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HomeMy WebLinkAboutDEIR Ch 05_02_AQ 5. Environmental Analysis 5.2 AIR QUALITY The analysis in this section is based in part on the following technical reports(s): . General Plan Update 2004, Circulation Impact and Mitigation Measures, Transtech Engineers, December 22, 2004. . Arrowhead Springs Specific Plan, Traffic Impact Analysis and Mitigation Measures. Transtech Engineers, December 29, 2004. A complete copy of these studies is included in the Technical Appendices to this Draft EIR (Volume II, Appendix G, and Volume III, Appendix H) 5.2.1 Environmental Setting 5.2.1.1 San Bernardino General Plan Meteorologic Conditions The City of San Bernardino and SOl areas lie in the South Coast Air Basin (SoCAB or Basin) which includes all of Orange County as well as the non-desert portions of Los Angeles, Riverside, and San Bernardino Counties. The Basin is located in a coastal plain with connecting broad valleys and low hills, and is bounded by the Pacific Ocean in the southwest quadrant with high mountains forming the remainder of the perimeter. The general region lies in the semi-permanent high pressure zone of the eastern Pacific. As a result, the climate is mild, tempered by cool sea breezes. This usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds. ~ Temperature and Precipitation The annual average temperature varies little throughout the 6,600-square-mile Basin, ranging from the low 60s to the high 80s, measured in degrees Fahrenheit. With a more pronounced oceanic influence, coastal areas show less variability in annual minimum and maximum temperatures than inland areas. According to the Western Regional Climate Center, the yearly average temperature of City of San Bernardino is 65.90F.1 The average low is reported at 39.40F in December and January while the average high is 96.60F in July. All areas in the Basin have recorded temperatures above 1 OooF in recent years, and temperatures as high as 1100F have been recorded at the Ontario station. January is typically the coldest month in this area of the Basin, with minimum temperatures in the 30s. In contrast to a very steady pattern of temperature, rainfall is seasonally and annually highly variable. Almost all rain falls from November through April. Summer rainfall is normally restricted to widely scattered thunder- showers near the coast, with slightly heavier shower activity in the east and over the mountains. According to the Western Regional Climate Center, rainfall averages around 16.7 inches per year in the City of San Bernardino. Humidity Although the Basin has a semi-arid climate, the air near the surface is typically moist because of the presence of a shallow marine layer. Except for infrequent periods when dry, continental air is brought into the Basin by off-shore winds, the ocean effect is dominant. Periods of heavy fog, especially along the coastline, 1 Western Regional Climate Center. City of San Bernardino. Obtained March, 2005 from http://www.wrcc.dri.edu/cgi- bin/cliMAIN.pl?casanb General Plan Update and Associated Specific Plans EIR City of San Bernardino - Page 5.2-1 5. Environmental Analysis are frequent; and low stratus clouds, often referred to as "high fog" are a characteristic climatic feature. Annual average humidity is 70 percent at the coast and 57 percent in the eastern portions of the Basin. Wind Wind patterns across the south coastal region are characterized by westerly and southwesterly on-shore winds during the day and by easterly or northeasterly breezes at night. Wind speed is somewhat greater during the dry summer months than during the rainy winter season. Between periods of dominant air flow, periods of air stagnation may occur, both in the morning and evening hours. Whether such a period of stagnation occurs is one of the critical determinants of air quality conditions on any given day. During the winter and fall months, surface high pressure systems over the Basin, combined with other meteorological conditions, can result in very strong, down-slope Santa Ana winds. These winds normally continue a few days before predominant meteorological conditions are reestablished. The mountain ranges to the east represent topographical features that affect the transport and diffusion of pollutants in the project area by inhibiting the eastward transport of pollutants. Air quality in the SoCAB generally ranges from fair to poor and is similar to air quality in most of coastal Southern California. The entire region experiences heavy concentrations of air pollutants during prolonged periods of stable atmospheric conditions. Inversions In conjunction with the two characteristic wind patterns that affect the rate and orientation of horizontal pollutant transport, there are two similarly distinct types of temperature inversions that control the vertical depth through which pollutants are mixed. These inversions are the marine/subsidence inversion and the radiation inversion. The height of the base of the inversion at any given time is known as the "mixing height." This mixing height can change under conditions when the top of the inversion does not change. The combination of winds and inversions are critical determinants in leading to the highly degraded air quality in summer and the generally good air quality in the winter in the project area. Air Pollutants of Concern Criteria Air Pollutants The air pollutants emitted into the ambient air by stationary and mobile sources are regulated by Federal and State law. These regulated air pollutants are known as "criteria air pollutants" and are categorized as primary and secondary pollutants. Primary air pollutants are those that are emitted directly from sources. Carbon monoxide (CO), reactive organic gases (ROG), nitrogen oxides (NOx), sulfur dioxide (S02) and most fine particulate matter (PM1a, PM25) including lead (Pb) and fugitive dust; are primary air pollutants. Ofthese CO, S02' PM1a and PM25 are criteria pollutants. ROG and NOx are criteria pollutant precursors and go on to form secondary criteria pollutants through chemical and photochemical reactions in the atmosphere. Ozone (03) and nitrogen dioxide (N02) are the principal secondary pollutants. Presented below is a description of each of the primary and secondary criteria air pollutants and their known health effects. Other pollutants, such as carbon dioxide, a natural by-product of animal respiration that is also produced in the combustion process, have been linked to such phenomena as global warming. These emissions are unregulated and there are no thresholds for their release. These pollutants do not jeopardize the attainment status of the Basin and so are omitted from further discussion. Carbon Monoxide (CO) is a colorless, odorless, toxic gas produced by incomplete combustion of carbon substances (e.g., gasoline or diesel fuel). The primary adverse health effect associated with CO is interference with normal oxygen transfer to the blood, which may result in tissue oxygen deprivation. Page 5.2-2 . The Planning Center July 2005 5. Environmental Analysis Reactive Organic Gases (ROGs) are compounds comprised primarily of atoms of hydrogen and carbon. Internal combustion associated with motor vehicle usage is the major source of hydrocarbons. Other sources of ROG include evaporative emissions associated with the use of paints and solvents, the appli- cation of asphalt paving and the use of household consumer products such as aerosols. Adverse effects on human health are not caused directly by ROG, but rather by reactions of ROG to form secondary pollutants such as ozone. Nitrogen Oxides (NOx) serve as integral participants in the process of photochemical smog production. The two major forms of NOx are nitric oxide (NO) and nitrogen dioxide (N02). NO is a colorless, odorless gas formed from atmospheric nitrogen and oxygen when combustion takes place under high temperature and/or high pressure. N02 is a reddish-brown irritating gas formed by the combination of NO and oxygen. NOx acts as an acute respiratory irritant and increases susceptibility to respiratory pathogens. Nitrogen Dioxide (N02) is a byproduct of fuel combustion. The principal form of N02 produced by combustion is NO, but NO reacts with oxygen to form N02, creating the mixture of NO and N02 commonly called NOx. N02 acts as an acute irritant and, in equal concentrations, is more injurious than NO. At atmospheric concentrations, however, N02 is only potentially irritating. There is some indication of a relationship between N02 and chronic pulmonary fibrosis. Some increase in bronchitis in children (two and three years old) has also been observed at concentrations below 0.3 part per million (ppm). N02 absorbs blue light; the result is a brownish-red cast to the atmosphere and reduced visibility. N02 also contributes to the formation of PM10 (particulates having an aerodynamic diameter of 10 microns or 0.0004 inch or less in diameter) and ozone. Sulfur Dioxide (S02) is a colorless, pungent, irritating gas formed by the combustion of sulfurous fossil fuels. Fuel combustion is the primary source of S02' At sufficiently high concentrations, S02 may irritate the upper respiratory tract. At lower concentrations and when combined with particulates, S02 may do greater harm by injuring lung tissue. A primary source of S02 emissions is from the burning of high sulfur content coal. ~ Particulate Matter (PM) consists of finely divided solids or liquids such as soot, dust, aerosols, fumes and mists. Two forms of fine particulates are now recognized. Course particles, or PM10, include that portion of the particulate matter with an aerodynamic diameter of 10 microns (Le., 10 one-millionths of a meter or 0.0004 inch) or less. Fine particles, or PM25, have an aerodynamic diameter of 2.5 microns (Le., 2.5 one- millionths of a meter or 0.0001 inch) or less. Particulate discharge into the atmosphere results primarily from industrial, agricultural, construction and transportation activities. However, wind action on arid landscapes also contributes substantially to local particulate loading. Both PM10 and PM25 may adversely affect the human respiratory system, especially in those people who are naturally sensitive or susceptible to breathing problems. Fugitive Dust primarily poses two public health and safety concerns. The first concern is that of respiratory problems attributable to the suspended particulates in the air. Diesel particulates are classified by the CARB as a carcinogen. The second concern is that of motor vehicle accidents caused by reduced visibility during severe wind conditions. Fugitive dust may also cause significant property damage during strong windstorms by acting as an abrasive material agent (much like sandblasting activities). Finally, fugitive dust can result in a nuisance factor due to the soiling of proximate structures and vehicles. Ozone (03) or smog is one of a number of substances called photochemical oxidants that are formed when reactive organic compounds (ROC) and NOx (both byproducts of the internal combustion engine) react with sunlight. 