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

Air Quality Analysis

The Air Quality Analysis presented in the DEIR/EIS has been prepared following Caltrans’
standard format. The analysis addresses regional conformity, project-level conformity, the
potential for CO “hot spots”, a discussion of PM2.5/PM10, a discussion of naturally-occurring
asbestos, and a discussion of Mobile Source Air Toxics (MSATs). The following are specific
comments on the DEIR/EIS section.

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information cited in the section is outdated.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

2. Page 3.14-2: The Air Quality Section includes outdated information regarding the
attainment status of the air basin. The “basic” designation for attainment has been
overturned and the SDAB is in the process of being redesignated as a serious ozone
nonattainment area. This will have a direct bearing on how projects like the I-5 North
Coast Corridor project have been evaluated within the attainment demonstration
conducted by SANDAG and the SDAPCD. Furthermore, as shown in the MSAT
analysis, emissions of MSATs increase and emissions of criteria pollutants are also likely
to increase due to increased traffic with the project; this is not discussed in the analysis
and nothing has been provided to indicate how these increases are accounted for within
the SDAB given the pending redesignation.

3. Page 3.14-2: Table 3.14.1 shows out of date information on the ambient air quality
standards. One of the standards that is out of date is the newly adopted federal 1-hour
standard for NO2, which is lower than the current California state standard. Since on-
road traffic is the single largest contributor to NOx emissions within the San Diego Air
Basin (See: http://www.arb.ca.gov/app/emsinv/emseic1_query.php), it should be part of
the quantitative analysis to assess whether the project, which results in increased traffic
on the I-5 North Coast Corridor, would result in an exceedance of the new NO 2 standard,
resulting in a significant impact on air quality in the vicinity of the freeway. Because the
section relies on a Technical Study that was prepared three years ago, however, no
discussion has been provided regarding whether and how the project will comply with the
new NO2 standard. The USEPA has also adopted a new 1-hour SO2 standard. While it is
unlikely that traffic on I-5 would result in an exceedance of the SO 2 standard, the new
standard is not acknowledged in the document.

4. Recent studies show a link between childhood asthma incidence and exposure to
particulates, NOx, and black carbon generated from traffic. Given the potential
 association of these health effects with traffic emissions, the I-5 North Coast Corridor
study should have evaluated whether widening the road, and thus moving traffic and
emissions closer to sensitive receptors, would have the potential to result in increases in
health effects among the population.

5. Page 3.14-3: Tables 3.14.2 and 3.14.3 are out of date and do not reflect the current
attainment status of the air basin for ozone. Also, Table 3.14.3, which includes
“Exceedance in the Last 3 Years” only presents data for 2004 through 2006 and does not
present information on recent exceedances of air quality standards.

6. Page 3.14-5: The Air Quality section discusses PM10 and PM2.5, and indicates that a
qualitative hot spot analysis method that follows federal guidelines was prepared for the
project. The conclusion is reached that indicates that the project is not a Project of Air
Quality Concern. The analysis does not discuss potential exposure to ultra-fine
particulates, and does not address the effect of widening the freeway and moving traffic
closer to sensitive receptors. Ultrafine particles (particles with a diameter of less than 0.1
microns) were not addressed in the analysis; yet recent studies indicate that ultrafine
particles may be a source of health concern in populations located near traffic sources.

7. Page 3.14-6: The Air Quality Section indicates that PM10 and PM2.5 in the SDAB show a
general downward trend. The text states that concentrations of PM10 and PM2.5 from 2005
through 2008 are presented in Table 3.15.6 (sic); however, the table only shows data
from 2004 through 2006. When basin-wide PM10 and PM2.5 concentrations are plotted,
they do not show a clear downward trend. While it may be possible to argue that annual
PM2.5 concentrations may be trending downward, 24-hour concentrations of PM10 and
PM2.5 do not show a downward trend, and annual PM10 concentrations may be trending
higher.
Annual SDAB Concentrations of PM2.5 and PM10

Maximum 24-Hour Concentrations of PM2.5 and PM10

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

8. Given the concerns identified by the ARB regarding exposure of sensitive receptors to
particulate concentrations, and given studies indicating that freeway traffic may be a key
contributor to particulate concentrations, at a minimum, a quantitative analysis is
warranted. The ARB has released draft guidance in its Diesel Particulate Matter
Exposure Assessment Study for the Ports of Los Angeles and Long Beach (ARB 2006),
which recommends calculations of mortality and morbidity based on exposure to
particulate matter concentrations to provide a quantitative assessment of health effects.
Given that the project proposes to move traffic closer to receptors, a quantitative
assessment of PM impacts is warranted and should be conducted for the project.

