and agencies are critical leaders in reducing emissions through
actions that reduce demand for electricity, transportation fuels, and natural gas, and improved natural and
working lands management. Many local governments already employ efforts to reduce GHG emissions
beyond those required by the State. For example, many cities and counties improve their municipal
operations by upgrading vehicle fleets, retrofitting government buildings and streetlights, purchasing greener
products, and implementing waste-reduction policies. In addition, they may adopt more sustainable codes, standards, and general plan improvements to reduce their community’s footprints and emissions. Many Tribes within and outside of California have engaged in consultations with CARB to develop robust carbon offset
projects under California’s Cap-and-Trade Program, in particular forest projects. In fact, Tribal forest projects
represent a significant percentage of offset credits issued under the Program. These consultations and
carbon sequestration projects are in addition to other Tribal climate-related efforts. The State will provide a
supportive framework to advance these and other local efforts, while also recognizing the need to build on,
and export, this success to other regional, Tribal, and local governments throughout California and beyond.
Local actions are critical for implementation of California’s ambitious climate agenda. State policies,
programs, and actions–such as many of those identified throughout this Scoping Plan–can help to
support, incentivize, and accelerate local actions to achieve mutual goals for more sustainable and resilient
communities. Local municipal code changes, zoning changes, or policy directions that apply broadly to the
community within the general plan or climate action plan area can promote the deployment of renewable,
zero emission, and low carbon technologies such as zero net energy buildings, renewable fuel production
facilities, and zero emission charging stations. Local decision-making has an especially important role in
achieving reductions of GHG emissions generated from transportation. Over the last 60 years, development patterns have led to sprawling suburban neighborhoods, a vast highway system, growth in automobile ownership, and under-prioritization of infrastructure for public transit and active transportation. Local
decisions about these policies today can establish a more sustainable built environment for the future.
International Efforts
California is not alone in its efforts to address climate change at the international level to reduce global
GHG emissions. The agreement reached in Paris by the 2015 Conference of Parties to the United Nations
Framework Convention on Climate Change (UNFCCC), aimed at keeping the global temperature rise below
2°C, is spurring worldwide action to reduce GHGs and support decarbonization across the global economy.
In recent years, subnational governments have emerged to take on a prominent role. With the establishment
of the Under 2 Memorandum of Understanding (MOU),46,47 the Governors’ Climate and Forests Task Force,48
and the Western Climate Initiative,49 among other partnership initiatives, subnational jurisdictions from the
around the world are collaborating and leading on how best to address climate change.
46 Under 2 MOU website: under2mou.org/ 47 One of the Brown Administration’s priorities is to highlight California’s climate leadership on the subnational level, and to ensure that subnational activity is recognized at the international level. In the year preceding the Paris negotiations, the Governor’s Office recruited subnational jurisdictions to sign onto the Memorandum of Understanding on Subnational Global Climate Leadership (Under 2 MOU), which brings together states and regions willing to commit to reducing their GHG emissions by 80 to 95 percent, or to limit emissions to 2 metric tons CO2-equivalent per capita, by 2050. The governor led a California delegation to the Paris negotiations to highlight our successful climate programs and to champion subnational action and international cooperation on meeting the challenge of reducing GHG emissions. As of October 2017, 188 jurisdictions representing more than 1.2 billion people and more than one-third of the global economy had joined California in the Under 2 MOU.48 Governors’ Climate and Forests Task Force website: www.gcftaskforce.org/49 Western Climate Initiative website: www.wci-inc.org/
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From its inception, AB 32 recognized the importance of California’s climate leadership and engagement with
other jurisdictions, and directed CARB to consult with the federal government and other nations to identify
the most effective strategies and methods to reduce GHGs, manage GHG control programs, and facilitate
the development of integrated and cost-effective regional, national, and international GHG reduction
programs. California undertook a two-pronged approach: first, we assessed our State-specific circumstances
to develop measures that would apply specifically in California; and second, we assessed which measures
might lend themselves, through careful design and collaboration with other interested jurisdictions, toward
linked or collaborative GHG reduction programs. Under the Clean Air Act, California has a special role as an
innovator and leader in the area of motor vehicle emission regulations, which allows our State to adopt motor
vehicle emission standards that are stricter than federal requirements. Partners around the country and the world emulate these motor vehicle standards, leading to widespread health benefits. Similarly, by enacting a comprehensive climate strategy that appeals to national and international partners, California can help lead the world in tackling climate change.
Today, the State’s Cap-and-Trade Program is linked with Québec’s program and scheduled to link with Ontario’s emissions trading system on January 1, 2018. Low carbon fuel mandates similar to California’s LCFS have been adopted by the United States Environmental Protection Agency (U.S. EPA) and by other
jurisdictions including Oregon, British Columbia, the European Union, and the United Kingdom. Over two-
dozen states have a renewables portfolio standard. California is a member of the Pacific Coast Collaborative
with British Columbia, Oregon, and Washington, who collaborate on issues such as energy and sustainable
resource management, among others.50 California continues to discuss carbon pricing through a cap-and-
trade program with international delegations. We have seen design features of the State’s Cap-and-Trade
Program incorporated into other emerging and existing programs, such as the European Union Emissions
Trading System, the Regional Greenhouse Gas Initiative, China’s emerging national trading program, and
Mexico’s emerging pilot emission trading program.
Recognizing the need to address the substantial GHG emissions caused by the deforestation and
degradation of tropical and other forests, California worked with a group of subnational governments to
form the Governors’ Climate and Forests Task Force (GCF) in 2008.51 The GCF is currently comprised of 38
different subnational jurisdictions– including states and provinces in Brazil, Colombia, Ecuador, Indonesia, Ivory Coast, Mexico, Nigeria, Peru, Spain, and the United States–that are contemplating or enacting programs for low-emissions rural development and reduced emissions from deforestation and land use. GCF members continue to engage in discussions to share information and experiences about the design of
such programs and how the programs could potentially interact with carbon markets. Ongoing engagement
between California and its GCF partners, as well as ongoing discussions with other stakeholders, continues to
provide lessons on how such programs could complement California’s climate programs.52
Further, California’s High-Speed Rail is part of the International Union of Railways (UIC), and California has
signed the Railway Climate Responsibility Pledge, which was commended by the Secretary of the UNFCCC
as part of achieving the global 2050 targets. This initiative is to demonstrate that rail transport is part of the
solution for sustainable and carbon free mobility.
California will continue to engage in multi-lateral forums that develop the policy foundation and technical
infrastructure for GHG regulations in multiple jurisdictions through entities such as the International Carbon
Action Partnership (ICAP), established by California and other partners in 2007. Members of the ICAP that
have already implemented or are actively pursuing market-based GHG programs53 share experiences and
knowledge. California also participates in the Partnership for Market Readiness (PMR), a multilateral World
Bank initiative that brings together more than 30 developed and developing countries to share experiences
and build capacity for climate change mitigation efforts, particularly those implemented using market
instruments.54 In November 2014, CARB became a Technical Partner of the PMR, and CARB staff members have provided technical information on the design and implementation of the Cap-and-Trade Program at several PMR meetings.
50 Pacific Coast Collaborative website: pacificcoastcollaborative.org/51 Governors’ Climate and Forests Task Force Website: www.gcftaskforce.org/ 52 Continued collaboration on efforts to reduce emissions from tropical deforestation and to evaluate sector-based offset programs, such as the jurisdictional program in Acre, Brazil, further demonstrates California’s ongoing climate leadership and fosters partnerships on mutually beneficial low emissions development initiatives, including measures to encourage sustainable supply chain efforts by public and private entities.53 International Carbon Action Partnership website: icapcarbonaction.com/ 54 Partnership for Market Readiness website: www.thepmr.org/
21
Many foreign jurisdictions seek out California’s expertise because of our history of success in addressing
air pollution and climate change. California also benefits from these interactions. Expanding global action
to fight air pollution and climate change expands markets for clean technology. This can bolster business
for companies in California developing clean energy products and services and help to bring down the cost
of those products globally and in California. Additionally, innovative policies and lessons learned from our
partners’ jurisdictions can help to inform future climate policies in California.
Governor Brown’s focus on subnational collaborations on climate change and air quality has strengthened
and deepened California’s existing international relationships and forged new ones. These relationships are
a critical component of reducing emissions of GHGs and other pollutants worldwide. As we move forward,
CARB and other State agencies will continue to communicate and collaborate with international partners
to find the most cost-effective ways to improve air quality, fight climate change, and share California’s
experience and expertise in reducing air pollution and GHGs while growing a strong economy. To highlight
the State’s resolve and support of other governments committed to action and tackling the threat of the global warming, on July 6, 2017, Governor Brown announced a major initiative to host world leaders at a Global Climate Action Summit planned for September 2018 in San Francisco.
22
This chapter describes the State strategy for meeting the 2030 GHG target (also called the Scoping Plan
Scenario), along with a short description of the four alternative scenarios, which were evaluated but ultimately
rejected when compared against statutory and policy criteria and priorities that the State’s comprehensive
climate action must deliver. All scenarios are set against the business-as-usual (BAU or Reference Scenario) scenario–what would GHG emissions look like if we did nothing beyond the existing policies that are required and already in place to achieve the 2020 limit. BAU includes the existing renewables requirements, advanced clean cars, the 10 percent reduction in carbon intensity Low Carbon Fuel Standard, and the SB 375 program
for sustainable communities, among others. However, it does not include a range of new policies or measures
that have been developed or put into statute over the past two years.
The Reference Scenario (BAU) shows continuing, but modest, reductions followed by a later rise of GHG
emissions as the economy and population grow. The comprehensive analysis of all five alternatives indicates
that the Scoping Plan Scenario–continuing the Cap-and-Trade Program–is the best choice to achieve the
State’s climate and clean air goals. It also protects public health, provides a solid foundation for continued
economic growth, and supports California’s quality of life.
All of the alternative scenarios briefly described in this chapter are the product of the Scoping Plan
development process and were informed by public input, including that from EJAC, as well as Board and
legislative direction over the course of two years. The scenarios all include a range of additional measures
developed or required by legislation over the past two years with 2030 as their target date and include:
extending the LCFS to an 18 percent reduction in carbon intensity beyond 2020, and the requirements of
SB 350 to increase renewables to 50 percent and to double energy efficiency savings. They also all include
the Mobile Source Strategy targets for more zero emission vehicles and much cleaner trucks and transit, the
Sustainable Freight Action Plan to improve freight efficiency and transition to zero emission freight handling technologies, and the requirements under SB 1383 to reduce anthropogenic black carbon 50 percent and hydrofluorocarbon and methane emissions by 40 percent below 2013 levels by 2030. The recent adoption of AB 398 into State law on July 25, 2017, clarifies the role of the Cap-and-Trade Program through December 31, 2030.
Work is still underway on how to quantify the GHG emissions within the natural and working lands sector. As such, the analyses in this chapter do not include any estimates from this sector. Additional information on the current efforts to better understand GHG emissions fluxes and model the actions needed to support
the goal of net carbon sequestration in natural and working lands can be found in Chapter 4. Even absent
quantification data, the importance of this sector in achieving the State’s climate goals should be considered
in conjunction with any efforts to reduce GHG emissions in the energy and industrial sectors.
During the development of the Scoping Plan, stakeholders suggested alternative scenarios to achieve the
2030 target. While countless scenarios could potentially be developed and evaluated, the four below were
considered, as they were most often included in comments by stakeholders and they bracket the range of
potential scenarios. Several of these alternative scenarios were also evaluated in the Initial AB 32 Scoping
Plan in 2008 (All Regulations, Carbon Tax).55 Since the adoption of the Initial AB 32 Scoping Plan, some of the
alternative scenarios have been implemented or contemplated by other jurisdictions, which has helped in the
analysis and the development of this Scoping Plan. This section provides a brief description of the alternatives.
A full description of the alternatives and staff’s AB 197 and policy analyses are included in Appendix G.
55 CARB. 2009. Initial AB 32 Climate Change Scoping Plan Document. www.arb.ca.gov/cc/scopingplan/document/scopingplandocument.htm
Chapter 2
the S copI ng p lan S cenar I o
23
Scoping Plan Scenario: Ongoing and statutorily required programs and continuing the Cap-and-Trade
Program. This scenario was modified from the January 2017 Proposed Scoping Plan to reflect AB 398,
including removal of the 20 percent refinery measure.
Alternative 1: No Cap-and-Trade. Includes additional activities in a wide variety of sectors, such as
specific required reductions for all large GHG sources, and more extensive requirements for renewable
energy. Industrial sources would be regulated through command and control strategies.
Alternative 2: Carbon Tax. A carbon tax to put a price, but not limit, on carbon, instead of the Cap-and-
Trade Program.
Alternative 3: All Cap-and-Trade. This alternative is the same as the Scoping Plan Scenario, while maintaining the LCFS at a 10 percent reduction in carbon intensity past 2020.
Alternative 4: Cap-and-Tax. This would place a declining cap on individual industrial facilities, and individual natural gas and fuel suppliers, while also requiring them to pay a tax on each metric ton of GHGs emitted.
Since the statutory direction on meeting a 2030 GHG target is clear, the issue of certainty of reductions is paramount. These alternatives vary greatly as to the certainty of meeting the target. The declining mass emissions cap under a cap-and-trade program provides certain and measurable reductions over time; a carbon
tax, meanwhile, establishes some carbon price certainty, but does not provide an assurance on reductions and
instead assumes that some degree of reductions will occur if costs are high enough to alter behavior.
There are also other considerations: to what extent does an alternative meet the target, but also deliver
clean air benefits, prioritize reductions at large stationary sources, and allow for continued investment in
disadvantaged communities? What is the cost of an alternative and what will be the impact on California
consumers? Does an alternative allow for California to link with other jurisdictions, and support the Clean
Power Plan56 and other federal and international climate programs? Does an alternative provide for flexibility
for regulated entities, and a cost-effective approach to reduce greenhouse gases?
The Scoping Plan Scenario provides a portfolio of policies and measures that balances this combination
of objectives, including the highest certainty to achieve the 2030 target, while protecting the California
economy and consumers. A more detailed analyses of the alternatives is provided in Appendix G.
Scoping Plan Scenario
The development of the Scoping Plan began by first modeling a Reference Scenario (BAU). The Reference
Scenario is the forecasted statewide GHG emissions through 2030 with existing policies and programs, but
without any further action to reduce GHGs. Figure 6 provides the modeling results for a Reference Scenario
for this Scoping Plan. The graph shows the State is expected to reduce emissions below the 2020 statewide
GHG target, but additional effort will be needed to maintain and continue GHG reductions to meet the
mid- (2030) and long-term (2050) targets. Figure 6 depicts a linear, straight-line path to the 2030 target. It
should be noted that in any year, GHG emissions may be higher or lower than the straight line. That is to be
expected as periods of economic recession or increased economic activity, annual variations in hydropower,
and many other factors may influence a single or several years of GHG emissions in the State. CARB’s annual
GHG reporting and inventory will provide data on progress towards achieving the 2030 target. More details about the modeling for the Reference Scenario can be found in Appendix D.
56 Although the Clean Power Plan is being challenged in legal and administrative processes, its requirements reflect U.S. EPA’s statutory obligation to regulate greenhouse gases from the power sector. Thus it, and other federal programs, are a key consideration for Scoping Plan development.
24
Figure 6: 2017 sCoping plan reFerenCe sCenario
The Scoping Plan Scenario is summarized in Table 1. As shown in the table, most of the measures are
identified as “known commitments” (marked with “*”), meaning that they are existing programs or required
by statute. These commitments are not part of the Reference Scenario (BAU) in Figure 6 since their passage
and implementation is related to meeting the Governor’s climate pillars, the 2030 climate target, or other
long-term climate and air quality objectives. In addition to the known commitments, the Scoping Plan Scenario includes a post-2020 Cap-and-Trade Program.Annual GHG Emissions (MMTCO2e)0
100
200
300
400
500
1990 2000 2010 2020 2030 2040 2050
REFERENCE SCENARIO (BAU)
431 MMTCO2e
2020 Target
260 MMTCO2e
2030 Target
2050 Goal
25
table 1: sCoping plan sCenario
Policy Primary Objective Highlights Implementation
Time Frame
SB 35057*
Reduce GHG emissions in
the electricity sector through
the implementation of the
50 percent RPS, doubling of
energy savings, and other
actions as appropriate to
achieve GHG emissions
reductions planning targets
in the Integrated Resource
Plan (IRP) process.
• Load-serving entities file plans to achieve GHG emissions
reductions planning targets while ensuring reliability and
meeting the State’s other policy goals cost-effectively.
• 50 percent RPS.
• Doubling of energy efficiency savings in natural gas and
electricity end uses statewide.
2030
Low Carbon
Fuel Standard
(LCFS)*
Transition to cleaner/less-
polluting fuels that have a
lower carbon footprint.
• At least 18 percent reduction in carbon intensity, as included
in the Mobile Source Strategy.2030
Mobile Source
Strategy
(Cleaner
Technology
and Fuels
[CTF]
Scenario)58*
Reduce GHGs and other
pollutants from the
transportation sector
through transition to zero-
emission and low-emission
vehicles, cleaner transit
systems and reduction of
vehicle miles traveled.
• 1.5 million zero emission vehicles (ZEV), including plug-in
hybrid electric, battery-electric, and hydrogen fuel cell vehicles
by 2025 and 4.2 million ZEVs by 2030.
• Continue ramp up of GHG stringency for all light-duty vehicles
beyond 2025.
• Reductions in GHGs from medium-duty and heavy-duty
vehicles via the Phase 2 Medium and Heavy-Duty GHG
Standards.
• Innovative Clean Transit: Transition to a suite of innovative
clean transit options. Assumed 20 percent of new urban buses
purchased beginning in 2018 will be zero emission buses with
the penetration of zero-emission technology ramped up to
100 percent of new bus sales in 2030. Also, new natural gas
buses, starting in 2018, and diesel buses, starting in 2020,
meet the optional heavy-duty low-NOX standard.
• Last Mile Delivery: New regulation that would result in the use
of low NOX or cleaner engines and the deployment of
increasing numbers of zero-emission trucks primarily for class
3-7 last mile delivery trucks in California. This measure assumes
ZEVs comprise 2.5 percent of new Class 3–7 truck sales in local
fleets starting in 2020, increasing to 10 percent in 2025.
• Reduction in vehicle miles traveled (VMT), to be achieved
in part by continued implementation of SB 375 and regional
Sustainable Community Strategies; forthcoming statewide
implementation of SB 743; and potential additional VMT
reduction strategies not specified in the Mobile Source
Strategy, but included in the document “Potential VMT
Reduction Strategies for Discussion” in Appendix C.59
Various
SB 1383*
Approve and Implement
Short-Lived Climate
Pollutant strategy60 to
reduce highly potent GHGs
• 40 percent reduction in methane and hydrofluorocarbon (HFC)
emissions below 2013 levels by 2030.
• 50 percent reduction in anthropogenic black carbon emissions
below 2013 levels by 2030.
2030
California
Sustainable
Freight Action
Plan61*
Improve freight efficiency,
transition to zero emission
technologies, and increase
competitiveness of
California’s freight system.
• Improve freight system efficiency by 25 percent by 2030.
• Deploy over 100,000 freight vehicles and equipment capable
of zero emission operation and maximize both zero and
near-zero emission freight vehicles and equipment powered by
renewable energy by 2030.
2030
Post-2020
Cap-and-Trade
Program
Reduce GHGs across largest
GHG emissions sources
• Continue the existing Cap-and-Trade Program with declining
caps to ensure the State’s 2030 target is achieved.
* These measures and policies are referred to as “known commitments.”
57 58 5960 61
57 SB 350 Clean Energy and Pollution Reduction Act of 2015 (De León, Chapter 547, Statutes of 2015). leginfo.legislature.ca.gov/faces/
billNavClient.xhtml?billid=201520160SB350 This policy also includes increased demand response and PV.58 CARB. 2016. 2016 Mobile Source Strategy. www.arb.ca.gov/planning/sip/2016sip/2016mobsrc.pdf59 CARB. Potential State-Level Strategies to Advance Sustainable, Equitable Communities and Reduce Vehicle Miles of Travel (VMT)-- for Discussion. www.arb.ca.gov/cc/scopingplan/meetings/091316/Potential%20VMT%20Measures%20For%20Discussion_9.13.16.pdf60 CARB. 2016. Reducing Short-Lived Climate Pollutants in California. www.arb.ca.gov/cc/shortlived/shortlived.htm61 State of California. California Sustainable Freight Action Plan website. www.casustainablefreight.org/
26
Table 2 summarizes the results of the modeling for the Reference Scenario and known commitments. Per SB
32, the 2030 limit is 260 MMTCO2e. That is a limit on total GHG emissions in a single year. At approximately
389 MMTCO2e, the Reference Scenario is expected to exceed the 2030 limit by about 129 MMTCO2e.
Table 2 also compares the Reference Scenario 2030 emissions estimate of 389 MMTCO2e to the 2030
target of 260 MMTCO2e and the level of 2030 emissions with the known commitments, estimated to be 320
MMTCO2e. And, in the context of a linear path to achieve the 2030 target, there is also a need to achieve
cumulative emissions reductions of 621 MMTCO2e from 2021 to 2030 to reach the 2030 limit. While there
is no statutory limit on cumulative emissions, the analysis considers and presents some results in cumulative
form for several reasons. It should be recognized that policies and measures may perform differently over
time. For example, in early years, a policy or measure may be slow to be deployed, but over time it has
greater impact. If you were to look at its performance in 2021 versus 2030, you would see that it may not
seem important and may not deliver significant reductions in the early years, but is critical for later years as
it results in greater reductions over time. Further, once GHGs are emitted into the atmosphere, they can have long lifetimes that contribute to global warming for decades. Policies that reduce both cumulative GHG emissions and achieve the single-year 2030 target provide the most effective path to reducing climate change impacts. A cumulative construct provides a more complete way to evaluate the effectiveness of any
measure over time, instead of just considering a snapshot for a single year.
table 2: 2030 modeling ghg results For the reFerenCe sCenario and
known Commitments
Modeling
Scenario
2030 GHG
Emissions
(MMTCO2e)
Cumulative GHG
Reductions 2021–
2030 (MMTCO2e)
Cumulative Gap
to 2030 Target
(MMTCO2e)
Reference Scenario
(Business-as-Usual)389 n/a 621
Known Commitments 320 385 236
As noted above, the known commitments are expected to result in emissions that are 60 MMTCO2e above
the target in 2030, and have a cumulative emissions reduction gap of about 236 MMTCO2e. This means the
known commitments do not decline fast enough to achieve the 2030 target. The remaining 236 MMTCO2e
of estimated GHG emissions reductions would not be achieved unless further action is taken to reduce
GHGs. Consequently, for the Scoping Plan Scenario, the Post-2020 Cap-and-Trade Program would need to
deliver 236 MMTCO2e cumulative GHG emissions reductions from 2021 through 2030. If the estimated GHG
reductions from the known commitments are not realized due to delays in implementation or technology
deployment, the post-2020 Cap-and-Trade Program would deliver the additional GHG reductions in
the sectors it covers to ensure the 2030 target is achieved. Figure 7 illustrates the cumulative emissions
reductions contributions of the known commitments and the Cap-and-Trade Program from 2021 to 2030.
Post-2020 Cap-and-Trade Program with Declining Caps
This measure would continue the Cap-and-Trade Program post-2020 pursuant to legislative direction in AB
398. The program is up and running and has a five-year-long record of auctions and successful compliance.
In the face of a growing economy, dry winters, and the closing of a nuclear plant, it is delivering GHG
reductions. This is not to say that California should continue on this road simply because the Cap-and-Trade
Program is already in place. The analyses in this chapter, and the economic analysis in Chapter 3, clearly demonstrate that continuing the Cap-and-Trade Program through 2030 will provide the most secure, reliable, and feasible clean energy future for California–one that will continue to deliver crucial investments to improve the quality of life and the environment in disadvantaged communities.
Under this measure, funds would also continue to be deposited into the Greenhouse Gas Reduction Fund (GGRF) to support projects that fulfill the goals of AB 32, with AB 398 identifying a list of priorities for the Legislature to consider for future appropriations from GGRF. Investment of the Cap-and-Trade Program
proceeds furthers the goals of AB 32 by reducing GHG emissions, providing net GHG sequestration,
providing co-benefits, investing in disadvantaged communities and low-income communities, and
supporting the long-term, transformative efforts needed to improve public and environmental health and
27
develop a clean energy economy. These investments support programs and projects that deliver major
economic, environmental, and public health benefits for Californians. Importantly, prioritized investments in
disadvantaged communities are providing a multitude of meaningful benefits to these communities some of
which include increased affordable housing opportunities, reduced transit and transportation costs, access to
cleaner vehicles, improved mobility options and air quality, job creation, energy cost savings, and greener and
more vibrant communities.
Further, the Cap-and-Trade Program is designed to protect electricity and natural gas residential ratepayers
from higher energy prices. The program includes a mechanism for electricity and natural gas utilities to
auction their freely allocated allowances, with the auction proceeds benefiting ratepayers. The Climate Credit
is a twice-annual bill credit given to investor-owned utility electricity residential customers. The total value of
the Climate Credit for vintage 2013 auction allowances alone was over $400 million. The first of these credits
appeared on customer bills in April 2014.62 Currently, natural gas utilities are permitted to use a portion of
their freely allocated allowances to meet their own compliance obligations; however, over time, they must consign a larger percentage of allowances and continue to provide the value back to customers.
Additionally, under this measure, the State would preserve its current linkages with its Canadian partners
and support future linkages with other jurisdictions, thus facilitating international action to address climate change. The high compliance rates with the Cap-and-Trade Program also demonstrate that the infrastructure and implementation features of the program are effective and understood by the regulated community. This measure also lends itself to integration with the Clean Power Plan requirements and is flexible to allow
expansion to other sectors or regions.
In late 2017, CARB began evaluating changes to program design features for post-2020 in accordance with AB 398.63 This includes changes to the offset usage limit, direction on allocation, two price containment
points, and a price ceiling – which, if in the unlikely event were to be accessed, must result in GHG reductions
by compensating for any GHG emissions above the cap, ensuring the environmental integrity of the program.
Changes to conform to the requirements of AB 398 will be subject to a public process, coordinated with
linked partners, and be part of a future rulemaking that would take effect by January 1, 2021.
62 www.arb.ca.gov/cc/capandtrade/allowanceallocation/edu-v2013-allowance-value-report.pdf63 www.arb.ca.gov/cc/capandtrade/meetings/20171012/ct_presentation_11oct2017.pdf
28
Figure 7: sCoping plan sCenario – estimated Cumulative ghg reduCtions
by measure (2021–2030)64
The Scoping Plan Scenario in Figure 7 represents an expected case where current and proposed GHG
reduction policies and measures begin as expected and perform as expected, and technology is readily
available and deployed on schedule. An Uncertainty Analysis was performed to examine the range of
outcomes that could occur under the Scoping Plan policies and measures. The uncertainty in the following factors was characterized and evaluated:• Economic growth through 2030;• Emission intensity of the California economy;
• Cumulative emissions reductions (2021 to 2030) achieved by the
prescriptive measures, including the known commitments; and
• Cumulative emissions reductions (2021 to 2030) that can be motivated
by emission prices under the Cap-and-Trade Program.
The combined effects of these uncertainties are summarized in Figure 8. As shown in Figure 7, the Scoping
Plan analysis estimates that the prescriptive measures will achieve cumulative emissions reductions of 385
MMTCO2e, the Cap-and-Trade Program will achieve 236 MMTCO2e, resulting in total cumulative emissions
reductions of 621 MMTCO2e. These values are again reflected in the bar on the left of Figure 8. The results of
the Uncertainty Analysis are summarized in the three bars on the right of the figure as follows:
• The cumulative emissions reductions required to achieve the 2030 emission limit has
the potential to be higher or lower than the Scoping Plan estimate. The uncertainty
analysis simulates an average required emissions reductions of about 660 MMTCO2e with a range of +130 MMTCO2e.65 This estimate and the range are shown in Figure 8 as the bar on the right. Notably, the estimate of the average required emissions reductions is 40 MMTCO2e greater than the estimate in the Scoping Plan analysis.
• The prescriptive measures have the potential to underperform relative to expectations. Based on
CARB staff assessments of the potential risk of underperformance of each measure, the average
emissions reductions simulated to be achieved was 335 MMTCO2e, or about 13 percent below the
Scoping Plan estimate. The range for the performance of the measures was about +50 MMTCO2e.
64 The whole number values displayed in Figure 7 do not mathematically sum to 621 MMTCO2e, consistent with the modeling results summary in Table 2. This is a result of embedded significant figures and rounding for graphic display purposes. Please refer to the corresponding PATHWAYS modeling data spreadsheets for details.65 The ranges presented are the 5th and 95th percentile observations in the Uncertainty Analysis. See Appendix E for details.
Scoping PlanGHG Emissions (MMTCO2e)0
100
200
300
400
500
600
700
800
64 Mobile Sources CFT & Freight
217 Short Lived Climate Pollutants High Global Warming Gases & Methane
Reduction from LCFS and Direct Measures
236 Cap-and-Trade Program
64 Energy Efficiency (Res, Com, Ind Ag & TCU)
25 Biofuels (18% LCFS)16 50% RPS
29
These values for the potential reductions achieved by the measures are shown in the figure.
• The Cap-and-Trade program is designed to fill the gap in the required emissions reductions
over and above what is achieved by the prescriptive measures. Because the total required
emissions reductions are uncertain, and the emissions reductions achieved by the prescriptive
measures are uncertain, the required emissions reductions from the Cap-and-Trade Program
are also uncertain. The Uncertainty Analysis simulated the average emissions reductions achieved
by the Cap-and-Trade Program at about 305 MMTCO2e, or about 30 percent higher than the
Scoping Plan estimate. The range was simulated to be about +120 MMTCO2e. These values
for the potential reductions achieved by the Cap-and-Trade Program are shown in the figure.
The Uncertainty Analysis provides insight into the range of potential emissions outcomes that may occur, and
demonstrates that the Scoping Plan, with the Cap-and-Trade Program, is extremely effective in the face of
uncertainty, assuring that the required emissions reductions are achieved (see Appendix E for more detail).
The Uncertainty Analysis also indicates that the Cap-and-Trade Program could contribute a larger or smaller share of the total required cumulative emissions reductions than expected in the Scoping Plan analysis.
Figure 8: unCertainty analysis
While the modeling results provide estimates of the GHG reductions that could be achieved by the
measures, the results also provide other insights and highlight the need to ensure successful implementation
of each measure. The SLCP Strategy will provide significant reductions with a focus on methane and
hydrofluorocarbon gases. To ensure the SLCP Strategy implementation is successful, it will be critical
to ensure programs such as LCFS maintain incentives to finance the capture and use of methane as a
transportation fuel–further reducing the State’s dependence on fossil fuels. The modeling also shows that
actions on energy efficiency could provide the same magnitude of GHG emissions reductions as the mobile
source measures, but each effort will provide different magnitudes of air quality improvements and cost-
effectiveness as discussed in Chapter 3.
Another way to look at this scenario is to understand the trajectory of GHG reductions over time, relative to
the 2030 target. Figure 9 provides the trajectory of GHG emissions modeled for the Scoping Plan Scenario.
Again, this depicts a straight-line path to the 2030 target for discussion purposes, but in reality GHG
emissions may be above or below the line in any given year(s).
Scoping Plan
UNCERTAINTY
PrescriptiveMeasuresCumulative GHG Emission Reductions2021 to 2030 (MMTCO2e)Cap-and-Trade TotalReductions
0
100
200
300
400
500
600
700
800
900
Cap-and-
Trade
Measures
30
Figure 9: sCoping plan sCenario ghg reduC tions
Figure 9 shows the Reference Scenario (yellow) and the version of the Scoping Plan Scenario that excludes
the Cap-and-Trade Program (blue). Until 2023, the measures in the Scoping Plan Scenario constrain GHG
emissions below the dotted straight line. After 2023, GHG emissions continue to fall, but at a slower rate than
needed to meet the 2030 target. It is the Cap-and-Trade Program that will reduce emissions to the necessary
levels to achieve the 2030 target. In this scenario, it is estimated that the known commitments will result in an emissions level of about 320 MMTCO2e in 2030. Thus, for the Scoping Plan Scenario, the Cap-and-Trade Program would deliver about 60 MMTCO2e in 2030 and ensure the 2030 target is achieved.
To understand how the Scoping Plan affects the main economic sectors, Table 3 provides estimated GHG
emissions by sector, compared to 1990 levels, and the range of GHG emissions for each sector estimated for 2030. This comparison helps to illustrate which sectors are reducing emissions more than others and where to focus additional actions to reduce GHGs across the entire economy.
20152010 2020 2025 2030
REFERENCE
SCENARIO (BAU)
Scoping Plan
Scenario
Gap closed by
Cap-and-Trade
431 MMTCO2e
2020 Target
0
100
200
300
400
500
260 MMTCO2e
2030 Target
31
table 3: estimated Change in ghg emissions by seCtor (mmtCo2e)
1990 2030 Scoping
Plan Ranges66
% change
from 1990
Agriculture 26 24–25 -8 to -4
Residential and Commercial 44 38–40 -14 to -9
Electric Power 108 30–5367 -72 to -51
High GWP 3 8–1168 267 to 367
Industrial 98 83–9069 -15 to -8
Recycling and Waste 7 8–970 14 to 29**
Transportation (Including TCU)152 103–111 -32 to -27
Natural Working Lands Net Sink*-7***TBD TBD
Sub Total 431 294–339 -32 to -21
Cap-and-Trade Program n/a 34–79 n/a
Total 431 260 -40
* Work is underway through 2017 to estimate the range of potential sequestration benefits from the natural and working lands sector.** The SLCP will reduce emissions in this sector by 40 percent from 2013 levels. However, the 2030 levels are still higher than the 1990 levels as emissions in this sector have grown between 1990 and 2013.*** This number reflects net results and is different than the intervention targets discussed in Chapter 4.
The sector ranges may change in response to how the sectors respond to the Cap-and-Trade Program. While
the known commitments will deliver some reductions in each sector, the Cap-and-Trade Program will deliver
additional reductions in the sectors it covers. Annual GHG reporting and the GHG inventory will track annual
changes in emissions, and those will provide ongoing assessments of how each sector is reducing emissions
due to the full complement of known commitments and the Cap-and-Trade Program, as applicable.
Scenario Modeling
There are a variety of models that can be used to model GHG emissions. For this Plan, the State is using the
PATHWAYS model.70 PATHWAYS is structured to model GHG emissions while recognizing the integrated
nature of the industrial economic and energy sectors. For example, if the transportation sector adds more
electric vehicles, PATHWAYS responds to reflect an energy demand increase in the electricity sector. However,
PATHWAYS does not reflect any change in transportation infrastructure and land use demand associated with
additional ZEVs on the road. The ability to capture a subset of interactive effects of policies and measures helps to provide a representation of the interconnected nature of the system and impacts to GHGs.
66 Unless otherwise noted, the low end of the sector range is the estimated emissions from the Scoping Plan Scenario and the high end adjusts the expected emissions by a risk factor that represents sector underperformance.67 The high end of the electric power sector range is represented by the Scoping Plan Scenario, and the low end by enhancements and additional electricity sector measures such as deployment of additional renewable power, greater behind-the-meter solar PV, and additional energy efficiency. The electric power sector range provided in Table 3 will be used to help inform CARB’s setting of the SB 350 Integrated Resource Plan greenhouse gas emissions reduction planning targets for the sector. CARB, CPUC, and CEC will continue to coordinate on this effort before final IRP targets are established for the sector, load-serving entities, and publicly-owned utilities. State agencies will investigate the potential for and appropriateness of deeper electric sector reductions in light of the overall needs of the Scoping Plan to cost-effectively achieve the statewide GHG goals. Concurrently, CEC and CPUC are proceeding with their respective IRP processes using this range.68 The sector emissions are anticipated to increase by 2030. As such, the high end of the sector range is the estimated emissions from the Scoping Plan Scenario and the low end adjusts the expected emissions by a risk factor that represents sector over performance.69 This estimate does not account for the reductions expected in this sector from the Cap-and-Trade Program. The Cap-and-Trade line item includes reductions that will occur in the industrial sector.70 CARB. 2016. AB 32 Scoping Plan Public Workshops. www.arb.ca.gov/cc/scopingplan/meetings/meetings.htm
32
At this time, PATHWAYS does not include a module for natural and working lands. As such, PATHWAYS
cannot be used to model the natural and working lands sector, the interactive effects of polices aimed at
the economic and energy sectors and their effect on land use or conditions, or the interactive effects of
polices aimed at the natural environment and their impact on the economic and energy sectors. For this Plan,
external inputs had to be developed for PATHWAYS to supply biofuel volumes. The natural and working lands
sector is also being modeled separately as described in Chapter 4. Moving forward, CARB and other State
agencies will work to integrate all the sectors into one model to fully capture interactive effects across both
the natural and built environments.
Lastly, the PATHWAYS assumptions and result s in this Plan show the significant action that the State must take
to reach its GHG reduction goals. It is important to note that the modeling assumptions may differ from other
models used by other State agencies. Modeling exercises undertaken in future regulatory proceedings may
result in different measures, programs, and program results than those used in the modeling for this Scoping
Plan. State agencies will engage on their specific policies and measure development processes separately from CARB Scoping Plan activities, in public forums to engage all stakeholders.
Uncertainty
Several types of uncertainty are important to understand in both forecasting future emissions and estimating
the benefits of emissions reductions scenarios. In developing the Scoping Plan, we have forecast a Reference
Scenario and estimated the GHG emissions outcome of the Scoping Plan using PATHWAYS. Inherent in the
Reference Scenario modeling is the expectation that many of the existing programs will continue in their current form, and the expected drivers for GHG emissions such as energy demand, population growth, and economic growth will match our current projections. However, it is unlikely that the future will precisely match our projections, leading to uncertainty in the forecast. Thus, the single “reference” line should be understood
to represent one possible future in a range of possible predictions. For the Scoping Plan Scenario,
PATHWAYS utilized inputs that are assumptions external to the model. PATHWAYS was provided plausible
inputs such as energy demand over time, the start years for specific policies, and the penetration rates of
associated technologies. Each of the assumptions provided to PATHWAYS has some uncertainty, which is also
reflected in the results. Thus, while the results presented in the Scoping Plan may seem precise due to the
need for precision in model inputs, these results are estimates, and the use of ranges in some of the results is
meant to capture that uncertainty.
Further, as noted in the November 7, 2016, 2030 Target Scoping Plan Workshop, “All policies have a degree
of uncertainty associated with them.”71 As this Scoping Plan is meant to chart a path to achieving the 2030
target, additional work will be required to fully design and implement any policies identified in this Scoping
Plan. During the subsequent development of policies, CARB and other State agencies will learn more
about technologies, cost, and how each industry works as a more comprehensive evaluation is conducted in coordination with stakeholders. Given the uncertainty around assumptions used in modeling, and in performance once specific policies are fully designed and implemented, estimates associated with the Scoping Plan Scenario are likely to differ from what actually occurs when the Scoping Plan is implemented.
One way to mitigate for this risk is to develop policies that can adapt and increase certainty in GHG emissions
reductions. Periodic reviews of progress toward achieving the 2030 target and the performance of specific
policies will also provide opportunities for the State to consider any changes to ensure we remain on course
to achieve the 2030 target. The need for this periodic review process was anticipated in AB 32, as it calls for
updates to the Scoping Plan at least once every five years. Additional information on the uncertainty analyses
conducted in the development of this Scoping Plan is located in Appendix E.
71 Bushnell, James. Economic Modeling and Environmental Policy Choice. PowerPoint. Department of Economics, University of California, Davis. www.arb.ca.gov/cc/scopingplan/meetings/110716/bushnellpresentation.pdf
33
Policy Analysis of Scoping Plan Scenario
The following key criteria were considered while evaluating potential policies beyond the known
commitments. The results of the economic analysis (presented in Chapter 3) were also important in the
design of this Scoping Plan.
• Ensure the State achieves the 2030 target. The strategy must ensure that GHG emissions
reductions occur and are sufficient to achieve the 2030 target.
• Provide air quality co-benefits. An important concern for environmental justice communities is
for any Scoping Plan to provide air quality co-benefits.
• Prioritize rules and regulations for direct GHG reductions. AB 197 requires CARB in developing
this Scoping Plan to prioritize emissions reductions rules and regulations that result in direct
emissions reductions at large stationary sources of GHG emissions sources and direct
emissions reductions from mobile sources.• Provide protection against emissions leakage. Require any policies to achieve the statewide limits to minimize emissions leakage to the extent possible. Emissions leakage can occur when production moves out-of-state, so there appears to be a reduction in California’s emissions, but the production
and emissions have just moved elsewhere. This loss in production may be associated with loss
in jobs and decreases in the State’s gross domestic product (GDP) and could potentially increase
global GHG emissions if the production moves to a less efficient facility outside of California.
• Develop greenhouse gas reduction programs that can be readily exported to other
jurisdictions. Currently, California’s Cap-and-Trade Program is linked with Québec’s
program and is scheduled to link with Ontario’s cap-and-trade program beginning
in 2018. At the same time, California’s ambitious policies such as the RPS, LCFS, and
Advanced Clean Cars have resulted in other regions adopting similar programs.
• Minimize costs and increase investment in disadvantaged and low-income communities, and
low-income households. Currently, Cap-and-Trade auction proceeds from the sale of State- owned allowances are appropriated for a variety of programs to reduce GHGs, and provide other environmental, health and economic benefits including job creation and economic development.
Under AB 1550, a minimum of 25 percent of the proceeds are to be invested in projects located
in and benefiting disadvantaged communities, with an additional minimum 10 percent to projects
in low-income communities, and low-income households. It is important to understand if the
strategy will require or result in funding to support these GHG reductions and associated benefits.
• Avoid or minimize the impacts of climate change on public health by continuing reductions in
GHGs. Climate change has the potential to significantly impact public health, including increases
in heat illness and death, air pollution-related exacerbation of cardiovascular and respiratory
diseases, injury and loss of life due to severe storms and flooding, increased vector-borne and
water-borne diseases, and stress and mental trauma due to extreme weather-related catastrophes.• Provide compliance flexibility. Flexibility is important as it allows each regulated entity the ability to pursue its own path toward compliance in a way that works best for its business model. Flexibility also acknowledges that regulatory agencies may not have a
complete picture of all available low-cost compliance mechanisms or opportunities even
across the same sector. In addition, under AB 32 and AB 197, the strategy to reduce GHGs
requires consideration of cost-effectiveness, which compliance flexibility provides.
• Support the Clean Power Plan and other federal climate programs. California will continue to
support aggressive federal action, as well as to defend existing programs like the Clean Power Plan,
which is the most prominent federal climate regulation applicable to stationary sources. The U.S.
Supreme Court has repeatedly confirmed that federal greenhouse gas regulation must move forward
under the federal Clean Air Act, so it is important to ensure that California’s programs can support
federal compliance as well. Although continuing litigation has stayed certain Clean Power Plan deadlines in the near term, and U.S. EPA has proposed to reconsider aspects of the rule as issued, the Clean Power Plan remains the law of the land. California is vigorously defending this important program, and is continuing to support federal climate regulation as is required
by law. U.S EPA also has a legal obligation to implement GHG controls for power plants, even
if it proposes to alter the form of those controls in the future. Therefore, the Clean Power Plan
and other federal efforts are important considerations for this Scoping Plan. With regard to the
34
Clean Power Plan, California power plants are expected to be within their limits as set forth by
the State’s compliance plan, which was approved by CARB on July 27, 2017. However, the State
still needs a mechanism to ensure the emissions for the covered electricity generating plants
do not exceed the federal limits. This mechanism must be federally enforceable with regard
to the affected power plants, and limit their emissions in accordance with the federal limit.
Table 4 uses the criteria listed above to assess the Scoping Plan Scenario. This assessment is based on CARB
staff evaluation as well as the analyses described in Chapter 3.
table 4: poliCy assessment oF the sCoping plan
Criteria Details
Ensure the State Achieves the 2030 Target
• Incorporates existing and new commitments to reduce emissions from all sectors
• The Cap-and-Trade Program scales to ensure reductions are achieved, even if
other policies do not achieve them. This is particularly critical given the uncertainty
inherent in both CARB’s emission forecast and its estimate of future regulations.
Provide Air Quality Co-Benefits
• Reduced fossil fuel use and increased electrification (including plug-in hybrid
electric, battery-electric, and hydrogen fuel cell vehicles) from policies such
as the Mobile Source Strategy, enhanced LCFS and RPS, energy efficiency, and
land conservation will likely reduce criteria pollutants and toxic air contaminants.
• The Cap-and-Trade Program will ensure GHG emissions reductions within
California that may reduce criteria pollutants and toxic air contaminants.
Prioritize Rules and Regulations for Direct
GHG Reductions
• Advanced Clean Cars regulations require reduction in the light-duty vehicle sector.
• Enhanced LCFS requires reductions in light-duty and heavy-duty transportation.
• SB 350, RPS, and energy efficiency will reduce the need for fossil power generation.
• The Cap-and-Trade Program constrains and reduces emissions across
approximately 80 percent of California GHG emissions.
• SB 1383 and the Short-lived Climate Pollutant Reduction Strategy require
reductions in the agricultural, commercial, residential, industrial, and
energy sectors.
Protect Against Emissions Leakage • Free allowance allocation to minimize leakage, where supported by research.
Develop GHG Reduction Programs that can
be Readily Exported to Other Jurisdictions
• Supports existing and future linkages, allows for larger GHG emissions reductions
worldwide through collaborative regional efforts.
• Provides leadership on how to integrate short-lived climate pollutants into the
broader climate mitigation program.
Minimize Costs and Invest in Disadvantaged
and Low-Income Communities, and
Low-Income Households
• Continue to fund programs and projects that reduce GHGs and meaningfully
benefit disadvantaged and low-income communities and low-income households
through the Greenhouse Gas Reduction Fund.
Avoid or Minimize the Impacts of Climate
Change on Public Health
• Reduces GHGs and provides leadership nationally and internationally for
climate action.
• Provides funding for programs such as home weatherization focused on
disadvantaged communities, to mitigate potential cost impacts.
Compliance Flexibility
• Regulated sources self-identify and implement some GHG emissions reductions
actions, beyond those already required to comply with additional prescriptive
measures.
Support the Clean Power Plan and
other Federal Climate Programs
• Post-2020 Cap-and-Trade Program can be used to comply with the Clean
Power Plan.
35
Programs for Air Quality Improvement in California
For half a century, CARB has been a leader in measuring, evaluating, and reducing sources of air pollution
that impact public health. Its air pollution programs have been adapted for national programs and emulated
in other countries. Significant progress has been made in reducing diesel particulate matter (PM), which
is a designated toxic air contaminant, and many other hazardous air pollutants. CARB partners with local
air districts to address stationary source emissions and adopts and implements State-level regulations to
address sources of criteria and toxic air pollution, including mobile sources. The key air quality strategies
being implemented by CARB include the following:
• State Implementation Plans (SIPs).72 These comprehensive plans describe how an area will
attain national ambient air quality standards by deadlines established by the federal Clean
Air Act. SIPs are a compilation of new and previously submitted plans, programs, air district
rules, State regulations, and federal controls designed to achieve the emissions reductions needed from mobile sources, fuels, stationary sources, and consumer products. On March 23, 2017, CARB adopted the Revised Proposed 2016 State Strategy for the SIP, describing the commitments necessary to meet federal ozone and PM2.5 standards over the next 15 years.
• Diesel Risk Reduction Plan.73 The plan, adopted by CARB in September 2000, outlined 14
recommended control measures to reduce the risks associated with diesel PM and achieve a goal of
75 percent PM reduction by 2010 and 85 percent by 2020. Since 2000, CARB has adopted
regulations to reduce smog-forming pollutants and diesel PM from mobile vehicles and
equipment (e.g., trucks, buses, locomotives, tractors, cargo handling equipment, construction
equipment, marine vessels, transport refrigeration units); stationary engines and portable
equipment (e.g., emergency standby generators, prime generators, agricultural irrigation
pumps, portable generators); and diesel fuels. Diesel PM accounts for approximately 60
percent of the current estimated inhalation cancer risk for background ambient air.74 CARB staff continues to work to improve implementation and enforcement efforts and examine needed amendments to increase the community health benefits of these control measures.• Sustainable Freight Action Plan.75 This joint agency strategy was developed in response to
Governor’s Executive Order B-32-15 to improve freight efficiency, transition to zero emission
technologies, and increase the competitiveness of California’s freight system. The transition
of the freight transport system is essential to support the State’s economic development
in the coming decades and reduce air pollution affecting many California communities.
• AB 32 Scoping Plan.76 This comprehensive strategy is updated at least
every five years and is designed to achieve the State’s climate goals, which
includes measures that achieve air pollutant reduction co-benefits.
• AB 1807.77 AB 1807 (Tanner, 1983) created California’s program to reduce exposure to air toxics.
CARB uses a comprehensive process to prioritize the identification of substances that pose the greatest health threat and to develop airborne toxic control measures to reduce those exposures. CARB has reduced public exposure to toxic air contaminants (TACs) through control of motor vehicles, fuels, consumer products, and stationary sources, including adopting control measures for
72 CARB. 2016. California State Implementation Plans. www.arb.ca.gov/planning/sip/sip.htm73 CARB. 2000. Final Diesel Risk Reduction Plan with Appendices. www.arb.ca.gov/diesel/documents/rrpapp.htm 74 CARB and California Air Pollution Control Officers Association. 2015. Risk Management Guidance for Stationary Sources of Air Toxics. July 23. www.arb.ca.gov/toxics/rma/rmgssat.pdf 75 CARB. 2016. Sustainable Freight Transport. www.arb.ca.gov/gmp/sfti/sfti.htm 76 CARB. 2016. AB 32 Scoping Plan. www.arb.ca.gov/cc/scopingplan/scopingplan.htm 77 CARB. 2014. California Air Toxics Program – Background. www.arb.ca.gov/toxics/background.htm
Chapter 3
e valuat Ion S
36
industrial sources (e.g., perchloroethylene in automotive products; hexavalent chromium from cooling
towers, automotive coatings and plating; ethylene oxide from sterilizers and aerators; dioxins from
medical waste incinerators; perchloroethylene from dry cleaners; cadmium from metal melting).
• AB 2588 Air Toxics “Hot Spots” Program.78 The Hot Spots Program supplements the AB
1807 program by requiring a statewide air toxics inventory, identification of facilities having
localized impacts, notification of nearby residents exposed to a significant health risk, and
facility risk management plans to reduce those significant risks to acceptable levels.
• AB 617 Community Air Protection Program. Together with the extension of the Cap-and-Trade
Program and in recognition of ongoing air quality challenges, California has committed to expand its
criteria and toxic emissions reductions efforts through the pursuit of a multipronged approach to reduce localized air pollution and address community exposure, framed by recently-signed new legislation, AB 617 (C. Garcia, 2017). AB 617 outlines actions in five core areas, to be completed in the 2018 to 2020 timeframe, to reduce
criteria and toxic emissions in the most heavily impacted areas of the State:
• Community-scale air monitoring. Ambient air monitoring is needed to evaluate the
status of the atmosphere compared to clean air standards and historical data. Monitoring
helps identify and profile air pollution sources, assess emerging measurement methods,
characterize the degree and extent of air pollution, and track progress of emissions reductions
activities. AB 617 requires a statewide assessment of the current air monitoring network and
identification of priority locations where community-level air monitoring will be deployed.
• Statewide Strategy to reduce air pollutants impacting communities. CARB will
identify locations with high cumulative exposure to criteria and toxic pollutants, the sources contributing to those exposures, and select locations that will be required to develop a community action plan to reduce pollutants to acceptable levels.• Community Action Plans to reduce emissions in identified communities. High priority
locations identified in the Statewide Strategy will need to prepare a community action
plan that includes emissions reductions targets, measures, and an implementation
timeline. The plan will be submitted to CARB for review and approval.
• Accelerated retrofits and technology clearinghouse. This effort will focus on stationary
source equipment at Cap-and-Trade facilities that, as of 2007, have not been retrofitted
with BARCT-level emission controls for nonattainment pollutants. In addition, creation
of a statewide clearinghouse that identifies BACT and BARCT technologies and emission
levels for criteria pollutants and TACs will be developed to assist the air districts with the
BARCT evaluation and identify available emission controls for the Statewide Strategy.• Direct reporting of facility emissions data to CARB. An improved, standardized emission inventory promotes a better understanding of actual emissions and helps identify major emission sources, priorities for emissions reduction, and data gaps requiring further work. AB 617 requires CARB
to establish a uniform emission inventory system for stationary sources of criteria pollutants and
TACs. Data integration and transparency-related efforts are already required by AB 197 (E. Garcia,
2016) and underway at CARB, so this new task will build on these efforts. Moreover, it is clear
that better data reporting is necessary to identify localized exposure risk to harmful criteria and
toxic pollutants and actions to address any localized impacts must be taken as quickly as possible.
To support efforts to advance the State’s toxics program, the Office of Environmental Health Hazard
Assessment (OEHHA) finalized a new health risk assessment methodology, Air Toxics Hot Spots Program Risk
Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments, on March 6, 2015, which
updates the previous version of the guidance manual and reflects advances in the field of risk assessment
along with explicit consideration of infants and children.79 Subsequently, CARB, in collaboration with the
California Air Pollution Control Officers Association (CAPCOA), finalized a Risk Management Guidance for
Stationary Sources of Air Toxics for the air districts to use to incorporate OEHHA’s new health risk assessment
methodology into their stationary source permitting and AB 2588 Air Toxics Hot Spots programs.80
Together, all of these efforts will reduce criteria and toxics emissions in the State, with a focus on the most
burdened communities. In particular, AB 617 responds to environmental justice concerns that the Cap-and-
78 CARB. 2016. AB 2588 Air Toxics “Hot Spots” Program. www.arb.ca.gov/ab2588/ab2588.htm 79 OEHHA. 2015. Notice of Adoption of Air Toxics Hot Spots Program Guidance Manual for the Preparation of Health Risk Assessments 2015. http://oehha.ca.gov/air/crnr/notice-adoption-air-toxics-hot-spots-program-guidance-manual-preparation-health-risk-0 80 www.arb.ca.gov/toxics/rma/rmgssat.pdf
37
Trade Program does not force large GHG emitters to reduce air pollution which results in localized health
impacts. Prior to the passage of AB 617, in February 2017, OEHHA published the first in a series of reports
tasked with evaluating the impacts of California’s climate change programs on disadvantaged communities.
The initial report focused on the Cap-and-Trade Program.81 Future reports will focus on the impacts of
other climate programs on disadvantaged communities. The report confirms disadvantaged communities
are frequently located close to large stationary and mobile sources of emissions. It also notes there are
complexities in trying to correlate GHGs with criteria and toxics emissions across industry and within sectors,
although preliminary data review shows there may be some poor to moderate correlations in specific instances.
Lastly, the report noted, “…the emissions data available at this time do not allow for a conclusive analysis.”
Two additional reports were released during this same period of time: a California Environmental Justice
Alliance (CEJA) report focused on identifying equity issues for disadvantaged communities resulting from the
implementation of the Cap-and-Trade Program82 and a research paper examining the question of whether the
Cap-and-Trade Program is causing more GHG emissions in disadvantaged communities when compared to
other regions.83 Both of these reports also confirmed that disadvantaged communities are disproportionately located close to large stationary and mobile sources of emissions. While the CEJA report noted, “Further research is needed before firm policy conclusions can be drawn from this preliminary analysis,” the research
paper, in reference to GHGs, states, “By and large, the annual change in emissions across disadvantaged and
non-disadvantaged communities look similar.”
While the reports do not provide evidence that implementation of the Cap-and-Trade Program is contributing
to increased local air pollution, they do underscore the need to use all of the tools (e.g., enhanced
enforcement, new regulations, tighter permit limits) available to the State and local agencies to achieve
further emissions reductions of toxic and criteria pollutants that are impacting community health. Importantly,
AB 617 provides a new framework and tools for CARB, in collaboration with local air districts, to deploy
focused monitoring and ensure criteria and toxics emissions reductions at the State’s largest GHG emitters.
AB 197 Measure Analyses
This section provides the required AB 197 estimates for the measures evaluated in this Scoping Plan. These
estimates provide information on the relative impacts of the evaluated measures when compared to each
other. To support the design of a suite of policies that result in GHG reductions, air quality co-benefits, and
cost-effective measures, it is important to understand if a measure will increase or reduce criteria pollutants
or toxic air contaminant emissions, or if increasing stringency at additional costs yields few additional GHG
reductions. To this end, AB 197 (E. Garcia, Chapter 250, Statutes of 2016) requires the following for each
potential reduction measure evaluated in any Scoping Plan update:
• The range of projected GHG emissions reductions that result from the measure.
• The range of projected air pollution reductions that result from the measure.
• The cost-effectiveness, including avoided social costs, of the measure.
As the Scoping Plan was developed, it was important to understand if any of the proposed policies or
measures would increase criteria pollutant or toxic air contaminant emissions. Note the important caveats
around some of the estimates; they must be considered when using the information in the tables below for purposes other than as intended.
Estimated Emissions Reductions for Evaluated Measures
For many of the existing programs with known commitments, such as the Mobile Source Strategy, previous analyses provide emission factors or other methods for estimating the impacts required by AB 197. Where available, these values were used. In some cases, estimates are based on data from other sources, such as the
California Public Utilities Commission (CPUC) Renewables Portfolio Standard Calculator. For newly proposed
measures, assumptions were required to estimate the values. Consequently, the estimates for the newly
proposed measures have substantial uncertainty. The uncertainty in the impacts of these measures would be
reduced as the measures are defined in greater detail during the regulatory processes that are undertaken to
81 https://oehha.ca.gov/media/downloads/environmental-justice/report/oehhaab32report020217.pdf82 http://dornsife.usc.edu/PERE/enviro-equity-CA-cap-trade83 https://www.dropbox.com/s/se3ibxkv8t4at8g/Meng_CA_EJ.pdf?dl=1
38
define and adopt the programs. For example, as a measure is developed in detail, ways to obtain additional
co-pollutant reductions or avoid co-pollutant increases may be identified and evaluated.
Table 5 provides the estimates for the measures evaluated during the development of the Scoping Plan. Based on the estimates below, these measures are expected to provide air quality benefits. The table also
provides important context, limitations, and caveats about the values. As shown, the table includes criteria
pollutant and diesel PM estimates. As mentioned in the Diesel Risk Reduction Plan, diesel PM accounts for
60 percent of the current estimated inhalation cancer risk for background ambient air. As we do not have
direct modeling results for criteria and toxic pollutant estimates from PATHWAYS, we are estimating air
quality benefits by using reductions in GHGs to assign similar reductions for criteria and toxic pollutants. By
assigning an arbitrary 1:1 relationship in changes between GHGs and criteria and toxic pollutants, the air
quality reductions likely overestimate the actual reductions from implementation of the measures. As noted
in the OEHHA report, the exact relationship between GHGs and air pollutants is not clearly understood at
this time. Moving forward, CARB will continue to assess the nature of the exact relationship between GHGs and criteria and toxics emissions. All estimates in Table 5 have some inherent uncertainty. The table allows for assessing measures against each other and should not be used for other purposes without understanding the limitations on the how the air quality values are derived.
Table 6 provides a summary of the total estimated emissions reductions for the Scoping Plan Scenario as outlined in Table 1. Table 6 was developed by adding the estimated emissions reductions for all of the measures included within the Scoping Plan Scenario in Table 1. More detail on the estimates for the Scoping
Plan Scenario, as well as the specific measures included in each of the other four alternative scenarios can
be found in Appendix G. In 2030, the Scoping Plan scenario and alternatives will provide comparable GHG
and air quality reductions. When there is a range, the measure or policy should be designed to maximize the
benefit to the extent possible.
table 5: ranges oF estimated air pollution reduCtions by poliCy or measure in 2030
Measure
Range of NOX
Reductions
(Tons/Day)
Range of VOC
Reductions
(Tons/Day)
Range of PM2.5
Reductions
(Tons/Day)
Range of Diesel
PM Reductions
(Tons/Day)
50 percent RPS ~0.5 <0.1 ~0.4 < 0.01
Mobile Sources CTF and Freight 51–60 4.6–5.5 ~1.1 ~0.2
18 percent Carbon Intensity Reduction Target
for LCFS - Liquid Biofuels*3.5–4.4 0.5–0.6 0.4–0.6 ~0.5
Short-Lived Climate Pollutant Strategy ––––
2x additional achievable energy efficiency in the
2015 Integrated Energy Policy Report (IEPR)0.4–0.5 0.5–0.7 < 0.1 < 0.01
Cap-and-Trade Program A A A 4–9
* LCFS estimates include estimates of the NOX and PM2.5 tailpipe benefits limited to renewable diesel consumed in the off-road sector.
– CARB is evaluating how to best estimate these values. Criteria and toxic values are shown in tons per day, as they are episodic emissions events with residence times of a few hours to days, unlike GHGs, which have atmospheric residence times of decades.
A Due to the inherent flexibility of the Cap-and-Trade Program, as well as the overlay of other complementary GHG reduction measures, the mix of compliance strategies that individual facilities may use is not known. However, based on current law and policies that control industrial and electricity generating sources of air pollution, and expected compliance responses, CARB believes that emissions increases at the statewide, regional, or local level due to the regulation are not likely. A more stringent post-2020 Cap-and-Trade Program will provide an incentive for covered facilities to decrease GHG emissions and any related emissions of criteria and toxic pollutants. Please see CARB’s Co-Pollutant Emissions Assessment for a more detailed evaluation of a cap-and-trade program and associated air emissions impacts: www.arb.ca.gov/regact/2010/capandtrade10/capv6appp.pdf
NOX = nitrogen oxides; VOC = volatile organic compound
Important: These estimates assume a 1:1 relationship between changes in GHGs, criteria pollutants, and toxic air contaminant emissions,
and it is unclear whether that is ever the case. The values should not be considered estimates of absolute changes for other analytical
purposes and only allow for comparison across measures in the table. The values are estimates that represent current assumptions
of how programs may be implemented; actual impacts may vary depending on the design, implementation, and performance of the
policies and measures. The table does not show interactions between measures, such as the relationship with increased transportation
39
electrification and associated increase in energy demand for the electricity sector. The measures in the Scoping Plan Scenario are shown
in bold font in the table below. Additional details, including GHG reductions, are available in Appendix G.
table 6: summary oF r anges oF estimated air pollution reduCtions For the sCoping
plan sCenario in 2030
Scenario
Range of NOX
Reductions
(Tons/Day)
Range of VOC
Reductions
(Tons/Day)
Range of PM2.5
Reductions
(Tons/Day)
Range of Diesel PM Reductions (Tons/Day)
Scoping Plan Scenario 48–73 5.1–7.3 1.4–2.4 5–10
The total estimates for air pollution reductions provided in this table for the Scoping Plan Scenario are estimated by adding the air pollution benefits for the subset of individual measures examined in Table 5 and included in the Scoping Plan Scenario described in Table 1, and scaled by a risk adjustment factor to capture interactive effects and risks of under/over achieving on air pollution reductions. Appendix G includes details of the specific measures in the Scoping Plan Scenario and Alternatives. All caveats in Table 5
apply to air quality estimates in this table.
Estimated Social Costs of Evaluated Measures
Consideration of the social costs of GHG emissions is a requirement in AB 197, including evaluation of the avoided social costs for measures within this Scoping Plan.84 Social costs are generally defined as the cost of an action on people, the environment, or society and are widely used to evaluate the impact of regulatory
actions. Social costs do not represent the cost of abatement or the cost of GHG reductions, rather social
costs estimate the harm that is avoided by reducing GHGs.
Since 2008, federal agencies have been incorporating the social costs of GHGs, including carbon dioxide,
methane, and nitrous oxide into the analysis of their regulatory actions. Agencies including the U.S.
Environmental Protection Agency (U.S. EPA), Department of Transportation (DOT), and Department of
Energy (DOE) are subject to Executive Order 12866, which directs agencies “to assess both the costs and
benefits of the intended regulation…”.85 In 2007, the National Highway Transportation Safety Administration
(NHTSA) was directed by the U.S. 9th Circuit Court of Appeals to include the social cost of carbon in a
regulatory impact analysis for a vehicle fuel economy rule. The Court stated that “[w]hile the record shows
that there is a range of values, the value of carbon emissions reduction is certainly not zero.”86
In 2009, the Council of Economic Advisors and the Office of Management and Budget convened the
Interagency Working Group on the Social Cost of Greenhouse Gases87 (IWG) to develop a methodology
for estimating the social cost of carbon (SC-CO2). This methodology relied on a standardized range of
assumptions and could be used consistently when estimating the benefits of regulations across agencies and
around the world. The IWG, comprised of scientific and economic experts, recommended the use of SC-CO2 values based on three integrated assessment models (IAMs) developed over decades of global peer-reviewed research.88
In this Scoping Plan, CARB utilizes the current IWG supported SC-CO2 values to consider the social costs of actions to reduce GHG emissions. This approach is in line with Executive Orders including 12866 and the OMB Circular A-4 of September 17, 2003, and reflects the best available science in the estimation of the socio-economic impacts of carbon.89 CARB is aware that the current federal administration has recently
withdrawn certain social cost of carbon reports as no longer representative of federal governmental policy.90
However, this determination does not call into question the validity and scientific integrity of federal social
84 AB 197 text available at: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201520160AB197. 85 https://www.reginfo.gov/public/jsp/Utilities/EO_12866.pdf 86 Center for Biological Diversity v National Highway Traffic Safety Administration 06-71891 (9th Cir, November 15 2007)87 Originally titled the Interagency Working Group on the Social Cost of Carbon, the IWG was renamed in 2016.88 Additional technical detail on the IWG process is available in the Technical Updates of the Social Cost of Carbon for Regulatory Impact Analysis – Under Executive Order 12866. Iterations of the Updates are available at: https://obamawhitehouse.archives.gov/
sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf, https://obamawhitehouse.archives.gov/sites/
default/files/omb/inforeg/scc-tsd-final-july-2015.pdf, and https://obamawhitehouse.archives.gov/sites/default/files/omb/inforeg/
scc_tsd_final_clean_8_26_16.pdf. 89 OMB circular A-4 is available at: https://www.transportation.gov/sites/dot.gov/files/docs/OMB%20Circular%20No.%20A-4.pdf. 90 See Presidential Executive Order, March 28, 2017, sec. 5(b).
40
cost of carbon work, or the merit of independent scientific work. Indeed, the IWG’s work remains relevant,
reliable, and appropriate for use for these purposes.
The IWG describes the social costs of carbon as follows:
The social cost of carbon (SC-CO2) for a given year is an estimate, in dollars, of the present discounted
value of the future damage caused by a 1-metric ton increase in carbon dioxide (CO2) emissions into the
atmosphere in that year, or equivalently, the benefits of reducing CO2 emissions by the same amount in
that year. The SC-CO2 is intended to provide a comprehensive measure of the net damages – that is, the
monetized value of the net impacts – from global climate change that result from an additional ton of CO2.
These damages include, but are not limited to, changes in net agricultural productivity, energy use,
human health, property damage from increased flood risk, as well as nonmarket damages, such as the
services that natural ecosystems provide to society. Many of these damages from CO2 emissions today will
affect economic outcomes throughout the next several centuries.91
Table 7. presents the range of IWG SC-CO2 values used in regulatory assessments including this Scoping Plan.92
table 7: sC-Co2, 2015-2030 (in 2007 $ per metriC ton)
Year 5 Percent
Discount Rate
3 Percent
Discount Rate
2.5 Percent
Discount Rate
2015 $11 $36 $56
2020 $12 $42 $62
2025 $14 $46 $68
2030 $16 $50 $73
The SC-CO2 is year specific, that is, the IAMs estimate the environmental damages from a given year in the future and discount the value of the damages back to the present. For example, the SC-CO2 for the year 2030
represents the value of climate change damages from a release of CO2 in 2030 discounted back to today.
The SC-CO2 increases over time as systems become stressed from the aggregate impacts of climate change
and future emissions cause incrementally larger damages. Table 7 presents the SC-CO2 across a range of
discount rates – or the value today of preventing environmental damages in the future. A higher discount
rate decreases the value placed on future environmental damages. This Scoping Plan utilizes the IWG
standardized range of discount rates, from 2.5 to 5 percent to represent varying valuation of future damages.
The SC-CO2 is highly sensitive to the discount rate. Higher discount rates decrease the value today of future
environmental damages. This Scoping Plan utilizes the IWG standardized range of discount rates, from 2.5
to 5 percent to represent varying valuation of future damages. The value today of environmental damages in
2030 is higher under the 2.5 percent discount rate compared to the 3 or 5 percent discount rate, reflecting
the trade-off of consumption today and future damages. The IWG estimates the SC-CO2 across a range of
discount rates that encompass a variety of assumptions regarding the correlation between climate damages and consumption of goods and is consistent with OMB’s Circular A-4 guidance.93
There is an active discussion within government and academia about the role of SC-CO2 in assessing
regulations, quantifying avoided climate damages, and the values themselves. In January 2017, the National Academies of Sciences, Engineering, and Medicine (NAS) released a report examining potential approaches for a comprehensive update to the SC-CO2 methodology to ensure resulting cost estimates reflect the best available science. The NAS review did not modify the estimated values of the SC-CO2, but evaluated the
models, assumptions, handling of uncertainty, and discounting used in the estimating of the SC-CO2. The
report titled, “Valuating Climate Damages: Updating Estimation of the Social Cost of Carbon Dioxide,”
recommends near-term improvements to the existing IWG SC-CO2 as well as a long-term strategy to more
comprehensive updates.94 The State will continue to follow updates to the IWG SC-CO2, including changes
91 From The National Academies, Valuing Climate Damages: Updating Estimation of the Social Cost of Carbon Dioxide, 2017, available at: http://www.nap.edu/24651 92 The SC-CO2 values as of July 2015 are available at: https://obamawhitehouse.archives.gov/sites/default/files/omb/inforeg/scc-tsd-
final-july-2015.pdf 93 The National Academies, Valuing Climate Damages: Updating Estimation of the Social Cost of Carbon Dioxide, 2017, available at: http://www.nap.edu/24651. 94 The National Academies, Valuing Climate Damages: Updating Estimation of the Social Cost of Carbon Dioxide, 2017, available at:
41
outlined in the NAS report, and incorporate appropriate peer-reviewed modifications to estimates based on
the latest available data and science.
It is important to note that the SC-CO2, while intended to be a comprehensive estimate of the damages caused by carbon globally, does not represent the cumulative cost of climate change and air pollution to
society. There are additional costs to society outside of the SC-CO2, including costs associated with changes
in co-pollutants, the social cost of other GHGs including methane and nitrous oxide, and costs that cannot
be included due to modeling and data limitations. The IPCC has stated that the IWG SC-CO2 estimates
are likely underestimated due to the omission of significant impacts that cannot be accurately monetized,
including important physical, ecological, and economic impacts.95 CARB will continue engaging with experts
to evaluate the comprehensive California-specific impacts of climate change and air pollution.
The Social Cost of GHG Emissions
Social costs for methane (SC-CH4) and nitrous oxide (SC-N2O) have also been developed using methodology
consistent with that used in estimating the IWG SC-CO2. These social costs have also been endorsed by the
IWG and have been used in federal regulatory analyses.96 Along with the SC-CO2, the State also supports the
use of the SC-CH4 and SC-N2O in monetizing the impacts of GHG emissions.
While the SC-CO2, SC-CH4, and SC-N2O provide metrics to account for the social costs of climate change,
California will continue to analyze ways to more comprehensively identify the costs of climate change and air
pollution to all Californians. This will include following updates to the IWG methodology and social costs of
GHGs and incorporating the SC-CO2, SC-CH4, and SC-N2O into regulatory analyses.