03 is present in relatively high concentrations in the SoCAB, and the damaging effects of photochemical smog are generally related to the concentrations of 03, 03 poses a health threat to those who already suffer from respiratory diseases as well as to healthy people. Additionally, 03 has been tied to crop damage, typically in the form of stunted growth and premature death. 03 can also act as a corrosive, resulting in property damage such as the degradation of rubber products. General Plan Update and Associated Specific Plans EIR City of San Bernardino - Page 5.2-3 5. Environmental Analysis Toxic Air Contaminants The public's exposure to toxic air contaminants (TACs) is a significant environmental health issue in California. In 1983, the California Legislature enacted a program to identify the health effects ofTACs and to reduce exposure to these contaminants to protect the public health. The Health and Safety Code defines a TAC as "an air pollutant which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health." A substance that is listed as a hazardous air pollutant (HAP) pursuantto subsection (b) of Section 112 ofthe Federal act (42 USC Sec. 7412[b]) is a toxic air contaminant. Under State law, the California Environmental Protection Agency, acting through the CARB, is authorized to identify a substance as a TAC if it determines the substance is an air pollutant that may cause or contribute to an increase in mortality or to an increase in serious illness, or that may pose a present or potential hazard to human health. California regulates TACs primarily through AB 1807 (Tanner Air Toxics Act) and AB 2588 (Air Toxics "Hot Spot" Information and Assessment Act of 1987). The Tanner Air Toxics Act sets forth a formal procedure for CARB to designate substances as TACs. Once a TAC is identified, CARB adopts an "airborne toxics control measure" for sources that emit designated TACs. If there is a safe threshold for a substance (a point below which there is no toxic effect), the control measure must reduce exposure to below that threshold. If there is no safe threshold, the measure must incorporate toxics best available control technology (T-BACT) to minimize emissions. CARB has, to date, established formal control measures for 11 TACs, all of which are identified as having no safe threshold. Air toxics from stationary sources are also regulated in California under the Air Toxics "Hot Spot" Information and Assessment Act of 1987. Under AB 2588, toxic air contaminant emissions from individual facilities are quantified and prioritized by the air quality management district or air pollution control district. High priority facilities are required to perform a health risk assessment and, if specific thresholds are exceeded, are required to communicate the results to the public in the form of notices and public meetings. To date the CARB has designated nearly 200 compounds as TACs. Additionally, the CARB has implemented control measures for a number of compounds that pose high risks and show potential for effective control. The majority of the estimated health risks from T ACs can be attributed to a relatively few compounds, one of the most important in the southern California being particulate matter from diesel-fueled engines. In 1998, the CARB had identified particulate emissions from diesel-fueled engines (diesel PM) as a TAC. Previously, the individual chemical compounds in the diesel exhaust were considered as TACs. Almost all diesel exhaust particle mass is in the fine particle range of 10 microns or less in diameter. Because of their extremely small size, these particles can be inhaled and eventually trapped in the bronchial and alveolar regions of the lung. In 2000, the SCAQMD conducted a study on ambient concentrations of TACs and estimated the potential health risks from air toxics. The results showed that the overall risk for excess cancer from a lifetime expo- sure to ambient levels of air toxics was about 1,400 in a million. The largest contributor to this risk was diesel exhaust, accounting for 71 percent of the air toxics risk. Other Effects of Air Pollution Just as humans are affected by air pollution, so too are plants and animals. Animals must breathe the same air and are subject to the same types of negative health effects. Certain plants and trees may absorb air pollutants that can stunt their development or cause premature death. There are also numerous impacts to our economy including lost workdays due to illness, a desire on the part of business to locate in areas with a healthy environment, and increased expenses from medical costs. Pollutants may also lower visibility and cause damage to property. Certain air pollutants are responsible for discoloring painted surfaces, eating Page 5.2-4 . The Planning Center July 2005 5. Environmental Analysis away at stones used in buildings, dissolving the mortar that holds bricks together, and cracking tires and other items made from rubber. In conformance with the requirements of the Clean Air Act Amendments, the Federal Environmental Protection Agency (EPA) has prepared a monetary cost/benefit analysis related to implementation requirements. By the year 2010, the EPA estimates that its emissions reductions programs would cost approximately 27 billion dollars. The programs are estimated to result in a savings benefit of 110 billion dollars for a net benefit of 83 billion dollars2. While these values are for the nation as a whole, a net benefit ratio of about 4: 1 is noted and a similar ratio could be expected for the City of San Bernardino and its residents. Another direct cost/benefit issue relates to Federal funding. Areas that do not meet the Federal air quality standards may lose eligibility for Federal funding for road improvements and other projects that require Federal or California Department of Transportation approval. Cleaner air also yields benefits to ecological systems. The quantified benefits of Clean Air Act Amendments programs reflected in the overall monetary benefits include: increased agricultural and timber yields; reduced effects of acid rain on aquatic ecosystems; and, reduced effects of nitrogen deposited to coastal estuaries. Many ecological benefits, however, remain difficult or impossible to quantify, or can only be quanti- fied for a limited geographic area. The magnitude of quantified benefits and the wide range of unquantified benefits nonetheless suggest that as we learn more about ecological systems and can conduct more comprehensive ecological benefits assessments, estimates of these benefits could be substantially greater. Regulatory Setting ~ The development in the City of San Bernardino and SOl areas has the ability to release gaseous emissions of criteria pollutants and dust into the ambient air, it falls under the ambient air quality standards promulgated on the local, State, and Federal levels. The City of San Bernardino is located in the SoCAB and is subject to the rules and regulations imposed by the South Coast Air Quality Management District (SCAQMD). However, the SCAQMD reports to the California Air Resources Board (CAR B) , and all criteria emissions are also governed by the California Ambient Air Quality Standards (CAAQS) as well as the National Ambient Air Quality Standards (NAAQS). Ambient Air Quality Standards (AAQS) The Clean Air Act Amendment of 1971 established national Ambient Air Quality Standards (AAQS), with states retaining the option to adopt more stringent standards or to include other pollution species. These standards are the levels of air quality considered to provide a margin of safety in the protection of the public health and welfare. They are designed to protect those "sensitive receptors" most susceptible to further respiratory distress such as asthmatics, the elderly, very young children, people already weakened by other disease or illness and persons engaged in strenuous work or exercise. Healthy adults can tolerate occasional exposure to air pollutant concentrations considerably above these minimum standards before adverse effects are observed. Both the State of California and the Federal government have established health based Ambient Air Quality Standards for six air pollutants. As shown in Table 5.2-1, these pollutants include ozone, carbon monoxide, nitrogen dioxide, sulfur dioxide, suspended particulate matter (PM10) and lead. (PM25 particulate matter has also recently been added to this listing. However, for regulatory reasons discussed below and because the SCAQMD has not issued daily criteria for this type of pollutant, potential PM25 impacts are omitted from this analysis.) In addition, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility 2 US. Environmental Protection Agency. Benefits and Costs of the Clean Air Act. Final Report to Congress on Benefits and Costs of the Clean Air Act. 1990 to 2010. EPA 410-R-99-001. General Plan Update and Associated Specific Plans EIR City of San Bernardino - Page 5.2-5 5. Environmental Analysis reducing particles. These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety. Table 5.2-1 Ambient Air Quality Standards for Criteria Pollutants Federal California Primary Pollutant Averaging Time Standard Standard Major Pollutant Sources 1 hour 0.09 ppm 0.12 ppm Motor vehicles, paints, coatings, Ozone (Os) and solvents. 8 hours 0.07 ppm 0.08 ppm Internal combustion engines, Carbon Monoxide (CO) 1 hour 20 ppm 35 ppm primarily gasoline-powered motor vehicles. 8 hours 9.0 ppm 9 ppm Motor vehicles, petroleum-refining Annual Average * 0.05 ppm operations, industrial sources, Nitrogen Dioxide (N02) aircraft, ships, and railroads. 1 hour 0.25 ppm * Fuel combustion, chemical plants, Annual Average * 0.03 ppm sulfur recovery plants, and metal Sulfur Dioxide (S02) processing. 1 hour 0.25 ppm * 24 hours 0.04 ppm 0.14 ppm Dust and fume-producing construction, industrial, and Annual Arithmetic 20 /-lg/ms 50 /-lg/ms agricultural operations, combustion, Suspended Particulate atmospheric photochemical Matter Mean reactions, and natural activities (PM1o) (e.g. wind-raised dust and ocean sprays). 50 /-lg/ms 150 /-lg/ms 24 hours (PM1o) (PM1o) Dust and fume-producing construction, industrial, and Annual Arithmetic 12 /-lg/ms 15 /-lg/ms agricultural operations, combustion, Suspended Particulate atmospheric photochemical Matter Mean reactions, and natural activities (PM25) (e.g. wind-raised dust and ocean sprays). 