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

10. Page 3.14-10: The Air Quality Analysis includes a qualitative discussion of construction
effects, but no attempt was made to quantify construction emissions and evaluate whether
construction activities (which would include earthmoving activities, heavy equipment,
and increases in truck traffic) would have a significant impact on air quality both locally
 and regionally. While Caltrans typically does not quantify emissions for projects that are
less than five years in duration, there is no such statement in the Air Quality section as to
duration of construction. Construction emissions could have a significant impact on
basin-wide air quality issues such as ozone and PM2.5. The statement that “These
emissions would be…limited to the immediate area surrounding the relocation site, and
therefore would not adversely affect air quality” does not address regional pollutant
impacts or the impacts of truck trips transporting construction materials to and from the
site. As this project is a major construction project extending through approximately half
of the coastal region of San Diego County and the SDAB, construction of a project of this
scale could have a significant impact on air quality in the region and should be analyzed.
It should be noted that construction emission estimates were provided in the Air Quality
Analysis; these emissions should have been discussed in the Draft EIR/EIS and
conclusions as to significance provided.

MSAT Analysis

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

It should be noted that the FHWA’s guidance on MSATs was updated on September 30, 2009.
The MSAT analysis followed the 2006 guidance, rather than the 2009 guidance. In the updated
guidance, the FHWA eliminated acetaldehyde from its list of pollutants with significant
contributions to risk, and added two new pollutants, naphthalene and polycyclic organic matter.
Neither of these pollutants has been addressed in the current MSAT analysis.

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

Furthermore, the MSAT analysis does not describe the effects of moving travel lanes, and
therefore emission sources, closer to sensitive receptors. The edge of travel lanes will be moved
anywhere from 48 to 73 feet closer to existing receptors in the City of Encinitas. It should also
be noted that truck traffic tends to utilize the slower lanes, which would be the closest to
receptors. No discussion of this has been provided in the MSAT analysis.
Specific comments on the MSAT analysis as presented in the Draft EIR/EIS follow.

1. Page 3.14-9 of the EIR that says the following: “Although the No Build Alternative is
expected to accommodate less traffic as indicated in Table 3-14.6, its MSAT emissions
are expected to be greater than those of other Build Alternatives in both 2015 and 2035.
The greater MSAT emission projected for the No Build Alternative, despite less traffic,
are attributable to the congested traffic conditions and breakdown of travel speeds during
peak periods.”

First, the tables are not referenced correctly in the text; the reference in the above
statement should be to Table 3.14.7, which shows the traffic activity for the I-5 North
Corridor project. Second, Tables 3.14.8 and 3.14.9, which present emissions associated
with the Build alternatives versus the No Build alternative, clearly show that emissions
for both Build alternatives increase over the No Build Alternative, in contradiction to the
statement made on Page 3.14-9 of the text. According to the data presented in the
analysis, the No Build Alternative’s MSAT emissions are projected to be lower than the
Build alternatives.

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

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

has released a health risk assessment model that allows for the prediction of health effects
from toxic air contaminants, in its HotSpots Analysis and Reporting Program (HARP).
The HARP model has been used to assess potential impacts from traffic on roadways in a
number of studies. Furthermore, the South Coast Air Quality Management District
(SCAQMD) has issued guidance on addressing risks from diesel particulate matter in its
Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source
Diesel Idling Emissions for CEQA Air Quality Analysis (SCAQMD 2003), in which they
provide recommendations for addressing diesel emissions from trucks on roadways and
streets. Contrary to the statements in the Draft EIR/EIS, these tools are available and
could have been used to estimate the health effects from MSAT emissions.

3. The MSAT analysis does not describe the effects of moving travel lanes, and therefore
emission sources, closer to sensitive receptors. The edge of travel lanes will be moved
anywhere from 48 to 73 feet closer to existing receptors in the City of Encinitas. It
should also be noted that truck traffic, which is the major source of diesel particulate
matter, tends to utilize the slower lanes, which would be the closest to receptors.
Specific comments on the Draft Air Quality Analysis and the Mobile Source Air Toxics
Analysis, which were provided as appendices to the Draft EIR/EIS, are provided below.

Draft Air Quality Analysis

1. Pages 1 and 24: The Air Quality Analysis, which was written in August 2007, contains
outdated information regarding the attainment status of the SDAB. The SDAB is no
longer classified as a “basic” nonattainment area; the “basic” designation has been
rescinded by EPA. The SDAPCD is in the process of redesignating the SDAB as a
serious ozone nonattainment area, which will require further analysis of projects such as
the I-5 North Coast Corridor Project to ascertain its impacts on ozone attainment.

2. Page 16: While ultra-fine particulates are not currently regulated by the U.S. EPA as a
criteria pollutant, recent studies indicate that adverse health effects are associated with
exposure to ultra-fine particulates, and specifically ultra-fine particulates from roadways.
Some discussion of ultra-fine particulates is warranted in the Air Quality Analysis.

3. Page 16: The Air Quality Analysis states “No standards exist for quantitative impact
analysis for diesel particulates. Some air districts have issued preliminary project
guidance for projects with large or concentrated numbers of trucks, such as warehouses
and distribution facilities.” Most air quality regulatory agencies are requiring quantitative
impact analyses for diesel particulates for projects under CEQA. In 1994, the State of
California identified diesel particulate matter as a toxic air contaminant, and identified a
cancer slope factor and reference exposure level that allows a quantitative evaluation of
impacts from diesel particulates. Standards therefore do exist under the California AB
2588 Air Toxics Hot Spots Information and Assessment Act which set forth toxicity
factors and methodologies to assess potential risks of exposure to diesel particulate
matter.