Table 9 presents the estimated social cost for each policy or measure considered in the development of the
Scoping Plan in 2030. For each measure or policy, Table 9 includes the range of the IWG SC-CO2 values that
result from the anticipated range of GHG reductions in 2030 presented in Appendix G. The SC-CO2 range is
obtained using the IWG SC-CO2 values in 2030 at the 2.5, 3, and 5 percent discount rates. These values (of
$16 using the 5 percent discount rate, $50 using the 3 percent discount rate, and $73 using the 2.5 percent
discount rate) are translated into 2015 dollars and multiplied across the range of estimated reductions by measure in 2030 to estimate the value of avoided social costs from each measure in that year.97
Implementation of the SLCP Strategy will result in reduction of a variety of GHGs, including methane and
HFCs, which reported in carbon dioxide equivalent (CO2e). While there is no social cost of CO2e, the avoided damages associated with the methane reductions outlined in the SLCP Strategy are estimated in Table 9 using the IWG SC-CH4 as presented in Table 8.98
table 8: sC-Ch4, 2015-2030 (in 2007$ per metriC ton)
Year 5 Percent
Discount Rate
3 Percent
Discount Rate
2.5 Percent
Discount Rate
2015 $450 $1000 $1400
2020 $540 $1200 $1600
2025 $650 $1400 $1800
2030 $760 $1600 $2000
The range of SC-CH4 is obtained using the IWG SC-CH4 values in 2030 at the 2.5, 3, and 5 percent discount
rates. The SC-CH4 values (e.g., $760 using the 5 percent discount rate, $1,600 using the 3 percent discount
rate, and $2,000 using the 2.5 percent discount rate) are translated into 2015 dollars and multiplied across the range of estimated methane reductions in 2030 to estimate the value of climate benefits from the SLCP
http://www.nap.edu/24651 95 https://www.ipcc.ch/publications_and_data/ar4/wg3/en/ch3s3-5-3-3.html96 More information is available at: https://obamawhitehouse.archives.gov/sites/default/files/omb/inforeg/august_2016_sc_ch4_sc_
n2o_addendum_final_8_26_16.pdf 97 The IWG.SC-CO2 values are in 2007 dollars. In 2015 dollars, $16, $50, and $73 in 2007 translates to about $18, $57, and $83, respectively, based on the Bureau of Labor Statistics GDP Series Table 1.1.4.98 https://obamawhitehouse.archives.gov/sites/default/files/omb/inforeg/august_2016_sc_ch4_sc_n2o_addendum_final_8_26_16.pdf
42
Strategy.99 As the social cost associated with the SLCP Strategy does not include the impact associated with
non-methane reductions, Table 9 underestimates the avoided social costs of this Scoping Plan as calculated
using the IWG valuations.
As this Scoping Plan is a suite of policies developed to reduce GHGs to a specific level in 2030, any alternative
scenario that also achieves the 2030 target (with the same proportion of carbon dioxide and methane
reductions) will have the same avoided social cost, as estimated using the IWG social cost of GHGs, for the
single year 2030. The social costs of alternatives could vary if the 2030 target is achieved with vastly different
ratios of carbon dioxide to methane reductions. However, all alternatives in this Scoping Plan are anticipated
to achieve the same proportion of carbon dioxide and methane reductions and will therefore all have the
same estimated avoided social damage or social cost. This social cost, as estimated in 2030 using the IWG
SC-CO2 and SC-CH4, ranges from $1.9 to $11.2 billion using the 2.5 to 5 percent discount rates, and is
estimated at $5.0 to $7.8 billion using the 3 percent discount rate. For example, in Table 9 the CH4 reductions
for the SCLP strategy are about 1 MMTCH4. That value is multiplied by the 2030 SC-CH4 values in Table 8 for
the 2030 values at the 2.5 and 5 percent discount rates to get a range of $860 to $2,260 in 2015 dollars.
99 The IWG.SC-CH4 values are in 2007 dollars. In 2015 dollars, the range of SC-CH4 translates to about $858, $1,807, and $2,259, for the 5 percent, 3 percent, and 2.5 percent discount rates, respectively. These values are based on the Bureau of Labor Statistics GDP Series Table 1.1.4.
43
table 9: estimated soCial Cost (avoided eConomiC damages) oF poliCies
or measures Considered in the 2017 sCoping plan development#
Measure (Measures in bold are included in the Scoping Plan)Range of Social Cost of Carbon
$ million USD (2015 dollars)**
50 percent Renewables Portfolio Standard (RPS)$55–$250
Mobile Sources CTF and Freight $200–$1,080
18 percent Carbon Intensity Reduction Target for LCFS -Liquid Biofuels $70–$330
Short-Lived Climate Pollutant Strategy $860-$2,260
(SC-CH4)
2x additional achievable energy efficiency in the 2015 IEPR $125–$750
Cap-and-Trade Program $610–$6,560
10 percent incremental RPS and additional 10 GW behind-the-meter solar PV*$250–$1,160
25 percent Carbon Intensity Reduction Target for LCFS and a Low-Emission Diesel Standard
- Liquid Biofuels*$90–$415
20 percent Refinery $55–$500
30 percent Refinery $20–$250
25 percent Industry $20–$415
25 percent Oil and Gas $35–$330
5 percent Increased Utilization of RNG (core and non-core)$35–$165
Mobile Source Strategy (CTF) with Increased ZEVs in South Coast and early retirement of
LDVs with more efficient LDVs*$55–$500
2.5x additional achievable energy efficiency in the 2015 IEPR, electrification of buildings
(heat pumps and res. electric stoves) and early retirement of HVAC*$70–$580
Carbon Tax $775–$8,300
All Cap-and-Trade $700–$6,890
Cap-and-Tax $775–$8,300
Scoping Plan Scenario SC-CO2Scoping Plan Scenario SC-CH4Scoping Plan Scenario (Total)
$1,060–$8,970
$860–$2,260
$1,920–$11,230
Note: All values are rounded. The values for SC-CO2 and SC-CH4 in 2030 are presented in Tables 7 and 8.
* Where enhancements have been made to a measure or policy, the ranges in emissions reductions are incremental to the
original measure. For example, the ranges for the 25 percent LCFS are incremental to the emissions ranges for the 18 percent LCFS.
# Measures included in the Scoping Plan and the All Cap-and-Trade measure reflect emissions reductions from modeling changes
after passage of AB 398. Emissions reductions from all other measures reflect modeling completed prior to passage of AB 398.
See Appendix G for additional details.
** All values have been rounded to the nearest 0 or 5.
~ Some measures do not show a significant change in 2030 when there is an incremental increase in measure stringency or when modeling uncertainty was factored.
44
Social Costs of GHGs in Relation to Cost-Effectiveness
AB 32 includes a requirement that “rules and regulations achieve the maximum technologically feasible and cost-effective greenhouse gas emissions reductions.”100 Under AB 32, cost-effectiveness means the relative cost per metric ton of various GHG reduction strategies, which is the traditional cost metric associated with
emission control. In contrast, the SC-CO2, SC-CH4, and SC-N2O are estimates of the economic benefits, and
not the cost of reducing GHG emissions.
There may be technologies or policies that do not appear to be cost-effective when compared to the SC-
CO2, SC-CH4, and SC-N2O associated with GHG reductions. However, these technologies or policies may
result in other benefits that are not reflected in the IWG social costs. For instance, the evaluation of social
costs might include health impacts due to changes in local air pollution that result from reductions in GHGs,
diversification of the portfolio of transportation fuels (a goal outlined in the LCFS) and reductions in criteria
pollutant emissions from power plants (as in the RPS).
Estimated Cost Per Metric Ton by Measure
AB 197 also requires an estimation of the cost-effectiveness of the potential measures evaluated for
the Scoping Plan. The values provided in Table 10 are estimates of the cost per metric ton of estimated
reductions for each measure in 2030. To capture the fuel and GHG impacts of investments made from 2021
through 2030 to meet the 2030 GHG goal, the table also includes an evaluation of the cost per metric ton
based on the cumulative GHG emissions reductions and cumulative costs or savings for each potential
measure from 2021 through 2030. While it is important to understand the relative cost effectiveness of measures, the economic analysis presented in Appendix E provides a more comprehensive analysis of how the Scoping Plan and alternative scenarios affect the State’s economy and jobs.
The cost (or savings) per metric ton of CO2e reduced for each of the measures is one metric for comparing the performance of the measures. Additional factors beyond the cost per metric ton that could be considered include continuity with existing laws and policies, implementation feasibility, contribution to fuel diversity and
technology transformation goals, as well as health and other benefits to California. These considerations are
not reflected in the cost per ton metric below.
Because many of the measures interact with each other, isolating the cost and GHG savings of an individual
measures is analytically challenging. For example, the performance of the renewable electricity measure
impacts the GHG savings and cost per ton associated with increasing the use of electric vehicles. Likewise,
the increased use of electric vehicles may increase flexible loads on the electric system, enabling increased
levels of renewable electricity to be achieved more cost effectively. Both the renewable electricity measure
and the increased use of electric vehicles affect the cost of meeting the Low-Carbon Fuel Standard.
For most of the measures shown in Table 10, the 2030 cost per metric ton is isolated from the other measures
by performing a series of sensitivity model runs in the California PATHWAYS model. This cost per metric ton
is calculated as the difference in the 2030 annualized cost (or savings) with and without the measure. For
the measures in the Scoping Plan Scenario, the analysis starts with the Scoping Plan Scenario PATHWAYS
estimates, and then costs and emissions are recalculated with each measure removed individually. For
measures included in the No Cap-and-Trade Scenario, the approach starts with the No Cap-and-Trade
Scenario PATHWAYS estimates and then each measure is removed. Using this approach, the incremental impact on GHG emissions and costs for each measure is calculated. The incremental cost in 2030 is divided by the incremental GHG emission impact to calculate the cost per ton in 2030.
The same approach of removing each measure individually is used to estimate the incremental cost and emission impacts of each measure for the period 2021 to 2030. For each measure, its annual incremental costs from 2021 to 2030 are calculated and then discounted to 2021 using the discount rate used in PATHWAYS to levelize capital costs over the life of equipment. As a result, the discounted incremental cost of each measure is the total investment required from 2021 to 2030 to achieve each measure’s emissions
reductions from 2021 to 2030 (including both incremental capital costs and incremental fuel savings/
expenditures). This discounted cost for each measure was divided by its cumulative emissions reductions from
2021 to 2030 to calculate a cost per ton for the measure for the period. A second calculation was also made
that divides each measure’s discounted cost by its discounted emissions reductions from 2021 to 2030. The
100 www.arb.ca.gov/cc/docs/ab32text.pdf
45
same discount rate is used to discount both incremental costs and emissions in this approach. The estimates
are presented in the table below.
Costs that represent transfers within the state, such as incentive payments for early retirement of equipment, are not included in this California total cost metric. The cost ranges shown below represent some of the
uncertainty inherent in estimating this metric. The details of how the ranges for each measure were estimated
are described in the footnotes below. All cost estimates have been rounded representing further uncertainty
in individual values.
It is important to note that this cost per metric ton does not represent an expected market price value for
carbon mitigation associated with these measures. In addition, the single year (2030) values and the estimates
that encompass 2021 to 2030 do not capture the fuel savings or GHG reductions associated with the full
economic lifetime of measures that have been implemented by 2030, but whose impacts extend beyond
2030. The estimates also do not capture the climate or health benefits of the GHG mitigation measures.
Table 10 also notes the measures for which sources other than the PATHWAYS model were used to develop
estimates of the cost per metric ton. The estimates in the table indicate that the relative cost of the measures
is reasonably consistent across the different measures of cost per metric ton. Measures that are relatively
less costly using the 2030 cost per metric ton are also less costly using the cost per metric ton based on the period 2021 to 2030. However, for several measures the sign of the estimate differs, such that in 2030 the measure has a positive cost while there is a negative cost for the period 2021 to 2030. This difference in sign occurs because the measure includes increasingly costly investments toward the end of the period examined.
By examining only 2030, the lower cost components of the measure that occur in earlier years are omitted,
resulting in a higher cost estimate for 2030 alone.
46
table 10: estimated Cost per metriC ton oF measures Considered in the 2017
sCoping plan development and averaged From 2021 through 2030
Important: As individual measures are designed and implemented they will be subject to further evaluation and refinement and public review, which may result in different findings than presented below. The ranges are estimates that represent current assumptions of how programs may be implemented and may vary greatly depending on the design, implementation, and performance of the policies and measures. Measures in bold text are included in the Scoping Plan.
Measure Cost/metric
ton in 2030*
Cost/metric ton
2021-2030**
50 percent Renewables Portfolio Standard (RPS) a $175 $100 to $200
Mobile Sources CFT and Freight b <$50 <$50
Liquid Biofuels (18 percent Carbon Intensity Reduction Target for LCFS) c $150 $100 to $200
Short-Lived Climate Pollutant Strategy d $25 $25
2x additional achievable energy efficiency in the 2015 IEPR f -$350 -$300 to -$200
10 percent incremental RPS and additional 10 GW behind-the-meter solar PV a $350 $250 to $450
Liquid Biofuels (25 percent Carbon Intensity Reduction Target for LCFS and a Low-Emission
Diesel Standard) b $900 $550 to $975
20 percent Refinery d $100 $50 to $100
30 percent Refinery d $300 $175 to $325
25 percent Industry d $200 $150 to $275
25 percent Oil and Gas d $125 $100 to $175
5 percent Increased Utilization of renewable natural gas - core and non-core e $1500 $1350 to $3000
Mobile Source Strategy (CFT) with Increased ZEVs in South Coast & additional reductions in
VMT and energy demand & early retirement of LDVs with more efficient LDVs b $100 <$50
2.5x additional achievable energy efficiency in the 2015 IEPR, electrification of buildings
(heat pumps & res. electric stoves) and early retirement of HVAC f $75 -$120 to -$70
* Where enhancements have been made to a measure or policy, the cost per metric ton are incremental to the original measure.
For example, the cost per metric ton for the 25 percent LCFS are incremental to the cost per metric ton for the 18 percent LCFS.
** The lower values use a cost discount rate of 10 percent and cumulative emissions for the period 2021 to 2030. The higher values
discount both costs and emissions using a discount rate of 10 percent.
a Cost estimate is based on PATHWAYS sensitivity analysis as described in the main text.
b Cost estimate is based on PATHWAYS sensitivity analysis as described in the main text.
c Liquid biofuel values are calculated as the average unsubsidized cost of biofuels supplied above that of an equivalent volume of
fossil fuels. These values do not reflect impacts from other biofuel policies, such as the Renewable Fuel Standard or production
tax credits, that are partially supported by fuel purchasers/taxpayers outside of California. Therefore, these values do not
represent LCFS program costs or potential LCFS credit prices.
d See Appendix D
e Cost estimate is based on PATHWAYS sensitivity analysis as described in the main text.
f Cost estimate is based on PATHWAYS sensitivity analysis as described in the main text. The cost per metric ton does not represent
the results of the CPUC’s or CEC’s standard cost-effectiveness evaluation tests
47
Health Analyses
Climate mitigation will result in both environmental and health benefits. This section presents information
about the potential health benefits of the Scoping Plan. The impacts are primarily from reduced particulate
matter pollution, reduced toxics pollution (both diesel combustion particles and other toxic pollutants), and
the health benefits of increased physical activity that will result from more active modes of transportation
such as walking and biking in lieu of driving. CARB is using the AB 197 air quality estimates in Table 5 as a
proxy to understand the potential health impacts from the Scoping Plan. There is uncertainty in the air quality
estimates and that is carried through to the health impacts evaluation presented here. In the future, CARB
will be working to explore how to better integrate health analysis and health considerations in the design and implementation of climate programs.
Because the health endpoints of each of these benefits is different (e.g., fewer incidences of premature
mortality, lower cancer risk, and fewer incidences of heart disease), the methodologies for estimating the benefits differ. Further, the methodologies are statistical estimates of adverse health outcomes aggregated to the statewide level. Therefore, this information should only be used to understand the relative health benefits of the various strategies and should not be taken as an absolute estimate of the health outcomes of
the Scoping Plan statewide, or within a specific community. The latter is a function of the unique exposure
to air pollutants within each community and each individual’s choice of more active transport modes that
increase physical activity.
The estimates of health benefits in this section do not include any potential avoided adverse health impacts
associated with a reduction in global climate change. While we recognize that mitigating climate change
will, for example, prevent atmospheric temperature rise, thereby preventing increases in ozone in California,
which will result in fewer breathing problems, the connection is difficult to estimate or model. Since it takes
collective global action to mitigate climate change, the following analyses do not attempt to quantify the
improved health outcomes from reducing or stopping the rise in global temperatures.
The estimated statewide health benefits of the Scoping Plan are dominated by reductions in particulate
matter from mobile sources and wood burning and a switch to more active transport modes. In particular,
the focus on the impacts of exposure to particulate matter from mobile sources is expected because this is a
major cause of air pollution statewide. For this reason, the actions concerning mobile sources in the Scoping
Plan were specifically developed with the goal of achieving health-based air quality standards by reducing
criteria and toxics emissions as well as GHG emissions simultaneously. In addition, actions that support walkable communities not only result in reduced VMT and related GHG emissions, but promote active transport and increased physical activity that is strongly related to improved health.
Table 11 provides a summary of the total estimated health benefits from the relevant metrics for the Scoping Plan. The sections below summarize the methodologies used to estimate these benefits. More detail on how these estimates were calculated can be found in Appendix G. The air pollutant values used in estimating the health impacts are from Table 5 and all caveats in the estimation of the air quality impacts
must be considered when reviewing the health impacts discussed below as the air pollutant values are likely
overestimates based on assigned relationships to GHGs that may not be real.
Potential Health Impacts of Reductions in Particulate Matter Air Pollution
CARB relied on an U.S. EPA-approved methodology to estimate the health impacts of reducing air pollution
by actions in the Scoping Plan. This methodology relies on an incidents-per-ton factor to quantify the health
benefits of directly emitted (diesel particles and wood smoke) and secondary PM2.5 formed from oxides of
nitrogen from reductions due to regulatory controls. It is similar in concept to the methodology developed
by the U.S. EPA for comparable estimations101, but uses California air basin specific relationships between
emissions and air quality. The basis of the methodology is an approximately linear relationship between
changes in PM2.5 emissions and estimated changes in health outcomes. In this methodology, the number
of premature deaths is estimated by multiplying emissions by the incidents-per-ton scaling factor. The
factors are derived from studies that correlate the number of incidents (premature deaths, hospitalizations,
emergency room visits) associated with exposure to PM2.5.
101 Fann, N., Fulcher, C.M, & Hubbell, B.J. (2009) The influence of location, source, and emission type in estimates of the human health benefits of reducing a ton of air pollution. (2009)Air Quality, Atmosphere & Health 2(3), 169–176
48
Potential Health Impacts of Reductions in Toxic Air Pollution
A number of factors complicate any attempt to evaluate the health benefits of reducing exposure to toxic air pollution. First, there are hundreds of individual chemicals of concern with widely varying health effects and
potencies. Therefore, a single metric is of limited value in capturing the range of potential toxics benefits.
Furthermore, unlike the criteria pollutants whose impacts are generally measured on regional scales, toxics
pose concern for both near-source impacts and larger-scale photochemical transformations and transport.
Finally, the accepted scientific understanding for cancer risk is that there is usually no safe threshold for
exposures to carcinogens. Therefore, cancer risks are usually expressed as “chances per million” of contracting
cancer over a (70-year) lifetime exposure (in Table 11 lifetime exposure is provided in the far right column).
In light of these complexities, CARB relied on the most recent National Air Toxics Assessment (NATA)
conducted by the U.S. EPA.102 The NATA 2011 models the potential risks from breathing emissions of
approximately 180 toxic air pollutants across the country. Modeled cancer risk results are available by
census tract. The NATA data cover industrial facilities, mobile sources (on-road and off-road), small area-
wide sources, and more. CARB multiplied the NATA “cancer risk-per-million” values by census tract by the
census tract’s population, in order to estimate a population-weighted metric that could be aggregated to
the statewide level. This statistic should not be construed as actual real-world cancers (due to the many uncertainties in estimating the real-world levels of risk). Next, CARB applied the percent reductions in emissions due to Scoping Plan actions, in order to obtain an estimate of the “avoided incidence” of statistical
lifetime cancers attributable to implementation of the Scoping Plan. Again, the “avoided incidence” is a
construct designed to provide a useful statistical metric for comparative purposes among scenarios. It should
not be construed to be a real-world parameter.
Potential Health Impacts of Active Transportation
High levels of active transportation have been linked to improved health and reduced premature mortality
by increasing daily physical activity, representing a major direct co-benefit of using active transportation as
a strategy to reduce GHG emissions. The benefits of physical activity can be very large. Individuals who are
active for approximately 12 minutes a day have a 20 percent lower risk of dying early than those who are
active for just 5 minutes a day and those who are active an hour a day, have close to a 40 percent lower risk of
premature death.103
The Scoping Plan includes reductions in VMT, which can be achieved in a number of ways, including increased
active transportation. To estimate the potential health benefits of active transport, CARB staff reviewed
work done by the California Department of Public Health (CDPH) concerning the potential health benefits
associated with the Caltrans Strategic Management Plan. In this Management Plan, Caltrans set a target for
increasing the adoption of active transportation, aiming for a doubling of walking and a tripling of bicycle trips by 2020 compared to 2010. While this plan itself is not part of the Scoping Plan, it helps provide a sense of the magnitude of health benefits associated with increased active transportation.
CDPH performed a risk assessment to compare the number of premature deaths due to physical inactivity and traffic injuries in the baseline year of 2010 to the year 2020, assuming that Caltrans’ walking and bicycling mode share targets were met.104 CPDH’s methodology has been documented in a publicly available technical
manual105 and the model has appeared in many peer-reviewed research articles.106 It has been in development
102 U.S. Environmental Protection Agency (2011), National Air Toxics Assessment (NATA) 2011, https://www.epa.gov/national-air-toxics-assessment/2011-nata-assessment-results 103 U.S. Department of Health and Human Services (2008) Physical Activity Guidelines Advisory Committee. Physical Activity Guidelines Advisory Committee Report, Washington, DC104 Maizlish, N. (2016a) Increasing Walking, Cycling, and Transit: Improving Californians’ Health, Saving costs, and Reducing Greenhouse Gases. Office of Health Equity, California Department of Public Health. https://www.cdph.ca.gov/Programs/OHE/CDPH%20Document%20Library/Maizlish-2016-Increasing-Walking-Cycling-
Transit-Technical-Report-rev8-17-ADA.pdf105 Maizlish, N. (2016b) Integrated Transport and Health Impact Model (ITHIM): A Guide to Operation, Calibration and Integration with Travel Demand Models. California Spreadsheet Version December 12, 2016.106 Gotschi, T., Tainio, M., Maizlish, N., Schwanen, T., Goodman, A., & Woodcock, J. (2015). Contrasts in active transport behaviour across four countries: how do they translate into public health benefits? Preventative Medicine, 74, 42-48. doi:10.1016/j.ypmed.2015.02.009 Maizlish, N., Woodcock, J., Co, S., Ostro, B., Fanai, A., & Fairley, D. (2013). Health cobenefits and transportation-related reductions in greenhouse gas emissions in the San Francisco Bay area. American journal of public health, 103(4), 703-709. doi:10.2105/ajph.2012.300939 Whitfield, G. P., Meehan, L. A., Maizlish, N., & Wendel, A. M. (2016). The Integrated Transport and Health Impact Modeling
49
since 2009, and a California-specific version was released with a recent update in November 2016.107
CDPH estimated that 2,100 premature deaths annually would be avoided if Californians met the Management Plan’s 2020 targets were met by Californians compared to 2010 travel patterns. A recent paper by Dr. Maizlish et al108 quantified the health co-benefits of the preferred Sustainable Communities Strategies scenarios
(compared to the 2010 baseline travel pattern) for the major Metropolitan Planning Organizations using the
same methodology and found that 940 deaths annually would be avoided. For both analyses, there were
significant reductions in cause-specific premature mortality due to increased physical activity, which was
slightly counteracted by a much smaller increase in fatal traffic injuries due to the increased walking and
bicycling. When taken together, the health benefit of increasing active transportation greatly outweighed
the increased mortality from road traffic collisions. The Scoping Plan goals related to active transportation
are more aggressive than those in both the Maizlish et al. 2017 publication and the analysis by CDPH for the
Management Plan. Therefore, CARB staff used the CDPH estimate of approximately 2,100 fewer premature
deaths from the Management Plan as a lower bound of what could be realized through implementation of the VMT reductions and active transport goals called for in the Scoping Plan Scenario.
table 11: summary oF r anges oF estimated health impaC ts For the sCoping plan
sCenario in 2030
Fewer
Premature
Deaths
Fewer
Hospitalizations
(all)
Fewer ER
visits
Fewer
cancers *
Diesel PM ~60-91 ~9-14 ~25-38
Secondary PM ~76-120 ~11-17 ~33-50
Toxics ~21-61
Wood smoke ~1000 ~ 148 ~ 418
Active Transport**>2100
Total ~3300 ~180 ~500 ~21-61
* This metric should not be construed as actual real-world cancer cases. It is intended
to be a comparative metric, based on the NATA estimates of lifetime cancer risk
(chances-per-million over a 70 year life-time exposure) by census tract multiplied by
the tract population.
** Reduction in premature death assumes meeting the CSMP 2020 mode shift target.
Note: The numbers in the table represent individual avoided incidences.
Tool in Nashville, Tennessee, USA: Implementation Steps and Lessons Learned. Journal of transport & health, 3. doi:10.1016/j. jth.2016.06.009 Woodcock, J. (2015). Integrated Transport and Health Impact Modelling Tool (ITHIM). Retrieved from http://www.cedar.iph.cam.ac.uk/research/modelling/ithim/ Woodcock, J., Edwards, P., Tonne, C., Armstrong, B. G., Ashiru, O., Banister, D., & Roberts, I. (2009). Public health benefits of strategies to reduce greenhouse-gas emissions: urban land transport. Lancet, 374(9705), 1930-1943. doi:10.1016/s0140- 6736(09)61714-1 Woodcock, J., Givoni, M., & Morgan, A. S. (2013). Health impact modelling of active travel visions for England and Wales using an Integrated Transport and Health Impact Modelling Tool (ITHIM). PLoS One, 8(1), e51462. doi:10.1371/journal.pone.0051462 Woodcock, J., Tainio, M., Cheshire, J., O’Brien, O., & Goodman, A. (2014). Health effects of the London bicycle sharing system: health impact modelling study. BMJ (Clinical research ed.), 348, g425. doi:10.1136/bmj.g425107 Woodcock, J. Maizlish, N. (2016). ITHIM: Integrated Transport & Health Impact Modelling, California Version, November 11, 2016. Original citation: Woodcock J, Givoni M, Morgan AS. Health Impact Modelling of Active Travel Visions for England and Wales Using an Integrated Transport and Health Impact Modelling Tool (ITHIM). PLoS One. 2013;8(1):e51462.108 Maizlish N, Linesch N,& Woodcock J.(2017) Health and greenhouse gas mitigation benefits of ambitious expansion of cycling, walking, and transit in California. Journal of Transport and Health. ; doi: 10.1016/j.jth.2017.04.011
50
Future Health Activities
As Table 11 shows, the Scoping Plan measures would have significant potential positive health outcomes. The integrated nature of the strategies to reduce emissions of GHGs and criteria and toxics emissions could
provide multiple benefits. Actions to reduce black carbon from wood smoke are reducing the same particles
that lead to premature mortality. Reductions in fossil combustion will not only reduce GHG emissions, but
also toxics emissions. Finally, reducing VMT with strategies that provide opportunities for people to switch to
active transport modes can have very large health benefits resulting from increased physical activity.
In recognition of the potential for significant positive health benefits of the Scoping Plan, CARB is initiating
a process to better understand how to integrate health analysis broadly into the design and implementation
of our climate change programs with the goal of maximizing the health benefits. Although health impact
assessments have been used to inform CARB’s policymaking, these analyses have not been consistently
integrated into the general up-front design of CARB programs. To begin the effort to increase health benefits
from climate change mitigation policies, CARB will convene a public meeting in Spring 2018 to solicit input on
how best to incorporate health analyses into our policy development. CARB staff will seek appropriate tools
for these analyses and will assemble a team of academic advisors to provide input on the latest developments
in methods and data sources.
Economic Analyses
The following section outlines the economic impact of the Scoping Plan relative to the business-as-usual
Reference Scenario. Additional detail on the economic analysis, including modeling details and the estimated
economic impact of alternative scenarios is presented in Appendix E.
The Scoping Plan outlines a path to achieve the SB 32 target that requires less reliance on fossil fuels and
increased investment in low carbon fuels and clean energy technologies. Through this shift, California can
lead the world in developing the technologies needed to reduce the global risks of climate change. This
builds on California’s current successes of reducing GHG emissions while also developing a cleaner, resilient
economy that uses less energy and generates less pollution. Innovation in low-carbon technologies will
continue to open growth opportunities for investors and businesses in California. As modeled, the analysis in this Scoping Plan suggests that the costs of transitioning to this lower carbon economy are small, even without counting the potential opportunities for new industries and innovation in California. Under the
Scoping Plan, the California economy, employment, and personal income will continue to grow as California
businesses and consumers make clean energy investments and improve efficiency and productivity to reduce
energy costs.
In 2030, the California economy is projected to grow to $3.4 trillion, an average growth rate of 2.2 percent
per year from 2021 to 2030. It is not anticipated that implementation of the Scoping Plan will change the
growth of annual State Gross Domestic Product (GDP). Further, this growth in GDP will occur under the entire
projected range of Cap-and-Trade Program allowance prices. Based on this analysis, in 2030 the California
economy will take only three months longer to grow to the GDP estimated in the absence of the Scoping
Plan–referred to as the Reference Scenario. The impact of the Scoping Plan on job growth is also negligible,
with employment less than one half of one percent smaller in 2030 compared to the Reference Scenario.
Additionally, reducing GHG emissions 40 percent below 1990 levels under the Scoping Plan will lead to avoided
social damages from climate change on the order of $1.9 to $11.2 billion, as estimated using the SC-CO2 and
SC-CH4, as well as additional potential savings from reductions in air pollution and petroleum dependence.
These impacts are not accounted for in this economic analysis. The estimated impact to California households
is also modest in 2030. In 2030, the average annual household impact of the Scoping Plan ranges from $115 to
$280, depending on the price of reductions under the Cap-and-Trade Program.109 Estimated personal income in California is also relatively unchanged by the implementation of the Scoping Plan.
109 Household projections are obtained from the California Department of Finance and were access on March 16, 2017 at: http://www.dof.ca.gov/Forecasting/Demographics/projections/.
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Overview of Economic Modeling
Two models are used to estimate the economic impact of the Scoping Plan and California’s continued clean
energy transition: (1) the California PATHWAYS model, and (2) the Regional Economic Models, Inc. (REMI)
Policy Insight Plus model. The California PATHWAYS model estimates the direct costs and GHG emissions
reductions of implementing the prescriptive (or non-Cap-and-Trade) measures in the Scoping Plan relative
to the BAU scenario.110 Direct costs are the sum of the incremental changes in capital expenditures and fuel
expenditures, including fuel savings for reduced energy use from efficiency measures. In most cases, reducing GHG emissions requires the use of more expensive equipment that can be operated using less fuel. In the Scoping Plan, the prescriptive measures modeled in PATHWAYS account for a portion of the GHG reductions required to meet the 2030 target. The remaining reductions are delivered through the Cap-and-Trade Program. The direct costs associated with the Cap-and-Trade Program are calculated outside of PATHWAYS
based on an assumed range of Cap-and-Trade allowance prices from 2021 through 2030.
To estimate the future costs of the Scoping Plan, this economic analysis necessarily creates a hypothetical
future California that is essentially identical to today, adjusted for currently existing climate policy as well
as projected economic and population growth through 2030. The analysis cannot predict the types of
innovation that will create efficiencies nor can it fully account for the significant economic benefits associated
with reducing emissions. Rather, the economic modeling is conducted by estimating incremental capital and
clean fuel costs of measures and assigning those costs to certain sectors within this hypothetical future.
The macroeconomic impacts of the Scoping Plan on the California economy are modeled using the REMI
model with output from California PATHWAYS and estimated Cap-and-Trade Program costs as inputs.
Additional methodological detail is presented in Appendix E.111
Estimated Cost of Prescriptive Measures
As described above, the Scoping Plan combines new measures addressing legislative mandates and
the extension of existing measures, including a comprehensive cap on overall GHG emissions from the
State’s largest sources of pollution. The PATHWAYS model calculates costs and GHG emissions reductions
associated with the prescriptive measures in the Scoping Plan. Changes in energy use and capital investment
are calculated in PATHWAYS and represent the estimated cost of achieving an estimated 50 to 70 percent of
the cumulative GHG reductions required to reach the SB 32 target between 2021 and 2030. The Cap-and-
Trade Program delivers any remaining reductions, as shown in Figure 8.
Table 12 outlines the cost of prescriptive measures by sector in 2030, compared to the Reference Scenario,
as calculated in PATHWAYS. Estimated capital costs of equipment are levelized over the life of the equipment
using a 10 percent discount rate and fuel costs are calculated on an annual basis.112 The costs in Table 12
are disaggregated into capital costs and fuel costs, which includes the varying costs of gasoline, diesel,
biofuels, natural gas, electricity and other fuels.113 Table 12 assumes that all prescriptive measures deliver anticipated GHG reductions, and does not include any uncertainty in GHG reductions or cost.114 The impact of uncertainty in GHG reductions is explored in more detail in Appendices E, which include additional detail on measure, cost, and Reference Scenario uncertainty.
The prescriptive measures result in incremental capital investments of $6.7 billion per year in 2030, but these annual capital costs are nearly offset by annual fuel savings of $6.6 billion in 2030. The incremental net cost of prescriptive measures in the Scoping Plan is estimated at $100 million in 2030, which represents 0.03 percent
of the projected California economy in 2030. The residential and transportation sectors are anticipated to
see net savings in 2030 as fuel savings for these areas vastly outweigh annual capital investment. Several
sectors will see a net cost increase from implementation of the prescriptive measures. The industrial sector
sees higher fuel costs relative to the Reference Scenario. In the agriculture sector, capital expenditures are
due to investments in more efficient lighting and the mitigation of agricultural methane and nitrogen oxides.
Agricultural fuel costs increase due to higher electricity and liquid biofuel costs.
110 The PATHWAYS modeling is described in Chapter 2, and additional detail is presented in Appendix D. 111 Additional modeling details are available at the REMI PI+ webpage: http://www.remi.com/products/pi.112 PATHWAYS costs are calculated in real $2012. For this analysis, all costs are reported in $2015. The PATHWAYS
costs are inflated using Bureau of Economic Analysis (BEA) data available at: https://www.bea.gov/iTable/iTable.
cfm?ReqID=9#reqid=9&step=1&isuri=1&903=4.113 Additional information on the fuels included in PATHWAYS is available at: www.arb.ca.gov/cc/scopingplan/meetings/1142016/
e3pathways.pdf.114 More information on the inputs to the California PATHWAYS model is available at: www.arb.ca.gov/cc/scopingplan/scoping_plan_
scenario_description2016-12-01.pdf.
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table 12: Change in pathways seCtor Costs in 2030 relative to the reFerenCe
sCenario (billion $2015)115
End Use Sector116 Levelized
Capital Cost
Fuel Cost Total Annual
Cost
Residential $0.1 -$1.2 -$1.1
Commercial $1.8 -$1.8 $0.1
Transportation $3.5 -$3.8 -$0.3
Industrial $0.8 $0.3 $0.5
Oil and Gas Extraction $0.0 $0.0 $0.1
Petroleum Refining $0.0 $0.0 $0.0
Agriculture $0.3 $0.2 $0.5
TCU (Transportation
Communications and Utilities)
$0.1 $0.1 $0.2
Total $6.7 -$6.6 $0.1
Note: Table values may not add due to rounding.
Estimated Cost of the Cap-and-Trade Program
The direct cost of achieving GHG reductions through the Cap-and-Trade Program is estimated outside of
PATHWAYS. The Cap-and-Trade Program sets an economy-wide GHG emissions cap and gives firms the
flexibility to choose the lowest-cost approach to reduce emissions. As with the prescriptive measures, the
direct costs of any single specific GHG reduction activity under the Cap-and-Trade Program is subject to
a large degree of uncertainty. However, as Cap-and-Trade allows covered entities to pursue the reduction
options that emerge as the most efficient, overall abatement costs can be bounded by the allowance price. Covered entities should pursue reduction actions with costs less than or equal to the allowance price. An upper bound on the compliance costs under the Cap-and-Trade Program can therefore be estimated by multiplying the range of anticipated allowance prices by the anticipated GHG reductions needed (in
conjunction with the reductions achieved through the prescriptive measures) to achieve the SB 32 target.
A large number of factors influence the allowance price, including the ease of substituting lower carbon production methods, consumer price response, the pace of technological progress, and impacts to the price
of fuel. Other policy factors that also affect the allowance price include the use of auction proceeds from the
sale of State-owned allowances and linkage with other jurisdictions.
Flexibility allows the Cap-and-Trade allowance price to adjust to changes in supply and demand while a firm
cap ensures GHG reductions are achieved. This analysis includes a range of allowance prices bounded at the
low end by the Cap-and-Trade auction floor price (C+T Floor Price) which represents the minimum sales price
for allowances sold at auction and the Allowance Price Containment Reserve Price (C+T Reserve Price), which
represents the price at which an additional pool of allowances will be made available to ensure entities can
comply with the Cap-and-Trade Program and is the highest anticipated price under the Program. Table 13
outlines the projected allowance prices used in this analysis.117
115 PATHWAYS costs reported in $2012 are inflated to $2015 using the Bureau of Economic Analysis (BEA) data available at: https://www.bea.gov/iTable/iTable.cfm?ReqID=9#reqid=9&step=1&isuri=1&903=4.116 Information on the end use sectors are available in the California PATHWAYS documentation available at: www.arb.ca.gov/cc/scopingplan/scopingplan.htm.117 The Cap-and-Trade allowance price range is based on the Cap-and-Trade Regulation approved by the Office of Administrative
53
table 13: estimated r ange oF Cap-and-trade allowanCe priCe 2021–2030*
($2015)2021 2025 2030
C+T Floor Price $16.2 $19.7 $25.2
C+T Reserve Price $72.9 $76.4 $81.9
* Based on current regulation in effect October 1, 2017
Uncertainty in the GHG reduction potential of prescriptive measures in the Scoping Plan can affect the cost of
achieving the 2030 target. The aggregate emissions cap of the Cap-and-Trade Program ensures that the 2030 target will be met–irrespective of the GHG emissions realized through prescriptive measures. If GHG reductions anticipated under prescriptive measures do not materialize, the Cap-and-Trade Program will be responsible for a larger share of emissions reductions. Under that scenario, the demand for Cap-and-Trade allowances may
rise, resulting in an increase in allowance price. While the Cap-and-Trade allowance price may rise, it is highly
unlikely that it will rise above the C+T Reserve price, given the program design. If prescriptive measures deliver
anticipated GHG reductions, demand for allowances will be low, depressing the price of allowances. However,
the C+T Floor Price represents the lowest price at which allowances can be sold at auction.
Table 14 presents the estimated direct cost estimates for GHG reductions achieved through the Cap-and-
Trade Program in 2030. These costs represent the lower and upper bounds of the cost of reducing GHG
emissions to achieve the SB 32 target under the Scoping Plan. The estimated direct costs range from $1.6 to
$5.1 billion dollars (in $2015), depending on the allowance price in 2030. This range highlights the allowance
price uncertainty that is a trade-off to the GHG reduction certainty provided by the Cap-and-Trade Program.
The estimated cost of GHG reductions is calculated by multiplying the allowance price by the GHG emissions
reductions required to achieve the SB 32 target.
Sensitivity Analysis
In addition to uncertainty in the Cap-and-Trade allowance price and uncertainty in the GHG reductions
achieved through the prescriptive measures, there is uncertainty in the GHG emissions that will occur under
the Reference Scenario, as presented in Figure 6. There is also uncertainty in costs embedded within the
Reference Scenario including the price of oil, other energy costs, and technology costs.
The PATHWAYS incremental cost results are also sensitive to the fossil fuel price assumptions. Altering
the fuel price trajectory in the Reference Scenario directly impacts the incremental cost of achieving GHG
reductions in the Scoping Plan, as the costs of the Scoping Plan are relative to the Reference Scenario.118
The PATHWAYS scenarios use fossil fuel price projections from the Annual Energy Outlook (AEO) 2015
reference case.119 To estimate the impact of changes in future fuel prices on the estimated incremental cost
of the Scoping Plan two sensitivities were conducted. In the low fuel price sensitivity, the AEO low oil and
natural gas price case is used to project the future cost of fuels in the Reference Scenario. The cost of the
Scoping Plan, relative to the Reference Scenario, increases under these conditions, since fuel savings are less valuable when fuel prices are low. A second sensitivity shows that high future oil and natural gas prices (as projected in the AEO high oil price case) reduce the net cost of the Scoping Plan, relative to the Reference Scenario. This is because avoided fuel savings are more valuable when fuel prices are high. Table 14 outlines
the costs and savings from the Scoping Plan (both prescriptive measures and cap-and-trade) under the high
and low fuel price sensitivities.
The price of oil and natural gas affects the value of fuel savings (as presented in Table 12), which are
estimated to be significant using AEO reference oil and natural gas prices. Under the low fuel price sensitivity,
Law on September 18, 2017. Documentation is available at: www.arb.ca.gov/regact/2016/capandtrade16/capandtrade16.htm 118 In addition to the fuel cost sensitivities presented in this section, Appendix E includes an uncertainty analysis of the Scoping Plan Scenario and alternatives. This analysis addresses uncertainty in the Reference Scenario emissions, GHG reductions from each measure, as well as capital and fuel costs.119 The high and low fuel price sensitivity ranges are derived from differences between the AEO 2016 High Oil Price or Low Oil Price forecast and the AEO 2016 reference case, and are applied as ratios to the base case fuel price assumptions (which are based on the AEO 2015 report). The AEO 2015 report is available at: http://www.eia.gov/outlooks/aeo/pdf/0383(2015).pdf and the AEO 2016 report is available for download at: http://www.eia.gov/outlooks/aeo/pdf/0383(2016).pdf.
54
the net incremental cost of prescriptive measures is $2.9 billion in 2030. Under the high fuel price sensitivity,
the prescriptive measures result in net savings of $4.9 billion in 2030. Table 14 also shows that these price
uncertainties are captured within the analyzed range of allowance prices. As described above, changes in
fuel prices may affect the price of Cap-and-Trade allowances, but the price is highly unlikely to go outside
the range of prices bounded by the C+T Floor Price and C+T Reserve Price. The final column in Table 14
presents the estimated direct cost of the Scoping Plan, including both the prescriptive measures and a range
of estimated costs to achieve GHG reductions under the Cap-and-Trade Program for varying projections
of future fuel prices. The total cost, reflecting fuel and allowance price uncertainty, ranges from an annual
savings to California of $3.3 billion to an annual cost of $8.0 billion in 2030. The net climate benefits, as
estimated by the SC-CO2 and SC-CH4, outweigh these direct costs.120
table 14: estimates oF direCt Cost and Climate beneFits in 2030 relative to
the reFerenCe sCenario and inCluding Fuel priCe sensitivity (billion $2015)
Scenario Prescriptive
Measures
C+T Floor
Price
C+T Reserve
Price
2030 Total
Cost
Scoping Plan $0.1 $1.6 $5.1 $1.7 to $5.2
Low Fuel Price Sensitivity $2.9 $1.6 $5.1 $4.5 to $8.0
High Fuel Price Sensitivity -$4.9 $1.6 $5.1 -$3.3 to -$0.2
Fuel price sensitivity is directly modeled in PATHWAYS, resulting in a range of impacts from prescriptive measures. The range of costs
labeled “2030 Total Cost” includes the cost of prescriptive measures estimated in PATHWAYS and the impact of the Cap and-Trade
Program calculated at the C+T Floor Price (the lower bounds) and the C+T Reserve Price (the upper bounds).The social cost of GHGs estimated range in 2030 is $1.9 to $11.2 billion.
Macroeconomic Impacts
The macroeconomic impacts of the Scoping Plan are estimated using the REMI model. Annual capital and
fuel costs (for example, the costs in Table 12) are estimated using PATHWAYS and input into the REMI model
to estimate the impact of the Scoping Plan on the California economy each year relative to GDP, which is
often used as a proxy for economic growth, as well as employment, personal income, and changes in output
by sector and consumer spending. Table 15 presents key macroeconomic impacts of implementing the
Scoping Plan, based on the range of anticipated allowance prices. In 2030, under the Scoping Plan, growth
across the indicators is about one-half of one percent less than the Reference Scenario. The results in Table 15
include not only the estimated direct cost of the Cap-and-Trade Program, but also distribution of allowance
value from the auction of Cap-and-Trade allowances to California and consumers. See Appendix E for more detail on the modeling of the return of allowance value under the Cap-and-Trade Program in REMI.
The Cap-and-Trade Program is modeled in REMI as an increase in production cost to sectors based on
estimated future GHG emissions and anticipated free allowance allocation. If a sector is expected to receive
free allocation of allowances, the value of those free allowances is not modeled as a cost in REMI. The analysis does include the estimated benefit to sectors due to the proceeds from the auction of cap-and-trade allowances and assumes that each year $2 billion of proceeds from the auction of State-owned cap-and-
trade allowances are distributed to the economic sectors currently receiving GGRF appropriations. These
funds work to achieve further GHG reductions in California, lower the cost to businesses of reducing GHG
emissions and protect disadvantaged communities. Any auction proceeds remaining after the distribution
of $2 billion through GGRF sectors are distributed evenly to consumers in California as a dividend. The
estimated costs in Table 15 include the cost of the GHG reductions to sectors, as well as the benefit to
those sectors when allowance proceeds are returned through the GGRF and as a dividend to consumers, as
detailed in Appendix E.
120 Climate benefits are estimated using the Social Cost of Carbon in 2030 across the range of discount rates from 2.5 to 5 percent. All values are reported in $2015. Additional information on the Social Cost of Carbon is available from the National Academies of Sciences, Engineering, and Medicine at: https://www.nap.edu/catalog/24651/valuing-climate-damages-updating-estimation-of-
the-social-cost-of.
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table 15: maCroeConomiC indiCators in 2030 under base Fuel priCe assumptions
Reference Scenario
(2030)
Scoping Plan
(2030)
Percentage Change Relative
to Reference Scenario
California GDP (Billion
$2015)
$3,439 $3,430 to $3,420 -0.3 percent to
-0.6 percent
Employment (Thousand
Jobs)
23,522 23,478 to 23,441 -0.2 percent to
-0.3 percent
Personal Income
(Billion $2015)
$3,010 $3,006 to $3,008 -0.1 percent to
-0.1 percent
Table 15 was estimated using the REMI model. The range of costs for the Scoping Plan represents the impact of achieving the SB 32
target through prescriptive measures and the Cap-and-Trade Program at the C+T Floor Price (the lower bounds) and the C+T Reserve
Price (the upper bounds).
It is important to put the results of Table 15 into context of the growing $3.4 trillion California economy in
2030. As noted earlier, the economic analysis does not include avoided social damages and other potential
savings from reductions in air pollution and petroleum dependency.
Determining employment changes as a result of policies is challenging to model, due to a range of uncertainties
and global trends that will influence the California economy, regardless of implementation of the Scoping Plan.
The global economy is seeing a shift toward automation and mechanization, which may lead to slowing of
employment across some industries globally, irrespective of California’s energy and low carbon investments. In California, employment is projected to reach 23.5 million jobs in 2030. In this analysis, implementing the Scoping Plan would slow the growth of employment by less than one-half of one percent in 2030.
Estimated personal income in California is relatively unchanged under the Scoping Plan relative to the Reference Scenario. Considering the uncertainty in the modeling, modest changes in the growth of personal income are not different from zero, which suggests that meeting the SB 32 target will not change the growth of personal income relative to the Reference Scenario.
When analyzing the estimated macroeconomic impacts, it is important to remember that a major substitution of electricity and capital away from fossil fuels is anticipated to have a very small effect on California GDP, employment, and personal income–less than one percent relative to the Reference Scenario in 2030. The
economic impacts indicate that shifting money and investment away from fossil fuels and to clean energy
is likely to have a negligible effect on the California economy. Additionally, it is certain that innovation will
continue as new technologies are developed and implemented. While this analysis projects the costs and
GHG reductions of current technologies over time, it does not capture the impact of new technologies that
may shift the economy and California in unanticipated ways or benefits related to changes in air pollution
and improvements to human health, avoided environmental damages, and positive impacts to natural and
working lands. Thus, the results of this analysis very likely underestimate the benefits of shifting to a clean
energy economy.
Consumer spending also shifts in response to implementation of the Scoping Plan relative to the Reference
Scenario. As presented in Table 15, there is a negligible impact to consumer income, but small changes in
income can alter the distribution of consumer spending among categories. In 2030, consumer spending is
lower under the Scoping Plan than in the Reference Scenario across all analyzed allowance prices. Consumers spend less on fuels, electricity, natural gas, and capital as a result of measures in the Scoping Plan that reduce demand, increase efficiency, and drive technological innovations. The estimated impact to California households is also modest in 2030. The estimated cost to California households in 2030 ranges from $115 to
$280, depending on the price of reductions under the Cap-and-Trade Program.121
The household impact is estimated using the per-household change in personal income as modeled in REMI and utilizing household estimates from the California Department of Finance. The household impact does not
account for benefits from reduced climate impacts, health savings from reduced air pollution impacts, or lower
petroleum dependence costs that might impact households. Additional details are presented in Appendix E.
As modeled, the household impact of the Scoping Plan comprises approximately one percent of average
household expenditures in 2030. To ensure that vulnerable populations and low-income households are not
121 Household projections are obtained from the California Department of Finance and are available at: http://www.dof.ca.gov/Forecasting/Demographics/projections/.
56
disproportionately affected by California’s climate policy, CARB is taking steps to better quantify localized
economic impacts and ensure that low-income households see tangible benefits from the Scoping Plan.
Researchers at the University of California, Los Angeles (UCLA) are currently working on a retrospective
analysis that will estimate the impacts across California communities of the implementation of AB 32, which
will help identify areas of focus as 2030 measures are developed. The Cap-and-Trade Program will also
continue to provide benefit to disadvantaged communities through the disbursement of GGRF funds.
The investments made in implementing the Scoping Plan will have long-term benefits and present significant
opportunities for California investors and businesses, as upfront capital investments will result in long-term
fuel and energy efficiency savings, the benefits of which will continue into the future. The California economy
will continue to grow under the Scoping Plan, but it will grow more resilient, more sustainable, and will be
well positioned to reap the long-term benefits of lower carbon investments.
Economic Modeling of Health Impacts
Health benefits associated with reductions in diesel particulate matter (DPM) and nitrogen oxides (NOX) are
monetized for inclusion in the macroeconomic modeling. The health benefits are estimated by quantifying the
harmful future health effects that will be avoided by reducing human exposure to DPM and NOX, as detailed
in Appendix G, and monetized by estimating a health effect’s economic value to society. As previously noted
the health impacts are based on air quality benefits estimated in Table 6, which have important limitations
and likely overestimate the impacts of the Scoping Plan. Additional detail on the economic modeling of
health impacts, including the monetization methodology and modeling results for all Scoping Plan scenarios, is presented in Appendix E. Including the monetized health impacts in the REMI modeling has no discernible impact on the overall results. The impact of including the monetized health impacts is indiscernible relative to the impact of the Scoping Plan.
Estimating the Economic Impact on Disadvantaged Communities (DACs)
Implementing the Scoping Plan is estimated to have a small impact on the Statewide California economy
through 2030. However, shifting from fossil fuels can disproportionately affect specific geographic regions whose local economies rely on fossil fuel intensive industries. These regions can also include vulnerable populations and disadvantaged communities who may be disproportionately impacted by poor air quality and climate.
The regional impacts of the Scoping Plan, including the impact to disadvantaged communities, are estimated using the REMI California County model, which represents the 58 counties and 160 sectors of the California economy. Utilizing the same inputs used for modeling the statewide impact of the Scoping Plan relative to
the Reference Scenario, the California County model estimates how measures will affect employment, value
added, and other economic indicators at the county level across the state.
The county-level REMI output is also used to estimate impacts on disadvantaged communities affected by
the Scoping Plan by allocating county impacts proportional to their share of economic indicators unique to
each census tract.122 These indicators include industry output, industry consumption by fuel category, personal
consumption, and population. The overall impact on employment across regions is not significant and there
is no discernible difference in the impact to employment in disadvantaged communities. There is also no
discernible impact to wages in disadvantaged communities across regions in California. Additional details on
the regional modeling, including the results for the Scoping Plan and alternatives, is presented in Appendix E.
In addition to the regional modeling conducted in this analysis, there are currently three research contracts
underway at CARB to quantify the impact of California’s climate policy on regions and disadvantaged
communities throughout California. As mentioned above, researchers from UCLA are estimating the
improvements in health outcomes associated with AB 32, with a focus on disadvantaged communities.
This research will be informed by input from technical advisory committees including a group focused on
environmental justice.
122 Census tracts are small geographic areas within greater metropolitan areas that usually have a population between 2,500 and 8,000 persons. More information on the composition of census tracts available here: https://www.census.gov/geo/reference/
gtc/gtc_ct.html. Disadvantaged census tracts are identified using CalEnviroScreen 2.0. Additional information is available at: https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-version-20.
57
There are also two studies currently underway to quantify the impact of GGRF funds. A UCLA contract
focuses on quantifying jobs supported by GGRF funds in California, while a University of California, Berkeley
contract is constructing methodologies to assess the co-benefits of GGRF projects across California. These
research efforts will provide a regional analysis of the impact of and benefits to specific communities and
sectors to ensure that all Californians see economic benefits, in addition to clean air benefits, from the
implementing the Scoping Plan.
Public Health
Many measures to reduce GHG emissions also have significant health co-benefits that can address climate
change and improve the health and well-being of all populations across the State. Climate change is already
affecting the health of communities.123 Climate-related health impacts can include increased heat illness and
death, increases in air pollution-related exacerbation of cardiovascular and respiratory diseases, injury and
loss of life due to severe storms and flooding, increased vector-borne and water-borne diseases, and stress
and mental trauma due to extreme weather-related catastrophes.124 The urgency of action to address the
impacts already being felt from a changing climate and the threats in coming decades provides a unique
opportunity for California’s leadership in climate action to reduce GHG emissions and create healthy,
equitable, and resilient communities where all people thrive. This section discusses the link between climate
change and public health. It does not analyze the specific measures included in the strategy but provides context for assessing the potential measures and scenarios.
Achieving Health Equity through Climate Action
Many populations in California face health inequities, or unfair and unjust health differences between
population groups that are systemic and avoidable.125 Differences in environmental and socioeconomic
determinants of health result in these health inequities. Those facing the greatest health inequities include
low-income individuals and households, the very young and the very old, communities of color, and those who have been marginalized or discriminated against based on gender or race/ethnicity.126 It is these very same populations, along with those suffering existing health conditions and certain populations of workers (e.g., outdoor workers), that climate change will most disproportionately impact.127 The inequitable distribution of
social, political, and economic power results in health inequities, while perpetuating systems (e.g., economic,
transportation, land use, etc.) that drive GHG emissions. As a result, communities face inequitable living
conditions. For example, low-income communities of color tend to live in more polluted areas and face
climate change impacts that can compound and exacerbate existing sensitivities and vulnerabilities.128,129 Fair
and healthy climate action requires that the inequities creating and intensifying community vulnerabilities
be addressed. Living conditions and the forces that shape them, such as income, education, housing,
transportation, environmental quality, and access to services, significantly drive the capacity for climate
resilience. Thus, strategies such as alleviating poverty, increasing access to opportunity, improving living
conditions, and reducing health and social inequities will result in more climate-resilient communities. In fact, there are already many “no-regret” climate mitigation and adaptation measures available (discussed below) that can reduce health burdens, increase community resilience, and address social inequities.130 Focusing efforts to achieve health equity can thus lead to significant progress in addressing human-caused climate change.
123 USGCRP. 2016. The Impacts of Climate Change on Human Health in the United States: A Scientific Assessment. Crimmins, A., J. Balbus, J. L. Gamble, C. B. Beard, J. E. Bell, D. Dodgen, R. J. Eisen, N. Fann, M. D. Hawkins, S. C. Herring, L. Jantarasami, D. M. Mills, S. Saha, M. C. Sarofim, J. Trtanj, and L. Ziska, Eds. U.S. Global Change Research Program, Washington, D.C., 312 pp.124 Ibid.125 Whitehead, M. 1992. “The concepts and principles of equity and health.” International Journal of Health Services 22(3), 429–445.126 California Department of Public Health (CDPH). 2015. The Portrait of Promise: The California Statewide Plan to Promote Health and Mental Health Equity. A Report to the Legislature and the People of California by the Office of Health Equity. Sacramento, CA: California Department of Public Health, Office of Health Equity.127 Shonkoff, S., R. Morello-Frosch, M. Pastor, and J. Sadd. 2011. “The climate gap: Environmental health and equity implications of climate change and mitigation policies in California–a review of the literature.” Climatic Change 109 (Suppl 1):S485–S503.128 Ibid.129 Rudolph, L. and S. Gould. 2015. “Climate change and health inequities: A framework for action.” Annals of Global Health 81:3, 432–444.130 Watts N, Adger WN, Agnolucci P, et al. 2015. Health and climate change: policy responses to protect public health. Lancet: 386, 1861-1914
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Potential Health Impacts of Climate Change Mitigation Measures
Socioeconomic Factors: Income, Poverty, and WealthEconomic factors, such as income, poverty, and wealth, are collectively one of the largest determinants of health. As such, climate mitigation measures that yield economic benefits can improve population health
significantly, especially if the economic benefits are directed to those most vulnerable and disadvantaged
(including those living in poverty) who often face the most health challenges. From the poorest to richest
ends of the income spectrum, higher income is associated with greater longevity in the United States.131,132,133
The gap in life expectancy between the richest 1 percent and poorest 1 percent of Americans was almost 15
years for men in 2014, and about 10 years for women.134 Early death among those living in poverty is not a
result of those with higher incomes having better access to quality health care.135 Only about 10-20 percent of
a person’s health status is accounted for by health care (and 20-30 percent attributed to genetics), while the
remainder is attributed to the social determinants of health. These include environmental quality, social and
economic circumstances, and the social, media, policy, economic, retail, and built environments– all of which in turn shape stress levels and behaviors, including smoking, diet, and exercise.136 ,137,138 ,139,140,141,142,143,144,145 ,146 In fact, where people live, work, learn, and play is often a stronger predictor of life expectancy than their genetic and biological makeup.147 The World Health Organization’s Commission on the Social Determinants
of Health concluded that the poor health of poor people, and the social gradient in health, are caused by the
unequal distribution of power, income, goods, and services resulting from poor social policies and programs,
unfair economic arrangements, and bad politics.148 Thus, improving the conditions of daily life and tackling
the inequitable distribution of power, money, and resources can remedy inequitable health outcomes.149
Simply put, the more evenly distributed the wealth, the healthier a society is.150
The wealth-health gradient has significant implications for this Scoping Plan. State climate legislation and
policies require prioritizing GHG reduction strategies that serve vulnerable populations and improve well-
being for disadvantaged communities. As such, strategies that improve the financial security of communities
facing disadvantages while reducing GHG emissions are win-win strategies. These include providing funds
or services for GHG reduction programs (e.g., weatherization, energy efficiency, renewable energy, ZEVs,
transit, housing, and others) to low-income individuals and households to help them reduce costs. Among
the poorest 25 percent of people, per capita government expenditures are strongly associated with longer
131 Chetty, R., M. Stepner, S. Abraham, et al. 2016. “The Association Between Income and Life Expectancy in the United States, 2001–2014.” JAMA Published online April 10, 2016. doi:10.1001/jama.2016.4226.132 Marmot, M., S. Friel, R. Bell, et al. 2008. “Closing the gap in a generation: Health equity through action on the social determinants of health.” The Lancet 372, 9650: 1661–1669.133 Woolf, S. H., and P. Braveman. 2011. “Where health disparities begin: The role of social and economic determinants–and why current policies may make matters worse.” Health Affairs (Millwood) 30(10), 1852–1859.134 Chetty R, Stepner M, Abraham S, et al. 2016. The Association between Income and Life Expectancy in the United States, 2001- 2014. JAMA. Published online April 10, 2016. doi:10.1001/jama.2016.4226135 Ibid.136 DHHS, Public Health Service. 1980. Ten leading causes of death in the United States. Atlanta, GA: Bureau of State Services.137 McGinnis, J., and W. Foege. 1993. “Actual causes of death in the United States.” JAMA 270(18), 2207–2212.138 Lantz, P. et al. 1998. “Socioeconomic factors, health behaviors, and mortality: Results from a nationally representative prospective study of US adults.” JAMA 279(21), 1703–1708.139 McGinnis, J. et al. 2002. “The case for more active policy attention to health promotion.” Health Affairs 21(2), 78–93.140 Mokdad, A. et al. 2004. “Actual causes of death in the United States, 2000.” JAMA 291(10), 1238–1245.141 Danaei, G. et al. 2009. “The preventable causes of death in the United States: Comparative risk assessment of dietary, lifestyle, and metabolic risk factors.” PLoS Medicine 6(4), e1000058.142 World Health Organization (WHO). 2009. Global health risks: Mortality and burden of disease attributable to selected major risks. Geneva: WHO.143 Booske, B. et al. 2010. Different perspectives for assigning weights to determinants of health. County Health Rankings Working Paper. Madison, WI: University of Wisconsin Population Health Institute.144 Stringhini, S. et al. 2010. “Association of socioeconomic position with health behaviors and mortality.” JAMA 303(12), 1159–1166.145 Thoits, P. 2010. “Stress and health: Major findings and policy implications.” Journal of Health and Social Behavior 51 Suppl, S41–53.146 McGovern, L., G. Miller and P. Highes-Cromwick. 2014. “Health policy brief: The relative contribution of multiple determinants to health outcomes.” Health Affairs147 Iton, A. 2006. Tackling the root causes of health disparities through community capacity building. In: Hofrichter R, ed. Tackling Health Inequities Through Public Health Practice: A Handbook for Action. Washington, D.C., and Lansing, MI: National Association of County and City Health Officials and Ingham County Health Department; 116–136.148 Marmot M, Friel S, Bell R, et al. 2008. Closing the gap in a generation: health equity through action on the social determinants of health. The Lancet , Volume 372 , Issue 9650, 1661 – 1669149 Ibid.150 Smith, R. 1996. “The big idea.” British Medical Journal 312:April 20th, Editor’s choice.
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life spans.151 Successful strategies California has already implemented to assure the poor do not pay higher
costs for societal GHG reductions include low-income energy discount programs, in combination with direct
climate credits, and policies and programs that help Californians reduce electricity, natural gas, and gasoline
consumption.152 More such strategies could be pursued. To tackle the inequitable distribution of power that
leads to disparate health outcomes, agencies can first assure their hearing and decision-making processes
provide opportunities for civic engagement so people facing health inequities can themselves participate
in decision-making about solutions. Whether it is absolute poverty or relative deprivation that leads to poor
health, investments and policies that both lift up the poor and reduce wealth disparities will address the
multiple problems of climate change mitigation, adaptation, and health inequities.
Employment
Employment status impacts human health in many ways. Poor health outcomes of unemployment
include premature death, self-rated ill-health (a strong predictor of poor health outcomes), and mental
illness.153 ,154,155,156 Economic strain related to unemployment can impact mental health and trigger stress that
is linked to other health conditions.157,158 Populations of color are overrepresented in the unemployment
and under-employment ranks, which likely contributes to racial health inequities. In 2014, 14.7 percent of
African-Americans, 12.1 percent of American Indians and Alaska Natives, and 9.8 percent of Latinos were unemployed, compared to 7.9 percent of Whites.159 In addition to providing income, the work experience has health consequences. There is a work status–health gradient similar to the wealth–health gradient. Workers with lower occupational status have a higher risk of death,160 increased blood pressure,161 and more heart
attacks.162,163 Higher status workers often have a greater sense of autonomy, control over their work, and
predictability, compared to lower status workers, whose lack of control and predictability translates to stress
that shortens their lives.164 Nonstandard working arrangements such as part-time, seasonal, shift, contract,
or informal sector work have been linked to greater psychological distress and poorer physical health.165,166
Women are heavily overrepresented in nonstandard work, as are people of color and people with low levels
of education.167,168
The implementation of California’s climate change goals provides great opportunity to not only improve the
habitability of the planet, but also to increase economic vitality, employ historically disadvantaged people
151 Chetty R, Stepner M, Abraham S, et al. 2016. The Association between Income and Life Expectancy in the United States, 2001- 2014. JAMA. Published online April 10, 2016. doi:10.1001/jama.2016.4226152 Gattaciecca, J., C. Callahan, and J. R. DeShazo. 2016. Protecting the most vulnerable: A financial analysis of Cap-and-Trade’s impact on households in disadvantaged communities across California. UCLA Luskin School of Public Affairs: Los Angeles, CA. http://innovation.luskin.ucla.edu/content/protecting-most-vulnerable. Accessed April 22, 2016.153 Krueger, P., and S. Burgard. 2011. Income, occupations and work. In: Rogers R, Crimmins E, eds. International Handbook of Adult Mortality. New York: Springer: 263–288.154 Rogers, R., R. Hummer, and C. Nam. 2000. Living and Dying in the USA. Behavioral, health, and social differentials of adult mortality. New York, NY: Academic.155 Ross, C. and J. Mirowsky. 1995. “Does employment affect health?” Journal of Health and Social Behavior 36(3):230–243.156 Burgard, S., and K. Lin. 2013. “Bad jobs, bad health? How work and working conditions contribute to health disparities.” Am Behav Sci 57(8).157 Price, R., D. Friedland, J. Choi, and R. Caplan. 1998. Job-loss and work transitions in a time of global economic change.158 Price, R., J. Choi, and A. Vinokur. 2002. “Links in the chain of adversity following job loss: How financial strain and loss of personal control lead to depression, impaired functioning, and poor health.” Journal of Occupational Health Psychology 7(4), 302.159 U.S. Census Bureau. 2014. American Community Survey 1-Year Estimates. http://www2.census.gov/programs-surveys/acs/
summary_file/2014/data/. Last updated August 31, 2015. Accessed April 20, 2016.160 Rogers R, Hummer R, and Nam C. 2000. Living and Dying in the USA. Behavioral, health, and social differentials of adult mortality. New York, NY: Academic161 Colhoun, H., H. Hemingway, and N. Poulter. 1998. “Socio-economic status and blood pressure: An overview analysis.” Journal of Human Hypertension 12(2).162 Möller, J., T. Theorell, U. De Faire, A. Ahlbom, and J. Hallqvist. 2005. “Work related stressful life events and the risk of myocardial infarction. Case-control and case-crossover analyses within the Stockholm heart epidemiology programme (SHEEP).” Journal of Epidemiology and Community Health 59(1), 23–30.163 Burgard S, Lin K. 2013. Bad jobs, bad health? How work and working conditions contribute to health disparities. Am Behav Sci: 57(8).164 Marmot, M., G. Rose, M. Shipley, and P. Hamilton. 1978. “Employment grade and coronary heart disease in British civil servants.” Journal of Epidemiology and Community Health 32(4), 244–249.165 Dooley, D., and J. Prause. 2004. Settling down: Psychological depression and underemployment. The social costs of underemployment, 134-157. In: Dooley, D. and J. Prause. The Social Costs of Underemployment: Inadequate Employment as Disguised Unemployment. 166 Virtanen, M., M. Kivimäki, M. Joensuu, P. Virtanen, M. Elovainio, and J. Vahtera. 2005. “Temporary employment and health: A review.” International Journal of Epidemiology 34(3): 610–622.167 Nollen, S. 1996. “Negative aspects of temporary employment.” Journal of Labor Research 17(4): 567–582.168 Burgard S, Lin K. 2013. Bad jobs, bad health? How work and working conditions contribute to health disparities. Am Behav Sci: 57(8)
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in secure jobs, and improve the health of the population. Measures in the Scoping Plan that aim to reduce
GHGs can simultaneously improve health and social equity by prioritizing or requiring that: (1) infrastructure
projects using public funds pay living wages, provide quality benefits to all employees, and minimize
nonstandard work; (2) locals are hired as much as is feasible; (3) preference is given for women-owned and
minority-owned businesses; (4) employers receiving public funds assess and reduce work stress and lack of
workplace control; (5) projects benefiting from State climate investments prioritize hiring from historically
hard-to-employ groups, such as youth (especially youth of color), formerly incarcerated people, and people
with physical or mental illness; and (6) training is provided to these same groups to work in jobs in sectors
that will support a sustainable economy.
Communications Supporting Climate Change Behaviors and Policies
California’s leadership on GHG reductions is exceptional. However, climate mitigation goals are often treated
independently by sector, and the public does not see a unified message that changes must take place on
every level in every sector to preserve human health and well-being. Climate strategy could be supported by
public communications campaigns that link sectors and present a message of the need for bold action, along
with the benefits that action can yield. Mass media communications and social marketing campaigns can help
shift social and cultural norms toward sustainable and healthy practices. Messaging about the co-benefits of climate change policies in improving health and well-being can lead to increased community and decision-maker support among vulnerable groups for policies and measures outlined in the Scoping Plan.
Community Engagement Leads to Robust, Lasting, and Effective Climate Policies
For California’s climate change policies to be supported by the public and be implemented with enthusiasm,
they must be developed through ample, genuine opportunities for community members to discuss and
provide input. Californians’ contributions to the policy arena strengthen the end products and assist in their implementation and enforcement.
Efforts to mitigate climate change through policy, environmental, and systems change present considerable
opportunities to promote sustainable, healthy, resilient, and equitable communities. The measures in the Scoping Plan, and the way they are implemented, can help create living conditions that facilitate physical activity; encourage public transit use; provide access to affordable, fresh, and nutritious foods; protect the natural systems on which human health depends; spur economic development; provide safe, affordable, and
energy-efficient housing; enable access to jobs; and increase social cohesion and civic engagement. These
climate change mitigation measures can improve overall population health, as well as material conditions,
access to opportunity, and health and well-being in communities facing health inequities. Approaching
the policy solutions outlined in the Scoping Plan with a health and equity lens can ultimately help lead to a
California in which all current and future generations of Californians can benefit and thrive.
Environmental Analysis
CARB, as the lead agency, prepared a Draft Environmental Analysis (Draft EA) in accordance with the
requirements of the California Environmental Quality Act (CEQA) and CARB’s regulatory program (CARB’s
program has been certified as complying with CEQA by the Secretary of Natural Resources; see California
Code of Regulation, title 17, sections 60006-60008; California Code of Regulation, title 14, section 15251,
subdivision (d)). The resource areas from the CEQA Guidelines Environmental Checklist were used as a
framework for a programmatic environmental analysis of the reasonably foreseeable compliance responses
resulting from implementation of the measures proposed in the Scoping Plan to achieve the 2030 target.
Following circulation of the Draft EA for an 80-day public review and comment period (January 20, 2017
through April 10, 2017), CARB prepared the Final Environmental Analysis Prepared for the Proposed Strategy
for Achieving California’s 2030 Greenhouse Gas Target (Final EA), which includes minor revisions to the Draft EA, and the Response to Comments on the Draft Environmental Analysis prepared for the Proposed Strategy for Achieving California’s 2030 Greenhouse Gas Target (RTC). The Final EA is included as Appendix F to the 2017 Scoping Plan. The Final EA and RTC were posted on CARB’s Scoping Plan webpage before the Board
hearing in December 2017.
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The Final EA provides a programmatic level of analysis of the adverse environmental impac ts that are
reasonably foreseeable as resulting from implementation of the proposed Scoping Plan measures; feasible
mitigation measures; a cumulative impac ts analysis and an alternatives analysis.
Collectively, the Final EA concluded that implementation of these actions could result in the following
short-term and long-term beneficial and adverse environmental impac ts:
• Beneficial long-term impacts to air quality, energy demand and greenhouse gas emissions.
• Less than significant impacts to energy demand, resources related to land use planning,
mineral resources, population and housing, public services, and recreational services.
• Potentially significant and unavoidable adverse impacts to aesthetics, agriculture and forest
resources, air quality, biological resources, cultural resources, geology and soils, hazards
and hazardous materials, hydrology and water quality, resources related to land use planning,
noise, recreational services, transportation/traffic, and utilities and service systems.
The potentially significant and unavoidable adverse impacts are disclosed for both short-term construction-
related activities and long-term operational activities, which explains why some resource areas are identified
above as having both less-than-significant impacts and potentially significant impacts. For a summary of
impacts, please refer to the table in Attachment B to the Final EA.
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Climate change mitigation policies must be considered in the context of the sector’s contribution to the
State’s total GHGs, while also considering any co-benefits for criteria pollutant and toxic air contaminant
reductions. The transportation, electricity (in-state and imported), and industrial sectors are the largest
contributors to the GHG inventory and present the largest opportunities for GHG reductions. However, to ensure decarbonization across the entire economy and to meet our 2030 GHG target, policies must be considered for all sectors. Policies that support energy efficiency, alternative fuels, and renewable power also can provide co-benefits for both criteria and toxic air pollutants.