24 hours * 65 /-lg/ms Present source: lead smelters, Monthly 1.5 /-lg/ms * battery manufacturing & recycling Lead (Pb) facilities. Past source: combustion of leaded gasoline. Quarterly * 1.5 /-lg/ms Sulfates (S04) 24 hours 25 /-lg/ms * Industrial processes. ppm: parts per million; f.lgjm3: micrograms per cubic meter * = standard has not been established for this pollutanVduration by this entity. Page 5.2-6 . The Planning Center July 2005 5. Environmental Analysis Air Quality Management Planning The SCAQMD and the Southern California Association of Governments (SCAG) are the agencies responsible for preparing the Air Quality Management Plan (AQMP) for the SoCAB. Since 1979, a number of AQMPs have been prepared. The 1997 AQMP, updated in 1999 and replaced in 2003, was based on the 1994 AQMP and on the 1991 AQMP, and was designed to comply with State and Federal requirements, reduce the high level of pollutant emissions in the SoCAB, and ensure clean air for the region through various control measures. To accomplish its task, the 1991 AQMP relied on a multilevel partnership of governmental agencies at the Federal, State, regional, and local level. These agencies (Le., the USEPA, CARB, local governments, SCAG, and SCAQMD) are the cornerstones that implement the AQMP programs. The most recent comprehensive plan is the 2003 Air Quality Management Plan, which was adopted on August 1, 2003. The 2003 AQMP updates the attainment demonstration for the Federal standards for ozone and particulate matter (PM10); replaces the 1997 attainment demonstration for the Federal carbon monoxide (CO) standard and provides a basis for a maintenance plan for CO for the future; and updates the maintenance plan for the Federal nitrogen dioxide (N02) standard that the South Coast Air Basin (Basin) has met since 1992. The AQMP provides local guidance for the State Implementation Plan (SIP) which provides the framework by which air quality basins would achieve attainment of the State and federal ambient air quality standards. Areas that meet ambient air quality standards are classified as "attainment" areas, while areas that do not meet these standards are classified as "non-attainment" areas. Severity classifications for ozone non- attainment include and range in magnitude from: marginal, moderate, serious, severe and extreme. The attainment status for the SoCAB is included in Table 5.2-2. Table 5.2-2 Attainment Status for the SoCAB ~ Pollutant State Status Federal Status Ozone Extreme Non-attainment Extreme Non-attainment PM,n Serious Non-attainment Serious Non-attainment CO Attainment Attainment/Maintenance N02 Attainment Attainment/Maintenance The Basin is also designated as attainment of the CAAQS for S02' lead, and sulfates. Areas that are extreme non-attainment of the ozone standard must meet attainment by November 15, 2010. Areas considered as serious non-attainment of the PM10 standards must reach attainment by December 31 of the year 2006, or as expeditiously as possible. Federal Clean Air Act Requirements The CAA requires the creation of plans to provide for the implementation of all reasonably available control measures, including the adoption of reasonably available control technology, for reducing emissions from existing sources. Emission control innovations in the form of market-based approaches are explicitly encouraged by the CAA. The SCAQMD is the first local agency in the country to adopt a market-based approach for controlling stationary source emissions of oxides of nitrogen and sulfur. Other Federal requirements addressed in the revision include mechanisms to track plan implementation and milestone compliance for 03 and CO. The USEP A is now phasing out and replacing the current 1-hour primary ozone standard with a new 8-hour standard to protect against longer exposure periods. The new ozone standard is set at a concentration of General Plan Update and Associated Specific Plans EIR City of San Bernardino - Page 5.2- 7 5. Environmental Analysis 0.08 parts per million (ppm) and represents a tightening of the existing 1-hour ozone standard, which is currently set at 0.12 ppm. Under the standard adopted by USEPA, areas are allowed to disregard their three worst measurements every year and average their fourth highest measurements over three years to determine if they meet the standard. For particulate matter, the USEP A established a new annual and a 24-hour standard for PM25 to complement the existing PM10 standards. The new annual PM25 standard is set at 15 micrograms per cubic meter and the new 24-hour PM25 standard is set at 65 micrograms per cubic meter. The annual component of the standard was set to provide protection against typical day-to-day exposures as well as longer-term exposures, while the daily component protects against more extreme short-term events. For the new 24-hour PM25 standard, the form of the standard is based on the 98th percentile of 24-hour PM25 concentrations measured in a year (averaged over three years) at the monitoring site with the highest measured values in an area. This form of the standard will reduce the impact of a single high exposure event that may be due to unusual meteorological conditions and thus provide a more stable basis for effective control programs. While USEPA has retained the current annual PM10 standard of 50 micrograms per cubic meter, it has modified the form of the 24-hour PM10 standard set at 150micrograms per cubic meter. More specifically, USEPA revised the one-expected exceedance form of the current standard with a 99th percentile form, averaged over three years. The state implementation plans that will incorporate attainment demonstrations with the new 8-hour and PM25 standards are expected to be required within three years of the air quality designations, or by 2007. Therefore, the current regulatory control strategies will continue to focus on attaining the 1-hour ozone standard, with the recognition that these controls will have benefits toward attaining the 8-hour ozone and PM25 standards. The USEPA is considering several options in transitioning from the 1-hour to the 8-hour standard, while ensuring that no backsliding will occur. Based on the recent consent decree guidance, it is most likely that the Basin will have to meet the federal PM25 standards by 2014 and the 8-hour ozone standard by 2021. Baseline Air Quality Existing levels of ambient air quality and historical trends and projections in the City of San Bernardino and SOl area are best documented by measurements made by the SCAQMD. The City of San Bernardino is located within the central portion of Source Receptor Area (SRA) 34 (Central San Bernardino Valley). The SCAQMD air quality monitoring station in the SRA34 is located within the City of San Bernardino on 4th street. Data from this station is summarized below in Table 5.2-3. Page 5.2-8 . The Planning Center July 2005 5. Environmental Analysis Table 5.2-3 Ambient Air Quality Monitoring Summary Number of Days Threshold Were Exceeded and Maximum Levels Such Violations State 1-Hour ~ 0.09 ppm 48 56 43 59 55 State 8-Hour 2: 0.07 ppm - - - - - FederaI1-Hour> 0.12 ppm 7 18 6 19 9 Federal8-Hour > 0.08 ppm 23 38 29 45 39 Max. 1-Hour Conc. (ppm) 0.149 0.184 0.147 0.160 0.157 Max. 8-Hour Conc. (ppm) 0.126 0.144 0.112 0.137 0.129 State 8-Hour > 9.0 ppm 0 0 0 0 0 Federal8-Hour ~ 9.5 ppm 0 0 0 0 0 Max. 8-Hour Conc. (ppm) 4.14 3.26 3.20 4.45 3.24 Nitrogen Dioxide State 1-Hour ~ 0.25 ppm Max. 1-Hour Conc. (ppm) Coarse Particulates (PMl(J3 o 0.114 o 0.118 State 24-Hour > 50 j.1g/ms 32 31 33 23 4 Federal 24-Hour > 150 j.1g/ms 0 0 0 0 0 Max. 24-Hour Conc. (J.1g/mS) 108.0 106.0 94.0 98.0 118.0 Fine PartictilateSW(PM z.5J3 Federal 24-Hour > 65 j.1g/ms 5 Max. 24-Hour Conc. (J.1g/mS) 78.5 ppm: parts per million; ~gjm3: micrograms per cubic meter Source: South Coast Air Quality Management District. San Bernardino 4th Street Monitoring Station 3 81.9 ~ The data show recurring violations of both the State and Federal ozone standards. The data also indicate that the area regularly exceeds the State PM10 standards. Additionally, PM25 has exceeded the Federal standard since this pollutant has been monitored. Neither the CO nor N02 standard have been violated in the last five years at this station. Sensitive Receptors Some land uses are considered more sensitive to air pollution than others due to the types of population groups or activities involved. Sensitive population groups include children, the elderly, the acutely ill, and the chronically ill, especially those with cardio-respiratory diseases. Residential areas are also considered to be sensitive receptors to air pollution because residents (including children and the elderly) tend to be at home for extended periods of time, resulting in sustained exposure to any pollutants present. Other sensitive receptors include retirement facilities, hospitals, and schools. Recreational land uses are considered moderately sensitive to air pollution. Although exposure periods are generally short, exercise places a high demand on respiratory functions, which can be impaired by air pollution. In addition, noticeable air pollution can detract from the enjoyment of recreation. Industrial and commercial areas are considered the least sensitive to air pollution. Exposure periods are relatively short and intermittent, as the majority of the workers tend to stay indoors most of the time. In addition, the working population is generally the healthiest segment of the public. General Plan Update and Associated Specific Plans EIR City of San Bernardino . Page 5.2-9 5. Environmental Analysis 5.2.1.2 Arrowhead Springs The Arrowhead Springs Specific Plan Area is also located in the central portion of SRA 24. The closest monitoring station to Arrowhead Springs is also the San Bernardino 4th Street monitoring station. Refer to Table 5.2-3 for existing air quality for the Arrowhead Springs Specific Plan area. 5.2.2 Thresholds of Significance According to Appendix G of the CEQA Guidelines, a project would normally have a significant effect on the environment if the project would: AQ-1 AQ-2 Conflict with or obstruct implementation of the applicable air quality plan. Violate any air quality standard or contribute substantially to an existing or projected air quality violation. AQ-3 Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors). AQ-4 AQ-5 Expose sensitive receptors to substantial pollutant concentrations. Create objectionable odors affecting a substantial number of people.3 The Initial Study, included as Volume 2, Appendix A, substantiates that impacts associated with the following thresholds would be less than significant only for the General Plan: AQ-5 South Coast Air Quality Management District Thresholds CEQA allows for the significance criteria established by the applicable air quality management or air pollution control district to be used to assess impacts of a project on air quality. The SCAQMD has established thresholds of significance for air quality for construction activities and project operation as shown below in Table 5.2-4: Air Pollutant Construction Phase Operational Phase Reactive Organic Gases (ROG) 75lbs/day 55 Ibs/day Carbon Monoxide (CO) 550 Ibs/day 550 Ibs/day Nitrogen Oxides (NOxl 100 Ibs/day 55lbs/day Sulfur Oxides (SOxl 150 Ibs/day 150 Ibs/day Particulates (PM1o) 150lbs/day 150 Ibs/day Table 5.2-4 SCAQMD's Significance Thresholds 3 The Initial Study concluded impacts less than significant for this threshold for the General Plan however. the Initial Study did not analyze odor impacts from the proposed wastewater treatment plant proposed as part of the Arrowhead Springs Specific Plan. As a result. odor impacts will be discussed for the Arrowhead Springs Specific Plan project. Page 5.2-10 . The Planning Center July 2005 5. Environmental Analysis In addition to the daily thresholds listed above, projects are also subject to the ambient air quality standards. These are addressed though an analysis of localized CO impacts. The California 1-hour and 8-hour CO standards are: . 