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

5. Page 24: The Air Quality Analysis states that ambient air quality measurements from the
San Diego Beardsley Street monitoring station were used to represent background air
quality. Data are presented for the period from 2004 to 2006. No analysis was presented
showing data from the Del Mar-Mira Costa monitoring station or the Camp Pendleton
monitoring station, which are located closer to the project area. Furthermore, no
discussion was provided as to why the Beardsley data are considered representative of
conditions along the I-5 North Coast Corridor. Some discussion is warranted to give a
perspective on whether these data best and most accurately represent current conditions
in the project area. Furthermore, the data should be updated to include recent
measurements, especially in light of adoption of new ambient air quality standards.
6. Page 25: Table 4 is out of date, both in the presentation of ambient monitoring data, and
in the listing of ambient air quality standards. The 1-hour O 3 NAAQS has been
rescinded, a new 8-hour O3 NAAQS of 0.075 ppm and a new 8-hour O3 CAAQS of 0.070
ppm have been adopted; a new 1-hour NO2 NAAQS of 0.100 ppm has been adopted; the
24-hour PM2.5 NAAQS is 35 µg/m3; and the annual and 24-hour NAAQS for SO2 have
been rescinded and replace with a new 1-hour NAAQS for SO2 of 0.075 ppm. None of
these changes are reflected in the table and the data provided as background data do not
give an accurate representation of current conditions within the region.

7. Page 30: The statement is made that “The proposed project would not generate traffic
but would accommodate future traffic volumes by providing increased efficiency via
expanded capacity. Therefore, it may be presumed that the project would not measurably
increase traffic volume or the percentage of vehicles in cold start mode.” However, the
MSAT analysis (Table A, Page 5) clearly shows that traffic volumes would measurably
increase with the project; peak hour VMT is more than doubled from the No Build
alternative with Alternative 2, and average daily VMT is 8% higher with Alternative 2
than under the No Build Alternative. As stated on Page 29 of the Air Quality Analysis, a
substantial increase in traffic volumes is defined as “an increase in volumes in excess of 5
percent.” Thus it appears that the project does measurably increase traffic volumes;
impacts from this increase in traffic volumes should be evaluated in the Air Quality
Analysis.

8. Page 31: The Air Quality Analysis states that “the SDAB is not federally designated as a
PM2.5 or PM10 nonattainment or maintenance area; thus, the project does not require a
PM2.5 or PM10 conformity analysis.” While the SDAB is not a federally designated
nonattainment area for PM2.5 and PM10, it is a state nonattainment area for these
pollutants. Potential impacts from PM2.5 and PM10 emissions associated with the project
must be addressed under CEQA, whether or not the project is designed as a federal
nonattainment area. Further analysis of this issue is warranted, especially given the
increases in VMT identified in the MSAT analysis.

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

1. Page 1: The MSAT Analysis, which was written as a technical addendum to the Air
Quality Analysis in June 2008, follows 2006 MSAT guidance from the FHWA which has
since been revised. In the updated guidance, the FHWA eliminated acetaldehyde from
its list of pollutants with significant contributions to risk, and added two new pollutants,
naphthalene and polycyclic organic matter. Neither of these pollutants has been
addressed in the current MSAT analysis.

2. Page 2: The MSAT Analysis acknowledges that the project warrants a quantitative
analysis. The only analysis that has been conducted is to run the CT-EMFAC model, and
present differences in emissions between alternatives. However, no analysis of the
impact of moving traffic lanes closer to receptor has been provided.

3. Page 6: Table B reports emissions for “Carolina”. We presume this is “acrolein”, but
should be corrected in the table.

4. Page 12: The report states “Differences in MSAT emissions among the proposed
alternatives are noted in Tables B and C. The “Build” Alternatives result in higher VMT
and emissions when compared to the No Build Alternatives. However the “Build”
Alternatives substantially relieve congestion with average peak period speed increments
from the No Build Alternatives ranging from 85 to 103 percent for the operational year
and 101 to 180 percent for the horizon year.” Please clarify why this statement
contradicts information provided in the tables and text, which indicate the Build
alternatives would result in higher MSAT emissions, despite reducing congestion. The
report goes on to state that “Project-specific health impacts cannot be predicted with
available technical tools.” This statement ignores the technical models that are available
and used regularly to predict downwind concentrations of MSATs, and technical models
that are available to predict health effects (such as HARP) from exposure to these
concentrations of MSATs.

5. Page 13: The report provides a discussion on why the FHWA concluded that the
technical tools available for dispersion modeling are limited; however, the project is also
subject to CEQA, and state and local agencies in California regularly use dispersion
modeling techniques and approaches to predict health effects from mobile sources. In
their MATES Studies, the SCAQMD used AERMOD to analyze potential health effects
from on-road sources. The analysis should therefore have included an evaluation of
potential impacts from MSATs in accordance with CEQA.