The specific policies identified in this Scoping Plan are subject to additional analytical and public processes to refine the requirements and methods of implementation. For example, a change in the LCFS Carbon Intensity (CI) target would only take effect after a subsequent rulemaking for that regulation, which would
include its own public process and environmental, economic, and public health analyses. As described in
Chapter 2, many policies for reducing emissions toward the 2030 target are already known. This Scoping
Plan identifies these and additional policies or program enhancements needed to achieve the remaining
GHG reductions in a complementary, flexible, and cost-effective manner to meet the 2030 target. These
policies should continue to encourage reductions beyond 2030 to keep us on track to stabilize the climate.
Policies that ensure economy-wide investment decisions that incorporate consideration of GHG emissions
are particularly important.
As we pursue GHG reduction targets, we must acknowledge the integrated nature of our built and natural
environments, and cross-sector impacts of policy choices. The State’s Green Buildings Strategy is one such
example of this type of integrated approach. Buildings have tremendous cross-sector interactions that
influence our health and well-being and affect land use and transportation patterns, energy use, water use,
communities, and the indoor and outdoor environment. Green building regulations and programs offer complementary opportunities to address the direct and indirect effects of buildings on the environment by incorporating strategies to minimize overall energy use, water use, waste generation, and transportation impacts. The Governor’s Green Buildings Executive Order B-18-12 for State buildings and the California
Green Building Standards (CALGreen) Code169 are key state initiatives supporting emissions reductions
associated with buildings. Local governments are taking action by adopting “beyond code” green building
standards. Additional efforts to maintain and operate existing buildings as third-party certified green
buildings provides a significant opportunity to reduce GHG emissions associated with buildings. These
foundational regulations and programs for reducing building-related emissions are described in more detail
in Appendix H. Looking forward, there is a need to establish a path toward transitioning to zero net carbon
buildings170, which will be the next generation of buildings that can contribute significantly to achieving long-
term climate goals. A discussion of how the green buildings strategy can support GHG reductions to help
meet the 2030 target is provided in Appendix I. Recent research activities have provided results to better quantify GHG emissions reductions of green buildings, and additional research activities need to continue to expand their focus to support technical feasibility evaluations and implementation. Research needs related to green buildings are included in Appendix I.
Further, each of the policies directed at the built environment must be considered in the broader context of the high-level goals for other sectors, including the natural and working lands sector. For example, policies that support natural and working lands can reduce emissions and sequester carbon, while also providing
ecosystem benefits such as better water quality, increased water yield, soil health, reduced erosion, and
169 The authority to update and implement the CALGreen Code is the responsibility of several State agencies identified in California Building Standards Law.170 A zero carbon building generates zero or near zero GHG emissions over the course of a year from all GHG emission sources associated, directly and indirectly, with the use and occupancy of the building (initial definition included in the May 2014 First Update to the Climate Change Scoping Plan).
Chapter 4
K ey S ector S
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habitat connectivity. These policies and co-benefits will be considered as part of the integrated strategy
outlined above. Table 16 provides examples of the cross-sector interactions between and among the main
sectors analyzed for the Scoping Plan that are discussed in this chapter (Energy, Transportation, Industry,
Water, Waste Management, and Natural and Working Lands, including agricultural lands).
This chapter recognizes these interactions and relates these broad strategic options to the specific additional
programs recommended in Chapter 2 of this document. Accordingly, Chapter 4 provides an overview of each
sector’s contributions to the State’s GHG emissions, a description of both ongoing and proposed programs
and policies to meet the 2030 target, and additional climate policy or actions that could be considered in the
future. The wide array of complementary and supporting measures being contemplated or undertaken across
State government are detailed here. The broad view of State action described in this chapter thus provides
context for the narrower set of measures discussed in detail in Chapter 2 of this Scoping Plan. It is these
measures in Chapter 2 that CARB staff has identified as specific actions to meet the 2030 target in SB 32.
The following phrases have specific meanings in this discussion of the policy landscape: “Ongoing and
Proposed Measures” refers to programs and policies that are either ongoing existing efforts, or efforts
required by statute, or which are otherwise underway or about to begin. These measures include, but are
not limited to, those identified as necessary specific actions to meet the 2030 GHG target, and which are set apart and described in greater detail in Chapter 2. “Sector Measures” listed also include cross-cutting measures that affect many entities in the sector; some of these are also identified in Chapter 2. “Potential Additional Actions” are not being proposed as part of the specific strategy to achieve the 2030 target in this
Scoping Plan. This Scoping Plan includes this broader, comprehensive, review of these measures because
it aims to spur thinking and exploration of innovative new technologies and polices that may help the State
achieve its long-term climate goals. Some of these items may not ever be formally proposed, but they are
included here because CARB, other agencies, and stakeholders believe their potential should be explored
with stakeholders in coming years.
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table 16: Cross-seC tor relationships
Sector Example Interactions with Other Sectors
Energy
• Hydroelectric power, cooling, cleaning, waste water treatment plant (WWTP) bioenergy
• Vehicle-to-grid power; electricity supply to vehicle charging infrastructure
• Biomass feedstock for bioenergy, land for utility-scale renewable energy (solar, wind)
• Agricultural waste and manure feedstocks for bioenergy/biofuels
• Organic waste for bioenergy
Transportation
• Electric vehicles, natural gas vehicles, transit/rail; more compact development patterns that reduce
vehicle miles traveled (VMT) also demand less energy per capita
• More compact development patterns that reduce VMT also demand less water per capita and reduce
conversion of natural and working lands
• Reducing VMT also reduces energy demands necessary for producing and distributing fuels and vehicles
and construction and maintenance of roads
• Biomass feedstock for biofuels
• Agricultural waste and manure feedstocks for biofuels
• Organic waste for biofuels
• Greenfield suburban development on natural and working lands leads to increased VMT
Industry
• Potential to electrify fossil natural gas equipment, substitution of fossil-based energy with renewable energy
• Greenfield urban development impacts
Water
• Energy consumption for water pumping, treatment, heating; resource for cooling, cleaning; WWTP bioenergy
• Use of compost to help with water retention / conservation / drought mitigation
• Land conservation results in healthier watersheds by reducing polluted runoff, allowing groundwater
recharge, and maintaining properly functioning ecosystems
Waste
Management
• Composting, anaerobic digestion, and wastewater treatment plant capacity to help process organic waste
diverted from landfills
• Compost for carbon sequestration, erosion control in fire-ravaged lands, water conservation, and healthy soils
• Replacing virgin materials with recycled materials associated with goods production; enhanced producer
responsibility reduces energy impacts of consumption
• Efficient packaging materials reduces energy consumption and transportation fuel use
Agriculture
• Crop production, manure management; WWTP biosolids for soil amendments
• Agricultural waste and manure feedstocks for bioenergy
• Compost production in support of Healthy Soils Initiative
Natural and
Working Lands
• Healthy forestlands provide wood and other forest products
• Restoring coastal and sub-tidal areas improves habitat for commercial and other fisheries
• Sustainable management can provide biomass for electricity
• Sustainable management can provide biomass for biofuels
• Resilient natural and working lands provide habitat for species and functions to store water, recharge
groundwater, naturally purify water, and moderate flooding. Forests are also a source of compost and other
soil amendments.
• Conservation and land protections help reduce VMT and increase stable carbon pools in soils and
above-ground biomass
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Low Carbon Energy
The energy sector in California is composed of electricity and natural gas infrastructure, which brings
electricity and natural gas to homes, businesses, and industry. This vast system is critical to California’s
economy and public well-being, and pivotal to reducing its GHG emissions.
Historically, power plants generated electricity largely by combusting fossil fuels. In the 1970s and early
1980s, a significant portion of California’s power supply came from coal and petroleum resources. To
reduce air pollution and promote fuel diversity, the State has shifted away from these resources to natural
gas, renewable energy, and energy efficiency programs, resulting in significant GHG emissions reductions.
Emissions from the electricity sector are currently approximately 20 percent below 1990 levels and are well on
their way to achieving deeper emissions cuts by 2030. Since 2008, renewable generation has almost doubled,
coal generation has been reduced by more than half, and GHG emissions have been reduced by a quarter.
Carbon dioxide is the primary GHG associated with electricity and natural gas systems. The electricity sector,
which is composed of in-State generation and imported power to serve California load, has made great
strides to help California achieve its climate change objectives. Renewable energy has shown tremendous
growth, with capacity from solar, wind, geothermal, small hydropower, and biomass power plants growing from 6,600 megawatts (MW) in 2010 to 27,500 MW as of June 2017.171
Renewable energy adoption in California has been promoted through the RPS and several funding
mechanisms, such as the California Solar Initiative (CSI) programs, Self-Generation Incentive Program (SGIP), Net-Energy Metering (NEM), and federal tax credits. These mandates and incentives have spurred both utility-scale and small-scale customer-developed renewable energy projects. SB 350 increased the RPS requirement from 33 percent by 2020 to 50 percent by 2030.
SB 350 requires publicly-owned utilities under the jurisdiction of the California Energy Commission (CEC) and all load-serving entities under the jurisdiction of the California Public Utilities Commission (CPUC) to file integrated resource plans (IRPs) with the CEC and CPUC, respectively. Through their IRPs, filing entities
will demonstrate how they will plan to meet the electricity sector’s share of the State’s 2030 GHG reduction
target while ensuring reliability in a cost-effective manner. The CEC and CPUC have developed the guidelines
that publicly-owned utilities and load-serving entities will follow to prepare and submit IRPs, and CARB is
working collaboratively with CEC and CPUC to set the sector and utility and load-serving entity planning
targets. The Scoping Plan provides information to help establish the range of GHG reductions required for
the electricity sector, and those numbers will be translated into planning target ranges in the IRP process. The
IRP processes as currently proposed by CEC and CPUC staff will grant publicly-owned utilities flexibility to
determine the optimal way to reduce GHG emissions, and load serving entities some flexibility to achieve the
electricity sector’s share of the 2030 goal. The CPUC has developed a Reference System Plan to help guide investment, resource acquisition, and programmatic decisions to reach the State’s policy goals, in addition to informing the development of individual load serving entities’ IRPs.
Energy efficiency is another key component to reducing energy sector GHG emissions, and is another consideration in each agency’s IRP process. Utilities have been offering energy efficiency programs, such as incentives, to California customers for decades, and CEC has continually updated building and appliance standards. In the context of IRPs, utility-ratepayer-funded energy efficiency programs will likely continue to
play an important role in reducing GHG emissions in the electricity sector.
SB 350 requires CEC and CPUC to establish annual targets for statewide energy efficiency savings and demand reduction that will achieve a cumulative doubling of statewide energy efficiency savings in electricity
and natural gas end uses by 2030. These targets can be achieved through appliance and building energy
efficiency standards; utility incentive, rebate, and technical assistance programs; third-party delivered
energy efficiency programs; and other programs. Achieving greater efficiency savings in existing buildings,
as directed by Governor Brown in his 2015 inaugural speech, will be essential to meet the goal of doubling
energy efficiency savings. In September 2015, CEC adopted the Existing Buildings Energy Efficiency Action
Draft Plan, which is designed to provide foundational support and strategies to enable scaling of energy
efficiency in the built environment. Pursuant to SB 350, CEC published an updated Existing Buildings Energy
Efficiency Action Plan prior to January 2017. More than $10 billion in private capital investment will be needed
171 California Energy Commission. August, 2017. Tracking Progress. Renewable Energy – Overview. http://www.energy.ca.gov/renewables/tracking_progress/documents/renewable.pdf
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to double statewide efficiency savings in California.172 Energy efficiency programs are one part of the broader
green buildings strategy, which incorporates additional measures to minimize water use, waste generation,
and transportation impacts. The green buildings strategy is described in further detail in Appendix I.
Heating fuels used for activities such as space and water heating in the residential, commercial, and industrial
sectors represent a significant source of GHG emissions. Transitioning to cleaner heating fuels is part of
the solution of achieving greater efficiency savings in existing buildings and has significant GHG emissions
reductions potential. Examples of this transition can include use of renewable gas and solar thermal, as well
as electrification of end uses in residential, commercial, and industrial sectors. However, achieving significant
GHG emissions reductions can only be achieved by decarbonizing the electricity sector – switching from
natural gas end uses to electricity generated by burning natural gas would not be effective. Electrification
can complement renewables and energy storage if implemented in an integrated, optimized manner. Other
hurdles that will have to be overcome include electric equipment performance across all California climate
regions, seasonal variations of renewable generation, cost-effectiveness, and consumer acceptance of
different heating fuel options.
Fossil-fuel-based natural gas is a significant fuel source for both in-State electricity generation and electricity
imported into California. It is also used in transportation applications and in residential, commercial, industrial, and agricultural sector end uses. Greenhouse gas emissions from combustion of fossil natural gas decreased from 134.71 MMTCO2e in 2000 to 126.98 MMTCO2e in 2015, while natural gas pipeline fugitive emissions were estimated to be 4.0 MMTCO2e in 2015 and have been nearly unchanged since 2000.173
Greenhouse gas-reduction strategies should focus on efficiency, reducing leakage from wells and pipelines,
implementing the SLCP strategy, and studying the potential for renewable gas fuel switching (e.g., renewable
hydrogen blended with methane or biomethane).
Moving forward, reducing use of fossil natural gas wherever possible will be critical to achieving the State’s
long-term climate goals. For end uses that must continue to rely on natural gas, renewable natural gas could
play an important role. Renewable natural gas volume has been increasing from approximately 1.5 million diesel
gallon equivalent (dge) in 2011 to more than 68.5 million dge in 2015, and continued substitution of renewable
gas for fossil natural gas would help California reduce its dependence on fossil fuels. In addition, renewable
gas can be sourced by in-vessel waste digestion (e.g., anaerobic digestion of food and other organics) and
recovering methane from landfills, livestock operations, and wastewater treatment facilities through the use of
existing technologies, thereby also reducing methane emissions. The capture and productive use of renewable
methane from these and other sources is consistent with requirements of SB 1383.
Collectively, renewable energy and energy efficiency measures can result in significant public health and
climate benefits by displacing air pollution and GHG emissions from fossil-fuel based energy sources, as well
as by reducing the health and environmental risks associated with the drilling, extraction, transportation, and storage of fossil fuels, especially for communities living near fossil-fuel based energy operations.
As the energy sector continues to evolve and decarbonize, both the behavior of individual facilities and the
design of the grid itself will change, with important distributional effects. Some power plants may operate more flexibly to balance renewables, emerging technologies (examples include storage, smart inverters, renewably-fueled fuel cells, and others) will become more prevalent, and aging facilities may retire and be replaced. In turn, this may shift patterns of criteria pollutant emissions at these facilities. Because many
existing power plants are in, or near, disadvantaged communities, it is of particular importance to ensure that
this transition to a cleaner grid does not result in unintended negative impacts to these communities.
Appendix H highlights the more significant existing policies, programs, measures, regulations, and initiatives
that provide a framework for helping achieve GHG emissions reductions in this sector.
172 California Energy Commission. 2016. Existing Building Energy Efficiency Action Plan. page 61. Available at: http://docketpublic.energy.ca.gov/PublicDocuments/16-EBP-01/TN214801_20161214T155117_Existing_Building_Energy_
Efficency_Plan_Update_Deceber_2016_Thi.pdf173 CARB. 2017. CARB’s Emission Inventory Activities. www.arb.ca.gov/ei/ei.htm
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Looking to the Future
This section outlines the high-level objectives and goals to reduce GHGs in this sector.
Electricity Goals
• Achieve sector-wide, publicly-owned utility, and load-serving entity specific GHG
reduction planning targets set by the State through Integrated Resource Planning.
• Reduce fossil fuel use.
• Reduce energy demand.
Natural Gas Goals
• Ensure safety of the natural gas system.
• Decrease fugitive methane emissions.• Reduce dependence on fossil natural gas.
Cross-Sector Interactions
The energy sector interacts with nearly all sectors of the economy. Siting of power plants (including solar and wind facilities) and transmission and distribution lines have impacts on land use in California–be it conversion
of agricultural or natural and working lands, impacts to sensitive species and habitats, or implications to
disadvantaged, vulnerable, and environmental justice communities. Additionally, more compact development
patterns reduce per capita energy demands, while less-compact sprawl increases them. Further, efforts to
reduce GHG emissions in the transportation sector include electrification, such as PHEVs, BEVs, and FCEVs.
Some industrial sources also use electricity as a primary or auxiliary source of power for manufacturing. In
the future, industrial facilities may electrify their systems instead of relying on natural gas. These activities will
increase demand in this sector. In addition, water is used in various applications in the energy sector, ranging
in intensity from cooling of turbines and other equipment at power plants to cleaning solar photovoltaic
panels. Given California’s recent historic drought, water use for the electricity sector is an important
consideration for operation, maintenance, and construction activities.
Continued planning and coordination with federal, State, and local agencies, governments, Tribes, and
stakeholders will be crucial to minimizing environmental and health impacts from the energy sector,
deploying new technologies, and identifying feedstocks.
Efforts to Reduce Greenhouse Gases
The measures below include some required and new potential measures to help achieve the State’s 2030 target and to support the high-level objectives for this sector. Some measures may be designed to directly address GHG reductions, while others may result in GHG reductions as a co-benefit.
Ongoing and Proposed Measures – Electricity
• Per SB 350, with respect to Integrated Resource Plans, establish GHG planning targets
for the electricity sector, publicly-owned utilities, and load-serving entities.
• Per SB 350, ensure meaningful GHG emissions reductions by publicly-owned utilities and load-serving entities through Integrated Resource Planning.• Per AB 197, prioritize direct reductions at large stationary
sources, including power-generating facilities.
• Per SB 350, increase the RPS to 50 percent of retail sales by 2030 and ensure grid reliability.
• Per Governor Brown’s Clean Energy Jobs Plan, AB 327 (Perea, Chapter 611, Statutes
of 2013), and AB 693 (Eggman, Chapter 582, Statutes of 2015), increase development
of distributed renewable generation, including for low income households.
• Continue to increase use of distributed renewable generation at State facilities where space allows.
• Increase retail customers’ use of renewable energy through
optional utility 100 percent renewable energy tariffs.
• Continue GHG reductions through participation in the California
Independent System Operator (CAISO) Energy Imbalance Market.
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• Per SB 350, efforts to evaluate, develop, and deploy regionalization of the grid and
integration of renewables via regionalization of the CAISO should continue while
maintaining the accounting accuracy and rigor of California’s GHG policies.
• Per SB 350, establish annual targets for statewide energy efficiency savings and
demand reduction that will achieve a cumulative doubling of statewide energy
efficiency savings in electricity and natural gas end uses by 2030.
• Per SB 350, implement the recommendations of the Barriers Study for increasing access to renewable
energy generation for low-income customers, energy efficiency and weatherization investments
for low-income customers, and contracting opportunities for local small business in disadvantaged
communities.174 And, track progress towards these actions over time to ensure disadvantaged communities are getting equal access and benefits relative to other parts of the State.• Continue implementation of the Regulations Establishing and Implementing a Greenhouse Gases Emission Performance Standard for Local Publicly Owned Electric Utilities as required
by SB 1368 (Perata, Chapter 598, Statutes of 2006), which effectively prohibits electric utilities
from making new long-term investments in high-GHG emitting resources such as coal power.
• Per AB 802 (Williams, Chapter 590, Statutes of 2015), adopt the forthcoming CEC regulations
governing building energy use data access, benchmarking, and public disclosure.
• Per AB 2868 (Gatto, Chapter 681, Statutes of 2016), encourage development of
additional energy storage capacity on the transmission and distribution system.
• Per AB 758 (Skinner, Chapter 470, Statutes of 2009),175 implement recommendations
under State jurisdiction included in the AB 758 Action Plan developed by CEC.
Ongoing and Proposed Measures – Natural Gas
• Implement the CARB Regulation for Greenhouse Gas Emission Standards for Crude Oil and Natural
Gas Facilities to reduce fugitive methane emissions from storage and distribution infrastructure.
• Per SB 1371 (Leno, Chapter 525, Statutes of 2014), adopt improvements in investor- owned utility (IOU) natural gas systems to address methane leaks.• Implement the SLCP Strategy to reduce natural gas leaks from oil and gas wells, pipelines, valves, and pumps to improve safety, avoid energy losses,
and reduce methane emissions associated with natural gas use.
• Per SB 1383, CEC will develop recommendations for the development and use of
renewable gas as part of its 2017 Integrated Energy Policy Report (IEPR).
• Per SB 1383, adopt regulations to reduce methane emissions from livestock manure and dairy
manure management operations by up to 40 percent below the dairy sector’s and
livestock sector’s 2013 levels by 2030, including establishing energy infrastructure
development and procurement policies needed to encourage dairy biomethane
projects. The regulations will take effect on or after January 1, 2024.
• Per SB 1383, reduce methane emissions at landfills by reducing landfill disposal of organic waste 75 percent below 2014 levels by 2025, including establishing energy infrastructure development and procurement policies needed to encourage in-vessel digestion projects and increase the production and use of renewable gas.
• Per SB 887 (Pavley, Chapter 673, Statutes of 2016), initiate continuous monitoring
at natural gas storage facilities and (by January 1, 2018) mechanical integrity testing
regimes at gas storage wells, develop regulations for leak reporting, and require risk
assessments of potential leaks for proposed new underground gas storage facilities.
• Per Public Utilities (PU) Code 454.56, CPUC, in consultation with CEC, (1) identifies all potentially
achievable cost-effective natural gas efficiency savings and establishes gas efficiency
targets for the gas corporation to achieve, and (2) requires gas corporations to first
meet unmet resource needs through available natural gas efficiency and demand
reduction resources that are cost-effective, reliable, and feasible (PU Codes 890–
174 CEC. 2016. Low-Income Barriers Study, Part A: Overcoming Barriers to Energy Efficiency and Renewables for Low-Income Customers and Small Business Contracting Opportunities in Disadvantaged Communities. http://docketpublic.energy.ca.gov/
PublicDocuments/16-OIR-02/TN214830_20161215T184655_SB_350_LowIncome_Barriers_Study_Part_A__Commission_Final_
Report.pdf175 AB 758 requires CEC, in collaboration with CPUC, to develop a comprehensive program to achieve greater energy efficiency in the State’s existing buildings.
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900 provide public goods charge funding authorization for these programs).
• Per SB 185 (De Leon, Chapter 605, Statutes of 2015), implement the requirement for the
California Public Employees’ Retirement System (CalPERS) and the California State Teachers’
Retirement System (CalSTRS) to sell their holdings in coal-producing companies by June 1,
2017, and explore extending divestiture requirements for additional fossil-fuel assets.
Sector Measures
• Implement the post-2020 Cap-and-Trade Program.
Potential Additional Actions
The actions below have the potential to reduce GHGs and complement the measures and policies identified
in Chapter 2. These are included to spur thinking and exploration of innovation that may help the State
achieve its long-term climate goals. It is anticipated that there will be workshops and other stakeholder
forums in the years following finalization of the Scoping Plan to explore these potential actions.
• Further deploy fuel cells that use renewable fuels or those that generate
electricity that is less carbon intensive than the grid.
• Increase use of renewable energy through long-term agreements between customers
and utilities (such as Sacramento Municipal Utility District Solar Shares).
• Develop rules needed for the development of electricity storage technologies.
• Adopt a zero net energy (ZNE) standard for residential buildings
by 2018/2019, and for commercial buildings by 2030.• Through a public process, evaluate and set targets for the electrification of space and water heating in residential and commercial buildings and cleaner heating fuels that will result in GHG reductions, and identify actions that can be taken to spur market transformation in the 2021-2030 period.
• Expand the State Low-Income Weatherization Program (LIWP) to continue
to improve energy efficiency and weatherize existing residential buildings,
particularly for low-income individuals and households.
• Decrease usage of fossil natural gas through a combination of energy
efficiency programs, fuel switching, and the development and use of
renewable gas in the residential, commercial, and industrial sectors.
• Accelerate the deployment of heat pumps and the replacement of diesel generators.
• Consider enhanced energy efficiency (high efficiency air conditioners, light-emitting diode (LED)
lamps, efficiency improvements in industrial process cooling and refrigeration, efficient street lighting).• Promote programs to support third-party delivered energy efficiency projects.• Per AB 33 (Quirk, Chapter 680, Statutes of 2016), consider large-scale electricity storage.• Support more compact development patterns to promote reduced per capita energy
demand (see the Transportation sector for specific policy recommendations).
Industry
California’s robust economy, with the largest manufacturing sector in the United States, is supported by a
variety of sub-industrial sectors, some of which include cement plants, refineries, food processors, paper products, wineries, steel plants, and industrial gas, entertainment, technology and software, aerospace, and defense companies. Together, industrial sources account for approximately 21 percent of the State’s GHG emissions–almost equal to the amount of GHG emissions from the energy sector. Emissions in this sector
are mainly due to fuel combustion and, in some industries, process-related emissions. Changes in this sector
strongly correlate with changes in the overall economy. For example, housing and construction growth usually
increases demand for cement. Moving toward a cleaner economy and ensuring we meet the statewide targets
requires us to address GHG emissions in this sector, which has the potential to provide local co-benefits
in criteria pollutant and toxic air contaminant reductions in immediate surrounding locations, especially in
vulnerable communities. At the same time, we must ensure there is a smooth path to a cleaner future to
support a resilient and robust economy with a strong job force, including training opportunities for workers in
disadvantaged communities, while continuing to support economic growth in existing and new industries.
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Greenhouse gas emissions in the Industrial sector have remained relatively flat for the last few years while
the State’s economy has continued to grow, meaning the GHG emissions to produce each dollar of gross
standard product is decreasing. Manufacturing accounts for approximately 10 percent of the gross state
product.176 In 2016, California industry exported $163.6 billion in merchandise.177
Policies to address GHG emissions reductions must continue to balance the State’s economic well-being with
making progress toward achievement of the statewide limits.
As this sector is dominated by combustion-related emissions, policies and measures to supply cleaner fuels
and more efficient technology are the key to reducing GHG emissions. Some sectors, such as cement and
glass, also have significant process emissions, and it may be more challenging to address those process
emissions, as they are related to chemical reactions and processes to meet safety, product-specific, or
regulatory standards for the final products. Another important aspect for this sector is its role as the State
transitions to a cleaner future. Infrastructure, including existing facilities and new facilities, can support
the production of new technology to bolster the State’s efforts to address GHGs. For example, existing refineries have an opportunity to move away from fossil fuel production and switch to the production of biofuels and clean technology. As the State works to double energy efficiency in existing buildings, there will be an increased demand for efficient lighting fixtures, building insulation, low-e178 coatings for existing
windows, or new windows–goods which could be produced in California. The predominant paths to reducing
GHG emissions for the Industrial sector are: fuel switching, energy efficiency improvements, and process
modifications. Carbon capture and sequestration also offers a potential new, long-term path for reducing
GHGs for large stationary sources.
Relocation of production to outside the State would also reduce emissions, but this is disadvantageous for
a couple of reasons and efforts are needed to avoid this outcome. First, AB 32 requires the State’s climate
policies to minimize emissions leakage, and relocation would shift GHG emissions outside of the State
without the benefit of reducing pollutants that contribute to overall global warming impacts. Second, it could
also reduce the availability of associated jobs and could impact a local tax base that supports local services
such as public transportation, emergency response, and social services, as well as funding sources critical to
protecting the natural environment and keeping it available for current and future generations.
Even while we continue to seek further GHG reductions in the sector, it is important to recognize the State
has a long history of addressing health-based air pollutants in this sector. Many of the actions for addressing
criteria pollutants and toxic air contaminants in the industrial sector are driven by California’s local air district
stationary source requirements to ensure progress toward achieving State and national ambient air quality standards. Some of those actions, such as use of Best Available Control Technology, have resulted in co-benefits in the form of GHG reductions. The State must continue to strengthen its existing criteria and toxic air pollutant programs and relationships with local air districts to ensure all Californians have healthy, clean air.
This is especially true in disadvantaged communities.
AB 32 directed CARB to take several actions to address GHG emissions, such as early action measures, GHG reporting requirements for the largest GHG sources, and other measures. In response, the State adopted
multiple measures and regulations, including regulations for high global warming potential (high-GWP) gases
used in refrigeration systems and the semiconductor industry.179 These regulations apply to specific GHGs
and types of equipment that can be found across the economy. For example, high-GWP gases are found in
refrigeration systems in large food processing plants and chemical and petrochemical facilities, among others.180
The State has also adopted the first in the world economy-wide cap-and-trade program that applies to
all large industrial GHG emitters, imported electricity, and fuel and natural gas suppliers. As discussed in
Chapters 2 and 3, the Cap-and-Trade Program is a key element of California’s GHG reduction strategy. The
176 http://www.investopedia.com/articles/investing/011416/californias-economy-9-industries-driving-gdp-growth.asp177 U.S. Department of Commerce. International Trade Administration. 2017. California Exports, Jobs, & Foreign Investment. www.trade.gov/mas/ian/statereports/states/ca.pdf178 Low-e coatings reduce the emissivity, or heat transfer, from a window to improve its insulating properties.179 CARB. Refrigerant Management Program. www.arb.ca.gov/cc/rmp/rmp.htm180 The U.S. Environmental Protection Agency (U.S. EPA) has also enacted regulations to reduce hydrofluorocarbon (HFC) emissions by prohibiting high-GWP refrigerants in new retail food refrigeration equipment and in chillers used for large air-conditioning applications. On the international level, the European Union F-gas regulations went into effect January 1, 2015. Those regulations prohibit high-GWP HFCs in new equipment and require a gradual phasedown in the production and import of HFCs. A similar HFC phasedown that would take place globally was the subject of international negotiations during the Montreal Protocol meeting in Rwanda in October, 2016. Those negotiations resulted in an agreement that will phase down the use of HFCs and put the world on track to avoid nearly 0.5°C of warming by 2100.
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Cap-and-Trade Program establishes a declining limit on major sources of GHG emissions, and it creates a
powerful economic incentive for major investment in cleaner, more efficient technologies. The Cap-and-
Trade Program applies to emissions that cover about 85 percent of the State’s GHG emissions. CARB creates
allowances equal to the total amount of permissible emissions (i.e., the “cap”) over a given compliance
period. One allowance equals one metric ton of GHG emissions. Fewer allowances are created each year, thus
the annual cap declines and statewide emissions are reduced over time. An increasing annual auction reserve
(or floor) price for allowances and the reduction in annual allowance budgets creates a steady and sustained
pressure for covered entities to reduce their GHGs. All covered entities in the Cap-and-Trade Program are
still subject to the air quality permit limits for criteria and toxic air pollutants.
The Cap-and-Trade Program is designed to achieve the most cost-effective statewide GHG emissions
reductions; there are no individual or facility-specific GHG emissions reductions requirements. Each entity
covered by the Cap-and-Trade Program has a compliance obligation that is set by its GHG emissions
over a compliance period, and entities are required to meet that compliance obligation by acquiring and surrendering allowances in an amount equal to their compliance obligation. Companies can also meet a limited portion of their compliance obligation by acquiring and surrendering offset credits, which are compliance instruments that are based on rigorously verified emissions reductions that occur from projects
outside the scope of the Cap-and-Trade Program. Like allowances, each offset credit is equal to one metric
ton of GHG emissions. The program began in January 2013 and achieved a near 100 percent compliance rate
for the first compliance period (2013–2014). Reported and verified emissions covered by the Cap-and-Trade
Program have been below the cap throughout the first years of the Program.181
Allowances are issued by CARB and distributed by free allocation and by sale at auctions. CARB also provides
for free allocation to some entities covered by the Program to address potential trade exposure due to the
cost of compliance with the Program and address concerns of relocation of production out-of-state and
resulting emissions leakage. Offset credits are issued by CARB to qualifying offset projects. Secondary
markets exist where allowances and offset credits may be sold and traded among Cap-and-Trade Program
participants. Facilities must submit allowances and offsets to match their annual GHG emissions. Facilities
that emit more GHG emissions must surrender more allowances or offset credits, and facilities that can cut
their emissions need to surrender fewer compliance instruments. Entities have flexibility to choose the lowest-cost approach to achieving program compliance; they may purchase allowances at auction, trade allowances and offset credits with others, take steps to reduce emissions at their own facilities, or utilize a combination of these approaches. Proceeds from the sale of State-owned allowances at auction are placed into the Greenhouse Gas Reduction Fund.
It is important to note that while the Cap-and-Trade Program is designed to reduce GHGs for the industrial sector, there are recommendations from the EJAC (or Committee) for the State to pursue more facility-
specific GHG reduction measures to achieve potential local air quality co-benefits, and AB 197 directs CARB
to prioritize direct reductions at large stationary sources. The Committee has expressed a strong preference
to forgo the existing Cap-and-Trade Program and rely on prescriptive facility level regulations.
We agree with the EJAC that more can and should be done to reduce emissions of criteria pollutants and
toxic air contaminants. These pollutants pose air quality and related health issues to the communities
adjacent to the sources of industrial emissions. Further, many of these communities are already
disadvantaged and burdened by a variety of other environmental stresses. As described in Chapter 3,
however, there is not always a direct correlation between emissions of GHGs, criteria pollutants, and toxic air
contaminants. Also, relationships between these pollutants are complex within and across industrial sectors.
The solution, therefore, is not to do away with or change the regulation of GHGs through the Cap-and-Trade
Program to address these legitimate concerns; instead, consistent with the direction in AB 197 and AB 617,
State and local agencies must evaluate and implement additional measures that directly regulate and reduce emissions of criteria and toxic air pollutants through other programs.
181 CARB. 2016. Mandatory Greenhouse Gas Emissions Reporting. www.arb.ca.gov/cc/reporting/ghg-rep/ghg-rep.htm
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Looking to the Future
This section outlines the high-level objectives and goals to reduce GHGs in this sector.
Goals
• Increase energy efficiency.
• Reduce fossil fuel use.
• Promote and support industry that provides products and clean
technology needed to achieve the State’s climate goals.
• Create market signals for low carbon intensity products.
• Maximize air quality co-benefits.
• Support a resilient low carbon economy and strong job force.• Make California the epicenter for research, development, and deployment of technology needed to achieve a near-zero carbon future.
• Increase in-State recycling manufacturing.
Cross-Sector Interactions
There are clear, direct relationships between the industrial sector and other sectors that go beyond the
economic support that a strong economy provides. For instance, this sector could increase its use of
renewable fuels such as biomethane, which would be sourced from landfills or dairies. Additionally, some
industries could shift from raw materials to recycled materials to reduce waste and reduce GHG emissions
associated with processing of raw materials. Further, addressing energy efficiency could reduce onsite
heating, water, and fuel demand. Moreover, supporting mass-transit or ride share programs for employees
would reduce VMT. Finally, upgrading existing facilities or repurposing existing infrastructure instead of constructing new facilities or infrastructure would support land conservation and smart growth goals.
Efforts to Reduce Greenhouse Gases
The measures below include some required and new potential measures to help achieve the State’s 2030 target and to support the high-level objectives for this sector. Some measures may be designed to directly
address GHG reductions, while others may result in GHG reductions as a co-benefit.
Ongoing and Proposed Measures
• At the October 2016 annual Montreal Protocol Meeting of Parties in Kigali, Rwanda,
an international amendment to globally phase down HFC production was agreed upon
by more than 150 countries. Depending on the level of future HFC emissions reductions
expected for California from the Kigali Agreement, California may also: (1) consider placing
restrictions on the sale or distribution of refrigerants with a GWP > 2,500, and (2) consider
prohibiting refrigerants with a GWP >= 150 in new stationary refrigeration equipment
and refrigerants with a GWP >= 750 for new stationary air-conditioning equipment. At
the time the SLCP Strategy was finalized, U.S. EPA was expected to continue implementing
certain HFC reductions under its Significant New Alternatives Policy (SNAP). Recent
litigation may result in CARB implementing similar measures as state law instead.
• Develop a regulatory monitoring, reporting, verification, and implementation methodology for the implementation of carbon capture and sequestration projects.• Implement the CARB Regulation for Greenhouse Gas Emission Standards for Crude Oil and Natural
Gas Facilities to reduce fugitive methane emissions from storage and distribution infrastructure.
Sector Measures
• Implement the post-2020 Cap-and-Trade Program.
• Continue and strategically expand research and development efforts to identify, evaluate,
and help deploy innovative strategies that reduce GHG emissions in the industrial sector.
• Promote procurement policies that prioritize low carbon production to
delivery options, including at the State and local government levels.
• Identify and remove barriers to existing grant funding for
onsite clean technology or efficiency upgrades.
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Potential Additional Actions
The actions below have the potential to reduce GHGs and complement the measures and policies identified in Chapter 2. These are included to spur thinking and exploration of innovation that may help the State achieve its long-term climate goals. It is anticipated that there will be workshops and other stakeholder
forums in the years following finalization of the Scoping Plan to explore these potential actions.
• Further deploy fuel cells that use renewable fuels or those that generate electricity that is less carbon intensive than the grid.
• Decrease usage of fossil natural gas through a combination of efficiency,
fuel switching, and the development and use of renewable gas.
• Partner with California’s local air districts to effectively use BARCT to achieve
air quality and GHG reduction co-benefits at large industrial sources.
• Evaluate the potential for and promote electrification for industrial stationary
sources whose main emissions are onsite natural gas combustion.
• Identify new funding for grants and tariff opportunities for onsite clean technology, efficiency
upgrades, diesel generator replacement, or recycling manufacturing technology.
• Develop an incentive program to install low-GWP refrigeration systems in retail food stores.• Evaluate and design additional mechanisms to further minimize emissions leakage in the Cap-and-Trade Program (e.g., border carbon adjustment).
Transportation Sustainability
California’s population is projected to grow to 50 million people by 2050. How and where the State grows will
have important implications for all sectors of the economy, especially the transportation sector. Supporting
this growth while continuing to protect the environment, developing livable and vibrant communities, and
growing the economy is dependent on transitioning the State’s transportation system to one powered by ZEVs (including PHEVs, BEVs, and FCEVs) and low carbon fuels. It must also offer other attractive and convenient low carbon transportation choices, including safe walking and bicycling, as well as quality public transportation. Investments should consider California’s diverse communities and provide accessible and
clean travel options to all while drastically reducing reliance on light-duty combustion vehicles.
The transportation system in California moves people between home, work, school, shopping, recreation, and other destinations, and connects ports, industry, residential communities, commercial centers,
educational facilities, and natural wonders.182 California’s vast transportation system includes roads and
highways totaling more than 175,000 miles and valued at approximately $1.2 trillion, 500 transit agencies, 245
public-use airports, 12 major ports, and the nation’s first high-speed rail system, now under construction.183
Transportation infrastructure also includes sidewalks, bicycle paths, parking, transit stations and shelters,
street trees and landscaping, signage, lighting, and other elements that affect the convenience, safety, and
accessibility of transportation choices. Increasingly, technologies such as real-time, web- and mobile-enabled
trip planning and ride-sourcing services are changing how people travel. In the near future, automated and
connected vehicles, and unmanned aerial systems (e.g., drones) are expected to be part of our transportation
landscape and to transform the way that people and freight are transported. Responsibility for the transportation system is spread across State, regional, and local levels.
Through effective policy design, the State has an opportunity to guide technology transformation and
influence investment decisions with a view to mitigate climate and environmental impacts while promoting economic opportunities and community health and safety. The network of transportation technology and infrastructure, in turn, shapes and is shaped by development and land use patterns that can either support or detract from a more sustainable, low carbon, multi-modal transportation future. Strategies to reduce
GHG emissions from the transportation sector, therefore, must actively address not only infrastructure and
technology, but also coordinated strategies to achieve development, conservation, and land use patterns that
align with the State’s GHG and other policy goals.
Transportation also enables the movement of freight such as food, building materials, and other consumable
products, as well as waste and recyclables. The California freight system includes myriad equipment and
182 Caltrans. California Transportation Plan 2040, February 2016.183 Ibid.
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facilities,184 and is the most extensive, complex, and interconnected system in the country, with approximately
1.5 billion tons of freight valued at $2.8 trillion shipped in 2015 to, through, and within California.185 Freight-
dependent industries accounted for over $740 billion of California’s GDP and over 5 million California jobs
in 2014.186, 187
Transportation has a profound and varied impact on individuals and communities, including benefits such as
economic growth, greater accessibility, and transport-related physical activity, and adverse consequences
such as GHG emissions, smog-forming and toxic air pollutants, traffic congestion, and sedentary behaviors.
The sector is the largest emitter of GHG emissions in California. Air pollution from tailpipe emissions
contributes to respiratory ailments, cardiovascular disease, and early death, with disproportionate impacts
on vulnerable populations such as children, the elderly, those with existing health conditions (e.g., chronic
obstructive pulmonary disease, or COPD), low-income communities, and communities of color.188, 189, 190, 191,
192 Importantly, transportation costs are also a major portion of most Californian’s household budgets.193
Additionally, dependence on cars has a direct impact on levels of physical activity, which is closely linked to multiple adverse health outcomes.
Fortunately, many measures that reduce transportation sector GHG emissions simultaneously present
opportunities to bolster the economy, enhance public health, revitalize disadvantaged communities, strengthen resilience to disasters and changing climate, and improve Californians’ ability to conveniently access daily destinations and nature. These opportunities are particularly important for those who are not able to, or cannot afford to, drive. In addition, a growing market demand for walkable, bikeable, and transit-
accessible communities presents a significant opportunity to shift California’s transportation systems toward
a lower-carbon future while realizing significant public health benefits through increased levels of physical
activity (e.g., walking and bicycling). In fact, transport-related physical activity could result in reducing risks
from chronic diseases such as cardiovascular disease, diabetes, certain cancers, and more, to such an extent
that it would rank among the top public health accomplishments in modern history, and help to reduce the
billions of dollars California spends each year to treat chronic diseases. Just as California was the first to
mitigate the contribution of cars and trucks to urban smog, it is leading the way toward a clean, low carbon,
healthy, interconnected, and equitable transportation system.
Continuing to advance the significant progress already under way in the areas of vehicle and fuel technology is
critical to the transportation sector strategy and to reducing GHG emissions in the transportation sector. The
rapid technological and behavioral changes underway with automated and connected vehicles, unmanned
aerial systems, and ride-sourcing services are redefining the transportation sector, and should be part of the solution for a lower carbon transportation sector. It is critical to support and accelerate progress on transitioning to a zero carbon transportation system, while ensuring VMT reductions are still achieved. The growing severity of climate impacts, persistent public health impacts and costs from air pollution,194
and rapid technology progress that supports the expectation that cost parity between some ZEVs and
comparable internal combustion vehicles will be attained in a few years, underscores the need for further
184 The freight system includes trucks, ocean-going vessels, locomotives, aircraft, transport refrigeration units, commercial harborcraft and cargo handling, industrial and ground service equipment used to move freight at seaports, airports, border crossings, railyards, warehouses, and distribution centers.185 U.S. Department of Transportation, Bureau of Transportation Statistics and Federal Highway Administration. Freight Analysis Framework, V 4.1, 2016.186 U.S. Department of Commerce, Bureau of Economic Analysis. Regional Economic Accounts. Available at: www.bea.gov/regional/index.htm, accessed March 11, 2016.187 State of California Employment Development Department. Labor Market Information by California Geographic Areas. Available at: www.labormarketinfo.edd.ca.gov/geography/lmi-by-geography.html, accessed March 21, 2016.188 CARB. May 2016. Mobile Source Strategy. Available at: www.arb.ca.gov/planning/sip/2016sip/2016mobsrc.pdf189 Hoek, G., Krishnan, R. M., Beelen, R., Peters, A., Ostro, B., Brunekreef, B., and Kaufman, J. D. 2013. Long-term air pollution exposure and cardio-respiratory mortality: a review. Environmental Health, 12(1), 1.190 Friedman, M. S., K. E. Powell, L. Hutwagner, L. M. Graham, and W. G. Teague. 2001. “Impact of changes in transportation and commuting behaviors during the 1996 Summer Olympic Games in Atlanta on air quality and childhood asthma.” JAMA 285(7), 897–905.191 Bell, M. L., and K. Ebisu. 2012. “Environmental inequality in exposures to airborne particulate matter components in the United States.” Environmental Health Perspectives 120(12), 1699.192 Morello-Frosch, R., M. Zuk, M. Jerrett, B. Shamasunder, and A. D. Kyle. 2011. “Understanding the cumulative impacts of inequalities in environmental health: implications for policy.” Health Affairs 30(5), 879–887.193 H + T® Index website. htaindex.cnt.org/194 For example, a recent report by the American Lung Association estimates the costs of climate and air pollution from passenger vehicles in California to be $15 billion annually. Holmes-Gen, B. and W. Barrett. 2016. Clean Air Future – Health and Climate Benefits of Zero Emission Vehicles. American Lung Association in California, October.
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action on ZEVs. Therefore, CARB is signaling the need for additional policy and technical support on
strategies to move toward a goal of achieving 100 percent ZEV sales in the light-duty vehicle sector. Austria,
Germany, India, Netherlands, and Norway are all taking steps to, or have indicated a desire to, move to 100
percent ZEV sales in the 2020–2030 time frame.
In addition, policies that maximize the integration of electrified rail and transit to improve reliability and travel
times, increase active transportation such as walking and bicycling, encourage use of streets for multiple modes
of transportation, improve freight efficiency and infrastructure development, and shift demand to low carbon
modes will need to play a greater role as California strives to achieve its 2030 and 2050 climate targets.195
The State’s rail modernization program has identified critical elements of the rail network where
improvements, either in timing of service or infrastructure, provide benefits across the entire statewide
network, furthering the attractiveness of rail for a range of trip distances.196 The State also uses the Transit
and Intercity Rail Capital Program (TIRCP) and Low Carbon Transit Operations Program (LCTOP) to provide
grants from GGRF to fund transformative improvements modernizing California’s intercity, commuter,
and urban rail systems, as well as bus and ferry transit systems, to reduce emissions of GHGs by reducing
congestion and VMT throughout California. As the backbone of an electrified mass-transportation network
for the State, the high-speed rail system catalyzes and relies on focused, compact, and walkable development well-served by local transit to funnel riders onto the system and provide alternative options to airplanes and automobiles for interregional travel. Concentrated development, such as that incentivized by the Affordable Housing and Sustainable Communities (AHSC) grant program, can improve ridership and revenue for the
system while providing vibrant communities for all.
At the same time, more needs to be done to fully exploit synergies with emerging mobility solutions like ride-sourcing and more effective infrastructure planning to anticipate and guide the necessary changes in
travel behavior, especially among millennials. Uniquely, high-speed rail affects air-miles traveled, diverting, at
minimum, 30 percent of the intrastate air travel market in 2040.197
While most of the GHG reductions from the transportation sector in this Scoping Plan will come from
technologies and low carbon fuels, a reduction in the growth of VMT is also needed. VMT reductions are
necessary to achieve the 2030 target and must be part of any strategy evaluated in this Plan. Stronger SB
375 GHG reduction targets will enable the State to make significant progress toward this goal, but alone will
not provide all of the VMT growth reductions that will be needed. There is a gap between what SB 375 can
provide and what is needed to meet the State’s 2030 and 2050 goals.
At the time of this writing, adoption of the first round of SCSs by MPOs is complete, and the second round
of SCS planning is underway. Three MPO regions are in the very early stages of developing their third SCSs.
To date, CARB staff reviewed the final determinations of 16 MPOs, and concluded that all 16 of those SCSs
would achieve their targets, if implemented, with many of the MPOs indicating that they expect to exceed
their targets. CARB staff recognizes the very strong performance in this first round of SCSs as a major
success. Currently adopted sustainable communities strategies achieve, in aggregate, a 17 percent reduction
in statewide per capita GHG emissions relative to 2005 by 2035.
Since 2014, CARB has been working with MPOs and other stakeholders to update regional SB 375 targets.
At the same time, CARB has also conducted analysis for development of the Mobile Source Strategy and
Scoping Plan that identifies the need for statewide per capita greenhouse gas emissions reductions on the order of 25 percent by 2035, to meet our climate goals. Many MPOs have identified challenges to incorporating additional strategies and reducing emissions further in their plans, principally tied to the need for additional and more flexible revenue sources. MPOs have submitted target update recommendations
to CARB that in aggregate maintains a 17 percent reduction statewide, which includes commitments of 18
percent reduction by 2035 from each of the four largest MPOs in the State.
CARB is currently reviewing each MPOs target update recommendations alongside new State policies. State
agencies have been working on new State-level VMT-related Policies and Measures (see Table 17) as part of
this Scoping Plan intended to provide the State, MPOs, and local agencies with additional funding resources
and tools to successfully meet the State’s climate goals. CARB’s preliminary review indicates that new State-
level policies and measures will help support updated SB 375 targets that achieve up to 20 percent of the
195 Morello-Frosch, R., M. Zuk, M. Jerrett, B. Shamasunder, and A. D. Kyle. 2011. “Understanding the cumulative impacts of inequalities in environmental health: Implications for policy.” Health Affairs 30(5), 879–887.196 California State Transportation Agency. 2016. 2018 California State Rail Plan factsheet and TIRCP fact sheet.197 California High-Speed Rail Authority. 2016. 2016 Business Plan. Ridership and Revenue Forecast.
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needed statewide reduction, as well as help bridge the remaining VMT growth reduction gap.
Discussions among a broad suite of stakeholders from transportation, the building community, financial institutions, housing advocates, environmental organizations, and community groups are needed to begin the process to pursue and develop the needed set of strategies to ensure that we can achieve necessary
VMT reductions, and that the associated benefits are shared by all Californians. Appendix C further details
potential actions for discussion that can be taken by State government, regional planning agencies, and local
governments, to achieve a broad, statewide vision for more sustainable land use and close the VMT gap.198
At the State level, a number of important policies are being developed. Governor Brown signed Senate Bill
743 (Steinberg, Chapter 386, Statutes of 2013), which called for an update to the metric of transportation
impact in CEQA. That update to the CEQA Guidelines is currently underway. Employing VMT as the metric of
transportation impact statewide will help to ensure GHG reductions planned under SB 375 will be achieved
through on-the-ground development, and will also play an important role in creating the additional GHG
reductions needed beyond SB 375 across the State. Implementation of this change will rely, in part, on local
land use decisions to reduce GHG emissions associated with the transportation sector, both at the project
level, and in long-term plans (including general plans, climate action plans, specific plans, and transportation
plans) and supporting sustainable community strategies developed under SB 375. The State can provide guidance and tools to assist local governments in achieving those objectives.
Appendix H highlights the more significant existing policies, programs, measures, regulations, and initiatives
that provide a framework for helping achieve GHG emissions reductions in this sector.
Looking to the Future
This section outlines the high-level objectives and goals to reduce GHGs in this sector.
Vibrant Communities and Landscapes / VMT Reduction Goals
• Implement and support the use of VMT as the metric for determining
transportation impacts under CEQA, in place of level of service (LOS).
• Promote all feasible policies to reduce VMT, including:
• Land use and community design that reduce VMT,
• Transit oriented development,• Complete street design policies that prioritize transit, biking, and walking, and• Increasing low carbon mobility choices, including improved access to viable and affordable public transportation and active transportation opportunities.
• Complete the construction of high-speed rail integrated with
enhanced rail and transit systems throughout the State.
• Promote transportation fuel system infrastructure for electric, fuel-cell, and other
emerging clean technologies that is accessible to the public where possible, and
especially in underserved communities, including environmental justice communities.
• Increase the number, safety, connectivity, and attractiveness
of biking and walking facilities to increase use.
• Promote potential efficiency gains from automated transportation systems and identify policy
priorities to maximize sustainable outcomes from automated and connected vehicles (preferably ZEVs), including VMT reduction, coordination with transit, and shared mobility, and minimize any increase in VMT, fossil fuel use, and emissions from using automated transportation systems.• Promote shared-use mobility, such as bike sharing, car sharing and ride-sourcing services to
bridge the “first mile, last mile” gap between commuters’ transit stops and their destinations.
• Continue research and development on transportation system infrastructure, including:
• Integrate frameworks for lifecycle analysis of GHG emissions with life-
cycle costs for pavement and large infrastructure projects, and
• Health benefits and costs savings from shifting from driving to walking, bicycling, and transit use.
• Quadruple the proportion of trips taken by foot by 2030 (from a baseline
198 CARB. Potential State - Level Strategies to Advance Sustainable, Equitable Communities and Reduce Vehicle Miles of Travel (VMT) -- for Discussion. www.arb.ca.gov/cc/scopingplan/meetings/091316/Potential%20VMT%20Measures%20For%20
Discussion_9.13.16.pdf
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of the 2010–2012 California Household Travel Survey).
• Strive for a nine-fold increase in the proportion of trips taken by bicycle by 2030
(from a baseline of the 2010–2012 California Household Travel Survey).
• Strive, in passenger rail hubs, for a transit mode share of between 10 percent and 50
percent, and for a walk and bike mode share of between 10 percent and 15 percent.
Vehicle Technology Goals
• Through a strong set of complementary policies–including reliable incentives, significant
infrastructure investment, broad education and outreach, and potential regulation–aim to
reach 100 percent ZEV sales in the light-duty sector (PHEVs, BEVs, and FCEVs) by 2050.
• Make significant progress in ZEV penetrations in non-light-duty sectors.
• Deploy low-emission and electrified rail vehicles.
Clean Fuels Goals
• Electrify the transportation sector using both electricity and hydrogen.
• Promote research development and deployment of low carbon fuels
such as renewable gas, including renewable hydrogen.
• Rapidly reduce carbon intensity of existing liquid and gaseous transportation fuels.
Sustainable Freight Goals
• Increase freight system efficiency of freight operations at specific facilities and along
freight corridors such that more cargo can be moved with fewer emissions.• Accelerate use of clean vehicle and equipment technologies and fuels of freight through targeted introduction of zero emission or near-zero emission (ZE/NZE) technologies, and continued development of renewable fuels.
• Encourage State and federal incentive programs to continue supporting zero
and near-zero pilot and demonstration projects in the freight sector.
• Accelerate use of clean vehicle, equipment, and fuels in freight sector through targeted
introduction of ZE/NZE technologies, and continued development of renewable fuels.
This includes developing policy options that encourage ZE/NZE vehicles on primary freight
corridors (e.g., Interstate-710); examples of such policy options include a separated ZE/
NZE freight lane, employing market mechanisms such as favorable road pricing for ZE/NZE
vehicles, and developing fuel storage and distribution infrastructure along those corridors.
Cross-Sector Interactions
The transportation sector has considerable influence on other sectors and industries in the State. California’s transportation sector is still primarily powered by petroleum, and to reduce statewide emissions, California
must reduce demand for driving; continue to reduce its gasoline and diesel fuel consumption; diversify its
transportation fuel sources by increasing the adoption of low- and zero-carbon fuels; increase the ease and
integration of the rail and transit networks to shift travel mode; and deploy ZE/NZE vehicles.
As California’s population continues to increase, land use patterns will directly impact GHG emissions from
the transportation sector, as well as those associated with the conversion and development of previously
undeveloped land. Specifically, where and how the State population grows will have implications on distances
traveled and tailpipe emissions; as well as on secondary emissions from the transportation sector, including
emissions from vehicle manufacturing and distribution, fuel refining and distribution, demand for new
infrastructure (including roads, transit, and active transportation infrastructure), demand for maintenance
and upkeep of existing infrastructure. Conversion of natural and working lands further affects emissions,
with the attendant impacts to food security, watershed health, and ecosystems. Less dense development
also demands higher energy and water use. With the exception of VMT reductions, none of these secondary emissions are currently accounted for in the GHG models used in this Scoping Plan, but are nonetheless important considerations. Additionally, compact, lower-VMT future development patterns are essential to achieving public health, equity, economic, and conservation goals, which are also not modeled but are
important co-benefits of the overall transportation sector strategy. For example, high-speed rail station
locations were identified in downtown areas to reinforce existing city centers.
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Achieving LCFS targets and shifting from petroleum dependence toward greater reliance on low carbon fuels
also has the potential to affect land use in multiple ways. For example, increased demand for conventional
biofuels could require greater use of land and water for purpose-grown crops, which includes interactions
with the agricultural and natural and working lands sectors. On the other hand, continuing growth in fuels
from urban organic waste, as well as waste biomass such as composting residues, by-processing residues and
agricultural waste and excess forest biomass acts to alleviate the pressure on croplands to meet the need for
food, feed, and fuel. Likewise, captured methane from in-vessel digestion, landfills or dairy farms for use in
vehicles requires close interaction with the waste and farming sectors.
Also, as more electric vehicles and charging stations are deployed, drivers’ charging behavior will affect
the extent to which additional electric generation capacity and ancillary services are needed to maintain a
reliable grid and accommodate a portfolio of 50 percent renewable electricity by 2030. Charging control
and optimization technologies will determine how well integrated the electric and transportation sectors
can become, including, for instance, the widespread use of electric vehicles as storage for excess renewable
generation, vehicle to grid, smart charging, and/or smart grid. The GHG emissions intensity of electricity affects the GHG savings of fuel switching from petroleum-based fuels to electricity; the cleaner the electric grid, the greater the benefits of switching to electricity as a fuel. Similar to electric vehicles, hydrogen fuel
cell electric vehicles have zero-tailpipe emissions and can mitigate GHGs and criteria pollutants. Greenhouse
gas emissions could be further reduced with the use of renewable hydrogen, which can be produced using
renewable electricity or renewable natural gas.
Efforts to Reduce Greenhouse Gases
The measures below include some required and new potential measures to help achieve the State’s 2030
target and to support the high-level objectives for the transportation sector. Some measures may be
designed to directly address GHG reductions, while others may result in GHG reductions as a co-benefit.
Ongoing and Proposed Measures – Vibrant Communities and Landscapes / VMT
Reduction Goals
• Mobile Source Strategy – 15 percent reduction in total light-duty VMT from the BAU in 2050
(with measures to achieve this goal not specified; potential measures identified in Appendix C).• Work with regions to update SB 375 Sustainable Communities Strategies targets for 2035 to better align with the 2030 GHG target and take advantage of State rail investments.• Stronger SB 375 GHG reduction targets will enable the State to make significant progress
toward the goal of reducing total light-duty VMT by 15 percent from expected levels in 2050,
but alone will not provide all of the VMT reductions that will be needed. The gap between what
SB 375 can provide and what is needed to meet the State’s 2030 and 2050 goals needs to be
addressed through additional VMT reduction measures such as those mentioned in Appendix C.
• Implement and support the adoption and use of VMT as the CEQA metric of
transportation impact, such that it promotes GHG reduction, the development
of multimodal transportation networks, and a diversity of land uses.
• Continue to develop and explore pathways to implement State-level VMT reduction strategies, such
as those outlined in the document “Potential State-Level Strategies to Advance Sustainable, Equitable Communities and Reduce Vehicle Miles of Travel (VMT) – for Discussion”199 – included in Appendix C – through a transparent and inclusive interagency policy development process to evaluate and identify implementation pathways for additional policies to
reduce VMT and promote sustainable communities, with a focus on:
• Accelerating equitable and affordable transit-oriented and infill development
through new and enhanced financing and policy incentives and mechanisms,
• Promoting stronger boundaries to suburban growth through enhanced
support for sprawl containment mechanisms such as urban growth
boundaries and transfer of development rights programs,
• Identifying performance criteria for transportation and other infrastructure investments
199 Refers to the document discussed at the September 2016 Public Workshop on the Transportation Sector to Inform Development of the 2030 Target Scoping Plan Update, also available at: www.arb.ca.gov/cc/scopingplan/meetings/091316/
Potential%20VMT%20Measures%20For%20Discussion_9.13.16.pdf
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to ensure alignment with GHG reduction goals and other State policy priorities and
expand access to transit, shared mobility, and active transportation choices,
• Promoting efficient development patterns that maximize protection of natural and working lands,
• Developing pricing mechanisms such as road user/VMT-based
pricing, congestion pricing, and parking pricing strategies,
• Reducing congestion and related GHG emissions through commute trip reduction strategies, and
• Programs to maximize the use of alternatives to single-occupant vehicles,
including bicycling, walking, transit use, and shared mobility options.
• Finalize analysis of the results of the pilot road usage charge program, implemented pursuant to SB
1077 (DeSaulnier, Chapter 835, Statues of 2014), and evaluate deployment of a statewide program.• Continue promoting active transportation pursuant to SB 99 (Committee on Budget and Fiscal Review, Chapter 359, Statutes of 2013) – The Active Transportation Program and beyond.• Continue to build high-speed rail and broader statewide rail modernization
pursuant to the funding program in SB 862 (Committee on Budget and
Fiscal Review, Chapter 36, Statutes of 2014) and other sources.
• Encourage use of streets for multiple modes of transportation (including public transit and active
transportation, such as walking and bicycling), and for all users, including the elderly, young, and less
able bodied, pursuant to AB 1358 (Leno, Chapter 657, Statutes of 2008) – Complete Streets policies.
• Support and assist local and regional governments, through technical assistance, and grant and other
local assistance programs, to develop and implement plans that are consistent with the goals and
concepts in The Second Investment Plan for Fiscal Years 2016-2017 through 2018-2019200 and its
subsequent updates, and Appendix C: Vibrant Communities and Landscapes, including the following:• California Climate Investment programs such as Transformative Climate Communities Program, ensuring promotion of GHG reductions from neighborhood-level community plans in disadvantaged communities.
• AB 2087 (Levine, Chapter 455, Statutes of 2016) – Help local and State agencies apply
core investment principles when planning conservation or mitigation projects.
• High speed rail station area plans.
• Implementation of updated General Plan Guidelines.
• Per SB 350, implement the recommendations identified in the Barriers Study to accessing ZE/NZE
transportation options for low-income customers and recommendations on how to increase
access.201 And, track progress towards these actions over time to ensure disadvantaged
communities are getting equal access and benefits relative to other parts of the State.
• Take into account the current and future impacts of climate change when planning, designing, building, operating, maintaining, and investing in State infrastructure, as required under Executive Order B-30-15.
Ongoing and Proposed Measures – Vehicle Technology
• Implement the Cleaner Technology and Fuels Scenario of CARB’s Mobile Source Strategy, which includes:• An expansion of the Advanced Clean Cars program, which further increases
the stringency of GHG emissions for all light-duty vehicles, and 4.2 million
zero emission and plug-in hybrid light-duty electric vehicles by 2030,
• Phase 1 and 2 GHG regulations for medium- and heavy-duty trucks, and
• Innovative Clean Transit.
• Periodically assess and promote cleaner fleet standards.
• Deploy ZEVs across all vehicle classes, including rail vehicles,
along with the necessary charging infrastructure.
• Encourage State and federal incentive programs to continue supporting
zero and near-zero pilot and demonstration projects.• Collaborate with the U.S. Environmental Protection Agency to promulgate more
200 CARB. January 2016. Cap-and-Trade Auction Proceeds Second Investment Plan: Fiscal Years 2016-17 through 2018-19. Available at: www.arb.ca.gov/cc/capandtrade/auctionproceeds/16-17-updated-final-second-investment-planii.pdf201 CARB. 2017. Low-Income Barriers Study, Part B: Overcoming Barriers to Clean Transportation Access for Low Income Residents. www.arb.ca.gov/msprog/transoptions/draft_sb350_clean_transportation_access_guidance_document.pdf
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stringent locomotives requirements,202 work with California seaports, ocean carriers,
and other stakeholders to develop the criteria to incentivize introduction of Super-
Low Emission Efficient Ships, and investigate potential energy efficiency improvements
for transport refrigeration units and insulated truck and trailer cargo vans.
• Promote research, development, and deployment of new technology
to reduce GHGs, criteria pollutants, and toxics.
• Implement a process for intra-state agency and regional and local transportation coordination
on automated vehicles to ensure shared policy goals in achieving safe, energy efficient, and
low carbon autonomous vehicle deployment that also contribute to VMT reductions.
Ongoing and Proposed Measures – Clean Fuels
• Continue LCFS activities, with increasing stringency of at least
18 percent reduction in carbon intensity (CI).
• Continue to develop and commercialize clean transportation fuels through renewable energy integration goals, tax incentives, research investments, support for project demonstration, public outreach, setting procurement standards, including updating State and local procurement contracts.• Per SB 1383 and the SLCP Strategy, adopt regulations to reduce and recover methane
from landfills, wastewater treatment facilities, and manure at dairies; use the methane as a
source of renewable gas to fuel vehicles and generate electricity; and establish infrastructure
development and procurement policies to deliver renewable gas to the market.
• Accelerate deployment of alternative fueling infrastructure pursuant to the following:
• SB 350 – CPUC to accelerate widespread transportation electrification.
• Executive Order B-16-2012 and 2016 ZEV Action Plan – call for
infrastructure to support 1 million ZEVs by 2020.
• CEC’s Alternative and Renewable Fuel and Vehicle Technology Program (ARFVTP).
• CPUC’s NRG settlement.• CALGreen Code provisions mandate installation of PEV charging infrastructure in new residential and commercial buildings.203
• IOU electric vehicle charging infrastructure pilot programs.
Ongoing and Proposed Measures – Sustainable Freight
• Implement the California Sustainable Freight Action Plan:• 25 percent improvement of freight system efficiency by 2030.
• Deployment of over 100,000 freight vehicles and equipment capable
of zero emission operation, and maximize near-zero emission freight
vehicles and equipment powered by renewable energy by 2030.
Ongoing and Proposed Measures – California and Transportation Plan
• Update every five years and implement California Transportation Plan.
Sector Measures
• Implement the post-2020 Cap-and-Trade Program
Potential Additional Actions
The actions below have the potential to reduce GHGs and complement the measures and policies identified
in Chapter 2. These are included to spur thinking and exploration of innovation that may help the State
achieve its long-term climate goals.
• Develop a set of complementary policies to make light-duty ZEVs clear market winners, with
a goal of reaching 100 percent light-duty ZEV sales. This could include the following:
• Reliable purchase/trade-in incentives for at least 10 years.
• Dealer incentives for ZEV sales.
• Policies to ensure operating cost savings for ZEVs relative to internal
202 www.arb.ca.gov/railyard/docs/final_locomotive_petition_and_cover_letter_4_13_17.pdf203 Such as raceway and panel capacity to support future installation of electrical vehicle charging stations.
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combustion engines, including low cost electricity.
• Additional investments in charging and ZEV refueling infrastructure.
• A broad and effective marketing and outreach campaign.
• Collaborations with cities to develop complementary incentive and use policies for ZEVs.
• Targeted policies to support ZEV sales and use in low income and disadvantaged communities.
• Develop a Low-Emission Diesel Standard to diversify the fuel pool by incentivizing
increased production of low-emission diesel fuels. This standard is anticipated
to both displace consumption of conventional diesel with increased use of low-
emission diesel fuels, and to reduce emissions from conventional fuels.
• Continue to develop and explore pathways to implement State-level VMT reduction strategies, such as those outlined in Appendix C through a transparent and inclusive interagency policy development process to evaluate and identify implementation pathways for additional policies to reduce VMT and promote sustainable communities, with a focus on the following:
• Accelerating equitable and affordable transit-oriented and infill development
through new and enhanced financing and policy incentives and mechanisms.
• Promote infrastructure necessary for residential development in existing
communities, and ensure any urban growth boundaries are paired with significant
infill promotion strategies and removal of infill development barriers.
• Identifying performance criteria for transportation and other infrastructure investments, to
ensure alignment with GHG reduction goals and other State policy priorities, and improve
proximity, expanded access to transit, shared mobility, and active transportation choices.
• Promoting efficient development patterns that maximize protection of natural and working lands.• Developing pricing mechanisms such as road user/VMT-based pricing, congestion pricing, and parking pricing strategies.• Reducing congestion and related GHG emissions through programs to
maximize the use of alternatives to single-occupant vehicles, including bicycling,
walking, transit use, and shared mobility options for commute trips.
• Continue to promote research and standards for new and existing
technologies to reduce GHGs, including but not limited to:
• Low rolling resistance tires in the replacement tire market, subject to certification standards that
identify tires as low rolling resistance tires or verify emissions reductions and potential fuel savings.
• Impacts on VMT of car sharing, ride-sourcing, and other emerging mobility options.
• Driving behaviors that reduce GHG emissions, such as ecodriving
training and real-time feedback mechanisms.
Natural and Working Lands Including Agricultural Lands
In his 2015 State of the State address, Governor Brown established 2030 targets for GHG emissions
reductions and called for policies and actions to reduce GHG emissions from natural and working lands,
including forests, rangelands, farms, wetlands, and soils. The passage of SB 1386 (Wolk, Chapter 535, Statutes of 2015-16) codified this policy and emphasized the important role natural and working lands play in the State’s climate strategy. This Scoping Plan focuses renewed attention on California’s natural and working lands and the contribution they make to meet the State’s goals for carbon sequestration, GHG reduction, and
climate change adaptation.
California’s natural and working lands encompass a range of land types and uses, including farms, ranches, forests, grasslands, deserts, wetlands, riparian areas, coastal areas and the ocean-- as well as the green
spaces in urban and built environments. These resources can be both a source and sink for GHG emissions.
Policy in this sector must balance GHG emissions reductions and carbon sequestration with other co-
benefits, such as clean air, wildlife and pollinator habitat, strong economies, food, fiber and renewable energy
production, and water supply.204
Recent trends indicate that significant pools of carbon from these landscapes risk reversal: over the period
2001–2010 disturbance caused an estimated 150 MMT C loss, with the majority– approximately 120 MMT C–
204 www.sierranevada.ca.gov/our-region/ca-primary-watershed
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lost through wildland fire.205 At the same time, energy use, methane, and N2O emissions from the agricultural
sector accounts for eight percent of the emissions in the statewide GHG inventory.
California’s climate objective for natural and working lands is to maintain them as a carbon sink (i.e., net zero or negative GHG emissions) and, where appropriate, minimize the net GHG and black carbon emissions
associated with management, biomass utilization, and wildfire events. In order to achieve this objective,
this Plan directs the continued development of the broad and growing understanding of carbon dynamics
on California’s landscapes, statewide emission trends, and their responses to different land management
scenarios. Further, in order to build a programmatic framework for achieving this long-term objective to
maintain California’s natural and working lands as a carbon sink, this Plan directs the State to quantify the
carbon impacts of both publicly funded (e.g., bonds, special taxes, general fund) climate intervention activities
on California’s natural and working lands made through existing programs as well as potential regulatory
actions on land management. This Plan proposes an intervention based reduction goal of at least 15-20 million
metric tons by 2030 as a reasonable beginning point for further discussion and development based on the State’s current preliminary understanding of what might be feasible. This Plan recognizes that achieving an initial statewide goal of sequestering and avoiding emissions in this sector by at least 15-20 million metric tons by 2030 through existing pathways and new incentives would provide a crucial complement to the measures
described in this Scoping Plan and will inform the development of longer-term natural and working lands goals.
Achieving this ambitious climate goal will require collaboration and support from State and local agencies,
which must improve their capacity to participate and benefit from State climate programs, and set the path for
natural and working lands to help the State meet its long-range climate goals.
Looking to the Future
This section outlines how the State will achieve California’s climate objectives to: (1) maintain them as a
resilient carbon sink (i.e., net zero or negative GHG emissions), and (2) minimize the net GHG and black
carbon emissions associated with management, biomass disposal, and wildfire events to 2030 and beyond.
Implementation will include policy and program pathways, with activities related to land protection; enhanced
carbon sequestration; and innovative biomass utilization. The framework for this section is to:
• Protect land from conversion to more intensified uses by increasing
conservation opportunities and pursuing local planning processes in urban and
infrastructure development patterns that avoid greenfield development.
• Enhance the resilience of and potential for carbon sequestration on lands through management
and restoration, and reduce GHG and black carbon emissions from wildfire and management
activities. This enhancement includes expansion and management of green space in urban areas.
• Innovate biomass utilization such that harvested wood and excess agricultural and forest biomass can be used to advance statewide objectives for renewable energy and fuels, wood product manufacturing, agricultural markets, and soil health, resulting in avoided GHG emissions relative to traditional utilization pathways. Associated activities
should increase the resilience of rural communities and economies.
To accomplish these objectives, the State, led by California Natural Resources Agency (CNRA), California Department of Food and Agriculture (CDFA), California Environmental Protection Agency (CalEPA) and CARB
will complete a Natural and Working Lands (NWL) Climate Change Implementation Plan (Implementation
Plan) in 2018 to evaluate a range of implementation scenarios for natural and working lands and identify
long-term (2050 or 2100) sequestration goals that can be incorporated into future climate policy. The
Implementation Plan will:
• Include a projection of statewide emissions under business-as-usual land use and management
conditions and alternative scenarios, as well as a listing and quantitative assessment
of conservation and management activities the state may pursue to achieve
the NWL climate objectives and the statewide goals of at least 15-20 MMTCO2e
emissions sequestering and avoidance from the NWL sector by 2030;
• Identify state departments, boards, conservancies, and CNRA and CDFA
programs responsible for meeting the 15-20 MMTCO2e goal by 2030; and
• Identify methodologies to be used by State programs to account for the
205 www.arb.ca.gov/cc/inventory/sectors/forest/forest.htm
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GHG impacts of prior state funded land use and management interventions,
and to be used to estimate the GHG impacts of future interventions.