1 hour = 20 parts per million . 8 hour = 9 parts per million 5.2.3 Environmental Impacts 5.2.3.1 San Bernardino General Plan The following impact analysis addresses those air quality issues for which the Initial Study disclosed potentially significant impacts. The applicable thresholds are identified in parentheses after the impact statement. The City of San Bernardino General Plan guides growth and development within the City of San Bernardino. The City of San Bernardino had a year 2000 population of 185,401 and 63,535 housing units4, which does not include the City's SOl area. Upon build-out of the General Plan, San Bernardino's future population is projected to grow to 276,264 in the City and 42,976 in the SOl areas. The included analysis is based on methodologies and emission factors included in the SCAQMD Handbook and URBEMIS2002 computer model and CARB's EMFAC2002 and CALlNE4 computer models. GP IMPACT 5.2-1: THE SAN BERNARDINO GENERAL PLAN UPDATE IS CONSISTENT WITH THE SOUTH COAST AQMP. [THRESHOLD AQ-1] ~ Impact Analysis: CEQA requires that General Plans be evaluated for consistency with the AQMP. A consistency determination plays an important role in local agency project review by linking local planning and individual projects to the AQMP. It fulfills the CEQA goal of informing decision-makers of the environmental effects of the project under consideration at a stage early enough to ensure that air quality concerns are fully addressed. It also provides the local agency with ongoing information as to whether they are contributing to clean air goals contained in the AQMP. Only new or amended General Plan elements, Specific Plans, and major projects need to undergo a consistency review. This is because the AQMP strategy is based on projections from local General Plans. Projects that are consistent with the local General Plan are considered consistent with the air quality-related Regional Plan. Discussion with the SCAQMD (Susan Nakamura, Planning Manager, (March 2, 2004) noted that if growth projections included in the 2003 AQMP are not exceeded, a project would generally be considered to be consistent with the 2003 AQMP if it incorporates emissions reduction measures included in the 2003 AQMP. The emissions forecasted within the 2003 AQMP are based on forecasts of various socioeconomic categories such as population, housing and employment. These demographic growth forecasts were developed by SCAG for their 2001 Regional Transportation Program (RTP) to estimate future emissions described in the 2003 AQMP and in the demonstration of attainment of the State and federal Ambient Air Quality Standards (AAQS). As shown in Section 5.8, Land Use, in Table 5.8-4, the existing General Plan population and buildout projections are greater than those projected for the General Plan Update. As a result, the General Plan update would be consistent with the AQMP as the growth and buildout projections do not exceed those projected within the existing General Plan. 4 US Census Bureau 2000. General Plan Update and Associated Specific Plans EIR City of San Bernardino . Page 5.2-11 5. Environmental Analysis GP IMPACT 5.2-2: CONSTRUCTION ACTIVITIES ASSOCIA TED WITH THE PROPOSED PROJECT WOULD GENERATE SHORT-TERM EMISSIONS WHILE LONG-TERM OPERATION OF THE PROJECT WOULD GENERATE ADDITIONAL VEHICLE TRIPS AND ASSOCIATED EMISSIONS IN EXCEEDANCE OF SCAQMD'S THRESHOLD CRITERIA. [THRESHOLDS AQ-2 AND AQ-3] Impact Analysis: Construction Construction activity would occur over the build-out horizon in accordance with the proposed General Plan Update would cause temporary, short-term emissions of various air pollutants. ROG, NOx, PM10 and CO would be emitted by the operation of construction equipment, while fugitive dust (PM10) would be emitted by activities that disturb the soil, such as grading and excavation, road construction and building demolition and construction. Information regarding specific development projects, soil types, and the locations of receptors would be needed in order to quantify the level of impact associated with construction activity. However, given the amount of development that the proposed General Plan Update could accommodate, it is reasonable to conclude that some major construction activity could occur at any given time over the life of the General Plan, which could exceed SCAQMD's adopted thresholds and would result in a significant air quality impact due to construction activities. Operation The San Bernardino General Plan Update guides growth and development within the City of San Bernardino by designating land uses and through implementation of goals and policies. With growth, comes additional emissions generate by stationary and vehicular sources. These emissions contribute to the overall emissions inventory in the air basin. The project includes the planned development within developed and undeveloped portions of the City. Upon General Plan build-out, the City of San Bernardino is anticipated too have 95,664 housing units, approximately 195.7 million square-feet of commercial and industrial uses, 7.4 million square feet of public facilities, and 3,091 acres of public and private open space. Although the San Bernardino General Plan does not assume an ultimate build-out date, the General Plan assumes an annual rate of growth. To obtain air quality emissions estimates of the amount of emissions attributable to the additional development associated with the proposed General Plan update, the UBEMIS2002 emissions inventory model was used. The additional land use development due to the build-out of the General Plan update is based on the difference in development between year 2005 and 2030 conditions. There is no data on the total existing year 2005 land use areas. As such, 2005 development areas were calculated based on housing and employment projections from the RTP as detailed in Table 5.11-2 in Section 5.11, Population and Housing. While build-out will ultimately be market driven, for modeling purposes this analysis is based on the assumption that all uses will be implemented by the year 2030 and emissions are based on this horizon. Operational impacts could result from local and regional vehicle emissions generated by future traffic growth, as well as direct emissions due to the use of on-site utilities and consumer goods associated with the proposed land uses. The daily number of vehicle trips associated with build-out of the proposed General Plan was based the URBEMS2002 trip generation calculations assumed from build-out associated with the proposed land uses. The total emissions generated by the proposed land uses are included in Table 5.24. To calculate the increase in emissions that would occur due to the increased development discussed under the General Plan Update, emissions associated with the additional development was calculated and evaluated against the SCAQMD daily operational phase emissions thresholds. In addition to vehicle emissions, emissions would be created from stationary sources including the use of natural gas, the use of landscape maintenance equipment, fireplaces and the use of consumer products, Page 5.2-12 . The Planning Center July 2005 5. Environmental Analysis such as aerosol sprays. Emissions were calculated for both the summer and winter seasons. The primary differences in emissions between these two seasons are fireplace emissions that occur in the winter. Emissions from wood fired fire places contribute substantial emissions during the winter season. These emissions are also predicted by the URBEMIS2002 model and included in Table 5.2 6. Various industrial and commercial processes (e.g., dry cleaning) allowed under the proposed General Plan Update would also be expected to release emissions; some of which could be hazardous. These emissions are controlled at the local and regional level through permitting and would be subject to further study and health risk assessment prior to the issuance of any necessary air quality permits. Because the nature of these emissions cannot be determined at this time, and are subject to further regulation and permitting, they will not be addressed further in this analysis. As noted in Table 5.2-5, future growth in accordance with the proposed General Plan Update would exceed the daily SCAQMD thresholds for CO, NOx, ROG, PM10, The exceedance of the SCAQMD emissions thresholds would be expected because these thresholds were designed for individual projects. As such, specific or general plans would substantially exceed the SCAQMD thresholds by orders of magnitude because these plans incorporate the development of multitudes of individual projects. Exceedance of the SCAQMD daily emissions thresholds is considered to result in a significant adverse impact. Table 5.2-5 Project Related Operational Phase Emissions (In Pounds Per Day) General Plan Build-Out Year 2030 UUIIIIII'" ROG NOx CO SOp PM1n Area Sources 574 448 218 1 1 Vehicle Sources 2,418 2,098 25,754 70 12,164 Total 2,991 2,546 25,972 71 12,164 Winter ROG NOx CO S02 PM10 Area Sources 12,868 586 13,746 21 1,859 Vehicle Sources 2,203 3,010 23,881 63 12,164 Total 15,071 3,597 37,627 84 14,022 SCAQMD Standard 75 100 550 150 150 Significant? Yes Yes Yes No Yes ~ Source: The Planning Center using the URBEMIS2002 emissions inventory model, March 2005. GP IMPACT 5.2-3: IMPLEMENTATION OF THE SAN BERNARDINO GENERAL PLAN UPDATE WOULD RESULT IN A CUMULATIVELY CONSIDERABLE NET INCREASE OF CRITERIA POLLUTANTS FOR WHICH THE PROJECT REGION IS IN A STATE OF NON-ATTAINMENT. [THRESHOLD AQ-3] As discussed previously, the proposed project would result in emissions which exceed the SCAQMD emissions thresholds for both the construction and operational phases. The SCAQMD considers exceedance of their daily significance thresholds to lead to a significant contribution to emissions on a cumulative basis. Because the air basin is currently in a state of non-attainment for CO, ozone and particulate matter, the additional air pollution generated by further development of the General Plan would incrementally contribute to the state of non-attainment of the ambient air quality standards. General Plan Update and Associated Specific Plans EIR City of San Bernardino . Page 5.2-13 5. Environmental Analysis GP IMPACT 5.2-4: BUlLDOUT OF THE SAN BERNARDINO GENERAL PLAN UPDATE WOULD NOT EXPOSE SENSITIVE RECEPTORS TO SUBSTANTIAL POLLUTANT CONCENTRATIONS. [THRESHOLD AQ-4] Impact Analysis: An impact is potentially significant if concentration of emissions exceed the State or Federal Ambient Air Quality Standards. Methodologies for the modeling of concentrations of criteria pollutants have not been established at a city level to demonstrate compliance with CEQA requirements. Modeling concentrations of pollutants at this macro level of analysis is typically only performed by local air quality districts. Macro scale analyses of pollutant concentrations would involve urban airshed modeling which involves multiple cities and meteorological data and are not conducted for General Plans. However, a defined methodology has been established by the SCAQMD to determine concentrations of CO at a local level such as for individual projects or General