While growing trees and other vegetation, as well as soil carbon sequestration, reduce some of the carbon losses measured, climate change itself further stresses many of these systems and affects the ability of
California’s landscapes to maintain its carbon sink. The State will continue to rely on best available science
to support actions and incentives to slow and reverse these trends, in concert with other production and
ecological objectives of land use. The Forest Climate Action Team, Healthy Soils Initiative, State Coastal
Conservancy’s Climate Ready Program, various California Climate Investment programs, and CARB’s
compliance offset program already undertake portions of this work. As we move towards and maximize the
ability of our land base to serve as a carbon sink, it will also be important to strengthen these individual
activities through the coordination and aggregation of ecoregional plans that inform these interventions.
These and future additional efforts can not only protect California’s natural carbon stocks, they can also
improve quality of life in urban and rural communities alike and increase the climate resilience of agricultural, forestry, and recreational industries and the rural communities they support; the State’s water supply; biodiversity; and the safety and environmental health of all who call California home.
Research and Policy Needs
Research is ongoing across agencies to advance the state of the science on NWL carbon dynamics, including
a number of projects within the Fourth Climate Change Assessment, and a compendium of climate research
being managed by the CNRA that will be completed in 2018. Additionally, California needs a well-defined reference case, or “business as usual” scenario to set a comprehensive and strategic path forward for California’s lands and ocean environments to contribute to the State’s climate goals. Finally, efforts must increase to gather, interpret, and unify best available science on the GHG and carbon sequestration impacts
of land use and management practices applied across forests, cultivated agricultural lands, rangelands and
grasslands, wetlands, coastal and ocean systems, desert ecosystems, and urban and other settled lands.
The Implementation Plan, as summarized above, will utilize the Protect-Enhance-Innovate framework and
employ projections for carbon sequestration and GHG emissions from California’s land base under reference
case and increased management scenarios. The quantitative outputs of these projections, expressed as
carbon dioxide equivalents will drive acreage needs for implementation using CO2e/acre results from multiple
modeling efforts. The Implementation Plan will also identify GHG emissions quantification within and across
programs and agencies and describe implementation monitoring and emissions inventories.
Natural and Working Lands Inventory
In order to understand how carbon is released and sequestered by natural and working landscapes, CARB has
worked extensively with other State agencies, academic researchers and the public to develop a Natural and
Working Lands inventory that will guide this process. As with other sectors, the CARB Natural and Working
Lands inventory represents a snapshot of emissions in recent years, using a combination of reported and
measured data. A time lag exists between the last year of available data and the completion of the inventory
to allow time for reporting and processing the data. For emission sources that are hard to individually measure,
the CARB inventory estimates emissions based on “surrogates,” such as the typical amount of travel on
unpaved roads to estimate particulate matter emissions at the county level. The most recent inventory can also
be “forecast” to project prevailing conditions in a future year based on rules and programs currently in place – known as a “business as usual projection” - along with scenarios to explore the benefits of further strategies to reduce emissions. Forecasts of business-as-usual and policy scenarios guide planning efforts.
As discussed below, ongoing research into forecasting emissions from Natural and Working Lands includes a project at Lawrence Berkeley National Laboratory funded by CNRA. CARB is monitoring this and other research activities and will incorporate results into a proposed inventory and forecasting methodology for Natural and Working Lands. CARB will solicit public feedback and review on the resulting product prior to
completing the first full Natural and Working Lands Inventory by the end of 2018, as called for in SB 859. The
Natural and Working Lands Inventory is spatially-resolved, so it can be segmented by county, watershed, or
other regional planning areas. This spatial resolution allows local governments and regional organizations to
use the inventory, along with more granular location-specific information, to track progress from projects in
their jurisdictions.
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CARB plans to update the forest component of the Natural and Working Lands inventory to include 2012
GHG emissions estimates, followed by emissions estimates for soil carbon, urban forestry, and croplands
by mid-2018. Work currently in progress applies airborne and space-based technologies to monitor forest
health and quantify emissions associated with land-based carbon. California and federal agencies are working
with researchers and funding studies to enhance our understanding of the roles of forests and other lands in
climate change using rapidly advancing remote sensing technology.206, 207
CALAND Carbon Emissions Model
CNRA is managing the development of a CALAND model through Lawrence Berkeley National Laboratory,
which will include a projection of business-as-usual emissions as well as a listing and quantitative assessment
of conservation and management activities the State may pursue to achieve at least 15-20 MMT sequestration
and GHG avoided emissions from the NWL sector by 2030.
CNRA, along with CARB and CDFA, will establish a formal public engagement process to gather
external scientific expertise to inform development and finalization of the CALAND model for use in the
Implementation Plan. Development of the Implementation Plan itself will also include a formal public process.
Cross-Sector Interactions
Strategies that reduce GHG emissions or increase sequestration in the natural and working lands sector
often overlap and result in synergies with other sectors, most notably at intersections with land use, biomass
and waste utilization, energy and water. It will be important for the sector to make critical linkages to other
sectors, including energy, transportation fuels, and waste, and develop plans to integrate the natural and
working lands sector into existing models, such as PATHWAYS and REMI.
Landowner, local, and regional decisions affect land use development patterns and natural and working land
conversion rates; conversely, conservation activities can support infill-oriented regional development and
related transportation needs. As discussed earlier in the Transportation Sustainability section, under SB 375,
Sustainable Communities Strategies (SCSs) aim to link transportation, housing, and climate policy to reduce per capita GHG emissions while providing a range of other important benefits for Californians. Some SCSs include policies, objectives or implementation measures relating to conservation and land protections, and to urban greening.208 Protecting natural and working lands that are under threat of conversion can promote
infill development, reduce VMT, limit infrastructure expansion, and curb associated GHG emissions. An
integrated vision for community development, land conservation and management, and transportation is a
key component of meeting our transportation and natural and working lands goals.209
Agricultural and commercial forestry operations produce biomass as both an objective (i.e., food and fiber
production) and a waste by-product. How this material is utilized can either increase or decrease emissions
associated with management and restoration activities, turn waste into usable products, displace fossil
fuels used in energy and transportation, and increase carbon stored in durable wood products in the built
environment. Finding productive ways to use this material offers new opportunities to reduce GHG emissions,
promote carbon sequestration, and generate economic resources for forest, agricultural, and waste sectors
and communities. California is investigating ways to transform how organic waste from the agricultural and
municipal sectors is managed to meet SLCP emissions reductions targets required by SB 1383,210
and to protect public health. Cross-sector synergies and complete waste inter-cycles, discussed further in the Waste Management section, result from conscientious treatment of these resources, including opportunities to improve soil health, increase renewable energy generation, and enhance market support for non-commercial products and waste. Productive utilization of dead and dying trees is a significant focus of
the Governor’s Tree Mortality Task Force, and efforts to resolve the current shortfall in utilization capacity is
addressed in that State of Emergency Declaration as well as in SB 859.
Natural and working lands stewardship is essential to securing the State’s water supply along the entire
206 Asner, G. et al. (2015) Progressive forest canopy water loss during the 2012–2015 California drought. PNAS 113.2: E249-E255207 Battles, J. et al. (in progress) Innovations in measuring and managing forest carbon stocks in California. Project 2C: 4th California Climate Change Assessment. Natural Resources Agency. resources.ca.gov/climate/fourth/208 Livingston, Adam. Sustainable Communities Strategies and Conservation. January 2016. Available at: www.nature.org/
ourinitiatives/regions/northamerica/unitedstates/california/sustainable-communities-strategies-and-conservation.pdf209 www.arb.ca.gov/cc/scopingplan/meetings/meetings.htm210 SB1383 (Lara, Chapter 396, Statutes of 2016) requires a 50 percent reduction in anthropogenic black carbon emissions by 2030.
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supply chain, from protection and management of the forested headwaters to preserving the ability of
mountain meadows to retain and filter water ensuring flows and habitat in the Delta and its tributaries, end
use efficiencies in agricultural and urban uses, and groundwater infiltration and utilization statewide. For
example, more efficient water and energy use in farming operations could support GHG emissions reductions
goals in the energy sectors. And improving forest health in the Sierra Nevada, Cascades, and other
headwaters protects water quality and availability, in alignment with the California Water Action Plan.
Potential Actions to Enhance Carbon Sequestration and Reduce Greenhouse
Gases in NWL
While agricultural and forest lands comprise the greatest acreage of NWL statewide, representing significant
opportunity for achieving the State’s NWL climate goals, actions on all NWL remain critical. The land
management strategies and targets included in these sections are illustrative of the types of actions that will
be necessary to maintain all of California’s NWL and urban green space as a net sink of carbon, and are being
used to aid in development of scenario modeling. The Implementation Plan will use this scenario modeling to
scope the scale of action needed to ensure resilient future landscapes and identify key areas for advancement.
Agriculture’s Role in Emissions Reductions and Carbon Sequestration
In 2030 and 2050, the agricultural sector must remain vibrant and strong. California’s agricultural production
is critical to global food security. It is also vulnerable to climate change. A study211 by the University of
California concluded that the drought in 2015 cost the state economy $2.7 billion and 21,000 full time jobs.
These losses are expected to ripple through rural communities for another several years. This illustrates the
importance of strengthening agriculture while protecting resources and mitigating climate change.
As the State works to meet emissions reductions goals, the agricultural sector can reduce emissions from
production, sequester carbon and build soil carbon stocks, and play a role in cross-sectoral efforts to
maximize the benefits of natural and working lands.
Climate-smart agriculture is an integrated approach to achieving GHG reductions while also ensuring food
security and promoting agricultural adaptation in the face of climate change. Conserving agricultural land,
sequestering carbon in agricultural soils, employing a variety of techniques to manage manure on dairies, and increasing the efficiency of on-farm water and energy use are examples of practices that can achieve climate and food production goals across diverse agricultural systems. Climate-smart agriculture can support the Protect, Enhance, and Innovate goals.
Approximately 60 percent of agricultural emissions are methane emissions from the dairy and livestock sectors. Emissions come from the animals themselves, through enteric fermentation, as well as from manure management–especially at dairies. SB 1383 and the resultant SLCP Strategy identify a mix of
voluntary, incentive-based, and potential regulatory actions to achieve significant emissions reductions
from these sources. A variety of techniques can attain the best results for each specific farming operation;
effectively implementing a broad mix of strategies will reduce the GHG emissions from the agricultural
sector significantly. CARB and CDFA and other agencies are working together to solicit input from industry,
environmental, and community groups to encourage early and meaningful action to reduce emissions from
the livestock sector.
Over the last several years, farms have begun to optimize fertilizer applications to protect water quality,
maintain high yields, and reduce emissions of N2O, a greenhouse gas. Farmers are required through the
Irrigated Lands Regulatory Program to manage nitrogen fertilizers to protect water quality through the use of
nitrogen management plans. Nitrogen management plans are a tool designed to prevent over-applications of
nitrogen through an approach that accounts for the nitrogen inputs from water, soil amendments and other
sources, and also accounts for nitrogen removed from the field. CDFA’s Fertilizer Research and Education Program, in coordination with university researchers and others, has developed fertilization guidelines to optimize the rate, timing and placement of fertilizers for crops that represent more than half of the irrigated agriculture in California. Similarly, innovations in water management and the expansion of high efficiency
irrigation methods also are contributing to N2O reductions.
211 Howitt, Richard E., Duncan MacEwan, Josué Medellín-Azuara, Jay R. Lund, Daniel A. Sumner. 2015. Economic Analysis of the 2015 Drought for California. Davis, CA: Center for Watershed Sciences, University of California – Davis.
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California’s farms and ranches have the ability to remove carbon from the atmosphere through management
practices that build and retain soil organic matter. Adequate soil organic matter ensures the continued soil
capacity to function as a vital living ecosystem with multiple benefits, producing food for plants, animals,
and humans. The Healthy Soils Initiative, announced by Governor Brown in 2015, offers an opportunity to
incentivize the management of farmland for increased carbon sequestration in soil, also augmenting co-
benefits including improved plant health and yields, increased water infiltration and retention, reduced
sediment erosion and dust, improved water and air quality, and improved biological diversity and wildlife
habitat.
SB 859, signed into law in 2016, establishes the Healthy Soils Program at CDFA to provide incentives to
farmers. It enables financial support for on-farm demonstration projects that “result in greenhouse gas
benefits across all farming types with the intent to establish or promote healthy soils”. It defines healthy
soils as “soils that enhance their continuing capacity to function as a biological system, increase soil
organic matter, improve soil structure and water-and nutrient-holding capacity, and result in net long-term greenhouse gas benefits.”
As noted in the Cross-Sector Interactions section, State and local efforts to manage land for carbon
sequestration must work in conjunction with existing plans, incentives, and programs protecting California’s water supply, agricultural lands, and wildlife habitat. This Scoping Plan fits within a wide range of ongoing planning efforts throughout the State to advance economic and environmental priorities associated with natural and working lands.
The Role of Forests in Emissions Reductions and Carbon Sequestration
Decades of fire exclusion, coupled with an extended drought and the impacts of climate change, have
increased the size and intensity of wildfires and bark beetle infestations; exposed millions of urban and rural residents to unhealthy smoke-laden air from wildfires; and threatened progress toward meeting the state’s long-term climate goals. Managing forests in California to be healthy, resilient net sinks of carbon is a vital part of California’s climate change policy.
More than 100 million trees are dead, and recent wildfires have been among the most destructive and expensive in state history. As many as 15 million acres of California forests are estimated to be unhealthy and in need of some form of restoration, including more than 9 million acres managed by federal land
management agencies and 6 million acres of State and privately managed forests.
California’s urban forests also face multiple challenges, including drought and invasive exotic insects. Urban forests require maintenance to preserve the multiple values they provide and merit expansion to sequester
carbon and secure other benefits to urban dwellers and the State.
The California Forest Carbon Plan (FCP), being developed by the Forest Climate Action Team (FCAT), seeks to establish California’s forests as a more resilient and reliable long-term carbon sink, rather than a GHG and
black carbon emission source, and confer additional ecosystem benefits through a range of management
strategies.212 The FCP emphasizes working collaboratively at the watershed or landscape scale to restore
resilience to all forestlands in the state.
The current draft of the FCP places carbon sequestration and reducing black carbon and GHG emissions as
one set of management objectives in the broader context of forest health and a range of other important
forest co-benefits. California will manage for carbon alongside wildlife habitat, watershed protection,
recreational access, traditional tribal uses, public health and safety, forest products, and local and regional
economic development.
212 http://www.fire.ca.gov/fcat/
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Federally managed lands play an important role in the achievement of the California climate goals established
in AB 32 and subsequent related legislation and plans. Over half of the forestland in California is managed
by the federal government, primarily by the USDA Forest Service Pacific Southwest Region, and these lands
comprise the largest potential forest carbon sink under one ownership in the state. Several regulatory, policy,
and financial challenges have hindered the ability of the Forest Service and Department of Interior agencies
(Bureau of Land Management and National Park Service) to increase the pace and scale of restoration
needed, such as the current budget structure to fund wildland fire suppression and the procedural
requirements of a number of federal environmental and planning statutes. The State of California must
continue to work closely and in parallel to the federal government’s efforts to resolve these obstacles and
achieve forest health and resilience on the lands that federal agencies manage.
Protection of Land and Land Use
California will continue to pursue development and new infrastructure construction patterns that avoid
greenfield development, limit conflicts with neighboring land uses, and increase conservation opportunities
for NWL to reduce conversion to intensified uses. Success will depend on working through local and regional
land use planning and permitting, as well as developing incentives for participation by local governments and
individual landowners.
Enhance Carbon Sequestration and Resilience through Management and Restoration
California will increase efforts to manage and restore land to secure and increase carbon storage and
minimize GHG and black carbon emissions in a sustainable manner so that the carbon bank is resilient and
provides other benefits such as water quality, habitat and recreation.
One tool to demonstrate the potential for greater management and restoration on NWL is the CALAND
model. As detailed in the Discussion Draft213 and discussed above, it considers a variety of management
and restoration activities employed across the State. Version 1 of the CALAND model considered two
potential scenarios, a “low” and a “high” rate of implementation to 2030, with resulting carbon sequestration
outcomes to 2050. The acreages given in the “low” scenario all represent feasible implementation on public and private lands beyond current rates for the listed activity, given availability of additional funding and other supporting resources. The “high” scenario represents a more ambitious approach, requiring new programs and policies, including collaboration with federal partners, to support implementation.
The activities presented in the Discussion Draft and Version 2 of CALAND are not inclusive of all activities under this strategy. Modeling will continue beyond finalization of the Scoping Plan. Agencies and modelers will continue to identify and analyze land management and restoration activities to advance the State’s
climate goals and improvements in modeling projections or other quantification protocols.
Management and restoration activities under consideration to help reduce GHG emissions beyond those identified in initial modeling include, but are not limited to the following:
• Forest fuel reduction treatments, reforestation, other restoration activities, prescribed fire and managed ignition.• Restoration of mountain meadows, managed wetlands in the Sacramento
San Joaquin Delta, coastal wetlands and desert habitat.
• Increasing the extent of eelgrass beds.
• Creation and management of parks and other greenspace in urban
areas, including expansion of the existing urban tree canopy.
• Implementation of U.S. Department of Agriculture (USDA) Natural Resource
Conservation Service (NRCS) management practices suitable for California agriculture
including those practices identified in the Healthy Soils Incentive Program.
• Compost application to irrigated cropland.
Additional potential tools to encourage these activities include working with the federal government to
fund more management on federal lands, mitigating for land conversion (as modeled by the High Speed Rail
Authority), and revisiting the Forest Practices Act to enhance carbon sequestration benefits associated with
timber production activities.
213 www.arb.ca.gov/cc/scopingplan/2030target_sp_dd120216.pdf
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Innovate NWL Waste Utilization Pathways
Excess materials generated by commercial agricultural and forestry operations, biomass and wood harvested through forest health and restoration treatments, and material that is generated in response to Tree Mortality Emergency activities, should be used in a manner that minimizes GHG and black carbon emissions
and promotes public and environmental health. The Legislature and Governor Brown set an ambitious
goal of 75 percent recycling, composting or source reduction of solid waste in landfills by 2020. The State
and stakeholders must develop targeted policies or incentives to support durable markets for all of this
diverted material. Market opportunities include production of renewable electricity and biofuels, durable
wood products, compost and other soil amendments, animal feed and bedding, and other uses. Research,
development, and implementation activities in energy, wood products, waste, and soil amendment fields
should be spatially-scaled to better link waste generation with infrastructure development.
The goals of this sector, with the potential to reduce GHGs and complement the measures and policies
identified in Chapter 2, are described in Looking to the Future. The development of the Implementation Plan
will spur thinking and exploration of innovation that may help the State achieve its long-term climate goals.
Waste Management
The Waste Management sector covers all aspects of solid waste214 and materials management including
reduction/reuse; recycling, and remanufacturing of recovered material; composting and in-vessel (anaerobic
and aerobic) digestion; biomass management (chip and grind, composting, biomass conversion); municipal
solid waste transformation; and landfilling. This sector also includes market development programs, such as
the State’s recycled-content product procurement program and a range of grant and loan programs. Data
from CalRecycle’s report, 2014 Disposal Facility-Based Characterization of Solid Waste in California, shows
that materials, such as organics, that decompose in landfills and generate methane comprise a significant
portion of the waste stream. Methane is a potent SLCP with a global warming potential 25 times greater than that of carbon dioxide on a 100-year time horizon and more than 70 times greater than that of carbon dioxide on a 20-year time horizon.215
Within CARB’s greenhouse gas inventory, emissions from the waste management sector consist of methane and nitrous oxide emissions from landfills and from commercial-scale composting, with methane being the primary contributor to the sector’s emissions. The sector emitted 8.85 MMTCO2e in 2014, comprising approximately 2 percent of the State’s GHG emissions.
Emissions from recycling and waste have grown by 19 percent since 2000. The majority of those emissions are attributed to landfills, despite the majority of landfills having gas collection systems in place.216 Landfill emissions account for 94 percent of the emissions in this sector, while compost production facilities make up
a small fraction of emissions.217 The annual amount of solid waste deposited in California landfills grew from
37 million tons in 2000 to its peak of 46 million tons in 2005, followed by a declining trend until 2009 when
landfilled solid waste stabilized to relatively constant levels. Landfill emissions are driven by the total waste-in-
place, rather than year-to-year fluctuation in annual deposition of solid waste, as the rate and volume of gas
produced during decomposition depends on the characteristics of the waste and a number of environmental
factors. As a result, waste disposed in a given year contributes to emissions that year and in subsequent
years.
In addition to direct emissions, the reduction, reuse, and recycling of waste materials decreases upstream
GHG emissions associated with the extraction and processing of virgin materials and their use in production
and transport of products. Although many of these upstream GHG emissions happen outside of California,
California’s waste policies can reduce both local and global GHG emissions and create jobs within the State.
214 In general, the term solid waste refers to garbage, refuse, sludges, and other discarded solid materials resulting from residential activities, and industrial and commercial operations. This term generally does not include solids or dissolved material in domestic sewage or other significant pollutants in water such as silt, dissolved or suspended solids in industrial wastewater effluents, dissolved materials in irrigation return flows or other common water pollutants.215 Intergovernmental Panel on Climate Change. 2007. Climate Change 2007: Working Group I: The Physical Science Basis. 2.10.2 Direct Global Warming Potentials. Fourth Assessment Report. www.ipcc.ch/publications_and_data/ar4/wg1/en/ch2s2-10-2.html 216 CARB. 2013. California Greenhouse Gas Inventory for 2000–2013 – by Category as Defined in the 2008 Scoping Draft Plan (based upon IPCC Fourth Assessment Report’s Global Warming Potentials). 217 CARB. 2016. 2016 Edition California GHG Emission Inventory. California Greenhouse Gas Emission Inventory: 2000–2014. Version June 17, 2016.
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While landfills are an effective and relatively safe way to manage some waste, disposal-centric activities
result in squandering valuable resources and generate landfill gases as well as other risks. A large fraction
of the organics in the waste stream can be diverted from landfills to composting or digestion facilities to
produce beneficial products. Moreover, food waste is the largest component of organics disposed in landfills;
a portion of this is edible and should be captured at its source and, for example, provided to food banks
to feed people in need. A State waste management sector “loading order” should focus more attention
on reducing how much waste we generate and recovering and recycling whatever resources we can, using
landfills as a last resort.
Landmark initiatives like the Integrated Waste Management Act of 1989 (AB 939) demonstrate California’s
efforts to build communities that consume less, recycle more, and take resource conservation to higher and
higher levels. Statewide, Californians achieved a 49 percent recycling rate in 2014, and recycling programs
support an estimated 75,000 to 115,000 green jobs in California. If California were to achieve a 75 percent
statewide solid waste recycling rate by 2020–a goal set out by the Legislature in AB 341 (Chesboro, Chapter 476, Statutes of 2011)–by recycling and remanufacturing at in-state facilities, the State could potentially generate an additional 100,000 green jobs.218 In addition to employment contributions, diversion of organic waste from landfills can generate positive environmental impacts. Compost from organic matter provides
soil amendments to revitalize farmland, reduces irrigation and landscaping water demands, contributes to
erosion control in fire-ravaged landscapes, and potentially increase long-term carbon storage in rangelands.
Production and use of bioenergy in the form of biofuels and renewable natural gas has the potential to
reduce dependency on fossil fuels for the transportation sector. For the energy sector, however, renewable
natural gas faces safety, feasibility, and cost issues.
The State has a robust waste management system in place, with established programs that reduce air
emissions through activities such as gas collection systems from landfills219 and stringent recycling mandates.
AB 939 required cities and counties to reduce the amount of waste going to landfills by 50 percent in 2000,
and municipalities have nearly universally met this mandate. Californians dispose about 30 million tons of
solid waste in landfills each year. To further reduce landfilled solid waste, the Legislature adopted AB 341
to achieve more significant waste reductions by setting a goal that 75 percent of solid waste generated be
reduced, recycled, or composted by 2020, and by mandating commercial recycling. AB 1826 (Chesboro, Chapter 727, Statutes of 2014) added requirements regarding mandatory commercial organics recycling.
Although solid waste management has evolved over the last 27 years and diversion rates (which include more
than recycling) have increased more than six-fold since 1989, if no further changes in policy are made, the State’s growing population and economy will lead to higher amounts of overall disposal along with associated increases in GHG emissions. The pathway to reducing disposal and associated GHG emissions will require significant expansion of the composting, anaerobic digestion, and recycling manufacturing infrastructure in
the State.
To help reduce GHG emissions by 40 percent below 1990 levels by 2030 and meet California’s waste reduction goals, California’s waste management sector strives to achieve in-state processing and
management of waste generated in California. To carry out this vision, we must work with residents and
producers to reduce the volume of waste generated overall and capitalize on technology and social changes
that might enable waste reduction. Packaging comprises approximately 8 million tons of waste landfilled in
California annually, or about one quarter of the State’s total disposal stream. To reduce the climate change
footprint of packaging, the State is promoting the inclusion of source reduction principles in packaging and
product design; fostering recycling and recyclability as a front end design parameter for packaging and
products that cannot be reduced; and encouraging recycling markets and market development for recycled-
content products and packaging. CalRecycle is developing a packaging policy model containing components
necessary for a mandatory comprehensive, statewide packaging program in California; this would need to be legislatively enacted to achieve a packaging reduction goal, such as 50 percent by 2030. CalRecycle is also continuing to work with stakeholder organizations and industry to explore complementary voluntary activities that have the potential to significantly decrease packaging disposal in California. In addition, large-scale shifts
in materials management will be necessary, including steps to maximize recycling and diversion from landfills
218 CalRecycle. 2013. AB 341’s 75 Percent Goal and Potential New Recycling Jobs in California by 2020. July. www.calrecycle.ca.gov/Publications/Documents/1463/20131463.pdf219 CARB approved a regulation to reduce methane from municipal solid waste landfills as a discrete early action measure under AB 32. The regulation became effective June 17, 2010. Additional information is available at: www.arb.ca.gov/regact/2009/
landfills09/landfillfinalfro.pdf
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and build the necessary infrastructure to support a sustainable, low carbon waste management system within
California. Working together, State and local agencies will identify ways to increase the use of waste diversion
alternatives and expand potential markets, obtain funds and incentives for building the infrastructure and
strengthening markets, and evaluate the need for additional research to achieve California’s GHG reduction
and waste management goals.
Additional legislation codified since the First Scoping Plan Update outlines new opportunities and
requirements to reduce GHG emissions from the waste sector, with a focus on reducing organic waste
sent to landfills. SB 605 (Lara, Chapter 523, Statutes of 2014) requires that CARB develop a strategy to
reduce SLCPs and SB 1383 requires the strategy to be implemented by January 1, 2018. CARB’s recently
adopted SLCP Reduction Strategy includes organic waste diversion targets for 2020 and 2025 consistent
with SB 1383 to reduce methane emissions from landfills. It requires CalRecycle, in consultation with CARB,
to adopt regulations to achieve statewide disposal targets to reduce landfilling of organic waste by: (1) 50
percent from the 2014 level by 2020, and (2) 75 percent from the 2014 level by 2025. Under SB 1383, of the edible food destined for the organic waste stream, not less than 20 percent is to be recovered to feed people in need by 2025. The regulations are to take effect on or after January 1, 2022, and CalRecycle, in consultation with CARB, must analyze the progress that the waste management sector, State government,
and local government have made in achieving the 2020 and 2025 goals by July 1, 2020. It is estimated that
the combined effect of the food waste prevention and rescue programs and organics diversion from landfills
will reduce 4 MMTCO2e of methane in 2030 (using a 20-year GWP), but one year of waste diversion in 2030 is
expected to result in a reduction of 14 MMTCO2e of emissions over the lifetime of waste decomposition.
Looking to the Future
This section outlines the high-level objectives and goals to reduce GHGs in this sector.
Goals
• Take full ownership of the waste generated in California.
• View waste as a resource and convert waste from all sectors to beneficial uses.
• Develop a sustainable, low carbon waste management system that processes collected
waste within California and generates jobs, especially in disadvantaged communities.
• Maximize recycling and diversion from landfills.
• Reduce direct emissions from composting and digestion operations through improved technologies.
• Build the infrastructure needed to support a sustainable, low
carbon waste management system within California.
• Increase organics markets which complement and support other sectors.220
• Capture edible food before it enters the waste stream and provide to people in need.• Increase production of renewable transportation fuels from anaerobic digestion of waste.• Recognize the co-benefits of compost application.
Cross-Sector Interactions
The waste management sector interacts with all of the other sectors of the State’s economy. Reducing
waste, including food waste, is key to reducing the State’s overall carbon footprint. Additionally, replacing
virgin materials with recycled materials reduces the energy and GHGs associated with the goods we
produce and consume.
California leads the United States in agricultural production in terms of value and crop diversity. Soil carbon
is the main source of energy for important soil microbes and is key for making nutrients available to plants.
Waste-derived compost and other organic soil amendments support the State’s Healthy Soils Initiative being
implemented by CDFA. In addition, the use of compost to increase soil organic matter in the agricultural
sector provides other benefits, including reduced GHG emissions, conserved water, reduced synthetic
(petroleum-based) fertilizer and herbicide use, and sequestered carbon.
220 Examples may include renewable energy (biogas to renewable transportation fuels or electricity); soils (application of organics to agricultural soils for building soil organic matter and conserving water; application of organics to mulch for erosion control; application of organics to rangelands for increased carbon sequestration); and forests (support use of forest residues for erosion control; stabilization of fire-ravaged lands).
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Efforts to Reduce Greenhouse Gases
The measures below include some required and new potential measures to help achieve the State’s 2030 target and to support the high-level objectives for this sector. Some measures may be designed to directly
address GHG reductions, while others may result in GHG reductions as a co-benefit. In addition, to move
forward with the goals of the waste management sector and achieve the 2030 target, certain actions are
recommended to help set the groundwork. These actions affect several broad areas and are necessary for
reducing the challenges facing this sector, and they are listed below as supporting actions.
Ongoing and Proposed Measures
• Continue implementation of the Landfill Methane Control Measure.
• Continue implementation of the Mandatory Commercial Recycling Regulation
and the Mandatory Commercial Organics Recycling requirements.
• As required by SB 1383:
• By 2018, CARB will implement the SLCP Strategy.
• CalRecycle will develop regulations to require 50 percent organic waste diversion from
landfills from 2014 levels by 2020 and 75 percent by 2025, including programs to achieve an
edible food waste recovery goal of 20 percent below 2016 levels by 2025. The regulations
shall take effect on or after January 1, 2022. By July 1, 2020, analyze the progress that the
waste sector, State government, and local governments have made in achieving these goals.
• CEC will develop recommendations for the development and use of renewable gas as part of the 2017 Integrated Energy Policy Report. Based on these recommendations, adopt policies and incentives to significantly increase sustainable production and use of renewable gas.
Potential Additional or Supporting Actions
The actions below have the potential to reduce GHGs and complement the measures and policies identified in Chapter 2. These are included to spur thinking and exploration of innovation that may help the State
achieve its long-term climate goals.
• Establishing a sustainable State funding source (such as an increased landfill tip fee and new generator charge) for development of waste management infrastructure, programs, and incentives.
• Working with residents and producers to reduce the volume of waste generated overall
and capitalize on technology and social changes that might enable waste reduction.
• Increasing organics diversion from landfills, building on established mandates (AB 341’s
75 percent by 2020 solid waste diversion goal, AB 1594,221 AB 1826,222 AB 876223) and new
short-lived climate pollutant targets for 2025 (SB 605, SB 1383) to be accomplished via
prevention (including food rescue), recycling, composting/digestion, and biomass options.
• Addressing challenges and issues associated with significant expansion and
construction of organics and recycling infrastructure in California that is needed
to achieve recycling and diversion goals. Challenges and issues include permitting,
grid/pipeline connection, funding, local siting, markets, and research.• Developing programmatic Environmental Impact Reports (EIRs) and model permit and guidance documents to assist in environmental review and CEQA for new facilities.
• Providing incentives for expanded and new facilities to handle
organics and recyclables to meet 2020 and 2030 goals.
• Providing incentives to develop and expand food rescue programs to
reduce the amount of edible food being sent to landfills.
• Further quantifying co-benefits of compost products and addressing regulatory
barriers that do not provide for consideration of co-benefits.
• Supporting existing and new clean technologies and markets for excess
woody biomass from urban areas, forests, and agriculture.
• Supporting the development of transportation fuel production at
digestion facilities to generate renewable transportation fuels.
221 Assembly Bill 1594, Waste Management (Williams, Chapter 719, Statutes of 2014).222 Assembly Bill 1826, Solid Waste: Organic Waste (Chesbro, Chapter 727, Statutes of 2014).223 Assembly Bill 876, Compostable Organics (McCarty, Chapter 593, Statutes of 2015).
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• Resolving issues of pipeline injection and grid connection to
make renewable energy projects competitive.
• Supporting the use of available capacity at wastewater treatment
plants that have digesters to process food waste.
• Working with local entities to provide a supportive framework to advance
community-wide efforts that are consistent with, or exceed, statewide goals.
• Supporting research and development and pathways to market for dairy and
codigestion digesters, including pipeline injection and interconnection.
• Supporting research on digestate characterization and end products.
Water
Water is essential to all life, and is vital to our overall health and well-being. A reliable, clean, and abundant
supply of water is also a critical component of California’s economy and has particularly important
connections to energy, food, and the environment. California’s water system includes a complex infrastructure
that has been developed to support the capture, use, conveyance, storage, conservation, and treatment of water and wastewater. This elaborate network of storage and delivery systems enables the State to prosper and support populations, amidst wide variability in annual precipitation rates and concentration of rain north of Sacramento, through storing and moving water when and where it is needed.
Local water agencies play an important role in delivering water to communities, farms, and businesses. Some purchase water from the major State and federal projects, treat the water as needed, and deliver it to their customers; others act as wholesale agencies that buy or import water and sell it to retail water suppliers.
Some agencies operate their own local water supply systems, including reservoirs and canals that store
and move water as needed. Many agencies rely on groundwater exclusively, and operate local wells and
distribution systems. In recent decades, local agencies have developed more diversified sources of water
supplies. Many agencies use a combination of imported surface water and local groundwater, and also
produce or purchase recycled water for end uses such as landscape irrigation.224
The State’s developed surface and groundwater resources support a variety of residential, commercial,
industrial, and agricultural activities. California’s rapidly growing population–estimated to reach 44 million by
2030225 – is putting mounting pressure on the water supply system. In the future, the ability to meet most new
demand for water will come from a combination of increased conservation and water use efficiency, improved
coordination of management of surface and groundwater, recycled water, new technologies in drinking water
treatment, groundwater remediation, and brackish and seawater desalination.226
One of the State’s largest uses of energy is attributed to several aspects of the water life cycle, including end
uses such as heating and cooling, and water treatment and conveyance. Ten percent of the State’s energy
use is associated with water-related end uses, while water and wastewater systems account for 2 percent
of the State’s energy use.227 Therefore, as water demand grows, energy demand may increase concurrently. Population growth drives demand for both water and energy resources, so both grow at about the same rates and in many of the same geographic areas.228 This dynamic is further exacerbated by the precipitation-population mismatch between Northern and Southern California. Since the greatest energy consumption
related to water is from delivery to end uses, the potential for energy savings also resides with water end
users, where water conservation and efficiency play an important role.
The principal source of GHG emissions from the water sector comes from the fossil fuel-based energy
consumed for water end uses (e.g., heating, cooling, pressurizing, and industrial processes), and the fossil
fuel-based energy used to “produce” water (e.g., pump, convey, treat). Therefore, emissions reductions
strategies are primarily associated with reducing the energy intensity of the water sector. Energy intensity is
a measure of the amount of energy required to take a unit of water from its origin (such as a river or aquifer)
224 California Department of Water Resources. Regional Energy Intensity of Water Supplies. www.water.ca.gov/climatechange/RegionalEnergyIntensity.cfm225 http://www.dof.ca.gov/Forecasting/Demographics/projections/ 226 California Natural Resources Agency, California Department of Food and Agriculture, and California Environmental Protection Agency. California Water Action Plan.227 California Department of Water Resources. Water-Energy Nexus: Statewide. Web page accessed November 2016 at: www.water.ca.gov/climatechange/WaterEnergyStatewide.cfm.228 Ibid
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and extract and convey it to its end use.229 Within California, the energy intensity of water varies greatly
depending on the geography, water source, and end use. The California Department of Water Resources
(DWR) subdivides the State into 10 regions corresponding to the State’s major drainage basins. An interactive
map on the DWR website allows users to see a summary of the energy intensity of regional water supplies,
ignoring end-use factors.230 As the energy sector is decarbonized through measures such as increased
renewable energy and improved efficiency, energy intensities will also be reduced. It is also important to
note that end user actions to reduce water consumption or replace fresh water with recycled water do not
automatically translate into GHG reductions. The integrated nature of the water supply system means that
a reduction by one end user can be offset by an increase in consumption by another user. Likewise, use of
recycled water has the potential to reduce GHGs if it replaces, and not merely serves as an alternative to, an existing, higher-carbon water supply.
The State is currently implementing several targeted, agricultural, urban, and industrial-based water
conservation, recycling, and water use efficiency programs as part of an integrated water management effort that will help achieve GHG reductions through reduced energy demand within the water sector. Appendix H highlights the more significant existing policies, programs, measures, regulations, and initiatives that provide a framework for helping achieve GHG emissions reductions in this sector.
While it is important for every sector to contribute to the State’s climate goals, ensuring universal access to clean water as outlined in AB 685 (Eng, Chapter 524, Statutes of 2012), also known as the “human right to water” bill, should take precedence over achieving GHG emissions reductions from water sector activities
where a potential conflict exists. AB 685 states that it is the policy of the State that “every human being has
the right to safe, clean, affordable, and accessible water adequate for human consumption, cooking, and
sanitary purposes.” As described in this section, water supplies vary in energy intensity and resulting GHGs,
depending on the source of the water, treatment requirements, and location of the end user.
Looking to the Future
This section outlines the high-level objectives and goals to reduce GHGs in this sector.
Goals
• Develop and support more reliable water supplies for people, agriculture, and the
environment, provided by a more resilient, diversified, sustainably managed water
resources system with a focus on actions that provide direct GHG reductions.
• Make conservation a California way of life by using and reusing water more efficiently
through greater water conservation, drought tolerant landscaping, stormwater capture, water
recycling, and reuse to help meet future water demands and adapt to climate change.
• Develop and support programs and projects that increase water sector energy efficiency and reduce GHG emissions through reduced water and energy use.• Increase the use of renewable energy to pump, convey, treat, and utilize water.• Reduce the carbon footprint of water systems and water uses for both surface and
groundwater supplies through integrated strategies that reduce GHG emissions while
meeting the needs of a growing population, improving public safety, fostering environmental
stewardship, aiding in adaptation to climate change, and supporting a stable economy.
Cross-Sector Interactions
Water, energy, food, and ecosystems are inextricably linked, and meeting future climate challenges will
require an integrated approach to managing the resources in these sectors.
Water is used in various applications in the energy sector, ranging in intensity from cooling of turbines and other
equipment at power plants to cleaning solar photovoltaic panels. In 2003, CEC adopted a water conservation
policy for power plants to limit the use of freshwater for power plant cooling, and has since encouraged project
229 A broader definition of energy intensity could consider the “downstream” energy (i.e., wastewater treatment) as well as the upstream components. More robust data are needed, and the State is working to better quantify these upstream and downstream emissions.230 California Department of Water Resources. Regional Energy Intensity of Water Supplies. www.water.ca.gov/climatechange/RegionalEnergyIntensity.cfm
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owners proposing to build new power plants in California to reduce water consumption with water-efficiency
technologies such as dry cooling and to conserve fresh water by using recycled water. Likewise, energy is used
in multiple ways and at multiple steps in water delivery and treatment systems, including energy for heating and
chilling water; treating and delivering drinking water; conveying water; extracting groundwater; desalination;
pressurizing water for irrigation; and wastewater collection, treatment, and disposal.
Although GHG reduction strategies for the water sector have the closest ties to energy, the water sector also
interacts with the natural and working lands, agricultural, waste management, and transportation sectors.
Water flows from mountains to downstream regions through natural and working lands, which provide habitat
for many species and function to store water, recharge groundwater, naturally purify water, and moderate
flooding. Protection of key lands from conversion results in healthier watersheds by reducing polluted
runoff and maintaining a properly functioning ecosystem. California is the United States’ leading agricultural
production state in terms of value and crop diversity. Approximately nine million acres of farmland in
California are irrigated.231 In addition, water use is associated with livestock watering, feedlots, dairy operations, and other on-farm needs. Altogether, agriculture uses about 40 percent of the State’s managed water supply.232 In the end, agricultural products produced in California are consumed by humans throughout the world as food, fiber, and fuel. Wastewater treatment plants provide a complementary opportunity for
the waste management sector to help process organic waste diversion from landfills. Treatment plants with
spare capacity can potentially accommodate organic waste for anaerobic co-digestion of materials such as
food waste and fats, oil, and grease from residential, commercial, or industrial facilities to create useful by-
products such as electricity, hydrogen, biofuels, and soil amendments.233 The water sector is also essential to
our community health and long-term well-being, and measures must ensure that we continue to have access
to clean and reliable sources of drinking water. Climate change threatens to impact our water supplies, for
example, with long-term droughts leading to wells and other sources of water running dry. This can have
devastating consequences, especially on communities already vulnerable and sensitive to changes in their
water supply and natural hydrological systems, including rural communities who have limited options for water supplies. Water conservation and management strategies that are energy efficient can also ensure a continued supply of water for our health and well-being.
Efforts to Reduce Greenhouse Gases
The measures below include some required and new potential measures to help achieve the State’s 2030 target and to support the high-level objectives for this sector. Some measures may be designed to directly
address GHG reductions, while others may result in GHG reductions as a co-benefit. In addition, several
recommended actions are identified to help the water sector move forward with the identified goals and
measures to achieve the 2030 target; these are listed as supporting actions.
Ongoing and Proposed Measures
• As directed by Governor Brown’s Executive Order B-37-16, DWR and State Water Resources Control Board (SWRCB) will develop and implement new water use targets to generate
more statewide water conservation than existing targets (the existing State law requires
a 20 percent reduction in urban per capita water use by 2020 [SBx7-7, Steinberg, Chapter
4, Statutes of 2009]). The new water use targets will be based on strengthened standards
for indoor use, outdoor irrigation, commercial, industrial, and institutional water use.
• SWRCB will develop long-term water conservation regulation, and
permanently prohibit practices that waste potable water.
• DWR and SWRCB will develop and implement actions to minimize water system leaks, and to set
performance standards for water loss, as required by SB 555 (Wolk, Chapter 679, Statutes of 2015).
• DWR and CDFA will update existing requirements for agricultural water management plans to increase water system efficiency.
231 Hanson, Blaine. No date. Irrigation of Agricultural Crops in California. PowerPoint. Department of Land, Air and Water Resources University of California, Davis. www.arb.ca.gov/fuels/lcfs/workgroups/lcfssustain/hanson.pdf232 Applied water use is the official terminology used by DWR. “Applied water refers to the total amount of water that is diverted from any source to meet the demands of water users without adjusting for water that is used up, returned to the developed supply, or considered irrecoverable.”233 An example of a resource recovering project that can help achieve methane reductions includes fuel cells that are integrated into wastewater treatment plants for both onsite heat and power generation and the production of renewable hydrogen.
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• CEC will certify innovative technologies for water conservation and water loss detection and control.
• CEC will continue to update the State’s Appliance Efficiency Regulations (California Code of
Regulations, Title 20, Sections 1601–1608) for appliances offered for sale in California to establish
standards that reduce energy consumption for devices that use electricity, gas, and/or water.
• California Environmental Protection Agency (CalEPA) will oversee development
of a voluntary registry for GHG emissions resulting from the water-energy
nexus, as required by SB 1425 (Pavley, Chapter 596, Statutes of 2016).
• The State Water Project has entered long-term contracts to procure
renewable electricity from 140 MW solar installations in California.
• As described in its Climate Action Plan, DWR will continue to increase the use of renewable energy to operate the State Water Project.
Overall, these actions will contribute to the broader energy efficiency goals discussed in the Low Carbon
Energy section of this chapter.
Potential Additional or Supporting Actions
The actions below have the potential to reduce GHGs and complement the measures and policies identified
in Chapter 2. These are included to spur thinking and exploration of innovation that may help the State
achieve its long-term climate goals.
• Where technically feasible and cost-effective, local water and wastewater utilities should adopt a
long-term goal to reduce GHGs by 80 percent below 1990 levels by 2050 (consistent with
DWR’s Climate Action Plan), and thereafter move toward low carbon or net-zero carbon
water management systems.
• Local water and wastewater utilities should develop distributed renewable energy where feasible, using the expanded Local Government Renewable Energy Bill Credit (RES-BCT) tariff and new Net Energy Metering (which allow for installation without system size limit).• In support of the Short-Lived Climate Pollutant Strategy, encourage resource recovering
wastewater treatment projects to help achieve the goal of reducing fugitive methane
by 40 percent by 2030, to include:
• Determining opportunities to support co-digestion of food-related waste
streams at wastewater treatment plants.
• Incentivizing methane capture systems at wastewater treatment plants to
produce renewable electricity, transportation fuel, or pipeline biomethane.
• Support compact development and land use patterns, and associated conservation
and management strategies for natural and working lands that reduce per capita water
consumption through more water-efficient built environments.
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Meeting, and exceeding, our mandated GHG reduction goals in 2020 and through 2030 requires building
on California’s decade of success in implementing effective climate policies. State agencies are increasingly
coordinating planning activities to align with overarching climate, clean air, social equity, and broader
economic objectives.
However, to definitely tip the scales in favor of rapidly declining emissions, we also need to reach beyond
State policy-making and engage all Californians. Further progress can be made by supporting innovative
actions at the local level–among governments, small businesses, schools, and individual households. Ultimately, success depends on a mix of regulatory program development, incentives, institutional support, and education and outreach to ensure that clean energy and other climate strategies are clear, winning alternatives in the marketplace–to drive business development and consumer adoption.
Ongoing Engagement with Environmental
Justice Communities
CARB continues seek ways to improve implementation of AB 32 and the unique set of impacts facing environmental justice communities. However, CARB’s environmental justice efforts reach far beyond climate change. In 2001, the Board approved CARB’s “Policies and Actions for Environmental Action,”234 which
expresses a broad commitment to environmental justice and makes it integral to all of CARB’s programs,
consistent with State directives at the time. Though over the years CARB has taken on a wide array of
activities aimed at reducing environmental burdens on environmental justice communities, it has not knitted
its various efforts together in a coherent narrative or maximized the impact of these activities by leveraging
them off of each other.
This year, CARB appointed its first executive-level environmental justice liaison. Under her leadership,
CARB will lay a roadmap for better serving California’s environmental justice communities in the design and
implementation of its programs, and identifying new actions CARB can take to advance environmental justice
and social equity in all of its functions.
The extensive legislative framework addressing climate change, air quality, and environmental justice that
has emerged since the passage of AB 32 has prompted CARB to step up its environmental justice efforts and
articulate a vision that reflects the current context. CARB will initiate a public process, seeking advice and
input from environmental justice advocates and other key stakeholders to inform the development of a new
strategic plan for further institutionalizing environmental justice and social equity.
CARB understands that in addition to our programs to address climate change and reduce emissions of
GHGs, more needs to be done to reduce exposure to toxic air and criteria pollutants and improve the
quality of life in communities surrounding our largest emissions sources. To this end, and consistent with
AB 617, AB 197, AB 1071, SB 535 and AB 1550, we will actively engage EJ advocates, communities, and relevant air districts in the development of programs that improve air quality and quantify the burdens placed on air quality in local communities. Measuring and monitoring air quality conditions over time and ongoing community engagement are integral to the success of CARB’s efforts. This engagement will include
substantive discussions with EJ stakeholders, gathering their input and providing adequate time for review
before matters are taken to the Board for decision.
234 www.arb.ca.gov/ch/programs/ej/ejpolicies.pdf
Chapter 5
a ch I ev I ng S ucce SS
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CARB’s approach to environmental justice will be grounded in five primary pillars: transparency, integration,
monitoring, research, and enforcement.
• Transparency: CARB must improve communication and engagement with environmental justice stakeholders and deepen partnerships with local communities impacted by air
pollution. CARB will continue to prioritize transparency in its decision-making processes and
provide better access to the air quality, toxics, and GHG data CARB collects and stewards.
• Integration: Besides integrating environmental justice throughout all of CARB’s programs, those
programs must complement each other. To that end, CARB will endeavor to break down
programmatic silos so that it is able to leverage its work and achieve more effective and timely results.
Focused resources in individual communities can accelerate reduction in emissions, proliferation of
clean vehicles and creation of jobs in the clean energy economy, while concurrently
improving public health.
• Monitoring: Communities should be engaged in CARB’s monitoring work. They can play a critical role in collecting their own data and adding to the coverage of other air monitoring efforts (e.g., CARB, local air districts). CARB has already invested in research on low- cost monitors that are accessible by communities, and it will continue to evaluate
how community monitoring can make CARB more nimble in identifying and addressing
“hotspots.” Mobile monitoring projects similarly will allow CARB to better serve and protect
residents of disadvantaged communities. CARB will continue to build partnerships with
local communities and help build local capacity through funding and technical assistance.
• Research: CARB’s research agenda is core to achieving its mission. To ensure that the research
done by CARB responds to environmental justice concerns and has the greatest potential to improve
air quality and public health in disadvantaged communities, CARB will engage communities groups
early in the development of its research agenda and the projects that flow out from that agenda.
• Enforcement: Disadvantaged communities are often impacted by many sources of pollution. In order to improve air quality and protect public health, CARB will prioritize compliance with legal requirements, including enforcement actions if necessary, in environmental justice communities to ensure emissions of toxic and criteria pollutants in these communities are as low as possible.
Our inclusive approaches to further environmental justice in California’s local communities may include an array of direct regulation, funding, and community capacity-building. CARB will continue to actively implement the provisions of AB 617, AB 197, AB 1071, SB 535, AB 1550, and other laws to better ensure
that environmental justice communities see additional benefits from our clean air and climate policies. Our
inclusive approaches to further environmental justice in California’s local communities may include an array of
direct regulation, funding, and community capacity-building.
Enabling Local Action
Local governments are essential partners in achieving California’s goals to reduce GHG emissions. Local governments can implement GHG emissions reduction strategies to address local conditions and issues and can effectively engage citizens at the local level. Local governments also have broad jurisdiction,
and sometimes unique authorities, through their community-scale planning and permitting processes,
discretionary actions, local codes and ordinances, outreach and education efforts, and municipal operations.
Further, local jurisdictions can develop new and innovative approaches to reduce GHG emissions that can
then be adopted elsewhere. For example, local governments can develop land use plans with more efficient
development patterns that bring people and destinations closer together in more mixed-use, compact
communities that facilitate walking, biking, and use of transit. Local governments can also incentivize
locally generated renewable energy and infrastructure for alternative fuels and electric vehicles, implement
water efficiency measures, and develop waste-to-energy and waste-to-fuel projects. These local actions
complement statewide measures and are critical to supporting the State’s efforts to reduce emissions. Local efforts can deliver substantial additional GHG and criteria emissions reductions beyond what State policy can alone, and these efforts will sometimes be more cost-effective and provide more cobenefits than relying exclusively on top-down statewide regulations to achieve the State’s climate stabilization goals. To ensure
local and regional engagement, it is also recommended local jurisdictions make readily available information
regarding ongoing and proposed actions to reduce GHGs within their region.
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Many cities and counties are already setting GHG reduction targets, developing local plans, and making
progress toward reducing emissions. The Statewide Energy Efficiency Collaborative recently released a report,
The State of Local Climate Action: California 2016,235 which highlights local government efforts, including:
• In California, 60 percent of cities and over 70 percent of counties have completed a
GHG inventory, and 42 percent of local governments have completed a climate, energy,
or sustainability plan that directly addresses GHG emissions. Many other community-scale
local plans, such as general plans, have emissions reduction measures incorporated as well
(see Governor’s Office of Planning and Research [OPR] Survey questions 23 and 24).236
• Over one hundred California local governments have developed emissions
reduction targets that, if achieved, would result in annual reductions that total 45 MMTCO2e by 2020 and 83 MMTCO2e by 2050.237
Local air quality management and air pollution control districts also play a key role in reducing regional and
local sources of GHG emissions by actively integrating climate protection into air quality programs. Air districts also support local climate protection programs by providing technical assistance and data, quantification tools, and even funding.238 Local metropolitan planning organizations (MPOs) also support the State’s climate action goals via sustainable communities strategies (SCSs), required by the Sustainable
Communities and Climate Protection Act of 2008 (SB 375, Chapter 728, Statutes of 2008). Under SB 375,
MPOs must prepare SCSs as part of their regional transportation plan to meet regional GHG reduction
targets set by CARB for passenger vehicles in 2020 and 2035. The SCSs contain land use, housing, and
transportation strategies that allow regions to meet their GHG emissions reductions targets.
State agencies support these local government actions in several ways:
• CoolCalifornia.org is an informational website that provides resources that assist local governments,
small businesses, schools, and households to reduce GHG emissions. The local government webpage
includes carbon calculators, a climate planning resource guide, a Funding Wizard that outlines grant
and loan programs, and success stories. It also features ClearPath California, a no-cost GHG inventory, climate action plan development, and tracking tool developed through the Statewide Energy Efficiency Collaborative in coordination with CARB and the Governor’s Office of Planning and Research (OPR).
• Chapter 8 of OPR’s General Plan Guidelines239 provides guidance for climate action plans and
235 Statewide Energy Efficiency Collaborative. 2016. State of Local Climate Action: California 2016. californiaseec.org/wp-content/uploads/2016/10/State-of-Local-Climate-Action-California-2016_Screen.pdf236 Governor’s Office of Planning and Research. 2016. 2016 Annual Planning Survey Results. November. www.opr.ca.gov/docs/2016_APS_final.pdf237 These reductions include reductions from both state and local measures.238 Examples include: (1) Bay Area Air Quality Management District (BAAQMD). 2016 Clean Air Plan and Regional Climate Protection Strategy. Available at: www.baaqmd.gov/plans-and-climate/air-quality-plans/plans-under-development; (2) California Air Pollution Control Officers Association. California Emissions Estimator Model (CalEEMod). Available at: www.caleemod.com/; (3) San Joaquin Valley Air Pollution Control District. Grants and Incentives. Available at: valleyair.org/grants/; (4) BAAQMD. Grant Funding. Available at: www.baaqmd.gov/grant-funding; (5) South Coast Air Quality Management District. Funding. Available at: www.aqmd.gov/
grants-bids/funding; (6) Sacramento Metropolitan Air Quality Management District. Incentive Programs. Available at: www.airquality.org/Residents/Incentive-Programs.239 http://opr.ca.gov/planning/general-plan/
To engage communities in efforts to reduce GHG emissions,
CARB has partnered with Energy Upgrade California on the
CoolCalifornia Challenge. It is a competition among California
cities to reduce their carbon footprints and build more vibrant and sustainable communities. Three challenges have been completed. Most recently, the 2015–2016 Challenge included 22 cities and engaged nearly 3,200 households, each of which took actions to reduce energy use and carbon GHG emissions. In total, the
participants reported savings of 5,638 MTCO2 from completed
actions, equivalent to emissions from more than 1,000 cars or from
electricity used by more than 2,500 California homes in a year.
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other plans linked to general plans, which address the community scale approach outlined in
CEQA Guidelines Section 15183.5(b), Plans for the Reduction of Greenhouse Gas Emissions.
• OPR hosts the Integrated Climate Adaptation and Resiliency Program, which is
developing resources and case studies that outline the co-benefits of implementing
emissions reduction strategies and addressing the impacts of climate change.
• CARB is developing a centralized database and interactive map that will display the current statewide
status of local government climate action planning. Users can view and compare the details of
emission inventories, planned GHG reduction targets and strategies, and other climate action details
specific to each local government. This information will help jurisdictions around
California identify what climate action strategies are working in other, similar jurisdictions across the State, and will facilitate collaboration among local governments pursuing GHG reduction strategies and goals. This database and map will be featured on the CoolCalifornia.org website and are anticipated to be available in 2017.
• Additional information on local government activities is available on
Cal-Adapt (www.cal-adapt.org) and OPR (www.opr.ca.gov)
Further, a significant portion of the $3.4 billion in cap-and-trade expenditures has either directly or indirectly
supported local government efforts to reduce emissions, including, for example, the Affordable Housing and
Sustainable Communities (AHSC) program and approximately $142 million for project implementation and
planning grants awarded under the Transformative Climate Communities program.
Climate Action through Local Planning and Permitting
Local government efforts to reduce emissions within their jurisdiction are critical to achieving the State’s long-term GHG goals, and can also provide important co-benefits, such as improved air quality, local economic benefits, more sustainable communities, and an improved quality of life. To support local governments in
their efforts to reduce GHG emissions, the following guidance is provided. This guidance should be used
in coordination with OPR’s General Plan Guidelines guidance in Chapter 8, Climate Change.240 While this
guidance is provided out of the recognition that local policy makers are critical in reducing the carbon
footprint of cities and counties, the decision to follow this guidance is voluntary and should not be interpreted
as a directive or mandate to local governments.
Recommended Local Plan-Level Greenhouse Gas Emissions Reduction Goals
CARB recommends statewide targets of no more than six metric tons CO2e per capita by 2030 and no more
than two metric tons CO2e per capita by 2050.241 The statewide per capita targets account for all emissions
sectors in the State, statewide population forecasts, and the statewide reductions necessary to achieve the
2030 statewide target under SB 32 and the longer term State emissions reduction goal of 80 percent below
1990 levels by 2050.242 The statewide per capita targets are also consistent with Executive Order S-3-05,
B-30-15, and the Under 2 MOU that California originated with Baden-Württemberg and has now been signed
or endorsed by 188 jurisdictions representing 39 countries and six continents.243,244 Central to the Under 2
MOU is that all signatories agree to reduce their GHG emissions to two metric tons CO2e per capita by 2050.
This limit represents California’s and these other governments’ recognition of their “fair share” to reduce GHG emissions to the scientifically based levels to limit global warming below two degrees Celsius. This limit is also consistent with the Paris Agreement, which sets out a global action plan to put the world on track to avoid dangerous climate change by limiting global warming to below 2°C.245
CARB recommends that local governments evaluate and adopt robust and quantitative locally-appropriate
240 http://opr.ca.gov/planning/general-plan/ . 241 These goals are appropriate for the plan level (city, county, subregional, or regional level, as appropriate), but not for specific individual projects because they include all emissions sectors in the State. 242 This number represents the 2030 and 2050 targets divided by total population projections from California Department of Finance.243 http://under2mou.org/ California signed the Under 2 MOU on May 19, 2015. See under2mou.org/wp-content/uploads/2015/05/
California-appendix-English.pdf and under2mou.org/wp-content/uploads/2015/05/California-Signature-Page.pdf.244 The Under 2 MOU signatories include jurisdictions ranging from cities to countries to multiple-country partnerships. Therefore, like the goals set forth above for local and regional climate planning, the Under 2 MOU is scalable to various types of jurisdictions.245 UNFCCC. The Paris Agreement. unfccc.int/paris_agreement/items/9485.php
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goals that align with the statewide per capita targets and the State’s sustainable development objectives
and develop plans to achieve the local goals. The statewide per capita goals were developed by applying
the percent reductions necessary to reach the 2030 and 2050 climate goals (i.e., 40 percent and 80 percent,
respectively) to the State’s 1990 emissions limit established under AB 32.
Numerous local governments in California have already adopted GHG emissions reduction goals for year
2020 consistent with AB 32. CARB advises that local governments also develop community-wide GHG
emissions reduction goals necessary to reach 2030 and 2050 climate goals. Emissions inventories and
reduction goals should be expressed in mass emissions, per capita emissions, and service population
emissions. To do this, local governments can start by developing a community-wide GHG emissions target
consistent with the accepted protocols as outlined in OPR’s General Plan Guidelines Chapter 8: Climate
Change. They can then calculate GHG emissions thresholds by applying the percent reductions necessary
to reach 2030 and 2050 climate goals (i.e., 40 percent and 80 percent, respectively) to their community-wide
GHG emissions target. Since the statewide per capita targets are based on the statewide GHG emissions inventory that includes all emissions sectors in the State, it is appropriate for local jurisdictions to derive evidence-based local per capita246 goals based on local emissions sectors and population projections that are consistent with the framework used to develop the statewide per capita targets. The resulting GHG emissions
trajectory should show a downward trend consistent with the statewide objectives. The recommendation for
a community-wide goal expands upon the reduction of 15 percent from “current” (2005-2008) levels by 2020
as recommended in the 2008 Scoping Plan.247
In developing local plans, local governments should refer to “The U.S. Community Protocol for Accounting
and Reporting of Greenhouse Gas Emissions,”248 (community protocol) which provides detailed guidance on
completing a GHG emissions inventory at the community scale in the United States – including emissions
from businesses, residents, and transportation. Quantification tools such as ClearPath California, which was
developed with California agencies, also support the analysis of community-scale GHG emissions. Per the
community protocol, these plans should disclose all emissions within the defined geographical boundary,
even those over which the local government has no regulatory authority to control, and then focus the
strategies on those emissions that the jurisdiction controls. For emissions from transportation, the community
protocol recommends including emissions from trips that extend beyond the community’s boundaries. Local plans should also include the carbon sequestration values associated with natural and working lands, and the importance of jurisdictional lands for water, habitat, agricultural, and recreational resources. Strategies developed to achieve the local goals should prioritize mandatory measures that support the Governor’s “Five
Pillars” and other key state climate action goals.249 Examples of plan-level GHG reduction actions that could
be implemented by local governments are listed in Appendix B. Additional information and tools on how to
develop GHG emissions inventories and reduction plans tied to general plans can be found in OPR’s General
Plan Guidelines and at CoolCalifornia.org.
These local government recommendations are based on the recognition that California must accommodate
population and economic growth in a far more sustainable manner than in the past. While state-level
investments, policies, and actions play an important role in shaping growth and development patterns,
regional and local governments and agencies are uniquely positioned to influence the future of the built
environment and its associated GHG emissions. Greenhouse gas emissions reduction strategies in Climate
Action Plans (CAPs) and other local plans can also lead to important co-benefits, such as improved air quality,
local economic benefits such as green jobs, more mobility choices, improved public health and quality of
life, protection of locally, statewide, and globally important natural resources, and more equitable sharing of these benefits across communities.
Contributions from policies and programs, such as renewable energy and energy efficiency, are helping to
achieve the near-term 2020 target, but longer-term targets cannot be achieved without land use decisions that allow more efficient use and management of land and infrastructure. Local governments have primary authority to plan, zone, approve, and permit how and where land is developed to accommodate population growth, economic growth, and the changing needs of their jurisdictions. Land use decisions affect GHG
emissions associated with transportation, water use, wastewater treatment, waste generation and treatment,
energy consumption, and conversion of natural and working lands. Local land use decisions play a particularly
246 Or some other metric that the local jurisdiction deems appropriate (e.g., mass emissions, per service population)247 2008 Scoping Plan, page 27, www.arb.ca.gov/cc/scopingplan/document/scopingplandocument.htm248 http://icleiusa.org/publications/us-community-protocol/249 www.arb.ca.gov/cc/pillars/pillars.htm
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critical role in reducing GHG emissions associated with the transportation sector, both at the project level,
and in long-term plans, including general plans, local and regional climate action plans, specific plans,
transportation plans, and supporting sustainable community strategies developed under SB 375.
While the State can do more to accelerate and incentivize these local decisions, local actions that reduce VMT
are also necessary to meet transportation sector-specific goals and achieve the 2030 target under SB 32.
Through developing the Scoping Plan, CARB staff is more convinced than ever that, in addition to achieving
GHG reductions from cleaner fuels and vehicles, California must also reduce VMT. Stronger SB 375 GHG
reduction targets will enable the State to make significant progress toward needed reductions, but alone
will not provide the VMT growth reductions needed; there is a gap between what SB 375 can provide and
what is needed to meet the State’s 2030 and 2050 goals. In its evaluation of the role of the transportation
system in meeting the statewide emissions targets, CARB determined that VMT reductions of 7 percent
below projected VMT levels in 2030 (which includes currently adopted SB 375 SCSs) are necessary. In 2050,
reductions of 15 percent below projected VMT levels are needed. A 7 percent VMT reduction translates to a reduction, on average, of 1.5 miles/person/day from projected levels in 2030. It is recommended that local governments consider policies to reduce VMT to help achieve these reductions, including: land use and community design that reduces VMT; transit oriented development; street design policies that prioritize
transit, biking, and walking; and increasing low carbon mobility choices, including improved access to viable
and affordable public transportation and active transportation opportunities. It is important that VMT
reducing strategies are implemented early because more time is necessary to achieve the full climate, health,
social, equity, and economic benefits from these strategies.
Once adopted, the plans and policies designed to achieve a locally-set GHG goal can serve as a performance
metric for later projects. Sufficiently detailed and adequately supported GHG reduction plans (including
CAPs) also provide local governments with a valuable tool for streamlining project-level environmental review.
Under CEQA, individual projects that comply with the strategies and actions within an adequate local CAP
can streamline the project-specific GHG analysis.250 The California Supreme Court recently called out this
provision in CEQA as allowing tiering from a geographically specific GHG reduction plan.251 The Court also
recognized that GHG determinations in CEQA should be consistent with the statewide Scoping Plan goals,
and that CEQA documents taking a goal-consistency approach may soon need to consider a project’s effects on meeting the State’s longer term post-2020 goals.252 The recommendation above that local governments develop local goals tied to the statewide per capita goals of six metric tons CO2e by 2030 and no more than two metric tons CO2e per capita by 2050 provides guidance on CARB’s view on what would be consistent
with the 2017 Scoping Plan and the State’s long-term goals.
Production based inventories and emissions reduction programs are appropriate for local communities wanting to mitigate their emissions pursuant to CEQA Section 15183.5(b). Consumption based inventories are
complementary to production based inventories and are appropriate as a background setting, disclosure, and
as an outreach tool to show how personal decisions may change a person’s or household’s contribution to
climate change. For additional information, see the OPR General Plan Guidelines.253
Project-Level Greenhouse Gas Emissions Reduction Actions and Thresholds
Beyond plan-level goals and actions, local governments can also support climate action when considering discretionary approvals and entitlements of individual projects through CEQA. Absent conformity with
an adequate geographically-specific GHG reduction plan as described in the preceding section above,
CARB recommends that projects incorporate design features and GHG reduction measures, to the degree
feasible, to minimize GHG emissions. Achieving no net additional increase in GHG emissions, resulting in
no contribution to GHG impacts, is an appropriate overall objective for new development. There are recent
examples of land use development projects in California that have demonstrated that it is feasible to design
projects that achieve zero net additional GHG emissions. Several projects have received certification from
the Governor under AB 900, the Jobs and Economic Improvement through Environmental Leadership Act
(Buchanan, Chapter 354, Statutes of 2011), demonstrating an ability to design economically viable projects
that create jobs while contributing no net additional GHG emissions. 254 Another example is the Newhall
250 CEQA Guidelines, § 15183.5, sub. (b).251 Center for Biological Diversity v. California Dept. of Fish and Wildlife (2015) 62 Cal.4th 204, 229–230.252 Id. at pp. 223–224. 253 http://opr.ca.gov/planning/general-plan/.254 Governor’s Office of Planning and Research. California Jobs. http://www.opr.ca.gov/ceqa/california-jobs.html
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Ranch Resource Management and Development Plan and Spineflower Conservation Plan,255 in which the
applicant, Newhall Land and Farming Company, proposed a commitment to achieve net zero GHG emissions
for a very large-scale residential and commercial specific planned development in Santa Clarita Valley.
Achieving net zero increases in GHG emissions, resulting in no contribution to GHG impacts, may not be
feasible or appropriate for every project, however, and the inability of a project to mitigate its GHG emissions
to net zero does not imply the project results in a substantial contribution to the cumulatively significant
environmental impact of climate change under CEQA. Lead agencies have the discretion to develop
evidence-based numeric thresholds (mass emissions, per capita, or per service population) consistent with
this Scoping Plan, the State’s long-term GHG goals, and climate change science.256
To the degree a project relies on GHG mitigation measures, CARB recommends that lead agencies prioritize
on-site design features that reduce emissions, especially from VMT, and direc t investments in GHG reductions
within the project’s region that contribute potential air quality, health, and economic co-benefits locally. For
example, on-site design features to be considered at the planning stage include land use and community
design options that reduce VMT, promote transit oriented development, promote street design policies that prioritize transit, biking, and walking, and increase low carbon mobility choices, including improved access to viable and affordable public transportation, and active transportation opportunities. Regionally, additional GHG reductions can be achieved through direct investment in local building retrofit programs that can pay
for cool roofs, solar panels, solar water heaters, smart meters, energy efficient lighting, energy efficient
appliances, energy efficient windows, insulation, and water conservation measures for homes within the
geographic area of the project. These investments generate real demand side benefits and local jobs, while
creating the market signals for energy efficient products, some of which are produced in California. Other
examples of local direct investments include financing installation of regional electric vehicle (EV) charging
stations, paying for electrification of public school buses, and investing in local urban forests.
Local direct investments in actions to reduce GHG emissions should be supported by quantification
methodologies that show the reductions are real, verifiable, quantifiable, permanent, and enforceable.
Where further project design or regional investments are infeasible or not proven to be effective, it may
be appropriate and feasible to mitigate project emissions through purchasing and retiring carbon credits.
CAPCOA has developed the GHG Reduction Exchange (GHG Rx) for CEQA mitigation, which could provide
credits to achieve additional reductions. It may also be appropriate to utilize credits issued by a recognized and reputable voluntary carbon registry. Appendix B includes examples of on-site project design features, mitigation measures, and direct regional investments that may be feasible to minimize GHG emissions from land use development projects.
California’s future climate strategy will require increased focus on integrated land use planning to support livable, transit-connected communities, and conservation of agricultural and other lands. Accommodating population and economic growth through travel- and energy-efficient land use provides GHG-efficient
growth, reducing GHGs from both transportation and building energy use.257 GHGs can be further reduced
at the project level through implementing energy-efficient construction and travel demand management
approaches.258 Further, the State’s understanding of transportation impacts continues to evolve. The CEQA
Guidelines are being updated to focus the analysis of transportation impacts on VMT. OPR’s Technical
Advisory includes methods of analysis of transportation impacts, approaches to setting significance
thresholds, and includes examples of VMT mitigation under CEQA.259
255 https://nrm.dfg.ca.gov/documents/ContextDocs.aspx?cat=NewhallRanchFinal256 CARB provided some guidance on development project thresholds in a paper issued in October 2008, which included a concept utilizing a bright-line mass numeric threshold based on capturing approximately 90 percent of emissions in that sector and a concept of minimum performance based standards. Some districts built upon that work to develop thresholds. For example, Santa Barbara County adopted a bright-line numeric threshold of 1,000 MTCO2e/yr for industrial stationary-source projects, and Sacramento Metropolitan Air Quality Management District adopted a 10,000 MTCO2e/yr threshold for stationary source projects and a 1,100 MTCO2e/yr threshold for construction activities and land development projects in their operational phase. CARB is not endorsing any one of these approaches, but noting them for informational purposes.257 Robert Cervero, Jim Murakami; Effects of Built Environment on Vehicle Miles Traveled: Evidence from 370 US Urbanized Areas. Environment and Planning A, Vol 42, Issue 2, pp. 400-418, February-01-2010; Ewing, R., & Rong, F. (2008). The impact of urban form on U.S. residential energy use. Housing Policy Debagte, 19 (1), 1-30.).258 CAPCOA, Quantifying Greenhouse Gas Mitigation Measures: A Resource for Local Government to Assess Emission Reductions from Greenhouse Gas Mitigation Measures, August, 2010.259 http://www.opr.ca.gov/ceqa/updates/sb-743/
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Implementing the Scoping Plan
This Scoping Plan outlines the regulations, programs, and other mechanisms needed to reduce GHG
emissions in California. CARB and other State agencies will work closely with State and local agencies,
stakeholders, Tribes, and the public to develop regulatory measures and other programs to implement
the Scoping Plan. CARB and other State agencies will develop regulations in accordance with established
rulemaking guidelines. Per Executive Order B-30-15, as these regulatory measures and other programs are
developed, building programs for climate resiliency must also be a consideration. Additionally, agencies
will further collaborate and work to provide the institutional support needed to overcome barriers that may
currently hinder certain efforts to reduce GHG emissions and to support the goals, actions, and measures identified for key sectors in Chapter 4. Table 17 provides a high-level summary of the Climate Change Policies and Measures discussed in the Scoping Plan, including, but not limited to, those identified specifically to achieve the 2030 target.
table 17: Climate Change poliCies and measures
Recommended Action Lead Agency
Implement SB 350 by 2030:
• Increase the Renewables Portfolio Standard to 50 percent of retail sales by 2030 and
ensure grid reliability.
• Establish annual targets for statewide energy efficiency savings and demand reduction
that will achieve a cumulative doubling of statewide energy efficiency savings in
electricity and natural gas end uses by 2030.
• Reduce GHG emissions in the electricity sector through the implementation of the
above measures and other actions as modeled in IRPs to meet GHG emissions
reductions planning targets in the IRP process. Load-serving entities and publicly-
owned utilities meet GHG emissions reductions planning targets through a
combination of measures as described in IRPs.
CPUC, CEC, CARB
Implement Mobile Source Strategy (Cleaner Technology and Fuels):
• At least 1.5 million zero emission and plug-in hybrid light-duty electric vehicles by 2025.
• At least 4.2 million zero emission and plug-in hybrid light-duty electric vehicles by 2030.
• Further increase GHG stringency on all light-duty vehicles beyond existing Advanced
Clean Cars regulations.
• Medium- and heavy-duty GHG Phase 2.
• Innovative Clean Transit: Transition to a suite of to-be-determined innovative clean
transit options. Assumed 20 percent of new urban buses purchased beginning in 2018
will be zero emission buses with the penetration of zero-emission technology ramped
up to 100 percent of new sales in 2030. Also, new natural gas buses, starting in 2018,
and diesel buses, starting in 2020, meet the optional heavy-duty low-NOX standard.
• Last Mile Delivery: New regulation that would result in the use of low NOX or cleaner
engines and the deployment of increasing numbers of zero-emission trucks primarily
for class 3-7 last mile delivery trucks in California. This measure assumes ZEVs
comprise 2.5 percent of new Class 3–7 truck sales in local fleets starting in 2020,
increasing to 10 percent in 2025 and remaining flat through 2030.
• Further reduce VMT through continued implementation of SB 375 and regional
Sustainable Communities Strategies; forthcoming statewide implementation of
SB 743; and potential additional VMT reduction strategies not specified in the Mobile
Source Strategy but included in the document “Potential VMT Reduction Strategies
for Discussion.”
CARB, CalSTA, SGC, CalTrans
CEC, OPR, Local agencies
Increase stringency of SB 375 Sustainable Communities Strategy (2035 targets).CARB
By 2019, adjust performance measures used to select and design transportation facilities.
• Harmonize project performance with emissions reductions, and increase
competitiveness of transit and active transportation modes (e.g. via guideline
documents, funding programs, project selection, etc.).
CalSTA and SGC, OPR, CARB, GoBiz,
IBank, DOF, CTC, Caltrans
By 2019, develop pricing policies to support low-GHG transportation (e.g. low-emission
vehicle zones for heavy duty, road user, parking pricing, transit discounts).
CalSTA, Caltrans, CTC, OPR/SGC,
CARB
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Recommended Action Lead Agency
Implement California Sustainable Freight Action Plan:
• Improve freight system efficiency.
• Deploy over 100,000 freight vehicles and equipment capable of zero emission
operation and maximize both zero and near-zero emission freight vehicles and
equipment powered by renewable energy by 2030.
CalSTA, CalEPA, CNRA, CARB,
CalTrans, CEC, GoBiz
Adopt a Low Carbon Fuel Standard with a CI reduction of 18 percent.CARB
Implement the Short-Lived Climate Pollutant Strategy by 2030:
• 40 percent reduction in methane and hydrofluorocarbon emissions below 2013 levels.
• 50 percent reduction in black carbon emissions below 2013 levels.
CARB, CalRecycle, CDFA, SWRCB,
Local air districts
By 2019, develop regulations and programs to support organic waste landfill reduction
goals in the SLCP and SB 1383.
CARB, CalRecycle, CDFA, SWRCB,
Local air districts
Implement the post-2020 Cap-and-Trade Program with declining annual caps.CARB
By 2018, develop Integrated Natural and Working Lands Implementation Plan to secure
California’s land base as a net carbon sink:
• Protect land from conversion through conservation easements and other incentives.
• Increase the long-term resilience of carbon storage in the land base and enhance
sequestration capacity
• Utilize wood and agricultural products to increase the amount of carbon stored in the
natural and built environments
• Establish scenario projections to serve as the foundation for the Implementation Plan
CNRA and departments within, CDFA,
CalEPA, CARB
Establish a carbon accounting framework for natural and working lands as described in SB
859 by 2018 CARB
Implement Forest Carbon Plan CNRA, CAL FIRE, CalEPA and
departments within
Identify and expand funding and financing mechanisms to support GHG reductions across
all sectors.State Agencies & Local Agencies
A Comprehensive Approach to Support Climate Action
Ultimately, successfully tipping the scales in the fight against climate change relies on our ability to incentivize clean technologies in the marketplace and to make other climate strategies clearly understood and easily accessible. We must support and guide our businesses as they continue to innovate and make clean technologies ever more attractive to ever more savvy consumers. Until the point that clean technologies
become the best and lowest cost option–which is clearly on the horizon for many technologies, including
renewable energy and electric cars–we must continue to support emerging markets through incentives
and outreach efforts. More than just coordinating among agencies and providing institutional support as
described above, we will succeed if we tackle climate change from all angles–through regulatory and policy
development, targeted incentives, and education and outreach.
Regulations and Programmatic Development
Our decade of climate leadership has demonstrated that developing mitigation strategies through a public
process, where all stakeholders have a voice, leads to effective actions that address climate change and yield
a series of additional economic and environmental co-benefits to the State. As we implement this Scoping
Plan, State agencies will continue to develop and implement new and existing programs, as described herein.
During any rulemaking process, there are many opportunities for both informal interaction with technical
staff in meetings and workshops, and formal interaction at Board meetings, Commission business meetings,
monthly public meetings, and others. Each State agency will consider all information and stakeholder input
during the rulemaking process. Based on this information, the agency may modify proposed measures
to reflect the status of technological development, the cost of the measure, the cost-effectiveness of the measures, and other factors before presenting them for consideration and adoption.
Further, to achieve cost-effective GHG reductions, California State agencies must consider the environmental
impact of small businesses and provide mechanisms to assist businesses as GHG reduction measures are
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implemented. CARB provides resources and tips for small businesses to prevent pollution, minimize waste,
and save energy and water on CoolCalifornia.org. California’s small businesses and their employees represent
a valuable economic resource in the State and “greening” existing businesses is not only achievable, but sets
an example for new businesses which will prove significant as California transitions to a low carbon state.
State agencies conduct environmental and environmental justice assessments of our regulatory actions.
Many of the requirements in AB 32 overlap with traditional agency evaluations. In adopting regulations to
implement the measures recommended in the Scoping Plan, or including in the regulations the use of market-
based compliance mechanisms to comply with the regulations, agencies will ensure that the measures have
undergone the aforementioned screenings and meet the requirements established in California Health and
Safety Code Section 38562(b)(1-9) and Section 38570(b)(1-3).
Incentive Programs
Financial incentives and direct funding are critical components of the State’s climate framework. In particular,
incentives and funding are necessary to support GHG emissions reductions strategies for priority sectors,
sources, and technologies. Although California has a number of existing incentive programs, available
funding is limited. It is critical to target public investments efficiently and in ways that encourage integrated,
system wide solutions to produce deep and lasting public benefits. Significant investments of private capital,
supported by targeted, priority investments of public funding, are necessary to scale deployment and to
maximize benefits. Public investments, including through decisions related to State pension fund portfolios,
can help incentivize early action to accelerate market transition to cleaner technologies and cleaner practices, which can also be supported by regulatory measures.
Many existing State funding programs work in tandem to reduce emissions from GHGs, criteria pollutants,
and toxic air contaminants, and are helping to foster the transition to a clean energy economy and protect and manage land for carbon sequestration. State law, including Senate Bill 535 (De León, Chapter 830, Statutes of 2012) and Assembly Bill 1550 (Gomez, Chapter 369, Statutes of 2016) also requires focused investment in low income and disadvantaged communities.
The State will need to continue to coordinate and utilize funding sources, such as the Greenhouse Gas Reduction Fund (cap-and-trade auction proceeds), the Alternative and Renewable Fuel and Vehicle Technology Program (AB 118), Electric Program Investment Charge (EPIC) Program, Carl Moyer Program,
Air Quality Improvement Program, and Proposition 39 to expand clean energy investments in California and
further reduce GHG and criteria emissions. Additionally, programs including the Bioenergy Feed-In Tariff,
created by Senate Bill 1122 (Rubio, Chapter 612, Statutes of 2012), Low Carbon Fuel Standard, Cap-and-Trade,
Self-Generation Incentive Program, Federal Renewable Fuel Standard, utility incentives pursuant to Assembly
Bill 1900 (Gatto, Chapter 602, Statutes of 2012), and others provide important market signals and potential
revenue streams to support projects to reduce GHG emissions.
These programs represent just a portion of the opportunities that exist at the federal, State, and local levels
to incentivize GHG emissions reductions. The availability of dedicated and long-lasting funding sources is
critical to help meet the State’s climate objectives and help provide certainty and additional partnership
opportunities at the national, State, Tribal, regional, and local levels for further investing in projects that have
the potential to expand investments in California’s clean economy and further reductions in GHG emissions.
Public Education and Outreach Efforts
California State agencies are committed to meaningful opportunities for public input and effective
engagement with stakeholders and the public through the development of the Scoping Plan, and as
measures are implemented through workshops, other meetings, and through the formal rulemaking process.
Additionally, the State has broad public education and outreach campaigns to support markets for key
technologies, like ZEVs and energy efficiency, as well as resources to support local and voluntary actions, such
as CoolCalifornia.org.
In developing this Scoping Plan, there has been extensive outreach with environmental justice organizations
and disadvantaged communities. The EJAC launched a community engagement process starting in July 2016,
conducting 19 community meetings throughout the State and collecting hundreds of individual comments. To enhance the engagement opportunity, CARB coordinated with local government agencies and sister State agencies to hold collaborative discussions with local residents about specific climate issues that impact their
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lives. This effort was well received and attended by local community residents and initiated a new community
engagement endeavor for CARB. Recognizing the value of the input received and the opportunity to present
California’s climate strategy to communities across the State, CARB intends to continue this community
involvement to generate awareness about California’s climate strategy and be responsive to specific
community needs as climate programs are implemented.
Conclusion
This Scoping Plan continues more than a half-century of California’s nation-leading efforts to clean our air, our water and improve the environment. But, climate change poses a challenge of unprecedented proportions
that will, in one way or another, impact all Californians whether they are city dwellers in Los Angeles, San
Diego or San Francisco, farmers in Salinas or the Central Valley, or the millions of Californians who live in the
Sierra or in the desert areas.
This is the State’s climate action plan, and in a very real sense it belongs to all those Californians who are
feeling, and will continue to feel, the impacts of climate change. Californians want to see continued effective
action that addresses climate change and benefits California – this Plan responds to both of these goals. The
Plan was developed by the coordinated consensus of State agencies, but it is really California’s Plan, because
over the coming decades the approaches in this document will be carried out by all of us.
In this Scoping Plan, every sector in our thriving economy plays a crucial role. Tribes, cities, and local
governments are already rising to the challenge, and will play increasingly important roles with everything from
low-carbon and cleaner transit, to more walkable streets and the development of vibrant urban communities.
We will see a remarkable transformation of how we move throughout the state, away from cars that burn
fossil fuels to cleaner, electric cars that will, in some cases, even drive themselves. Freight will be moved
around the state by trucks that are vastly cleaner than those on the road now, with our ports moving towards
zero- and near-zero emissions technologies. The heavily traveled Los Angeles-San Francisco corridor will be
serviced by comfortable, clean and affordable high speed rail.
In addition to reducing GHGs, these efforts will slash pollution now created from using gasoline and diesel
fuel statewide, with the greatest benefits going to the disadvantaged communities of our state which are
so often located adjacent to ports, railyards, freight distribution centers and freeways. And, thanks to the
continued investment of proceeds from the Cap-and-Trade Program in these same communities, we can
continue to work on bringing the benefits of clean technology – whether electric cars or solar roofs – to those in our state who need them the most.
Climate change presents us with unprecedented challenges – challenges that cannot be met with traditional ways
of thinking or conventional solutions. As Governor Brown has recognized, meeting these challenges will require “courage, creativity and boldness.” The last ten years proved to ourselves, and the world, that Californians recognize the danger of climate change. It has also demonstrated that developing mitigation strategies through a public process where all stakeholders have a voice leads to effective actions that address climate change while
yielding a series of co-benefits to the state. This Scoping Plan builds on those early steps and moves into a new
chapter that will deliver a thriving economy and a clean environment to our children and grandchildren. It is a
commitment to the future, but it begins today by moving forward with the policies in this Plan.
eduCation and environment initiative
The California Environmental Protection Agency (CalEPA), the California
Department of Education, and the California Natural Resources Agency
have developed an environmental curriculum that is being taught in more
than half of California’s school districts. The Education and Environment
Initiative (EEI) provides California’s teachers with tools to educate students
about the natural environment and how everyday choices can improve our
planet and save money.
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a bbrev I at I on S
AB Assembly Bill
AC air conditioning
AEO Annual Energy Outlook
AHSC Affordable Housing and Sustainable Communities
ARFVTP Alternative and Renewable Fuel and Vehicle Technology Program
BARCT best available retrofit control technology
BAU business-as-usual
BC British Columbia
BEV Battery-electric vehicle
CARB California Air Resources Board
CAISO California Independent System Operator
CalEPA California Environmental Protection Agency
CALGreen California Green Building Standards
CalPERS California Public Employees’ Retirement System
CalSTA California State Transportation Agency
CalSTRS California State Teachers’ Retirement System
CAP Climate Action Plan
CARE California Alternate Rates for Energy Program
CDFA California Department of Food and Agriculture
CDPH California Department of Public Health
CEC California Energy Commission
CEQA California Environmental Quality Act
CFT Clean Fuels and Technology
CH4 Methane
CI carbon intensity
CNRA California Natural Resources Agency
CO2 carbon dioxide
CO2e carbon dioxide equivalent
COPD chronic obstructive pulmonary disease
CPUC California Public Utilities Commission
CSI California Solar Initiative
dge diesel gallon equivalent
DWR California Department of Water Resources
EA Environmental Analysis
EEI Education and Environment Initiative
EIR Environmental Impact Report
EJAC Environmental Justice Advisory Committee
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EO Executive Order
EPIC Electric Program Investment Charge Program
F-gases fluorinated gases
FCEV Fuel-cell electric vehicle
FERA Family Electric Rate Assistance
GCF Governors’ Climate and Forests Task Force
GDP gross domestic product
GGRF Greenhouse Gas Reduction Fund
GHG greenhouse gas
GoBiz Governor’s Office of Business and Economic Development
GWP global warming potential
HCD California Department of Housing and Community Development
HFC Hydrofluorocarbon
HVAC heating, ventilation and air conditioning
ICAP International Carbon Action Partnership
IEPR Integrated Energy Policy Report
IOU investor-owned utility
IPCC United Nations Intergovernmental Panel on Climate Change
IRP integrated resource plan
IWG Interagency Working Group on the Social Cost of Greenhouse Gases
LCFS Low Carbon Fuel Standard
LCTOP Low Carbon Transit Operations Program
LDV light-duty vehicle
LED light-emitting diode
LIWP Low-Income Weatherization Program
LOS level of service
MMTCO2e million metric tons of carbon dioxide equivalent
MOU memorandum of understanding
MPO metropolitan planning organization
MRR Regulation for the Mandatory Reporting of GHG Emissions
MTCO2 metric tons of carbon dioxide
MW Megawatt
N2O nitrous oxide
NAICS North American Industry Classification System
NEM Net-Energy Metering
NF3 nitrogen trifluoride
NOX nitrogen oxide
NZE near-zero emission
OEHHA Office of Environmental Health Hazard Assessment
OPR Governor’s Office of Planning and Research
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PEV plug-in electric vehicle
PHEV Plug-in hybrid electric vehicle
PFC Perfluorocarbon
PM particulate matter
PM2.5 fine particulate matter
PMR Partnership for Market Readiness
REMI Regional Economic Models, Inc.
RES-BCT Renewable Energy Bill Credit
RNG renewable natural gas
RPS renewable portfolio standard
RTP regional transportation plan
SB Senate bill
SCS Sustainable Communities Strategies
SC-CO2 social cost of carbon
SF6 sulfur hexafluoride
SGC Strategic Growth Council
SGIP Self-Generation Incentive Program
SLCP Short-lived climate pollutant
SWRCB State Water Resources Control Board
TBD to be determined
TCU Transportation Communications and Utilities
TIRCP Transit and Intercity Rail Capital Program
UCLA University of California, Los Angeles
UHI urban heat island
UIC International Union of Railways
UNFCCC United Nations Framework Convention on Climate Change
USDA U.S. Department of Agriculture
U.S. EPA United States Environmental Protection Agency
VMT vehicle miles traveled
WWTP waste water treatment plant
ZE zero emission
ZEV zero emission vehicles
ES20
REDUCE “SUPER POLLUTANTS”
40% reduction in methane and HFCs
CLEAN ENERGY
At least 50% renewable electricity
CLEAN TRANSIT
100% of new buses
are zero-emission
Double energy efficiency in existing buildings
CLEAN CARS
Over 4 million affordable
electric cars on the road
High density, transit-oriented housing
Walkable & bikable communities
On-road oil demand
reduced by half
CLEAN FUELS
18% carbon intensity reduction
California’s 2030 Vision
NATURAL &
WORKING
LANDS
RESTORATION
15-20 million metric
tons of reductions
SUSTAINABLE
FREIGHT
Transitioning to zero
emissions everywhere
feasible, and near-zero
emissions with renewable
fuels everywhere else
CAP-AND-TRADE
Firm limit on 80% of emissions
Exhibit 2
APPENDIX 2.1-A
Ramboll Environ, Greenhouse Gas Emissions Technical Report,
Landmark Village, Los Angeles County, California, October 2016
SR000395
Prepared for
The Newhall Land and Farming Company
Valencia, California
Project Number
0534264Q
Date
October 2016
GREENHOUSE GAS EMISSIONS
TECHNICAL REPORT
LANDMARK VILLAGE
LOS ANGELES COUNTY, CALIFORNIA
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CONTENTS
Executive summary 1
1. Introduction 4
1.1 Project Description 4
1.2 Regulatory Framework Compliance 5
1.3 Mitigation Measures 5
1.4 Existing Condition 5
2. Scientific Background, Regulatory Background, and Significance Thresholds 7
2.1 Scientific Background 7
2.1.1 Science of Global Climate Change 7
2.1.2 Effects of Human Activity on Global Climate Change 9
2.1.3 Potential Effects of Climate Change on State of California 11
2.1.3.1 Air Quality 11
2.1.3.2 Water Supply 12
2.1.3.3 Hydrology 13
2.1.3.4 Agriculture 13
2.1.3.5 Ecosystems and Wildlife 14
2.2 Regulatory Setting 14
2.2.1 Federal 14
2.2.1.1 Clean Air Act 14
2.2.1.2 Federal Plan to Reduce GHG Emissions by 2025 14
2.2.1.3 Federal Vehicle Standards 15
2.2.1.4 Energy Independence and Security Act 15
2.2.2 State 16
2.2.2.1 Executive Order S-3-05 16
2.2.2.2 Assembly Bill 32 16
2.2.2.3 2015 State of the State Address 20
2.2.2.4 Executive Order B-30-15 20
2.2.2.5 2016 State of the State Address 20
2.2.2.6 Senate Bill 32 and Assembly Bill 197 20
2.2.2.7 Energy Sources 20
2.2.2.8 Mobile Sources 22
2.2.2.9 Solid Waste Diversion 25
2.2.2.10 CEQA Guidelines on GHG Emissions 26
2.2.3 Regional 26
2.2.3.1 SCAG’s Regional Transportation Plan/Sustainable Communities Strategy 26
2.2.3.2 South Coast Air Quality Management District 27
2.2.4 Local 31
2.2.4.1 County of Los Angeles General Plan and Community Climate Action Plan 31
2.2.4.2 Santa Clarita Valley Area Plan: One Valley One Vision 2012 32
2.2.4.3 Green Building Standards 32
2.2.5 Carbon Markets 32
2.2.5.1 Cap-and-Trade Program 33
2.2.5.2 Voluntary Markets 33
2.2.6 Significance Thresholds 35
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CONTENTS (CONTINUED)
3. GHG Emissions Inventory 36
3.1 Measurement and Resources 36
3.1.1 Units of Measurement: Tonnes of CO2 and CO2e 36
3.1.2 Resources 36
3.1.2.1 CalEEMod® 36
3.1.2.2 Other Resources 38
3.1.3 Indirect GHG Emissions from Electricity Use 38
3.2 One-Time Emissions 39
3.2.1 Construction 39
3.2.1.1 Emissions from Construction Equipment 40
3.2.1.2 Emissions from On-Road Construction Trips 41
3.2.1.3 Total Construction Emissions 41
3.2.2 Vegetation Changes 42
3.2.2.1 Vegetation Change Emissions 42
3.3 Unmitigated Annual Operational Emissions 42
3.3.1 Area Sources 42
3.3.2 Energy Use 42
3.3.3 Water Supply, Treatment and Distribution 44
3.3.4 Solid Waste 45
3.3.5 Mobile Sources 46
Estimating Mobile Source Emissions 47
3.3.5.2 SCVCTM Data 47
3.3.5.3 Adjusting for Trip Generation Numbers 48
Deriving CalEEMod® Inputs 49
Summary of CalEEMod® Inputs 49
Mobile Source Emissions 50
4. Project Inventory in Context (Unmitigated) 51
4.1 Project Emissions Inventory 51
4.1.1 SCS Consistent Emissions Inventory 51
4.2 Statewide Emissions Reduction Targets 51
5. Mitigation Measures 52
5.1 List of Mitigation Measures 52
5.1.1 Mobile Related Emissions Reduction Methodology 58
5.2 Mitigation Measures 58
5.2.1 GCC-1. Residential ZNE 58
5.2.2 GCC-2. Non-Residential ZNE 60
5.2.3 GCC-3. Swimming Pool Heating 61
5.2.4 GCC-4. Residential EV Chargers and Vehicle Subsidy 62
5.2.5 GCC-5. Commercial Development Area EV Chargers 69
5.2.6 GCC-6. Transportation Demand Management Program 71
5.2.7 GCC-7. Traffic Signal Synchronization 71
5.2.8 GCC-8. Electric School Bus Funding Program 71
5.2.9 GCC-9. Subsidy for Electric Transit Buses 72
5.2.10 GCC-10. Carbon Credits 73
5.2.11 GCC-11. Off-site Retrofit Program 73
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CONTENTS (CONTINUED)
5.2.12 GCC-12. Off-site Electric Vehicle Chargers 73
5.2.13 GCC-13. GHG Reduction Plan 74
6. Project Inventory in Context (Mitigated) 75
6.1 Project Emissions Inventory 75
6.1.1 SCS Consistent Emissions Inventory 75
6.2 Statewide Emissions Reduction Targets 75
TABLES
Table ES-1. Summary of Existing On-Site GHG Emissions
Table ES-2. Summary of 2024 Project GHG Emissions
Table ES-3. Summary of GHG Emissions Reductions due to Mitigation Measures (2024)
Table ES-4. Summary of 2024 Project GHG Emissions (SCS Consistent)
Table 1-1. Project Statistical Summary
Table 1-2. List of Applicable Regulatory Standards
Table 2-1. GHG Emissions Sources Covered by Cap-and-Trade Program
Table 3-1. Project Land Uses and Square Footage
Table 3-2. Analyzed Emissions Inventories
Table 3-3. Construction Schedule Assumptions
Table 3-4. Construction Equipment Mix Assumptions
Table 3-5. Summary of Construction Worker, Vendor and Hauling Trips
Table 3-6. Building Construction and Architectural Coating Worker and Vendor Trips Adjustment
Table 3-7. Annual GHG Construction Emissions from Off-Road Equipment
Table 3-8. Annual GHG Construction Emissions from On-Road Vehicles
Table 3-9. Summary of GHG Construction Emissions
Table 3-10a. Number of Net New Trees
Table 3-10b. Vegetation Change Evaluation
Table 3-11. GHG Emissions from Area Sources
Table 3-12. Utility GHG Emission Factor Associated with Renewable Portfolio Standard
Table 3-13a. Residential Electricity and Natural Gas Usage Rates
Table 3-13b. Non-Residential Electricity and Natural Gas Usage Rate
Table 3-14a. GHG Emissions Associated with Swimming Pools
Table 3-14b. GHG Emissions Associated with Electricity and Natural Gas
Table 3-15a. Project Water Demand
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TABLES (CONTINUED)
Table 3-15b. GHG Emissions Reductions Associated with Recycled Water
Table 3-15c. GHG Emissions Associated with Water Use
Table 3-16. GHG Emissions Associated with Waste
Table 3-17a. SCVCTM Daily Tripend Generation
Table 3-17b. SCVCTM Average Trip Length Data
Table 3-17c. SCVCTM Tripend Internalization Percentages
Table 3-17d. Daily Trip Generation (Adjusted Internal Trips)
Table 3-17e. Calculating Total Daily VMT
Table 3-17f. Trip Lengths and Trip Rates for CalEEMod®
Table 3-17g. CalEEMod® Input Assumptions for Traffic
Table 3-18. GHG Emissions Associated With Traffic
Table 4-1. Summary of Assumptions
Table 4-2. Unmitigated Project GHG Emissions: Percentage Contribution to Existing International,
National, State, and County Inventories
Table 4-3. Service Population Calculations
Table 4-4. 2024 Unmitigated Project GHG Emissions (SCS Consistent)
Table 5-1a. GHG Emissions Reduction due to Residential 2019 Title 24 Building Features
Table 5-1b. GHG Emissions Reduction due to Residential ZNE Building Solar PV
Table 5-1c. Total GHG Emissions Reductions due to Residential ZNE Building Features and Solar PV
Table 5-2a. GHG Emissions Reduction due to Non-Residential 2019 Title 24 Building Features
Table 5-2b. GHG Emissions Reduction due to Non-Residential ZNE Building Solar PV
Table 5-2c. Total GHG Emissions Reductions due to Non-Residential ZNE Building Features and
Solar PV
Table 5-3. GHG Emissions Reductions for Residential Electric Vehicles
Table 5-4. GHG Emissions Reductions for Commercial Development Area Electric Vehicle Charging
Stations
Table 5-5. GHG Emissions Reductions due to Transportation Demand Management
Table 5-6. GHG Emissions Reductions due to Traffic Signal Synchronization
Table 5-7. GHG Emissions Reduction to Replace CNG with Electric School Buses
Table 5-8. GHG Emissions Reduction to Replace Transit CNG Buses with Electric Buses
Table 5-9. GHG Emissions Reduction due to Building Retrofit Program
Table 6-1. Summary of GHG Emissions Reductions due to Mitigation Measures (2024 SCS
Consistent)
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FIGURE
Figure 1-1: Landmark Village Land Use Plan
APPENDICES
Appendix A: Calculation Methodology for GHG Emissions under Existing Conditions
Appendix B: CalEEMod® Output Files
Appendix C: ConSol Residential and Commercial Building Analysis Report
Appendix D: Stantec Trip Rate and Trip Length Estimates
Appendix E: Fehr & Peers Transportation Demand Management Program Technical Memorandum
Appendix F: Newhall Ranch GHG Reduction Plan
Appendix G: Newhall Ranch Building Retrofit Program
Appendix H: Forecasting Electric Vehicle Purchases in the Newhall Ranch Community
Appendix I: Stantec Traffic Signal Synchronization Analysis
Appendix J: ConSol Energy Efficiency Upgrades for Existing Buildings
Appendix K: Offsets Analysis
Appendix L: GHG Emissions Modeling: Post-2010 Modifications to Methodologies
Appendix M: Consistency with CARB Scoping Plan
\\Env-SF-File1\public\Air\Newhall Plan B\7 Report\Landmark\2016-11-07 Landmark Village GHG TR.docx
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Acronyms and Abbreviations Ramboll Environ
ACRONYMS AND ABBREVIATIONS
AB Assembly Bill
ACC Advanced Clean Cars
ACR American Carbon Registry
AEA Additional Environmental Analysis
AEP Association of Environmental Professionals
AR4 IPCC’s Forth Assessment Report
AR5 IPCC’s Fifth Assessment Report
AvgHP Maximum rated average horsepower
BAAQMD Bay Area Air Quality Management District
BAU Business-As-Usual
BEV battery-electric vehicles
bhp break horsepower
BPS Best Performance Standards
CalEEMod® California Emission Estimator Model®
CalGreen The California Green Building Standards
CalRecycle California Department of Resources Recycling and Recovery
CAPCOA California Air Pollution Control Officers Association
CAR Climate Action Reserve
CARB California Air Resources Board
CCAP Community Climate Action Plan
CCCC California Climate Change Center
CCR California Code of Regulations
CDM Clean Development Mechanism
CEC California Energy Commission
CEQA California Environmental Quality Act
CEUS Commercial End-Use Survey
CFC Chlorofluorocarbon
CH4 Methane
CNG compressed natural gas
CO2 Carbon Dioxide
CO2e CO2 Equivalents
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Acronyms and Abbreviations Ramboll Environ
ACRONYMS AND ABBREVIATIONS
CPUC California Public Utilities Commission
CVRP Clean Vehicle Rebate Project
DC Direct Current
DOE Department of Energy
DOT Department of Transportation
DWR Department of Water Resources
E3 Energy + Environmental Economics
EDR Energy Design Rating
EF Emission factor
EGU electric generation units
EIR Environmental Impact Report
EISA Energy Independence and Security Act of 2007
EMFAC EMission FACtor Model
Ramboll Environ Ramboll Environ US Corporation, formerly ENVIRON US Corporation
EO Executive Order
ES Executive Summary
EV Electric Vehicle
EVSE electric vehicle supply equipment
ft feet
g gram
GHG Greenhouse Gas
GW Gigawatt
GWP Global Warming Potential
HFCs Hydrofluorocarbons
hr hour
ICEV internal combustion engine vehicles
IPCC Intergovernmental Panel on Climate Change
KW Kilowatt
kWh Kilowatt-hour
lbs Pounds
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Acronyms and Abbreviations Ramboll Environ
ACRONYMS AND ABBREVIATIONS
LCFS Low Carbon Fuel Standard
LOS levels of service
LAX Los Angeles International Airport
m meter
MSW Municipal Solid Waste
MT Metric Tonnes
MTCO2e Metric Tonnes of CO2 Equivalent
MT/year Metric Tonnes per Year
MW Megawatt
MWh Megawatt-Hour
N2O Nitrous Oxide
NHTSA National Highway Traffic Safety Administration
NRSP Newhall Ranch Specific Plan
OFFROAD Emissions Inventory Program model
OPR Office of Planning and Research
PEV plug-in electric vehicles
PHEV plug-in hybrid electric vehicles
ppm Parts Per Million
Pop population
PUP Power/Utility Protocol
PV Photovoltaic
RCP Representative Concentration Pathways
RFS Renewable Fuel Standard
RMDP Resource Management and Development Plan
RPH range of miles traveled per hour
RPS Renewables Portfolio Standard
RTP Regional Transportation Plan
SB Senate Bill
SCAG Southern California Association of Governments
SCAQMD South Coast Air Quality Management District
SR000404
Acronyms and Abbreviations Ramboll Environ
ACRONYMS AND ABBREVIATIONS
SCE Southern California Edison
SCP Spineflower Conservation Plan
SCS Sustainable Communities Strategy
SCVCTM Santa Clarita Valley Consolidated Traffic Model
SEA Significant Ecological Area
SJVAPCD San Joaquin Valley Air Pollution Control District
SLOAPCD San Luis Obispo Air Pollution Control District
SMAQMD Sacramento Metropolitan Air Quality Management District
SRES Special Report on Emissions Scenarios
SWP State Water Project
TDV Time Dependent Valuation
TAZ Traffic Analysis Zones
TDM Transportation Demand Management
TSF thousand square feet
UCS Union of Concerned Scientists
USDOE US Department of Energy
USEPA United States Environmental Protection Agency
VCS Verified Carbon Standard
VMT Vehicle Miles Traveled
VTTM Vesting Tentative Tract Map
WRP Water Reclamation Plant
yd yard
ZEV Zero emission vehicles
ZNE Zero Net Energy
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Executive summary Ramboll Environ
EXECUTIVE SUMMARY
As described further in Section 1.1, Landmark Village (“Project”) would accommodate
1,444 homes (specifically, 270 single-family and 1,174 multi-family homes, including 69
mixed-use/multi-family homes and 1,033,000 square feet of commercial (retail/office)
uses. The Project also would include a 9.7-acre elementary school, 9.9-acre community
park, 1.3-acre fire station, park and ride facility, and 76.7 acres of open space (including a
community park, recreation areas, trails, and a trailhead). Landmark Village also proposes
supporting facilities and infrastructure, including roads, the Long Canyon Road Bridge,
trails, drainage improvements, flood protection, potable and recycled water systems, a
sanitary sewer system, and dry utilities systems.
The analysis provided in this report recommends the adoption of a number of mitigation
measures to reduce Project-related greenhouse gas (GHG) emissions. The mitigation
measures would create a new paradigm in land use planning and achieve growth without
increased GHG emissions (i.e., net zero GHG emissions), establishing a precedent-setting
achievement consistent with the state’s GHG climate change policies. The recommended
mitigation measures would result in the establishment of a planned community with zero
net GHG emissions by placing high emphasis on on-site, innovative energy efficiencies and
solar energy generation within the community’s homes and buildings. Additionally, the
transportation (mobile) emissions mitigation measures include an innovative, robust
Transportation Demand Management (TDM) program that focuses on reducing vehicle
miles traveled (VMT) and providing incentives to accelerate deployment of zero-emission
electric vehicles. The details of these mitigation measures and their effectiveness at
reducing Project emissions are presented in Section 5.
This Executive Summary includes a short description of the scope, methodology, and
results of the analysis’ assessment of GHG emissions from the Project. As shown in this
analysis, the Project’s GHG emissions total would be reduced from that reported in the
previously certified 2011 Environmental Impact Report (EIR) with implementation of the
recommended mitigation measures.
The GHG emissions inventory presented in Section 3 of this analysis includes the following
sources of emissions: (1) area sources (e.g., landscaping-related fuel combustion sources);
(2) energy use associated with residential and non-residential buildings; (3) water and
wastewater treatment and distribution; (4) solid waste; (5) mobile sources (e.g.,
passenger vehicles); (6) construction; and (7) vegetation changes. The ongoing
operational emissions consist of the first five categories, while the one-time emissions are
associated with construction and vegetation changes. The typical types of GHG emissions
resulting from mixed-use developments such as the Project are emissions of carbon dioxide
(CO2), methane (CH4) and nitrous oxide (N2O). GHG emissions are typically measured in
terms of tonnes of CO2 equivalents (CO2e), calculated as the product of the mass emitted
of a given GHG and its specific global warming potential (GWP).
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This analysis primarily utilized the California Emission Estimator Model version 2013.2.2
(CalEEMod®)1 to assist in quantifying the GHG emissions in the inventories presented in this
report for the Project. CalEEMod® is a statewide program designed to calculate both criteria
and GHG emissions from development projects in California. Third-party studies were also
relied upon to support analyses and assumptions made outside of CalEEMod®.
The analysis provided in this report evaluates the significance of the Project’s GHG
emissions by reference to the following questions from Section VII, Greenhouse Gas
Emissions, of Appendix G of the California Environmental Quality Act (CEQA) Guidelines:
Threshold 1. Would the Project generate GHG emissions, either directly or indirectly, that
may have a significant impact on the environment?
Threshold 2. Would the Project conflict with an applicable plan, policy, or regulation
adopted for the purpose of reducing the emissions of GHGs?
This report, relative to Threshold 2, addresses whether the Project would conflict with the
statewide emission reduction targets for 2020, 2030 and 2050. Section 2.1, Global Climate
Change and Greenhouse Gas Emissions, of the Project’s additional environmental analysis
also addresses whether the Project would conflict with the County of Los Angeles’
Community Climate Action Plan (CCAP), the 2012 and 2016 Sustainable Communities
Strategy plans adopted by the Southern California Association of Governments (SCAG), and
the emission reduction measures outlined in the California Air Resources Board’s (CARB)
Scoping Plan. That analysis is supported – in part – by analyses completed by Meridian
Consultants and Stantec.
To address Threshold 1, and as discussed in Sections 4.1 and 6.1, this report estimates the
GHG emissions resulting from the Project. As documented in subsequent portions of this
report and shown in Table Executive Summary (ES)-1, the Project site – in its existing
condition – emits 698 metric tonnes (MT) of CO2e per year, whereas the Mitigated Project
will emit zero metric tonnes of CO2 equivalent (MTCO2e) per year (as shown in Table ES-
2). The Project will not result in a significant impact to global climate change because there
will not be a net increase in GHG emissions as compared to the existing GHG emission
levels. As discussed in more detail below, for purposes of Threshold 2, because there will
be no net increase in GHG emissions, the Project will not conflict with applicable plans,
policies and regulations, including statewide policies for the reduction of GHG emissions in
2020, 2030 and 2050. Table ES-3 shows the GHG reductions achieved by each of the
recommended mitigation measures.
The report also compares the Project’s emissions to an emissions inventory that excludes
emissions associated with cars and light-duty trucks. As shown in Table ES-4, the
Mitigated Project’s emissions are less than zero, after excluding light-duty vehicle
emissions from the emissions inventory, due to the continued application of the Project’s
GHG Reduction Plan.
While the recommended mitigation measures ensure that the Mitigated Project’s emissions
are reduced to zero, as presented in Sections 4.2 and 6.2, there is also evidence that the
evolving regulatory framework and improving technologies will result in the Project’s
1 SCAQMD. 2013. California Emissions Estimator Model®. Available at: http://www.CalEEMod.com/. Accessed:
September 2016.
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emissions inventory decreasing with time, consistent with the state’s 2030 and 2050
targets for securing further reductions in California’s GHG emissions level. In particular, in
order to reach Executive Order S-3-05's 2050 goal, additional regulatory and technological
advancements, such as decarbonization of the fuel supply, will need to occur.2 Reducing
the carbon content of motor fuels and fuels for electricity generation will reduce CO2e
emissions from this Project. Therefore, it is reasonable to expect the Project’s emissions
level to decline as the regulatory initiatives identified by California Air Resources Board
(CARB) in the First Update are implemented, and other technological innovations occur.
Stated differently, the Project’s emissions total at build-out represents the maximum
emissions inventory for the Project as California’s emissions sources are being regulated
(and foreseeably expected to continue to be regulated in the future) in furtherance of the
State’s environmental policy objectives. Given the Project’s mitigating to zero emissions, as
well as the reasonably anticipated decline in Project emissions from regulatory and
technological advancements, the Project would not impede efforts by the state to meet
Senate Bill (SB) 32’s 2030 target or Executive Order S-3-05’s 2050 target.
2 California Energy Commission. 2007. State Alternative Fuels Plan. December. CEC-600-2007-011-CMF. Available
at: http://www.energy.ca.gov/2007publications/CEC-600-2007-011/CEC-600-2007-011-CMF.PDF. Accessed:
September 2016.
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1. INTRODUCTION
The purpose of this technical report is to present the quantitative analyses that were
used to evaluate the Project’s greenhouse gas (GHG) emissions. Emissions during both
construction and operation of the Project were quantified. For purposes of the latter
category of emissions, both Unmitigated and Mitigated Project emissions were
quantified in the Project’s build-out year (2024). Legislation and rules regarding climate
change, as well as the scientific understanding of the extent to which different activities
emit GHGs, continue to evolve; as such, the inventory in this report is a reflection of
the guidance and knowledge currently available.
1.1 Project Description
Landmark Village would implement one of five villages within the Newhall Ranch
Specific Plan area, which was approved by the County of Los Angeles in 2003. The
approved Specific Plan authorizes a large-scale mixed-used community located in
unincorporated Santa Clarita Valley in northwestern Los Angeles County. The Specific
Plan specifically will guide the long-term development and conservation of the 11,999-
acre Newhall Ranch community, as approved to include a broad range of residential,
mixed-use, commercial/retail uses within five interrelated villages. The Landmark
Village project site, inclusive of the tract map and off-site improvements, is situated on
approximately 1,042 acres.
As approved by the County Board of Supervisors on February 21, 2012, Landmark
Village would accommodate 1,444 homes (specifically, 270 single-family and 1,174
multi-family homes, including 69 mixed-use/multi-family homes) and 1,033,000 square
feet of commercial (retail/office) uses. The project also would include a 9.7-acre
elementary school, a 9.9-acre community park, 1.3-acre fire station, a park and ride
facility, and 76.7 acres of open space (including a community park, recreation areas,
trails, and a trailhead). Landmark Village would further include supporting facilities and
infrastructure, including roads, the Long Canyon Road Bridge, trails, drainage
improvements, flood protection, potable and recycled water systems, a sanitary sewer
system, and dry utilities systems.
To facilitate development of the Landmark Village tract map site (Vesting Tentative
Tract Map 53108), project-related improvements are proposed for construction outside
the tract map boundary. These off-site improvements include a utility corridor; a
potable water tank and the conversion of an existing potable tank to a recycled water
tank; construction of the Long Canyon Road bridge, bank stabilization, storm drainage
improvements, and four debris basins; and, various grading activities, including
grading to accommodate SR-126 road improvements and the utility corridor. The
Landmark Village project’s development/grading footprint is approximately 1,042
acres, and the total amount of grading (for the tract map and off-site improvements) is
estimated at 7.0 million cubic yards.
As demonstrated in this technical report, the Landmark Village project, if reapproved,
would include additional mitigation measures to reduce the project’s greenhouse gas
emissions impacts from that reported in the previously certified 2011 Environmental
Impact Report (EIR).
In 2012, when Landmark Village was approved, the County Board adopted the
following project approvals: (a) VTTM 53108-(5), (b) Significant Ecological Area (SEA)
Conditional Use Permit No. 2005-00112-(5), (c) Conditional Use Permit 00-196-(5),
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(d) Oak Tree Permit No. 00-196-(5), (e) General Plan Amendment No. 00-196-(5), (f)
Specific Plan Amendment No. 00-196-(5), and (g) Local Plan Amendment No. 00-196-
(5). There are no proposed changes with regard to the Landmark Village project’s
discretionary project approvals.
Figure 1-1, Landmark Village Land Use Plan, depicts the Landmark Village land use
plan approved by the County Board of Supervisors in February 2012. This plan remains
the same as when it was approved in February 2012. Table 1-1, Landmark Village
Tract Map Statistical Summary, identifies the Landmark Village individual land use
types; the corresponding acreages; and the total units or square footage. This
summary also presents the same Landmark Village project data as approved in
February 2012. This data provides the basis for the analysis of greenhouse gas
emissions associated with the Landmark Village project.
1.2 Regulatory Framework Compliance
As a matter of law, the Project will comply with applicable Federal, State, Regional, and
County requirements. Many of the applicable regulatory standards are summarized in
Table 1-2 and apply to different GHG-generating activities/sources, including
construction, landscape equipment, building energy, passenger vehicles, medium- and
heavy-duty trucks, solid waste, water usage, and vegetation. Table 1-2 notes whether
the emissions reductions resulting from implementation of the regulatory standards are
quantified in the Project’s unmitigated and mitigated emissions inventories. As
illustrated in Table 1-2, several regulatory standards were not incorporated due to the
difficulty associated with modeling and quantifying the reductions. Incorporating these
regulations would further reduce Project emissions; as such, the emissions estimates
presented in this report provide a conservative representation of Project emissions.
1.3 Mitigation Measures
Mitigation measures are recommended to reduce the Project’s emissions to levels
below significance for purposes of California Environmental Quality Act CEQA. The
mitigation measures achieve growth without increased GHG emissions, establishing a
precedent-setting milestone consistent with the state’s GHG/climate change policies.
The mitigation measures recommended for the Project place high emphasis on and
prioritize on-site, innovative energy efficiencies and renewable energy generation
within the community’s homes and buildings. Additionally, the transportation (mobile)-
oriented mitigation measures include the implementation of a robust Transportation
Demand Management (TDM) Plan that focuses on reducing vehicle miles traveled and
provide incentives to accelerate the deployment of various categories of zero-emission
electric vehicles (EVs). The details of these mitigation measures and their effectiveness
at reducing Project emissions are presented in Section 5.
1.4 Existing Condition
The Project site is generally comprised of vacant land, some agricultural uses, water
wells, abandoned oil wells, and associated access roads. The area for agricultural uses
is approximately 424.6 acres; for purposes of this analysis, it is conservatively
assumed that the agricultural acreage would be permanently eliminated due to Project
buildout. The Project site is periodically leased to the movie industry for set locations.
All existing emission sources would be eliminated during Project buildout. Appendix A
of this report describes in detail the existing land use and associated GHG emissions
from those existing on-site land uses. The existing condition emissions inventory is
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estimated at 698 Metric Tonnes (MT) CO2e per year, as shown in Table Executive
Summary (ES)-1. If any existing emissions (e.g., from agricultural uses) are
permanently removed due to the Project development, the GHG emissions associated
with those existing operations could be considered permanently removed from the
global GHG emissions inventory.3
3 This analysis does not quantitatively account for the Project’s elimination of some existing sources of GHG
emissions located within the Project site’s development footprint. This analytical approach is conservative
because, as recognized by the Bay Area Air Quality Management District, if a proposed project involves the
removal of existing emission sources, the existing emissions level should be subtracted from the emissions
level estimated for the new proposed land uses in order to accurately quantify the change to environmental
conditions. See BAAQMD, 2012. California Environmental Quality Act Air Quality Guidelines. Page 4-5.
Available at: http://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/baaqmd-ceqa-
guidelines_final_may-2012.pdf?la=en. Accessed: September 2016.
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5. MITIGATION MEASURES
This section describes the mitigation measures developed for the Project that are
recommended for adoption. The section summarizes the mitigation measures and describes
the anticipated emission reductions based on the unmitigated emissions inventory. The
mitigation measures recommended here are intended to replace in full the mitigation
measures contained in Section 8.0 of the previously certified EIR (2011).
5.1 List of Mitigation Measures
The 13 mitigation measures set forth below, are identical to those recommended for
system-wide implementation across the applicant’s land holdings where development would
be facilitated by California Department of Fish and Wildlife’s Resource Management and
Development Plan and Spineflower Conservation Plan (RMDP/SCP) Project.106
Building Energy Efficiency
GCC-1. Prior to the issuance of residential building permits, the project applicant or its
designee shall submit a Zero Net Energy Confirmation Report (ZNE Report) prepared
by a qualified building energy efficiency and design consultant to Los Angeles County
for review and approval. The ZNE Report shall demonstrate that the residential
development within the RMDP/SCP project site subject to application of Title 24, Part
6, of the California Code of Regulations has been designed and shall be constructed to
achieve ZNE, as defined by CEC in its 2015 Integrated Energy Policy Report, or
otherwise achieve an equivalent level of energy efficiency, renewable energy
generation or greenhouse gas emissions savings.
A ZNE Report may, but is not required to:
(1) Evaluate multiple buildings and/or land use types. For example, a ZNE Report may
cover all of the residential and commercial buildings within a
neighborhood/community, or a subset thereof.
(2) Rely upon aggregated or community-based strategies to support its determination
that the subject buildings are designed to achieve ZNE. For example, shortfalls in
renewable energy generation for one or more buildings may be offset with excess
renewable generation from one or more other buildings, or off-site renewable
energy generation. As such, a ZNE Report could determine a building is designed
to achieve ZNE based on aggregated or community-based strategies even if the
building on its own may not be designed to achieve ZNE.
(3) Make reasonable assumptions about the estimated electricity and natural gas loads
and energy efficiencies of the subject buildings.
(This mitigation measure applies to Landmark Village without change.)
GCC-2. Prior to the issuance of building permits for commercial development and
private recreation centers, and prior to the commencement of construction for the
public facilities, respectively, the project applicant or its designee shall submit a Zero
106 The RMDP/SCP Project’s geographic boundaries encompass three planning areas: the Newhall Ranch Specific
Plan, Valencia Commerce Center, and Entrada. As previously discussed, the Landmark Village Project is one of
five inter-related, mixed-use villages located within the Newhall Ranch Specific Plan area proposed for
development by the applicant.
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Net Energy Confirmation Report (ZNE Report) prepared by a qualified building energy
efficiency and design consultant to Los Angeles County for review and approval. The
ZNE Report shall demonstrate that the commercial development, private recreation
centers, and public facilities within the RMDP/SCP project site subject to application of
Title 24, Part 6, of the California Code of Regulations have been designed and shall be
constructed to achieve ZNE, as defined by CEC in its 2015 Integrated Energy Policy
Report, or otherwise achieve an equivalent level of energy efficiency, renewable
energy generation or GHG gas emissions savings.
(“Commercial development” includes retail, light industrial, office, hotel, and
mixed-use buildings. “Public facilities” are fire stations, libraries, and
elementary, middle/junior high and high schools.)
A ZNE Report may, but is not required to:
(1) Evaluate multiple buildings and/or land use types. For example, a ZNE Report may
cover all of the residential and non-residential buildings within a
neighborhood/community, or a subset thereof.
(2) Rely upon aggregated or community-based strategies to support its determination
that the subject buildings are designed to achieve ZNE. For example, short falls in
renewable energy generation for one or more buildings may be offset with excess
renewable generation from one or more other buildings, or off-site renewable
energy generation. As such, a ZNE Report could determine a building is designed to
achieve ZNE based on aggregated or community-based strategies even if the
building on its own may not be designed to achieve ZNE.
(3) Make reasonable assumptions about the estimated electricity and natural gas loads
and energy efficiencies of the subject buildings.
(This mitigation measure applies to Landmark Village without change.)
GCC-3. Prior to the issuance of private recreation center building permits, the project
applicant or its designee shall submit swimming pool heating design plans to Los
Angeles County for review and approval. The design plans shall demonstrate that all
swimming pools located at private recreation centers on the RMDP/SCP project site
have been designed and shall be constructed to use solar water heating or other
technology with an equivalent level of energy efficiency.
(This mitigation measure applies to Landmark Village without change.)
Mobile Sources
GCC-4. Prior to the issuance of residential building permits, the project applicant or its
designee shall submit building design plans, to Los Angeles County for review and
approval, which demonstrate that each residence within the RMDP/SCP project site
subject to application of Title 24, Part 6, of the California Code of Regulations shall be
equipped with a minimum of one single-port electric vehicle (EV) charging station.
Each charging station shall achieve a similar or better functionality as a Level 2
charging station.
Additionally, prior to the issuance of the first building permit for the RMDP/SCP
project site, the project applicant or its designee shall establish and fund a
dedicated account for the provision of subsidies for the purchase of ZEVs, as
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defined by ARB. The project applicant or its designee shall provide proof of the
account’s establishment and funding to Los Angeles County.
The dedicated account shall be incrementally funded, for each village-level
project, in an amount that equals the provision of a $1,000 subsidy per
residence – on a first-come, first-served basis – for 50 percent of the village’s
total residences subject to application of Title 24, Part 6, of the California Code
of Regulations.
(This mitigation measure applies to Landmark Village without change.)
GCC-5. Prior to the issuance of commercial building permits, the project applicant or
its designee shall submit building design plans, to Los Angeles County, which
demonstrate that the parking areas for commercial buildings on the RMDP/SCP project
site shall be equipped with EV charging stations that provide charging opportunities to
7.5 percent of the total number of required parking spaces. (“Commercial buildings”
include retail, light industrial, office, hotel, and mixed-use buildings.)
The EV charging stations shall achieve a similar or better functionality as a
Level 2 charging station. In the event that the installed charging stations use
more superior functionality/technology than Level 2 charging stations, the
parameters of the mitigation obligation (i.e., number of parking spaces served
by EV charging stations) shall reflect the comparative equivalency of Level 2
charging stations to the installed charging stations on the basis of average
charge rate per hour. For purposes of this equivalency demonstration, Level 2
charging stations shall be assumed to provide charging capabilities of 25 range
miles per hour.
(This mitigation measure applies to Landmark Village without change.)
GCC-6. The project applicant-submitted Newhall Ranch Transportation Demand
Management Plan (TDM Plan), located in Appendix E, shall be implemented to reduce
VMT resulting from project build out with oversight from Los Angeles County. The TDM
Plan is designed to influence the transportation choices of residents, students,
employees, and visitors, and serves to enhance the use of alternative transportation
modes both on and off the project site through the provision of incentives and
subsidies, expanded transit opportunities, bikeshare and carshare programs,
technology-based programs, and other innovative means. Implementation of relevant
elements of the TDM Plan will be included as a condition of approval by Los Angeles
County when approving tentative subdivision maps for land developments that are
part of the project.
Accordingly, the TDM Plan identifies key implementation actions that are
critical to the effectiveness of the VMT-reducing strategies, as well as timeline
and phasing requirements, monitoring standards, and performance metrics
and targets tailored to each of the strategies.
In accordance with the TDM Plan, a non-profit Transportation Management
Organization (TMO) or equivalent management entity shall be established to
provide the services required, as applicable.
(This mitigation measure applies to Landmark Village without change.)
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GCC-7. Prior to the issuance of traffic signal permits, the project applicant or its
designee shall work with Los Angeles County and the California Department of
Transportation (Caltrans), as applicable, to facilitate traffic signal coordination along:
(1) State Route 126 from the Los Angeles County line to the Interstate 5 north-bound
ramps;
(2) Chiquito Canyon Road, Long Canyon Road, and Valencia Boulevard within the
RMDP/SCP Project site;
(3) Magic Mountain Parkway from Long Canyon Road to the Interstate 5 north-bound
ramps; and,
(4) Commerce Center Drive from Franklin Parkway to Magic Mountain Parkway.
To effectuate the signal synchronization and specifically the operational and
timing adjustments needed at affected traffic signals, the project applicant or
its designee shall submit traffic signal plans for review and approval, and/or
pay needed fees as determined by Los Angeles County or Caltrans, as
applicable.
A majority of the signals that will be synchronized will be new signals
constructed/installed by the project. Thus, for these signals, the project will
provide the necessary equipment at the signal controller cabinet, as well as
within the new roadways themselves, to enable and facilitate synchronization.
The project is responsible for paying 100 percent of the applicable fee amount
for the signal synchronization work, with assurance that the necessary funding
will be available to fully implement this measure.
(For purposes of the Landmark Village Project, the following roadway segments shall
be subject to traffic signal synchronization improvements: (a) SR-126 from west of
Chiquita Canyon Road to east of Wolcott Way (adjacent to the Landmark Village
boundary); and, (b) Long Canyon Road (within the Landmark Village boundary).)
GCC-8. Consistent with the parameters of the Newhall Ranch TDM Plan, the project
applicant or its designee shall provide Los Angeles County with proof that funding has
been provided for the purchase, operation and maintenance of electric school buses in
furtherance of the school bus program identified in the project’s TDM Plan. The proof
of funding shall be demonstrated incrementally as the school bus program is paced to
village-level occupancy and student enrollment levels.
(This mitigation measure applies to Landmark Village without change.)
GCC-9. Prior to the issuance of the first 2,000th residential building permit within the
RMDP/SCP project site and every 2,000th residential building permit thereafter, the
project applicant or its designee shall provide Los Angeles County with proof that it
has provided a subsidy of $100,000 per bus for the replacement of up to 10 diesel or
compressed natural gas transit buses with electric buses to the identified transit
provider(s).
(The Landmark Village Project shall be responsible for its proportional share of the
referenced subsidies.)
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Construction Sources
GCC-10. Prior to issuing grading permits for village-level development within the
RMDP/SCP project site, Los Angeles County shall confirm that the project applicant or
its designee shall fully mitigate the related construction and vegetation change GHG
emissions (the “Incremental Construction GHG Emissions”) by relying upon one of the
following compliance options, or a combination thereof, in accordance with the project
applicant-submitted Newhall Ranch GHG Reduction Plan (GHG Reduction Plan; see
Appendix F):
(1) Directly undertake or fund activities that reduce or sequester GHG emissions and
retire the associated GHG reduction credits in a quantity equal to the Incremental
Construction GHG Emissions; or
(2) Obtain and retire carbon credits that have been issued by a recognized and
reputable carbon registry, as described in the GHG Reduction Plan, in a quantity
equal to the Incremental Construction GHG Emissions.
(This mitigation measure applies to Landmark Village without change.)
Off-site Mitigation
GCC-11. Prior to the issuance of building permits for every 100 residential units or
100,000 square feet of commercial development for each village-level project, the
project applicant or its designee shall provide proof of funding of the proportional
percentage of the Building Retrofit Program (Retrofit Program), as included in
Appendix G, to Los Angeles County. (“Commercial development” includes retail, light
industrial, office, hotel and mixed-use buildings.) Building retrofits covered by the
Retrofit Program can include, but are not limited to: cool roofs, solar panels, solar
water heaters, smart meters, energy efficient lighting (including, but not limited to,
light bulb replacement), energy efficient appliances, energy efficient windows,
insulation, and water conservation measures.
The Retrofit Program shall be implemented within the geographic area defined
to include Los Angeles County and primarily within disadvantaged
communities, as defined by the Retrofit Program, or in other areas accepted
by the Los Angeles County Planning Director.
Funding shall be applied to implement retrofits strategies identified in the
Retrofit Program or other comparable strategies accepted by the Los Angeles
County Planning Director.
(This mitigation measure applies to Landmark Village without change.)
GCC-12. Prior to the issuance of the first building permit for the RMDP/SCP project
site, the project applicant or its designee shall provide Los Angeles County with proof
of installation of EV charging stations capable of serving 20 off-site parking spaces.
Thereafter, the project applicant or its designee shall provide Los Angeles County
proof of installation of EV charging stations prior to the issuance of residential and
commercial building permits per the following ratios: one (1) off-site parking space
shall be served by an electric vehicle charging station for every 30 dwelling units, and
one (1) off-site parking space shall be served by an electric vehicle charging station
for every 7,000 square feet of commercial development. (“Commercial development”
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includes retail, light industrial, office, hotel and mixed-use buildings.) Off-site EV
charging stations capable of servicing 2,036 parking spaces would be required if the
maximum allowable development facilitated by the RMDP/SCP project occurs; fewer
EV charging stations would be required if maximum build-out under the RMDP/SCP
project does not occur.
The EV charging stations shall achieve a similar or better functionality as a
Level 2 charging station and may service one or more parking spaces. In the
event that the installed charging stations use more superior
functionality/technology than Level 2 charging stations, the parameters of the
mitigation obligation (i.e., number of parking spaces served by EV charging
stations) shall reflect the comparative equivalency of Level 2 charging stations
to the installed charging stations on the basis of average charge rate per hour.
For purposes of this equivalency demonstration, Level 2 charging stations shall
be assumed to provide charging capabilities of 25 range miles per hour.
The EV charging stations shall be located within the geographic area defined to
include Los Angeles County, and in areas that are generally accessible to the
public. For example, the charging stations may be located in areas that
include, but are not limited to, retail centers, employment centers, recreational
facilities, schools, and other categories of public facilities.
(This mitigation measure applies to Landmark Village without change.)
GCC-13. In addition to GCC-1 through GCC-12, the project applicant shall offset GHG
emissions to zero by funding activities that directly reduce or sequester GHG
emissions or, if necessary, obtaining carbon credits through the Newhall Ranch GHG
Reduction Plan. The project applicant-submitted Newhall Ranch GHG Reduction Plan
focuses on achieving GHG reductions or sequestration through the direct investment in
specific programs or projects in coordination with an accredited carbon registry, such
as the Climate Action Reserve. If these direct investment efforts do not achieve an
adequate amount of GHG reductions, the project applicant can obtain carbon credits
from accredited carbon registries.
SCAQMD recommends that mitigation be considered in the following prioritized
manner: (1) project design feature/on-site reduction measures; (2) off-site within
neighborhood; (3) off-site within district; (4) off-site within state; and (5) off-site out
of state (SCAQMD 2008).
Prior to issuing building permits for development within the project site, Los Angeles
County shall confirm that the project applicant or its designee shall fully offset the
project’s remaining (i.e., post implementation of GCC-1 through GCC-12) operational
GHG emissions over the 30-year project life associated with such building permits
(“Incremental Operational GHG Emissions) by relying upon one of the following
compliance options, or a combination thereof, in accordance with the Newhall Ranch
GHG Reduction Plan:
(1) Demonstrate that the project applicant has directly undertaken or funded activities
that reduce or sequester GHG emissions (“Direct Reduction Activities”) that are
estimated to result in GHG reduction credits, as described in the GHG Reduction
Plan, and retire such GHG reduction credits in a quantity equal to the Incremental
Operational GHG emissions;
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(2) Provide a guarantee that it shall retire carbon credits issued in connection with
Direct Reduction Activities in a quantity equal to the Incremental Operational GHG
Emissions;
(3) Undertake or fund Direct Reduction Activities and retire the associated carbon
credits in a quantity equal to the Incremental Operational GHG Emissions; or
(4) If it is impracticable to fully offset Incremental Operational Emissions through the
Direct Reduction Activities, the project applicant or its designee may purchase and
retire carbon credits that have been issued by a recognized and reputable,
accredited carbon registry in a quantity equal to the Incremental Operational GHG
Emissions.
Compliance with GCC-13 shall be demonstrated incrementally prior to obtaining
building permits, and shall in the context of the project overall follow the preferred
geographic hierarchy recommended by SCAQMD, discussed above. Incremental
Operational GHG emissions shall be equal to the sum of the number of proposed
residential units covered by the applicable building permit multiplied by 107.45 MT
CO2e and every thousand square feet of proposed commercial development covered
by the applicable building permit multiplied by 542.40 MT CO2e.
(This mitigation measure applies to Landmark Village without change, with the
exception that the emissions reduction rates specified in the mitigation measure for
residential and commercial building permits have been modified to reflect the Project-
specific emissions analysis presented in this report and equate to those rates of
emissions reductions needed to ensure that Project emissions are reduced to zero.)
5.1.1 Mobile Related Emissions Reduction Methodology
The combined emission reductions related to the mitigation measures addressing mobile
source emissions need to be estimated sequentially, in order to avoid double counting the
emission reductions. For purposes of this analysis, the emission reductions are calculated
and applied in the following order: (1) Transportation Demand Management (TDM Plan),
(2) incentives for residential electric vehicles (EVs); and (3) traffic signal synchronization.
The emission reductions due to commercial development area EV charging stations, and
the utilization of electric transit and school buses, are independent of the TDM Plan's
reductions, since they are based on a fixed number of replaced vehicles, and do not need
to be accounted for in a particular sequence.
5.2 Mitigation Measures
The following section describes the estimates for the GHG reductions.
5.2.1 GCC-1. Residential ZNE
The residential development within the Project site subject to application of Title 24, Part 6,
of the California Code of Regulations shall be designed and constructed to achieve ZNE, as
defined by the CEC in its 2015 Integrated Energy Policy Report.107, 108. Specifically, this
107 California Energy Commission. Integrated Energy Policy Report. 2015. Available at:
http://docketpublic.energy.ca.gov/PublicDocuments/15-IEPR-
01/TN210527_20160224T115023_2015_Integrated_Energy_Policy_Report__Small_Size_File.pdf. Accessed:
September 2016.
108 As stated in the CEC IEPR, the ZNE goal is also supported “by the CPUC in the Long-Term Energy Efficiency
Strategic Plan, by California Air Resources Board (ARB) in the First Update to the Climate Change Scoping Plan,
and in Governor Brown’s Clean Energy Jobs Plan.”
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mitigation assumes the following definition of ZNE: A ZNE building is one “where the value
of the net amount of energy produced by on-site renewable energy resources is equal to
the value of the energy consumed annually by the building at the level of a single ‘project’
seeking development entitlements and building code permits measured using the California
Energy Commission’s Time Dependent Valuation metric.”109
Achieving ZNE represents “a unique opportunity to manage energy costs and meet
greenhouse gas (GHG) reduction goals.” 110 CEC proposes to meet ZNE through a variety of
energy efficiency improvements coupled with on-site renewable energy generation. While
energy efficient design required by “future updates of the building and appliance energy
efficiency standards” serves to minimize energy demand, CEC anticipates that “onsite
renewable electricity generation such as solar photovoltaic systems or wind-driven
electricity generators” will generate the remainder of a building’s energy needs to achieve
ZNE.111, 112
Estimated GHG Reduction
The main variables contributing to the calculated GHG benefit of achieving residential ZNE
are as follows:
Residential Building Prototypes: The residential building prototypes modeled by ConSol
are used as the basis for this estimate of GHG emission reductions from achieving ZNE
(see Appendix C). ConSol studied two residential building prototypes in its analysis
that are representative of the development that would be facilitated by the Project, a
single family home and a multifamily home, and evaluated how each residential home
could achieve ZNE.
Residential Energy Efficiency: ConSol's modeling estimates the energy consumption of
a home that is designed to achieve ZNE by exceeding the 2016 Title 24 standards
through the combined use of building envelope efficiencies and on-site onsite
Photovoltaic (PV) systems. 113 The electricity and natural gas consumption of this
"2019 Title 24 Standards" home are shown Appendix C, and the GHG reductions from
upgrading the 2016 Title 24 homes to 2019 Title 24 homes are shown in Table 5-1a.
PV System Design: The estimated GHG reductions achieved through residential ZNE
are based, in part, on the additional PV system requirements as estimated by ConSol.
Specifically, ConSol estimated the rated PV system size required for the single family
and multifamily building prototypes to achieve ZNE using the CEC's California Solar
Initiative Incentive Calculator. Based on ConSol’s analysis, a 5.0-kilowatt (kW) system
109 The CEC and CPUC concept of TDV “is based on the cost for utilities to provide energy at different times.” This
valuation accounts for the variable value of electricity and natural gas based on hour, day, or season.
110 California Energy Commission. Achieving Energy Savings in California Buildings. 2011. Available at:
http://www.energy.ca.gov/2011publications/CEC-400-2011-007/CEC-400-2011-007-SD.pdf. Accessed:
September 2016.
111 California Energy Commission. Achieving Energy Savings in California Buildings. 2011. Available at:
http://www.energy.ca.gov/2011publications/CEC-400-2011-007/CEC-400-2011-007-SD.pdf.
Accessed: September 2016.
112 California Energy Commission. Integrated Energy Policy Report. 2011. Available at:
http://www.energy.ca.gov/2011publications/CEC-100-2011-001/CEC-100-2011-001-CMF.pdf.
Accessed: September 2016.
113 The ConSol modeling represents one option of many that may be feasible to achieve residential ZNE.
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per single family home and a 21.9-kW system per multifamily home were required to
meet ZNE. These PV systems are sized to achieve ZNE by exceeding the Energy
Design Rating (EDR) and TDV energy consumption of the modeled homes, as
described in more detail in Appendix C. The calculations shown in Table 5-1b
estimate the GHG reduction from installing the PV systems necessary to achieve ZNE.
Emission Factors: The analysis is based on the assumption that the 40 percent RPS for
2024 is achieved.
Table 5-1c shows the total GHG reduction achieved through the Project’s development of
ZNE residences.
5.2.2 GCC-2. Non-Residential ZNE
The non-residential development within the Project site subject to application of Title 24,
Part 6, of the California Code of Regulations shall be designed and constructed to achieve
Zero Net Energy, as defined by the California Energy Commission in its 2015 Integrated
Energy Policy Report, or otherwise achieve an equivalent level of energy efficiency or
greenhouse gas emissions savings.114, 115
Estimated GHG Reduction
The main variables contributing to the calculated GHG benefit of achieving residential ZNE
are as follows:
Non-Residential Building Prototypes: The commercial building prototypes modeled by
ConSol are used as the basis for this estimate of GHG emission reductions from
achieving ZNE (see Appendix C). ConSol studied three commercial building
prototypes in its analysis that are representative of the development that would be
facilitated by the Project: an office building, a light industrial building, and a retail
building. ConSol's modeling showed that ZNE could be achieved through a combination
of additional energy efficiency design improvements beyond the 2016 Title 24
Standards and adequate on-site PV systems. 116 The estimated GHG reductions by
building prototype were mapped to the land uses represented for the Project. For
example, “regional shopping center” was mapped to retail, and “industrial park” was
mapped to industrial.
Non-Residential Energy Efficiency: In ConSol’s analysis, the estimated improvements
in building design are applied to each building prototype in order to estimate the GHG
reductions. Given the variability in energy usage in the building prototypes, the
required energy efficiency improvements vary across the three prototypes modeled.
Table 5-2a presents the GHG reductions from improving building energy efficiencies
beyond the 2016 Title 24 Standards to 2019 Title 24 Standards.
114 California Energy Commission. Integrated Energy Policy Report. 2015. Available at:
http://docketpublic.energy.ca.gov/PublicDocuments/15-IEPR-
01/TN210527_20160224T115023_2015_Integrated_Energy_Policy_Report__Small_Size_File.pdf. Accessed:
September 2016.
115 As stated in the CEC IEPR, the ZNE goal is also supported “by the CPUC in the Long-Term Energy Efficiency
Strategic Plan, by California Air Resources Board (ARB) in the First Update to the Climate Change Scoping Plan,
and in Governor Brown’s Clean Energy Jobs Plan.”
116 The ConSol modeling represents one option of many that may be feasible to achieve commercial ZNE.
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PV System Design: The estimated GHG reductions achieved through additional PV
system requirements, as estimated by ConSol, are contribute to the overall GHG
reduction resulting from the Project’s development of ZNE commercial buildings. As
shown in Table 5-2b, ConSol identified the rated PV system size required for each of
the building prototypes to achieve ZNE. Table 5-2b also identifies the annual GHG
reduction attributable to the PV systems identified for the non-residential building
prototypes.
Emission Factors: The analysis is based on the assumption that the 40 percent RPS for
2024 is achieved.
Table 5-2c shows the total GHG reduction achieved through the Project’s development of
ZNE non-residential buildings.117
5.2.3 GCC-3. Swimming Pool Heating
All swimming pools located at the private recreation centers on the Project site shall be
designed and constructed to use solar water heating or other technology with an equivalent
level of energy efficiency (e.g., use solar energy (or equivalent) to replace natural gas for
purposes of heating the swimming pool waters).
Estimated GHG Reduction
The main variables contributing to the calculated GHG benefit of solar heating the
swimming pools are as follows:
Energy sources: The swimming pools are assumed to use electricity for filters and
pumps and use natural gas for water heating for the Unmitigated Project. The
mitigation measure requires that solar heating (or equivalent) replaces all natural gas
heating at the swimming pools.
Energy use factor: The electricity and natural gas energy usage factors for swimming
pools are based on the energy consumption of filter pumps and water heaters included
in a published pools study by the City of Oakland (Pools Study),118 and scaled to
represent energy consumption per year per volume of the pool. The Pools Study data
included pool volume, number of heaters, heater rating, operation schedule, and
annual electricity usage. Annual Natural Gas Usage was calculated by multiplying the
number of hours per day, days per year, heaters, and the heating rating. The
calculated Annual Natural Gas Usage was adjusted to account for (1) the higher
average ambient temperature in Southern California compared to Oakland (i.e., an
average temperature of 55.5° F for Oakland and 63.3° F for Santa Clarita), and (2)
savings from newer energy efficient heater standards, i.e., Ramboll Environ assumed
that the Oakland pools used 78 percent efficient heaters, which is the minimum
efficiency legally required (see 10 CFR Part 431). According to the U.S. Department of
Energy, newer pools are likely to use heaters with 89-95 percent efficiency.119 Ramboll
Environ conservatively assumed 90 percent efficiency for San Bernardino pool heaters,
117 No GHG benefits were included for shifting load from peak to off-peak hours.
118 City of Oakland/Oakland Unified School District. October 2006. Energy Efficient Commercial Pool Program;
Preliminary Facility Reports for DeFremery Pool, Fremont Pool, Live Oak Pool, Lyons Pool, and Temescal Pool.
119 Available at: http://www.energysavers.gov/your_home/water_heating/index.cfm/mytopic=13170.
Accessed: May 2016.
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resulting in a 12 percent savings over the Pool Study data. Average Annual Electricity
Usage was calculated from the Annual Electricity Usage of the Pool Study data divided
by the swimming pools total pool volume.
Emission Factors: The utility emission factors are consistent with the analyses for the
project.
Swimming pool size: All the swimming pools are assumed to be 50m x 25yd x 8ft.120
The calculations shown in Table 3-14a estimate the GHG reduction from replacing natural
gas with solar energy for heating the swimming pools. The GHG emissions reduction is the
difference between the total GHG emissions from the unmitigated and mitigated emission
estimates.