Plans. Modeling of CO is performed for vehicle sources because they have the potential for creation of CO "hot spots" at heavily congested intersections. Because CO is produced in greatest quantities from vehicle combustion and does not readily disperse into the atmosphere, adherence to the Ambient Air Quality Standards is typically demonstrated through an analysis of localized CO concentrations. Areas of vehicle congestion have the potential to create "pockets" of CO called "hot spots." These pockets may have the potential to exceed the State 1 hour standard of 20 ppm and/or the 8 hour standard of 9.0 ppm or Federal levels of 35 and 9 ppm, respectively. During the operations phase of the General Plan Update, traffic may have the potential to contribute to local area air quality impacts. Analysis at selected intersections was performed to determine the potential for the presence or the creation of CO hot spots attributable to the proposed project. Local area CO concentrations were projected using the CALlNE4 traffic pollutant dispersion model. The analysis of CO impacts followed the protocol recommended by the California Department of Transportation's Transportation Project-Level Carbon Monoxide Protocol (Protocol) (December 1997). It is also consistent with procedures identified through the SCAQMD CO modeling protocol, with all four corners of each intersection analyzed to determine whether project operations would result in CO concentrations that exceed the national or state CO AAQS. Consistent with and required by the Caltrans Protocol, sensitive receptor monitoring was conducted 10 feet from the edge of the road for each corner of the intersection. Placing the sensitive receptor locations 10 feet from the edge of the road at each corner of the study intersection represents a worst case modeling approach in which these locations are exposed to peak hour traffic volumes traveling at speeds associated with congested road conditions and under meteorological conditions conducive to pollutant formation. Receptor locations further than 10 feet from the edge of the road and further from the study intersection would experience lower concentrations of CO due to increase pollutant dispersion from the pollutant source. The CALlNE4 model generates results of CO concentrations averaged over a one-hour time period under worst case atmospheric conditions for the area which include low wind speeds and low atmospheric circulation. Eight-hour concentrations were calculated by converting the 1-hour concentrations to 8-hour equivalents, using the conversion protocol recommended by the SCAQMD. Future CO concentrations were determined by adding the predicted increase in CO concentrations attributable to the operation of the proposed project to a projected ambient concentration. Traffic conditions during the build-out year of year of the project were modeled for the baseline traffic scenario (Le., future traffic not including the project) and the baseline-plus-project condition. CO concentrations associated with both the baseline and baseline-plus-project condition are evaluated against the AAQS. Congested intersections that are most conducive to the formation of CO hotspots were modeled. Table 5.2-6 lists the existing year 2003 and build-out year 2030 CO concentrations that would occur at the study area intersections, with and without the proposed project. Build-out year CO concentrations were found to be lower than the existing year 2005 concentrations due to technological improvements in vehicle emissions. Based on the CALI NE4 analyses, neither the existing nor future year traffic would result in any exceedances of the state 1-hour CO AAQS at the study area intersections. Similarly, 8-hour concentrations at the analyzed Page 5.2-14 . The Planning Center July 2005 5. Environmental Analysis intersections would be below the state AAQS, as shown in Table 5.2-7. Consequently, sensitive receptors in the area would not be significantly adversely affected by CO emissions generated by operation of the proposed project. Localized air quality impacts related to CO from mobile source emissions would therefore be less than significant for the proposed project. Receptor Hunts Lane/E Street Table 5.2-6 One-Hour Carbon Monoxide Dispersion Analysis For Existing Year 2000 and Year 2030 Build-out Year of the General Plan Update (In Parts Per Million) Year 2030 Build-out Existing Year SCAQMD Threshold Significant Impact? Northeast 7.7 3.9 20 No Southeast 7.4 3.9 20 No Southwest 6.6 3.8 20 No Northwest 8.0 3.9 20 No Waterman Avenue/30th Street Northeast 6.6 3.8 20 No Southeast 6.1 3.9 20 No Southwest 7.2 3.9 20 No Northwest 6.7 3.9 20 No SR-30 Westbound Ramp/30th Street Northeast 5.7 3.8 20 No Southeast 5.6 3.8 20 No Southwest 5.5 3.8 20 No Northwest 5.7 3.8 20 No ~ Tippecanoe Avenue/Rialto Avenue Southeast 6.0 3.8 20 No Southwest 5.9 3.8 20 No Northwest 5.9 3.8 20 No Northeast 5.8 3.8 20 No Mountain View/San Bernardino Road Northeast 5.4 3.8 20 No Southeast 6.2 3.9 20 No Southwest 5.9 3.9 20 No Northwest 5.9 3.9 20 No Source: The Planning Center based on the Caltrans' traffic emission dispersion model CALlNE4 General Plan Update and Associated Specific Plans EIR City of San Bernardino . Page 5.2-15 5. Environmental Analysis Table 5.2-7 Eight-Hour Carbon Monoxide Dispersion Analysis For Existing Year 2000 and Year 2030 Build-out Year of the General Plan Update (In Parts Per Million) Year 2025 SCAQMD Build-out Threshold Existing Year Significant Impact? Receptor Hunts Lane/E Street Northeast 5.8 3.1 9 No Southeast 5.6 3.1 9 No Southwest 5.0 3.0 9 No Northwest 6.0 3.1 9 No Stre,~t Northeast 5.0 3.0 9 No Southeast 4.7 3.1 9 No Southwest 5.5 3.1 9 No Northwest 5.1 3.1 9 No SR-30 Westbound Ramp/30th Street Northeast 4.4 3.0 9 No Southeast 4.3 3.0 9 No Southwest 4.3 3.0 9 No Northwest 4.4 3.0 9 No Tippecanoe Avenue/Rialto Avenue Southeast 4.6 3.0 9 No Southwest 4.6 3.0 9 No Northwest 4.6 3.0 9 No Northeast 4.5 3.0 9 No D"",..t Northeast 4.2 3.0 9 No Southeast 4.8 3.1 9 No Southwest 4.6 3.1 9 No Northwest 4.6 3.1 9 No Source: The Planning Center based on the Caltrans' traffic emission dispersion model CALlNE4 Relevant General Plan Policies and Programs The relevant General Plan policies and programs pertaining to air quality include the following: Natural Resources and Conservation Element Policy 12.4.2: Impose conditions and enforce mitigation measures on mining operations to reduce dust, noise, and safety hazards associated with removal of construction aggregate and minimize impacts on adjacent properties and environmental resources. Policy 12.4.8: Require that new, non-mining land uses adjacent to existing mining operations be designed to provide a buffer between the new development and the mining operations. The buffer distance shall be based on an evaluation of noise, aesthetics, drainage, operating conditions, biological resources, topography, lighting, traffic, operating hours, and air quality. Page 5.2-16 . The Planning Center July 2005 5. Environmental Analysis Policy 12.5.1: Reduce the emission of pollutants including carbon monoxide, oxides of nitrogen, photochemical smog, and sulfate in accordance with South Coast Air Quality Management District (SCAQMD) standards. Policy 12.5.2: Prohibit the development of land uses (e.g. heavy manufacturing) that will contribute significantly to air quality degradation, unless sufficient mitigation measures are undertaken according SCAQMD standards. Policy 12.5.3: Require dust abatement measures during grading and construction operations. Policy 12.5.4: Evaluate the air emissions of industrial land uses to ensure that they will not impact adjacent uses. Policy 12.5.5: Purchase City vehicles that use energy efficient fuel and minimize air pollution. Policy 12.6.1: Promote a pattern of land uses which locates residential uses in close proximity to employment and commercial services and provides, to the fullest extent possible, local job opportunities and commercial service to minimize vehicular travel and associated air emissions. Policy 12.6.2: Disperse urban service centers (libraries, post offices, social services, etc.) throughout the City to minimize vehicle miles traveled and the concomitant dispersion of air pollutants. Policy 12.6.3: Install streets cape improvements and other amenities to encourage pedestrian activity in key City areas and reduce vehicular travel and associated air emissions. Policy 12.6.4: Facilitate the development of centralized parking lots and structures in commercial districts to promote walking between individual businesses in lieu of the use of automobiles. (LU-1) ~ Policy 12.6.5: Require qualifying development to implement or participate in transportation demand management programs, which provide incentives for car pooling, van pools, and the use of public transit and employ other trip reduction techniques (consistent with the Circulation Element and South Coast Air Quality Management Plan). Policy 12.6.6: Continue to cooperate with Omnitrans and the Rapid Transit District to expand as necessary the comprehensive mass transit system for the City to reduce vehicular travel. Policy 12.6.7: Promote the use of public transit and alternative travel modes to reduce air emissions. Policy 12.7.1: Cooperate with the South Coast Air Quality Management District and incorporate pertinent local implementation provisions of the Air Quality Management Plan. Policy 12.7.2: Work with the South Coast Air Quality Management District to establish controls and monitor uses in the City that could add to the air basin's degradation (e.g. auto repair, manufacturers). Policy 12.7.3: Coordinate with SCAQMD to ensure that all elements of air quality plans regarding reduction of air pollutant emissions are being enforced. Policy 12.7.4: Work with the other cities in the South Coast Air Basin to implement regional mechanisms to reduce air emissions and improve air quality. Policy 12.7.5: Support legislation that promotes cleaner industry, clean fuel vehicles, and more efficient burning engines and fuels. Policy 12.7.6: Encourage, publicly recognize, and reward innovative approaches to improve air quality. General Plan Update and Associated Specific Plans EIR City of San Bernardino . Page 5.2-1 7 5. Environmental Analysis Policy 12.7.8: Involve environmental groups, the business community, special interests, and the general public in the formulation and implementation of programs that actively reduce airborne pollutants. 