5.2.4 GCC-4. Residential EV Chargers and Vehicle Subsidy
Each residence within the Project site subject to application of Title 24, Part 6, of the
California Code of Regulations shall be equipped with a minimum of one single-port electric
vehicle charging station. Each charging station will achieve a similar or better functionality
as a Level 2 charging station. Additionally, a $1,000 subsidy shall be available for 50
percent of the Project site’s residences subject to application of Title 24, Part 6, of the
California Code of Regulations, on a first-come, first-served basis, for the purchase of a
zero emission vehicle, as defined by the California Air Resources Board.
These measures will complement the Project’s commitments to install Level 2 charging
stations for 7.5 percent of the parking spaces within the Project site and to install Level 2
charging stations at publicly available areas within the SCAG region. Through these
commitments, the Project will help support an increasingly inter-connected web of charging
infrastructure, making it easier to own and use EVs, consistent with goals aimed to
increase EV penetration.
Mobile GHG emissions are a major component of overall land use development emission
inventories. Conventional gasoline and diesel vehicles emit GHGs from the tailpipe,
whereas EVs minimize these emissions. EVs including battery-electric vehicles (BEVs) and
plug-in hybrid electric vehicles (PHEVs) comprise a growing fraction of the passenger
vehicles on the roads in California, and EV adoption is expected to greatly increase over the
upcoming decades due in part to improvements in battery technology and public initiatives
and goals. In addition to the discussion below, a study that forecasts electric vehicle
purchases in the Newhall Ranch Community is included in Appendix H.
A variety of external factors will complement Newhall Ranch’s commitment to facilitate the
use of EVs and the growth of electric vehicle penetration. There are dozens of electric
vehicle models available for purchase in California, and the costs of batteries and BEVs
continues to decrease. Batteries for electric vehicles have seen rapidly decreasing costs in
recent years, averaging roughly fourteen percent annually from 2007 to 2014121.
Furthermore, the impact of learning-by-doing cost reductions (resulting from a doubling in
production), is between six and nine percent. This has resulted in the industry-wide
120 ENVIRON International Corporation, October 2009. Prepared for The Newhall Land and Farming Company,
Valencia, CA. Climate Change Technical Addendum: Resource Management and Development Plan Spineflower
Conservation Plan.
121 Nykvist, B. and Nilsson, M. Rapidly falling costs of battery packs for electric vehicles. Nature: Climate Change
(2015), 5, pg. 329-332.
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average cost of a battery pack declining from $1000/kWh to $410/kWh (2007 to 2014),
and an even greater reduction among market-leading battery electric vehicle
manufacturers, to around $300/kWh. There are statewide and regional initiatives to help
fund electric vehicle and infrastructure purchases, and ambitious goals to increase the
number of EVs on the road by 2025. Peer-reviewed studies show that vehicle electrification
is necessary to achieve California’s long-term greenhouse gas reduction goals. Reliable
access to EV chargers is an important factor contributing to people’s comfort levels when
buying electric vehicles.
Statewide Initiatives
As discussed in Section 2.2.2.7 above, California has programs and initiatives already in
place to further the progress of EV penetration. These include vehicle fuel efficiency
standards, executive orders, and purchase incentives.
Electric Vehicles Necessary to Achieve Statewide GHG Goals
As described in Section 2.2.2, California has goals to reduce GHGs to 40 percent below
1990 levels by 2030 and 80 percent below 1990 levels by 2050. Meeting these GHG
reduction goals will require an increase in vehicle electrification, according to several recent
studies. In a 2012 Science paper on achieving California’s 2050 goal,122 Williams concludes
that “[t]he most important finding of this research is that, after other emission reduction
measures were employed to the maximum feasible extent, there was no alternative to
widespread switching of direct fuel uses (e.g., gasoline in cars) to electricity in order to
achieve the reduction target.” The study parameters displace 75 percent of light-duty
gasoline use with EVs and PHEVs in 2050. A 2015 UC Davis study123 reiterates that EVs are
needed to reach California’s 2050 goal and also federal and national GHG reduction targets,
stating that “passenger vehicles will not be able to achieve an 80 percent GHG
reduction…using hydrocarbon fuels.”
Widespread EV adoption is necessary before 2050 to achieve California’s 2030 goals.
Energy + Environmental Economics (E3) developed a modeling tool called PATHWAYS to
chart the GHG impact of different scenarios of fuel usage, technology adoptions, and other
California policy changes that may affect future GHG emissions. They used PATHWAYS to
show potential pathways to meeting the 2030 and 2050 California state goals and national
goals. The pathways presented to meet California’s 2030 goal124 include six to seven million
ZEVs and PHEVs on the road by 2030, which is significantly higher than the Executive
Order (EO) B-16-2012 target of 1.5 million EVs by 2025. E3 shows that EVs should have a
new vehicle market share of 35 to 40 percent by 2025 and over 50 percent by 2030. Based
on E3’s sensitivity analysis, zero-emission vehicles are the single most important
contributor to GHG reductions for the 2050 goal.
122 Williams, J.H., et al. 2012. The Technology Path to Deep Greenhouse Gas Emissions Cuts by 2050: The Pivotal
Role of Electricity. Science, 335.
123 Brown, R., et al. 2015. Achieving California’s Greenhouse Gas Goals: A Focus on Transportation. Institute of
Transportation Studies, University of California, Davis, Research Report UCD-ITS-RR-15-14. Available at:
http://www.its.ucdavis.edu/research/publications/publication-detail/?pub_id=2529. Accessed: September 2016.
124 Energy + Environmental Economics (E3). 2015. California PATHWAYS: GHG Scenario Results. April 6. Available
at: https://ethree.com/documents/E3_PATHWAYS_GHG_Scenarios_Updated_April2015.pdf.
Accessed: September 2016.
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Residential EV Charging is an Important Factor for Increasing EV Penetration
While charging stations at work places and retail stores are becoming more widespread,
most EV charging has historically taken place at homes, and will continue to do so.125 An
average vehicle spends 90 percent of its time at home and work, with over
70 to 80 percent of EV charging taking place at home, followed by workplace
charging.126,127 In fact, the availability and accessibility of a plug at home increases a
person’s propensity to buy an electric vehicle.128 National Renewable Energy Laboratory’s
assessment for the California Energy Commission129 found that home charging is the
predominant location for charging, followed by workplace/retail charging, then public
charging. In the near term, the CEC believes that “can’t miss” locations are homes and
multi-unit dwellings, followed by workplaces.130
Research shows that access to charging infrastructure at home plays an important role in
decisions regarding purchase of EVs. A 2013 study conducted by the Institute of
Transportation Studies at University of California, Davis explored the characteristics of
1,200 households who actually purchased a new plug-in vehicle in California during 2011-
2012, with the overall target population of the survey being new plug-in electric vehicle
(PEV) owners in California.131 This study reveals that purchasing a PEV is associated in
most cases with the installation of EVSE at home and the ability to plug the car to the
power for charging.132 In 2011, a report released by the National Research Council of the
National Academies on the barriers to electric vehicle deployment pointed to lack of
charging infrastructure deployment as one of the barriers to EV deployment, with 21.3
percent of survey respondents stating concern about access to charging infrastructure as
125 Holland, B. 2013. How important is charging infrastructure to EV adoption? GreenBiz. January 17. Available at:
https://www.greenbiz.com/blog/2013/01/17/how-important-charging-infrastructure-ev-adoption.
Accessed: September 2016.
126 Holland, B. 2013. How important is charging infrastructure to EV adoption? GreenBiz. January 17. Available at:
https://www.greenbiz.com/blog/2013/01/17/how-important-charging-infrastructure-ev-adoption.
Accessed: September 2016.
127 Leemput, N. et al. 2015. MV and LV Residential Grid Impact of Combined Slow and Fast Charging of Electric
Vehicles. Energies (2015), 8, 1760-1783. Available at: http://www.mdpi.com/1996-1073/8/3/1760.
128 Hidrue, M.K., G.R. Parsons, W. Kempton, and M.P. Gargner. 2011. Willingness to pay for electric vehicles and
their attributes. Resource Energy Econ. doi:10.1016/j.reseneeco.2011.02.002. Available at:
http://www.udel.edu/V2G/resources/HidrueEtAl-Pay-EV-Attributes-correctedProof.pdf. Accessed: September
2016.
129 National Renewable Energy Laboratory (NREL). 2014. California Statewide Plug-In Electric Vehicle Infrastructure
Assessment. Available at: http://www.energy.ca.gov/2014publications/CEC-600-2014-003/CEC-600-2014-
003.pdf. Accessed: September 2016.
130 Ibid.
131 Tal, G., M.A. Nicholas, J. Woodjack, and D. Scrivano. February 2013. Who Is Buying Electric Cars in California?
Exploring Household and Vehicle Fleet Characteristics of New Plug-In Vehicle Owners. Institute of
Transportation Studies at University of California, Davis. Research Report – UCD-ITS-RR-13-02. Available at:
https://merritt.cdlib.org/d/ark:%252F13030%252Fm56692z3/1/producer%252F2013-UCD-ITS-RR-13-02.pdf.
Accessed: September 2016.
132 Tal, G., M.A. Nicholas, J. Woodjack, and D. Scrivano. February 2013. Who Is Buying Electric Cars in California?
Exploring Household and Vehicle Fleet Characteristics of New Plug-In Vehicle Owners. Institute of
Transportation Studies at University of California, Davis. Research Report – UCD-ITS-RR-13-02. Available at:
https://merritt.cdlib.org/d/ark:%252F13030%252Fm56692z3/1/producer%252F2013-UCD-ITS-RR-13-02.pdf.
Accessed: September 2016.
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the barrier.133 Another study revealed that when asked about the critical factors that may
influence their decision, the highest percentage (63 percent) of respondents cited the
ability to charge at home [other factors included battery range, total operating cost,
government subsidy].134
The Plug-in Electric Vehicle Owner Survey, managed by the Center for Sustainable Energy,
further highlighted the importance of subsidized or discounted chargers.135 Of those with an
installed Level 2 charger at home, 64 percent received a free or subsidized charger and 80
percent of them found the importance of the subsidy to install a Level 2 charger influential.
Thus, a home with an already installed (free) charger might influence residents to purchase
a PHEV. Another study reveals that 83.1 percent of the participants of a consumer survey
on plug-in hybrid electric vehicles stated that it would increase their comfort in purchasing
or leasing a PHEV by “a lot” or would be “a deciding factor” if they have recharge facilities
at home for easy overnight recharge.136 This evidence suggests that investment in a
residential charging infrastructure could result in an increased probability of a household
purchasing an EV. Another study also identified the importance of residential parking and
charging, suggesting that: 137
Fleet penetration of EVs beyond 22 percent will require residential infrastructure
investment to increase access to outlets near home parking;
Fleet penetration beyond 39 percent may require significant residential infrastructure
investment because many households will need to upgrade their electrical
infrastructure to charge multiple vehicles;
Fleet penetration beyond 47 percent will require residential charging to be available for
renters; and
Fleet penetration beyond 56 percent may require not only new chargers but also
additional residential parking, with associated logistics, space implications, and
environmental impacts.
The program to install charging stations in residential areas has the potential to fulfill an
important component to facilitate the level of conversion to EV that will be necessary if
133 Slavin, M.I. December 2013. Drivers and Barriers to Electric Vehicle Adoption. Published in EV World. Available
at: http://evworld.com/article.cfm?storyid=2076. Accessed: September 2016.
134 Accenture. 2011. Plug In Electric Vehicles Changing Perceptions, Hedging Bets - Accenture end-consumer
survey on the electrification of private transport. Available at: https://www.accenture.com/us-
en/~/media/Accenture/Conversion-Assets/DotCom/Documents/Global/PDF/Industries_9/Accenture-Plug-in-
Electric-Vehicle-Consumer-Perceptions.pdf. Accessed: September 2016.
135 California Center for Sustainable Energy (CCSE) and California Environmental Protection Agency - Air Resources
Board (ARB). 2012. California Plug-in Electric Vehicle Owner Survey. Available at:
https://energycenter.org/sites/default/files/docs/nav/policy/research-and-reports/California%20Plug-
in%20Electric%20Vehicle%20Owner%20Survey%20Report-July%202012.pdf. Accessed: September 2016.
136 Krupa, J.K., D.M. Rizzo, M.J. Eppstein, D.B. Lanute, D.E. Gaalema, K. Lakkaraju, and C.E. Warrender. 2014.
Analysis of a Consumer Survey on Plug-in Hybrid Electric Vehicles. Transportation Research Part A 64 (2014)
14-34. Available at: http://www.sciencedirect.com/science/article/pii/S0965856414000500.
Accessed: September y 2016.
137 Traut, E.J., T.C. Cherng, C. Hendrickson, and J.J. Michalek. 2013. US Residential Charging Potential for Electric
Vehicles. Transportation Research Park D 25 (2013) 139-145. Available at:
http://www.cmu.edu/me/ddl/publications/2013-TRD-Traut-etal-Residential-EV-Charging.pdf.
Accessed: September 2016.
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California is to meet its stated penetration targets and associated emission reduction goals.
Increased market penetration often results in a ‘neighbor effect’ of adoption, meaning that
as more people see neighbors and friends successfully adopting EVs, the fewer perceived
barriers remain.138 In short, as EVs become more common due to reduced costs, increased
availability of infrastructure and other incentives, members of the
neighborhood/community without an EV will be increasingly more likely to purchase and
use an EV.
Subsidies Incentivise EV Adoption
Given the rapid pace of EV technological improvement and the many policy efforts to
encourage EV adoption, economists and policy researchers have considered the
effectiveness of rebates and other incentives with influencing the rate of EV adoption.
Research suggests that rebates and other policies that reduce the overall price of EV
purchase and operations are one of the most effective at increasing rates of adoption.139
Policies that provide other benefits such as increasing the availability of public chargers,
carpool lane access, and emissions testing exemptions were also shown to be effective.
Economic models of EV purchasing behavior suggest that price is still a significant barrier to
adoption of EVs. Many models have evaluated the decision to select EVs compared with
internal combustion engine vehicles (ICEVs), as a function of cost, range, income of the
buyer, driving habits, price of gas, recharging infrastructure, ‘greenness’ including the
influence of neighbors and friends among other determinants of EV adoption.
Rebates and other incentives fundamentally work to reduce the cost of purchasing and then
operating an EV.140 While policies differ from state to state,141 adoption of EVs does
correlate strongly to subsidies and rebates offered.
California is currently one of the largest markets for EVs in the United States, and has, in
fact, been referred to as “America’s capital of plug-in cars.”142 Based on sales figures
tracked by the California Air Resources Board, Californians buy approximately 40 percent of
all plug-in vehicles sold in the United States143 (36 percent in 2015).144
138 Nelson-Nygaard Consulting Associates Inc. 2014. Removing Barriers to Electric Vehicle Adoption by Increasing
Access to Charging Infrastructure. Seattle Office of Sustainability & Environment. Available at:
http://www.seattle.gov/Documents/Departments/OSE/FINAL%20REPORT_Removing%20Barriers%20to%20EV
%20Adoption_TO%20POST.pdf. Accessed: September 2016.
139 Jin, Lingzhi, Stephanie Searle, and Nic Lutsey, 2014. Evaluation of State-Level U.S. Electric Vehicle Incentives,
White Paper for the International Council on Clean Transportation, October. Available at:
http://www.theicct.org/sites/default/files/publications/ICCT_state-EV-incentives_20141030.pdf.
140 Clinton, Bentley, Austin Brown, Carolyn Davidson, and Daniel Steinberg, 2015. Impact of Direct Financial
Incentives in the Emerging Battery Electric Vehicle Market: A Preliminary Analysis. National Renewable Energy
Laboratory. Department of Economics, University of Colorado – Boulder. February.
141 See DeShazo, J.R., CC Song, Michael Sin, and Thomas Gariffo, 2015. State of the Sates’ Plug-in Electric Vehicle
Policies, UCLA Luskin School of Public Affairs, March for a good review. Available at:
http://innovation.luskin.ucla.edu/sites/default/files/EV_State_Policy.pdf. Accessed: September 2016.
142 Jeff Cobb. February 2016. California Plug-in Sales Led the US Last Year with Nearly Five-Times Greater Market
Share. HybridCars.com. Available at: http://www.hybridcars.com/california-plug-in-sales-led-us-last-year-with-
nearly-five-times-greater-market-share/. Accessed: September 2016.
143 Dana Hull. September 2014. California charges ahead with electric vehicles. San Jose Mercury News. Available
at: http://www.mercurynews.com/business/ci_26493736/california-charges-ahead-electric-vehicles.
Accessed: September 2016.
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EV Usage Rate Exceeds Conventional Vehicles
An annual survey of California PEV owners145 shows that even though many households
with EVs also own a conventional gasoline or diesel car, they use the PEV for over 85
percent of work commute, personal errands, and shopping, while the conventional vehicle
is the primary vehicle for vacation travel. The following year’s survey shows that the
average PEV owner drives 28.9 miles per day, which is well within the electric range of
many eligible PEVs available in 2013.146
A survey conducted by the Union of Concerned Scientists (UCS)147 found that 64 percent of
respondents live in a household with two or more vehicles. This is consistent with a survey
of EV users, which reported that 79.4 percent of EV owners and potential owners had two
or more vehicles in the household.148 Conventional wisdom as well as economic theory
suggest that when households have at least one EV and one ICEV, they favour the EV and
use the more costly-to-drive ICEV for longer distance trips on the weekend, for hauling, or
if there is a need for more than five passengers.149 One detailed study found exactly this in
a broad survey of different types of households that have EVs. For example, one-car
households that switch from one ICEV to one EV showed very little difference in daily
driving distances nor the number of daily trips taken when they invested in an EV.150 But
the households that had one (or more) EV and at least one ICEV all showed that after three
months of EV ownership, the daily distance driven for the ICE declined, and the EV
increased so that the EV usage was about 45 percent higher in use. This is consistent with
survey data from Norway, which showed that 90 percent of EV owners said that the EV car
“Completely” or “To a High Degree” replaced their ICEV, with 66 percent of the
144 Extrapolated from Data Provided in: California New Car Dealers Association (CNCDA). February 2016. California
New Vehicle Registrations Expected to Remain Above 2 Million Units in 2016. Registrations through December
2015 since 2011. Revised figures for 2014. Available at:
http://www.cncda.org/CMS/Pubs/Cal%20Covering%204Q%2015.pdf. Accessed: September 2016.
AND
Electric Drive Transportation Association (EDTA). 2016. Electric Drive Sales Dashboard. Sales figures sourced
from HybridCars.com and direct reports submitted by EDTA member companies. Available at:
http://electricdrive.org/index.php?ht=d/sp/i/20952/pid/20952#sthash.5QBifqpG.EyVW8gqf.dpuf and
http://electricdrive.org/index.php?ht=d/sp/i/20952/pid/20952. Accessed: September 2016.
145 California Center for Sustainable Energy. 2012. California Plug-in Electric Vehicle Owner Survey. Available at:
https://energycenter.org/sites/default/files/docs/nav/policy/research-and-reports/California%20Plug-
in%20Electric%20Vehicle%20Owner%20Survey%20Report-July%202012.pdf. Accessed: September 2016.
146 California Center for Sustainable Energy. 2013. California Plug-in Electric Vehicle Driver Survey Results.
Available at: https://energycenter.org/sites/default/files/docs/nav/transportation/cvrp/survey-
results/California_Plug-in_Electric_Vehicle_Driver_Survey_Results-May_2013.pdf. Accessed: September 2016.
147 Union of Concerned Scientists, 2013, Electric Vehicle Survey Methodology and Assumptions; American Driving
Habits, Vehicle Needs, and Attitudes toward Electric Vehicles, December. Available at:
http://www.ucsusa.org/sites/default/files/legacy/assets/documents/clean_vehicles/UCS-and-CU-Electric-
Vehicle-Survey-Methodology.pdf. Accessed: September 2016.
148 Shahan, Zachary, 2015, Electric Cars: What Early Adopters and First Followers Want. Important Media.
Available at: http://cleantechnica.us2.list-
manage.com/subscribe?u=a897522b53d0853c85abbf9fa&id=a264ba3c49. Accessed: September 2016.
149 UCS, 2013.
150 Hwang, Sang-kyu, and Sang-hoon Son, 2015. Electric Vehicle User Mobility Analysis with Dashboard Camera in
Jeju Island, Korea. Paper presented at Electric Vehicle Symposium, EVS28, in Kintex, Korea, May 3-6, 2015.
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respondents living in two car households.151 This is also consistent with preliminary data
from Ford, which also suggests that with time – six months – the frequency of use of the
EV increases, and the ICEV use decreases.152
Accordingly, as EV penetration increases, the amount of miles driven for residential trips by
EV compared to conventional vehicles will grow at a disproportionately higher rate because
households with EVs will tend to rely on the EV for a large majority of their trips.
Estimated GHG Reduction
The main variables contributing to the calculated GHG benefit of installing residential EV
chargers and providing EV vehicle subsidies include the following assumptions:
Electric Vehicle Penetration: Based on the discussion above, a variety of factors will
contribute to high rates of electric vehicle penetration near Newhall Ranch. First, there
are already dozens of electric vehicle models available for purchase in California, and
the costs of batteries continue to decrease. Second, there are numerous statewide and
regional initiatives to help fund electric vehicle and infrastructure purchases, and many
policy goals aim to increase the number of EVs because vehicle electrification is critical
to achieving California’s long-term greenhouse gas reduction goals. Third, reliable
access to EV chargers is an important factor contributing to buying electric vehicles.
Therefore, the Project’s mitigation measures requiring that EV charging infrastructure
be made widely available and the provision of EV purchase incentives will encourage
EV ownership and use. Given the market trends, policy goals, infrastructure growth
and incentives, this analysis assumes that half the residential units facilitated by the
Project will have an EV by 2024.
Electrical Vehicle Usage Rate: As explained above, even though many households with
EVs also own a conventional gasoline or diesel car, they use the EV for over 85
percent of work commute, personal errands, and shopping, while the conventional
vehicle is the primary vehicle for vacation travel. Therefore, the evidence supports an
assumption that households with an EV will have a very high usage rate for residential
trips, even if the households also own a conventional vehicle.
EV Miles Driven From Residential Land Uses: Based on the commitment to install EV
chargers in all dwelling units, the subsidy for EV purchase, published peer reviewed
studies regarding EV usage behavior and EV adoption trends, and the state’s ongoing
effort to encourage EV adoption, it is anticipated that at least half of the dwelling units
in the Project will have an EV. As discussed above, studies have shown that
households tend to preferentially use the EV. Numerous other factors (e.g., declining
costs of EVs) are also anticipated to push the number of EV’s used by Project residents
to be even higher than that estimated here. Thus, the overall effect of this mitigation
measure is estimated to displace 50 percent of the miles driven from residential land
uses from traditional gasoline/diesel vehicles with electric vehicles.
151 Haugneland, Petter, and Hans Havard Kvisle, 2013. Norwegian Electric Car User Experiences, paper presented
at EVS27, Barcelona Spain, November.
152 Castrucci Alexandria, Mike 2015. Good Habits Pay Dividends for Electric Car Drivers. Posted on October 7, 2013.
Available at: http://www.mikecastruccialexandria.com/blog/electric-car-driving-habits/); Based on data from
MyFord Mobile app, available at: (https://www.myfordmobile.com/content/mfm/app/site/my-car/home.html.
Accessed: September 2016.
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Emission Factors: The analysis is based on the assumption that the 40% RPS for 2024
is achieved, and the gasoline/diesel CO2 emission factors are derived using California
Air Resource Board’s EMFAC2014 software model.
The calculations shown in Table 5-3 estimate the GHG reduction from replacing
conventional gasoline or diesel light-duty vehicles with electric vehicles. The table
calculates the estimated emission reduction for each mile driven in an electric vehicle as
compared to the default emission factor calculated by CalEEMod® in the mobile emissions
inventory. To ensure that the calculated Project benefit is in only the incremental increase
in EV usage beyond what is already anticipated, the emission factor and emissions
inventory incorporates the existing EV fleet penetration rates included in EMFAC2014. This
ensures that the VMT reduction benefits of the Project EVs does not double count the
benefit of the existing EVs. The calculation then estimates the average annual residential
traffic, after the reduction in VMT due to transportation demand management strategies is
applied. The GHG emissions reduction is the total miles displaces by EVs from this measure
multiplied by the emissions reduction per mile. The remaining project traffic GHG emissions
in Table 5-3 (35,457 MT CO2e/year) results after subtracting the GHG emissions
reductions due to residential EV (4,207 MT CO2e/year, respectively) from the remaining
mobile GHG emissions after TDMs from Table 5-5 (39,664 MT CO2e/year).
5.2.5 GCC-5. Commercial Development Area EV Chargers
The parking areas for commercial buildings on the Project site shall be equipped with
electric vehicle charging stations that provide charging opportunities to 7.5 percent of the
total number of required parking spaces. (“Commercial buildings” include retail, light
industrial, office, hotel, and mixed‐use buildings.) The electric vehicle charging stations shall
achieve a similar or better functionality as a Level 2 charging station. This mitigation
measure will complement the Project’s residential commitment to install charging station
for each single family and multifamily dwelling unit and subsidize the purchase of electric
vehicles. Overall, the Project will help support an increasingly inter-connected web of
charging infrastructure; the combination of commercial development area and residential
charging stations will encourage EV ownership and use.
As discussed in greater detail in the Residential EV Charger section above, a variety of
factors will contribute to high rates of electric vehicle penetration near Newhall Ranch.
There are already dozens of electric vehicle models available for purchase in California, and
the costs of batteries continue to decrease. There are statewide and regional initiatives to
help fund electric vehicle and infrastructure purchases, and ambitious goals to increase the
number of EVs on the road by 2025. Peer-reviewed studies show that vehicle electrification
is necessary to achieve California’s long-term greenhouse gas reduction goals. Reliable
access to EV chargers is an important factor contributing to buying electric vehicles.
Estimated GHG Reduction
The main variables contributing to the calculated GHG benefit of installing commercial
development area EV charging stations are as follows:
Electric Vehicle Penetration and Usage Rate: Charge station usage will vary from zero
hours per day to 24 hours per day for each electric vehicle charging station. Ramboll
Environ assumes a ten hour per day charger usage rate when in consideration of the
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anticipated increase in EV adoption throughout the state.153 As discussed in above, the
state will need to further its efforts to improve and increase EV penetration rates such
that the prevalence of EV will be greater and the use of the EV chargers will continue
to increase for EV chargers in a variety of locations. Furthermore, as discussed by
Bakker154 the fundamental challenge with EV adoption is range anxiety.
Charge Rate: The charge rate refers to the amount of power supplied from the charger
to the car battery per hour, or the range of miles the charger enables the car to travel
per hour (RPH). The US Department of Energy (USDOE) writes that a Level 2 charging
station is expected to charge 10 to 20 miles of RPH, depending on the circuitry.155
ChargePoint commercial Level 2 electric vehicle charging stations charge up to 25
RPH.156 Direct Current (DC) “fast charging” stations and future three-phase charging
options allow for much higher rates of charging.157 These charge rates are influenced
based on the technology for the actual charge rate of kilowatts per hour and also the
vehicle fuel efficiency (discussed further below). The technology for chargers,
batteries, and electric vehicle efficiency is expected to improve into the future. Thus,
we have assumed that the charging stations can provide 25 miles of driving range per
hour of charging.
Electric Vehicle Fuel Economy: Electric vehicle fuel economy reflects the amount of
electricity needed to drive a certain distance. Based on 2013 USDOE data, the range of
fuel economy in currently available electric vehicles ranges from 25 to 40 kilowatt-
hours per 100 miles (kWh/100 mi).158 This fuel economy varies depending on the
vehicle model, with examples of a 2012 Nissan Leaf achieving 34 kWh/100 mi and a
Tesla Roadster achieving 21.7 kWh/100 mi. The technology for batteries and electric
vehicle fuel economy is expected to improve into the future. Thus, we have assumed
that the electric vehicles will achieve a fuel economy of 25 kWh/100 mi to represent
the near-future electric vehicle fleet.
Emission Factors: The analysis is based on the assumption that the 40% RPS for 2024
is achieved, and the gasoline/diesel CO2 emission factors are derived using California
Air Resource Board’s EMFAC2014 software model.
The calculations shown in Table 5-4 estimate the GHG reduction from replacing
conventional gasoline or diesel light-duty vehicles with electric vehicles. The table
calculates the estimated range that each charging station is estimated to provide to electric
vehicles in miles per year, based on the charge station usage and charge station rate. The
153 Chang, D., et al. 2012. Financial Viability of Non-Residential Electric Vehicle Charging Stations. Available at:
http://innovation.luskin.ucla.edu/content/financial-viability-non-residential-electric-vehicle-charging-stations.
Accessed: September 2016.
154 Bakker, J.J. 2011. Contesting range anxiety: The role of electric vehicle charging infrastructure in the
transportation transition. Available at: http://alexandria.tue.nl/extra2/afstversl/tm/Bakker_2011.pdf.
Accessed: September 2016.
155 US Department of Energy (USDOE) Alternative Fuels Data Center. 2016. Charging Equipment. Available at:
http://www.afdc.energy.gov/fuels/electricity_infrastructure.html. Accessed: September 2016.
156 ChargePoint. 2015. Available at: http://www.chargepoint.com/news/2015/0702/defining-rph-miles-range-per-
hour-an-ev-charging-station-delivers/. Accessed: September 2016.
157 USDOE. op. cit.
158 USDOE. 2015. Available at: http://www.afdc.energy.gov/fuels/electricity_benefits.html. Accessed: September
2016.
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range for one station is multiplied by the total number of stations in the mitigation
commitment. This results in a total number of miles per year that will be driven in electric
vehicles instead of conventional vehicles. The difference between the total GHG emissions
from the conventional vehicles and the GHG emissions from the electric vehicles is the
emissions benefit from the charging stations.
5.2.6 GCC-6. Transportation Demand Management Program
The Newhall Ranch Transportation Demand Management (TDM) Plan (see Appendix E)
shall be implemented in order to reduce vehicle miles traveled resulting from Project build
out. The TDM Plan is designed to influence the transportation choices of residents,
students, employees, and visitors, and serves to enhance the utilization of alternative
transportation modes both on and off the Project site through the provision of incentives
and subsidies, expanded transit opportunities, bikeshare and carshare programs,
technology-based programs, and other innovative means.
Estimated GHG Reduction
The TDM program reduces annual vehicle miles traveled by 15.6 percent from the
Unmitigated Project. Since mobile GHG emissions are directly proportional to vehicle miles
traveled, this equates to a 15.6 percent reduction in mobile emissions. This reduction
calculation is shown in Table 5-5.
5.2.7 GCC-7. Traffic Signal Synchronization
The applicant or its designee shall work with the applicable agency(ies) with jurisdiction
over the local roadway network to facilitate traffic signal coordination throughout the
Project area. This program is described in detail in Appendix I.
Estimated GHG Reduction
The traffic signal coordination program reduces mobile GHG emissions by 2.99 percent
from the Unmitigated Project. This percent was determined using the CAPCOA GHG
reduction methodology for measure RPT-2.159 The percent reduction is applied sequentially
with the other mobile GHG mitigation measures to avoid double-counting. This reduction
calculation is shown in Table 5-6.
5.2.8 GCC-8. Electric School Bus Funding Program
The applicant or its designee shall provide funding for electric school buses.
Estimated GHG Reduction
The main variables contributing to the calculated GHG benefit of the Project’s commitment
to subsidizing the conversion to electric school buses are as follows:
Annual Average VMT: The annual average VMT refers to the number of miles a vehicle
runs each year. For school buses and transit buses, this metric is derived using
California Air Resource Board’s EMFAC2014 software model, based on vehicle model
years and speeds in Los Angeles County. EMFAC2014 data shows that school buses’
annual VMT is 13,801 miles per year (mi/yr) in 2024.
159 CAPCOA. Available at: http://www.capcoa.org/wp-content/uploads/2010/11/CAPCOA-Quantification-Report-9-
14-Final.pdf. Accessed: September 2016.
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Electric Bus Fuel Economy: Electric vehicle fuel economy reflects the amount of
electricity needed to drive a certain distance. Buses from two existing electric bus
manufacturers are Proterra and BYD are used to estimate electric bus fuel economy.
Proterra’s 40-foot and BYD’s electric bus fuel economy is 1.7 kilowatt-hours per mile
(kWh/mi) 160 and 1.87 kWh/mi,161 respectively. The fuel economy used to calculate the
electric bus electricity usage was an average of Proterra and BYD’s specification:
1.8 kWh/mi. The technology for batteries and electric vehicle fuel economy is expected
to improve into the future, so using current electric bus specifications is a conservative
assumption.
Emission Factors: The analysis is based on the assumption that the 40 percent RPS for
2024 is achieved, and the gasoline/diesel CO2 emission factors are derived using
California Air Resource Board’s EMFAC2014 software model.
The data from the California Air Resource Board’s EMFAC2014 software model provided the
GHG emission factors for the Compressed Natural Gas (CNG) buses. The CNG emission
factors were identified through data from the web-based EMFAC2014 tool and the desktop
application. The web-based EMFAC2014 model provided an ‘urban transit diesel emission
factor’ which represents a composite of both CNG and diesel buses. To get separated CNG
and diesel emission factors for urban transit buses, the EMFAC2014 Desktop Application
was run in the Project-Level Assessment Mode to generate an estimate of the ratio of CNG
and diesel buses. For the EMFAC2014 Desktop Application analysis, the temperature and
relative humidity were based on the EMFAC2014 Los Angeles County default values. The
data from the web-based EMFAC2014 program and the ratio of CNG and diesel buses from
the EMFAC Desktop application were used to derive the CNG bus emission factor for 2024.
Conservatively, emissions from idling and starting the engine for the CNG buses were not
included in the emissions calculations.
The calculations shown in Table 5-7 estimate the GHG reduction from replacing CNG
school buses with electric buses for 2024. The tables show the total number of miles per
year that will be driven in electric buses instead of CNG buses, the GHG emissions if CNG
buses were used, and the GHG emissions for the total miles based on electric vehicle fuel
economy and the electric grid emission factor. The difference between the total GHG
emissions from the CNG buses and the GHG emissions from the electric buses is the
emissions benefit from the electric bus replacement of CNG buses.
5.2.9 GCC-9. Subsidy for Electric Transit Buses
The applicant or its designee shall provide a subsidy of $100,000 per bus for the
replacement of up to one diesel or compressed natural gas transit buses with electric
buses.
Estimated GHG Reduction
The calculation is the same as for school buses, except for transit buses; EMFAC2014 data
shows annual VMT of 39,909 mi/yr in 2024.
The calculations shown in Table 5-8 estimate the GHG reduction from replacing CNG
transit buses with electric buses for 2024. The tables show the total number of miles per
160 Proterra. Available at: http://byd.com/na/ebus/ebus.html. Accessed: September 2016.
161 BYD. Available at: http://byd.com/na/ebus/ebus.html. Accessed: September 2016.
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year that will be driven in electric buses instead of CNG buses, the GHG emissions if CNG
buses were used, and the GHG emissions for the total miles based on electric vehicle fuel
economy and the electric grid emission factor. The difference between the total GHG
emissions from the CNG buses and the GHG emissions from the electric buses is the
emissions benefit from the electric bus replacement of CNG buses.
5.2.10 GCC-10. Carbon Credits
Prior to obtaining grading permits for the Project, the Project applicant or its designee will
fully mitigate the related construction and vegetation change GHG emissions.
Estimated GHG Reduction
The estimated emissions for construction and vegetation change will be offset.
5.2.11 GCC-11. Off-site Retrofit Program
The Project applicant or its designee shall fund the Building Retrofit Program (Retrofit
Program), located in Appendix G. Building retrofits covered by the Retrofit Program can
include, but are not limited to: cool roofs, solar panels, solar water heaters, smart meters,
energy efficient lighting (including, but not limited to, light bulb replacement), energy
efficient appliances, energy efficient windows, insulation, and water conservation
measures.
Estimated GHG Reduction
The Building Retrofit Program provides funding that will be used to implement various
improvements to the built environment. Table 5-9 provides a reasonable approximation of
how the Building Retrofit Program may achieve the estimated GHG reductions (see also
Appendix J). The emission estimates illustrate an estimate of how the Project may achieve
the GHG emission reductions. The emission ratios in the Retrofit Program are based on an
estimate of the 80 percent of the emission reductions being achieved in connection with the
Project’s residential development, and 20 percent of the emission reductions being
achieved in connection with the Project’s with commercial development.
5.2.12 GCC-12. Off-site Electric Vehicle Chargers
The Project applicant or its designee shall install, or cause to be installed, off-site electric
vehicle charging stations. Off-site electric vehicle charging stations servicing 196 parking
spaces would be required if the maximum allowable development facilitated by the
Landmark Village Project occurs; fewer electric vehicle charging stations would be required
if the maximum build-out does not occur. The electric vehicle charging stations shall
achieve a similar or better functionality as a Level 2 charging station and may service one
or more parking spaces.
Estimated GHG Reduction
The estimated GHG reductions follow the same methodology as described above (see
Table 5-4 and Section 5.2.5. It is estimated that 196 parking spaces will have access to a
charging station to estimate the GHG emission reductions benefit.
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5.2.13 GCC-13. GHG Reduction Plan
This section evaluates the amount of GHG reductions that will be required to fully offset all
remaining GHG emissions to zero over the project life, defined as 30 years. 162 The analysis
here estimates how the reductions over time would be accounted in determining the
necessary GHG reductions.
The figure shown in Appendix K illustrates the interpolation of the emissions modeled in
CalEEMod® starting in 2020 through the project life for the last piece of development
completed in 2024 to estimate the GHG offsets required. The reason for the 2020 and 2030
CalEEMod® model runs is to develop factors to account for the anticipated reduction in
emissions due to existing regulatory programs (i.e., the reductions of energy and water-
related emissions due to the 50 percent RPS and the reductions of mobile-related
emissions due to the fleet fuel efficiency improvements predicted by EMFAC2014) that will
reduce GHG emissions over the lifetime of the Project. The full description of offsets
calculation methodology is shown in Table K-1 through Table K-7 in Appendix K. This
analysis shows that the offsets requirement for the Project will be 24,608 MT per year for
the project life. This estimate is considered a conservative estimate as it is anticipated that
further regulatory programs and technology will develop in the future to further reduce
GHG emissions.
Prior to obtaining building permits for an incremental level of development within the
Project site, the incremental operational GHG emissions over the Project life associated
with such building permits that must be offset (the “Incremental Operational GHG
Emissions”) will be equal to the sum of: (1) the number of proposed residential units
covered by the applicable building permit multiplied by 107.45 MTCO2e; and (2) every
thousand square feet (“TSF”) of proposed commercial development covered by the
applicable building permit multiplied by 542.40 MTCO2e. For example, to obtain a building
permit for 75 residential units and 40,000 square feet of commercial development, the
Incremental Operational GHG Emissions would be: 75 units x 107.46 MTCO2e/unit + 40
TSF. x 542.40 MTCO2e/TSF = 29,756 MTCO2e.
162 The SCAQMD GHG Working Group proposed that off-site mitigation could be used to mitigate GHG emissions
from a project under CEQA. The SCAQMD indicated that offsets should have a 30-year project life unless a
shorter project life could be ensured based on a binding permit condition or other legal limit. SCAQMD, 2008.
Available at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-
significance-thresholds/ghgboardsynopsis.pdf?sfvrsn=2. Accessed: September 2016.
SR000479
Facts, Findings, and Statement of Overriding Considerations
Regarding the Environmental Effects of the Approval of
The Landing by San Manuel
(State Clearinghouse No. 2020100067)
General Plan Amendment No. 20-02
Development Code/Zoning Map Amendment No. 20-03
Specific Plan Amendment No. 20-01
Development Plan No. 20-02
Lead Agency
City of San Bernardino
201 North E Street, 3rd Floor
San Bernardino, CA 92401
CEQA Consultant
T&B Planning, Inc.
3200 El Camino Real, Suite 100
Irvine, CA 92602
Project Applicant
San Manuel Band of Mission Indians
26569 Community Center Drive
Highland, CA 92346
February 25, 2021
Table of Contents
Section Name and Number Page
The Landing by San Manuel State Clearinghouse No. 2020100067
Facts, Findings, and Statement of Overriding Considerations February 25, 2021
Page i
I. INTRODUCTION ....................................................................................................................................................... 1
II. PROJECT SUMMARY .............................................................................................................................................. 1
A. Project Site Definitions ........................................................................................................................................ 1
B. Site Location ......................................................................................................................................................... 2
C. Project Description ............................................................................................................................................... 2
1. General Plan Amendment No. 20-02 (GPA 20-02) ......................................................................................... 2
2. Development Code/Zoning Map Amendment No. 20-03 (DCA 20-03) ........................................................... 2
3. Specific Plan Amendment No. 20-01 (SP 20-01) ............................................................................................. 2
4. Development Permit Type-D No. 20-02 (DP-D 20-02) ................................................................................... 3
D. City of San Bernardino Actions Covered By the EIR ....................................................................................... 4
E. Project Objectives ................................................................................................................................................ 4
III. ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION ...................................................................... 5
IV. INDEPENDENT JUDGMENT FINDING ................................................................................................................ 7
V. FINDING OF NO LEGAL REQUIREMENT TO RECIRCULATE THE EIR ................................................... 8
VI. GENERAL FINDING ON MITIGATION MEASURES ........................................................................................ 8
VII. ENVIRONMENTAL IMPACTS AND FINDINGS ................................................................................................. 9
A. Impacts Found Not to be Significant as Part of the Initial Study Process ....................................................... 9
1. Aesthetics ........................................................................................................................................................ 9
2. Agriculture and Forestry Resources ............................................................................................................. 11
3. Air Quality ..................................................................................................................................................... 11
4. Biological Resources ..................................................................................................................................... 12
5. Cultural Resources ........................................................................................................................................ 14
6. Energy ........................................................................................................................................................... 14
7. Geology and Soils ......................................................................................................................................... 16
8. Hazards and Hazardous Materials ............................................................................................................... 18
9. Hydrology and Water Quality ....................................................................................................................... 20
10. Land Use and Planning ................................................................................................................................. 25
11. Mineral Resources ........................................................................................................................................ 25
12. Noise ............................................................................................................................................................. 26
13. Population and Housing ............................................................................................................................... 26
14. Public Services .............................................................................................................................................. 27
15. Recreation ..................................................................................................................................................... 28
16. Transportation .............................................................................................................................................. 28
17. Utilities and Service Systems ......................................................................................................................... 29
18. Wildfire.......................................................................................................................................................... 31
B. Impacts Identified in the EIR as No Impact or Less than Significant Impact - No Mitigation
Required ....................................................................................................................................................... 32
1. Air Quality ..................................................................................................................................................... 32
2. Cultural Resources ........................................................................................................................................ 33
3. Greenhouse Gas Emissions ........................................................................................................................... 34
4. Hydrology and Water Quality ....................................................................................................................... 35
5. Land Use and Planning ................................................................................................................................. 36
6. Noise ............................................................................................................................................................. 37
7. Transportation .............................................................................................................................................. 37
Table of Contents
Section Name and Number Page
The Landing by San Manuel State Clearinghouse No. 2020100067
Facts, Findings, and Statement of Overriding Considerations February 25, 2021
Page ii
8. Tribal Cultural Resources ............................................................................................................................. 38
C. Impacts Identified in the EIR as Less than Significant with Mitigation Incorporated ................................ 38
1. Biological Resources ..................................................................................................................................... 38
2. Cultural Resources ........................................................................................................................................ 41
3. Transportation .............................................................................................................................................. 42
D. Impacts Determined by the EIR to be Significant and Unavoidable ............................................................. 44
1. Air Quality ..................................................................................................................................................... 44
2. Greenhouse Gas Emissions ........................................................................................................................... 52
3. Noise ............................................................................................................................................................. 54
4. Transportation .............................................................................................................................................. 56
VIII. SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL EFFECTS ................................................................... 57
IX. GROWTH-INDUCING IMPACTS ......................................................................................................................... 58
X. PROJECT ALTERNATIVES .................................................................................................................................. 59
A. No Development Alternative (NDA) ................................................................................................................. 59
B. No Project Alternative (NPA)............................................................................................................................ 60
C. Reduced Project Alternative (RPA) .................................................................................................................. 61
D. Range of Alternatives ......................................................................................................................................... 62
XI. STATEMENT OF OVERRIDING CONSIDERATIONS ..................................................................................... 63
XII. ADOPTION OF A MONITORING PLAN FOR MITIGATION MEASURES .................................................. 65
XIII. APPROVING THE PROJECT ................................................................................................................................ 65
XIV. REGARDING STAFF DIRECTION ....................................................................................................................... 65
XV. REGARDING CONTENTS AND CUSTODIAN OF RECORD .......................................................................... 65
The Landing by San Manuel State Clearinghouse No. 2020100067
Facts, Findings, and Statement of Overriding Considerations February 25, 2021
Page 1
I. INTRODUCTION
The City of San Bernardino (“City”) has completed an Environmental Impact Report (“EIR”; State
Clearinghouse Number 2020100067) for the proposed The Landing by San Manuel project and associated
applications (hereafter, the “Project” or “proposed Project”). The City is the Lead Agency for the purposes
of preparing and certifying the EIR pursuant to §§ 15050 and 15367 of the State California Environmental
Quality Act (CEQA) Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.).
The purpose of this EIR is to evaluate the potential environmental impacts of the proposed Project, which
consists of applications for a General Plan Amendment (GPA 20-02), Development Code/Zoning Map
Amendment (DCA 20-03), an Amendment to the San Bernardino Alliance California Specific Plan (SP 20-
01), and a Development Permit Type-D (DP-D 20-02). In compliance with § 21002.1 of the CEQA statute
and § 15002 of the State CEQA Guidelines, the City, as Lead Agency, has prepared an EIR to (1) provide
information the general public, the local community, responsible and interested public agencies and the
City’s decision-making bodies and other organizations, entities, and interested persons of the potential
environmental effects of the proposed Project, feasible measures to reduce potentially significant
environmental effects, and alternatives that could reduce or avoid the significant effects of the proposed
Project, (2) enable the City to consider environmental consequences when deciding whether to approve the
proposed Project, and (3) to satisfy the substantive and procedural requirements of CEQA.
The City Council of the City of San Bernardino (the “City Council”) in approving Project, makes the
Findings described below and adopts the Statement of Overriding Considerations presented at the end of the
Findings. The Findings are based upon the entire record before the City Council, including the EIR prepared
for the Project by the City acting as lead agency under CEQA. The City adopts the facts and analyses in the
EIR, which are summarized herein for convenience. The omission of some detail or aspect of the EIR herein
does not mean that it has been rejected by the City.
Hereafter, the Notice of Preparation, Notice of Availability, Draft EIR, Technical Studies, Final EIR
(containing responses to public comments on the Draft EIR and text and exhibit revisions to the Draft EIR),
and the Mitigation Monitoring and Reporting Program (MMRP) will be referred to collectively herein as the
“EIR” unless otherwise specified.
II. PROJECT SUMMARY
A. Project Site Definitions
The Project Applicant (San Manuel Band of Mission Indians) submitted applications to the City of San
Bernardino for a General Plan Amendment (GPA), Development Code/Zoning Map Amendment (DCA),
Specific Plan Amendment (SP), and Development Permit Type-D (DP-D). The Project’s DP-D application
seeks to entitle a 52.97-acre property for development with a 1,153,644 square foot (s.f.) warehouse building
and associated site improvements. As part of the Project’s GPA, DCA, and SP applications, the
approximately 49.6-acre Third Street District of the San Bernardino Alliance California Specific Plan
(SBAC-SP) would be reconfigured to add approximately 12.89 acres to the SBAC-SP and remove
approximately 4.97 acres from the SBAC-SP, yielding a reconfigured Third Street District of approximately
57.52 acres (the 52.97 acres subject to the DP-D application and 4.55 acres to the east that is already
included in the Third Street District). Considering the geographic extent of all applications, the 62.49 acres
that would be affected by the Project’s GPA, DCA, and SP applications are referred to herein as the “Project
Site,” while the 52.97 acres that are proposed for development with warehouse uses as part of the Project’s
DP-D application are referred to as the “Development Site.”
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Page 2
B. Site Location
The Project Site is located immediately south of 3rd Street, north of the San Bernardino International Airport
(SBIA) property and W Street, east and west of Victoria Avenue, and approximately 0.5-mile west of
Alabama Street. The 52.97-acre Development Site portion of the Project Site is bounded by Victoria Avenue
to the west, 3rd Street to the north, private property to the east, the 3rd Street/Central Avenue intersection to
the northwest, and W Street to the south. The northern boundary of the Project Site is coterminous with the
jurisdictional boundary line between the City of San Bernardino and the City of Highland.
C. Project Description
As previously indicated, the Project Applicant (San Manuel Band of Mission Indians) submitted applications
to the City of San Bernardino for a General Plan Amendment (GPA 20-02), Development Code/Zoning Map
Amendment (DCA 20-03), an Amendment to the San Bernardino Alliance California Specific Plan (SP 20-
01), and a Development Permit Type-D (DP-D 20-02). As described in more detail below, approval of the
proposed Project would allow for the future development of a 1,153,644 square foot (s.f.) warehouse
building and associated site improvements, and would facilitate the reconfiguration of the Third Street
District of the SBAC-SP.
1. General Plan Amendment No. 20-02 (GPA 20-02)
The City of San Bernardino General Plan currently designates approximately 49.60 acres of the 62.49-acre
Project Site for “Industrial Light (IL)” land uses and designates an approximate 12.89-acre area in the
southern portion of the Development Site for “Public Facility/Quasi-Public (PF)” land uses. Proposed GPA
20-02 would change the land use designation on the approximately 12.89 acres of the Development Site from
“Public Facility/Quasi-Public (PF)” to “Industrial (IL).” In addition, GPA No. 20-02 would change the land
use designation of approximately 4.97 acres owned by the San Bernardino International Airport Authority
(SBIAA) west of the Development Site and west of Victoria Avenue from “Industrial Light (IL)” to “Public
Facility/Quasi-Public (PF).” Approval of GPA 20-02 would facilitate the reconfiguration of the Third Street
District of the SBAC-SP, and also would allow for construction of the light industrial/warehouse use
proposed by DP-D 20-02, which is described below.
2. Development Code/Zoning Map Amendment No. 20-03 (DCA 20-03)
The City of San Bernardino designates approximately 49.60 acres of the 62.49-acre Project Site as “Specific
Plan Alliance of California – 3rd Street (SP-AC),” and designates approximately 12.89 acres in the southern
portion of the Development Site as “Public Facilities (PF).” The proposed Development Code/Zoning
Amendment No. 20-03 (DCA 20-03) would change the Zoning Map classification of the 12.89 acres from
“PF” to “SP-AC.” In addition, DCA 20-03 would change the zoning classification of approximately 4.89
acres of the Project Site located west of Victoria Avenue owned by the Inland Valley Development Agency
(IVDA) from “SP-AC” to “PF.” Approval of DCA 20-03 would facilitate the reconfiguration of the Third
Street District of the SBAC-SP, and also would allow for construction of the light industrial/warehouse use
proposed by DP-D 20-02, which is described below.
3. Specific Plan Amendment No. 20-01 (SP 20-01)
A portion of the Development Site (40.08 acres), in addition to approximately 4.55 acres to the immediate
east and approximately 4.97 acres to the west of Victoria Avenue, comprise the existing Third Street District
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Page 3
of the SBAC-SP. In total, the Third Street District is 49.6 acres. Approximately 12.89 acres of the
Development Site are not currently located within the boundaries of the SBAC-SP. SP 20-01 is proposed in
order to reconfigure the boundaries of the Third Street District and SBAC-SP to encompass the entire 52.97-
acre Development Site, in addition to the 4.55 acres to the west that is already in the SBAC-SP boundary.
Specifically, proposed SP 20-01 would add approximately 12.89 acres in the southern portion of the
Development Site to the boundaries of the Third Street District of the SBAC-SP, and would remove
approximately 4.97 acres located west of Victoria Avenue from the SBAC-SP boundaries. As a result, the
reconfigured Third Street District would comprise approximately 57.52 acres (the 52.97-acre Development
Site and 4.55 acres to the east that is already located in the Third Street District). With approval of SP 20-01,
the 4.97 acres to be removed from the Third Street District boundaries would no longer be subject to the
development standards and requirements of SBAC-SP. Due to the proposed boundary change and acreage
adjustment for the Third Street District, SP 20-01 proposes to increase the permitted building square footage
in the Third Street District from 1,080,288 s.f. to 1,252,350 s.f., while maintaining the maximum FAR at 0.5.
In addition, SP 20-01 proposes to change the minimum setback for parking from Major Arterials (3rd Street)
from 20 feet to 9 feet. As described below under DP-D 20-02, the Project Applicant is proposing an
enhanced landscape treatment along 3rd Street in part due to the proposed setback reduction to 9 feet.
4. Development Permit Type-D No. 20-02 (DP-D 20-02)
DP-D 20-02 would allow for development of the 52.97-acre Development Site with a proposed 1,153,644 s.f.
warehouse building and associated site improvements. The building is designed to contain approximately
20,000 s.f. of ancillary office space, 73,500 s.f. of leasable mezzanine space, and 1,060,144 s.f. of warehouse
space. While the ultimate tenant of the proposed building is not currently known and no potential tenant is
currently being pursued, the Project Applicant anticipates that the building would be occupied by a high-cube
fulfillment center user with up to 1/3 of the building used for high-cube cold storage uses.
Pedestrian entrances into the building are proposed at all four corners of the building. A total of 218 dock
doors are proposed, including 113 dock doors along the north side of the building and 105 dock doors along
the southern portion of the building. Approximately 365 truck trailer parking stalls are proposed to the north,
south, and east of the building. Approximately 422 passenger vehicle parking spaces (including accessible
parking spaces) are proposed, a majority of which are proposed to the west of the building with a smaller
passenger vehicle parking area proposed to the east of the building. Additionally, a 30-foot-wide fire lane is
proposed around the building and in the western passenger vehicle parking lot.
Driveway connections serving the industrial warehouse building would include two driveways along 3rd
Street, two driveways along Victoria Avenue, and one driveway along W Street in the southwest corner of
the Development Site. The driveway at the southeastern portion of the site connecting with W Street is
designed as the primary truck entry and exit driveway. Trucks would enter the driveway, have access to a
truck staging parking area, and enter through a security gate. The northern driveway connecting with
Victoria Avenue would be restricted to right-turn-in, right-turn-out, and would accommodate passenger
vehicles, only. The southern driveway along Victoria Avenue would have full access, and would serve
passenger vehicles, only. The driveways along 3rd Street would provide for full access, and would
accommodate both passenger vehicles and truck traffic. In the northeast corner of the site, a secured (gated)
secondary access driveway for use by the SBIA is provided. This driveway would extend along the eastern
boundary of the Development Site and extend off-site to provide access to the SBIA property to the south.
This driveway would replace an existing driveway that the SBIA uses in the same approximate location
under existing conditions.
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Facts, Findings, and Statement of Overriding Considerations February 25, 2021
Page 4
As part of the DP-D 20-02 application, an existing water tower is planned to be relocated to the northwest
corner of the Development Site, assuming it is structurally stable enough to be moved. If relocation of the
existing water tower is not feasible, a replica water tower is planned to be erected at the northwest corner of
the Development Site. The water tower is planned to serve as the centerpiece of an approximate 1.1-acre
landscaped area planned at the northwest corner of the Development Site, which also is designed to include a
walking path, picnic tables, interpretive columns, and a monument sign. A bus stop to accommodate an
Omnitrans Tripper route is planned on the Development Site’s frontage with Victoria Avenue, just south of
3rd Street.
D. City of San Bernardino Actions Covered By the EIR
The following discretionary and administrative actions are required of the City to implement the Project. The
EIR prepared for the Project covers all discretionary and administrative approvals which may be needed to
construct and implement the Project, whether or not they are explicitly listed below.
Approve General Plan Amendment No. 20-02 (GPA 20-02);
Approve Development Code Amendment No. 20-03 (DCA 20-03);
Approve Specific Plan Amendment No. 20-01 (SP 20-01);
Approve Development Permit Type D No. 20-02 (DP-D 20-02);
Approve Conditions of Approval for DP-D 20-02;
Approve final maps, parcel mergers, or parcel consolidations as may be necessary;
Approve conditional or temporary use permits, if required;
Issue grading permits;
Issue building permits;
Approve road improvement plans;
Issue encroachment permits;
Accept public right-of-way dedications; and
Approve street vacations.
E. Project Objectives
The underlying purpose and goal of the proposed Project is to accomplish the reuse of underutilized property
that was formerly part of the Norton Air Force Base (AFB) with an economically viable, employment-
generating use that is compatible with the SBIA. This underlying goal aligns with various aspects of the
Southern California Association of Governments’ (SCAG’s) 2020-2045 Regional Transportation
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Facts, Findings, and Statement of Overriding Considerations February 25, 2021
Page 5
Plan/Sustainable Communities Strategy (RTP/SCS; also referred to as “Connect SoCal”), particularly the
facilitation of goods movement industries and the generation of local employment opportunities that can
reduce the need for long commutes to and from work. The following objectives are intended to achieve these
underlying purposes:
A. To expand economic development, facilitate job creation, and increase the tax base for the City of
San Bernardino by establishing new industrial development adjacent to established and planned
industrial areas.
B. To attract new employment-generating businesses in the City of San Bernardino, thereby growing the
economy and providing a more equal jobs-housing balance in the local area that will reduce the need
for members of the local workforce to commute outside the area for employment.
C. To develop vacant or underutilized property on the former Norton AFB with a use that is compatible
with the SBIA and that achieves a maximized floor area ratio per regulatory allowances to take full
advantage of the development potential of the property.
D. To develop a use that has architectural design and operational characteristics that are compatible with
other existing and planned developments in the local area.
E. To develop a Class A light industrial building in the City of San Bernardino that is designed to meet
contemporary industry standards and be economically competitive with similar industrial buildings in
the local area and region.
F. To attract businesses that can expedite the delivery of essential goods to consumers and businesses
around the SBIA, in the City of San Bernardino, and in the region beyond the City’s boundary.
G. To develop light industrial and warehousing uses with loading docks in close proximity to designated
truck routes and the State highway system to avoid or shorten truck-trip lengths on other roadways.
H. To modify the boundary of the SBAC-SP Third Street District to form a more viably-shaped area for
industrial development.
I. To add interpretive elements in public streetscape near the SBIA to convey the area’s history and
culture.
III. ENVIRONMENTAL REVIEW AND PUBLIC PARTICIPATION
The City conducted an extensive environmental review of the Project to ensure that the City’s decision
makers and the public are fully informed about potential significant environmental effects of the Project; to
identify ways that environmental damage can be avoided or significantly reduced; to prevent significant,
avoidable damage to the environment by requiring changes in the Project through the use of mitigation
measures which have been found to be feasible; and to disclose to the public the reasons why the City has
approved the Project in the manner chosen in light of the significant environmental effects which have been
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identified in the EIR. In order to do this, the City, acting as lead agency under CEQA, undertook the
following:
Prepared a CEQA Environmental Initial Study, dated September 30, 2020, to determine the scope
of the EIR and a Notice of Preparation (NOP), dated September 30, 2020, to indicate that an EIR
would be prepared to evaluate the Project’s potential to impact the environment. The Notice of
Preparation identified the environmental issues to be analyzed in the Project’s EIR as: Air
Quality, Biological Resources, Cultural Resources, Greenhouse Gas Emissions, Hydrology and
Water Quality, Land Use and Planning, Noise, Transportation, and Tribal Cultural Resources;
Filed the NOP with the California Office of Planning and Research (the “State Clearinghouse”)
for distribution to Responsible Agencies, Trustee Agencies, and other interested parties on
October 5, 2020, for a 30-day public review period. The NOP was distributed for public review
to solicit responses that would help the City identify the full scope and range of potential
environmental concerns associated with the Project so that these issues could be fully examined
in the EIR.
Held a publicly-noticed EIR Scoping Meeting on October 14, 2020, to solicit comments from the
public on the environmental issue areas that should be analyzed in the EIR. Due to the State
Emergency related to COVID-19 and as allowed pursuant to Executive Order N-29-20, the City
of San Bernardino hosted the EIR Scoping Meeting via an internet-based video and phone
conferencing service. The EIR Scoping Meeting provided public agencies, interested parties, and
members of the general public an additional opportunity to learn about the Project, the CEQA
review process, and how to submit comments on the scope and range of potential environmental
concerns to be addressed in the EIR;
Sent a Notice of Completion and copies of the Draft EIR to the California Office of Planning and
Research, State Clearinghouse, on November 23, 2020;
Filed a Notice of Availability with the San Bernardino County Clerk on November 23, 2020,
informing the public that the Draft EIR was available for a 45-day review period beginning on
November 23, 2020, and ending on January 6, 2021;
Mailed the Notice of Availability to all Responsible Agencies, Trustee Agencies, other interested
parties, and organizations and individuals who had previously requested the Notice on November
23, 2020;
Mailed the Notice of Availability to all property owners within a 500-foot radius of the Project
Site on November 23, 2020;
Placed copies of the Draft EIR on the City’s website, at the City Community Development,
Planning Division’s public counter and at the public library located at 555 West 6th St, San
Bernardino, CA 92410.
Published the Notice of Availability in the San Bernardino Sun, which is the newspaper of
general circulation in the area affected by the Project, on November 21, 2020;
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Prepared responses to comments on the Draft EIR received during the 45-day comment period on
the Draft EIR, which have been included in the Final EIR;
Published a notice on January 30, 2021, in the San Bernardino Sun, the newspaper of general
circulation in the area affected by the Project, that the Planning Commission would hold a public
hearing on February 9, 2021, to recommend to the City Council the certification of the Final EIR
as having been prepared in compliance with CEQA and the approval of the Project;
Mailed notice of the Planning Commission hearing to all property owners within a 500-foot
radius of the Project Site on January 29, 2021
Sent notice of the Planning Commission’s hearing to all organizations and individuals who had
previously requested notification of anything having to do with the Project on January 29, 2021;
Held a public hearing of the Planning Commission on February 9, 2021;
Published a notice on March 4, 2021, in the San Bernardino Sun, the newspaper of general
circulation in the area affected by the Project, that the City Council would hold a hearing on
March 17, 2021, to consider certification of the Final EIR as having been prepared in compliance
with CEQA and approve the Project;
Mailed notice of the City Council hearing to all property owners within a 500-foot radius of the
Project Site on March 3, 2021;
Sent notice of the City Council’s hearing to all organizations and individuals who had previously
requested notification of anything having to do with the Project on March 3, 2021;
Held a public hearing of the City Council on March 17, 2021, and, after full consideration of all
comments, written and oral, certified that the Final EIR had been completed in compliance with
CEQA and approved the Project;
All of the documents and notices identified above and all of the documents and sources of information that
are required to be part of the Project’s administrative record pursuant to Public Resources Code §21167.6(e)
are on file with the City’s Community Development Department, Planning Division, located at 201 North E
Street, 3rd Floor, San Bernardino, CA 92401. Questions should be directed to Elizabeth Mora-Rodriguez,
Associate Planner with the City’s Community Development Department.
IV. INDEPENDENT JUDGMENT FINDING
Finding: The EIR for the Project reflects the City’s and the City Council’s independent judgment and
analysis.
Facts in Support of the Finding: The EIR was prepared by T&B Planning, Inc., an independent consulting
firm hired and funded by the Project Applicant but working under the
supervision and direction of Planning Division staff of the City of San
Bernardino’s Community Development Department. The City Council,
as the City’s final decision-making body for the Project, received and
reviewed the Final EIR and the comments, written and oral, provided by
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public agencies and members of the public prior to certifying that the
Final EIR complied with CEQA. The professional qualifications and
reputation of the EIR Consultant, the supervision and direction of the
EIR Consultant by City staff, the independent review of the Draft EIR by
the City’s Development and Environmental Review Committee
(D/ERC), and the thorough and independent review of the Draft EIR and
Final EIR, including comments and responses, by City staff, the review
and careful consideration by the Planning Commission of the Final EIR,
including comments and responses, and the review and careful
consideration by the City Council of the Final EIR, including comments
and responses, all conclusively show that the Final EIR is the product of
and reflects the independent judgment and analysis of the City of San
Bernardino as the Lead Agency, and of the City Council as the decision-
making body for the Project.
V. FINDING OF NO LEGAL REQUIREMENT TO RECIRCULATE THE EIR
Finding: The City Council finds that the Final EIR does not add significant new information to the Draft
EIR (subsequently referred to as “Draft EIR” or “DEIR”) that would require recirculation of the
EIR.
Facts in Support of the Finding: The City Council recognizes that the Final EIR incorporates information
obtained and produced after the Draft EIR was completed and that the
Final EIR contains additions, amplifications, clarifications, and minor
modifications to the Draft EIR. The City Council has reviewed and
considered the Final EIR and all of the information contained in the Final
EIR and has determined that the new information added to the Final EIR
does not involve a new significant environmental impact, a substantial
increase in the severity of an environmental impact, nor a feasible
mitigation measure or an alternative considerably different from others
previously analyzed that the Project applicant declined to adopt and that
would clearly lessen the significant environmental impacts of the Project.
No information provided to the City Council indicates that the Draft EIR
was inadequate or conclusory or that the public was deprived of a
meaningful opportunity to review and comment on the Draft EIR.
VI. GENERAL FINDING ON MITIGATION MEASURES
In preparing the Conditions of Approval for this Project, City staff incorporated the mitigation measures
recommended in the EIR and its MMRP as applicable to the Project. In the event that the Conditions of
Approval do not use the exact wording of the mitigation measures recommended in the EIR, in each such
instance, the adopted Conditions of Approval are intended to be identical or substantially similar to the
recommended mitigation measure. Any minor revisions were made for the purpose of improving clarity or to
better define the intended purpose.
Finding: Unless specifically stated to the contrary in these Findings, it is the City’s intent to adopt all
mitigation measures recommended by the EIR that are applicable to the Project. If a measure has,
through error, been omitted from the Conditions of Approval or from these Findings, and that
measure is not specifically reflected in these Findings, that measure shall be deemed to be
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adopted pursuant to this paragraph. In addition, unless specifically stated to the contrary in these
Findings, all Conditions of Approval repeating or rewording mitigation measures recommended
in the EIR are intended to be substantially similar to the mitigation measures recommended in the
EIR and are found to be equally effective in avoiding or lessening the identified environmental
impact. In each instance, the Conditions of Approval contain the final wording for the mitigation
measures.
VII. ENVIRONMENTAL IMPACTS AND FINDINGS
City staff reports, the EIR, written and oral testimony at public meetings or hearings, these Facts, Findings
and Statement of Overriding Considerations, and other information in the administrative record, serve as the
basis for the City’s environmental determination.
An Initial Study was prepared for the proposed Project, which is included as Technical Appendix A to the
EIR. Through the Initial Study process, the City determined that the proposed Project could potentially cause
adverse environmental effects, and that an EIR was required. The City also determined that the Project had
no potential to result in significant adverse effects to 11 primary environmental subject areas, including:
Aesthetics, Agriculture and Forestry Resources, Energy, Geology and Soils, Hazards and Hazardous
Materials, Mineral Resources, Population and Housing, Public Services, Recreation, Utilities and Service
Systems, and Wildfire. Additionally, it was determined as part of the Project’s Initial Study that the Project
clearly would have no impact or a less-than-significant impact under some, but not all, of the thresholds of
significance under the issue areas of Air Quality, Biological Resources, Cultural Resources, Hydrology and
Water Quality, Land Use and Planning, Noise, and Transportation. Therefore, those thresholds of
significance were not required to be analyzed in detail in EIR Section 4.0, Environmental Analysis. The
discussion of issues (and the additional distinct thresholds) found not to be significant as part of the Initial
Study process is presented in Subsection 5.4 of the EIR. The City concurs with the conclusion of the Initial
Study that the issues discussed under Subsection VII.A, below, were found to have no significant impact.
The detailed analysis of potentially significant environmental impacts of the Project and proposed mitigation
measures for the Project are presented in Section 4.0 of the EIR. Responses to comments from the public and
other government agencies on the EIR are provided in Section F.2 of the Final EIR.
The EIR evaluated thresholds for nine (9) major environmental issues for potential impacts, including: Air
Quality, Biological Resources, Cultural Resources, Greenhouse Gas Emissions, Hydrology and Water
Quality, Land Use and Planning, Noise, Transportation, and Tribal Cultural Resources. Both Project-specific
and cumulative impacts were evaluated. The City concurs with the conclusions of the EIR that the issues and
sub-issues discussed in Subsections VII.B and C, below, were found to have either no significant and
unavoidable environmental impacts or that the environmental impacts could be mitigated to a level of less
than significant. Further, the City concurs with the conclusions of the EIR that the issues and sub-issues
discussed in Subsection VII.D, below, would result in significant and unavoidable environmental impacts
after the implementation of all proposed Project design features; federal, State, and City regulatory
requirements; City-imposed Conditions of Approval; and feasible mitigation measures.
A. Impacts Found Not to be Significant as Part of the Initial Study Process
1. Aesthetics
Potential Significant Impact: Whether the Project would have a substantial adverse effect on aesthetics.
(Thresholds a, b, and c)
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Finding: Impacts related to Aesthetics are discussed in Subsection 5.4.1 of the EIR. Based on the entire
record, the City finds that the Project would not have a substantial adverse effect to Aesthetics,
and no mitigation is required.
Facts in Support of the Finding: The Development Site and larger Project Site are located in the City of
San Bernardino. The properties are not designated as a scenic vista by
the City of San Bernardino General Plan or any other relevant planning
document and are not associated with any features identified in the
General Plan as potentially benefiting from sensitive treatment of land.
The San Bernardino Mountains, located north of the Project Site, are the
only relevant feature listed in the General Plan that is visible from the
Project Site. The proposed Project has no potential to block public views
of the San Bernardino Mountains because the mountains occur to the
north of the Project Site and public views to the mountains would
continue to be available from 3rd Street. The Project is located south of
3rd Street and therefore has no potential to obstruct views of features
located north of 3rd Street. Immediately south of the Project Site are
fenced and gated areas of the SBIA that are not accessible to the general
public and therefore offer no public views.
There are no designated or eligible State scenic highways within the
Project Site’s immediate vicinity. Due to the distance of these highways
to the Project Site and the presence of intervening development and
topography, the Project Site does not offer views of scenic resources
from these road segments.
The Project Site is located in an urbanized area and is surrounded by
existing developments. The proposed zoning classification revisions
would have no adverse effect on scenic quality. There are no components
of the proposed Project that would conflict with applicable Specific Plan
or City Municipal Code requirements related to scenic quality or other
regulations governing scenic quality. The Project’s perimeter treatment
along 3rd Street is designed to include landscaping and artistic and
interpretive elements as screening to enhance the scenic quality of the
roadway corridor. The building’s loading docks, truck courts, and trash
enclosures will be behind a solid barrier and will not be visible from 3rd
Street, and the higher elevation of the building façade visible from 3rd
Street is designed with architectural enhancements. Enhanced landscaped
areas also are proposed to be located at the northwest and northeast
corners of the Development Site to enhance the streetscape of 3rd Street.
Other than the SBAC-SP and the City of San Bernardino’s Municipal
Code, to which the Project would comply, there are no other regulations
governing scenic quality that apply to the Project. All new light sources
associated with the Project would be required to comply with the City’s
Municipal Code standards for exterior lighting, which will prevent light
spillover, glare, nuisance, inconvenience, or hazardous interference of
any kind on adjacent properties and streets. There are no components of
the Project-related lighting that could adversely affect day or nighttime
views in the area. (DEIR pp. 5-5 to 5-7)
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2. Agriculture and Forestry Resources
Potential Significant Impact: Whether the Project would have a substantial adverse effect to Agriculture
and Forestry Resources. (Thresholds a, b, c, d, and e)
Finding: Impacts related to Agriculture and Forestry Resources are discussed in Subsection 5.4.2 of the
EIR. Based on the entire record, the City finds that the Project would not have a substantial
adverse effect to Agriculture and Forestry Resources, and no mitigation is required.