5.2.3.2 Arrowhead Springs Specific Plan The Arrowhead Springs Specific Plan is the blueprint for development for the Arrowhead Springs area. Currently the Arrowhead Springs Specific Plan area is comprised of uses associated with the historical resort onsite, developed around the natural springs in the area. The area is no longer open as resort, however. The facilities present consist of approximately 34 buildings including a hotel, an auditorium, a chapel, dormitories, a pool and cabanas, residential bungalows, office buildings, and maintenance buildings. Only the office, maintenance, and select bungalow buildings are currently utilized. The uses proposed for the development are discussed in Section 3.3.4 of this DEIR. AHS IMPACT 5.2-1: THE ARROWHEAD SPRINGS SPECIFIC PLAN PROJECT IS CONSISTENT WITH THE SOUTH COAST AQMP. [THRESHOLD AQ-1] Impact Analysis: As noted in the discussion of GP IMPACT 5.2-1, SCAQMD would consider a project to be generally consistent with the 2003 AQMP if growth projections included in the 2003 AQMP are not exceeded and the project incorporates emissions reduction measures included in the 2003 AQMP. The explanation of consistency stated in the General Plan Update impact section also applies to the Arrowhead Springs Specific Plan. The majority of the Arrowhead Spring Specific Plan area is currently located outside the City limits for the City of San Bernardino but was also considered within the SOl and was included in the calculations of existing General Plan buildout. As shown in Section 5.8, Land Use, in Table 5.8-4, the existing General Plan population and buildout projections are greater than those projected for the General Plan Update. The buildout projections for the General Plan Update also include buildout of the City of San Bernardino and the Sphere of Influence areas, including the Arrowhead Springs Specific Plan project. With the increase in population due to the Arrowhead Springs project, the buildout projections of the existing General Plan are still greater than the proposed update. Given that the AQMP is based on the existing General Plan which has greater projections than the proposed General Plan update and that the buildout projections for the General Plan update include the SOl (and the Arrowhead Springs project), it can be concluded that the Arrowhead Springs Specific Plan would also be consistent with the AQMP. Page 5.2-18 . The Planning Center July 2005 5. Environmental Analysis AHS IMPACT 5.2-2: CONSTRUCTION ACTIVITIES ASSOCIA TED WITH THE PROPOSED PROJECT WOULD GENERATE SHORT-TERM EMISSIONS WHILE LONG-TERM OPERATION OF THE PROJECT WOULD GENERATE ADDITIONAL VEHICLE TRIPS AND ASSOCIATED EMISSIONS IN EXCEEDANCE OF SCAQMD'S THRESHOLD CRITERIA. [THRESHOLDS AQ-2 AND AQ-3] Impact Analysis: Construction Construction activities from development of the Arrowhead Springs Specific Plan would produce combustion emissions from various sources such as site grading, utility engines, on-site heavy-duty construction vehicles, equipment-hauling materials to and from the site, asphalt paving, and motor vehicles transporting the construction crew. Exhaust emissions from construction activities envisioned on site would vary daily as construction activity levels change. Construction activities associated with new development occurring in the project area would temporarily increase air pollutant emissions in the project vicinity. The primary source of air pollutant emissions is gasoline- and diesel-powered, heavy-duty mobile construction equipment such as scrapers and motor graders. Primary sources of PM10 emissions would be clearing and demolition activities, excavation and grading operations, construction vehicle traffic on unpaved ground, and wind blowing over exposed earth surfaces. During the construction phase, over 14 million cubic yards of cut and fill soil would be moved (7 million for cut and 7 million for fill onsite) for development of the Arrowhead Springs Specific Plan project footprint. This estimate of disturbed soil does not include remedial grading activities that may be required due eliminate slope instability, which may total an additional 1 million cubic yards. Emissions generated from construction activities are anticipated to cause temporary increases in pollutant emissions. The quantity of air pollutant emissions generated are dependant on a number of factors, including soil composition on site, the amount of soil disturbed, wind speed, the number and type of machinery used, the construction schedule, and the proximity of other construction and demolition projects. The included analysis is based on the URBEMIS2002 computer model. The results of the URBEMIS2002 computer modeling are included in Table 5.2-8 and assume a worst-case scenario for construction emissions from build-out of the Arrowhead Springs Specific Plan in two phases over a ten year buildout period. The first phase between the years of 2005-2007 assumes demolition, all mass grading, paving of major roads, installation of water and sewer facilities and dry utilities. The second phase would include construction of all structures for residential and commercial use. Site grading would occur over a two year period, with an estimated 28,409 cubic yards of cut and fill per day. Subsequent building construction was then assumed to occur over the following eight years with full buildout in the year 2015. Emissions estimates included in Table 5.2-8 represent worst-case emissions estimates from any given year during those phases. Table 5.2-8 Project Related Construction Phase Emissions (In Pounds Per Day) CO ROG NOx SOl PM10 Site Grading (2005-2007) 184 23 168 0.00 3,362 Building Construction (2007-2015) 483 815 131 0.18 6.11 SCAQMD Standard 550 75 100 150 150 Significant? Yes Yes Yes No Yes Source: The Planning Center using the URBEMIS2002 emissions inventory model. General Plan Update and Associated Specific Plans EIR City of San Bernardino . Page 5.2-19 ~ 5. Environmental Analysis As shown in Table 5.2-8, construction emissions for CO, ROG and NOx would significantly exceed the SCAQMD threshold during both site grading and construction. Operation Long-term air emission impacts are those associated with stationary sources and mobile sources related to any change related to the proposed project. The proposed development would consist of 1,350 residential units, 1,049,190 square-feet of commercial and office uses, 199-acre public golf course, a new 300 room hotel and conference center, reuse and expansion of the historic Arrowhead Springs Hotel resort. The stationary sources of emissions from the land uses associated from build-out of the Arrowhead Springs Specific Plan would come from its consumption of natural gas and electricity. Based on the traffic study prepared for the San Bernardino General Plan Update by Transtech Engineers (December 2004), the proposed project would generate 24,412 average daily trips upon cumulative build-out of phase one and phase two of the Arrowhead Springs Specific Plan development. Using the emissions inventory model URBEMIS2002, emissions associated with project-related vehicular trips were calculated and are included in Table 5.2-9. Table 5.2-9 Project Related Operational Phase Emissions (In Pounds Per Day) Summer co ROG NOx S02 PMib Stationary Sources (electricity/natural gas consumption, landscaping) 12 68 19 0 0 Mobile Sources 1,123 117 113 2 230 Total 1,233 185 132 2 230 SCAQMD Standard 550 55 55 150 150 Significant? Yes Yes Yes No Yes Winter co ROG NOx S02 PMib Stationary Sources (electricity/natural gas consumption, landscaping) 1,668 1,580 36 3 228 Mobile Sources 1,155 99 162 1 230 Total 2,831 1,679 198 4 459 SCAQMD Standard 550 55 55 150 150 Significant? Yes Yes Yes No Yes Source: The Planning Center using the URBEMIS2002 emissions inventory model. As shown, project-related emissions would exceed the SCAQMD daily emissions thresholds for CO, ROG, NOx, and PM10, Winter emissions generate substantially more than summer emissions because the residential units were modeled using conservative rates of wood burning fireplaces. Wood burning fireplaces emit a substantial amount of air pollutants because it is an uncontrolled burn. Consequently, this results in substantial emissions differences between summer and winter emissions. Mobile sources of emissions also represent a large portion of operational emissions for the project. Because the proposed project results in emissions which exceed the SCAQMD daily operational phase emissions thresholds, the proposed project's impact to air quality is considered significant. Page 5.2-20 . The Planning Center July 2005 5. Environmental Analysis AHS IMPACT 5.2-3: THE ARROWHEAD SPRINGS SPECIFIC PLAN PROJECT WOULD DELAY ATTAINMENT OF THE SOUTH COAST AQMP [THRESHOLD AQ-3] As discussed previously, the proposed project would result in emissions which exceed the SCAQMD emissions thresholds for both the construction and operational phases. The SCAQMD considers exceedance of their daily significance thresholds to lead to a significant contribution to emissions on a cumulative basis. Because the air basin is currently in a state of non-attainment for CO, ozone and particulate matter, the additional air pollution generated by further development of the Arrowhead Springs Specific Plan would incrementally contribute to the state of non-attainment of the ambient air quality standards. AHS IMPACT 5.2-4: IMPLEMENTATION OF THE ARROWHEAD SPRINGS SPECIFIC PLAN PROJECT WOULD NOT EXPOSE SENSITIVE RECEPTORS TO SUBSTANTIAL POLLUTANT CONCENTRATIONS. [THRESHOLD AQ-4] Impact Analysis: Vehicular trips associated with the proposed project would contribute to the congestion at intersections and along roadway segments in the project vicinity. The primary mobile source pollutant of local concern is CO. Typically, high CO concentrations are associated with roadways or intersections operating at unacceptable levels of service or with extremely high traffic volumes. The traffic impacts from the build-out of the Arrowhead Springs Specific Plan were included within the traffic volumes of the General Plan update. The traffic volumes were evaluated for the existing year and year 2025. The intersection vehicle turn volumes were used in the Caltrans CALlNE4 model to evaluate local CO concentrations at intersections most affected by project traffic. As shown previously, Table 5.2-5 and Table 5.2-6 list the CO concentrations for those intersections that are most impacted by traffic congestion. None of the intersections analyzed would have eight-hour CO concentration exceeding federal and State standards of 9 ppm. The one-hour CO concentration at these intersections would also be below the State standard of 20.0 ppm and below the federal standard of 35 ppm. The proposed project would not have a significant impact on local air quality for CO, and no mitigation measures would be required. ~ AHS IMPACT 5.2-5: CREATE OBJECTIONABLE ODORS AFFECTING A SUBSTANTIAL NUMBER OF PEOPLE. [THRESHOLD AQ-5] Construction activity will require the operation of equipment which may generate exhaust from either gasoline or diesel fuel. Construction and development will also require the application of paints and the paving of roads which could generate odors from materials such as paints and asphalt. As these odors are short-term in nature and quickly disburse into the atmosphere, this is not considered significant. Future residential and commercial development would involve minor, odor-generating activities, such as backyard barbeque smoke, lawn mower exhaust, application of exterior paints from home improvement, etc. These types and concentrations of odors are typical of residential communities and are not considered significant air quality impacts. The proposed wastewater treatment plant has the potential to generate odors. Modern sewage treatment plants have numerous project design features to control odor emissions during the sewage treatment process which include capture, containment and treatment of foul air. These project design features will, at a minimum, include enclosure of the most odorous wastewater treatment components which may include the headworks, primary clarifiers, digesters and grit chamber to contain odorous air prior to odor treatment. The contained odorous air will be piped into a chemical or biological odor control treatment process which would breakdown hydrogen sulfides and other compounds which are associated with odors. The proposed project is also required to comply with SCAQMD Rule 402 to prevent occurrence of public nuisances. As a result, the proposed wastewater treatment plant is required to control project related odors to avoid the creation of a public nuisance. Because the proposed project will incorporate odor control General Plan Update and Associated Specific Plans EIR City of San Bernardino . Page 5.2-21 5. Environmental Analysis systems as the project design features described above and is subject to mandatory compliance with SCAQMD Rule 402, odorous emissions attributable to the proposed project are not considered a significant adverse impact to air quality. 