Facts in Support of the Finding: The Project Site is part of the former location of the Norton AFB and is
not designated for agricultural use or as forest lands or timberlands. The
California Department of Conservation’s Farmland Mapping and
Monitoring Program (FMMP) does not map the site as “Prime
Farmland,” “Unique Farmland,” or “Farmland of Statewide Importance,”
nor does the site contain any Locally Important Farmland. The Project
Site is zoned “San Bernardino Specific Alliance Specific Plan (SBAC-
SP)” and “Public Faculties (PF).” The Project Site is not within an
agricultural preserve, nor is it subject to a Williamson Act contract, and
none of the surrounding properties are zoned for forestry- or timberland-
related uses. As such, the proposed Project has no potential to conflict
with existing zoning for agricultural use, or a Williamson Act contract,
and has no potential to conflict with existing zoning for, or cause
rezoning of, forest land, timberland, or timberland zoned Timberland
Production. (DEIR pp. 5-7 and 5-8)
3. Air Quality
a. Other Emissions / Odors
Potential Significant Impact: Whether the Project would result in other emissions (such as those leading
to odors) adversely affecting a substantial number of people. (Threshold d)
Finding: Impacts related to Air Quality Threshold d are discussed in detail in Subsection 5.4.3 of the EIR.
Based on the entire record, the City finds that the Project would not result in other emissions
(such as those leading to odors) adversely affecting a substantial number of people, and no
mitigation is required.
Facts in Support of the Finding: Any temporary odor impacts generated during construction activities on
the Development Site, such as asphalt paving and the application of
architectural coatings, would be short-term and cease upon completion of
the construction phase of the Project. Additionally, such odors would not
affect a substantial number of people, based on the proximity and nature
of land uses surrounding the Project Site (i.e., primarily industrial and
airport-related land uses). The warehouse use proposed for the
Development Site is not expected to involve activities that generate
substantial or noticeable amounts of odor during long-term operation.
Mandatory compliance with regulatory requirements related to nuisance
air contaminants and storage of solid waste will ensure that any odor
effects would be less than significant. (DEIR pp. 5-8 and 5-9)
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4. Biological Resources
a. Riparian Habitat or Other Sensitive Natural Community
Potential Significant Impact: Whether the Project would have a substantially adverse effect on any
riparian habitat or other sensitive natural community identified in local or
regional plans, policies, and regulations or by the California Department of
Fish and Game or U.S. Wildlife Service. (Threshold b)
Finding: Impacts related to Biological Resources Threshold b are discussed in detail in Subsection 5.4.4 of
the DEIR. Based on the entire record, the City finds that the Project would not impact any
riparian habitat or other sensitive natural community identified in local or regional plans,
policies, and regulations or by the California Department of Fish and Wildlife (“CDFW”) or U.S.
Fish and Wildlife Service (“USFWS”), and no mitigation is required.
Facts in Support of the Finding: Under existing conditions, the Project Site is fully disturbed by past
Norton AFB development and contains only developed, ornamental, and
ruderal habitat types. The Project Site does not contain any riparian
habitat or other sensitive natural community identified in local or
regional plans, policies, and regulations or by the CCDFW or USFWS.
Further, the Project’s stormwater system is designed to discharge into a
subsurface stormwater system and would not directly discharge to any
water courses that may contain riparian habitat. As such, the proposed
Project has no potential to have a substantial adverse effect on any on-
site or off-site riparian habitat or other sensitive natural community
identified in local or regional plans, policies, or regulations, or by the
CDFW or USFWS. (DEIR p. 5-9)
b. Federally-Protected Wetlands
Potential Significant Impact: Whether the Project would have a substantial adverse effect on State- or
federally-protected wetlands (including, but not limited to, marsh, vernal
pool, coastal, etc.) through direct removal, filling, hydrological interruption,
or other means. (Threshold c)
Finding: Impacts related to Biological Resources Threshold c are discussed in detail in Subsection 5.4.4 of
the EIR. Based on the entire record, the City finds that the Project would not impact any State- or
federally-protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological interruption, or other means, and no mitigation is
required.
Facts in Support of the Finding: The Project Site does not contain any natural or artificially occurring
water resources that support State- or federally-protected wetlands
(including, but not limited to, marsh, vernal pool, coastal, etc.). The
proposed Project also has no potential to impact State- or federally-
protected wetlands, because the Project Site does not contain any natural
drainages or jurisdictional wetlands. Further, the Project’s drainage
design is proposed to discharge into a subsurface stormwater system and
would not discharge to any protected water courses. (DEIR p. 5-9)
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c. Wildlife Movement, Wildlife Corridor, Wildlife Nursery Sites
Potential Significant Impact: Whether the Project would interfere substantially with the movement of any
resident or migratory fish or wildlife species or with established native
resident migratory wildlife corridors, or impede the use of native wildlife
nursery sites. (Threshold d)
Finding: Impacts related to Biological Resources Threshold d are discussed in detail in Subsection 5.4.4 of
the EIR. Based on the entire record, the City finds that the Project does not have the potential to
interfere substantially with the movement of any native resident or migratory wildlife corridors,
or impede the use of native wildlife nursery sites, and no mitigation is required.
Facts in Support of the Finding: Under existing conditions, the Project Site is fully disturbed by past
Norton AFB development and contains only developed, ornamental, and
ruderal habitat types. The Project Site does not contain any natural
bodies of water so there is no potential for the Project to interfere with
the movement of fish. Except for migratory birds, the Project has no
potential to result in impacts to migratory wildlife corridors due to the
urbanized nature of the Project Site and surroundings. Mandatory
compliance with regulatory requirements will ensure that active
migratory bird nests, if present, are not disturbed. Trees would only be
removed outside the nesting season, or if no nests are present. Upon
development of the Project as proposed, new trees will be installed on
the Development Site along 3rd Street, Victoria Street, and portions of
the Development Site’s interior, which will re-establish nesting habitat.
(DEIR p. 5-10)
d. Local Policies and/or Ordinances Protecting Biological Resources
Potential Significant Impact: Whether the Project would conflict with any local policies or ordinances
protecting biological resources, such as a tree preservation policy or
ordinance. (Threshold e)
Finding: Impacts related to Biological Resources Threshold e are discussed in detail in Subsection 5.4.4 of
the EIR. Based on the entire record, the City finds that the Project would not conflict with any
local policies or ordinances protecting biological resources and no mitigation is required.
Facts in Support of the Finding: City of San Bernardino Municipal Code Section 19.28.100 requires the
issuance of a tree removal permit prior to the removal of any mature
trees. The Development Site contained 139 trees that were removed
pursuant to the issuance of a tree removal permit. Mandatory compliance
with the tree removal permit ensures that trees are removed per City
requirements. There are no additional local policies or ordinances
protecting biological resources that are applicable to the Project or
Project Site. (DEIR p. 5-10)
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e. Habitat Conservation Plan
Potential Significant Impact: Whether the Project would conflict with the provisions of an adopted
Habitat Conservation Plan, Natural Conservation Community Plan, or other
approved local, regional, or State habitat conservation plan. (Threshold f)
Finding: Impacts related to Biological Resources Threshold f are discussed in detail in Subsection 5.4.4 of
the EIR. Based on the entire record, the City finds that the Project would not conflict with the
provisions of an adopted Habitat Conservation Plan, Natural Conservation Community Plan, or
other approved local, regional, or State habitat conservation plan, and no mitigation is required.
Facts in Support of the Finding: There is no adopted habitat conservation plan, natural conservation
community plan, or other approved local, regional, or State habitat
conservation plan applicable to the City of San Bernardino or the Project
Site. Accordingly, the Project would have no potential to conflict with
any such plans. (DEIR p. 5-10)
5. Cultural Resources
a. Disturbance of Human Remains Outside Formal Cemeteries
Potential Significant Impact: Whether the Project would disturb any human remains, including those
interred outside formal cemeteries (Threshold c).
Finding: Impacts related to Cultural Resources Threshold c are discussed in detail in Subsection 5.4.5 of
the EIR. Based on the entire record, the City finds that the Project’s potential to disturb human
remains, including those interred outside formal cemeteries, would be less than significant, and
no mitigation is required.
Facts in Support of the Finding: There are no known cemeteries at the Project Site and no known formal
cemeteries are located within the immediate site vicinity. While not
expected, in the unlikely event that human remains are discovered during
ground-disturbing activities, compliance with the applicable provisions
of California Health and Safety Code § 7050.5 as well as Public
Resources Code § 5097 et. seq. would be required. Mandatory
compliance with these provisions of State law would ensure that human
remains, if unearthed during construction activities, would be
appropriately treated. (DEIR p. 5-11).
6. Energy
Potential Significant Impact: Whether the Project would result in a potentially significant environmental
impact due to wasteful, inefficient, or unnecessary consumption of energy,
or wasteful use of energy resources, during Project construction or
operation, and whether the Project would conflict with or obstruct a State or
local plan for renewable energy or energy efficiency. (Thresholds a and b)
Finding: Impacts related to Energy are discussed in Subsection 5.4.6 of the EIR. Based on the entire
record, the City finds that the Project would not result in a potentially significant environmental
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impact due to wasteful, inefficient, or unnecessary consumption of energy, and would not
conflict with or obstruct a State or local plan for renewable energy or energy efficiency.
Facts in Support of the Finding: The Project’s construction process would consume electricity and fuel.
Project-related construction activities would represent a “single-event”
demand and would not require on-going or permanent commitment of
energy resources. Fuel consumed by construction equipment and
construction worker and vendor trips would be the primary energy
resource expended over the course of Project-related construction. The
equipment used for Project construction would conform to California Air
Resources Board (CARB) regulations and California emissions
standards. There are no unusual Project characteristics or construction
processes that would require the use of equipment that would be more
energy intensive than is used for comparable construction projects.
The Project does not propose uses or operations that would inherently
result in excessive and wasteful vehicle trips and/or vehicle miles
traveled, nor associated excess and wasteful vehicle energy consumption.
Enhanced fuel economies realized pursuant to federal and State
regulatory actions, and related transition of passenger vehicles and trucks
to alternative energy sources (e.g., electricity, natural gas, bio fuels,
hydrogen cells) are expected to decrease gasoline fuel demands in the
future. Under the Truck and Bus Regulation adopted by CARB in 2008,
all diesel truck fleets operating in California are required to adhere to an
aggressive schedule for upgrading and replacing heavy-duty truck
engines, which will result in fuel efficiencies. In addition, in June 2020,
CARB adopted a new Advanced Clean Truck Regulation Rule requiring
truck manufacturers to transition from diesel trucks and vans to electric
zero-emission trucks beginning in 2024. By 2045, every new truck sold
in California will be required to be zero-emission electric. Based on the
foregoing, Project transportation energy consumption would not be
considered inefficient, wasteful, or otherwise unnecessary.
The Project would not cause or result in the need for additional energy
facilities or an energy delivery system; existing utility connections are
site-adjacent in 3rd Street. Building operations and site maintenance
activities associated with the Project would result in the consumption of
electricity and potentially natural gas. For new development, compliance
with California Building Standards Code Title 24 energy efficiency
requirements (CALGreen) is considered demonstrable evidence of
efficient use of energy. The proposed warehouse building would be
required to promote and provide for energy efficiencies as required by
applicable federal or State of California standards and regulations, and in
so doing would meet all California Building Standards Code 24
standards. The Project would not result in wasteful, inefficient, or
unnecessary consumption of energy, or wasteful use of energy resources,
during construction or operation.
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Under existing conditions, there are no adopted State or local plans for
renewable energy or energy efficiency in the Project area. Thus, the
Project would have no potential to conflict with such plans, and no
impact would occur. Additionally, the Project would be consistent with
or otherwise would not conflict with policies and requirements related to
energy conservation. (DEIR pp. 5-11 to 5-14)
7. Geology and Soils
Potential Significant Impact: Whether the Project would have a substantial adverse effect to Geology and
Soils. (Thresholds a, b, c, d, e, and f)
Finding: Impacts related to Geology and Soils are discussed in Subsection 5.4.7 of the EIR. Based on the
entire record, the City finds that the Project would not have a substantial adverse effect to
Geology and Soils, and no mitigation is required.
Facts in Support of the Finding: The Project Site is not located near a known earthquake fault and is not
located within an Alquist-Priolo Earthquake Fault Zone. Accordingly,
the proposed Project would have no potential to expose people or
structures to potential substantial adverse effects, including the risk of
loss, injury, or death involving rupture of a known earthquake, as
delineated on the most recent Alquist-Priolo Earthquake Fault Zoning
Map. No known fault zones cross the Project Site; therefore, there is no
evidence that the site’s ground surface could rupture.
The Project Site is located in a seismically active area of Southern
California and is expected to experience moderate-to-severe ground
shaking during the lifetime of the Project. This risk is not considered
substantially different than that of other similar properties in the
Southern California area and is considered adequately mitigated to
protect public health, safety, and welfare if buildings are designed and
constructed in conformance with applicable building codes and sound
engineering practices. Pursuant to the City’s Municipal Code, the City
will condition the future grading and building permits to comply with the
requirements of the Project’s Geotechnical Study.
The Project Site is not located in an area with the potential for
liquefaction and is not subject to ground failure including failure by
seismically-induced liquefaction. Therefore, the Project would not be
subject to and would not exacerbate potential substantial adverse effects
including the risk of loss, injury, or death involving seismic-related
ground failure, including liquefaction.
The Project Site is not located in an area which has a known
susceptibility to landslides. Furthermore, the Project Site is relatively flat
and is approximately 4.4 miles away from the nearest location identified
by the San Bernardino General Plan as containing the potential for
landslide hazards. Accordingly, the proposed Project would not expose
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people or structures to potential substantial adverse effects, including the
risk of loss, injury, or death, involving landslides.
Grading activities associated with the Project would temporarily expose
underlying soils in the Project’s grading footprint to water and air, which
would increase erosion susceptibility during rainfall events or high winds
while the soils are exposed. The Project Applicant would be required to
obtain coverage under a National Pollutant Discharge Elimination
System (NPDES) permit for construction activities. The NPDES permit
is required for all projects that include construction activities, such a s
clearing, grading, and/or excavation that disturb at least one acre of total
land area. Additionally, during grading and other construction activities,
the Project would be subject to the requirements established in City of
San Bernardino Municipal Code Chapter 8.80 (Storm Water Drainage
System), which requires the Project Applicant to prepare and implement
a Stormwater Pollution Prevention Plan (SWPPP) that would identify the
erosion control measures, such as construction fencing, sandbags, and
other erosion-control features, that would be implemented during the
construction phase to reduce the Project Site’s potential for soil erosion
or the loss of topsoil. In addition, construction activities associated with
the Project would be required to comply with SCAQMD Rule 403
Fugitive Dust, which would minimize wind-related erosion hazards
during construction activities. Mandatory compliance with the Project’s
NPDES permit and the regulatory requirements of the City of San
Bernardino and the SCAQMD would ensure that water and wind erosion
is minimized and not substantial.
Following construction, wind and water erosion on the Development Site
would be minimal because the Development Site would be covered by
landscaping and impervious surfaces and stormwater runoff discharge
would be controlled through a storm drain system. The Project is subject
to the provisions of the City of San Bernardino Municipal Code Chapter
8.80, which requires the Project Applicant to prepare and implement a
SWPPP for long-term operational activities. The Project’s Water Quality
Management Plan (WQMP) provides a program for an effective
combination of erosion control and sediment control measures (i.e., Best
Management Practices (BMPs)) to reduce or eliminate long-term
discharge to surface water from stormwater and non-storm water
discharges. The Project’s design includes proposed catch basins that
would include filters that remove waterborne pollutants from stormwater
flows, including silt and sediment, and the proposed infiltration basins
would facilitate the settlement of sediments in runoff from the site prior
to discharging to existing storm drainage facilities. These design features
would be effective at removing silt and sediment from stormwater
runoff, and the WQMP requires post-construction maintenance and
operational measures to ensure ongoing erosion protection. Compliance
with the operational SWPPP and WQMP, along with long-term
maintenance of the on-site water quality features, would be required as a
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condition of Project approval. As such, the Project would not result in
substantial erosion or loss of top soil during long-term operation.
The City will condition future grading and building permits to
incorporate recommendations to address lateral spreading, subsidence,
and collapse. With mandatory compliance with the recommendations
provided, impacts related to geologic and soil stability would be less than
significant. Soils that underlie the Project Site have “Very Low”
expansion potential. The Project does not include the installation of any
septic tanks or alternative waste water disposal systems, as the
warehouse building would connect to the San Bernardino Valley
Municipal Water District’s sanitary sewer system.
The Project Site has been fully disturbed associated with past Norton
AFB development. The Project Site is overlain with artificial fill; no
native soil or bedrock is expected to occur within 3.5 feet of the ground
surface, and below the artificial fill are alluvium soils extending to
depths of approximately 20 feet. Other than for a limited number of
trenches associated with utility installation and the installation of
subsurface water chambers, no substantial amounts of below grade
construction are expected to be included in the proposed development .
Further, alluvial fan and fluvial soils have a low paleontological
sensitivity because they are not known to have produced fossils in the
past and consist of sediments too young to produce fossils. As such,
there is no reasonable potential that paleontological resources or unique
geologic features have the potential of being impacted by the Project .
(DEIR pp 5-14 to 5-17)
8. Hazards and Hazardous Materials
Potential Significant Impact: Whether the Project would have a substantial adverse effect due to Hazards
and Hazardous Materials. (Thresholds a, b, c, d, e, f, and g)
Finding: Impacts related to Hazards and Hazardous Materials are discussed in Subsection 5.4.8 of the EIR.
Based on the entire record, the City finds that the Project would not have a substantial adverse
effect to Hazards and Hazardous Materials, and no mitigation is required.
Facts in Support of the Finding: A Phase I Environmental Site Assessment (ESA) prepared for the
Development Site determined that the only potential existing sources of
site contamination were associated with potential asbestos, lead based
paints, and existing site utilities associated with buildings on the site that
have since been demolished and removed from the site. There were no
other identified Recognized Environmental Conditions (RECs); thus,
impacts due to existing site contamination would be less than significant.
Construction contractors would be required to comply with all applicable
federal, State, and local laws and regulations regarding the transport, use,
storage, and potential accidental upset of hazardous construction‐related
materials. With mandatory compliance with applicable hazardous
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materials regulations, the Project would not create a significant hazard to
the public or the environment through routine transport, use, or disposal
of hazardous materials during the construction phase.
If businesses that use or store hazardous materials occupy the Project, the
business owners and operators would be required to comply with all
applicable federal, State, and local regulations to ensure proper transport,
storage, use, emission, and disposal of hazardous substances. With
mandatory regulatory compliance, the Project is not expected to pose a
significant hazard to the public or the environment through the routine
transport, use, storage, emission, or disposal of hazardous materials, nor
would the Project increase the potential for accident conditions that
could result in the release of hazardous materials into the environment.
The Project Site is not located within one-quarter mile of an existing or
proposed school. The nearest existing school facilities to the Project Site
are Cypress Preschool (approximately 0.4 mile to the north) and
Lankershim Elementary School (approximately 0.8 mile to the
northwest). The proposed warehouse operation at the Development Site
would be conducted mainly inside of the enclosed building, where a
variety of consumer products would likely be stored. The Project does
not include any land uses that may be considered point source emitters.
Accordingly, the proposed Project would not emit hazardous emissions
or handle hazardous or acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed school.
The California Environmental Protection Agency (CalEPA) maintains
several lists of contaminated sites that are identified as meeting the
“Cortese List” requirements for hazardous materials sites. A review of
the CalEPA’s Cortese List Data Resources indicates that the Project Site
is not included on any list of hazardous materials sites compiled pursuant
to Government Code 65962.5.
The SBIA property is located immediately south of the Project Site. The
Project entails the development of a warehouse building, which is not a
noise-sensitive use. Also, the Project Site is not subject to incompatible
aircraft noise, as it is located outside of the SBIA’s projected 65 decibel
(dBA) CNEL noise contour. The arrival and departure paths for the
SBIA’s runways do not extend over the Project Site. Fixed wing and
helicopter aircraft arrive from the northeast and southwest and depart to
the southwest. Nonetheless, the Project Applicant and any successors in
interest would be required to grant an avigation easement to the SBIAA
to allow for aircraft overflight, and prior to construction of the building,
approval by the Inland Valley Development Agency (IVDA) and Federal
Aviation Administration (FAA) is required to assure compliance with all
applicable safety requirements. Therefore, there is no reasonable
potential for the Project to result in significant safety hazards or noise
exposure for people working or visiting on and around the Project Site.
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The Project Site does not contain any emergency facilities nor does it
serve as an emergency evacuation route. During construction and long-
term operation, the City of San Bernardino and the San Bernardino
County Fire Department will require adequate emergency access for
emergency vehicles. As part of the Project’s application review process,
and during subsequent review and approval processes for building
permits, the City of San Bernardino and County of San Bernardino Fire
Departments are responsible for reviewing the Project’s application
materials to ensure that appropriate emergency ingress and egress would
be available to-and-from the Project Site and that the Project would not
substantially impede emergency response times in the local area.
Accordingly, implementation of the Project would not impair
implementation of or physically interfere with an adopted emergency
response plan or an emergency evacuation plan.
The Development Site and larger Project Site are located in an urbanized
portion of the City of San Bernardino, and there are no areas of open
space in the Project’s immediate vicinity that could be subject to
wildland fire hazards. The Project would be required to be constructed in
accordance with the California Building Standards Code (CBSC, Title
24, Part 11 of the California Code of Regulations) and the Building Code
(Chapter 15.04 of the City of San Bernardino Municipal Code), which
incorporates the CBSC with minor exceptions and changes to ensure
applicability of the requirements within the City of San Bernardino. The
Building Code requires a minimum level of fire protection facilities, such
as fire sprinklers and hydrants. Additionally, site improvements,
including irrigated landscaping, would reduce the Project’s potential to
cause or be affected by wildland fire hazards. (DEIR pp. 5-18 to 5-21)
9. Hydrology and Water Quality
a. Water Quality Standards/Waste Discharge Requirements
Potential Significant Impact: Whether the Project will violate any water quality standards or waste
discharge requirements. (Initial Study Threshold a)
Finding: Impacts related to Hydrology and Water Quality Threshold a are discussed in detail in Subsection
5.4.9 of the EIR. Based on the entire record, the City finds that the Project would not cause or
contribute to the violation of any water quality standards or waste discharge requirements, and no
mitigation is required.
Facts in Support of the Finding: Construction of the Project would involve demolition/site preparation,
grading, paving, utility installation, building construction, and
landscaping activities, which have the potential to generate water quality
pollutants such as silt, debris, organic waste, and chemicals (e.g., paints,
solvents). Should these materials come into contact with water that
reaches the groundwater table or flows off site to a public storm drain,
the potential exists for the Project’s construction activities to adversely
affect water quality. As such, short-term water quality impacts have the
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potential to occur during construction in the absence of any protective or
avoidance measures. However, pursuant to the requirements of the Santa
Ana RWQCB and City of San Bernardino (San Bernardino Municipal
Code Chapter 8.80), the Project Applicant would be required to obtain
coverage under the State’s General Construction Storm Water Permit for
construction activities (NPDES permit), which would reduce impacts to
less than significant.
An NPDES permit is required for all development projects that include
construction activities, such as clearing, grading, and/or excavation, that
disturb at least one acre of total land area. Mandatory compliance with
regulatory requirements would ensure that the proposed Project does not
violate any water quality standards or waste discharge requirements
during construction activities.
Compliance with required regulations, permits, and a site-specific Water
Quality Management Plan would be required as a condition of approval
for the Project to minimize the release of potential waterborne pollutants,
including pollutants of concern for downstream receiving waters. Long-
term maintenance of on-site water quality features also would be
required as a condition of approval to ensure the long-term effectiveness
of all on-site water quality features.
The Project Applicant or any successor in interest would be required to
prepare a SWPPP for operational activities and implement a long-term
water quality sampling and monitoring program or receive an exemption.
Because the permit is dependent upon a detailed accounting of all
operational activities and procedures, and the SWPPP (or exemption
thereto) would be prepared at the time the Project’s building users and
their operational characteristics are known. However, based on the
performance requirements of the NPDES Industrial General Permit, it is
reasonably assured that mandatory compliance with all applicable water
quality regulations would further reduce potential water quality impacts
during the Project’s long-term operation. The Project would not violate
any water quality standards or waste discharge requirements or otherwise
substantially degrade surface or ground water quality during long-term
operation. (DEIR pp. 5-21 and 5-22)
b. Groundwater Supply and Recharge
Potential Significant Impact: Whether the Project would substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such that the project may
impede sustainable groundwater management of the basin. (Initial Study
Threshold b)
Finding: Impacts related to Hydrology and Water Quality Threshold b are discussed in detail in
Subsection 5.4.9 of the EIR. Based on the entire record, the City finds that the Project would not
substantially decrease groundwater supplies or interfere substantially with groundwater recharge
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such that the project may impede sustainable groundwater management of the basin, and no
mitigation is required.
Facts in Support of the Finding: The Project would be served with potable water from the San Bernardino
Municipal Water Department (SBMWD), and the Project Applicant does
not propose the use of any wells or other groundwater extraction
activities. Therefore, the Project would not directly draw water from the
groundwater table. Accordingly, implementation of the proposed Project
would not directly decrease groundwater supplies.
Development of the Project would increase impervious surface coverage
on the Project Site, which would, in turn, reduce the amount of water
percolating down into the underground aquifer that underlies the Project
Site and surrounding areas (i.e., Bunker Hill Groundwater Basin). The
Bunker Hill Basin is a part of the San Bernardino Basin Area, and is
among the most rigorously managed groundwater basins in the State.
Planning and management efforts evaluating needs and supplies have
been established for most of the basins within the watershed through the
next 20 to 40 years. Due to extensive management of the groundwater
basin, implementation of the Project would not interfere substantially
with groundwater recharge such that the Project may impede sustainable
groundwater management of the basin. Additionally, the Project includes
design features that would maximize the percolation of on-site
stormwater runoff into the groundwater basin, such as
detention/infiltration basins and permeable landscape areas. Furthermore,
runoff from the Project Site would be conveyed to existing drainage
facilities, which ultimately would convey flows to downstream areas
where infiltration would occur (e.g., the Santa River and Prado Dam).
Accordingly, buildout of the Project with these design features would not
interfere substantially with groundwater recharge of the Bunker Hill
Groundwater Basin. (DEIR pp. 5-22 and 5-23)
c. Alteration of Existing Drainage Patterns: Erosion or Siltation
Potential Significant Impact: Whether the Project would substantially alter the existing drainage pattern
of the site or area, including through the alteration of the course of a stream
or river or through the addition of impervious surfaces, in a manner which
would result in substantial erosion or siltation on or off site. (Initial Study
Threshold c(i))
Finding: Impacts related to Hydrology and Water Quality Threshold c(i) are discussed in detail in
Subsection 5.4.9 of the EIR. Based on the entire record, the City finds that the Project would not
substantially alter the existing drainage pattern of the site or area, including through the alteration
of the course of a stream or river or through the addition of impervious surfaces, in a manner
which would contribute to substantial erosion or siltation on or off site, and no mitigation is
required.
Facts in Support of the Finding: The Project would alter existing ground contours of the Project Site and
install impervious surfaces, which would result in changes to the site’s
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existing, internal drainage patterns. Although the Project would alter the
subject property’s internal drainage patterns, and as more fully evaluated
under Initial Study Threshold a, such changes would not result in
substantial erosion or siltation on or off site, either during construction or
during long-term operation. (DEIR p. 5-23)
d. Alteration of Existing Drainage Patterns: Flooding
Potential Significant Impact: Whether the Project would substantially alter the existing drainage pattern
of the site or area, including through the alteration of the course of a stream
or river or through the addition of impervious surfaces, in a manner which
would substantially increase the rate or amount of surface runoff in a
manner which would result in flooding on or off site. (Initial Study
Threshold c(ii))
Finding: Impacts related to Hydrology and Water Quality Threshold c(ii) are discussed in detail in
Subsection 5.4.9 of the EIR. Based on the entire record, the City finds that the Project would not
substantially alter the existing drainage pattern of the site or area, including through the alteration
of the course of a stream or river or through the addition of impervious surfaces, in a manner
which would substantially increase the rate or amount of surface runoff in a manner which would
result in flooding on or off site.
Facts in Support of the Finding: Implementation of the proposed Project would not affect the total
amount of runoff from the Project Site, but would affect the rate of peak
runoff. As a standard requirement of the City of San Bernardino, the
Project’s application materials include a preliminary hydrology study
that evaluates existing and proposed drainage conditions. As proposed,
the surface runoff would be divided into sub-areas and would be directed
to on-site cross gutters and curb and gutters. The runoff would be
directed from the curb and gutters toward proposed catch basins with
insert filters, then to a storm drain system that would discharge into the
proposed detention/infiltration basins. The basins would be designed to
accommodate the increased runoff associated with site development, as
well as appropriate Low Impact Development (LID) devices. Three
detention/infiltration basins are proposed. Because peak runoff from the
site would slightly decrease as compared to existing conditions, the
Project has no potential to result in runoff that could cause flood hazards
downstream. Additionally, the proposed drainage system would ensure
that no flooding would occur on site as a result of the proposed
development’s runoff. (DEIR p. 5-23)
e. Storm Water Drainage System Capacity
Potential Significant Impact: Whether the Project would substantially alter the existing drainage pattern
of the site or area, including through the alteration of the course of a stream
or river or through the addition of impervious surfaces, in a manner which
would create or contribute runoff water which would exceed the capacity of
existing or planned stormwater drainage systems or provide substantial
additional sources of polluted runoff. (Initial Study Threshold c(iii))
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Finding: Impacts related to Hydrology and Water Quality Threshold c(iii) are discussed in detail in
Subsection 5.4.9 of the EIR. Based on the entire record, the City finds that the Project would not
substantially alter the existing drainage pattern of the site or area, including through the alteration
of the course of a stream or river or through the addition of impervious surfaces, in a manner
which would exceed the capacity of existing or planned stormwater drainage systems or provide
substantial additional sources of polluted runoff, and no mitigation is required.
Facts in Support of the Finding: Peak flows from the Development Site during 100-year storm events
would decrease from 77.54 cfs under existing conditions to 75.09 cfs
under the proposed Project. Because the existing drainage systems
tributary to the Development Site is adequate to accommodate runoff
from the Development Site under existing conditions, and because peak
runoff would decrease under the proposed Project, the Project would not
create or contribute runoff water which would exceed the capacity of
existing or planned stormwater drainage systems. The Project also would
not result in substantial additional sources of polluted runoff during
either construction or long-term operation, as discussed under the
analysis of Threshold a. (DEIR pp. 5-23 and 5-24)
f. Conflicts with Water Quality/Groundwater Management Plans
Potential Significant Impact: Whether the Project would conflict with or obstruct implementation of a
water quality control plan or sustainable groundwater management plan.
(Initial Study Threshold e)
Finding: Impacts related to Hydrology and Water Quality Threshold e are discussed in detail in Subsection
5.4.9 of the EIR. Based on the entire record, the City finds that the Project would not conflict
with or obstruct implementation of a water quality control plan or sustainable groundwater
management plan, and no mitigation is required.
Facts in Support of the Finding: The Project would not result in impacts associated with sustainable
management of the San Bernardino Basin Area and would not contribute
substantial amounts of pollutants that could adversely affect groundwater
quality; thus, impacts would be less than significant. The applicable
water quality control plan for the area is the Santa Ana Region Basin
Plan (“Basin Plan”), which was most recently updated in June 2019. The
Project would be required to implement a SWPPP for construction-
related activities. The SWPPP would specify the BMPs that the Project’s
construction contractors would be required to implement during
construction activities to ensure that potential pollutants of concern are
prevented, minimized, and/or otherwise appropriately treated prior to
being discharged from the subject property. Additionally, long-term
operation of the Project would require compliance with the applicable
NPDES permit (NPDES Permit No. CAS618036, Order No. R8-2002-
0012) and City of San Bernardino Municipal Code Chapter 8.80 (Storm
Water Drainage System), which include requirements to prepare and
implement a WQMP as well as a SWPPP, and to incorporate and
maintain long-term BMPs to address potential water quality pollutants.
Implementation of these requirements would ensure that the Project does
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not conflict with or obstruct implementation of the Basin Plan, and
would ensure impacts would be less than significant. (DEIR p. 5-24)
10. Land Use and Planning
a. Disrupt Community
Potential Significant Impact: Whether the Project would physically divide an established community
(Initial Study Threshold a).
Finding: Impacts related to Land Use and Planning Threshold a are discussed in detail in Subsection
5.4.10 of the EIR. Based on the entire record, the City finds that the Project would not physically
divide an established community, and no mitigation is required.
Facts in Support of the Finding: There are no residential neighborhoods within the immediate proximity
of the Project Site, although existing residential neighborhoods occur
north of the Project Site (north of West 5th Street). A few residential
homes occur along the north side of 3rd Street near the Project Site, but
are not considered a neighborhood. Implementation of the Project would
not require or result in the physical division of the existing residential
neighborhoods located to the north of the Project Site. (DEIR p. 5-24)
11. Mineral Resources
Potential Significant Impact: Whether the Project would have a substantial adverse effect related to
Mineral Resources. (Thresholds a and b)
Finding: Impacts related to Mineral Resources are discussed in Subsection 5.4.11 of the EIR. Based on the
entire record, the City finds that the Project would not have a substantial adverse effect related to
mineral resources, and no mitigation is required.
Facts in Support of the Finding: The Project Site is classified by the California Geological Survey (CGS)
as Mineral Resources Zone 2 (MRZ2), which is defined by the CGS as
an area where geologic data indicate that significant mineral deposits
(aggregate resources) are present. However, the Project Site was used as
part of the Norton AFB for decades and mining activities in the Project
area have been and will continue to be precluded by the requirements of
the IVDA, which has been planning for light industrial uses on the site
since adoption of the SBAC-SP in 2007. The Project Site is not planned
for mining uses based on the site’s existing General Plan land use
designations, Specific Plan land use designations, and zoning
classifications, none of which allow for mineral resources extraction.
Thus, although the Project Site occurs within MRZ-2, mining activities
would not be compatible with existing and planned surrounding land
uses. Furthermore, mining of the site would result in the establishment of
a large pit at a substantially lower elevation than surrounding properties,
which is not desirable within the urban context of the Project area or the
streetscape desired along 3rd Street by the City of Highland or the City
of San Bernardino. Accordingly, mining on the Project Site is not
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compatible with existing zoning and the surrounding context, and
therefore is not feasible. The Project Site is not identified as a locally-
important mineral resources recovery site by the City of San
Bernardino’s General Plan, the SBAC-SP, or any other land use plan. As
such, the Project would not result in the loss of availability of a locally-
important mineral resource recovery site delineated on a local general
plan, specific plan or other land use plan. Because mining of the Project
Site is already precluded by the City of San Bernardino General Plan, the
Project would not result in the loss of availability of a locally important
known mineral resource. (DEIR p. 5-25)
12. Noise
a. Noise from Private Airstrip
Potential Significant Impact: Whether the Project, located within the vicinity of a private airstrip or an
airport land use plan or, where such a plan has not been adopted, within 2
miles of a public airport or public use airport, would expose people residing
or working in the Project area to excessive noise levels. (Initial Study
Threshold c)
Finding: Impacts related to Noise Threshold c are discussed in detail is Subsection 5.4.12 of the EIR.
Based on the entire record, the City finds that the Project would not expose people residing or
working in the Project area to excessive noise levels from a private airstrip, and no mitigation is
required.
Facts in Support of the Finding: There are no private airstrips in the City of San Bernardino and there are
no private airstrips within two miles of the Project Site. The nearest
airport is the San Bernardino International Airport (SBIA) which is
located adjacent to the Project Site’s southern border, and the Project
Site occurs within the Airport Influence Area (AIA) for the SBIA. The
Project Site occurs outside of the 65 dBA CNEL contour for the SBIA.
Pursuant to the San Bernardino General Plan, industrial uses such as
those proposed as part of the Project are considered “Normally
Acceptable” at noise levels up to 75 dBA CNEL, while industrial land
uses are considered “Conditionally Acceptable” at noise levels ranging
from 70 to 80 dBA CNEL. Thus, because the Project would not be
subject to noise levels exceeding 65 dBA CNEL, the Project would not
expose people residing or working in the area to excessive airport-related
noise levels, and impacts would therefore be less than significant. (DEIR
pp. 5-25 and 5-26)
13. Population and Housing
Potential Significant Impact: Whether the Project would have a substantial adverse effect related to
Population and Housing. (Thresholds a and b)
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Finding: Impacts related to Population and Housing are discussed in Subsection 5.4.13 of the EIR. Based
on the entire record, the City finds that the Project would not have a substantial adverse effect
related to Population and Housing, and no mitigation is required.
Facts in Support of the Finding: The proposed Project would have a beneficial effect on the area’s
employment base by redeveloping an underutilized site with a new
warehouse building. The new jobs generated would provide additional
employment opportunities for residents in the area. The Project Site is
currently designated by the City of San Bernardino’s General Plan for
“Public Facility/Quasi-Public (PF)” and “Industrial (I)” development,
and the Project does not propose any uses that would result in unplanned
population growth that is not already allowed by the General Plan.
Moreover, it is anticipated that any future employees generated by the
Project could be accommodated by existing residential communities
and/or by future residential uses to be constructed in accordance with the
City’s General Plan and/or the general plans of other nearby
jurisdictions, and that no additional unplanned housing would be
required to accommodate Project-related employees. Additionally, the
Project’s utility, drainage, and other improvements are designed to serve
only the proposed Project, and would not induce growth indirectly on
any other parcels in the Project vicinity. Under existing conditions, there
are no existing homes or residents on the Project Site; therefore, there
would be no displacement of existing people or housing. (DEIR p. 5-26)
14. Public Services
Potential Significant Impact: Whether the Project would have a substantial adverse effect to Public
Services. (Threshold a(i-v))
Finding: Impacts related to Public Services are discussed in Subsection 5.4.14 of the EIR. Based on the
entire record, the City finds that the Project would not have a substantial adverse effect to Public
Services, and no mitigation is required.
Facts in Support of the Finding: The Project would introduce a new building and employees to the
Development Site, which would result in an incremental increase in
demand for fire and police protection services. The nearest fire station
that the City of San Bernardino maintains is the San Bernardino County
Fire Station 233, which is located at 165 South Leland Norton Way
(approximately 1.2 miles from the Project Site) and the nearest first
response police station is at 1535 East Highland Avenue, San
Bernardino, CA, which is approximately 2.5 miles from the Project Site.
Due to the proximity of existing fire and police stations, the Project has
no potential to cause a fire station or police station to be physically
altered or for a new fire or police station to be constructed.
The proposed Project would not create a direct demand for public school
services, as the subject property would contain non-residential uses that
would not generate any school-aged children requiring public education.
Although the Project would not create a demand for additional public
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school services, the Project Applicant would be required to contribute
development impact fees to the San Bernardino City Unified School
District (SBCUSD), in compliance with California Senate Bill 50.
Mandatory payment of school fees would be required prior to the
issuance of a building permit. Pursuant to Senate Bill 50, payment of
school impact fees constitutes complete mitigation for project-related
impacts to school services.
The Project does not propose any type of residential use or other land use
that may generate a population that would result in a demand for
parkland resources, and no recreational facilities are proposed as part of
the Project. Thus, the Project would not result in substantial adverse
physical impacts associated with the provision of new or physically
altered recreational facilities.
The Project would not directly substantially increase the residential
population in the City, and therefore is not expected to result in a
demand for other public facilities/services, including libraries,
community recreation centers, post offices, and animal shelters. As such,
implementation of the proposed Project would not adversely affect other
public facilities or require the construction of new or modified public
facilities. (DEIR pp. 5-26 to 5-28)
15. Recreation
Potential Significant Impact: Whether the Project would have a substantial adverse effect related to
Recreation. (Thresholds a and b)
Finding: Impacts related to Recreation are discussed in Subsection 5.4.15 of the EIR. Based on the entire
record, the City finds that the Project would not have a substantial adverse effect related to
Recreation, and no mitigation is required.
Facts in Support of the Finding: The Project does not involve any type of residential use or other land use
that may generate a population that would increase the use of existing
neighborhood and regional parks or other recreational facilities.
Accordingly, implementation of the proposed Project would not result in
the increased use or substantial physical deterioration of an existing
neighborhood or regional park. The Project does not involve the
construction of any new on- or off-site recreation facilities and would not
expand any existing off-site recreational facilities. Therefore, no impacts
related to the construction or expansion of recreational facilities would
occur with implementation of the proposed Project. (DEIR p. 5-28)
16. Transportation
a. Emergency Access
Potential Significant Impact: Whether the Project would result in inadequate emergency access. (Initial
Study Threshold d)
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Finding: Impacts related to Transportation Threshold d are discussed in detail in Subsection 5.4.16 of the
EIR. Based on the entire record, the City finds that the Project would not result in inadequate
emergency access, and no mitigation is required.
Facts in Support of the Finding: The Project Site is not identified as a designated emergency access route.
During the course of the City of San Bernardino and San Bernardino
County Fire Department’s required review of the Project’s applications,
the Project’s design is reviewed to ensure that adequate access to and
from the site is provided for emergency vehicles during both
construction and long-term operation. With required adherence to the
City of San Bernardino and County Fire Department requirements for
emergency vehicle access, impacts are expected to be less than
significant. (DEIR pp. 5-28 and 5-29)
17. Utilities and Service Systems
Potential Significant Impact: Whether the Project would have a substantial adverse effect related to
Utilities and Service Systems. (Thresholds a, b, c, d, and e)
Finding: Impacts related to Utilities and Service Systems are discussed in Subsection 5.4.17 of the EIR.
Based on the entire record, the City finds that the Project would not have a substantial adverse
effect related to Utilities and Service Systems, and no mitigation is required.
Facts in Support of the Finding: The Project would entail local connections to existing water, wastewater
treatment, storm water drainage, electric power, natural gas, and
telecommunications facilities, as these facilities currently are available
within the immediately surrounding area. Such local connections are
inherent to the Project’s construction phase, and impacts associated with
the Project’s construction phase were evaluated in the Draft EIR under
the appropriate topical subheadings, as described herein. There are no
components of the Project’s proposed utility connections that would
result in significant environmental effects beyond what already is
evaluated in the Draft EIR for the Project’s construction phase under
associated environmental topic areas.
The operation of a warehouse building on the Development Site would
result in an increase in potable water demand compared to the site’s
existing, largely vacant condition. The Project Site is designated by the
City of San Bernardino General Plan for development with “Public
Facility/Quasi-Public (PF)” and “Industrial Light (IL)” land uses. The
water demand associated with the Project would be similar to the water
demand associated with development in accordance with the Project
Site’s existing land use designations. Because the 2015 UWMP
demonstrates that there would be adequate water resources to meet the
projected demands through 2040, and because the Project would result in
an approximately 3% reduction in demand for water resources as
compared to what was assumed by the 2015 UWMP, there is substantial
evidence to conclude that the SBMWD would have sufficient water
supplies available to serve the Project and reasonably foreseeable future
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development during normal, dry, and multiple dry years. A Water
Supply Assessment (“WSA”; Technical Appendix L to the EIR) was
prepared for the Project in accordance with SBMWD requirements to
document the change in demand resulting from the Project, which
determined that SBMWD has sufficient water supplies to meet the water
demands of the proposed Project, along with the other projected
municipal water demands.
Wastewater generated on the Development Site would be conveyed to
the San Bernardino Water Reclamation Plant (SBWRP). The SBWRP
has an existing design capacity of 33 million gallons per day (MGD).
Existing and planned developments, including the proposed Project,
ultimately would exceed the existing wastewater treatment capacity at
the SBWRP. However, this projected shortfall in wastewater treatment
capacity has been known for a long time and was documented in the EIR
prepared for the City’s 2005 General Plan Update and was known at the
time the SBAC-SP was adopted in May 2007. Furthermore, the
warehouse use proposed as part of the Project will generate substantially
less wastewater than other types of light industrial uses, because most of
the building space will be occupied by goods storage inside a large
warehouse, with wastewater generation sources generally limited to an
employee break room and restrooms. The SBMWD is currently
undertaking planning efforts and is currently preparing a Water
Reclamation Plant Master Plan (WRPMP), which will evaluate projected
wastewater treatment demands and will identify capacity upgrades
needed to accommodate existing and planned demands for wastewater
treatment throughout the SBMWD service area. As it is currently
unknown what capacity upgrades may be identified as part of the
WRPMP, any analysis of potential environmental effects associated with
such upgrades due to existing and planned growth through year 2060 in
the SBWMD service area would be speculative and are outside of the
scope of the proposed Project (CEQA Guidelines § 15145). However,
because the SBMWD is undertaking long-range planning efforts to
ensure adequate capacity exists to provide wastewater treatment for all
existing and planned developments, including the Project, it can be
concluded that the Project would not result in a determination by the
wastewater treatment provider which serves or may serve the Project that
it has inadequate capacity to serve the Development Project’s projected
demand in addition to existing commitments.
Solid waste collection within much of the City of San Bernardino is
provided by the Solid Waste Services and Refuse and Recycling
Division of the City of San Bernardino Department of Public Services.
The County of San Bernardino Solid Waste Management Division
(SWMD) is responsible for the operation and management of the solid
waste disposal system which consists of six regional landfills, eight
transfer stations and five community collection centers. The City of San
Bernardino has no active landfills but primarily utilizes the San Timoteo
and Mid-Valley landfills. Adequate capacity exists at both the San
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Timoteo and Mid-Valley landfills to accommodate solid waste generated
by the Project. The Project would be subject to the City of San
Bernardino’s solid waste regulations including enforceable requirements
for the recycling and diversion of solid waste from the regional landfills.
With mandatory compliance with regulations, the Project would not
generate solid waste in excess of State or local standards, or in excess of
the capacity of local infrastructure, or otherwise impair the attainment of
solid waste reduction goals. Future building users at the Development
Site would be required to work with refuse haulers to develop and
implement feasible waste reduction programs, including source
reduction, recycling, and composting. Additionally, the Project would be
required to provide adequate areas for collecting and loading recyclable
materials where solid waste is collected. The collection areas are
required to be shown on construction drawings and be in place before
occupancy permits are issued. The implementation of these programs
would reduce the amount of solid waste generated and diverted to
landfills, which in turn will aid in the extension of the life of affected
disposal sites. The Project would be subject to all federal, State, and local
statutes and regulations related to solid waste. (DEIR pp. 5-29 to 5-31)
18. Wildfire
Potential Significant Impact: Whether the Project would have a substantial adverse effect related to
Wildfire. (Thresholds a, b, c, and d)
Finding: Impacts related to Wildfire are discussed in Subsection 5.4.18 of the EIR. Based on the entire
record, the City finds that the Project would not have a substantial adverse effect related to
Wildfire, and no mitigation is required.
Facts in Support of the Finding: A State Responsibility Area (SRA) includes lands where the State of
California is financially responsible for the prevention and suppression
of wildfires, and the Project Site is not located within any SRAs. Fire
protection services to the Project Site are and would continue to be
provided by the San Bernardino County Fire Department (SBCFD). The
Project Site is not identified as part of any adopted emergency response
plans or emergency evacuation plans, and the Project has no potential to
conflict with any such plans. As such, no impacts to adopted emergency
response plans or emergency evacuation plans would occur with
implementation of the proposed Project. The Project Site is located in an
area that is largely urbanized and contains no large open space areas that
have the potential for wildland fire hazards. The Project would result in
construction and operation of a large warehouse building with exterior
impervious surfaces and irrigated landscaping, which would not result in
any increase in fire hazards in the local area. Therefore, the Project has
no potential to exacerbate wildfire risks, and would not expose people to
pollutant concentrations from a wildfire or the uncontrolled spread of a
wildfire. The Project Site is not located within a portion of the City of
San Bernardino that is subject to wildfire hazards. Aside from standard
building construction requirements, including the installation of fire
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sprinklers, the provision of fire hydrants, and the use of irrigated
landscaping, the Project does not include any fire protection-related
infrastructure that could result in temporary or ongoing impacts to the
environment. The Project Site occurs in a portion of the City of San
Bernardino that exhibits generally flat topography, and there are no large
slopes in the Project vicinity that could be subject to landslide hazards as
a result of post-fire slope instability. Additionally, there are no
components of the Project that could result in or exacerbate flooding
hazards associated with wildland fire hazards. Furthermore, the Project
generally would maintain the site’s existing drainage patterns, and would
not cause or contribute to any risks of flooding due to wildland fire
hazards. (DEIR pp. 5-32 to 5-33)
B. Impacts Identified in the EIR as No Impact or Less than Significant Impact - No Mitigation
Required
1. Air Quality
a. Localized Emissions
Potential Significant Impact: Whether the Project would expose sensitive receptors to substantial
pollutant concentrations. (Threshold c)
Finding: Impacts related to Air Quality Threshold c are discussed in detail in Subsection 4.1 of the EIR.
Based on the entire record, the City finds that the Project would be required to comply with
applicable regulatory requirements (as summarized in subsection 4.1.8 of the Draft EIR) and
would not expose sensitive receptors to substantial pollutant concentrations. No mitigation is
required.
Facts in Support of the Finding: The Project’s localized NOX, CO, and particulate matter (PM10 and
PM2.5) emissions would not exceed applicable SCAQMD thresholds
during Project construction or operation. Accordingly, Project
construction and Project operation would not expose any sensitive
receptors in the vicinity of the Project Site to substantial criteria pollutant
concentrations. Based on the relatively low traffic congestion levels, low
existing ambient CO concentrations, and the lack of any unusual
meteorological and/or topographical conditions in the Project vicinity,
the Project is not expected to cause or contribute to a CO “hot spot.”
Impacts due to localized air quality emissions would be less than
significant. Implementation of the Project: 1) would not exceed
applicable SCAQMD localized criteria pollution emissions thresholds
during construction and operation; 2) would not expose sensitive
receptors to toxic air contaminants (i.e., DPM) that exceed the applicable
SCAQMD carcinogenic and non-carcinogenic risk thresholds; and 3)
would not cause or contribute to the formation of a CO “hot spot.”
Impacts would be less than significant. (DEIR pp. 4.1-29 to 4.1-31 and
4.1-36)
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2. Cultural Resources
a. Archaeological Resources
Potential Significant Impact: Whether the Project would cause a substantial adverse change in the
significance of an archaeological resource as defined in Section 15064.5.
(Threshold b)
Finding: Impacts related to Cultural Resources Threshold b are discussed in detail in Subsection 4.3 of the
EIR. Based on the entire record, the City finds that the Project would not cause a substantial
adverse change in the significance of an archaeological resource as defined in CEQA Guidelines
Section 15064.5, and no mitigation is required. However, even though it is not required, out of an
abundance of caution, mitigation measure MM 4.3-2 shall apply to further ensure that Project
impacts to archaeological resources remain below a level of significance.
Facts in Support of the Finding: No archaeological resources are known to be present in the Study Area.
Aside from grading within the eastern and southeastern portions of the
Development Site that contain stockpiles of earthwork material, grading
activities associated with the Project would not exceed a depth of 3.5
feet, and proposed grading throughout the Development Site would not
involve disturbances to any native soils that may have the potential to
contain archaeological resources. As such, it is not reasonably
foreseeable that archaeological resources would be uncovered during
Project-related grading activities. Accordingly, the Project would not
cause a substantial adverse change in the significance of an
archaeological resource as defined in CEQA Guidelines Section 15064.5,
and impacts would be less than significant. (DEIR p. 4.3-14)
Although Project impacts to archaeological resources would be less than
significant, out of an abundance of caution the following mitigation
measure shall apply to further ensure that Project impacts to
archaeological resources remain below a level of significance.
MM 4.3-2 As a condition of grading permit issuance, the construction
contractor personnel involved in grading operations shall be trained on
the visual identification of archaeological resources by a member of the
Cultural Resources Management Department for the San Manuel Band
of Mission Indians. If archaeological resources are discovered during
any earth-moving operations associated with the proposed Project, the
construction contractor shall be required to temporarily halt all work
within 50 feet of the discovered resource until a representative of the San
Manuel Band of Mission Indians and a professional archaeologist are
called to the site to evaluate the suspected resource. Should resource
evaluation require additional archaeological fieldwork, a Phase II
Testing Plan (Plan) shall be created by the archaeologist and be
submitted to the San Manuel Band of Mission Indians and the City of San
Bernardino for review and approval prior to implementation. The Plan
shall include non-collection methods, non-destructive analysis methods,
and allow for Tribal monitors to be present during testing, if requested
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by the San Manuel Band of Mission Indians. Further Project-related
ground-disturbing activities shall not resume within the area of the
discovery until resource evaluation is completed and the appropriate
treatment has been implemented, as agreed upon by the San Manuel
Band of Mission Indians and the City of San Bernardino. If preservation
in place is not feasible, the archaeologist shall create a Phase III
archaeological data recovery plan to include the removal of the
resource(s), with the presence of Tribal monitors (if requested by the San
Manuel Band of Mission Indians), and subsequent laboratory
processing/analysis to exhaust all data potential. This plan shall be
submitted to the San Manuel Band of Mission Indians and the City of San
Bernardino for review and approval prior to implementation. All
collected Native American resources shall be reburied on site as close to
the original find location as possible, in an area where the resource will
be avoided, capped, or otherwise protected in perpetuity. (DEIR p. 4.3-
16)
3. Greenhouse Gas Emissions
a. Conflict with an Applicable Plan, Policy, or Regulation
Potential Significant Impact: Whether the Project would conflict with an applicable plan, policy, or
regulation adopted for the purpose of reducing the emissions of greenhouse
gases. (Threshold b)
Finding: Impacts related to Greenhouse Gas Emissions Threshold b are discussed in detail in Subsection
4.4 of the EIR. Based on the entire record, the City finds that the Project would not conflict with
an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of
greenhouse gases, and no mitigation is required.
Facts in Support of the Finding: The Project would be consistent with or otherwise would not conflict
with the CARB 2017 Scoping Plan, which is the applicable plan adopted
for the purpose of reducing the emissions of greenhouse gases. The 2017
Scoping Plan Update reflects the 2030 target of a 40% reduction belo w
1990 levels, set by Executive Order B-30-15 and codified by SB 32. The
Project would not conflict with any of the provisions of the Scoping Plan
and in fact supports seven of the action categories. Further, recent studies
show that the State’s existing and proposed regulatory framework will
allow the State to reduce its greenhouse gas emissions level to 40%
below 1990 levels by 2030. Therefore, the Project would not conflict
with an applicable plan, policy, or regulation adopted for the purpose of
reducing the emissions of greenhouse gases, and impacts would be less
than significant. (DEIR p. 4.4-27)
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4. Hydrology and Water Quality
a. Topography
Potential Significant Impact: Whether the Project would substantially alter the existing drainage pattern
of the site or area, including through the alteration of the course of a stream
or river, or through the addition of impervious surfaces, in a manner which
would impede or redirect flood flows. (Draft EIR Threshold a)
Finding: Impacts related to Hydrology and Water Quality Threshold a are discussed in detail in Subsection
4.5 of the EIR. Based on the entire record, the City finds that the Project would not impede or
redirect flood flows, and no mitigation is required.
Facts in Support of the Finding: The eastern portions of the Development Site are subject to inundation
during 500-year flood events and could be subject to up to one foot of
inundation during 100-year storm events. Although the eastern portions
of the Development Site are subject to inundation during peak storm
events, a majority of flood flows in the area would occur within the
Santa Ana River channel, which is located approximately 0.4 mile
southeast of the Development Site. As proposed, the Project generally
would maintain the site’s existing topography, and there would be no
change to the site’s potential for inundation during floods as compared to
existing conditions. With implementation of the Project, the majority of
flood flows would still continue to be confined to the Santa Ana River
channel. Because the Development Site occurs at the fringe areas subject
to inundation during peak flood events, and because no substantial
changes are proposed to the site’s topography, the Project would not
impede or redirect any flood flows. Therefore, impacts would be less
than significant. (DEIR p. 4.5-6)
b. Pollutant Risk from Flood Hazard, Tsunami, or Seiche
Potential Significant Impact: Whether the Project would result in flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project inundation. (Draft EIR Threshold b)
Finding: Impacts related to Hydrology and Water Quality Threshold b are discussed in detail in
Subsection 4.5 of the EIR. Based on the entire record, the City finds that the Project would not
risk the release of pollutants due to inundation by tsunamis, seiches, or other flood hazards, and
no mitigation is required.
Facts in Support of the Finding: The Project Site is located approximately 50 miles from the Pacific
Ocean and there are no large bodies of water in the vicinity capable of
producing tsunamis or seiches that could affect the Project Site. The
eastern portions of the Project Site are subject to inundation during 500-
year flood events and could be subject to up to one foot of inundation
during 100-year storm events. The Project entails development of a
1,153,644 s.f. warehouse building on the Development Site. Consistent
with similar warehouse uses, the Project business operations primarily
would be conducted within the enclosed building, except for traffic
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movement, parking, and loading and unloading of trucks at designated
loading bays. There is no reasonable potential that large quantities of
uncontained pollutants would be stored outside the proposed building.
Thus, in the event that the Project Site is inundated during peak storm
events, there is no reasonable potential that substantial pollutants would
come into contact with water and adversely affect water quality. The
Project Site is located within an area subject to inundation in the event of
a failure at the Seven Oaks Dam, located approximately 6.8 miles east of
the Project Site. The dam structure, which was completed in 2000, is a
550-foot-high earth and rock fill dam with a crest length of 2,980 feet.
The Seven Oaks Dam is part of the Santa Ana River Mainstem project
which provides the necessary flood protection for hundreds of square
miles of developed lands within Orange, Riverside, and San Bernardino
Counties. The Seven Oaks Dam has been designed to resist an
earthquake measuring 8.0 on the Richter scale, and also is designed to
provide flood protection during 350-year floor events. Based on design
characteristics and on-going maintenance of the dam’s structural
integrity, it is highly unlikely that the Project Site would be subject to
inundation due to a failure of the Seven Oaks Dam. Accordingly, impacts
due to the release of pollutants during inundation from flood events,
tsunamis, or seiches would be less than significant. (DEIR pp. 4.5-6 and
4.5-7)
5. Land Use and Planning
a. Conflicts with Plans
Potential Significant Impact: Whether the Project would cause a significant environmental impact due to
a conflict with any land use plan, policy, or regulation adopted for the
purpose of avoiding or mitigating an environmental effect. (Draft EIR
Threshold a)
Finding: Impacts related to Land Use and Planning Threshold a are discussed in detail in Subsection 4.6 of
the EIR. Based on the entire record, the City finds that the Project would not result in significant
land use and planning conflicts in the context of compliance with applicable environmental plans,
policies, and regulations beyond those identified in other Subsections of the EIR. Impacts would
be less than significant; therefore, mitigation is not required.
Facts in Support of the Finding: The Project’s proposed General Plan Amendment, Development
Code/Zoning Map Amendment, and amendment to the SBAC-SP would
eliminate inconsistencies between the proposed on-site land use and the
site’s existing zoning classifications and land use designations. The
Project would not result in significant land use and planning conflicts in
the context of compliance with applicable environmental plans, policies,
and regulations beyond those identified in other Subsections of the Draft
EIR. (DEIR pp. 4.6-8 to 4.6-13)
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6. Noise
a. Groundborne Vibration or Noise
Potential Significant Impact: Whether the Project would result in the generation of excessive
groundborne vibration or groundborne noise levels. (Draft EIR Threshold b)
Finding: Impacts related to Noise Threshold b are discussed in detail in Subsection 4.7 of the EIR. Based
on the entire record, the City finds that Project construction-related activities and operation
would not generate excessive groundborne vibration or groundborne noise levels and impacts
would be less than significant. No mitigation is required.
Facts in Support of the Finding: At distances ranging from 134 feet (at location R1) to 756 feet (at
location R2) from Project construction activities (measured from the
Development Site boundary), construction vibration levels are estimated
to range from 49.6 to 72.1 VdB and would remain below the FTA
Transit Noise and Vibration Impact Assessment Manual maximum
acceptable vibration criteria of 78 VdB for daytime residential uses at all
receiver locations. Therefore, the Project-related vibration impacts
during construction-related activities would be less than significant.
Under long-term conditions, the operational activities of the Project
would not include or require equipment, facilities, or activities that
would result in perceptible ground-borne vibration. Accordingly, Project
operation would not generate excessive groundborne vibration or
groundborne noise levels and impacts would be less than significant.
(DEIR pp. 4.7-30 and 4.7-31)
7. Transportation
a. Conflict with Program, Plan, Ordinance, or Policy
Potential Significant Impact: Whether the Project would conflict with an applicable program, plan,
ordinance, or policy addressing the circulation system, including transit,
roadway, bicycle, and pedestrian facilities. (Threshold a)
Finding: Impacts related to Transportation Threshold a are discussed in detail in Subsection 4.8 of the
EIR. Based on the entire record, the City finds that with implementation of transportation
improvements and fair-share contributions towards improvements required by the City as
conditions of Project approval, the Project would not conflict with a program, plan, ordinance, or
policy addressing the circulation system and impacts would therefore be less than significant. No
mitigation is required.
Facts in Support of the Finding: The Project would be consistent with the goals and policies of SCAG’s
regional planning program and any applicable General Plan policies
addressing the circulation system.
Based on the results of the Project’s Traffic Impact Analysis, the City
has conditioned the Project to implement several intersection
improvements and make fair-share funding payments for intersection
improvement. The Project must comply with Regulatory
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Requirement/Design Requirement (RRDR) 4.8-1. (DEIR pp. 4.8-9 to
4.8-11)
8. Tribal Cultural Resources
a. Known Tribal Cultural Resources
Potential Significant Impact: Whether the Project would cause a substantial adverse change in the
significance of a tribal cultural resource (TCR), defined in Public Resources
Code Section 21074 as either a site, feature, place, cultural landscape that is
geographically defined in terms of the size and scope of the landscape,
sacred place, or object with cultural value to a California Native American
tribe, and that is: (1) Listed or eligible for listing in the California Register
of Historical resources or in a local register of historical resources as
defined in Public Resources Code section 5020.1(k); or (2) A resource
determined by the lead agency, in its discretion and supported by substantial
evidence, to be significant pursuant to criteria set forth in subdivision (c) of
Public Resources Code Section 5024.1. (Threshold a)
Finding: Impacts related to Tribal Cultural Resources Threshold a are discussed in detail in Subsection 4.9
of the EIR. Based on the entire record, the City finds that Project impacts to Tribal Cultural
Resources would be less than significant, no mitigation is required. Additionally, implementation
of Mitigation Measure MM 4.3-2 as identified to further reduce the Project’s less-than-significant
impacts to archaeological resources also would apply, and would further serve to ensure that the
Project’s impacts to TCRs remain below a level of significance.
Facts in Support of the Finding: The Project Site and off-site improvement areas do not contain any
known TCRs, and proposed grading throughout the Development Site
would not involve disturbances to any native soils that may have the
potential to contain previously-undiscovered archaeological resources
(including TCRs). Although it is not reasonably foreseeable that impacts
to archaeological resources (including TCRs) would occur, the City of
San Bernardino has identified Mitigation Measure MM 4.3-2 as the
procedure that would be undertaken should the construction contractor
encounter resources that warrant evaluation to ensure that significant
impacts do not occur. Although impacts to TCRs are not reasonably
foreseeable and would be less than significant, Mitigation Measure MM
4.3-2, included above for Cultural Resources, shall apply. (DEIR pp.
4.9-3 and 4.9-4)
C. Impacts Identified in the EIR as Less than Significant with Mitigation Incorporated
1. Biological Resources
a. Habitat Modification
Potential Significant Impact: Whether the Project would have a substantial adverse effect, either directly
or through habitat modifications, on any species identified as a candidate,
sensitive, or special status species in local or regional plans, policies, or
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regulations, or by the California Department of Fish and Wildlife or U.S.
Fish and Wildlife Service. (Threshold a)
Finding: Impacts related to Biological Resources Threshold a are discussed in detail in Subsection 4.2 of
the EIR. Based on the entire record, the City finds that the Project has the potential to result in
impacts to native and migratory birds and burrowing owls. Mitigation is required, and would
reduce impacts to less-than-significant levels.
Facts in Support of the Finding: The Project would not result in direct or indirect impacts to riparian
habitat, sensitive natural plant communities, special-status plants,
special-status animals, or State- or federally-protected wetlands.
However, the Project has the potential to impact active migratory bird
nests containing sensitive bird species if vegetation is removed during
the nesting season (February 1 to September 15), which is considered a
significant direct impact. Additionally, there is a potential for the
Development Site to become occupied by the burrowing owl prior to
commencement of construction activities. The Project’s potential
impacts to the burrowing owl are considered a significant direct and
cumulatively-considerable impact.
Implementation of Mitigation Measure MM 4.2-1 would ensure that pre-
construction surveys are conducted for nesting and migratory birds
protected by the federal MBTA and/or California Fish and Game Code
during the breeding season to determine presence or absence prior to
disturbance of habitat with the potential to support nesting birds. With
implementation of the required mitigation, potential direct impacts to
nesting and migratory birds protected by the federal MBTA and/or
California Fish and Game Code would be reduced to below a level of
significance. Implementation of Mitigation Measure MM 4.2-2 would
ensure that pre-construction surveys are conducted for the burrowing owl
to determine the presence or absence of the species prior to ground-
disturbing construction activities. With implementation of the required
mitigation, potential direct and cumulatively-considerable impacts to the
burrowing owl would be reduced to below a level of significance. (DEIR
pp. 4.2-13 and 4.2-14)
MM 4.2-1: As a condition of tree removal permits, clearing permits, and
any other permits that would authorize vegetation removal, the
disturbance to and removal of trees and other potential bird nesting
habitat shall be prohibited during the migratory bird nesting season
(February 1 through September 15) unless a migratory bird nesting
survey is completed. If vegetation removal is planned to occur during the
migratory bird nesting season (February 1 – September 15), then a
migratory bird nesting survey shall be completed in accordance with the
following requirements:
a) Within three (3) days prior to initiating tree removals and/or
vegetation clearing, a nesting bird survey shall be conducted by
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a qualified biologist within the suitable habitat to be removed
and within a 250-foot radius.
b) If the survey identifies the presence of active sensitive bird nests,
then the nests shall not be disturbed unless the qualified biologist
verifies through non-invasive methods that either (i) the adult
birds have not begun egg-laying and incubation; or (ii) the
juveniles from the occupied nests are capable of independent
survival.
c) If the biologist is not able to verify any of the conditions from
sub-item “b,” above, then no disturbance shall occur within a
buffer zone specified by the qualified biologist for each nest or
nesting site. The buffer zone shall be species-appropriate (no less
than 100-foot radius around the nest for non-raptors and no
more than a 500-foot radius around the nest for raptors, or as
otherwise determined by the qualified biologist) and shall be
sufficient to protect the nest from direct and indirect impacts
from construction activities. The nests and buffer zones shall be
field checked approximately weekly by a qualified biological
monitor. The approved buffer zone shall be marked in the field
with construction fencing, within which no vegetation clearing or
ground disturbance shall commence until the qualified biologist
with City concurrence verify that the nests are no longer
occupied and/or juvenile birds can survive independently from
the nests.
MM 4.2-2: Within between 14 and 30 days prior to ground-disturbing
activities (i.e., tree removals, demolition, clearing, grading, etc.), a
qualified biologist shall conduct a survey of suitable habitat in the
disturbance area and within a 250-foot radius and make a determination
regarding the presence or absence of the burrowing owl. The
determination shall be documented in a report and shall be submitted to
and accepted by the City of San Bernardino prior to commencement of
ground-disturbing activities. The following provisions shall apply:
a) In the event that the pre-construction survey identifies no
burrowing owls on the property ground-disturbing activities may
commence without restriction.
b) In the event that the pre-construction survey identifies the
presence of the burrowing owl, then:
i. If a site-specific exclusion and translocation plan for
burrowing owl has not already been approved by the CDFW,
the Project Applicant shall retain a qualified biologist to
prepare such a plan for review and approval by the CDFW.
This plan will identify the procedures to be followed to
exclude and/or translocate burrowing owls from the site, with
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separate procedures identified for during the breeding season
and outside of the breeding season.
ii. No ground disturbance (tree removals, demolition, clearing,
grubbing, grading) shall occur within 50 meters of occupied
burrows during the non-breeding season (September 1
through January 31) or within 75 meters of occupied burrows
during the breeding season (February 1 through August 31),
until the owls have fledged as confirmed by a qualified
biologist or have been relocated per the CDFW-approved
exclusion and translocation plan. (DEIR pp. 4.2-12 and 4.2-
13)
2. Cultural Resources
a. Historical Resources
Potential Significant Impact: Whether the Project would cause a substantial adverse change in the
significance of a historic resource as defined in Section 15064.5. (Threshold
a)
Finding: Impacts related to Cultural Resources Threshold a are discussed in detail in Subsection 4.3 of the
EIR. Based on the entire record, the City finds that mitigation measures are required to address
the remote potential that subsurface historical resources may be impacted by development of the
Project as proposed. With implementation of the required mitigation, potential direct and
cumulatively-considerable impacts to the historic resources would be reduced to below a level of
significance.
Facts in Support of the Finding: The Project Site does not contain any historical resources as defined in
CEQA Guidelines Section 15064.5. Although a water tower of local
historic interest occurs on site, this water tower would be relocated on
site if feasible, and if relocation of the water tower is not feasible the
Project Applicant would construct a replica of the water tower on site.
With relocation or construction of a replica water tower, the Project’s
impacts to known historical resources would be less than significant
requiring no mitigation. However, the Project Site has the potential to
contain subsurface historical resources, such as those related to the
Project Site’s previous inclusion in Norton Air Force Base, that could be
uncovered during grading and ground-disturbing activities. Thus, there is
a possibility that subsurface historic resources may be impacted by
development of the Project as proposed. This is evaluated as a potentially
significant impact for which mitigation would be required. Mitigation
measure MM 4.3-1 shall apply to reduce to below a level of significance
the Project’s potential impacts to previously-undiscovered subsurface
historical resources. (DEIR pp. 4.3-13 to 4.3-15)
MM 4.3-1 As a condition of grading permit issuance, the construction
contractor personnel involved in grading operations shall be trained by
a qualified professional historic resources consultant on the visual
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identification of historic resources. If historic resources are discovered
during any earth-moving operations associated with the proposed
Project, the construction contractor shall be required to temporarily halt
all work within 50 feet of the discovered resource until the professional
historic resources consultant is called to the site to evaluate the
suspected resource. Any material uncovered and that is determined by
the professional historical resources consultant to comprise a
historically significant resource shall be curated at a public, non-profit
institution with a research interest in the materials, if such an institution
agrees to accept the material. If no institution accepts the historic
material, they shall be offered to a local school or historical society in
the area for educational purposes.
3. Transportation
a. Safety Hazards
Potential Significant Impact: Whether the Project would substantially increase hazards to a geometric
design feature (e.g., sharp curves or dangerous intersections) or
incompatible uses (e.g., farm equipment). (Threshold c)
Finding: Impacts related to Transportation Threshold c are discussed in detail in Subsection 4.8 of the
EIR. Based on the entire record, the City finds that the Project would not substantially increase
hazards to a geometric design feature or incompatible uses. With required implementation of a
traffic control plan during construction and the installation of signage as part of the Project’s
design, impacts would be less than significant and no mitigation is required. However, even
though it is not required, Mitigation Measures MM 4.8-1 through 4.8-4 are recommended to
assure that a traffic control plan will be prepared and implemented and that design features will
be implemented as part of the Project’s implementation pertaining to bicycle and pedestrian
safety.
Facts in Support of the Finding: No safety hazards are anticipated at the Project’s driveways along W
Street and Victoria Avenue, as no trucks would be using the Victoria
Avenue driveways and the main truck entrance and exit would occur at
W Street, where low levels of passenger car, pedestrian, and bicycle
traffic are anticipated. Additionally, the Project would not present any
obstructions to implementing the planned City Creek Trail; as part of the
Development Project’s construction, bicycle crossing pavement
markings would be enhanced across 3rd Street at the 3rd Street and
Victoria Avenue intersection to enhance bicycle safety. Any
construction-related hazards would be addressed in a required traffic
control plan and any potential operational hazards would be addressed by
signage incorporated into the Project’s design.
Although transportation safety impacts would be less than significant,
the following mitigation measures are recommended and included to
address bicycle and pedestrian safety.
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MM 4.8-1: Prior to grading and building permit issuance, the City of
San Bernardino shall review grading and building plans to ensure that
notes are included on the plans requiring the following. The City or its
designee also shall be responsible for monitoring and enforcement of
adherence to these notes.
The construction contractor shall ensure that the Development
Site’s frontage with 3rd Street is swept at least twice per day
using SCAQMD Rule 1186 certified street sweepers during
grading and paving operations, and shall sweep the 3rd Street
frontage more frequently during grading and paving operations
if visible soil materials or debris are carried onto the roadway,
including in the bicycle lane.
The construction contractor shall adhere to a traffic control plan
approved by the City of San Bernardino, including but not
limited to all requirements in the plan addressing vehicular,
pedestrian, and bicycle safety.
MM 4.8-2: As part of street improvement plans for the 3rd Street and
Victoria Avenue intersection and with concurrence of the City of
Highland, the developer shall be required to enhance the intersection
pavement markings to demark bike lane crossings across 3rd Street at
the intersection.