5.2.4 Existing Regulations and Standard Conditions SCAQMD Rules and Regulations: The City of San Bernardino and Arrowhead Springs Specific Plan area is located in the SoCAB and is subject to the rules and regulations imposed by the SCAQMD. All emissions within the City of San Bernardino are governed by the CAAQS as well as the NAAQS. New source pollution sources within the City of San Bernardino would be subject to a new source review by the SCAQMD. Any equipment that emits or controls air contaminants (such as nitrogen oxides or reactive organic gases) requires a permit from AQMD prior to construction, installation, or operation unless it is specifically exempted from the permit requirement by AQMD Rule 219. SCAQMD Rule 402: SCAQMD Rule 402 states, "A person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public or which cause, or have a natural tendency to cause, injury or damage to business or property." SCAQMD Rule 403: SCAQMD Rule 403 does not require a permit for construction activities, per se, but rather, sets forth general and specific requirements for all construction sites (as well as other fugitive dust sources) in the SoCAB. The general requirement prohibits a person from causing or allowing emissions of fugitive dust from construction (or other fugitive dust source) such that 1) the presence of such dust remains visible in the atmosphere beyond the property line of the emissions source or, 2) allows dust emissions to exceed 20 percent opacity (as determined by the appropriate test method included in the Rule 403 I mplementation Handbook), if the dust emission is the result of movement of a motorized vehicle. No person shall conduct active operations without utilizing the applicable best available control measures (BAC) to minimize fugitive dust emissions from each fugitive dust source type within the active operation. SCAQMD Rule 403 also prohibits a construction site from causing an incremental PM10 concentration impact at the property line of more than 50 micrograms per cubic meter as determined through PM10 high-volume sampling, but the concentration standard and associated PM10 sampling do not apply if specific measures identified in the rule are implemented and appropriately documented. SCAQMD Rule 403 identifies two sets of specific measures: one for high wind conditions and the other for more normal wind conditions. When wind gusts exceed 25 miles per hour, neither the sampling requirement nor the general requirement applies so long as the following measures are implemented and appropriately documented: Page 5.2-22 . The Planning Center July 2005 5. Environmental Analysis Source Earthmoving Disturbed Surface Areas Unpaved Roads Open Storage Piles Paved Road Track-out Control Measure Cease all active operations, or apply water to soil not more than 15 minutes prior to moving such soil. On the last day of active operations prior to a weekend, holiday, or any other period when active operations will not occur for not more than four consecutive days, apply water with a mixture of chemical stabilizer diluted to not less than 1/20 of the concentration required to maintain a stabilized surface for a period of six months; or Apply chemical stabilizers prior to wind event, or Apply water to all unstabilized disturbed areas 3 times per day. If there is any evidence of wind driven fugitive dust, watering frequency is increased to a minimum of four times per day); or Establish a vegetative ground cover within 21 days after active operations have ceased. Ground cover must be of sufficient density to expose less than 30 percent of unstabilized ground within 90 days of planting, and at all time thereafter); or Utilize any combination of the three measures immediately preceding such that, in total, these actions apply to all disturbed surface areas. Apply chemical stabilizers prior to wind event, or apply water twice per hour during active operation, or stop all vehicular traffic. Apply water twice per hour, or install temporary coverings. Cover all haul vehicles, or comply with the vehicle freeboard requirements of Section 23114 of the California Vehicle Code for both pubic and private roads. During normal wind conditions (Le., with wind gusts less than 25 miles per hour), the sampling requirement does not apply so long as the following measures are implemented and appropriately documented: ~ Source Earthmoving (not for including construction lines, conduct cut and fill) Earthmoving areas (construction than fill areas) Earthmoving from (construction cut areas) Disturbed Surface Areas (except completed stabilized, grading areas) Disturbed Surface Areas Control Measure Maintain soil moisture content to a minimum of 12 percent when earthmoving, as necessary to prevent visible dust emissions from exceeding 100 feet in length in any direction. Maintain soil moisture content at a minimum of 12 percent. For soils that have an optimum moisture content for compaction of less than 12 percent, complete the compaction process as expeditiously as possible after achieving at least 70 percent of the optimum soil moisture content. Conduct watering as necessary to prevent visible emissions extending more than 100 feet beyond the active cut area unless the area is inaccessible to watering vehicles due to slope conditions or other safety factors. Apply dust suppression in sufficient quantity and frequency to maintain a stabilized surface. Any areas that cannot be stabilized as evidenced by wind driven fugitive dust, must have an application of water at least twice per day to at least 80 percent of the unstabilized area. Apply chemical stabilizers within five working days of grading completion; or apply water to at least 80 percent of all inactive surface areas on a daily basis when there is evidence of wind driven fugitive dust, except any areas which are inaccessible to watering vehicles due to excessive slope or other safety conditions; or establish a vegetative ground cover within 21 days after active operations have ceased. Ground cover must be of sufficient density to expose less than 30 percent of unstabilized ground within 90 days of planting, and at all times thereafter. General Plan Update and Associated Specific Plans EIR City of San Bernardino . Page 5.2-23 5. Environmental Analysis Source Inactive Disturbed Surface Areas Control Measure Apply water to at least 80 percent of all inactive disturbed areas on a daily basis when there is evidence of wind driven fugitive dust, except any areas which are inaccessible to watering vehicles due to excessive slope or other safety conditions; or apply dust suppressants in sufficient quantity and frequency to maintain a stabilized surface; or establish a vegetative ground cover within 21 days after active operations have ceased (ground cover must be of sufficient density to expose less than 30 percent of unstabilized ground within 90 days of planting, and at all times thereafter); or utilize any combination of the above three measures such that, in total, these actions apply to all inactive disturbed surface areas. Water all roads used for any vehicular traffic at least once per every two hours of active operations; or water all roads used for any vehicular traffic once daily and restrict vehicle speeds to 15 miles per hour; or apply a chemical stabilizer to all unpaved road surfaces in sufficient quantity and frequency to maintain a stabilized surface. Apply chemical stabilizers; or apply water to at least 80 percent of the surface area of all open storage piles on a daily basis when there is evidence of wind driven fugitive dust; or install temporary coverings; or install a three-sided enclosure with walls with no more than 50 percent porosity which extend, at a minimum, to the top of the pile. Unpaved Roads Open Storage Piles The SCAQMD recently adopted changes to Rule 403 that took effect January 1, 2005. As per the new requirements, no person shall conduct an active operation with a disturbed surface area of five or more acres or with a daily import or export of 100 cubic yards or more of bulk material without utilizing at least one measure at each vehicle egress from the site to a paved public road: A. Install a pad consisting of washed gravel (minimum-size: one inch) maintained in a clean condition to a depth of at least six inches and extending at least 30 feet wide and at least 50 feet long. B. Pave the surface extending at least 100 feet and at least 20 feet wide. Utilize a wheel shaker/wheel spreading device consisting of raised dividers (rails, pipe, or grates) at least 24 feet long and 10 feet wide to remove bulk material from tires and vehicle undercarriages before vehicles exit the site. C. Pave the surface extending at least 100 feet and at least 20 feet wide. Utilize a wheel shaker/wheel spreading device consisting of raised dividers (rails, pipe, or grates) at least 24 feet long and 10 feet wide to remove bulk material from tires and vehicle undercarriages before vehicles exit the site. D. Install and utilize a wheel washing system to remove bulk material from tires and vehicle undercarriages before vehicles exit the site. E. Any other control measures approved by the Executive Officer and the U.S. EPA. In addition to the above requirements the AQMD after January 1, 2005, large operators are required to install and maintain project signage with project contact signage that meets the minimum standards of the Rule 403 Implementation Handbook, prior to initiating any earthmoving activities. Furthermore, large operators must identify a dust control supervisor that: is employed by or contracted with the property owner or developer; is on the site or available on-site within 30 minutes during working hours; has the authority to expeditiously employ sufficient dust mitigation measures to ensure compliance with all Rule requirements; and has completed the AQMD Fugitive Dust Control Class and has been issued a valid Certificate of Completion for the class. Page 5.2-24 . The Planning Center July 2005 5. Environmental Analysis SCAQMD Rule 481: Rule 481 applies to spray coating operations. Under Rule 481, a person shall not use or operate any spray painting or spray coating equipment unless one of the following conditions is met: . The spray coating equipment is operated inside a control enclosure which is approved by the Executive Officer. Any control enclosure for which an application for permit for new construction, alteration, or change of ownership or location is submitted after the date of adoption of this rule shall be exhausted only through filters at a design face velocity not less than 100 feet per minute nor greater than 300 feet per minute, or through a water wash system designed to be equally effective for the purpose of air; . Coatings are applied with HVLP, electrostatic and/or airless spray equipment, or . An alternative method of coating application or control is used which has an effectiveness equal to or greater than the equipment specified in paragraph (c) (1) or (c) (2) of this rule. SCAQMD Rules 431.1 and 431,2: Require the use of low sulfur fuel for stationary construction equipment. Wastewater Treatment Plant Operations: The Arrowhead Springs wastewater treatment plant is subject to the rules and regulations imposed by the SCAQMD. As a new source, the proposed Arrowhead Springs wastewater treatment plant is required to obtain a permit for operation of a wastewater treatment plant by the SCAQMD. Under Regulation XIII, Rule 1303, for new source review, the wastewater treatment plant is required to install the Best Available Control Technology (BACT). In addition to review, under SCAQMD new source review, SCAQMD Rule 1179 requires small capacity publicly owned treatment plants to prepare a Facility Description Report to the District and a wastewater analysis report that provides the mass rate of VOCs present in the influent and effluent wastewater. The analysis shall include measurements for average and peak flow rates. ~ 5.2.5 Level of Significance Before Mitigation 5.2.5.1 San Bernardino General Plan Upon implementation of General Plan policies, regulatory requirements, and standard conditions of approval, the following impacts would be less than significant: GP Impact 5.2-1 Growth and buildout projections for the General Plan Update are less than the existing General Plan and therefore consistent with the AQMP. GP Impact 5.2-4 None of the intersections analyzed would have eight-hour CO concentration exceeding federal and State standards of 9 ppm or concentrations exceeding the one-hour CO concentration State standard of 20.0 ppm and federal standard of 35 ppm. Without mitigation the following impacts from implementation of the General Plan Update would be significant: GP Impact 5.2-2 The magnitude of General Plan buildout development and corresponding generation of air pollutant emissions would result in exceedance of the SCAQMD's construction and operational phase emissions thresholds. General Plan Update and Associated Specific Plans EIR City of San Bernardino . Page 5.2-25 5. Environmental Analysis GP Impact 5.2-3 Emissions associated with General Plan buildout would result in emissions which exceed the SCAQMD significance thresholds for construction and operational phases as stated in GP Impact 5.2-2. As such, the SCAQMD considers these emissions to be significant on a cumulative basis. The construction and operation through implementation of the General Plan would result in cumulative air quality impacts. 5.2.5.2 Arrowhead Springs Specific Plan Upon implementation of regulatory requirements, and standard conditions of approval, the following impacts would be less than significant: AHS Impact 5.2-1 AHS Impact 5.2-4 AHS Impact 5.2-5 Growth and buildout projections for the Arrowhead Springs Specific Plan project are included in the San Bernardino General Plan Update, which is consistent with the AQMP. The AQMP forms the basis for attainment of the AAQS. As a result, the project would not have the potential to temporarily delay the attainment of the AAQS. The traffic impacts from the build-out of the Arrowhead Springs Specific Plan were included within the traffic volumes of the General Plan update. None of the intersections analyzed would have eight-hour CO concentration exceeding federal and State standards of 9 ppm or concentrations exceeding the one-hour CO concentration State standard of 20.0 ppm and federal standard of 35 ppm. With the exception of the wastewater treatment plant, the Arrowhead Springs Specific Plan would not result in land uses that generate substantial levels of odors. The wastewater treatment plant would be required to comply with SCAQMD Rule 402 which prohibits the creation of public nuisances due to odors. As such, the Plant would incorporate odor control systems which capture and treatment foul air associated with the treatment process. Consequently, no significant air quality impacts would occur from the development of the Arrowhead Springs Specific Plan Without mitigation, implementation of the Arrowhead Springs Specific Plan project the following impacts would be significant: AHS Impact 5.2-2 AHS Impact 5.2-3 The magnitude of development and corresponding generation of air pollutant emissions would result in exceedance of the SCAQMD's construction and operational phase emissions thresholds for CO, ROG, NOx and PM10' Emissions associated with the Arrowhead Specific Plan would exceed the SCAQMD significance thresholds during construction and operational phases. As such, the SCAQMD considers these emissions to be significant on a cumulative basis. 5.2.6 Mitigation Measures 5.2.6.1 San Bernardino General Plan The proposed project is expected to generate emissions levels in exceedance of AQMD's threshold criteria for CO, ROG, NOx, and PM10 in the SoCAB, which is classified as a non-attainment area. Goals and Policies are contained in the General Plan would facilitate continued City cooperation with the SCAQMD and SCAG to achieve regional air quality improvement goals, promotion of energy conservation design and develop- ment techniques, encouragement of alternative transportation modes, and implementation of transportation Page 5.2-26 . The Planning Center July 2005 5. Environmental Analysis demand management strategies. In addition to these policies, the following mitigation measures shall be required to reduce air quality impacts: GP 5.2-2A Prior to the issuance of grading permits, the property owner/developer shall include a note on all grading plans which requires the construction contractor to implement following measures during grading. These measures shall also be discussed at the pregrade conference. . Use low emission mobile construction equipment. . Maintain construction equipment engines by keeping them tuned. . Utilize existing power sources (Le., power poles) when feasible. . Configure construction parking to minimize traffic interference. . Minimize obstruction of through-traffic lanes. When feasible, construction should be planned so that lane closures on existing streets are kept to a minimum. . Schedule construction operations affecting traffic for off-peak hours to minimize traffic congestion. . Develop a traffic plan to minimize traffic flow interference from construction activities (the plan may include advance public notice of routing, use of public transportation and satellite parking areas with a shuttle service). ~ GP 5.2-2B The City shall promote the use of low or zero VOC content architectural coatings for construction and maintenance activities. GP 5.2-2C The City shall reduce vehicle emissions caused by traffic congestion by imple- menting transportation systems management techniques that include synchronized traffic signals and limiting on-street parking. GP 5.2-2D The City shall consider the feasibility of diverting commercial truck traffic to off-peak periods to alleviate non-recurrent congestion as a means to improve roadway efficiency. GP 5.2-2E The City shall promote the use of fuel efficient vehicles such as fuel hybrids when purchasing vehicles for the City's vehicle fleet. GP 5.2-3 Implementation of mitigation measures GP 5.2-2A, B, C, D and E shall be applied to reduce cumulative impacts. 5.2.6.2 Arrowhead Springs Specific Plan AHS 5.2-2A The developer or project applicant shall use zero Volatile Organic Compounds (VOC) content architectural coatings during the construction of the project to the maximum extent feasible which would reduce VOC (ROG) emissions by 95 percent over convention architectural coatings. AHS 5.2-2B Prior to and/or during construction operations, the property owner/developer shall implement the following measures to further reduce fugitive dust emission to the General Plan Update and Associated Specific Plans EIR City of San Bernardino . Page 5.2-27 5. Environmental Analysis extent feasible. To assure compliance, the City shall verify that these measures have been implemented during normal construction site inspections: . Pave, gravel or apply nontoxic soil stabilizers on-site haul roads with 150 or more daily trips . Phase grading to prevent the susceptibility of large areas to erosion over extended periods of time . Schedule activities to minimize the amounts of exposed excavated soil during and after the end of work periods . Dispose of surplus excavated material in accordance with local ordinances and use sound engineering practices . Maintain a minimum of one-foot freeboard ratio on haul trucks or cover payloads on trucks hauling soil using tarps or other suitable means . Install adequate storm water control systems to prevent mud deposition onto paved areas. . Water active sites at least three times daily. AHS 5.2-3 Implementation of mitigation measures AHS 5.2-2A and AHS 5.2-2B shall be applied to reduce cumulative impacts. 5.2.7 Level of Significance after Mitigation 5.2.7.1 San Bernardino General Plan The policies contained in the proposed General Plan update are expected to reduce emissions associated with future development. However, even after the application of these policies and the mitigation measures listed above, implementation of the General Plan update when viewed as a whole project is expected to generate emissions levels in exceedance of AQMD's threshold criteria for CO, ROG, NOx, and PM10 in the SoCAB. General Plan Impact 5.2-2 and Impact 5.2-3 would remain significant resulting in an unavoidable adverse air quality impact due to the magnitude of emissions that would be generated during construction and operation. 5.2.7.2 Arrowhead Springs Specific Plan The mitigation measures identified above would reduce potential impacts associated with air quality to the extent feasible. Despite the application of mitigation measures implementation of the Arrowhead Springs Specific Plan, Impact 5.2-2 and Impact 5.2-3 were found to result in a significant unavoidable adverse air quality impact due to the magnitude of emissions that would be generated during construction and operation. The proposed project is expected to generate emissions levels in exceedance of AQMD's threshold criteria for CO, ROG, NOx, and PM10 in the SoCAB. Page 5.2-28 . The Planning Center July 2005