MM 4.8-3: Prior to building permit issuance, the City of San Bernardino
shall review building plans to ensure that specifications are noted to
install painted crosswalks or enhanced paving materials denoting the
pedestrian and bicycle lane crossings across the Project’s driveways
connecting with 3rd Street. The markings are required to be bold enough
to be noticeable by truck drivers, for the purpose of visually alerting
drivers that pedestrians and bicyclists could be crossing the driveways.
The City shall verify that the markings are installed prior to the issuance
of an occupancy permit.
MM 4.8-4: The developer and all successors in interest shall install and
maintain signs at the Project driveway exits connecting with 3rd Street at
heights visible to truck drivers that state, “CAUTION, PEDESTRIAN
AND BICYCLE CROSSINGS AHEAD.” The City shall verify installation
of the signs prior to the issuance of an occupancy permit and require as
a condition of the occupancy permit that the signs be maintained in
legible condition. (DEIR pp. 4.8-14 and 4.8-15)
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D. Impacts Determined by the EIR to be Significant and Unavoidable
1. Air Quality
a. Air Quality Plan
Potential Significant Impact: Whether the Project would conflict with or obstruct implementation of the
applicable air quality plan. (Threshold a)
Finding: Impacts related to Air Quality Threshold a are discussed in detail in Subsection 4.1 of the EIR.
Based on the entire record, the City finds that the Project would exceed the growth projections
contained in SCAQMD’s 2016 AQMP and, also, would emit levels of nitrogen oxides (NOx)
under both construction and operation that would contribute to a delay in the attainment of
federal and State ozone standards in the South Coast Air Basin (SCAB). As such, the Project
would conflict with and could obstruct implementation of the AQMP and impacts would
therefore be significant prior to mitigation on both a direct and cumulatively-considerable basis.
Although mitigation measures identified in the EIR would reduce the Project’s construction-
related emissions to below the SCAQMD thresholds of significance, the City finds that there are
no feasible mitigation measures available to reduce the Project’s operational emissions of NOX to
below the SCAQMD threshold of significance for this criteria pollutant. Accordingly, due to the
Project’s operational emissions of NOX and because the Project would exceed the growth
projections of the 2016 AQMP, the Project would result in significant and unavoidable impacts
due to a conflict with the 2016 AQMP.
Facts in Support of the Finding: The SCAQMD Final 2016 AQMP is the applicable air quality plan for
the Project area and contains criteria for determining consistency with
the Final 2016 AQMP. The SCAQMD’s Consistency Criterion No. 1
refers to violations of the National Ambient Air Quality Standards
(NAAQS) and California Ambient Air Quality Standards (CAAQS).
Violations of the NAAQS and/or CAAQS would occur if the SCAQMD
localized emissions thresholds were exceeded. Project-related activities
would not exceed SCAQMD localized emissions thresholds during
construction or long-term operation. However, Project-related activities
would exceed the SCAQMD regional emissions threshold for NOx
during construction and long-term operation. Related to long-term
Project operation, mobile source emissions account for approximately 91
percent, by weight, of the Project’s total operational NOx emissions.
Mobile source emissions are regulated by standards imposed by federal
and State agencies, not local governments such as the City of San
Bernardino. NOx is a precursor for ozone; thus, Project construction and
operational activities would have the potential to contribute a substantial
volume of pollutants to the SCAB that could delay the attainment of
federal and State ozone standards. As such, prior to mitigation the
Project would conflict with Consistency Criterion No. 1.
SCAQMD Consistency Criterion No. 2 refers to the Project’s
consistency with the growth projections anticipated by the Final 2016
AQMP. Under existing conditions, approximately 49.6 acres of the
Project Site are designated for “Light Industrial (IL)” land use and
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approximately 12.89 acres of the Project Site is designated for “Public
Facility/Quasi-Public (PF)” by the City of San Bernardino’s General
Plan Land Use Map. The Project includes a request to change the
approximate 12.89-acre area from “PF” to “IL” and the land use
designation of approximately 4.89 acres of the Project Site located west
of Victoria Avenue from “IL” to “PF,” which, if approved, would result
in a land use and development intensity that was not anticipated by the
General Plan and, by extension, the growth models that were used in the
2016 AQMP. Accordingly, implementation of the Project would exceed
the assumptions in the AQMP based on the years of Project buildout
phase, and therefore would conflict with Consistency Criterion No. 2.
In summary, because the proposed Project does not satisfy Consistency
Criterion No. 1 or Consistency Criterion No. 2, the Project is determined
to be inconsistent with the 2016 AQMP. As such, the Project would
conflict with and could result in the obstruction of the applicable AQMP
and a significant impact would occur prior to mitigation. (DEIR pp. 4.1-
26 and 4.1-27)
Implementation of Mitigation Measures MM 4.1-1 through MM 4.1-3C
would reduce the Project’s construction-related emissions of NOx to
below the SCAQMD regional thresholds for this pollutant. Although
MM 4.1-4 through MM 4.1-9 would reduce the Project’s operational-
related emissions of NOx, the mitigation measures would not reduce NOx
emissions to below the applicable SCAQMD regional threshold. Mobile
source emissions account for approximately 91 percent, by weight, of the
Project’s total operational NOx emissions. Mobile source emissions are
regulated by standards imposed by federal and State agencies, not local
governments. No other mitigation measures related to vehicle tailpipe
emissions are available that are within the City of San Bernardino’s
jurisdictional authority that, also, are feasible for the City of San
Bernardino to enforce and have a proportional nexus to the Project’s
level of impact. Additionally, the Project would exceed the growth
assumptions for the Project Site relied upon in the SCAQMD 2016
AQMP, and no additional feasible mitigation is available to address this
impact. Therefore, Project impacts due to a conflict with the SCAQMD
2016 AQMP would be significant and unavoidable on both a direct and
cumulatively-considerable basis. (DEIR pp. 4.1-40 and 4.1-41)
(MMs 4.1-1 through 4.1-9 and RRDRs 4.1-1 through 4.1-3 are listed
below after discussion of Criteria Pollutant Increase, Air Quality
Threshold b).
b. Criteria Pollutant Increase
Potential Significant Impact: Whether the Project would result in a cumulatively considerable net
increase of any criteria pollutant for which the Project region is considered
non-attainment under an applicable federal or State ambient air quality
standard. (Threshold b)
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Finding: Impacts related to Air Quality Threshold b are discussed in detail in Subsection 4.1 of the EIR.
Based on the entire record, the City finds that Project-related activities would exceed the
applicable SCAQMD regional thresholds for NOx emissions during Project construction and
long-term operation of the Project. As such, Project-related emissions would violate SCAQMD
air quality standards and contribute to the non-attainment of ozone standards in the SCAB. This
impact is significant and mitigation is required. Although mitigation measures are identified to
reduce Project-related construction emissions of NOX to below the SCAQMD regional threshold
for NOX, additional feasible mitigation measures are not available to reduce the Project’s
operational-related emissions of NOX to below the SCAQMD regional threshold for this
pollutant.
Facts in Support of the Finding: Based on the entire record, the City finds that prior to mitigation, the
Project’s construction-related activities have the potential to result in
emissions of NOX that would exceed the SCAQMD regional threshold
for this pollutant. Mitigation Measures MM 4.1-1 through MM 4.1-3C
have been identified and included in the Project’s conditions of approval.
With implementation of the required mitigation, Project construction-
related emissions of NOX would be reduced to below the SCAQMD
regional threshold for NOX. Thus, implementation of the required
mitigation would reduce the Project’s construction-related air quality
impacts to below a level of significance.
In addition, the City finds that the Project’s long-term operational
emissions of nitrogen oxides (NOx) would violate SCAQMD’s air
quality standard, as well as contribute to an existing air quality violation.
The City also finds that mitigation measures applied to the Project would
lessen long-term emissions of NOx but would not reduce the Project’s
long-term emissions of NOx to less-than-significant levels. The City also
finds that no other feasible mitigations are available that would reduce
the Project’s long-term emissions of NOx to less-than-significant levels.
Peak Project operational NOx emissions, which primarily are emitted
from vehicle tailpipes, would exceed the applicable SCAQMD regional
threshold. NOx is a precursor for ozone, a pollutant for which the SCAB
does not attain federal (NAAQS) or State (CAAQS) standards.
Accordingly, the Project’s daily NOx emissions during long-term
operation would violate the SCAQMD regional threshold for this
pollutant and would result in a cumulatively considerable net increase of
a criteria pollutant for which the Project region is in non-attainment. This
impact is significant and mitigation is required.
Mitigation Measures MM 4.1-4 through MM 4.1-9 would reduce the
Project’s overall demand for energy resources and would reduce the
Project’s operational NOx emissions (NOx is released during the
combustion of certain types of energy resources). However, mobile
source emissions account for approximately 91 percent, by weight, of the
Project’s total operational NOx emissions. Mobile source emissions are
regulated by standards imposed by federal and State agencies, not local
governments. No other mitigation measures related to vehicle tailpipe
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emissions are available that are within the City of San Bernardino’s
jurisdictional authority that, also, are feasible for the City of San
Bernardino to enforce and have a proportional nexus to the Project’s
level of impact. As such, it is concluded that operation of the Project
would generate NOx emissions that would exceed the applicable
SCAQMD regional air quality threshold on a daily basis. The Project’s
operational-related NOx emissions also would cumulatively contribute to
an existing air quality violation in the SCAB (i.e., ozone concentrations),
as well as cumulatively contribute to the net increase of a criteria
pollutant for which the SCAB is considered non-attainment (i.e., federal
and State ozone concentrations). Accordingly, the Project’s long-term
operational-related emissions of NOx are concluded to result in a
significant and unavoidable impact on both a direct and cumulatively-
considerable basis. (DEIR pp. 4.1-27 to 4.1-29)
The following mitigation measures would reduce the Project’s
construction-related NOx emissions and the contributions of this
pollutant to the SCAB’s non-attainment status for ozone:
MM 4.1-1 Prior to grading permit issuance, the City of San Bernardino
shall review grading plans to ensure that a notation is included requiring
the grading contractor to utilize CARB Tier 4 Final Compliant
equipment in lieu of Tier 3 Compliant or Tier 4 Interim Compliant
equipment if Tier 4 equipment can be reasonably acquired by the Project
contractor. If Tier 4 Final Compliant equipment is not feasible to use
during grading activity due to lack of local availability of such
equipment, the Project Applicant or grading contractor shall provide
evidence to the City of San Bernardino showing that the grading
contractor attempted to secure the use of Tier 4 Final Compliant
equipment, but such equipment was not locally available (within a 50
mile radius). The notations shall require that all Tier 3 Compliant and
Tier 4 Interim Compliant equipment over 50 hp, if used, shall be fitted
with the best available control technology (BACT) devices, if technically
feasible and if the BACT devices can be reasonably acquired by the
Project grading contractor, to minimize air pollutant emissions. These
requirements also shall be specified in bid documents issued to
prospective grading contractors. In order to demonstrate compliance,
the grading contractor shall keep a copy of each unit’s certified tier
specification and CARB or SCAQMD operating permit (if applicable) on
the Development Site in a location available to the City or City designee
for inspection upon request. The City shall review and approve the list
of equipment over 50 hp, their CARB tier levels, and list of BACT devices
installed on Tier 3 Compliant and Tier 4 Interim Compliant equipment,
prior to the mobilization of grading equipment to the site.
MM 4.1-2 Prior to grading permit issuance, the City of San Bernardino
shall review grading plans to ensure that notification is included
requiring that all on-road heavy-duty diesel trucks with a gross vehicle
weight rating greater than 14,000 pounds with a 2010 model year engine
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or newer or shall be equipped with a particulate matter trap, as
available. This requirement also shall be specified in bid documents
issued to prospective construction contractors. The grading contractor
shall keep a copy of records for all on-road heavy-duty diesel trucks with
a gross vehicle weight rating greater than 14,000 pounds to demonstrate
compliance with this requirement, and the records shall be made
available to the City or City’s designee for inspection upon request.
MM 4.1-3 Prior to grading permit issuance, the City of San Bernardino
shall review grading plans to ensure that notification is included
requiring that all construction equipment shall comply with all
applicable California Air Resources Board (CARB) air quality
regulations. Also, the notes shall require that all Project construction
contractors must tune and maintain all construction equipment in
accordance with the equipment manufacturer’s recommended
maintenance schedule and specifications. These requirements also shall
be specified in bid documents issued to prospective construction
contractors. Maintenance records for all pieces of equipment shall be
kept on-site for the duration of construction activities and shall be made
available for periodic inspection by City of San Bernardino staff or their
designee.
MM 4.1-3A Plans submitted for grading permit issuance and building
permit issuance shall specify a designated area of the construction site
where electric or non-diesel vehicles, equipment, and tools can be fueled
or charged. The provision of temporary electric infrastructure for such
purpose shall be approved by the utility provider, Southern California
Edison (SCE). If SCE will not approve the installation of temporary
power for this purpose, the establishment of a temporary electric
charging area will not be required. If electric equipment will not be
used on the construction site because the construction contractor(s) does
not have such equipment in its fleet (as specified in Mitigation Measure
MM 4.1-3C), the establishment of a temporary electric charging area
also will not be required. If electric-powered equipment is in the
contractor(s) equipment fleet, and SCE approval is secured, the
temporary charging location is required to be established upon issuance
of grading permits and building permits.
MM 4.1-3B If electric or non-diesel off-road trucks and construction
support equipment, including but not limited to hand tools, forklifts,
aerial lifts, materials lifts, hoists, pressure washers, plate compactors,
and air compressors are available in the construction contractor’s
equipment fleet and can fulfill the Project’s construction requirements
during the building construction, paving, and architectural coating
phases of Project construction, such equipment shall be used during
Project construction. This requirement shall be noted on plans submitted
for building permit issuance.
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MM 4.1-3C Plans submitted for grading permit issuance and building
permit issuance shall specify the locations where anti-idling signs will be
located. Signs shall be placed on the construction site where medium
and heavy-duty trucks and other heavy equipment will stage, identifying
applicable California Air Resources Board (CARB) anti-idling
regulations. At a minimum, each sign shall include: 1) instructions to
shut off engines when equipment is not in use; and 2) instructions to
restrict idling to no more than five (5) minutes.
The following mitigation measures would reduce the Project’s
operational-related NOx emissions and the contributions of this pollutant
to the SCAB’s non-attainment status for ozone.
MM 4.1-4 The Project developer and all successors in interest shall
install and maintain legible, durable, weather-proof signs at truck access
gates, loading docks, and truck parking areas that identify applicable
California Air Resources Board (CARB) anti-idling regulations. At a
minimum, each sign shall include instructions for drivers of diesel-fueled
trucks to restrict idling to no more than five minutes. The Project
developer or successor(s) in interest shall permit City of San Bernardino
staff to conduct a site inspection to ensure that the signs are in place and
maintained.
MM 4.1-5 The Project developer and all successors in interest shall
install and maintain signs and/or painting/striping at on-site driveways
and drive aisles to clearly identify the on-site circulation pattern to
minimize unnecessary on-site vehicular travel. The Project developer or
successor(s) in interest shall permit City of San Bernardino staff to
conduct a site inspection to ensure that the signs/painting/striping are in
place and maintained.
MM 4.1-6 The Project developer and all successors in interest shall
provide the City of San Bernardino with an information packet that will
be provided to future building occupants that: 1) provides information
regarding the grants available from the Carl Moyer Memorial Air
Quality Standards Attainment Program for energy efficiency
improvement features – including truck modernization, retrofits, and/or
aerodynamic kits and low rolling resistance tires – and the resulting
benefits to air quality; 2) recommends the use of electric or alternatively-
fueled sweepers with HEPA filters; 3) recommends the use of water-
based or low VOC cleaning products; and 4) for occupants with more
than 250 employees, includes information related to SCAQMD Rule
2202, which requires the establishment of a transportation demand
management program to reduce employee commute vehicle emissions.
MM 4.1-7 The Project developer and all successors in interest shall
stipulate in building sale and lease agreements that all indoor and
outdoor forklifts and all outdoor cargo-handling equipment (e.g., yard
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trucks, hostlers, yard goats, pallet jacks, forklifts) shall be electric or
non-diesel fueled.
MM 4.1-8 The Project developer and all successors in interest shall
install and maintain a sign in public view with telephone, email, and
regular mail contact information for a designated representative of the
occupant who would receive complaints about excessive dust, fumes, or
odors. The sign shall also identify contact data for the City or SCAQM D
for perceived violations. The occupant’s representative shall keep
records of any complaints received and actions taken to communicate
with the complainant and resolve the complaint.
MM 4.1-9 The minimum number of automobile electric vehicle (EV)
charging stations required by the California Code of Regulations Title
24 shall be provided. In addition, and to facilitate the possible future
installation of infrastructure that would charge the batteries that power
the motors of electric-powered trucks, the following shall occur: (1) at
Shell building permit, an electrical room(s) and/or exterior area(s) of the
site shall be designated where future electrical panels would be located
for the purpose of supplying power to on-site charging facilities for
electric powered trucks; (2) conduit shall be installed from this
designated area where the panel would be located to the southwest
corner of the Development Site where the charging facilities would be
located and where electric-powered trucks would park and connect to
charging facilities. (DEIR pp. 4.1-38 to 4.1-40 and FEIR p. F-18)
The following are applicable regulatory requirements to which the
Project must comply. Because compliance with regulatory requirements
is mandatory and does meet CEQA’s definition for mitigation, they are
listed herein to demonstrate the Project’s compliance with applicable
requirements.
RRDR 4.1-1: The Project is required to comply with the provisions of
SCAQMD Rule 403, “Fugitive Dust” and Rule 403(e) “Additional
Requirements for Large Operations.” Rule 403 requires implementation
of best available dust control measures during construction activities
that generate fugitive dust, such as earth moving, grading, and
equipment travel on unpaved roads. Rule 403 also requires activities
defined as “large operations” to notify the SCAQMD by submitting
specific forms. The following notes shall be listed on the Project’s
grading plans, to be confirmed by the City of San Bernardino prior to
grading permit issuance. Project construction contractors shall be
required by their contracts to ensure compliance with the notes, submit
any required “large operations” forms to the SCAQMD, and permit
periodic inspection of the construction site by City of San Bernardino
staff or its designee to confirm compliance.
c) During grading and ground-disturbing construction activities,
the construction contractor shall ensure that all unpaved roads,
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active soil stockpiles, and areas undergoing active ground
disturbance within the Development Site are watered at least
three (3) times daily during dry weather. Watering, with
complete coverage of disturbed areas by water truck, sprinkler
system, or other comparable means, shall occur in the
midmorning, afternoon, and after work is done for the day. The
contractor or builder shall designate a person or persons to
monitor the dust control program and to order increased
watering, as necessary, to prevent transport of dust off site.
d) Temporary signs shall be installed on the construction site along
all unpaved roads indicating a maximum speed limit of 15 miles
per hour (MPH). The signs shall be installed before construction
activities commence and remain in place for the duration of
construction activities that include vehicle activities on unpaved
roads.
e) Gravel pads shall be installed at all access points to prevent
tracking of mud onto public roads.
f) Install and maintain trackout control devices in effective
condition at all access points where paved and unpaved access
or travel routes intersect (e.g., install wheel shakers, wheel
washers, limit site access).
g) When materials are transported off site, all material shall be
covered or effectively wetted to limit visible dust emissions, and
at least six inches of freeboard space from the top of the
container shall be maintained.
h) All street frontages adjacent to the construction site shall be
swept at least once a day using SCAQMD Rule 1186 certified
street sweepers utilizing reclaimed water trucks if visible soil
materials are carried to adjacent streets.
i) Post a publicly visible sign with the telephone number and
person to contact regarding dust complaints. This person shall
respond and initiate corrective action to legitimate complaints
within 24 hours.
j) Landscaping shall be planted as soon as possible to reduce the
disturbed area subject to wind erosion. Irrigation systems
required for these plants shall be installed as soon as possible to
maintain good ground cover and to minimize wind erosion of the
soil.
k) Any on-site stock piles of debris, dirt, or other dusty material
shall be covered or watered as necessary to minimize fugitive
dust pursuant to SCAQMD Rule 403.
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RRDR 4.1-2: The Project is required to comply with the provisions of
SCAQMD Rule 1186 “PM10 Emissions from Paved and Unpaved Roads
and Livestock Operations” and Rule 1186.1, “Less-Polluting Street
Sweepers” by complying with the following requirements. To ensure and
enforce compliance with these requirements, prior to grading and
building permit issuance, the City of San Bernardino shall verify that the
following notes are included on the grading and building plans. Project
construction contractors shall be required to ensure compliance with the
notes and permit periodic inspection of the construction site by City of
San Bernardino staff or its designee to confirm compliance.
a) If visible dirt or accumulated dust is carried onto paved roads
during construction, the contractor shall remove such dirt and
dust at the end of each work day by street cleaning.
b) Street sweepers shall be certified by the South Coast Air Quality
Management District as meeting the Rule 1186 sweeper
certification procedures and requirements for PM10 efficient
sweepers.
RRDR 4.1-3: The Project is required to comply with the provisions of
SCAQMD Rule 1113, “Table of Standards for Architectural Coatings,
Volatile Organic Compound (VOC) Limits.” Prior to building permit
issuance, the City of San Bernardino shall verify that a note is provided
on all building plans specifying that compliance with SCAQMD Rule
1113 is mandatory during application of all architectural coatings.
Project contractors shall be required to comply with the note and
maintain written records of such compliance that can be inspected by the
City of San Bernardino upon request. All architectural coatings shall
comply with the VOC limits prescribed by SCAQMD Rule 1113. (DEIR
pp. 4.1-36 to 4.1-38)
2. Greenhouse Gas Emissions
a. Operational Emissions of Greenhouse Gas
Potential Significant Impact: Whether the Project would generate greenhouse gas emissions, either
directly or indirectly, that may have a significant impact on the
environment. (Threshold a)
Finding: Impacts related to Greenhouse Gas Threshold a are discussed in detail in Subsection 4.4 of the
EIR. The City finds that the Project would exceed the SCAQMD/City’s screening threshold of
3,000 MTCO2e per year. Thus, the Project has the potential to result in a significant and
cumulatively-considerable impact with respect to greenhouse gas emissions.
Facts in Support of the Finding: The Project would result in approximately 23,514.15 MTCO2e per year;
thus, the proposed Project would exceed the City’s screening threshold
of 3,000 MTCO2e per year and would result in a significant
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cumulatively-considerable impact due to emissions of greenhouse gases
that may have a significant impact on the environment.
Implementation of applicable regulatory requirements, Mitigation
Measures MM 4.1-1 through MM 4.1-9, as well as Mitigation Measure
MM 4.4-1 and MM 4.1-2, would reduce the Project’s operational
emissions of greenhouse gases; however, these measures would not
substantially reduce Project mobile source emissions (i.e., emissions
from construction equipment, passenger cars, and trucks), which
comprise more than 60 percent of the Project’s anticipated greenhouse
gas emissions. Mobile source greenhouse gas emissions are regulated by
State and federal fuel standards and tailpipe emissions standards, and are
outside of the control of the City of San Bernardino, the Project
Applicant, and future Project occupants. CEQA provides that mitigation
measures must be within the responsibility and jurisdiction of the Lead
Agency (i.e., City of San Bernardino) in order to be implemented. No
other mitigation measures are available that are feasible for the City of
San Bernardino to enforce that have a proportional nexus to the Project’s
level of impact. Accordingly, the City of San Bernardino finds that the
Project’s greenhouse gas emissions represent a significant and
unavoidable cumulatively-considerable impact for which no additional
feasible mitigation is available to substantially reduce or avoid the
significant impact.
All of the mitigation measures listed in EIR Subsection 4.1, Air Quality,
are applicable to the reduction of greenhouse gas emissions. In addition,
the following measure is applied:
MM 4.4-1 Prior to the issuance of a building permit, the Project
Applicant or successor in interest shall provide documentation to the
City of San Bernardino demonstrating that the Project is designed to
meet or exceed CalGreen Tier 2 standards in effect at the time of
building permit application and includes the energy efficiency design
features listed below at a minimum.
a) Preferential parking locations for carpool, vanpool, EVs and
CNG vehicles.
b) Secure, weather protected bicycle parking.
c) Installation of the minimum number of passenger vehicle EV
charging stations required by Title 24 and the installation of
conduit at a minimum of five (5) percent of the Project’s total
number of automobile parking spaces to accommodate the
future, optional installation of EV charging infrastructure.
d) As part of shell building permit issuance, and subject to the
approval of the Federal Aviation Administration for the
installation of rooftop solar panels near an airport, the applicant
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shall be required to install a rooftop photovoltaic (PV) system
providing a minimum of 24,000 watts (24 KW) of power per
year. The remaining area of the building’s roof shall be designed
and constructed to accommodate the potential, future
construction of additional (PV) solar arrays taking into
consideration limitations imposed by other rooftop equipment,
roof warranties, building and fire code requirements, and other
physical or legal limitations. The building shall be designed to
accommodate an electrical system and other infrastructure
sufficiently sized to accommodate the potential installation of
additional PV arrays in the future.
e) The building’s electrical room shall be sufficiently sized to hold
additional panels that may be needed in the future to supply
power for the future installation of EV truck charging stations on
the site. Conduit should be installed from the electrical room to
the tractor trailer staging area in the southwestern corner of the
site for the purpose of accommodating the future installation of
EV truck charging stations at such time this technology becomes
commercially available and the building is being served by
trucks with electric-powered engines.
f) Use of light-colored roofing material.
g) Use of solar or light-emitting diode (LED) fixtures for outdoor
lighting.
h) All heating, cooling, and lighting devices and appliances shall be
Energy Star certified.
i) All fixtures installed in restrooms and employee break areas
shall be U.S. EPA Certified WaterSense or equivalent. (DEIR
pp. 4.4-33 to 4.4-35)
MM 4.4-2 Prior to the issuance of a building permit for warehouse
building space that contains refrigerated or freezer storage, an electrical
hookup shall be provided at all loading dock doors that are designated
for the loading/unloading of trailers holding refrigerated/frozen goods,
for the purpose of plugging the refrigeration units installed on such
trailers into the building’s electrical system. If refrigerated/freezer
warehouse space is not proposed, electrical hookups at dock doors will
not be required. (FEIR p. F-20)
3. Noise
a. Ambient Noise Levels
Potential Significant Impact: Whether the Project would result in the generation of a substantial
temporary or permanent increase in ambient noise levels in the vicinity of
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the Project in excess of standards established in the local general plan or
noise ordinance, or applicable standards of other agencies. (Threshold a)
Finding: Impacts related to Noise Threshold a are discussed in detail in Subsection 4.7 of the EIR. Based
on the entire record, the City finds that while construction- and operational-related activities
would not expose any nearby sensitive receptors to noise levels exceeding the thresholds of
significance, Project-related traffic would expose sensitive receptors along several roadway
segments to significant traffic-related noise impacts. There are no additional feasible mitigation
measures to substantially reduce or avoid the Project’s significant traffic-related noise impacts.
Therefore, the Project-related off-site traffic noise level increases at noise-sensitive land uses
adjacent to the affected roadway segments would represent a significant and unavoidable impact
of the proposed Project on a direct and/or cumulatively-considerable basis:
Facts in Support of the Finding: Construction noise levels are expected to range from 59.5 to 73.9 dBA
Leq, and the highest construction levels are expected to range from 69.6
to 73.9 dBA Leq at the nearest receiver locations. The construction noise
analysis shows that the nearest receiver locations would satisfy the
reasonable daytime 80 dBA Leq significance threshold during Project
construction activities, and the noise impacts due to Project construction
noise would be less than significant at all receiver locations. The
operational noise levels associated with the proposed Project would
satisfy the City of San Bernardino 65 dBA Leq exterior noise level
standards at all nearby receiver locations. Therefore, the operational
noise impacts are considered less than significant at the nearest noise-
sensitive receiver locations (DEIR pp. 4.7-20 to 4.7-23)
While construction- and operational-related activities would not expose
any nearby sensitive receptors to noise levels exceeding the thresholds of
significance, Project-related traffic would expose sensitive receptors
along the following roadway segments to significant traffic-related noise
impacts:
• Opening Year (2022)
o Existing noise-sensitive use on Lankershim Avenue north of 5th
Street (Segment #1).
o Existing noise-sensitive use on 5th Street west of Central Avenue
(Segment #5).
o Existing noise-sensitive use on 5th Street west of Church Avenue
(Segment #6).
• Opening Year Cumulative (2022)
o Existing noise-sensitive use on Lankershim Avenue north of 5th
Street (Segment #1).
o Existing noise-sensitive use on 5th Street west of Church Avenue
(Segment #6).
• Horizon Year (2040)
o Existing noise-sensitive use on 5th Street west of Church Avenue
(Segment #6).
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• Horizon Year Cumulative (2040)
o Existing noise-sensitive use on Lankershim Avenue north of 5th
Street (Segment #1).
o Existing noise-sensitive use on 5th Street east of Lankershim
Avenue (Segment #4).
o Existing noise-sensitive use on 5th Street west of Central Avenue
(Segment #5).
o Existing noise-sensitive use on 5th Street west of Church Avenue
(Segment #6).
The existing sensitive receptors along the above-listed roadway segments
are currently being planned for future development with light industrial
land uses as part of the Airport Gateway Specific Plan. Notwithstanding,
as it cannot be assured that the Airport Gateway Specific Plan would be
developed and operational under each of the above-described study
scenarios, or if or when the sensitive receivers would convert to non-
sensitive receivers, Project traffic-related noise impacts at the above-
listed roadway segments are considered direct and cumulatively-
considerable impacts of the proposed Project.
Rubberized asphalt and off-site noise barriers would not avoid or
substantially lessen the off-site traffic noise level increases at land uses
adjacent to the impacted roadway segments. There are no other feasible
mitigation measures to substantially reduce or avoid the Project’s
significant traffic-related noise impacts. Therefore, the Project-related
off-site traffic noise level increases at noise-sensitive land uses adjacent
to the affected roadway segments would represent a significant and
unavoidable impact of the proposed Project on a direct and/or
cumulatively-considerable basis. (DEIR pp. 4.7-34 to 4.7-36)
4. Transportation
a. Vehicle Miles Travelled (VMT) Impacts
Potential Significant Impact: Whether the Project would conflict with or be inconsistent with CEQA
Guidelines section 15064.3, subdivision (b). (Threshold b)
Finding: Impacts related to Transportation Threshold b are discussed in detail in Subsection 4.8 of the
EIR. Based on the entire record, the City finds that the Project would result in a significant and
unavoidable direct VMT impact.
Facts in Support of the Finding: SB 743, approved in 2013, was intended to change the way
transportation impacts are determined according to CEQA. Updates to
the State CEQA Guidelines that were approved in December 2018
included the addition of CEQA Guidelines Section 15064.3, of which
Subdivision b establishes criteria for evaluating a project’s transportation
impacts based on project type and using automobile VMT (vehicle miles
traveled) as the metric. As a component of the Office of Planning and
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Research revisions to the CEQA Guidelines, lead agencies were required
to adopt VMT thresholds of significance by July 1, 2020. The City of
San Bernardino adopted its City of San Bernardino Traffic Impact
Analysis Guidelines in August 2020, which is used in the analysis to
determine the significance of Project-related VMT.
The Project’s VMT per service population values would exceed the
City’s adopted threshold by 33.3% for baseline (2020) conditions and
25.9% for cumulative (2040) conditions. Therefore, based on the City’s
Guidelines, the Project would have a significant direct impact due to
VMT. The cumulative link-level VMT per service population within the
City of San Bernardino does not increase under the plus Project
condition. Therefore, based on the City’s Guidelines, the Project’s effect
on VMT is considered less-than-cumulatively considerable.
Mitigation measures available to reduce VMT include developing
pedestrian network improvements, removing physical barriers to
pedestrian circulation, and providing design features that encourage
people to walk or bike instead of drive. Various design features are
included in the Project to encourage pedestrian and bicycle activity
(sidewalks, trails, bike lanes and bicycle parking). Encouraging
businesses to allow telecommuting and alternative work week hours and
to use ridesharing programs also can reduce VMT, but the City of San
Bernardino has no jurisdictional authority to mandate the business
practices of private enterprises. There are no additional feasible
mitigation measures available to substantially reduce or avoid the
Project’s significant impacts due to VMT. As such, Project impacts due
to VMT would be significant and unavoidable. (DEIR pp. 4.8-11, 4.8-
12, and 4.8-16)
VIII. SIGNIFICANT IRREVERSIBLE ENVIRONMENTAL EFFECTS
Potential Significant Impact: Whether any significant irreversible environmental changes would result
from implementation of the Project. An environmental change would fall
into this category if: a) the project would involve a large commitment of
non-renewable resources; b) the primary and secondary impacts of the
project would generally commit future generations to similar uses; c) the
project involves uses in which irreversible damage could result from any
potential environmental accidents; or d) the proposed consumption of
resources is not justified (e.g., the project results in the wasteful use of
energy).
Finding: Significant irreversible environmental effects which would be caused by the Project are discussed
in detail in Subsection 5.2 of the EIR. Based on the entire record, the City finds that the Project
would not cause an irreversible change that would result in a significant adverse effect to the
environment.
Facts in Support of the Finding: Natural resources, in the form of construction materials and energy
resources, would be used in the construction of the proposed Project. The
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consumption of these natural resources would represent an irreversible
change to the environment. However, implementation of high-cube
fulfillment center and high-cube cold storage uses on the Development
Site would have no measurable adverse effect on the availability of such
resources, including resources that may be non-renewable (e.g.,
construction aggregates, fossil fuels). Additionally, the Project is
required by law to comply with the California Green Building Standards
Code (CALGreen), which will minimize the Project’s demand for
energy, including energy produced from non-renewable sources.
Implementation of the Project would commit the Development Site to
one large light industrial warehouse building. Mandatory compliance
with federal, State, and local regulations related to hazardous materials
handling, storage, and use by all Project construction contractors (near
term) and occupants (long-term) would ensure that any hazardous
materials used on site would be safely and appropriately handled to
preclude any irreversible damage to the environment that could result if
hazardous materials were released from the site. Development of the
proposed light industrial warehouse building would not result in a
wasteful, inefficient, or unnecessary consumption of energy.
Accordingly, the Project would not result in significant, irreversible
adverse changes to the environment as defined above. (DEIR pp. 5-2 to
5-4)
IX. GROWTH-INDUCING IMPACTS
Potential Significant Impact: Whether the proposed Project could be growth inducing. The CEQA
Guidelines identify a project as growth inducing if it would foster economic
or population growth, or the construction of additional housing, either
directly or indirectly, in the surrounding environment (CEQA Guidelines
§15126.2(d)).
Finding: The Project’s potential to result in growth-inducing impacts is discussed in detail in Subsection
5.3 of the EIR. Based on the entire record, the City finds that the Project would not result in
substantial, adverse growth-inducing impacts.
Facts in Support of the Finding: The City of San Bernardino’s population is projected to grow by 14,200
residents between 2016 and 2045 (approximately 0.2% annual growth).
Over this same time period, employment in the City is expected to add
24,300 new jobs (approximately 0.7% annual job growth). Economic
growth would likely take place as a result of the Project’s operation with
high-cube fulfillment center and high-cube cold storage uses. The
Project’s employees (short-term construction and long-term operational)
would purchase goods and services in the region, but any secondary
increase in employment associated with meeting these goods and
services demands is expected to be accommodated by existing goods and
service providers and, based on the amount of existing and planned
future commercial and retail services available in areas near the
Development Site, would be highly unlikely to result in any
unanticipated, adverse physical impacts to the environment. In addition,
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the Project would create approximately 1,120 jobs, a majority of which
would likely be filled by residents of the housing units either already
built or planned for development within the City of San Bernardino and
nearby cities and unincorporated areas. Accordingly, because it is
anticipated that most of the Project’s future employees would already be
living in the City of San Bernardino or the larger Inland Empire area, the
Project’s introduction of employment opportunities on the Development
Site would not induce substantial growth in the area. The area
surrounding the Project Site consists of industrial warehouses and
airport-related businesses and operations to the east, south, and west,
with a mixture of business enterprises, undeveloped property, and several
residential structures to the north. Development of the Project is not
expected to place short-term development pressure on abutting properties
because these areas are already built-out or are planned for urban uses.
There are no components of the Project that would induce development
on the currently undeveloped parcels to the north, as these parcels
already are served with existing infrastructure (roads, utilities, etc.).
(DEIR pp. 5-4 and 5-5)
X. PROJECT ALTERNATIVES
A. No Development Alternative (NDA)
The No Development Alternative (NDA) considers no development on the Project Site beyond what occurs
on the site under existing conditions. The NDA was selected by the Lead Agency to compare the
environmental effects of the proposed Project with an alternative that would leave the property in its existing
state.
Finding: Alternatives to the Project are discussed in detail in Section 6.0 of the EIR. Based on the entire
record, the City finds that the NDA was considered but rejects the NDA because the NDA would
fail to meet any and all of the Project’s objectives. Specifically, implementation of the NDA
would not expand economic development, facilitate job creation, or increase the tax base for the
City of San Bernardino by establishing new industrial development adjacent to established and
planned industrial areas. The NDA also would not attract new employment-generating
businesses in the City of San Bernardino, thereby growing the economy and providing a more
equal jobs-housing balance in the local area that will reduce the need for members of the local
workforce to commute outside the area for employment. The NDA would fail to meet the
Project’s objective to develop vacant or underutilized property on the former Norton AFB with a
use that is compatible with the SBIA and that achieves a maximized floor area ratio per
regulatory allowances to take full advantage of the development potential of the property. The
NDA also would not result in the development of a use that has architectural design and
operational characteristics that are compatible with other existing and planned developments in
the local area. In addition, implementation of the NDA would not meet the Project’s objective to
develop a Class A light industrial in the City of San Bernardino that is designed to meet
contemporary industry standards and be economically competitive with similar industrial
buildings in the local area and region. Implementation of the NDA also would not attract
businesses that can expedite the delivery of essential goods to consumers and businesses around
the SBIA, in the City of San Bernardino, and in the region beyond the City boundary. The NDA
also would not result in the development of light industrial and warehousing uses with loading
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docks in close proximity to designated truck routes and the State highway system to avoid or
shorten truck-trip lengths on other roadways. The NDA would fail to meet the Project’s
objective to modify the boundary of the SBAC-SP Third Street District to form a more viably-
shaped area for industrial development. Moreover, the NDA would not involve the addition of
interpretive elements in public streetscape near the SBIA to convey the area’s history and culture.
Additionally, the NDA is not feasible because it would be inconsistent with the Project Site’s
existing General Plan, Development Code/Zoning Map, and Specific Plan Alliance of California
land use designations, all of which designate the Project Site for future development with light
industrial and public facilities land uses.
Facts in Support of the Finding: Implementation of the NDA would avoid the Project’s significant and
unavoidable impacts due to air quality emissions, greenhouse gas
emissions, traffic-related noise, and VMT. Impacts to biological
resources and hydrology/water quality also would be reduced under the
NDA as compared to the proposed Project. Impacts to cultural resources,
land use and planning, and tribal cultural resources would be similar
under both the NDA and proposed Project. However, implementation of
the NDA would fail to meet any and all of the Project’s objectives.
Additionally, the NDA is not feasible because it would be inconsistent
with the Project Site’s existing General Plan, Development Code/Zoning
Map, and Specific Plan Alliance of California land use designations and
classifications, all of which identify the Project Site for future
development with light industrial and public facilities land uses.
Accordingly, the City rejects the NDA. (DEIR pp. 6-7 to 6-10)
B. No Project Alternative (NPA)
The No Project Alternative (NPA) considers redevelopment of the Project Site in accordance with the site’s
existing land use designations. The NPA was selected by the Lead Agency to compare the environmental
effects of the Project against a development proposal that conforms to the land use standards and
development regulations contained within the City of San Bernardino General Plan, the City’s Development
Code/Zoning Code, and the SBAC-SP.
Finding: Alternatives to the Project are discussed in detail in Section 6.0 of the EIR. Based on the entire
record, the City finds that the NPA was considered but rejects the NPA because although the
NPA would meet all but one of the Project’s objectives, the objective that would not be met is a
long-range planning objective that results in a better arrangement of land uses on the Project Site
in the Third Street District of the San Bernardino Alliance California Specific Plan (SBAC-SP).
Further, four of the objectives that would be met by the NPA would be met less effectively and to
a lesser degree than the Project. The NPA would be less effective at expanding economic
development, facilitating job creation, and increasing the tax base for the City of San Bernardino
due to the reduction in building area as compared to the proposed Project. Similarly, the NPA
would provide fewer new employment opportunities and lessen the development’s ability to help
the City provide a more equal jobs-housing balance in the local area that will reduce the need for
members of the local workforce to commute outside the area for employment. Additionally, the
NPA would not take full advantage of the development potential of the property, and would be
less effective at redeveloping a portion of the former Norton AFB with a use that is compatible
with the SBIA and that achieves a maximized floor area ratio per regulatory allowances. In
addition, because the NPA would provide less building space than the Project, it would be less
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effective than the Project in attracting businesses that can expedite the delivery of essential goods
to consumers and businesses around the SBIA, in the City of San Bernardino, and in the region
beyond the City boundary.
Facts in Support of the Finding: Implementation of the NPA would result in significant and unavoidable
impacts due to air quality emissions, a conflict with the SCAQMD 2016
AQMP, greenhouse gas emissions, traffic-related noise, and VMT) and ,
although the level of impact would be slightly reduced under the NPA as
compared to the proposed Project due to the slight reduction in the
amount of light industrial building area and associated traffic generation.
Therefore, implementation of the NPA would not avoid or substantially
reduce the Project’s significant impacts. Impacts to biological resources,
cultural resources (historical resources), and hydrology/water quality
would be less than significant under both the Project and NPA with the
implementation of mitigation measures, and the level of impact would be
similar. Impacts to cultural resources (archaeological resources), land use
and planning, and tribal cultural resources would be less than significant
under both the Project and NPA, and the level of impact would be
similar. There would be no increased impacts to the environment with
implementation of the NPA as compared to the proposed Project. While
the NPA would meet most of the Project’s objectives, those objectives
would be met less effectively than the proposed Project in many cases.
Accordingly, the City rejects the NPA. (DEIR pp. 6-10 to 6-14)
C. Reduced Project Alternative (RPA)
The Reduced Project Alternative (RPA) considers development of approximately half of the Development
Site with light industrial uses, while the remaining portions of the Development Site would be utilized for
truck trailer parking. This alternative was selected by the Lead Agency to compare the environmental effects
of the Project with less intense land uses that would serve to reduce the Project’s significant environmental
effects associated with air quality, greenhouse gas emissions, traffic-related noise, and Vehicle Miles
Traveled (VMTs).
Finding: Alternatives to the Project are discussed in detail in Section 6.0 of the EIR. Based on the entire
record, the City finds that the RPA was considered but rejects the RPA because while the RPA
would meet the Project’s objectives with some reduction in environmental impacts, in most cases
the objectives would be met much less effectively than with development of the proposed
Project. The RPA would be less effective than the Project in expanding economic development,
facilitating job creation, and increasing the tax base for the City of San Bernardino. The RPA
also would be less effective than the proposed Project in meeting the Project’s objective to attract
new employment-generating businesses in the City of San Bernardino. Because the RPA would
involve roughly half of the building area as proposed by the Project, the NPA also would not be
as effective as the Project in developing vacant or underutilized property on the former Norton
AFB with a use that is compatible with the SBIA and that achieves a maximized floor area ratio
per regulatory allowances to take full advantage of the development potential of the property.
Due to the reduction in building area under the RPA, the RPA also would be less effective than
the proposed Project in meeting the Project’s objective to develop a Class A light industrial in the
City of San Bernardino that is designed to be economically competitive with similar and that can
attract businesses that can expedite the delivery of essential goods to consumers and businesses
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around the SBIA, in the City of San Bernardino, and in the region beyond the City boundary.
Accordingly, the City rejects the RPA.
Facts in Support of the Finding: Implementation of the RPA would result in significant and unavoidable
impacts due to air quality emissions, greenhouse gas emissions, traffic-
related noise, and VMTs, although the level of impact would be reduced
under the RPA as compared to the proposed Project due to the reduction
in building intensity on site and associated reduction in vehicular traffic.
Nevertheless, implementation of the RPA would not avoid or
substantially reduce the Project’s significant impacts. Impacts to
biological resources, cultural resources (historical resources), and
hydrology/water quality would be less than significant under both the
Project and RPA with the implementation of mitigation measures, and
the level of impact would be similar. Impacts to cultural resources
(archaeological resources), land use and planning, and tribal cultural
resources would be less than significant under both the Project and RPA,
and the level of impact would be similar. There would be no increased
impacts to the environment with implementation of the RPA as
compared to the proposed Project. The RPA would meet most of the
Project’s objectives, although to a much lesser extent. Therefore, the City
rejects the RPA. (DEIR pp. 6-14 to 6-18)
D. Range of Alternatives
Finding: The City finds that Alternatives to the Project consisting of the No Development Alternative
(NDA), No Project Alternative (NPA), and Reduced Project Alternative (RPA), represent a
reasonable range of alternatives.
Facts in Support of the Finding: Pursuant to Public Resources Code Section 21002 and the State CEQA
Guidelines Section 15126.6(a), an EIR must assess a reasonable range of
alternatives to the project action or location. Section 15126.6(a) places
special emphasis on focusing the discussion on alternatives which
provide opportunities for eliminating any significant adverse
environmental impacts, or reducing them to a level of insignificance,
even if the alternative would impede to some degree the attainment of
the project objectives, or would be costlier. The discussion of
alternatives is governed by the “rule of reason.” The EIR need not
consider an alternative whose effect cannot be reasonably ascertained, or
does not contribute to an informed decision-making and public
participation process. Because there are no reasonably feasible and
available alternative sites for the Project or alternative land uses for the
Project Site, consideration of the NDA, NPA, and RPA represents a
reasonable range of alternatives. The purpose of the CEQA requirements
of studying a reasonable range of alternatives would not be met by
constructing additional alternatives that would not meet the basic
objectives of the Project. There are no other feasible alternatives that
would achieve all of the Project’s basic objectives while lessening or
avoiding the Project’s significant environmental effects.
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XI. STATEMENT OF OVERRIDING CONSIDERATIONS
This Section specifically addresses §15093 of the CEQA Guidelines, which requires the City, acting as the
Lead Agency, to balance the benefits of the Project against its significant and unavoidable adverse
environmental impacts and determine whether the benefits which will accrue from the development of the
Project outweigh its significant and unavoidable impacts. If the City finds that the major benefits of the
Project outweigh its significant and unavoidable adverse environmental impacts, the City may approve the
Project. Each of the separate benefits listed below are hereby determined to be, in itself, and independent of
the Project’s other benefits, the basis for overriding all significant and unavoidable environmental impacts
identified in the EIR.
As set forth in Section VII above, the EIR identified all of the Project’s adverse environmental impacts and
mitigation measures which can reduce the Project’s impacts to less-than-significant levels where feasible, or
to the lowest feasible levels. Mitigation imposed by the City must have a proportional nexus to the Project’s
impacts. As further set forth in Section VII, above, the EIR presents evidence that implementing the Project
would cause or contribute to impacts that would remain significant and unavoidable even after the imposition
of all feasible mitigation measures. Finally, as set forth in Section X above, there are no feasible alternatives
to the Project that would mitigate the Project’s significant and unavoidable impacts to less-than-significant
levels or avoid those environmental impacts while still attaining all of the Project’s basic objectives. Based
on the facts presented throughout this document, the City makes the following finding:
Finding: As the CEQA Lead Agency for the proposed Project, the City has reviewed the Project
description and the alternatives to the Project, as presented in the EIR, and the City fully
understands the Project and its alternatives. Further, the City finds that all potential adverse
environmental impacts and all feasible mitigation measures to reduce the impacts from the
Project have been identified in the Draft EIR, Final EIR, and public testimony. Having
considered the potential for the Project to cause or contribute to significant and unavoidable
adverse impacts to Air Quality, Greenhouse Gas Emissions, Noise, and
Transportation/Circulation, the City hereby determines that all feasible mitigation measures with
proportional nexus to the Project’s impacts have been adopted to reduce or avoid the significant
and unavoidable impacts identified in the EIR, and that no additional feasible mitigation is
available to further substantially reduce or avoid significant impacts. Further, the City finds that
economic, social, and other considerations of the Project outweigh the Project’s unavoidable
impacts to Air Quality, Greenhouse Gas, Noise, and Transportation/Circulation and that approval
of the Project is appropriate. In making this finding, the City has balanced the benefits of the
Project against its unavoidable environmental impacts, and has indicated its willingness to accept
those effects. Each of the separate benefits listed below are hereby determined to be, in itself, and
independent of the Project’s other benefits, the basis for overriding all significant and
unavoidable environmental impacts identified in the EIR. These benefits include the following:
A. The Project will improve the physical condition of the property by redeveloping a portion
of the former Norton Air Force Base (AFB) with a revenue-producing and job-creating
warehouse building. Redevelopment of the property will eliminate the potential threats of
vacancy, neglect, and blight that could occur if the property is not reused and which may
cause safety hazards to the residents of the City and hazard to the environment.
B. Development of the property with a modern warehouse building will assist the City in
achieving the vision of the San Bernardino California Alliance Specific Plan and numerous
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General Plan Goals and Policies including but not limited to: Goal 4.1 (to encourage
economic activity that capitalizes on the City’s transportation and locational strengths),
Goal 4.5 (to attract employment types/land uses that complement existing employment
clusters and foster long-term economic growth), and Goal 4.6 (to establish employment
sectors that support business growth).
C. The Project will help to fill southern California’s demand for over one billion square feet of
warehousing space by the year 2035, as projected by the Southern California Association of
Governments. In doing so, the Project will further diversify the City’s economy and secure
the City’s position in the regional, State, and international marketplace.
D. Implementation of the Project would capitalize on the transportation and locational
strengths of San Bernardino. The Development Site is located approximately 1 mile west of
the 5th Street on/off-ramp to Insterstate-210 (I-210) and approximately 2.6 miles north of
Interstate-10 (I-10), both of which provide accessibility to/from the Development Site to
the existing regional transportation system that facilitates the efficient movement of goods
as part of the California goods movement network.
E. The Project will attract a new employment-generating business to the City of San
Bernardino, thereby reducing the needs of the local workforce to commute outside of the
area for employment. Although the user(s) of the Project’s proposed building is not yet
known, an employment estimate can be made using Appendix 5 to the City’s General Plan,
which indicates that lands designated for “Industrial Light (IL)” uses generate
approximately one employee per 1,030 s.f. of building area. Based on this factor, the
Project is projected to generate approximately 1,120 new, recurring jobs (1,153,644 s.f. ÷
1,030 s.f./employee = 1,120 employees). The Project also could serve as a catalyst to attract
other businesses to the City of San Bernardino that desire close proximity the building’s
eventual tenant(s). Implementation of the Project is expected to create short-term
construction jobs that would generate increases in construction employee wages, as well as
a multiplier effect of those wages that will create secondary jobs to support Project-related
construction activities and the needs of construction workers. The addition of new jobs to
the City of San Bernardino will create direct and indirect economic benefits, such as
increased tax income to the City and spending on goods and services.
F. The Project will result in and facilitate the construction of improvements to Victoria
Avenue and the intersection of Victoria Avenue and 3rd Street. The Project also will result
in the installation of an Omnitrans tripper route bus stop and reserve space for the planned
location of a segment of the City Creek bike trail.
G. Implementation of the Project will result in payment of Development Impact Fees and City
permitting fees that would benefit the City of San Bernardino by increasing available
funding for needed public services and infrastructure.
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H. The Project will assist the City in representing and celebrating its history by relocating the
Norton AFB water tower (or building a replica thereof) at the southeast corner of the
intersection of Victoria Avenue and 3rd Street, and by installing a historic theme wall along
the Development Site’s frontage with 3rd Street.
I. The Project would ensure the property’s long-term compatibility with existing and planned
land uses abutting the site including airport-related uses to the immediate south.
XII. ADOPTION OF A MONITORING PLAN FOR MITIGATION MEASURES
Pursuant to §21081.6 of the Public Resources Code the City hereby adopts a Mitigation Monitoring and
Reporting Program (MMRP), which is based upon Table S-1 in the Final EIR, and supersedes all other
versions. The City finds that the MMRP is designed to ensure compliance with the changes (i.e., mitigation
measures) imposed on the Project to mitigate or avoid effects on the environment during Project
implementation. The MMRP is on file with the City’s Community Development Department, Planning
Division, located at 201 North E Street, 3rd Floor, San Bernardino, CA 92401.
XIII. APPROVING THE PROJECT
Based on the entire record before the San Bernardino City Council, including the Findings and all written
and oral evidence presented, the San Bernardino City Council hereby approves the Project with all the
mitigation measures and the MMRP, as set forth in this Facts, Findings and Statement of Overriding
Considerations document.
XIV. REGARDING STAFF DIRECTION
A Notice of Determination shall be filed with the Clerk of the County of San Bernardino within five (5)
working days of final Project approval.
XV. REGARDING CONTENTS AND CUSTODIAN OF RECORD
The documents and materials that constitute the record of proceedings on which these findings have been
based are located at the City of San Bernardino, Community Development Department, 201 North E Street,
3rd Floor, San Bernardino, California 92401. The custodian for these records is Elizabeth Mora-Rodriguez,
Associate Planner. This information is provided in compliance with Public Resources Code §21081.6.
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Mitigation Measures Responsible Parties
Implementation Stage
(to be monitored by the City
of San Bernardino)
4.1 4.1 Air Quality
MM 4.1-1: Prior to grading permit issuance, the City of San Bernardino shall review grading plans to ensure
that a notation is included requiring the grading contractor to utilize CARB Tier 4 Final Compliant equipment
in lieu of Tier 3 Compliant or Tier 4 Interim Compliant equipment if Tier 4 equipment can be reasonably
acquired by the Project contractor. If Tier 4 Final Compliant equipment is not feasible to use during grading
activity due to lack of local availability of such equipment, the Project Applicant or grading contractor shall
provide evidence to the City of San Bernardino showing that the grading contractor attempted to secure the
use of Tier 4 Final Compliant equipment, but such equipment was not locally available (within a 50-mile
radius). The notations shall require that all Tier 3 Compliant and Tier 4 Interim Compliant equipment over 50
hp, if used, shall be fitted with the best available control technology (BACT) devices, if technically feasible
and if the BACT devices can be reasonably acquired by the Project grading contractor, to minimize air
pollutant emissions. These requirements also shall be specified in bid documents issued to prospective
grading contractors. In order to demonstrate compliance, the grading contractor shall keep a copy of each
unit’s certified tier specification and CARB or SCAQMD operating permit (if applicable) on the Development
Site in a location available to the City or City designee for inspection upon request. The City shall review and
approve the list of equipment over 50 hp, their CARB tier levels, and list of BACT devices installed on Tier 3
Compliant and Tier 4 Interim Compliant equipment, prior to the mobilization of grading equipment to the site.
MM 4.1-2: Prior to grading permit issuance, the City of San Bernardino shall review grading plans to ensure
that notification is included requiring that all on-road heavy-duty diesel trucks with a gross vehicle weight
rating greater than 14,000 pounds with a 2010 model year engine or newer or shall be equipped with a
particulate matter trap, as available. This requirement also shall be specified in bid documents issued to
prospective construction contractors. The grading contractor shall keep a copy of records for all on-road
heavy-duty diesel trucks with a gross vehicle weight rating greater than 14,000 pounds to demonstrate
compliance with this requirement, and the records shall be made available to the City or City’s designee for
inspection upon request.
MM 4.1-3: Prior to grading permit issuance, the City of San Bernardino shall review grading plans to ensure
that notification is included requiring that all construction equipment shall comply with all applicable
California Air Resources Board (CARB) air quality regulations. Also, the notes shall require that all Project
construction contractors must tune and maintain all construction equipment in accordance with the equipment
manufacturer’s recommended maintenance schedule and specifications. These requirements also shall be
specified in bid documents issued to prospective construction contractors. Maintenance records for all pieces
Project Applicant, Grading
Contractor
Project Applicant,
Construction Contractors
Project Applicant,
Construction Contractors
Prior to issuance of grading
permits and during grading
activities
Prior to issuance of grading
permits and during grading
activities
Prior to issuance of grading
permits and during
construction activities
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of equipment shall be kept on-site for the duration of construction activities and shall be made available for
periodic inspection by City of San Bernardino staff or their designee.
MM 4.1-3A: Plans submitted for grading permit issuance and building permit issuance shall specify a
designated area of the construction site where electric or non-diesel vehicles, equipment, and tools can be
fueled or charged. The provision of temporary electric infrastructure for such purpose shall be approved by
the utility provider, Southern California Edison (SCE). If SCE will not approve the installation of temporary
power for this purpose, the establishment of a temporary electric charging area will not be required. If electric
equipment will not be used on the construction site because the construction contractor(s) does not have such
equipment in its fleet (as specified in Mitigation Measure MM 4.1-3B), the establishment of a temporary
electric charging area also will not be required. If electric-powered equipment is in the contractor(s)
equipment fleet, and SCE approval is secured, the temporary charging location is required to be established
upon issuance of grading permits and building permits.
MM 4.1-3B: If electric or non-diesel off-road trucks and construction support equipment, including but not
limited to hand tools, forklifts, aerial lifts, materials lifts, hoists, pressure washers, plate compactors, and air
compressors are available in the construction contractor’s equipment fleet and can fulfill the Project’s
construction requirements during the building construction, paving, and architectural coating phases of Project
construction, such equipment shall be used during Project construction. This requirement shall be noted on
plans submitted for building permit issuance.
MM 4.1-3C: Plans submitted for grading permit issuance and building permit issuance shall specify the
locations where anti-idling signs will be located. Signs shall be placed on the construction site where medium
and heavy-duty trucks and other heavy equipment will stage, identifying applicable California Air Resources
Board (CARB) anti-idling regulations. At a minimum, each sign shall include: 1) instructions to shut off
engines when equipment is not in use; and 2) instructions to restrict idling to no more than five (5) minutes.
MM 4.1-4: The Project developer and all successors in interest shall install and maintain legible, durable,
weather-proof signs at truck access gates, loading docks, and truck parking areas that identify applicable
California Air Resources Board (CARB) anti-idling regulations. At a minimum, each sign shall include
instructions for drivers of diesel-fueled trucks to restrict idling to no more than five minutes. The Project
developer or successor(s) in interest shall permit City of San Bernardino staff to conduct a site inspection to
ensure that the signs are in place and maintained.
Project Applicant,
Construction Contractors
Project Applicant,
Construction Contractors
Project Applicant,
Construction Contractors
Project Applicant and
Successors in Interest
Prior to issuance of grading
permit issuance and building
permit issuance and during
construction activities
Prior to building permit
issuance and during
construction activities
Prior to issuance of grading
permit issuance and building
permit issuance and during
construction activities
Prior to issuance of occupancy
permits and during long-term
operations
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MM 4.1-5: The Project developer and all successors in interest shall install and maintain signs and/or
painting/striping at on-site driveways and drive aisles to clearly identify the on-site circulation pattern to
minimize unnecessary on-site vehicular travel. The Project developer or successor(s) in interest shall permit
City of San Bernardino staff to conduct a site inspection to ensure that the signs/painting/striping are in place
and maintained.
MM 4.1-6: The Project developer and all successors in interest shall provide the City of San Bernardino with
an information packet that will be provided to future building occupants that: 1) provides information
regarding the grants available from the Carl Moyer Memorial Air Quality Standards Attainment Program for
energy efficiency improvement features – including truck modernization, retrofits, and/or aerodynamic kits
and low rolling resistance tires – and the resulting benefits to air quality; 2) recommends the use of electric or
alternatively-fueled sweepers with HEPA filters; 3) recommends the use of water-based or low VOC cleaning
products and 4) for occupants with more than 250 employees, includes information related to SCAQMD Rule
2202, which requires the establishment of a transportation demand management program to reduce employee
commute vehicle emissions.
MM 4.1-7: The Project developer and all successors in interest shall stipulate in building sale and lease
agreements that all indoor and outdoor forklifts and all outdoor cargo-handling equipment (e.g., yard trucks,
hostlers, yard goats, pallet jacks, forklifts) shall be electric or non-diesel fueled.
MM 4.1-8: The Project developer and all successors in interest shall install and maintain a sign in public view
with telephone, email, and regular mail contact information for a designated representative of the occupant
who would receive complaints about excessive dust, fumes, or odors. The sign shall also identify contact data
for the City or SCAQMD for perceived violations. The occupant’s representative shall keep records of any
complaints received and actions taken to communicate with the complainant and resolve the complaint.
MM 4.1-9: The minimum number of automobile electric vehicle (EV) charging stations required by the
California Code of Regulations Title 24 shall be provided. In addition, and to facilitate the possible future
installation of infrastructure that would charge the batteries that power the motors of electric-powered trucks,
the following shall occur: (1) at Shell building permit, an electrical room(s) and/or exterior area(s) of the site
shall be designated where future electrical panels would be located for the purpose of supplying power to on-
site charging facilities for electric powered trucks; (2) conduit shall be installed from this designated area
where the panel would be located to the southwest corner of the Development Site where the charging
facilities would be located and where electric-powered trucks would park and connect to charging facilities.
Project Applicant or
Successor in Interest/
Project Applicant or
Successor in Interest
Project Applicant or
Successor in Interest
Project Applicant,
Construction Contractor
Project Applicant or
Developer
Prior to issuance of occupancy
permits and during long-term
operations
Prior to issuance of occupancy
permits
As a component of building
sale and lease agreements and
during long-term operations
During grading and
construction activities
As a condition of Shell or
Tenant Improvement building
permits
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4.2 Biological Resources
MM 4.2-1: As a condition of tree removal permits, clearing permits, and any other permits that would
authorize vegetation removal, the disturbance to and removal of trees and other potential bird nesting habitat
shall be prohibited during the migratory bird nesting season (February 1 through September 15) unless a
migratory bird nesting survey is completed. If vegetation removal is planned to occur during the migratory
bird nesting season (February 1 – September 15), then a migratory bird nesting survey shall be completed in
accordance with the following requirements:
a) Within three (3) days prior to initiating tree removals and/or vegetation clearing, a nesting bird survey
shall be conducted by a qualified biologist within the suitable habitat to be removed and within a 250-foot
radius.
b) If the survey identifies the presence of active sensitive bird nests, then the nests shall not be disturbed
unless the qualified biologist verifies through non-invasive methods that either (i) the adult birds have not
begun egg-laying and incubation; or (ii) the juveniles from the occupied nests are capable of independent
survival.
c) If the biologist is not able to verify any of the conditions from sub-item “b,” above, then no disturbance
shall occur within a buffer zone specified by the qualified biologist for each nest or nesting site. The
buffer zone shall be species-appropriate (no less than 100-foot radius around the nest for non-raptors and
no more than a 500-foot radius around the nest for raptors, or as otherwise determined by the qualified
biologist) and shall be sufficient to protect the nest from direct and indirect impacts from construction
activities. The nests and buffer zones shall be field checked approximately weekly by a qualified
biological monitor. The approved buffer zone shall be marked in the field with construction fencing,
within which no vegetation clearing or ground disturbance shall commence until the qualified biologist
with City concurrence verify that the nests are no longer occupied and/or juvenile birds can survive
independently from the nests.
MM 4.2-2: Within between 14 and 30 days prior to ground-disturbing activities (i.e., tree removals,
demolition, clearing, grading, etc.), a qualified biologist shall conduct a survey of suitable habitat in the
disturbance area and within a 250-foot radius and make a determination regarding the presence or absence of
the burrowing owl. The determination shall be documented in a report and shall be submitted to and accepted
Project Applicant or
Developer, Project Biologist
Project Applicant or
Developer, Project Biologist
Prior to removal of trees
during the migratory bird
nesting season
Within between 14 and 30
days prior to ground-
disturbing activities
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by the City of San Bernardino prior to commencement of ground-disturbing activities. The following
provisions shall apply:
a) In the event that the pre-construction survey identifies no burrowing owls on the property ground-
disturbing activities may commence without restriction.
b) In the event that the pre-construction survey identifies the presence of the burrowing owl, then:
i. If a site-specific exclusion and translocation plan for burrowing owl has not already been approved by
the CDFW, the Project Applicant shall retain a qualified biologist to prepare such a plan for review and
approval by the CDFW. This plan will identify the procedures to be followed to exclude and/or
translocate burrowing owls from the site, with separate procedures identified for during the breeding
season and outside of the breeding season.
ii. No ground disturbance (tree removals, demolition, clearing, grubbing, grading) shall occur within 50
meters of occupied burrows during the non-breeding season (September 1 through January 31) or within
75 meters of occupied burrows during the breeding season (February 1 through August 31), until the
owls have fledged as confirmed by a qualified biologist or have been relocated per the CDFW-approved
exclusion and translocation plan.
4.3 Cultural Resources and 4.6 Tribal Cultural Resources
MM 4.3-1: As a condition of grading permit issuance, the construction contractor personnel involved in
grading operations shall be trained by a qualified professional historic resources consultant on the visual
identification of historic resources. If historic resources are discovered during any earth-moving operations
associated with the proposed Project, the construction contractor shall be required to temporarily halt all work
within 50 feet of the discovered resource until the professional historic resources consultant is called to the
site to evaluate the suspected resource. Any material uncovered and that is determined by the professional
historical resources consultant to comprise a historically significant resource shall be curated at a public, non-
profit institution with a research interest in the materials, if such an institution agrees to accept the material. If
no institution accepts the historic material, they shall be offered to a local school or historical society in the
area for educational purposes.
MM 4.3-2: As a condition of grading permit issuance, the construction contractor personnel involved in
grading operations shall be trained on the visual identification of archaeological resources by a member of the
Cultural Resources Management Department for the San Manuel Band of Mission Indians. If archaeological
Project Applicant or
Developer, Project Historical
Resources Consultant
Project Applicant or
Developer, Project
Archaeologist
As a condition of grading
permit issuance and during
ground-disturbing
construction activities
As a condition of grading
permit issuance and during
ground-disturbing
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resources are discovered during any earth-moving operations associated with the proposed Project, the
construction contractor shall be required to temporarily halt all work within 50 feet of the discovered resource
until a representative of the San Manuel Band of Mission Indians and a professional archaeologist are called
to the site to evaluate the suspected resource. Should resource evaluation require additional archaeological
fieldwork, a Phase II Testing Plan (Plan) shall be created by the archaeologist and be submitted to the San
Manuel Band of Mission Indians and the City of San Bernardino for review and approval prior to
implementation. The Plan shall include non-collection methods, non-destructive analysis methods, and allow
for Tribal monitors to be present during testing, if requested by the San Manuel Band of Mission Indians.
Further Project-related ground-disturbing activities shall not resume within the area of the discovery until
resource evaluation is completed and the appropriate treatment has been implemented, as agreed upon by the
San Manuel Band of Mission Indians and the City of San Bernardino. If preservation in place is not feasible,
the archaeologist shall create a Phase III archaeological data recovery plan to include the removal of the
resource(s), with the presence of Tribal monitors (if requested by the San Manuel Band of Mission Indians),
and subsequent laboratory processing/analysis to exhaust all data potential. This plan shall be submitted to the
San Manuel Band of Mission Indians and the City of San Bernardino for review and approval prior to
implementation. All collected Native American resources shall be reburied on site as close to the original find
location as possible, in an area where the resource will be avoided, capped, or otherwise protected in
perpetuity.
construction activities
4.4 Greenhouse Gas Emissions
MM 4.4-1: Prior to the issuance of a building permit, the Project Applicant or successor in interest shall
provide documentation to the City of San Bernardino demonstrating that the Project is designed to meet or
exceed CALGreen Tier 2 standards in effect at the time of building permit application and includes the energy
efficiency design features listed below at a minimum.
a) Preferential parking locations for carpool, vanpool, EVs and CNG vehicles;
b) Secure, weather protected bicycle parking;
c) Installation of the minimum number of passenger vehicle EV charging stations required by Title 24 and
the installation of conduit at a minimum of five (5) percent of the Project’s total number of automobile
parking spaces to accommodate the future, optional installation of EV charging infrastructure;
d) As part of shell building permit issuance, and subject to the approval of the Federal Aviation
Administration for the installation of rooftop solar panels near an airport, the applicant shall be required to
install a rooftop photovoltaic (PV) system providing a minimum of 24,000 watts (24 KW) of power per
year. The remaining area of the building’s roof shall be designed and constructed to accommodate the
Project Applicant or
Developer
Prior to issuance of a building
permit
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potential, future construction of additional PV solar arrays taking into consideration limitations imposed
by other rooftop equipment, roof warranties, building and fire code requirements, and other physical or
legal limitations. The building shall be designed to accommodate an electrical system and other
infrastructure sufficiently sized to accommodate the potential installation of additional PV arrays in the
future;
e) The building’s electrical room shall be sufficiently sized to hold additional panels that may be needed in
the future to supply power for the future installation of EV truck charging stations on the site. Conduit
should be installed from the electrical room to the tractor trailer staging area in the southwestern corner of
the site for the purpose of accommodating the future installation of EV truck charging stations at such
time this technology becomes commercially available and the building is being served by trucks with
electric-powered engines.
f) Use of light-colored roofing materials;
g) Use of solar or light-emitting diode (LED) fixtures for outdoor lighting;
h) All heating, cooling, and lighting devices and appliances shall be Energy Star certified; and
i) All fixtures installed in restrooms and employee break areas shall be U.S. EPA Certified WaterSense or
equivalent.
MM 4.4-2: Prior to the issuance of a building permit warehouse building space that contains refrigerated or
freezer storage, an electrical hookup shall be provided at all loading dock doors that are designated for the
loading/unloading of trailers holding refrigerated/frozen goods, for the purpose of plugging the refrigeration
units installed on such trailers into the building’s electrical system. If refrigerated/freezer warehouse space is
not proposed, electrical hookups at dock doors will not be required.
Project Applicant or
Developer
Prior to issuance of a building
permit
4.5 Transportation
MM 4.8-1: Prior to grading and building permit issuance, the City of San Bernardino shall review grading
and building plans to ensure that notes are included on the plans requiring the following. The City or its
designee also shall be responsible for monitoring and enforcement of adherence to these notes.
The construction contractor shall ensure that the Development Site’s frontage with 3rd Street is
swept at least twice per day using SCAQMD Rule 1186 certified street sweepers during grading and
paving operations, and shall sweep the 3rd Street frontage more frequently during grading and
paving operations if visible soil materials or debris are carried onto the roadway, including in the
bicycle lane.
Project Applicant or
Developer, Construction
Contractors
Prior to grading and building
permit issuance and during
construction activities
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The construction contractor shall adhere to a traffic control plan approved by the City of San
Bernardino, including but not limited to all requirements in the plan addressing vehicular,
pedestrian, and bicycle safety.
MM 4.8-2: As part of street improvement plans for the 3rd Street and Victoria Avenue intersection and with
concurrence of the City of Highland, the developer shall be required to enhance the intersection pavement
markings to demark bike lane crossings across 3rd Street at the intersection.
MM 4.8-3: Prior to building permit issuance, the City of San Bernardino shall review building plans to
ensure that specifications are noted to install painted crosswalks or enhanced paving materials denoting the
pedestrian and bicycle lane crossings across the Project’s driveways connecting with 3rd Street. The
markings are required to be bold enough to be noticeable by truck drivers, for the purpose of visually alerting
drivers that pedestrians and bicyclists could be crossing the driveways. The City shall verify that the
markings are installed prior to the issuance of an occupancy permit.
MM 4.8-4: The developer and all successors in interest shall install and maintain signs at the Project
driveway exits connecting with 3rd Street at heights visible to truck drivers that state, “CAUTION,
PEDESTRIAN AND BICYCLE CROSSINGS AHEAD.” The City shall verify installation of the signs prior
to the issuance of an occupancy permit and require as a condition of the occupancy permit that the signs be
maintained in legible condition.
Project Applicant or
Developer
Project Applicant or
Developer
Project Applicant or
Developer
Prior to approval of street
improvement plans
(Monitoring also will be
conducted by the City of
Highland)
Prior to building permit
issuance and prior to
occupancy permit.
Prior to building permit
issuance and prior to
occupancy permit.
Legend C Project Site Boundary
City of San Bernardino General Plan Land Use Designations
Commercial
- Commercial General (CG-1)
Multi-Family Residential
- Residential Medium (RM)
Specific Plan
Alliance California Specific Plan
Public/Quasi-Public
Source(s): City of Son Bernardino /2005), Neormop Imagery /2020), SB County /2019)
San Manuel Industrial Park Proposed General Plan Amendment
Job Number: 1032-001 Date: June 2020